Exposure routes

• The most common exposure route is inhalation, but others include skin/eye contact, ingestion, and injection via puncture wounds.

Inhalation

One important exposure route is inhalation. The majority of toxic substances enter the body through breathing. That’s because the lungs are extremely vulnerable to chemical agents. Even substances that do not directly affect the lungs may pass through lung tissue into the bloodstream, where they are transported to other vulnerable areas of the body.

Some toxic chemicals present in the atmosphere may not be detected by human senses — they may be colorless and odorless, and their toxic effects may not produce any immediate symptoms. Respiratory protection is therefore extremely important if there is a possibility that the worksite atmosphere may contain such hazardous substances.

Chemicals can also enter the respiratory tract through punctured eardrums. Where this is a hazard, workers with punctured eardrums should be medically evaluated to determine if this condition would place them at unacceptable risk and preclude their working at the task in question.

Skin/Eye contact

Direct contact of the skin and eyes with hazardous substances is another important route of exposure. Some chemicals directly injure the skin. Some pass through the skin into the bloodstream, where they are transported to vulnerable organs. Skin absorption is enhanced by abrasions, cuts, heat, and moisture.

The eye is particularly vulnerable because airborne chemicals can dissolve in its moist surface and be carried to the rest of the body through the bloodstream (capillaries are very close to the surface of the eye). Wearing protective equipment, not using contact lenses in contaminated atmospheres (since they may trap chemicals against the eye surface), keeping hands away from the face, and minimizing contact with liquid and solid chemicals can help protect workers against skin and eye contact.

Ingestion

Although ingestion should be the least significant route of exposure, it is important to be aware of how this type of exposure can occur. Deliberate ingestion of chemicals is unlikely. However, personal habits such as chewing gum or tobacco, drinking, eating, smoking cigarettes, or applying cosmetics on the jobsite may provide a route of entry for chemicals.

Injection

The last primary route of chemical exposure is injection, whereby chemicals are introduced into the body through puncture wounds (for example, by stepping or tripping and falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical hazards, and taking common-sense precautions are important protective measures against injection.

Organizational structure

• The organizational structure of the safety and health program establishes the chain of command and shows lines of authority, responsibility, and communication.

The organizational structure defines clear roles and responsibilities of personnel, and it establishes a specific chain of command within the organization. Key roles to be identified include:

• A general supervisor with the authority to direct activity;
• A site safety and health supervisor who has the responsibility and authority to develop and implement the site-specific safety and health plan and verify its compliance; and
• Other personnel needed for operations and emergency response, along with their duties.

Naming key personnel with their roles and titles in the organizational structure part of the program helps establish the chain of command. The structure shows lines of authority, responsibility, and communication between personnel and managers. In addition, it should identify how to communicate with response personnel.

The organizational structure must be kept current, meaning it must reflect the current status of a site’s operations.

The size of each operation will vary from site to site; therefore, the number and titles of personnel will also vary. The personnel who are essential at a safe hazardous waste cleanup site include:

• Senior management
• Project team leader
• Field team leader
• Command post supervisor
• Decontamination station workers
• Rescue team
• Site safety and health officer
• Work teams

Other personnel who may be present at a hazardous waste cleanup site include, but are not limited to:

• Bomb squad experts
• Communications experts
• Environmental scientists
• Health physicist
• Industrial hygienists
• Toxicologists

A strong commitment and good attitude toward safety is important from the beginning and for all levels of personnel, including management. Other organizational factors that contribute to successful safety and health programs include:

• Open communication,
• Good housekeeping and orderly work conditions,
• Careful selection of personnel and job placement,
• Advancement procedures and other employee support services,
• Training in safety topics,
• Effective safety practices, and
• A disciplinary plan to ensure adherence to safety practices.

Comprehensive work plan

• The comprehensive work plan in the safety and health program lays out the anticipated tasks and objectives with what’s required to achieve them.

Planning is the key element in a hazardous waste control program. Proper planning will greatly reduce worker hazards at waste sites.

Before work commences, the comprehensive work plan must be established. This plan describes the anticipated tasks and objectives of site operations, along with the logistics and resources required to accomplish them.

Specifically, the work plan must:

• Address anticipated cleanup activities and normal operating procedures,
• Define work tasks and objectives,
• Identify how to accomplish work tasks and objectives,
• Establish how many personnel are required to implement the work plan,
• Provide for the implementation of required training and information, and
• Provide for the implementation of required medical surveillance.

Items to consider when developing a comprehensive work plan include:

• Site records,
• Waste inventories,
• Hazardous waste manifests,
• Previous sampling and monitoring data,
• Site photos,
• State and local environmental and health agency records, and
• Input from all levels of personnel and possibly consultants.

The work plan should support the overall objectives of the control program and provide standard operating procedures (SOPs) for implementation. The plan should incorporate the employer’s standard operating procedures for safety and health and should also include necessary coordination between the general program and site-specific activities.

Site-specific safety and health plan

• The site-specific safety and health plan is an element of the larger safety and health program with the purpose of addressing the safety and health hazards of each phase of site operation.
• Pre-entry briefings and periodic inspections work in concert with the plan to ensure continuing compliance with and effectiveness of the plan.

The site-specific safety and health plan (sometimes referred to as the site-specific HASP, for “health and safety plan”) aids in eliminating or effectively controlling anticipated safety and health hazards. The plan must identify the hazards of each phase of the specific site operation and must be kept on the worksite.

The plan needs to include all the basic requirements of the overall safety and health program, but with attention to those characteristics unique to the site. For example, it may outline confined space entry procedures, air and personal monitoring and environmental sampling, and a spill containment program to address the particular hazards present at the site.

Plan basics

The site-specific safety plan establishes policies and procedures to protect workers and the public from any potential hazards at a specific site. It must be kept onsite.

The plan is intended to minimize accidents and injuries during normal activity and adverse conditions like extreme temperatures. The information used to develop the plan (and revise the plan as new data or information is obtained) comes from the site characterization, which consists of three phases:

1. A preliminary evaluation
2. An initial site entry
3. Ongoing evaluations

The plan should be developed by both onsite and offsite management, and it’s a good idea to have it reviewed by experts such as health physicists, chemists, and toxicologists.

Plan elements

Some of the elements (like training and medical surveillance) in the site-specific safety and health plan are also elements of the overall safety and health program. However, while the program addresses overall issues, the plan addresses site-specific concerns. It includes the following elements:

• A hazard or risk analysis for each task and operation performed onsite found in the comprehensive work plan;
• Confirmation that personnel have received proper training to perform their assigned tasks;
• The personal protective equipment (PPE) to be used by workers for each task and operation performed onsite;
• A description of site-specific medical surveillance requirements;
• Types of monitoring and sampling to be performed onsite, including instruments (and their maintenance and calibration), methods, and frequency;
• Site control measures under a site control program;
• Decontamination procedures;
• The emergency response plan or emergency action plan, whichever is applicable;
• Confined space entry procedures; and
• The spill containment program.

Pre-entry briefings

As a supplement to the plan, pre-entry briefings and safety meetings help to promote a safety-conscious work environment and apprise employees of the site-specific safety and health plan. These briefings should be conducted by the site safety officer or other informed, knowledgeable individual and may be held:

• Prior to site activity, and
• Any time new activities or changing conditions warrant it.

Safety meetings may also be held each day to ensure workers stay informed about safety expectations.

The purpose of briefings and safety meetings is to convey safety and health information and keep employees focused on safety and health. Topics they might address include:

• The tasks to be performed and any associated hazards associated,
• The coordination of activities,
• Methods and precautions to prevent injury and illness,
• Emergency plans,
• Changes to the site-specific plan,
• New conditions or information, and
• Worker feedback on work conditions and the plan’s effectiveness.

Inspections

Inspections also help ensure the effectiveness of the site-specific safety and health plan. It’s important to inspect site conditions, facilities, equipment, and activities because conditions can change quickly with site activity, degradation of containers, equipment maintenance, and weather.

Inspections should be conducted by the site safety and health supervisor, or, in the absence of that individual, another person who is knowledgeable in occupational safety and health. When conducting inspections, employers should:

• Use a checklist of items to inspect,
• Review inspection results with supervisors and workers,
• Reinspect identified issues to ensure they have been addressed,
• Document all inspections and corrective actions, and
• Retain inspection records.

Employers are responsible for correcting any deficiencies found in the site plan.

The frequency of inspections depends on the characteristics of the site and equipment. Things to consider:

• The severity of onsite risks;
• Regulations;
• Operation and maintenance requirements;
• The expected lifetime of equipment; and
• Professional judgment, lab tests, and field experience.

Safety and health training program

• Employees need to be trained in safety and health information and procedures applicable to their job duties before they do any work that might expose them to hazards.

Safety and health training is the program element that describes the training provided to general site employees. This training should be applicable to the work that employees will perform and consist of both classroom training and field experience under the direct supervision of a trained, experienced supervisor.

Employees must receive training before they are permitted to engage in hazardous waste operations that could expose them to hazardous substances, health hazards, or safety hazards.

General site employees are required to have initial training of at least 40 hours of classroom training and an additional three days of field experience. However, they may be able to bypass initial training if they received equivalent training (or work experience) somewhere else and have certification or documentation of the training (or work experience). In this case, they would still be required to have site-specific training before site entry, followed by appropriate supervised field experience at the new site.

Any employees who will be responding to hazardous emergency situations that may expose them to hazardous substances must also be trained in how to respond to expected emergencies.

Annual refresher training of at least eight hours is also required. Employees who fail to successfully complete this training must be prohibited from performing their duties.

The safety and health training program must address:

• Names of personnel and alternates responsible for site safety and health,
• Any hazards that are present onsite,
• The proper use of personal protective equipment (PPE),
• Work practices to minimize risks,
• Safe use of engineering controls and equipment,
• Decontamination procedures,
• The emergency response plan,
• Confined space entry procedures,
• The spill containment program, and
• Medical surveillance requirements.

More topics that may be included in the training program include:

• Biology, chemistry, and physics of hazardous materials;
• Toxicology;
• Industrial hygiene;
• Employee rights;
• Monitoring and sampling;
• Hazard evaluation;
• Selection and care of PPE and chemical protective clothing (CPC);
• The site-specific safety and health plan;
• Standard operating procedures (SOPs); and
• Applicable regulations.

Medical surveillance program

• The medical surveillance component of the safety and health program provides for monitoring of the health of employees whose work puts them at high risk for illness.

Another required element of the safety and health program is the medical surveillance program. While much attention is focused on safety hazards, health hazards are also a real concern at hazardous waste cleanup sites.

One of the biggest health hazards is exposure to hazardous substances. It’s possible to be exposed to a hazardous substance and not even know it because some substances are odorless and colorless. Employees exposed can have no indication of its presence until they start feeling the effects of exposure, and the effects from some substances might not show up right away.

Because employees working around hazardous substances may be at high risk of illness, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires employers to provide initial and regular medical exams in addition to any needed medical attention. Five types of exams offered in the medical surveillance program include:

• A pre-assignment exam
• Periodic exams
• A termination exam
• Post-illness or -injury exams
• Follow-up exams

The purpose of the medical surveillance program is to:

• Establish employees’ baseline medical condition,
• Assess fitness for duty,
• Document exposures and medical conditions,
• Detect and eliminate hazards, and
• Ensure emergency and non-emergency treatment is provided.

Standard operating procedures (SOPs)

• Employees should be trained in relevant SOPs — procedures for activities that can be standardized — prior to using them in the field.

As part of the safety and health program, the Occupational Safety and Health Administration (OSHA) requires employers to have written procedures for safe work practices. These standard operating procedures (SOPs) are used for activities that can be standardized. Some examples include:

• Decontamination
• Confined space entry
• Respirator fit tests
• Spill control
• Emergency response

SOPs should be easy to understand; prepared in advance; and based on available information, operational principles, and technical guidance. In addition, they should be field tested and should be revised as necessary.

Employees should receive training on specific SOPs needed to perform their duties and should be encouraged to review them prior to using them in the field. This will ensure they understand all the steps involved in the tasks and are able to gather and prepare any equipment they may need.

Cleanup site hazards

• Workers at hazardous waste cleanup sites may be unable to avoid encountering a vast array of hazards, both chemical and physical.

An uncontrolled hazardous waste site means any site identified by the government where an accumulation of hazardous substances creates a threat to the health and safety of individuals, the environment, or both.

It may be impossible for hazardous waste cleanup site employees to avoid hazards. That’s because cleanup operations involve handling and processing hazardous substances to remove, contain, incinerate, neutralize, clear up, or stabilize them. The ultimate goal of a cleanup operation is to make the site safer for people and the environment.

Employees at a hazardous waste site might face both chemical and non-chemical health and physical hazards. The Occupational Safety and Health Administration (OSHA) considers a chemical to be a health hazard if it:

• Is toxic
• Is corrosive
• Irritates the skin or eyes
• Is a respiratory or skin sensitizer
• Causes cells to mutate
• Causes cancer, birth defects, or reproductive issues
• Damages organs
• Displaces (and thus deprives the employee of) oxygen
• Is harmful or deadly if inhaled

Some chemicals can inflict physical damage when they react with the environment or other chemicals. The types of chemicals that can present physical hazards include:

• Flammables
• Explosives
• Oxidizers
• Self-reactive substances
• Pyrophoric gases, liquids, and solids
• Chemicals that emit flammable gas when in contact with water
• Self-heating substances
• Organic peroxides
• Corrosive metals
• Combustible dusts
• Gases under pressure

Chemicals are not the only health and physical hazards employees may be exposed to. Other health hazards include:

• Radiation (both ionizing and non-ionizing)
• Biological hazards
• Heat stress
• Cold temperatures
• Ergonomics issues
• Noise
• Psychological impacts

Some other physical hazards employees may encounter include:

• Electrical hazards
• Confined spaces
• Equipment and tool hazards
• Falling objects
• Weather-related hazards like storms and lightning

More physical hazards that employees should be aware of as they move around onsite and perform their work activities include:

• Holes, ditches, steep terrain, or uneven ground;
• Slippery surfaces from rain or spills;
• Sharp objects, such as nails, metal shards, and broken glass;
• Precariously placed objects like drums or boards that may fall;
• Unstable surfaces that may cave in or give way;
• Heights from which an employee may fall; and
• Tripping hazards.

Many hazards can also pose a threat to property and the environment. Chemical fires and explosions, for instance, can damage buildings, infrastructures, power sources, and technology.

Hazardous substances can seep into groundwater, ponds, and other bodies of water, killing off entire fish populations. In fact, the environment is very susceptible to hazardous substances. That’s because the air, land, water, vegetation, and wildlife all interact with each other. Damaging one may affect the others.

Preliminary evaluation

• During the preliminary evaluation stage of site characterization, the site is evaluated without entry using interviews, records, sampling, and perimeter observations.

It’s important to have information about site hazards before anyone sets foot on a site, so that employers can make informed decisions about how to protect entry personnel.

During the first stage of site characterization — the preliminary evaluation — no one sets foot on the site. It’s all done offsite by a qualified person. (In fact, the preliminary evaluation is also referred to as an “offsite characterization.”)

The preliminary evaluation starts with conducting interviews and researching records.

Interviews should be with people who have knowledge about the site, such as former employees and their families or nearby residents. However, any information obtained through interviews must be verified.

Records, too, may turn up site information. Examples include:

• Company records
• Receipts
• Workers’ compensation claims
• Logbooks
• Media reports
• Historical and current aerial photos
• Fire and police records
• Land surveying records
• Shipping papers
• Water and sewage records

Next, air monitoring should be performed along the perimeter of the site to test concentrations of airborne contaminants. The perimeter should be monitored for:

• Toxic substances
• Flammable or combustible gases or vapors
• Oxygen deficiency
• Ionizing radiation
• Specific substances that are known or suspected

Also, visual observations should be performed from the perimeter of the site. Things to look for include, but are not limited to:

• Unusual odors;
• Unusual conditions, such as vapor clouds, smoke, discolored liquids, oil slicks, or other suspicious substances;
• Labels, markings, or placards on containers or vehicles;
• Deterioration or damage of containers or vehicles;
• Changes in vegetation, and
• Changes in ground surfaces, such as mounding, depressions, and pits.

In addition, samples are usually collected and analyzed from offsite areas. A qualified person should take samples of the soil, surface water, site runoff, groundwater, and drinking water sources.

The Occupational Safety and Health Administration (OSHA) requires employers to obtain information prior to site entry that includes:

• The location and approximate size of the site;
• A description of the response activity and/or the job task to be performed;
• The duration of the planned employee activity;
• Site topography and accessibility by air and roads;
• Safety and health hazards expected at the site, including conditions that may cause death or serious harm;
• Pathways for hazardous substance dispersion;
• The availability and capabilities of emergency response teams;
• Hazardous substances involved or expected at the site and their chemical and physical properties;
• Inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH);
• Confined spaces;
• Potentially flammable or explosive situations;
• Visible vapor clouds; and
• Biological indicators, such as dead animals or vegetation.

The employer should use all the information collected during the preliminary evaluation to determine what control measures to take to keep the initial site entry team safe during entry activities. For example, engineering controls like ventilation or wet methods may be needed. Respiratory protection is another type of control method an employer might require for entry.

Initial site entry

• During the initial site entry phase of site characterization, a team of personnel in appropriate protective gear enters the site to make observations and take samples.

The second stage of site characterization is initial site entry. The purpose of this stage is to:

• Verify the information gathered in the preliminary evaluation, and
• Gather additional information.

No matter how thorough the preliminary evaluation is, there are always potential unknowns during an initial site entry. For that reason, a minimum of a Level B ensemble for protective clothing and equipment is highly recommended. A Level A ensemble must be worn for certain activities or if immediately dangerous to life or health (IDLH) conditions are expected.

The level of protective equipment and clothing worn during an initial site entry must be decided based on the results of the preliminary site evaluation. It must provide enough protection to keep exposure below permissible exposure limits (PELs) or published exposure levels.

If a positive-pressure self-contained breathing apparatus (SCBA) is not part of the entry ensemble but respiratory protection is necessary, then site entry personnel must carry escape SCBAs with at least five minutes of air.

If the preliminary site evaluation does not produce enough information to identify the hazards that may be present, then the team must wear at least a Level B ensemble for the initial site entry.

An initial site entry team should consist of a minimum of four personnel, and the buddy system must always be used — at least two employees enter the site, and at least two more employees wear the same (or higher) ensemble level as the entry employees but remain outside the site, ready to provide support in case of an emergency.

If the preliminary evaluation is insufficient or indicates the potential for ionizing radiation or IDLH conditions, one of the tasks of initial entry employees is to monitor the air and make visual observations to confirm site conditions. In this situation, the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires the use of direct-reading instruments, such as combustible gas meters and detector tubes, to check for:

• Hazardous levels of ionizing radiation,
• Any IDLH conditions, and
• Other conditions that may cause death or serious harm (such as combustible, explosive, or oxygen-deficient atmospheres or toxic substances).

The standard also calls for visual observations for actual or potential IDLH or other dangerous conditions like enclosed spaces that must be entered, bulging drums, or open patches with dead vegetation.

If deadly or serious hazards are indicated, initial entry employees should proceed with extreme caution. It may be necessary to regroup and take extra precautions before continuing.

The other main task of initial entry employees is to gather additional information, such as:

• The types of containers and storage systems;
• Any containers in damaged, corroded, leaking, or unsound condition;
• The quantities and physical states of materials (such as gases, liquids, or solids);
• Potential exposure indicators, such as dead fish, an oily sheen on water surfaces, dust in the air, and pools of liquid;
• Any safety hazards like unstable terrain and deteriorating structures;
• Land features and natural wind barriers;
• The presence of poisonous plants; and
• Any signs, labels, tags, or other identifying markings.

Finally, when gathering additional information, workers will:

Collect samples from the air, soil, pools of liquids, storage containers, ditches, streams, and groundwater; and

Use non-invasive methods like metal detection or radar to locate buried wastes.

After the initial site entry is completed, all the new information must be analyzed by a qualified person prior to starting operations onsite. This analysis will ensure employees are aware of:

• Specific hazardous substances onsite and their concentration levels,
• Any other health hazards that are present at the site, and
• Any other physical hazards that are present at the site.

Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances must be identified. Some risks that must be considered include:

• Exposures exceeding the PELs and published exposure levels,
• IDLH concentrations,
• Potential skin absorption and irritation sources,
• Potential eye irritation sources,
• Explosion sensitivity and flammability ranges, and
• Oxygen deficiency.

Before work begins onsite, the employer must make available to employees information concerning any identified risks and the properties of each hazardous substance present or anticipated at the site, if those substances are relevant to the duties workers are expected to perform. The employer may use the Hazard Communication (HazCom) Program for this purpose.

Ongoing evaluation

• During the ongoing evaluation phase of the site characterization process, air monitoring and workers’ observations keep track of any changes in conditions.

Once the initial site entry has been made and conditions analyzed, and it is determined the site is safe to start cleanup operations, appropriate engineering controls and personal protective equipment (PPE) must be selected and used for the tasks to be performed.

However, site characterization and analysis does not end there. Ongoing air monitoring must be implemented to provide information about any changes in conditions. Also, employees should be instructed to note any changes or new information and to immediately report to their supervisor anything different or unusual.

Site control program elements

• The site control program must establish a site map, work zones, a buddy system, communications methods, safe work practices, and medical assistance procedures.

The elements of the site control program are as follows:

• Site map
• Site work zones
• Buddy system
• Communications
• Safe work practices
• Medical assistance

Site map

Site maps are created to show topographic features; prevailing wind direction; drainage patterns; hazards present; and locations of buildings, containers, pits, ponds, and tanks. Activities in which a site map can be helpful include:

• Planning projects and work activities;
• Assigning personnel;
• Establishing access routes, evacuation routes, and problem areas;
• Determining areas that require the use of personal protective equipment (PPE); and
• Supplementing daily safety meetings.

An initial site map should be prepared before site entry and updated regularly to show:

• Changes in site activities and operations,
• Any onsite accidents or emergencies,
• New hazards that are discovered,
• New materials that are introduced,
• Unauthorized entry or incidents of vandalism, and
• Changes to weather patterns.

To show information without cluttering the map, overlays may be useful.

Site work zones

Refer to the More about site work zones section found elsewhere in this subject to learn about the three typical work zones at a site.

Buddy system

Workers in the Exclusion Zone (EZ) or any other hazardous areas must use the buddy system. When using the buddy system, employees are expected to:

• Provide each other with assistance,
• Observe each other for signs or symptoms of illness or injury,
• Verify the integrity of one another’s PPE, and
• Notify the Command Post Supervisor or others if an emergency develops.

Buddies enter the EZ through the access control point and must stay near to and in line of sight of each other, while in the EZ.

Communications

Two types of communications are needed for site control:

• For internal communication between onsite employees, and
• For external communication between onsite employees and offsite personnel.

Site personnel should be aware of the expectations for both internal and external communications.

Internal communication is used to inform workers of an emergency, to update personnel on safety information or changes in the work scope, and to help maintain control of the site. Both a primary and a backup means of internal communication should be set up and understood by all employees. It’s a good idea to establish a set of signals to be used only in emergencies.

Note that any communications used in potentially explosive atmospheres must be intrinsically safe.

Audible internal communications might include two-way radios, bells, whistles, sirens, megaphones, or an air horn. These communication methods could be impeded by background noise, respirators, and hoods. Therefore, when audible communication is difficult or impossible, visual communications might be preferred, such as hand signals, whole-body movements, lights, flares, or flags. In fact, flags also work great at providing visual awareness of workers in areas of poor visibility.

To allow them to identify each other, employees should mark their names on their protective clothing. Color-coding, numbers, or symbols can be added for long-distance identification.

Communication devices should be checked daily to ensure they are working properly.

Telephones (including landlines and cellphones) and radios are the primary means of external communication. A list of important phone numbers should be kept readily available. Site personnel may need to communicate externally to:

• Coordinate emergency response efforts,
• Report to management, and
• Maintain contact with essential offsite personnel.

Medical assistance

The site manager should maintain and post the identification and location of the nearest medical facilities. This critical information should be posted near phones or other external communication devices.

Posted information may include names; addresses; phone numbers; maps; directions; and procedures for contacting the nearest area hospitals/clinics and emergency ambulance, fire, and police.

Before work commences at the site, staff at nearby medical facilities should be made aware of the types of activities that take place onsite and the hazards that are present.

Other recommended program elements

• Site preparation and site security are useful to include in a site control program to ensure the safety of the site and those around it.

The site control program is not required to contain these elements, but they are recommended:

• Site preparation
• Site security

Site preparation

A lot of work goes into getting a site ready for daily cleanup activities. Dangers can be present during these preparations, so safety and protective measures are important.

During site preparation, roadways may need to be constructed. Whether sufficient roadways exist or not, traffic signs are installed to safely direct the flow of heavy equipment and vehicle traffic.

Efforts should then be made to remove as many hazards as possible. Steps that can be taken to eliminate hazards include:

• Ensuring no ignition sources exist in flammable areas.
• Working with the Site Safety Officer and local utility company to remove or fix any exposed, ungrounded, or low-hanging power lines or electrical wires. Only properly trained and qualified persons may handle electrical hazards.
• Removing or guarding any sharp or protruding objects.
• Addressing any slip, trip, or fall hazards, such as loose stair treads, unsecured railings, debris, and holes.
• Securing or removing objects on elevated surfaces, such as catwalks, rooftops, and scaffolding.
• Removing any debris that obstructs visibility.
• Installing skid-resistant strips or devices on slippery surface areas.

Other site preparations may include:

• Constructing foundations for temporary structures, mobile facilities, and decontamination areas.
• Constructing loading docks, processing areas, and staging areas.
• Installing any wiring or electrical equipment required according to code.
• Installing adequate lighting for performing work activities effectively and safely in all work areas.

If temporary lighting is installed, protective guarding around the lighting should be put in place to prevent breakage from accidental contact with it.

Site security

Site security is a site control plan element because it helps to:

• Prevent unauthorized and unprotected people from exposure to hazards onsite;
• Avoid vandalism, theft, and abandoned wastes; and
• Avoid interference with safe work procedures.

In addition to manned access control points, a hazardous waste cleanup site may implement several different controls for maintaining site security. Other security measures that can be taken include:

• Erecting fencing or other physical barriers and warning signs around the perimeter of the site.
• Using security guards to patrol the perimeter.
• Establishing an identification system including log-in procedures to quickly distinguish between authorized and unauthorized persons.
• Adopting a policy requiring visitors to have a valid reason to be onsite, approval for their visit, and a trained site employee to escort them.
• Assigning trained site employees for site surveillance.
• Enlisting help from local police departments if there is a threat to the surrounding community.
• Securing all equipment.

More about site work zones

• The three work zones, from most to least dangerous, are the Exclusion Zone (or hot zone), the Contamination Reduction Zone, and the Support Zone (or cold zone).
• The Support Zone should have no danger of contamination.

Setting up work zones onsite, another element of the site control program, is important because it reduces the spread of contamination, helps ensure proper personal protective equipment (PPE) is worn when working with hazardous substances, confines work activities to appropriate locations, and facilitates the location of personnel in emergency situations.

The boundaries of site work zones are decided based on the data collected during site characterization, including monitoring and sampling results. Access control points should be used to restrict the movement of personnel between the zones. This approach will also minimize the spread of contamination to clean areas.

Hazardous waste cleanup sites can have as many work zones as needed to operate safely. Most often, however, there are three work zones:

1. The Exclusion Zone (EZ)
2. The Contamination Reduction Zone (CRZ)
3. The Support Zone

Exclusion Zone

The innermost work zone where contamination is present is the EZ. This area is also referred to as the “hot zone.” The EZ extends outward far enough to prevent adverse effects to personnel outside the zone. Its outside perimeter is marked with ropes, barricade tape, stanchions, cones, chains, fencing, walls of existing buildings, or other markers. This boundary is called the “hotline.”

When establishing how far the EZ should extend and where to place the hotline, the employer will consider, among other things: the results of sampling and monitoring during the initial site entry, the safe distance in the event of a fire or explosion, the area needed to perform work activities, and typical wind and weather patterns.

Only employees with proper training, PPE, and chemical protective clothing (CPC) are allowed to enter the EZ through the access control point. Entering and exiting only through the access control point helps regulate the flow of personnel and equipment and verify that proper procedures are used. Personnel that typically work in the EZ include the Field Team Leader, work parties, and heavy equipment operators or other specialized workers. Emergency responders may also be found in the EZ in an emergency situation.

Work activities performed in the EZ might include:

• Monitoring and sampling,
• Installation of wells for groundwater monitoring, and
• Handling and processing hazardous waste, such as drum opening, drum staging, and other cleanup activities.

The EZ may be further subdivided into zones with varying degrees of hazards, incompatibilities, and PPE requirements. Each subdivision should be clearly marked, and protection requirements for each should be defined.

Contamination Reduction Zone

The CRZ is a buffer or transition area between the EZ and the Support Zone. The outer boundary of the CRZ, called the contamination control line, must be clearly marked.

Just like the EZ, no one is allowed to enter the CRZ unless they have had the proper training and are wearing the required PPE and CPC. Access is obtained through an access control point, which may even be staffed to make sure no unauthorized personnel enter the area.

A Contamination Reduction Corridor (or CRC), also known as the “decon line,” is set up inside the CRZ. It’s in this corridor that all the decon activities take place. This includes the decontamination and removal of PPE and protective clothing.

The CRC limits decon activities to a confined area and helps to minimize the spread of contamination. There may be more than one decon line in the corridor because a separate line is often used to accommodate the decontamination of heavy equipment and vehicles.

All entry and exit from the EZ is made through the access control points on the edges of the CRC. Each person or item in the CRC must be thoroughly decontaminated before entering the Support Zone.

Personnel working in the CRZ include the Site Safety Officer, a Personnel Decontamination Station (PDS) Operator, and decontamination crews. Emergency responders may enter the CRZ during an emergency.

People working in the CRZ may be there to:

• Decontaminate personnel, tools, vehicles, and heavy equipment;
• Maintain communication with work parties in the EZ;
• Monitor work parties for signs and symptoms; and
• Maintain site security.

Support Zone

The outermost zone is the Support Zone. This is also known as the “clean area” or “cold zone” and consists of all areas outside the contamination control line.

No one should be exposed to hazardous substances in the Support Zone. That means there is no need to wear protective equipment and clothing in this zone in relation to hazardous substances.

The command post, first aid station, emergency transport vehicles, equipment and supply center, field laboratory, lockers, and showering or changing facilities are all located in the Support Zone.

Factors that should be considered when making decisions about where to locate support facilities include:

• Locations of roads, highways, and railroad tracks and ease of access for emergency vehicles;
• Available resources like water, shelter, power lines, and telephone service;
• The line of sight to activities in the EZ;
• The prevailing wind direction (support facilities should be upwind of the EZ); and
• The distance from the EZ (support facilities should as far from the EZ as practicable).

All support activities are managed and handled from the Support Zone. The Command Post Supervisor runs daily and emergency activities from the command post in this area. Other employees who may be in the Support Zone include the project team leader, field team members who are preparing for entry or have returned from entry, medical personnel, and administrative personnel.

Other support work performed in the Support Zone might include:

• Maintaining communication;
• Recordkeeping;
• Monitoring work schedules;
• Maintaining site security;
• Performing medical activities;
• Inspecting, maintaining, and repairing equipment and supplies;
• Performing administrative duties; and
• Handling and processing field samples.

Hierarchy of controls

• Effective hazard control measures range from eliminating the hazard (most effective) to wearing PPE (least effective).

The functions of effective control measures include:

• Protecting employees from workplace hazards;
• Helping avoid injuries, illnesses, and incidents;
• Minimizing or eliminating safety and health risks; and
• Helping employers provide safe and healthful working conditions.

The employer will select the controls that are the most feasible, effective, and permanent for the site. The “hierarchy of controls,” from most effective to least effective, is as follows:

1. Eliminate or remove the hazard;
2. Substitute or replace the hazard;
3. Use engineering controls to isolate people from the hazard;
4. Use administrative controls to reduce the duration, frequency, and severity of exposure to hazards;
5. Use safe work practices; and
6. Wear personal protective equipment (PPE) around the hazard.

Eliminating a hazard could be as simple as noticing a sharp object and safely removing it or seeing a cord stretched across a pathway and putting this tripping hazard away. Both of these scenarios involve identifying and removing a hazard. An employer could also replace a safer chemical for a more hazardous one, thereby controlling the hazard by substitution.

Engineering controls are physical changes at the site to isolate people from the hazard or otherwise eliminate or reduce the hazard on the job or during the task. Examples include changing a process to minimize contact with hazardous substances, isolating or enclosing a process, using wet methods to reduce generation of dusts or other particulates, ventilating to dilute the air, using fume hoods, or using remotely operated equipment.

Administrative controls are policies and practices that reduce the duration, frequency, and severity of exposure to hazards. This control measure includes, but is not limited to: job rotation, shortened shift lengths, limiting overtime, taking frequent breaks, decreasing production rates, and increasing the number of employees assigned to a task.

Safe work practices are sometimes called “standing orders.” They are an element of the Site Control Plan and contribute to safety awareness. Anyone entering the site should be made aware of the expected safe work practices. A list may be maintained at the command post and access control points.

Some common safe work practices at a hazardous waste cleanup site are offered in the Engineering, administrative, and work practice controls section.

Employees could be reminded of safe work practices during daily job briefs. Whenever there is a new employee or a new project, a briefing should be provided about hazardous substances that might be encountered.

Standard Operating Procedures (or SOPs) are detailed documents that have steps for safety built into them and ensure each employee performs the task consistently. Of course, SOPs are only effective if they’re followed. They are used for many tasks, such as decontamination, selecting and inspecting PPE, entering confined spaces, handling drums, and locking out equipment.

The process of eliminating or substituting hazards and putting engineering, administrative, and work practice controls in place will help to mitigate many hazards. However, when hazards remain, there’s one more control method that employers may be required to provide to protect their workers — PPE.

PPE can help employees perform tasks within or alongside hazards, such as hazardous substances, noise, elevated surfaces, or electrical hazards. But, as important as PPE is, it has its limitations. PPE does not control the hazard; it merely controls exposure to the hazard by setting a barrier between the employee and the hazard. PPE is not suitable for all situations. For example, no single type of glove can protect against all solvents.

Fire control and sanitary measures

• Fire control measures include firefighting personnel and equipment, as well as detection and alarm systems.
• Sanitary measures have to do with food, water, hygiene, and living conditions.

Fire is among the deadliest of work hazards. Due to the nature of many hazardous substances at hazardous waste cleanup sites, fire is a real threat. Control measures must be in place to help protect against fire once it starts.

The different forms of fire protection that might be found at a site include:

• A fire brigade;
• Portable fire extinguishers;
• Standpipe and hose systems;
• Fixed fire suppression equipment, like automatic sprinkler systems;
• Fire detection systems; and
• Employee alarm systems.

Sanitation is yet another control measure. Sanitary measures are used to maintain an acceptable level of personal hygiene and to reduce the likelihood of exposure to hazardous substances through ingestion or dermal contact. Sanitary measures that must be taken at a hazardous waste cleanup site include the following:

• Adequate washing facilities must be provided for those engaged in operations involving hazardous substances. These facilities must be provided in areas where exposures are below permissible exposure limits (PELs) or published exposure levels.
• Adequate numbers of toilets must be provided.
• If the site is operating for six months or longer, showers and changing rooms must also be provided.
• If sleeping quarters are provided, they must be heated, ventilated, and lighted.
• Food-handling measures must meet local codes.
• Potable and non-potable water systems must be kept separate.
• Non-potable water systems must be clearly marked, indicating that the water is unsafe for drinking, washing, or cooking.
• Portable containers used for drinking water must be designed to prevent contamination of the water, be clearly marked as drinking water, and be equipped with a tap. Employees must not be allowed to dip water from the container.

Initial and refresher training and certification

• The amount of initial training required depends on an employee’s job role, but almost everyone is required to have eight hours of annual refresher training.

Before any work on a hazardous waste cleanup site, the employer must provide employees with initial training based on their tasks and operations and the anticipated exposures (see the table below).

Employees who have equivalent experience and skills from previous work experience and/or training do not have to receive the initial training, provided that the employer can verify it through documentation or certification. However, equivalently trained employees who are new to a site must receive site-specific training before site entry.

Employees who receive the specified training must receive a written certificate from their instructor (or the head instructor) and trained supervisor upon successful completion of that training. A written certificate shall be given to each person so certified.

If the employee goes to work at a new site, the training does not need to be repeated; however, the employee must receive the necessary additional site-specific training needed to work safely at the new site.

All employees must receive eight hours of annual refresher training as indicated in the table above. This training may include any critique of incidents that have occurred in the past year, examples of related work, and other relevant topics.

Notes:

• Subparagraph (e)(7) of 1910.120 and 1926.65 also calls for the training of employees who are engaged in responding to hazardous emergency situations at hazardous waste cleanup sites that may expose them to hazardous substances. That training must cover how to respond to such expected emergencies. No training duration is specified. Please refer to the Emergency response for uncontrolled hazardous waste sites section found elsewhere in this subject for further discussion.
• Non-mandatory Appendices C and E to the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 1910.120 and 1926.65 provide useful compliance guidelines and assistance in developing a site-specific training curriculum used to meet the training requirements in paragraph (e) of 1910.120 and 1926.65.

Training elements

• Supervisors and employees must be trained to understand and follow policies and procedures and to use and care for equipment.

Training makes employees aware of the potential hazards they may encounter and provides the necessary knowledge and skills to perform their work with minimal risk to their own and others’ safety and health. Both supervisors and employees must be trained to:

• Recognize hazards and prevent them;
• Select, care for, and use respirators properly, as well as other types of personal protective equipment (PPE);
• Understand engineering controls and their use;
• Use proper decontamination procedures; and
• Understand:
  • The emergency response plan,
  • Medical surveillance requirements,
  • Confined space entry procedures,
  • The spill containment program, and
  • Any appropriate work practices.

Employees also must know the names of personnel and their alternates responsible for site safety and health. Site personnel who are expected to respond to emergency situations at the site must receive additional training in how to respond to anticipated emergencies (e.g., fires, explosions, hazardous spills).

Training format

• HAZWOPER training can include a computer-based component, as long as the overall training program provides employees with hands-on experience and the ability to ask questions of a trainer.

According to the Occupational Safety and Health Administration (OSHA), use of computer-based (or online) training by itself is not sufficient to meet the intent of most of OSHA’s training requirements, in particular those of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. However, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. OSHA’s position on this matter is essentially the same as the agency’s policy on the use of training videos, since the two approaches have similar shortcomings.

OSHA urges employers to be wary of relying solely on generic, “packaged” training programs in meeting the agency’s training requirements. For example, training under HAZWOPER requires site-specific elements and should also, to some degree, be tailored to employees’ assigned duties.

In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them. In a computer-based program, HAZWOPER training requirements may be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer.

Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting. Many industrial operations, and in particular hazardous waste operations, can involve complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely.

Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks. The purpose of hands-on training, for example in putting on and removing personal protective equipment (PPE), is twofold:

1. To ensure that employees have an opportunity to learn by experience, and
2. To assess whether employees have mastered the necessary skills.

Sole reliance on a computer-based training program is unlikely to achieve these objectives.

Thus, OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer and provides trainees with sufficient hands-on experience.

Introduction

• Besides hazardous substance exposure, potential health hazards at a worksite include heat and cold, radiation, and noise.

While much attention is focused on safety hazards, health hazards are a real concern as well. Employees who work at hazardous waste cleanup sites or respond to emergency releases of hazardous substances may be exposed to health hazards.

One health hazard found in these two operations (hazardous waste cleanup and emergency response) is exposure to hazardous substances. It’s possible to be exposed to a hazardous substance and not even be aware of it because some substances are odorless and colorless. The first indication of the presence of these substances might be the employee feeling the effects of exposure. The trouble is the effects from some substances might not show up right away.

Besides exposure to hazardous substances, other potential health hazards include, but are not limited to:

• Heat stress
• Cold exposure
• Biologic hazards
• Ionizing radiation
• Oxygen deficiency
• Noise

With so many health hazards, the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires covered employers to perform medical surveillance and, for cleanup operations, have a written medical surveillance program in place.

Besides being required, medical surveillance is performed for many reasons, including:

• To diagnose and treat injuries or illnesses early;
• To establish an employee’s baseline medical condition;
• To assess an employee’s fitness for duty, including the ability to wear personal protective equipment (PPE) and chemical protective clothing (CPC);
• To document exposures and medical conditions;
• To detect and eliminate hazards and exposures contributing to health problems; and
• To ensure emergency and non-emergency treatment is provided.

Who needs medical surveillance?

• Under HAZWOPER, employers are required to provide medical surveillance, but employees can opt out of it.

For hazardous waste cleanup operations, medical surveillance must be made available to employees if:

• They are or may be exposed for 30 or more days a year to hazardous substances or health hazards at or above the permissible exposure limits (or PELs), or, if no PEL is available, then over the published exposure levels for these substances.
• They wear a respirator for 30 days or more a year.
• They are injured, become ill, or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards.
• They belong to a HAZMAT team, whose members are expected to control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance.

Employees who fit any of the criteria listed above are considered “covered employees.”

Under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, employers are obligated to make medical surveillance available without cost to employees, but the Occupational Safety and Health Administration (OSHA) does not require employees to participate. If an employee chooses not to take part in the medical surveillance program, this should be documented with a signed record in the employee’s personnel file.

HAZWOPER training should incorporate the purpose and content of the medical surveillance program required by the standard so employees understand that it is for their protection.

OSHA does not require employees to take a medical exam. However, employees who refuse to be medically evaluated cannot be assigned to work in areas where they are required to wear a respirator.

Signs and symptoms of overexposure

• There are two types of chemical exposure — acute (high concentration over a short time) and chronic (lower concentrations over a longer time).

There are many different hazardous substances, and the effects they can have on humans range from mild to deadly. Employees should be trained to seek medical attention immediately if they detect signs or symptoms in themselves or coworkers.

Some signs and symptoms that could indicate an exposure to hazardous substances include:

• Weakness;
• Headache;
• Cramps, diarrhea, or nausea;
• Decreased mental ability, confusion, or unconsciousness;
• Arm or leg numbness;
• Irritability, dizziness, poor balance, tremors, or convulsions; and
• Fatigue.

It should be noted that chemical exposure may not be noticeable right away. Chemical exposures are generally divided into two categories:

• Acute exposure. Exposure to a substance over a short period of time, typically in an isolated incident. Symptoms usually occur during or shortly after exposure to a sufficiently high concentration of the substance. Generally, medical attention and treatment are sought once symptoms are detected.
• Chronic exposure. Exposure to low concentrations of a chemical over a long period of time. It can take years for the effects or symptoms to show up. However, this is part of the reason for medical surveillance, which can help detect exposures earlier than people might detect them on their own.

Types of medical exams

• Under HAZWOPER, covered employees should receive medical exams and consultations to determine their fitness for duty and establish a baseline, compare to that baseline, evaluate illness and injuries, and keep their records up to date.

The medical surveillance program includes five types of medical exams, which are conducted at different points in employees’ job tenures to gather data about their health, both as a baseline and in relation to time and chemical exposure.

Pre-assignment exam

Employees must be offered a medical exam and consultation before performing any work that makes them a “covered employee” (see the Who needs medical surveillance? section). The pre-assignment exam, also called the initial exam, serves two purposes:

• To determine fitness for duty, and
• To acquire baseline data for comparison with future medical exams.

The physician will assess an employee’s ability to perform the physically demanding tasks their job may require in order to determine fitness for duty. The physician must assess the occupational and medical history but may also consider a physical exam of the organs, with emphasis on the heart, lungs, and musculoskeletal systems, and an assessment of the employee’s ability to work while wearing personal protective equipment (PPE) and/or chemical protective clothing (CPC).

The employee will be asked to fill out a medical questionnaire with a very detailed occupational and medical history. The physician will use this to:

• Review prior occupational exposures to chemical and physical hazards;
• Review past illnesses and chronic diseases, such as asthma and lung or heart disease;
• Review symptoms, past or present, such as shortness of breath, respiratory symptoms, cardiovascular issues, or heat intolerance;
• Assess any sensitivity to specific substances; and
• Assess any relevant hobbies and lifestyle habits, like smoking, drinking alcohol, and drug use.

Next, the physician performs a comprehensive physical examination including the following:

• Height, weight, temperature, pulse, respiration, blood pressure, head, nose, throat, vision, and hearing;
• The condition of the organs, with particular attention to the pulmonary, cardiovascular, and musculoskeletal systems;
• Blood chemistry, urinalysis, and chest x-ray;
• Any conditions that heighten vulnerability to heat stroke, such as obesity or poor physical condition;
• Any conditions that may interfere with respirator use, such as facial scars, dentures, or poor eyesight; and
• Any other limitations concerning the ability to use PPE and/or CPC.

A pulmonary function test, stress test, and/or electrocardiogram (EKG) may also be administered. Employees can be assigned to tasks that require respirators only if they have been determined to be physically able to perform under such conditions.

The physician uses all the information gathered to determine whether the employee is fit for duty as a covered employee. However, the pre-assignment exam will also acquire baseline data, which:

• Provides a measure for determining if subsequent exposures have adversely affected the employee’s health, and
• Creates a data set for the employer to verify the effectiveness of control measures.

Based on what substances employees may be exposed to, tasks they will be expected to perform, and their medical and work history, the physician will determine what other tests to administer to obtain baseline data. Some of the following will likely be part of the exam:

• EKG
• Pulmonary function test
• Hernia exam
• Skin exam
• Heavy metal screen
• Blood tests for other toxicants likely to be onsite
• Radiological bioassay
• Any other tests the physician deems necessary

Periodic exam

Periodic exams are essential to medical surveillance. By comparing baseline data from the pre-assignment exam to the data collected in periodic exams, the physician can identify trends that indicate the onset of negative health effects.

An annual periodic exam and consultation are recommended; however, the physician will determine the frequency (at least once every two years) based on the employee’s information. More frequent exams may be needed, depending on:

• The extent of potential or actual exposure;
• The type of substances involved in job duties;
• The duration of the assignment; and
• The employee’s profile, including things like age, medical history, previous exams, and previous exposures.

A periodic exam will include:

• An updated medical and work history focused on changes in health, any illnesses, and any possible work-related symptoms;
• A physical exam;
• Additional tests, which may include pulmonary function, EKG, hearing, vision, blood chemistry, and urinalysis; and
• Any other tests the physician deems necessary.

Termination exam

When an employee’s employment ends, or upon reassignment to a position that does not require medical surveillance, a full termination exam and consultation will be given if one of the following applies:

• The last periodic exam was conducted six or more months ago,
• Exposure has occurred since the last exam,
• Symptoms of exposure have arisen since the last exam, or
• The physician deems it necessary.

If a full exam and consultation is required, it will consist of:

• Updating the employee’s occupational and medical history,
• A physical exam,
• Laboratory tests, and
• Any other test the physician deems necessary.

If a full termination exam is not needed, a termination exam and consultation will be conducted to simply update the employee’s most recent occupational and medical history.

Post-illness or -injury exam

Medical examinations and consultations must also be offered as soon as possible when an employee develops signs or symptoms of overexposure to health hazards, or is injured or exposed above certain limits in an emergency. Depending on the situation, the physician will decide the extent of the exam.

While not required, the employer may offer additional exams or consultations for other situations, such as:

• Any recordable injury onsite,
• Any lost time illness of a certain number of days, and
• A contamination incident.

Emergency responders who are not “covered employees” (as listed in the Who needs medical surveillance? section) have no medical surveillance protections from OSHA. However, they’re entitled to medical consultation if they become injured or ill or develop signs or symptoms due to exposure to hazardous substances from an emergency response.

Follow-up exam

The physician will determine if any follow-up exams or consultations are medically necessary based on the employee’s information and situation after an exam involving an injury, illness, or possible overexposure.

Information exchanged with physician

• The employer must provide the physician who examines an employee with information about HAZWOPER and the employee’s work conditions, including duties, accompanying hazards, and PPE.
• After the exam, the examining physician must provide the employer with information about the employee’s medical risks and conditions that are related to the work, along with recommendations for work limitations.

Prior to an employee’s examination, the employer must furnish the physician with specific information, including:

• A copy of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard and its appendices;
• A description of the employee’s duties as they relate to hazardous substance exposure;
• The employee’s expected physical work effort;
• The employee’s anticipated or real chemical exposure levels;
• Temperature and humidity extremes that may be encountered;
• A description of any personal protective equipment (PPE) the employee has used or will be required to use, including the respirator type and weight, the duration and frequency of respirator use, and protective clothing and equipment to be worn; and
• Information from previous medical exams, if that information is not readily available to the physician.

Going the other direction, the examining physician will furnish the employer with a written opinion that includes:

• Whether the employee has any detected medical conditions that would cause increased risk on the job or with respirator use,
• The physician’s recommended limitations for the employee,
• The results of any medical exams and tests requested by the employee, and
• A statement that the employee has been informed of the medical exam results and any medical conditions which require further examination or treatment.

Any conditions discovered during a medical exam that are not related to the employee’s work must remain confidential and not be revealed to the employer.

Medical surveillance program

• Medical surveillance programs must be site-specific and may be tailored to an employee’s varying needs and potential exposures.
• Each year, the medical surveillance program must be reviewed by the site safety and health supervisor.

Employers at hazardous waste cleanup sites are required to have a medical surveillance program and to put it in writing.

In contrast, for emergency response operations, the employer is required to provide medical surveillance but is not required to put the details about medical surveillance in writing. However, emergency first aid and treatment information must be included in the emergency response plan (ERP), if applicable.

A medical surveillance program for cleanup site workers describes how worker health status is monitored and should include elements for:

• Medical exams, including pre-assignment, periodic, post-injury or -illness, follow-up, and termination exams;
• Emergency medical treatment and first aid;
• Recordkeeping; and
• Review of the program’s effectiveness.

The medical surveillance program must be site-specific, based on the specific needs, location, and potential exposures of employees at the site.

The surveillance needs of employees at a site under the program may vary slightly. That’s because exposure, medical and work history, age, sex, weight, stress level, diet, allergies, medications, and hobbies differ from person to person. The employer may attempt to tailor the medical exams and tests to fit individual employees and better protect their health.

Covered employees (as listed in the Who needs medical surveillance? section) should be encouraged to:

• Give complete, accurate, and detailed information on occupational and medical history questionnaires;
• Report any suspected exposures and watch for signs and symptoms of exposure in both themselves and their coworkers;
• Report all injuries;
• Wear their personal protective equipment (PPE) and chemical protective clothing (CPC) properly;
• Keep all medical exam appointments; and
• Live a healthy lifestyle, including plenty of sleep, balanced nutrition, and regular exercise.

Program review

When the medical surveillance program is required, it should be reviewed each year by the site safety and health supervisor or a management representative knowledgeable in occupational safety and health. Performing a thorough review helps ensure the effectiveness of the medical surveillance program.

The items that should be addressed during a medical surveillance program review include:

• Verifying that each incident or illness was investigated, the cause was determined, and any necessary changes to procedures were updated;
• Ensuring the proper tests are being provided to workers based on the potential exposures;
• Adding or deleting medical tests based on current data;
• Reviewing procedures for emergency medical treatment; and
• Updating emergency contact lists.

Other records

• Employers must keep employee medical records and exposure records and make them available to the employee and to OSHA.
• Each year, employers must post a yearly summary report of recordable work injuries and illnesses.

Employers are required to keep accurate and thorough records of medical surveillance. These records include:

• Employees’ names;
• The physicians’ written opinions, recommended limitations, and results of exams and tests;
• Any medical complaints that may be related to employees’ exposure to hazardous substances; and
• A copy of the information the employer provided to the physician.

Employee medical records

The Occupational Safety and Health Administration (OSHA) defines an “employee medical record” as a record concerning an employee’s health status, which is made or maintained by a healthcare professional and includes:

• Any medical and employment questionnaires or history;
• Results of medical exams and tests;
• Medical opinions, diagnoses, progress notes, and recommendations;
• First aid records;
• Descriptions of treatments and prescriptions; and
• Employee medical complaints.

All medical records from medical surveillance must be available to the employee upon request while employed with the employer and for an additional 30 years after the end of employment.

Employee exposure records

OSHA defines an “employee exposure record” as a record containing any of the following kinds of information:

• Environmental monitoring or measuring of a toxic substance or harmful physical agent,
• Biological monitoring results that directly assess the absorption of a toxic substance or harmful physical agent by body systems,
• Safety data sheets indicating the material may pose a hazard to human health, or
• In the absence of safety data sheets, a chemical inventory or other record that reveals the identity of the substance or agent and where and when it was used.

Exposure records must be available to the employee upon request for 30 years after exposure.

Availability of records

Medical and exposure records are kept confidential. However, employees or their authorized representatives can request copies of their medical and exposure records including test results and written opinions.

An authorized OSHA representative is also allowed access to medical records upon request, in accordance with the regulations.

Finally, each year the employer must post a yearly summary report of all “recordable” work injuries and illnesses. This annual summary report is posted in the workplace in a conspicuous place or places where notices to employees are customarily posted. The summary must be posted from February 1 to April 30 each year.

Program elements

• The PPE program required of employers covered under 29 CFR 1910.120 or 1926.65 must address topics including selection, use, and maintenance of PPE and CPC.

Employers whose employees will be exposed or have the potential to be exposed to hazardous substances are required to have a personal protective equipment (PPE) program. The purpose of the program is twofold:

• To provide protection from any chemical, physical, or biological hazards; and
• To ensure workers know how to wear their protective equipment and clothing properly so they are not harmed from improper use or malfunction.

The PPE program should be in writing and be available to all employees. Some topics that must be addressed in the PPE program include:

• Identification of hazards;
• Uses and limitations of the PPE and chemical protective clothing (CPC) provided;
• Proper selection of equipment and clothing;
• Medical monitoring of personnel;
• Environmental surveillance;
• Proper use, inspection, and maintenance of equipment and clothing;
• Decontamination methods for PPE and CPC;
• Training for employees, including hands-on training; and
• Proper donning and doffing procedures.

Another requirement of a PPE program is for the employer to review the program annually to evaluate its effectiveness. The review should be comprehensive and analyze aspects including:

• Compliance with regulations;
• Time workers spent wearing PPE;
• Accidents or illnesses;
• Adequacy of programs for:
  • Equipment selection,
  • Use,
  • Inspection,
  • Maintenance,
  • Decontamination, and
  • Storage; and
• Effectiveness of employee training.

The review of the PPE program should also be made available to all employees and should be used to assess if any changes are needed to improve upon the effectiveness of the program.

Types of PPE and CPC

• Chemicals, radiation, heat, explosions, immersion, and other hazards can all be addressed with the proper type of CPC.

There are many different types of personal protective equipment (PPE) and chemical protective clothing (CPC) that protect many different parts of the body from many different hazards.

Types of PPE

PPE can provide protection from the following:

• Chemical hazards such as spills, splashes, vapor clouds, and contaminated dusts;
• Physical hazards such as falls, flying objects, and sources of electricity; and
• Biological hazards such as bloodborne pathogens and other infectious agents.

Types of CPC

The CPC that workers should wear varies depending on the situation and the chemicals involved. Any article of clothing that offers protection for a person’s skin or body from chemical hazards is considered CPC. Some types of CPC include:

• Fully encapsulating suits
• Non-encapsulating suits
• Aprons, leggings, and sleeve protectors
• Firefighters’ protective clothing
• Proximity garments or approach suits
• Blast and fragmentation suits
• Radiation contamination suits
• Flotation gear
• Cooling garments
• Hoods or hair coverings
• Sweatbands
• Disposable shoe or boot covers

A fully encapsulating suit offers whole-body protection from splashes, dust, gases, and vapors through its one-piece design. The boots and gloves can be either part of the suit, attached so they can be replaced, or separate.

This type of suit requires an atmosphere-supplying respirator. Employees wearing fully encapsulating suits should be monitored for heat stress, especially if they are also wearing self-contained breathing apparatus (SCBA).

A non-encapsulating suit protects most of the body, but parts of the head or neck are not protected. It consists of separate pieces of clothing that are worn together, such as a jacket, a hood, pants or bib overalls, and/or one-piece coveralls.

This type of clothing can also cause heat stress. Tape should be used to seal the connections between pants and boots, and between gloves and sleeves.

Arm sleeves can be used to add protection to the arms. Arm sleeves typically go all the way up to the shoulder. For additional protection, workers can use tape to seal their arm sleeves to their gloves, preventing splashes from getting down inside the gloves.

Aprons and leggings can provide additional protection to the chest and legs. These, along with the arm sleeves, should only be used alone when the chances of hazardous substances splashing the whole body are extremely low.

Firefighters’ protective clothing consists of a helmet, fire-resistant coat, fire-resistant pants, and boots. The main purpose of this clothing is to protect against heat and hot water. It will add protection against some particles as well, but it is very hard to decontaminate and can be permeated and degraded by chemicals.

Firefighters’ protective clothing should never be used as protection against chemical splashes, gaseous atmospheres, or vapors.

A proximity garment, sometimes called an approach suit, consists of a one- or two-piece overgarment with boot covers, gloves, and a hood made of aluminized nylon or cotton. These items are worn over other protective clothing to provide brief protection from radiant heat.

If employees will be exposed to a toxic atmosphere or need more than a couple minutes of protection, they would need to wear some type of cooling aid and an SCBA.

A blast and fragmentation suit consists of special blast and fragmentation vests and clothing, bomb blankets, and bomb carriers. These items can be used to provide some protection when small detonations are expected. Bomb blankets and baskets can be used to help redirect a blast.

When wearing this clothing, employees must also use some type of hearing protection.

For protection against radioactive alpha and beta particles, employees would wear a radiation-contamination protective suit, which consists of coveralls, gloves, shoe or boot covers, and a hood. This protective clothing is designed to protect the skin from contamination; it will not provide protection from gamma radiation.

If radiation may be present, a radiation expert should be consulted, and personnel should be evacuated from the area until conditions have been evaluated.

Life jackets or vests can be used as flotation gear when working in or around water. A life jacket or vest should be worn underneath other protective clothing to prevent degradation of the material from exposure to chemicals.

When heat stress is a concern due to either temperatures or the type of protective clothing worn, cooling garments can be used. Methods used for cooling include:

• A pump that circulates cool, dry air to portions of the suit or throughout the suit using an air line;
• A vest or jacket worn under other protective clothing that has pockets for carrying ice packs; and
• A pump that circulates ice water from a reservoir through tubes that cover the upper torso.

To protect the head area:

• Hoods can be used to protect the hair and neck from contamination.
• Hair nets can be used to keep workers’ hair from impairing their vision, particularly long hair. These can be worn under hard hats, liners, or hoods.
• Sweatbands can help prevent sweat from dripping into the eyes, causing irritation or impaired vision. These don’t provide any protection from chemicals, but they may make it more comfortable to work in warm environments or wear full body protection.

Boot covers or shoe covers give the feet an added layer of protection from chemicals. These covers slip over boots or shoes and are typically single use.

Hazard assessment

• PPE and CPC are selected based on hazards identified during the site characterization and analysis.
• For general industry, HAZWOPER also requires a certified hazard assessment that documents which hazards are or may be present in a workplace.

Employees must be protected from actual and potential hazards with appropriate personal protective equipment (PPE) and chemical protective clothing (CPC). Under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, PPE and CPC must be “selected and used which will protect employees from the hazards and potential hazards they are likely to encounter as identified during the site characterization and analysis.” Site characterization and analysis is covered by paragraph (c) of 29 CFR 1910.120 and 1926.65. See the Site characterization and analysis section for details.

In addition, PPE and CPC must meet the requirements of paragraph (g) of 1910.120 and 1926.65, and this paragraph references 29 CFR 1910 Subpart I for general industry or 29 CFR 1926 Subpart E for construction.

In referencing Subpart I, the HAZWOPER Standard also references a hazard assessment certification requirement at 1910.132. Specifically, the employer must assess the workplace to determine if hazards are present, or are likely to be present, that necessitate the use of PPE or CPC. If such hazards are present, or likely to be present, the employer must:

• Select, and have each affected employee use, the types of PPE and CPC that will protect the employee from the hazards identified in the hazard assessment;
• Communicate selection decisions to each affected employee; and
• Select PPE and CPC that properly fits each affected employee.

Under 1910.132, the employer must also verify that the required workplace hazard assessment has been performed. This verification happens via a written certification that identifies:

• The workplace evaluated;
• The person certifying that the evaluation has been performed;
• The date(s) of the hazard assessment; and
• That the document is a certification of hazard assessment.

The non-mandatory Appendix B to 29 CFR 1910 Subpart I contains an example of procedures that would comply with the requirement for a hazard assessment.

The construction regulations at 29 CFR 1926 Subpart E do not carry a hazard assessment certification provision. However, 1926.95 calls for protective equipment and protective clothing “whenever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.”

Moreover, 1926.65 mandates that PPE and CPC be selected in accordance with the site characterization and analysis at 1926.65(c).

Selecting PPE and CPC

• Selection criteria for PPE and CPC should include not only the level and nature of protection they provide but their fit, compatibility, and ease of decontamination.

Before selecting any personal protective equipment (PPE) or chemical protective clothing (CPC), employees should be well informed about the conditions. What hazardous substances are present, what form they are in (such as a vapor cloud or a liquid spill), the concentration levels, the hazards involved, the exposure routes, and any expectations for possible changing conditions are all vital pieces of information.

Selecting PPE

One thing to take into consideration is whether all pieces of PPE needed are compatible and do not interfere with each other. For instance, an employee wearing a hard hat, goggles, and hearing protection should make sure the goggles don’t interfere with the fit of the hard hat. An employee preferring earmuffs as hearing protection may need a hard hat that has special grooves in it to accommodate them.

Another consideration is proper fit. PPE must be comfortable to wear; if it’s too tight and causing pinch points, it will be distracting. If it’s too large and falling off or moving around and the employee needs to adjust it regularly, that will be equally distracting.

Considerations when selecting PPE may include:

• Specific hazards such as elevated heights, projectiles, falling objects, loud noises, or splashing liquids;
• Unrestricted vision and movement;
• Electrical hazards;
• Explosive or combustible environments;
• Wet surfaces or slippery conditions;
• Possible changing conditions;
• Thermal protection;
• Duration of work;
• Grip requirements; and
• Shock absorbency.

Selecting CPC

When selecting CPC, one thing to consider is permeation. Even chemically resistant clothing is not immune to permeation. And in most cases, there won’t be any visible evidence that chemicals are permeating the material.

Chemical mixtures make permeation especially unpredictable, as even small concentrations of certain chemicals can enable the more rapid permeation of others.

Some factors that can affect the degree of permeation and how quickly it breaks through materials include:

• Material type and thickness;
• How the material was manufactured;
• The concentration of the hazardous substance; and
• Temperature, pressure, and humidity.

When selecting CPC, employees should also consider penetration and degradation. Penetration is the ability of chemicals to move through zippers, seams, or imperfections in material. Degradation involves physical changes in a material due to chemical exposure, use over time, or exposure to ambient conditions like sunlight. Signs of degradation include fading, swelling, loss of strength, and deterioration.

Another consideration is heat transfer. This refers to the clothing’s ability to dissipate heat. During work that occurs in a hot environment or requires rapid movement, heat can build up quickly inside CPC, which creates a concern for heat stress. The level of protection should never be downgraded due to heat stress, but adding some type of cooling garments may be necessary.

More factors to consider when selecting CPC include:

• Durability. Does the material have the strength to stand up to the physical stresses of the tasks the wearer needs to perform? Can the material resist tears, punctures, and abrasions?
• Flexibility. Will the material allow the wearer the flexibility required to perform necessary tasks?
• Temperature. What effects will hot or cold temperatures have on the protective clothing? Will the clothing remain flexible in extreme temperatures?
• Decontamination. How difficult is the clothing to decontaminate? Employees may decide to wear disposable or reusable clothing or a combination of both, depending on the conditions.
• Compatibility. Is the clothing compatible with other needed clothing and PPE? For instance, some fully encapsulating suits may not be compatible with a hard hat.
• Duration. How long will the required tasks take? Can the tasks be done before degradation or permeation becomes an issue?
• Special conditions. Are there any special conditions that are present or could potentially happen, such as fires, explosions, heat, and radiation? The employee could need protection from those conditions in addition to chemical protection.

Selecting ensembles

• When PPE and CPC are worn together, this is known as an ensemble.
• Ensembles range from more protective (level A) to less protective (level D), depending on their components.

Personal protective equipment (PPE) and chemical protective clothing (CPC) are typically worn together in what is called an ensemble. There are four different ensemble categories based on the degree of protection needed — levels A, B, C, and D.

Level A

Level A provides the highest degree of respiratory, skin, and eye protection from solids, liquids, vapors, and gaseous chemicals. Level A protection requires the following:

• A positive pressure full-facepiece self-contained breathing apparatus (SCBA) or a positive pressure supplied-air respirator with an escape SCBA,
• A fully encapsulating chemical protective suit,
• Inner and outer chemical-resistant gloves, and
• Chemical-resistant safety boots.

There are optional items that can be worn along with level A protection, such as:

• Cooling unit;
• Coveralls;
• Long underwear;
• Hard hat;
• Disposable suit, gloves, and boots worn over the top of the fully encapsulating suit.

Level A protection is needed for:

• Entering areas with high concentrations of an identified airborne hazardous substance that requires the highest level of protection for the skin, eyes, and respiratory system;
• Working where substances with a high degree of hazard to the skin are known or suspected to be present; and
• Performing operations in confined or poorly ventilated areas.

Level B

Level B provides the same level of respiratory protection as level A, but a lesser level of skin protection. Level B protection requires the following:

• A positive-pressure full-facepiece SCBA or a positive-pressure supplied-air respirator with an escape SCBA,
• A hooded chemical-resistant suit,
• Inner and outer chemical-resistant gloves, and
• Chemical-resistant safety boots.

There are also optional items that can be worn along with level B protection, such as:

• Coveralls
• Chemical-resistant disposable outer shoe covers
• Face shield
• Hard hat

Level B should be used when:

• There are high concentrations of identified airborne hazardous substances that require a high level of respiratory protection but a lesser level of skin protection;
• The atmosphere contains less than 19.5 percent oxygen; or
• There are unknown hazardous substances, but they are not suspected to contain high levels of substances harmful to skin or capable of being absorbed through the skin.

Level C

Level C protection provides the same level of skin protection as level B, but a lower level of respiratory protection. Level C protection requires the following:

• A full-face or half-mask air-purifying respirator,
• Hooded chemical-resistant clothing, and
• Inner and outer chemical-resistant gloves.

There are optional items which can be worn along with level C protection, such as:

• Coveralls
• Chemical-resistant safety boots
• Chemical-resistant disposable outer shoe covers
• Hard hat
• Escape mask
• Face shield

Level C protection should be used if:

• There are no hazardous substances present onsite that will negatively affect the skin,
• All airborne hazardous substances have been identified,
• An air-purifying respirator is available that can remove the contaminants, and
• All criteria for the use of air-purifying respirators are met.

Level D

Level D protection provides no respiratory protection and only minimal skin protection. Level D protection requires the following:

• Coveralls
• Safety shoes

There are optional items that can be worn along with level D protection, such as:

• Gloves
• Chemical-resistant safety boots
• Chemical-resistant disposable outer shoe covers
• Safety glasses or goggles
• Escape mask
• Face shield

Level D protection should be used if:

• The air contains no known hazards; and
• The work being performed precludes splashes, immersion, the potential for unexpected inhalation, or contact with hazardous levels of any substances.

Ensemble selection

Some things to consider when selecting ensembles include:

• An adequate level of protection,
• Each item’s compatibility with all other items,
• Time required to put on all clothing and equipment,
• Chemical hazards that are present,
• Physical environment and any physical hazards,
• Duration of exposure,
• Communication requirements, and
• The components available.

If hazards are unidentified, a minimum of a level B ensemble is appropriate, and employees must carry instruments that can identify IDLH (immediately dangerous to life or health) conditions.

If an SCBA is not part of the ensemble for initial entry, employees will need to bring an escape SCBA with at least five minutes of air.

Each ensemble level is a starting point and should be tailored to the specific situation. Conditions should be monitored continuously for any changes, so PPE and CPC can be re-evaluated as new information is known. Reasons why PPE and CPC could be upgraded or downgraded include:

• Upgrading — PPE and CPC might be upgraded because:
  • New information indicates that substances could affect the dermal layer of the skin or that gas or vapor emissions are likely,
  • A change in work tasks increases the employee’s contact with hazardous substances, or
  • The worker requests an upgrade.
• Downgrading — PPE and CPC might be downgraded because:
  • New information indicates that the situation is less hazardous than originally thought,
  • The hazardous conditions have decreased, or
  • A change in work tasks will decrease the employee’s contact with hazardous substances.

Donning and doffing an ensemble

• A worker should always have an assistant help with putting on and taking off an ensemble.
• The procedure for taking off an ensemble depends on how much air is left in the wearer’s SCBA tank.

Putting on and taking off (technically called donning and doffing) an ensemble is not as simple as it sounds. It’s a good idea to practice donning and doffing protective equipment and clothing. This creates an opportunity for the wearer to:

• Address any personal use issues,
• Know what sizes of items fit best,
• Get comfortable with the procedures of donning and doffing, and
• Gain facility with wearing and operating the individual pieces.

Donning an ensemble

The job of donning a protective ensemble can seem like a huge task, but employees always help each other. An assistant should always help an employee don the ensemble. Assistants can help tape seals, pull on boots, strap on a self-contained breathing apparatus (SCBA), and check to make sure none of the protective gear is missing and everything looks proper.

Prior to donning any personal protective equipment (PPE) or chemical protective clothing (CPC), the wearer should inspect each piece.

The following steps are for donning a level A ensemble.

1. If the fully encapsulating suit has a back closure for changing out air tanks, the wearer makes sure that closure is opened.
2. Then, from a standing or sitting position, the wearer steps into the suit, placing feet properly inside the suit. The wearer pulls the suit up and gathers it around the waist.
3. Next, the wearer puts on chemically resistant safety boots over the feet of the suit. Next, the leg cuff is brought over the top of the boots, and tape is used to seal the suit to the boots. If any additional foot protection like disposable boot or shoe covers will be worn, this would be put on now over the safety boots.
4. The wearer puts on the SCBA and adjusts the harness, then dons the facepiece and adjusts it so it’s secure and comfortable. The breathing hose isn’t connected yet, but the valve on the air tank should be open.
5. Next both negative- and positive-pressure tests on the facepiece are conducted:
   1. To perform a negative-pressure test, the palm of the hand is placed firmly over the inlet valve to block flow while the wearer gently inhales for 10 seconds. If any air rushes inside the facepiece, it indicates an improper fit. The facepiece must be adjusted and the test performed again.
   2. To perform a positive-pressure test, the wearer gently exhales while placing a hand over the exhalation valve. If air escapes from the mask and positive pressure cannot build up, this would also indicate an improper fit. The facepiece must be adjusted and the test performed again.
6. Next, the wearer puts on the inner gloves and tapes them to the sleeves. Arms go into the sleeves of the suit while the assistant helps pull the suit up and over the wearer’s SCBA. The assistant helps adjust the suit around the SCBA and the wearer’s shoulders to make sure the suit allows unrestricted movement.
7. Now the wearer puts on a hard hat and puts up the hood of the suit—carefully, so as not to break the seal on the facepiece.
8. The wearer makes sure the suit is adjusted comfortably and starts securing the suit by closing any fasteners, leaving just enough room to attach the breathing hose and open the main valve.
9. The assistant verifies the wearer is breathing properly and finishes closing the fasteners on the suit. The assistant then helps the wearer don outer gloves if needed and tapes them to the suit sleeves; checks all closures; and makes sure the wearer is comfortable and psychologically stable and that all equipment is operating properly before the wearer starts work.

Doffing an ensemble

Upon leaving a contaminated area, all the outside surfaces of the ensemble will be thoroughly decontaminated, with the employee still in the ensemble. Employers must have exact procedures for doffing that are written prior to the need for doffing.

When doffing (or removing) an ensemble, the wearer needs to be very careful not to touch any exposed surfaces of the equipment and clothing because there could still be residual contamination. There should also be an assistant for the doffing process, and this assistant must be dressed properly to prevent getting contaminated.

The start of the doffing process depends on how much air is left in the SCBA tank.

• More than five minutes — If more than five minutes of air are left in the SCBA air tank, the process of doffing begins with a thorough decontamination. The decontamination process could vary depending on what hazardous substances the wearer has been in contact with. The steps for doffing the ensemble are as follows:
  1. The wearer removes outer disposable clothing like shoe covers, outer gloves, and tape.
  2. The assistant helps remove the safety boots.
  3. The assistant opens the suit and carefully lifts the hood off the wearer’s head, letting the hood rest on the SCBA tank.
  4. The wearer’s arms are removed from the suit one at a time as the assistant pulls the suit back and away from the wearer.
  5. The wearer removes one leg at a time from the suit. If possible, this step is performed in a sitting position — it’s easier that way.
  6. The wearer follows the employer’s written procedure for doffing an SCBA.
  7. The wearer removes the internal gloves by pulling them down and inside out while taking them off. 8. If contamination is suspected, the wearer removes personal clothing and takes a shower.
• Five minutes or less — If the remaining air in the tank is five minutes or less, the wearer starts the process of doffing by skipping the thorough decontamination process. The goal is still the same, which is to remove protective equipment and clothing without the wearer or the assistant becoming contaminated. However, in this situation, getting the wearer air becomes the priority. Here are the steps:
  1. The wearer goes straight to removing any disposable clothing such as boot covers or shoe covers, outer gloves, and tape.
  2. Next, the wearer quickly scrubs and hoses off the suit, paying special attention to the zipper area. This is a quicker decontamination process, so extra caution is needed.
  3. The wearer opens the zipper just enough to reach the regulator and breathing hose. Immediately, another tank is attached to the breathing hose. Note: This procedure does help prevent contamination spreading to the wearer and the assistant, but they both need to proceed with caution, knowing there may be residual contamination on the wearer’s PPE and CPC.
  4. Once the wearer has air, the rest of the procedure is the same. In this case, the wearer has already removed the outer disposable clothing, so next, the assistant helps loosen and remove the wearer’s safety shoes or boots and continues with the normal doffing procedure.

Using PPE and CPC

• Employees using PPE and CPC need to take special precautions if they have long hair, tend to grow facial hair, or wear prescription glasses.
• When working in a contaminated area, employees should monitor themselves and their buddies for signs of exposure or PPE/CPC damage.

When it comes to using personal protective equipment (PPE) and chemical protective clothing (CPC), there are individual factors that must be taken into consideration. Because people are all different sizes and shapes, protective equipment and clothing should be provided in many different sizes to accommodate all employees.

Those employees with long hair need to tie it back and wear a protective hair covering to prevent hair from interfering with vision or the seal of the respirator.

No facial hair is allowed when wearing respirators with a tight-fitting facepiece. Even a day or two of growth can break the seal between the face and the respirator, allowing contaminants inside. Employees wearing a respirator must be clean shaven where the facepiece seals to the skin.

For employees with prescription glasses, there are special considerations when wearing a respirator. Regular glasses interfere with the seal of a worn together. Any employee who has prescription glasses and will be wearing a respirator must either have the respirator facepiece equipped with prescription lenses or wear contact lenses.

Chewing gum or tobacco is never allowed in contaminated areas. Employees should never attempt to chew gum or tobacco when wearing a respirator. In addition to providing a route for ingestion, chewing movements can break the seal between the respirator and the employee’s face.

In-use monitoring

When employees are in a contaminated area performing work tasks, they should monitor both themselves and their buddies for:

• Degradation of PPE or CPC
• Unexpected odors
• Skin becoming itchy or irritated
• Unusual residue on equipment or clothing
• Pain or discomfort
• Breathing problems
• Fatigue
• Vision or communication problems
• Movement being restricted
• Any medical issues
• A restricted breathing air line (if using)

Storage, inspection, and maintenance

• PPE and CPC should be stored according to manufacturer instructions, with potentially contaminated materials well separated from uncontaminated materials.
• Maintenance of PPE and CPC should only be attempted by qualified personnel.

Personal protective equipment (PPE) and chemical protective clothing (CPC) can literally mean the difference between life and death for their wearers, so it’s crucial to take care of them properly and make sure they are in excellent condition for each use.

Storage

PPE and CPC should be stored according to the manufacturer’s directions to prevent damage. If stored improperly, they could be exposed to dust, moisture, sunlight, chemicals, extreme temperatures, or impacts, which could cause them to fail when used.

To store PPE and CPC properly:

• Respirators should be taken apart, washed thoroughly, and disinfected prior to storage. They can be stored in their original cases, heat-sealed plastic bags, or resealable plastic bags.
• Clothing that is potentially contaminated should be stored in a separate area that is well-ventilated where it will not come into contact with street clothing.
• To prevent issuing the wrong items, clothing of different types and materials should be stored separately.

Inspection

Protective equipment and clothing should be inspected regularly. In fact, the first inspection happens when the items are received from the manufacturer or supply store, prior to being put into service.

Records should be kept each time an inspection occurs, documenting the item’s identification number if applicable, the date of inspection, the inspector’s name, and the condition of the item.

Other inspection times include when the equipment and clothing is issued for use, after use (even if only used for training), any time a problem or concern arises, and periodically while in storage.

Conditions to watch for when performing an inspection on PPE or CPC items include:

• Imperfect seams;
• Non-uniform coatings;
• Tears, cracks, punctures, or pinholes;
• Malfunctioning closures;
• Discoloration;
• Swelling or stiffness of material;
• Non-operational pressure relief valves in fully encapsulating suits;
• Loosened material around wrists, ankles, and neck; and
• Cracks, crazing, or fogginess on facepieces, goggles, or face shields.

If permeation of chemicals is suspected, CPC should be checked thoroughly inside and out for any signs of discoloration or degradation. With permeation, decontamination cannot remove the chemicals that have seeped into the fabric. These chemicals can continue to seep through and reach the inside of the clothing, where they will contaminate the next person who wears the CPC.

If any issues or concerns arise during inspection of PPE or CPC, the items of concern should be removed from service and either repaired if possible or discarded appropriately.

Care and maintenance

PPE and CPC should be handled with care to preserve their integrity. They should never be set down in dusty, dirty areas or left where they are exposed to elements like rain, direct sunlight, or extreme temperatures.

Employers’ PPE programs must cover the maintenance of PPE and CPC. Many manufacturers will only allow persons who are specifically trained and authorized to perform maintenance on their products.

There may be a specific person or department at a workplace with the knowledge, training, and authorization to perform maintenance, or items requiring maintenance may need to be sent to an authorized person or place offsite.

No one should attempt to perform maintenance on any PPE or CPC without the proper qualifications to do so.

Temperature extremes

• PPE and CPC can combine with heat or cold to make work conditions extra dangerous, but this hazard can be mitigated by choosing gear carefully for the situation.

The selection of PPE and CPC can be a complex process, especially when chemical exposures and extreme temperatures are combined. Employers should provide clear guidance to employees so that they can make informed choices about how to dress during extreme hot or cold conditions.

Hot environments

Many of the tasks performed at a hazardous waste cleanup site require the use of personal protective equipment (PPE) and chemical protective equipment (CPC), which protect workers from physical, chemical, and biological hazards. However, these present additional risks when it comes to working in hot environments.

The good news is that there are devices employees can wear to help keep their body temperature from rising while wearing PPE and CPC, including:

• Cooling vests or ice vests,
• Water-cooled garments, and
• A personal cooling system with circulating cool air that blows into the suit.

When wearing a respirator, employees should choose either a powered air-purifying respirator (PAPR) or a supplied-air respirator (SAR) if possible. These types of respirators can have a cooling effect because of the airflow they provide.

Cold environments

Where chemical exposures exist, choosing protective gear requires a balance to be struck between dressing for chemical and cold hazards. For instance, a totally encapsulating suit does not provide an outer layer that has ventilation; therefore, it could cause the wearer to overheat, even when working in the cold.

That doesn’t mean employees should avoid wear encapsulating suits, but they should pay special attention to their condition when they do. Should suits cause employees to sweat in a cold environment, they may even need to exit the Exclusion Zone to change their PPE ensemble more often during a job.

If an employee must wear a tight-fitting respirator, then a knit mask would not be allowed because it would break the seal of the facepiece. In this case, a hat or hood could be worn over any respirator straps.

Detectable hazards

While atmospheres can be hazardous, the good news is monitoring and sampling can detect many of these hazards. The following hazards are detectable through monitoring and sampling:

• Radioactivity
• Oxygen deficiency
• Oxygen-rich atmospheres
• Flammability
• Toxicity
• Reactivity
• Corrosives
• Pathogenicity

Monitoring versus sampling

• Monitoring produces instantaneous data, but these data can be incomplete due to the limitations of the direct-reading instruments.
• Sampling produces more complete data but requires more equipment and more time because results must be obtained from a lab.

The terms “monitoring” and “sampling” may seem synonymous, but they’re not. Here’s the difference:

• Monitoring uses direct-reading instruments to produce instantaneous data, and
• Sampling uses a pump or other collection device to produce samples that must be sent to a laboratory for analysis.

Monitoring

To monitor conditions, direct-reading instruments are used to produce instantaneous data. Because the data are instantaneous, employees are alerted to changing conditions quickly.

Using direct-reading instruments to monitor conditions has its advantages and disadvantages. Direct-reading instruments have an advantage because they:

• Provide a rapid (real-time) response,
• Can identify certain conditions such as IDLH (immediately dangerous to life or health) and oxygen deficiency, and
• Allow protective measures to be implemented quickly.

The disadvantages of direct-reading instruments are that:

• They usually cannot detect airborne contaminants at extremely low concentration levels;
• They are generally limited to detecting or measuring a specific class of chemicals;
• They may not detect certain classes of compounds; and
• Other chemicals can potentially cause interference, which may result in false readings.

Because of the limitations of direct-reading instruments, their results should be interpreted conservatively. Anyone using an instrument for monitoring must first be qualified to use it and familiar with its limitations.

When hazardous substances are unknown but the direct-reading instrument is giving a response, these contaminants should be reported as “needle deflection” or “positive instrument response” instead of a specific concentration.

Also, if there is no response or the instrument gives a reading of zero, this should be reported as “no instrument response” rather than “clean,” due to the possibility that substances were just not detected by the instrument.

Sampling

Sampling uses a device and some type of sampling medium to take samples that must be sent to a lab for analysis. Often this approach involves a pump that draws air through either a filter or sorbent.

Note: Only labs that are accredited by the American Industrial Hygiene Association (AIHA) should be used for analyzing samples. Labs have more sophisticated instruments for detecting hazardous substances. Therefore, the advantages of using a lab are that it:

• Can detect low-level concentrations,
• Has greater accuracy, and
• Can detect compound or class-specific substances.

On the other hand, because sending samples to a lab requires more time, some of the disadvantages are that:

• Results are not immediate;
• Conditions may change by the time results are received; and
• Sampling requires additional pumps, media, and analytical support.

To help remedy the disadvantages, sometimes onsite labs or mobile labs are used. Mobile labs tend to be located inside a mobile trailer and feature a few analytical instruments that can quickly identify and quantify contaminants.

Monitoring and sampling combined

There is no single instrument that can detect all hazardous contaminants. Generally, neither monitoring nor sampling alone can provide all the information each worker needs. Likewise, when determining the atmospheric hazards that may be present, it’s a good idea not to rely on just one device.

Instead, performing a combination of monitoring and sampling may provide enough information to ensure sufficient precautions are taken to keep exposure to hazardous substances under the limits. Together, monitoring and sampling support each other.

Air monitoring and sampling

• Air monitoring and sampling should be conducted to identify IDLH conditions, monitor the site overall, assess the perimeter of the site, and check offsite areas that might be at risk from the site.

Breathing in contaminants is a major concern when working at hazardous waste cleanup sites or responding to an emergency release. To protect workers against airborne hazards, air monitoring and sampling are critical.

Paragraph (h) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard lists the requirements for monitoring and sampling. Air monitoring and sampling have four main areas of concern:

• IDLH (immediately dangerous to life or health),
• General onsite,
• Perimeter, and
• Off-site.

IDLH

Checking for IDLH and other dangerous conditions should be the first step in any air monitoring program due to the deadly nature of these conditions. The process requires a variety of instruments that can detect flammable, explosive, oxygen-deficient, radioactive, and highly toxic atmospheres.

Of course, it’s necessary to test any areas where a spill has occurred, and it’s a good idea to monitor hollows, trenches, tanks, buildings, sumps, or other areas where concentrations may build up.

If substances are lighter than air, monitoring may be important on any elevated terrain on which people are working or under canopies where employees might congregate. Substances tend to disperse in open spaces, but if a release is very large, monitoring open spaces might also be necessary.

General onsite

A variety of instruments should be used when conducting general onsite monitoring. However, the first thing to do is identify the source of airborne contaminants, then begin monitoring downwind from that source, gradually working upwind.

Crosswind sections and areas upwind from the source should also be monitored to ensure there is no background interference and that contaminants are originating from the identified source.

Perimeter

Perimeter monitoring means using fixed locations along the site’s fence line and at work zone borders. This helps to verify conditions and the legitimacy of work zones and clean areas. It also helps ensure the safety of the surrounding community.

Off-site

Offsite monitoring is used to verify that airborne contaminants are not traveling to surrounding communities or affecting the environment. Considerations for where to monitor offsite include:

• Wind direction
• Wind speed
• Humidity
• Other environmental factors

If through monitoring, it’s found that multiple contaminants are present, it may be effective to monitor for just one of the contaminants, which is referred to as the “sentinel” or “indicator substance.”

However, this only works if the “indicator substance” is representative of the other contaminants. And the contaminant chosen should usually be the one with the lowest permissible exposure limit (PEL).

All work zones should be monitored and sampled for airborne contaminants, including the Exclusion Zone (EZ), the Contamination Reduction Zone (CRZ), and the Support Zone.

Personal sampling

• Employees may participate in personal sampling by wearing a sampling device such as a passive dosimeter clipped to their clothing or having their skin, breath, body fluids, and so forth tested for contaminants.

Employees may be asked to wear a personal sampler while conducting work activities. Selecting who will wear personal samplers is based on which employees will be closest to the source.

Personal samplers usually consist of:

• A pump unit, which is worn on a belt around the waist;
• A tube for drawing air through; and
• Some type of collection media, like a filter or canister of sorbent material.

It’s important to target the breathing zone when wearing sampling equipment. To stay in the breathing zone, the collection media should be fastened outside the facepiece of the respirator close to the employee’s face. That means it’s often secured to the employee’s shoulder or chest.

This type of sampling indicates what the actual inhalation exposure of an employee would be without a respirator. This information is used to help keep an employee’s exposure to airborne contaminants below permissible exposure limit (PEL) values.

Because there can be several different contaminants present, one employee may be asked to change sampling devices several times or each member of a team may be assigned to wear a different sampling device so exposure records can be recorded for each contaminant.

One personal sampling device that’s used is the passive dosimeter. Passive dosimeters are small badges worn clipped to clothing, usually on the collar or a shirt pocket. Hazardous substances are collected on the dosimeter as air passes over it. The dosimeter is then sent to a lab to be analyzed.

A less common type of sampling is dermal sampling, which tries to measure exposure through absorption to the dermal layer of skin using skin washes or wipes, dosimeter patches, or whole-body suits.

Another less common type of personal sampling is biological sampling, where samples of an employee’s blood, urine, and exhaled breath are used to measure contaminants that have made their way into the body.

Personal monitoring can also be performed during work tasks. An employee can monitor for oxygen deficiency, flammability, and radiation by either wearing or holding monitoring equipment that is set to alarm if the readings are too high.

Some monitoring instruments also allow an employee to take a quick sample while working to verify conditions.

Environmental sampling

• Environmental sampling fills in the gaps left by air monitoring, including testing water, soil, surfaces, and drum contents.
• Compatibility testing is a form of environmental sampling that tests whether substances can be mixed safely.

While air monitoring and sampling are critical to employee safety and health, environmental sampling is also important because it helps to identify and assess substances and exposures in the work environment.

Certain substances may only be present in solid or liquid forms that cannot be picked up in air monitoring or sampling. Environmental sampling fills in the gaps.

One type of environmental sampling is water sampling. Water samples can be collected from onsite and local wells, rivers, streams, ponds, lakes, or other bodies of water.

Soil samples can also help determine the spread of contaminants. Leaky drums can leach contaminants into the soil, and airborne contaminants may settle on top of soil and then seep down when it rains. Storage areas and prevailing winds in the area should be considered by anyone collecting soil samples.

Wipe testing, otherwise known as swipe testing, is done by wiping a piece of collection media (like cloth or special paper) over surfaces. These wipe tests are then analyzed for contaminants and can help determine the risk of skin exposures. Wipe tests are used on the inside and outside of personal protective equipment (PPE) and chemical protective clothing (CPC) to verify that they are free of contamination.

To verify or identify the substances in drums, drum sampling may be performed. There are several instruments to choose from when taking a drum sample. The most common is a glass rod called a “thief.” Drum sampling should be done with caution, however, and the employer should have specific safety procedures to follow while performing this task.

Another form of environmental sampling, compatibility testing, is used to determine if different hazardous substances can be mixed together safely. Samples of each substance are sent to a lab for compatibility testing. If the tests come back as compatible, it should be safe to mix them, but if they come back as incompatible, mixing them could be very dangerous.

All the water and soil samples, swipe tests, and drum samples collected can also be tested at a lab that has instruments capable of detecting even small amounts of hazardous substances.

Timing of monitoring and sampling

• Monitoring and sampling should be performed upon first entering a contaminated area, periodically to check for changes, when hazardous waste cleanup begins, and before and during confined space entry.

The Occupational Safety and Health Administration (OSHA) requires hazardous waste site employers to address monitoring and sampling frequency in the site safety and health plan. The plan should address monitoring and sampling performed:

• At initial entry,
• Periodically,
• After commencing hazardous waste cleanup, and
• Before and during confined space entry.

Initial entry monitoring

Upon first entering a contaminated area, initial entry monitoring is used to assess what hazardous substances are present, their concentration levels, and any other hazards. Monitoring during an initial entry must look for:

• Oxygen-deficient atmospheres,
• Any exposure to radioactive materials that exceed dose limits,
• Other IDLH (immediately dangerous to life or health) atmospheres,
• The presence of flammable or other dangerous atmospheres, and
• Any exposure over the permissible exposure limit (PEL) or published exposure level.

Typically, visual observations and direct-reading instruments are used during an initial entry because the employees need to be aware of the conditions quickly and there could be changing conditions that they must to be alerted to immediately.

Sampling is not always performed during initial entry; however, the employer may call for sampling to confirm monitoring results, detect low-level concentrations, or detect certain compounds or class-specific substances that monitoring devices are unable to detect.

Periodic monitoring and sampling

Conditions can change at any time during hazardous waste cleanup; in fact, the work activities themselves can cause conditions to change. Therefore, periodic monitoring and sampling must also be performed during these cleanup operations either to verify conditions haven’t changed or to document the change.

Certain events must prompt periodic monitoring, such as:

• Work begins in a new area,
• New work tasks and activities are initiated at the site,
• Newly identified hazardous substances are handled,
• Work is conducted in areas with liquid contamination like a spill or lagoon, and
• Leaking drums are handled.

Periodic sampling should be done as appropriate, and certainly if conditions are suspected to have changed. The data collected from periodic monitoring may actually help to determine when periodic sampling is needed.

After commencing hazardous waste cleanup

During hazardous waste cleanup activities, personal sampling must be done after the actual cleanup phase of any hazardous waste operation starts. For example, when soil, surface water, or containers are moved or disturbed, personal sampling must begin.

The employer must take personal samples of those employees who are likely to have the highest exposure to hazardous substances. When selecting the employees for personal sampling, the employer must consider what tasks employees are performing and their proximity to contaminants.

If the highest exposure from initial personal sampling during cleanup activities is above the PEL, then all employees at risk must undergo personal sampling.

Before and during confined space entry

Before anyone enters a confined space, the air must be monitored for hazardous conditions. Calibrated, direct-reading instruments must be used to test for:

• Oxygen content
• Flammable gases and vapors
• Potential toxic air contaminants

While inside the space, periodic or continuous monitoring of atmospheric hazards is required.

If atmospheric testing reveals a hazard, special safeguards — like forced air ventilation and continuous monitoring — must be used to make entry, and work, safe.

Analyzing results

• Factors that can influence monitoring and sampling results include temperature, wind speed, rainfall, moisture, vapor emissions, and work activities that may disturb hazardous substances.

Reading the output of instruments varies from easy to difficult. Employees must have hands-on training on each type of instrument they will be using. Only qualified personnel should analyze results.

Concentrations of solids are measured as milligrams per cubic meter of air (mg/m3), and air contaminants are measured in parts per million (ppm) of air.

It’s a good idea to verify sets of data against each other — for instance, by checking personal sampling information from the lab against the results from direct-reading instruments, or by using one instrument to confirm another instrument’s result.

Analyzing results helps ensure proper control measures and proper selection of personal protective equipment (PPE) and chemical protective clothing (CPC). Also, it helps assess if any changes are needed in the monitoring and sampling program.

If an instrument doesn’t show a reading, this doesn’t necessarily mean there is no hazard. It’s possible the instrument isn’t the right one for detecting the contaminant present.

Factors affecting results

Certain factors should be considered during analysis of any monitoring instrument readings or data collected from samples. That’s because these factors can influence monitoring and sampling results. These influencing factors include:

• Temperature — The vapor pressure of most chemicals increases in higher temperatures.
• Wind speed — Higher wind speeds can affect dusts, particulates, and vapor concentration levels.
• Rainfall — Rain can reduce airborne dusts, particulates, and vapor concentration levels.
• Moisture — Moisture can affect sampling results’ accuracy. Dusts are especially sensitive to moisture.
• Vapor emissions — Evaporation can cause vapor emissions and produce high concentrations.
• Work activities — Work activities can disturb hazardous substances, causing them to become airborne and creating higher concentrations.

Records

• Records of monitoring and sampling activities must be kept for at least 30 years.

The results of monitoring and sampling activities are considered exposure records, which employers are required to keep for at least 30 years. Therefore, it’s extremely important to maintain accurate records.

Specific information must be documented when samples are collected. The type of sample will determine which of the items listed below are pertinent:

• Name of employee sampled and person collecting the sample;
• Task being performed during sampling;
• Suspected contaminants;
• Level of personal protective equipment (PPE) worn by employee;
• Pump flow rate at beginning and end;
• Start and end times of sample;
• Date;
• Location, which may include a map;
• Sample number or identification;
• Environmental conditions like temperature, humidity, and wind speed; and
• Total volume of sample.

It’s also important to keep records of any readings taken out in the field using direct-reading instruments. These readings are usually entered in a logbook that includes all the pertinent information listed above.

The chain-of-custody forms and any documentation received from the lab are also important for recordkeeping. The lab will send back a report with its findings, including what contaminants were detected and the concentration levels of each contaminant.

Drum handling

• Handling drums has many dangers, both chemical and physical, and drum handling should be done as little as possible.

Handling drums of hazardous substances is extremely dangerous and should be kept to a minimum. Whether drums should be handled or whether they should be staged in specific areas are decisions that need to be made prior to certain activities.

Employers and their employees must always keep the dangers in mind and ensure drums are not handled more than absolutely necessary.

Typical steps involved in handling and shipping drums include:

• Inspecting drums;
• Creating a plan for handling drums;
• Handling drums to orient them for opening and sampling;
• Opening drums;
• Sampling drum contents;
• Characterizing drum contents;
• Bulking (transferring drums into bulk containers);
• Staging (in the above steps) in order to organize drums for opening, sampling, characterizing, and bulking activities; and
• Shipping drums or bulk containers offsite for treatment, storage, or disposal.

Hazard awareness

It’s the contents of the drums that make handling them so dangerous. The hazardous substances within drums could potentially cause:

• Detonations
• Fires
• Explosions
• Vapor generation

Handling drums also comes with the risk of physical injuries like cuts and scrapes, musculoskeletal disorders (MSDs), or struck-by incidents.

With so many risks involved, employers are required to ensure there are procedures in place that incorporate all the applicable regulations under the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT).

Inspecting drums

• Inspection of a drum should look for signs of deterioration or pressure as well as symbols, labels, and the construction of the drum, which provide information about the drum’s contents.
• Drums buried underground can be located using a variety of ground-penetrating systems.

Before drums and containers are handled and moved, they should be inspected to gather information about their contents and integrity.

Sometimes drums and containers are stored in a manner that makes it difficult or impossible to inspect them prior to moving, as when they’re buried or stacked. In this case, they should be moved just enough to allow for an inspection before they are moved any further.

What to watch for when inspecting a drum includes:

• Symbols, words, labels, or other markings that indicate the contents;
• Signs of deterioration, like corrosion, rust, punctures, or leaks;
• Signs of bulging or swelling, indicating the drum is under pressure;
• The material the container is made of; and
• The configuration of the drumhead:
  • If the drum lid is removable, the drum was designed for solids; and
  • If the drum lid has a bung hole, the drum was designed for liquids.

The material a drum is made of can be a clue to what type of hazardous waste might be inside. For instance:

• Polyethylene drums or drums lined with polyvinyl chloride (PVC) often contain strong acids or bases;
• Exotic metal drums like nickel, aluminum, and stainless steel might contain extremely dangerous material;
• Single-walled drums used as pressure vessels often contain reactive, flammable, or explosive materials; and
• Laboratory packs might contain incompatible materials; shock-sensitive materials; or highly volatile, corrosive, or toxic materials.

Before approaching drums or other containers for an inspection, the area should be monitored for radiation, organic vapors, and combustible gases to help classify any potential hazards. If there are any extremely swollen or bulging drums, they should not be approached until safety precautions can be put in place.

Drums with no labels or markings should be assumed to contain hazardous substances and handled accordingly. In addition, labels are not always accurate. Sometimes drums are mislabeled, especially if they have been reused.

If drums are buried underground, ground-penetrating systems must be used to help locate them and estimate the depth. One or more of the following systems may be considered:

• Electromagnetic wave
• Electrical resistivity
• Ground-penetrating radar
• Magnetometry
• Metal detection

Planning to handle drums

Each step of a drum-handling operation must be carefully planned to minimize the movement of drums. The information from drum inspections should be reviewed to determine:

• What hazards are present,
• Which drums need to be moved in order to open and sample them,
• The extent of handling necessary for the operation,
• Which personnel will perform handling operations, and
• Procedures for handling.

Once handling operations begin, new information about the contents or hazards may make it necessary to stop and revise the plan. Employees should always be on alert for new information.

Handling drums

• Drums of hazardous waste must be handled carefully.
• Safe practices include safeguards against electrical, fire, and chemical hazards.

The purpose of drum handling is to respond to obvious problems, stage drums for sampling activities, and organize drums for characterization.

Before anyone handles drums, employees must be aware of the hazards involved. Drums should only be handled if necessary. Other precautions to take during drum handling activities include:

• Warning personnel (prior to moving drums) that movement will be starting;
• Keeping overpack drums and sorbents nearby;
• Having a containment program in place in case of major spills; and
• Having trained spill responders on standby.

Heavy equipment like front-end loaders and rough terrain forklifts is often used for excavating around buried drums, removing drums from pits and trenches, and loading and transporting drums to storage or staging areas. Precautions to take when using heavy equipment include:

• Staying within the load capacity of equipment used;
• Providing air conditioning in equipment cabs;
• Protecting the equipment operator with splash shields;
• Ensuring operators of heavy equipment have a clear view or a signal person; and
• Using bars over excavator bucket teeth to prevent punctures when using an excavator.

A drum grappler is a great piece of equipment to use because it adds a degree of safety by putting distance between the operator and the drum. That way, if the drum detonates or ruptures, chances of the operator getting injured are lessened. Plus, the grappler claws partially deflect the energy from any detonation.

Other equipment used for handling drums may include:

• A roller conveyor with solid rollers,
• Drum carts, and
• Spark-proof tools used for opening and closing drums.

Safe practices

Safe practices must always be followed during work with drums of hazardous waste. Examples include:

• Using proper lifting techniques;
• Using extreme caution with drums that are not intact or not tightly sealed;
• Never pushing, rolling, or dragging drums;
• Allowing enough space between drums for people to move around and retreat quickly if needed;
• Grounding any equipment used to transfer waste to new drums;
• Always using respiratory protection, other personal protective equipment (PPE), and chemical protective equipment (CPC) that’s required;
• Abiding by any “no smoking” signs;
• Following the site’s emergency procedures if there is an actual or imminent release, fire, explosion, or other emergency; and
• Ensuring drums and containers meet appropriate Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations.

Environmental practices

Some key EPA hazardous waste container management provisions to keep in mind, if applicable, include the following:

• Use containers made of or lined with materials that will not react with, or are otherwise compatible with, the waste to be stored;
• Always keep hazardous waste containers closed during storage, except when it is necessary to add or remove waste;
• Keep containers of ignitable or reactive waste at least 50 feet from the facility’s property line;
• Separate or protect ignitable or reactive waste from sources of ignition, such as open flames, welding, sparks, or smoking;
• Do not place incompatible wastes (or incompatible wastes and other materials) in the same container;
• Do not place hazardous waste in an unwashed container that previously held an incompatible waste or material; and
• Provide a label (also known as an accumulation label) on the hazardous waste container during storage.

Special precautions with certain drums

• Drums that may be shock-sensitive or explosive should be handled with particular care, including movement-signaling alarms and continuous communication among site personnel.
• Leaking, open, or deteriorated drums should be moved to an overpack using a drum grappler.

Some drums require special precautions. For instance, any drums that have levels of radiation above background radiation should not be handled until an expert such as a health physicist has been consulted. Other special precautions to take with certain drums relate to the following:

• Shock-sensitive or explosive drums — Employees should seek special assistance before handling drums containing explosive or shock-sensitive waste and use the following precautions:
  • Handle with extreme caution,
  • Ensure non-essential personnel are at a safe distance,
  • Use a drum grappler constructed for explosive containment,
  • Use an audible alarm to signal the start and end of handling activities,
  • Maintain continuous communication with the site safety officer or command post while handling, and
  • Palletize and secure drums prior to transport.
• Bulging drums — If possible, bulging or swelling drums should not be moved. Instead, the cause of the swelling should be determined (if possible) and containment procedures should be implemented to protect people from eruption of the drums. If a bulging drum must be moved, a drum grappler should be used, and the drum should be moved only as far as necessary to firm ground or placed in an overpack.
• Lab packs — Lab packs usually contain several different individual containers that are typically surrounded by absorbent cushioning material. The waste in lab packs should be considered explosive and shock-sensitive until proven otherwise through characterization. Not just anyone can open a lab pack. Lab packs can only be opened by personnel specially trained in the inspection, classification, and segregation of the containers within the pack. Hazards that may be encountered in lab packs include:
  • Incompatible materials
  • Radioisotopes
  • Shock-sensitive materials
  • Highly volatile materials
  • Highly corrosive materials
  • Very toxic chemicals
  Precautions to take when working with lab packs include:
  • Making sure non-essential personnel are at a safe distance;
  • Using a drum grappler for explosive containment;
  • Maintaining continuous communication with the Site Safety Officer or the command post while handling;
  • Having a chemist inspect, classify, and segregate the waste containers within the pack without opening them;
  • Packing the unopened smaller containers in drums with sufficient absorbent and cushioning material;
  • Treating the material as shock-sensitive if crystalline material is noted, and getting expert advice; and
  • Palletizing and securing repackaged drums prior to transport.
• Leaking, open, or deteriorated drums — A drum grappler should be used to place the following drums in overpacks:
  • Leaky drums containing sludge or semi-solid material,
  • Open drums containing liquid or solid waste, and
  • Deteriorated drums that can be moved without rupturing.
  If any of these leaky, open, or deteriorated drums contain liquids and cannot be moved, the contents should be pumped to a different drum using grounded equipment. In fact, the Environmental Protection Agency (EPA) may require a site to transfer hazardous waste from a drum in poor condition to a sound container or otherwise manage the waste in some other way that complies with requirements.
• Buried drums — With ground-penetrating systems, once buried drums are located and their depth is known, the following precautions should be used:
  • Use a drum grappler, if possible;
  • Remove the soil with extreme caution; and
  • Have a dry chemical fire extinguisher on hand.

Opening drums

• Opening drums safely requires appropriate PPE/CPC; atmosphere-monitoring equipment; and precautions against chemical, fire, and physical hazards.

Whether drums are opened in place or moved to a staging area for opening, the procedures remain the same. Employers must have specific procedures for drum opening. Employees need to become familiar with these procedures prior to opening any drums.

Because several types of atmospheres might develop during drum opening, respiratory protection is required. Anyone opening a drum must wear an atmosphere-supplying respirator (ASR), either:

• A self-contained breathing apparatus (SCBA), or
• A supplied-air respirator (SAR).

Anyone using an SAR should make sure the air supply is in a clean area, protect the hose from damage, and carry an escape SCBA.

To monitor conditions during drum-opening activities, the sensors of direct-reading instruments should be placed as close to the source as possible. Monitoring for different types of atmospheres can be done using:

• Colorimetric tubes
• Dosimeters
• Radiation survey instruments
• Explosion meters
• Organic vapor analyzers
• Oxygen meters

During the opening process, employees should stand back as far as possible. If it’s necessary to be closer, explosion-resistant plastic shields should be placed between any persons and the drum. The controls for drum-opening equipment, monitoring instruments, and fire-suppression equipment should be located on the person side of the shield.

Using remote-controlled equipment adds another layer of protection. The following devices can be used for opening drums:

• A pneumatically operated impact wrench to remove drum bungs,
• Hydraulically or pneumatically operated drum piercers, and
• Backhoes equipped with bronze spikes for piercing drum tops.

Other precautions to take when opening drums include:

• Only using non-spark tools and equipment when flammable or explosive atmospheres are present.
• Never standing on drums or working from them.
• Never using picks, chisels, firearms, or other means to open a drum in a manner that may rupture the container or cause it to leak.
• Hanging tools to minimize employee exertion.
• Performing all steps slowly and relieve excess pressure on bulging or swelling drums.
• Opening exotic PVC-lined drums by the bung, using extreme caution.
• Not opening or sampling individual containers in lab packs.
• Resealing open bungs as quickly as possible, and, if bungs cannot be resealed, placing the drum in an overpack.
• Decontaminating drum-opening equipment after opening each drum to avoid mixing incompatible wastes.

Drum sampling

• Performing drum sampling safely requires appropriate PPE/CPC and maintaining physical distance from the contents of the drum.

During drum sampling, the potential exists to come into direct contact with the hazardous waste in the drum. That potential makes this task a threat to worker health and safety. Drum sampling should be carefully and thoughtfully planned prior to sampling any drums.

A drum sampling plan should include a description of:

• Expected or potential hazardous waste,
• Which drums will be sampled,
• Sampling devices and containers to be used, and
• The number, volume, and location of samples to obtain.

The plan should also list sampling procedures.

The personal protective equipment (PPE) and chemical protective clothing (CPC) worn during drum sampling should be selected by a professional trained in health and safety.

Proper drum sampling techniques include:

• Staying at a safe distance until drum opening is complete before performing sampling;
• Not leaning over a drum while sampling unless absolutely necessary;
• Covering drum tops with plastic sheeting to prevent the spread of contamination;
• Not standing on drums, but instead using a platform or mobile steps when gaining height is necessary;
• Using glass rods or vacuum pumps to obtain samples;
• Preventing cross-contamination and mixing incompatible wastes by not using contaminated items for sampling; and
• Removing glass rods prior to pumping.

Drum characterization and compatibility testing

• Drum characterization collects information on the contents of the drum so that it can be handled safely.
• Compatibility testing observes the behavior of different types of wastes when mixed together.

After sampling, the next step in the drum-handling process is to characterize the contents so wastes can be packaged and transported safely. Each drum is scanned for radioactivity as it is opened. If the scan is negative, a sample is taken.

Compatibility testing is performed on the collected samples, and the wastes are classified into general categories:

• Auto-reactives
• Water reactives
• Organic acids
• Inorganic acids
• Bases
• Heavy metals
• Pesticides
• Cyanides
• Organic oxidizers
• Inorganic oxidizers

Classifying wastes into general categories helps determine which wastes can safely be bulked together in a larger container without the risk of fire or explosion. If drums will be stored or staged for transport, this classification helps determine which drums can safely be stored or staged together.

It’s a good idea to fill out a form for each characterized drum, including information such as:

• The physical state of the waste;
• Any instrument readings;
• Drum type, color, size, condition, markings, and opening type; and
• Quantity and color of the drum contents.

Characterization of wastes should be performed by trained and experienced personnel.

For drum characterization, an onsite lab should be used if available. This will provide quicker results and reduce the risks of transporting samples. If samples do have to be shipped for testing, any hazardous waste shipments including samples must be shipped in accordance with Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations.

Compatibility tests are often performed on wastes in a controlled environment. Small amounts of different wastes are added together and then observed for vapor generation, heat generation, or any other reactions.

Staging drums

• Drum staging involves moving drums in an organized manner to predesignated areas.
• There are five types of staging areas — initial staging, opening, sampling, holding, and bulking.

Although every attempt should be made to minimize drum handling, drums must sometimes be staged (or moved in an organized manner to predesignated areas). Staging may facilitate drum opening, sampling, characterization, and bulking. It may also be used to protect drums from heavy equipment and high temperatures that may cause explosion, ignition, or pressure buildup.

The number of staging areas needed is specific to the site and dependent on the scope of operation, accessibility, and potential hazards of drum contents. However, the number of staging areas should be kept to a minimum. Staging drums is a trade-off between increased hazards from drum movement and decreased hazards from organizing and accessing wastes.

Each staging area should be set up with enough space that heavy equipment and other vehicles can access the area and move around easily. Separation between areas is also helpful in maintaining safe operations. In the event of a fire or explosion, it may prevent a chain reaction.

Some sites use up to five staging areas, including:

• Initial staging — This is where drums are stored prior to opening and sampling. In this area, drums get organized by suspected hazards and drum type and size.
• Opening area — Drum opening, sampling, and resealing occurs here. This area should be located a safe distance from all other areas.
• Sampling area — A separate sampling area may be set up during emergencies or large-scale operations. This reduces the number of personnel in the opening area in case of an explosion.
• Holding area — Drums can be stored in a holding area to be characterized. If any drums with unknown contents are in this area, they must be sealed to prevent incompatibility hazards.
• Bulking area — After wastes are characterized, the drums are placed in the final staging area or bulking area, where they are bulked for transport to a treatment, storage, or disposal facility.

The bulking area should be located as close to the site exit as possible. The area should be graded, covered with plastic sheeting, and surrounded by a dike to prevent the spread of contamination if a spill occurs.

The drums in the bulking area should be further separated by the hazards determined during characterization. Dikes, berms, walls, or other structures should be installed around each segregated area. This approach contains spills and keeps incompatible wastes from mixing should containers break or leak.

Between drums, there must be enough aisle space to allow quick escape from the area and to make room for equipment for drum handling, fire protection, spill control, and decontamination.

Staging areas must be equipped with firefighting equipment, an internal communications or alarm system, and a telephone or other device to summon emergency assistance.

All drum staging areas must be inspected weekly to look for leaking and deteriorating drums. If unsound drums are found, waste must be transferred from them to containers in good condition. Any leaks that occur should be cleaned up immediately.

Bulking materials

• Bulking means combining wastes (with careful attention to their properties and compatibility) in bulk containers for transport.

Bulking means to combine wastes in bulk containers like tanks, vacuum trucks, or trailers for shipment offsite to a treatment, storage, and disposal (TSD) facility. Before any wastes can safely be combined, they must go through a thorough characterization.

Before any wastes are bulked, the larger container must be clean and free of any residual contaminants, which could be incompatible with the wastes being transferred.

It’s important to understand the physical properties of the wastes being bulked. Some may require room for expansion, while others may need to completely fill the container, with zero headspace.

Extra precautions to take when bulking liquids include:

• Only using pumps rated by the National Fire Protection Association (NFPA);
• Ensuring pumps have a safety relief valve and a splash shield;
• Ensuring hoses, casings, fittings, and gaskets are compatible with the wastes being transferred;
• Inspecting hose lines, fittings, and valves for weak spots and ensuring everything is assembled properly;
• Using caution when handling hoses;
• Staying protected from splashing;
• Protecting the hose lines from any traffic in the area; and
• Using only approved containers to bulk flammable liquids.

Shipment of materials

• When drums must be shipped, they can’t be overfilled and must be secured and covered in the transport vehicle.
• Hazardous waste shipments must comply with OSHA, EPA, and DOT regulations.

Some important safety measures apply to preparing or shipping materials. For example, the bulking area should be as close to the site exit as possible. The flow of traffic may require careful planning to minimize conflict. Hauling vehicles must have ample space to move around, and roads must be kept in good condition. Also, vehicle operators must always obey any traffic lights or signs.

When vehicles arrive, operators should be directed to park in a safe area and stay in the cab until it’s time to start loading. Before loading begins, the vehicle operator must have any personal protective equipment (PPE) or chemical protective clothing (CPC) needed in the loading area.

Vehicle loads of bulked solids should go no higher than a couple inches below the container rim. To prevent the release of contaminants during transport, waste solids should be covered with a layer of soil, foam, and/or a tarp. Lastly, the load must be secured to prevent any shifting during transportation.

Bulking is not always an option, so sometimes it’s necessary to ship drums. Safety measures to adhere to when loading drums include:

• Ensuring each drum is closed in accordance with the drum manufacturer’s closure instructions. If the manufacturer is unknown and no closure instructions are available, repackage the waste (or use an overpack) and follow the packaging manufacturer’s closure instructions.
• Ensuring truck brakes are set and wheels chocked.
• Using an overpack for any leaking or deteriorated drums.
• Inspecting the truck bed to ensure it’s both clean and flat for the safe transport of drums.
• Not double stacking drums.
• Securing the load to prevent drums from moving or shifting.

Both trucks and roads have weight limitations. It’s a good idea to occasionally stop loading and weigh the transport vehicle to make sure those limitations will not be exceeded.

Transport vehicle tires should be decontaminated prior to leaving the site so public roadways are not contaminated. The truck operator should check the load occasionally to ensure no dust, liquids, or vapors are being released while in transport.

Regulations

All shipments of hazardous waste must comply with Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations:

• OSHA — OSHA regulates the shipment of hazardous waste under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. This regulation’s shipping provisions call for classifying containers, keeping staging to a minimum, providing adequate access and egress routes in staging areas, and bulking only after characterization.
• EPA — This is the agency that enforces the Resource Conservation and Recovery Act (RCRA), a law that gives EPA authority to control hazardous waste from the time the waste is generated until it’s disposed. This time span is called “cradle to grave,” and this duration includes transportation.
• DOT — The DOT regulates hazardous materials (hazmat) under the Hazardous Materials Regulations (HMR). These regulations ensure that hazmat is packaged, handled, and transported in a safe manner.

Special precautions with specific containers

• Tanks, vaults, vacuum trucks, elevated tanks, compressed gas cylinders, and ponds and lagoons all require special precautions to handle them and their contents safely.
• A confined space permit might be required before entering a tank or vault.

Sometimes containers present additional hazards due to their size, shape, location, or pressure. The container types covered below require extra precautions in addition to the general procedures for handling containers.

Tanks and vaults

It’s common to see tanks and vaults at hazardous waste cleanup sites. Note that excess pressure can build up inside a tank or vault. For protection from contaminants that may release when a container is opened, a deflecting shield should be placed between the employee opening the container and the opening.

Once the tank or vault is opened, manholes or access points should always be guarded to ensure no personnel inadvertently fall into the container. The contents should be identified using analysis of sample results, and the container should be characterized. If these results show the contents are safe to move, it may be possible to vacuum the waste into a vacuum truck and have it transported to a treatment, storage, and disposal (TSD) facility.

The tank or vault should be emptied and decontaminated before disposal.

It’s important to know that tanks and vaults are typical examples of confined spaces because they are often large enough to enter, have limited means of entry or exit, and are not designed for continuous occupancy.

Because tanks and vaults have the potential for dangerous atmospheres, a confined space permit may be required just to enter a tank or vault at a site. If a permit is required, the tank or vault is considered a “permit-required confined space.”

If at any time it becomes necessary to enter the tank, employees must adhere to the confined space entry procedures on the permit, along with the requirements of their employer’s written permit-required confined space program. Extra precautions needed for entering a tank or vault include:

• Disconnecting pipelines from the container;
• Obtaining air samples to verify oxygen levels and to check for flammable gases or toxic gases and vapors in the interior container atmosphere;
• Thoroughly purging, inerting, flushing, or ventilating the container to control atmospheric hazards;
• Making sure all entry workers are equipped with respiratory protection, protective clothing, a safety harness and retrieval line, and any other personal protective equipment (PPE), as needed;
• Having a trained attendant in place prior to entry;
• Establishing lifeline signals for communication between entry workers and the attendant;
• Stationing an additional employee in the area to assist the attendant if needed;
• Having the entry supervisor confirm that conditions are acceptable for entry; and
• Ensuring the attendant knows not to enter the area until additional personnel arrive.

Vacuum trucks

A vacuum truck is a tanker truck equipped with a powerful vacuum strong enough to suck sludges, slurries, and liquids into the tank on the truck. It works perfectly for emptying tanks and vaults of hazardous wastes.

Extra measures to take when working with vacuum trucks include:

• Wearing appropriate PPE and chemical protective clothing (CPC) when opening the hatch;
• Using mobile steps or suitable scaffolding if available;
• Avoiding climbing the ladder and catwalk on the vacuum tank;
• Using both hands to grip the side rails of the truck ladder while ascending or descending;
• Hoisting tools or sampling equipment only after reaching the top of the ladder;
• Sampling from the top of the vehicle if possible; and
• Standing off to the side and keeping absorbent materials close by if sampling from the drain spigot.

Elevated tanks

Elevated stationary tanks require the same precautions as vacuum trucks. However, these stationary tanks may also require fall protection, such as guardrails, safety net systems, or personal fall protection. Ladders and railings must also be maintained in a safe condition.

Compressed gas cylinders

Compressed gas cylinders can quickly become an explosion or projectile hazard if they’re damaged. When working with compressed gas cylinders, employees must:

• Handle them with extreme caution;
• Never roll, push, or pull cylinders;
• Use a cylinder cart when moving cylinders;
• Stage cylinders in cool, shaded areas;
• Keep cylinders away from any flames or sparks;
• Record identification numbers to aid in characterization; and
• Ensure cylinders are secured when moving or storing them.

Refer to the Compressed gases subject for further information.

Ponds and lagoons

Wearing PPE and CPC may make it difficult to swim, float, or tread water, creating a drowning hazard for employees near ponds and lagoons. When working around water, employees should take the following precautions:

• Work from shore if possible;
• Use lifeboats, flotation gear, or other necessary safety gear; and
• Be cautious along shorelines, keeping an eye out for solids that may float and give the appearance of a stable surface.

Spill containment program

• Employers covered under HAZWOPER must develop and implement a written spill containment program.
• The spill containment program needs to address hazardous materials onsite and detail potential control and response measures for them.

Although the Occupational Safety and Health Administration (OSHA) does not define exactly what a “major spill” is, the agency does require any employers that have the potential for a major spill to develop and implement a written spill containment program. Elements of a spill containment program are covered below.

Potential spills and available controls

To develop an effective spill containment program, the employer must conduct an assessment of the hazardous substances onsite; operations; and how containers are stored, handled, and transported.

After a careful assessment of all substances and operations at the site, the employer should document all hazardous substances onsite; any activities with spill potential, with their spill types and locations; and what control measures are available in the event of a spill.

Possible control measures include, but are not limited to:

• Absorbent materials;
• Overpack drums;
• Dikes and berms;
• Inflatable containment (like “kiddie pools”); and
• Pumps, hoses, shovels, and other equipment.

When selecting control measures, the employer must consider the largest possible spill that could occur. It should be noted that the site may be required to provide secondary containment in line with Environmental Protection Agency (EPA) regulations. These structures may require containment systems that:

• Have a “sufficiently impervious” base to contain leaks, spills, and accumulated precipitation until the material is detected and removed;
• Have a base that slopes or drains unless containers are elevated or protected from contact with accumulated liquids;
• Have sufficient capacity for 10 percent of the total volume of all containers in a containment system, or 100 percent of the volume of the largest container, whichever is greater;
• Have sufficient excess capacity to contain any run-on (such as rainwater, leachate, or other liquid that drains over the land), or otherwise prevent run-on from running into the containment system; and
• Remove any spilled or leaked waste or accumulated precipitation from the containment area in a timely manner to prevent overflow of the system.

Federal, state, and local secondary containment provisions that apply to a cleanup site may be more stringent.

Initial spill notification and response

The second element of the spill containment program must address who to call if a spill should occur, what information to provide during notification, and what response is expected, including when to activate the emergency response plan (ERP).

Site personnel should become familiar with their site’s spill containment program for specifics. However, upon discovery of a spill, this element of the program can provide instructions for:

• Summoning help;
• Alerting nearby personnel;
• Moving to a safe location;
• Contacting emergency medical services, if needed; and
• Keeping unauthorized personnel away from the spill.

Different employees may have different roles in the event of an emergency, depending on their level of training. All employees should know what their role is and what is expected of them should a spill occur.

Spill evaluation and response

The directives in the third spill containment program element include evaluating the spill and determining what type of response is needed to handle it. An authorized individual should identify the hazards associated with the hazardous substance involved and the spill volume and conditions. This individual will then determine whether the spill is:

• Incidental, and can be handled safely by site employees;
• More than incidental, and the ERP must be activated; or
• More than incidental, and external response organizations are needed.

If the spill is determined to be incidental, response personnel will rely on their training under the Personal Protective Equipment (PPE) and Hazard Communication standards to handle the spill. They may also be briefed as to spill conditions, response activities, decontamination, and waste handling.

If the spill is determined to be more than incidental, but response can be handled without outside help, the ERP will be activated, and each employee involved in the emergency response operation should be briefed on:

• The level of PPE and chemical protective clothing (CPC) required,
• Safety procedures,
• Isolating the spill and creating work zones,
• Tasks involved,
• Leak or spill control,
• Any medical care required, and
• Decontamination procedures.

Once the emergency is under control, post-emergency response procedures can be implemented. These will address cleaning up the area, decontaminating personnel and equipment, and properly disposing of the waste.

Post-spill-response evaluation

The spill response effort doesn’t end after control and cleanup activities are completed. Some common expectations and procedures for a post-spill-response evaluation — the last element of a spill containment program — include:

• Ensuring the incident is documented;
• Examining the root cause(s) of the incident;
• Examining response efforts;
• Implementing corrective actions;
• Replenishing supplies and equipment; and
• Ensuring medical, exposure, and monitoring records are completed and maintained.

Spill control measures

• The three methods to address a spill are containing it (e.g., plugging a leak), confining it (e.g., building a dam around it), and controlling it (e.g. neutralizing the substance).

When addressing the hazards of a spill, there are three methods that can be used:

• Contain it — Containing a release is keeping the remainder of the hazardous substance in its container. Examples of containing methods include plugging or patching leaks.
• Confine it — Actions to take to confine a hazardous release and keep it from flowing any further could include using absorbents, diverting a spill, building a dam, or digging a trench.
• Control it — Actions to otherwise control a spill and limit exposure and damages could include improving ventilation or neutralizing the substance, for example.

Everyone who is tasked with containing, confining, and/or controlling a hazardous substance release must be aware of their surroundings and watch for any indication that conditions are changing. Also, they must pay attention to how they are feeling and keep an eye on their “buddies.”

If any signs or symptoms of chemical exposure are present, employees should leave the area immediately. They can then regroup, discuss the new information, and make changes to the action plan.

The personnel authorized to address the release should consider the following factors when deciding what spill control measures to use:

• What the release substance is and its hazards;
• The chemical properties of the substance, including whether it is in solid, liquid, or gaseous form;
• Whether the substance is under pressure;
• Whether the release is on land, in the air, or in water;
• What natural or man-made barriers are already in place; and
• Weather conditions, such as extreme heat and cold, wind speed and direction, and rain.

Containing a spill might include measures such as:

• Plugging and patching,
• Overpacking,
• Shutting off a valve, or
• Rolling and tipping a leaking container so the hole is at the top.

Confining a spill might include the following measures:

• Sorbents
• Drip pans
• Diversion and retention ponds
• Damming, diking, or curbing
• Booming
• Drainage systems
• Vapor dispersion
• Vapor suppression
• Covering the spill

Some measures that can be used to control a spill emergency and limit exposure and damages include:

• Transferring the substance to a new container
• Vacuuming the spill
• Venting gases
• Using dispersants
• Dilution
• Ventilation
• Burning or flaring the substance
• Converting the spill to a gel or solid
• Neutralizing the spill
• Using a chemical to react with the substance

Decontamination basics

• Decontamination is intended to protect employees, contain contaminants, and prevent the mixing of incompatible wastes.

Unfortunately, no matter how well a workplace is safeguarded against contamination, contaminants may still reach employees. Once a person is contaminated, exposure can occur and health effects may result. That means decontamination is critical to:

• Reducing employee exposure to hazardous substances, and
• Protecting employee health.

The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard states that decontamination is the removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects.

Contaminants can be removed:

• Physically,
• Using chemicals to deactivate or neutralize the contaminants, or
• Using a combination of both physical and chemical removal methods.

One way of physically removing contaminants is by washing them off the surface, just as people wash their hands to prevent the spread of germs.

There are many different methods of decontamination that can be applied to employees, tools, equipment (including personal protective equipment, or PPE), instruments, samples, buildings, vehicles, roadways, soil, and even water supplies.

The process of decontamination is sometimes referred to as decon, decontaminating, or deconning. Its purpose is to:

• Protect employees as they remove contaminated PPE and chemical protective clothing (CPC),
• Prevent the mixing of incompatible wastes,
• Prevent others from being contaminated by minimizing the transfer of contaminants and contaminated equipment to clean areas of the site, and
• Protect the community by preventing the migration of contaminants from the site.

Decontamination procedures

Because decon is so critical to employee health, OSHA requires employers to have decon procedures in place. The agency requires all personnel to be appropriately decontaminated when leaving a contaminated area.

The decontamination process includes appropriately disposing of or decontaminating all contaminated clothing and equipment before leaving a contaminated area. The outside of sample containers too should be decontaminated.

Decontaminating PPE is an important part of maintaining its usefulness and effectiveness, along with cleaning, laundering, maintaining, and replacing it as needed.

At a hazardous waste cleanup site, the decon procedures will be part of the site-specific safety and health plan. For emergency response operations, the decon procedures will be part of the emergency response plan (ERP).

Decontamination procedures establish a standard way of performing decon activities. Employers must develop procedures that address:

• The number and placement of decon stations,
• The necessary decon equipment and methods,
• Procedures to prevent contamination of clean areas,
• Procedures to minimize contamination during the removal of PPE and CPC, and
• How to handle clothing and equipment that may not be able to be completely decontaminated.

Employees should read through all decontamination procedures before entering any areas with the potential for exposure to hazardous substances.

It’s also a good idea to run practice drills of decon procedures in non-contaminated areas, especially for the decon of personnel dressed out in their PPE and CPC. These drills may be slow going at first, but with practice, they can help employees perform actual decon activities quickly and efficiently, which may be necessary when an entry worker in a self-contained breathing apparatus (SCBA) is running out of air.

According to the HAZWOPER Standard, decontamination procedures must be monitored to determine their effectiveness. If any deficiencies are discovered in the procedures, steps must be taken to correct them.

Decon methods

• Contaminants can be removed using physical or chemical methods or a combination of the two.

Decon methods include physical and chemical methods or a combination of these methods. If multiple contaminants are present, a combination of both physical and chemical methods may be needed to remove them.

Physical methods

Physical methods are typically used to remove gross contamination. These physical methods of decon often involve one or more of the following:

• Dislodging
• Displacement
• Rinsing with water or a liquid rinse solution
• Wiping off
• Evaporation

Sometimes it may be necessary to use high pressure or heat to help physically remove contaminants. However, these two methods should be used with caution, as they may cause the spread of contamination or burn an employee or equipment.

Contaminants that can be removed by physical means typically fall into three categories:

• Loose contaminants — Dusts, soils, vapors, and particulates are examples of loose contaminants. Most often, loose contaminants can be rinsed off successfully with water alone, soap and water, or a liquid rinse. If they cling statically, anti-static solutions and sprays may help remove them.
• Adhering contaminants — Contaminated glues, cements, resins, and muds adhere and may be harder to remove. Some physical methods of removing adhering contaminants include scraping, brushing, wiping, and melting.
• Volatile liquids — Volatile-liquid-type contaminants are usually allowed to evaporate and then followed up with a water rinse. Using steam jets may help with the evaporation phase, but caution should be taken to prevent inhalation of the vaporized chemicals during this approach.

Other physical methods to consider for removing contaminants include:

• Pressure washing
• Sponge wiping
• Absorbing
• Vacuuming
• Pressurized air jets
• Removal by disposal

Chemical methods

Using chemicals may also take care of contaminants. A common chemical method is to dissolve contaminants in a solvent. There are three types of solvents: dilute acids, dilute bases, and organic solvents. Issues to consider when using solvents include the following:

• The solvent being used must be compatible with the equipment or clothing that is being decontaminated.
• Residues might be left behind on equipment or material.
• Using organic solvents on protective clothing could cause damage to the material or permeation.
• Halogenated solvents are toxic and could cause damage to materials — they should be used only as a last resort if recommended by an industrial hygienist.
• Used solvents must be collected and disposed of properly. Surfactants, such as common household detergents, are also used as a chemical method of contamination removal.

Surfactants reduce adhesive forces between the contaminant and the surface being cleaned. They also prevent the contaminant from redepositing on the surface.

Contaminants can be solidified by:

• Freezing them with ice or ice water,
• Using chemical reactions, or
• Removing the moisture from them with an absorbent material.

Rinsing the surface also helps remove contaminants through dilution, physical attraction, and increased solubility. Continuous rinsing or rinsing multiple times may be required for this method.

Yet another option uses chemical disinfectants, which can inactivate some infectious agents. However, this chemical method does not work well on personal protective equipment (PPE), so disposable PPE is often used when infectious agents are involved.

Other chemical methods that can be used for removal of contaminants include:

• Adsorption
• Neutralization
• Oxidation or reduction
• Irradiation

Decon extent, limits, and effectiveness

• The extent of decon required for an entry worker depends on the type, amount, and location of contaminant; the worker’s job tasks and reason for leaving the area; and the protection in use.

To decide the extent of decon needed for an entry worker, these factors should be considered:

• Type of contaminant,
• Amount of contaminant,
• Level of protection entry workers will use,
• Work function of entry workers,
• Location of contamination, and
• Reason for leaving the contaminated area.

For personnel decon, the type of contaminant plays a big role in the extent of decon required. If the hazardous substance is known to be highly toxic or destructive to the skin, a full decon should be performed. The procedure can be downgraded if the substance is less hazardous.

It’s sometimes possible to determine visually the amount of contamination deposited on protective clothing or equipment. If gross contamination exists, a thorough decon should be performed. High amounts or concentrations of contamination increase the probability of permeation. Contaminants remaining on protective clothing for an extended period may degrade it.

The level of protection can also affect the extent of decon required. Some pieces of equipment or clothing are more difficult to decontaminate. For example, a smooth material like a plastic apron may need only a water rinse, but the straps on a self-contained breathing apparatus (SCBA) may require much more effort.

The employee’s work function or tasks performed can contribute to the extent of decon required. For example, an employee shutting off a valve at the source of a leak will have a different level of contamination than an employee performing monitoring activities along the edge of the leak. The extent of decon required will be different.

The location of contamination also makes a difference. Contamination that has settled on the outer pant leg of an employee’s protective clothing poses less of a risk than contamination around the upper chest and shoulders near the employee’s breathing zone. In other words, the closer the contamination is to the breathing zone, the higher the risk.

Finally, the reason the employee is leaving the contaminated area can impact the extent of decon required. An employee who is leaving the area to drop off or pick up a tool may not require any decon or merely require a partial decon. However, an employee changing a respirator may require some degree of decon. Moreover, an employee who is leaving the contaminated area to go to a different area will require a full decon.

Decon limitations

Of course, decon has its limits. It can even pose hazards to employee health and safety. Limitations include:

• The method used could be incompatible with the contaminant being removed, causing an explosion, heat, or a toxic release.
• Some methods, especially those using organic solvents, can cause permeation or degradation of clothing, equipment, or other surface materials.
• Hazardous vapors used for some chemical decon methods may pose an inhalation hazard and/or be flammable.

The chemical and physical compatibility of the decon method must be determined before it is used. Any method that permeates, degrades, damages, or otherwise impairs the safe functioning of PPE should not be used.

Employers must take measures to adequately protect employees from any decontamination method that poses a direct health threat.

Decon effectiveness

Unfortunately, decontamination efforts are not always effective. The method chosen for decon may work great with one hazardous substance but not at all with another. The good news is that several methods can be used to test the effectiveness of decon, including:

• Visual observation
• Wipe sampling
• Cleaning solution analysis
• Testing for permeation

Effectiveness can be tested for by simply observing the surface material. Things to watch for include:

• Discolorations
• Stains
• Visible dirt
• Alterations
• Degraded materials

Substances adhering to objects may indicate contaminants have not been removed. Some contaminants can be detected with ultraviolet light. However, passing a visual observation test does not necessarily mean the material is free of contaminants. Many contaminants are not easily observed.

One way to assess decon in more depth than visual observation is to perform wipe sampling, in which a wet or dry cloth, glass fiber filter paper, or swab is wiped over the surface of the material or object after it has been decontaminated. This sample is then analyzed in a lab to verify whether the decon method was effective.

Yet another way to measure decon effectiveness is with cleaning solution analysis. If the final rinse solution used in the decon line still has elevated levels of contaminants, additional decontamination may be required.

And last, if visual observation suggests (or the employee otherwise suspects) that a material has been permeated, pieces of the material can be sent to a lab to be tested for permeation.

When decon measures are found to be ineffective, appropriate steps shall be taken to correct any deficiencies.

Decon equipment

• Necessary decon equipment includes supplies for marking and separating contaminated items and areas, supplies for washing, various containers, and general cleaning supplies.

Being prepared to decontaminate personnel and their protective equipment and clothing includes having all the decon equipment and supplies ready and available. It may be helpful to use a checklist to ensure there are enough supplies.

Some of the supplies and equipment needed to decontaminate personnel and their protective equipment and clothing include:

• Drop cloths or sheets of plastic to set heavily contaminated equipment and clothing on;
• Lined collection containers for items to be discarded;
• Tubs, tanks, or wading pools to hold wash and rinse solutions;
• Wash and rinse solutions;
• Long-handled, soft-bristled brushes;
• Paper or cloth towels;
• Folding chairs to sit on when removing boots;
• Lockers or cabinets for storing decontaminated items;
• Plastic sheeting or sealed pads with drains to collect wash and rinse solutions;
• Metal or plastic drums to collect wash and rinse solutions; and
• Shower facilities or wash sinks with soap, washcloths, and towels.

Other supplies and equipment needed for personnel decon include:

• Barricade tape (like caution tape),
• Tables to hold smaller containers and equipment,
• Masking and duct tape,
• Pens and permanent markers,
• Labels and tags,
• Sanitizing wipes,
• Spray bottles,
• Wire brush for hard-to-remove contaminants,
• Buckets,
• Stepladder, and
• HEPA vacuum with filters.

Vehicle and equipment decon

Large items like vehicles and heavy equipment can be challenging to decontaminate. Some of the supplies needed overlap with those for deconning personnel. Equipment and supplies that may be needed when decontaminating vehicles and heavy equipment include:

• Storage tanks for temporary storage and possibly treatment of contaminated wash and rinse solutions;
• Drains or pumps for collecting solutions;
• Long-handled brushes to help scrub exteriors;
• Long-handled rods or shovels to dislodge contaminants from tires and undersides of vehicles and heavy equipment;
• Wash and rinse solutions;
• Pressurized sprayers;
• Curtains, tarps, or enclosure booths to contain spray;
• Buckets or other containers to hold materials like soil that dislodge from the vehicle or heavy equipment;
• Wash and rinse buckets for interiors; and
• Brooms and brushes for interiors.

Equipment selection factors

The selection of equipment to use during decon should take into account the contaminants involved. How effective would the equipment be in removing those particular contaminants? Are there chemicals or biological agents that may require special attention?

Consider, too, the functionality and capacity of the equipment. In what areas could this be used? How many personnel, vehicles, or pieces of equipment could be decontaminated before it loses its capacity or is used up?

Other factors to consider when selecting equipment for decon include:

• Time required to set up the equipment,
• Type of power required to run the equipment,
• The operational environment (like extreme temperatures, rain, snow, or ice) and its impact on equipment,
• Whether the equipment is durable and rugged,
• Employees available to operate the equipment and their skill level and familiarity with it, and
• Whether training would be required to proficiently operate the equipment.

Location of decon operations

• Decontamination is conducted in the Contamination Reduction Zone, between the contaminated Exclusion Zone and the clear Support Zone.

Whenever there is a contaminated area or an emergency release of a hazardous substance, zones are set up around the area. The contaminated area is called the Exclusion Zone (EZ), also known as the “hot zone.” The EZ extends outward far enough to prevent adverse effects to personnel outside the area.

The outside perimeter of the EZ is marked by a boundary of ropes, barricade tape, stanchions, cones, or other markers. This boundary is called the “hotline.” Only employees with proper training, personal protective equipment (PPE), and chemical protective clothing are allowed to enter the EZ.

The Contamination Reduction Zone (or CRZ) is a buffer or transition area between the EZ and the clean area. The outer boundary of the CRZ, called the contamination control line, is marked. Decontamination occurs in the CRZ.

Note: Anyone who is working in the EZ with a self-contained breathing apparatus (SCBA) will need to leave the area with enough air to proceed through the decontamination process in the CRZ.

A Contamination Reduction Corridor (CRC), also known as the decon line, is set up inside the CRZ. It’s in this corridor that all the decon activities take place. This includes the decontamination and removal of PPE and protective clothing.

The corridor limits decon activities to a smaller area that minimizes the exposure of uncontaminated employees or equipment, including exposure from runoff or overspray.

Rest stations are often set up in the corridor. Depending on the weather conditions, the rest stations may offer warming or cooling while employees take a break.

There may be more than one decon line in the corridor. If entry workers may be exposed to incompatible components, they should have separate decon lines to allow them to avoid mixing. Also, a separate line can be used to accommodate the decontamination of heavy equipment and vehicles.

Because the CRZ and the EZ have the potential to be dangerous to life and health, no one is allowed in these areas without proper training, PPE, and protective clothing. The contamination control line has an entry point and is usually staffed to make sure no unauthorized personnel enter. If warranted, there may even be security personnel making sure the area is secure.

All entry and exit from the EZ is made through the CRC. Each person or item in the CRC must be thoroughly decontaminated before entering the clean area.

The outermost zone is the Support Zone. This is also known as the “clean area” or “cold zone” and consists of all areas outside the contamination control line. There should be no possibility of exposure to hazardous substances in the Support Zone, and thus no need to wear PPE and protective clothing in relation to hazardous substances.

The command post, first aid station, emergency transport vehicles, lockers, and showering or changing facilities are all located in the Support Zone.

Decon line basics

• A decon line is a row of stations for different decontamination tasks, arranged from most to least contaminated gear.

The decon line consists of different stations set up in a row, each with a specific purpose, such as washing boots or removing outer gloves. The stations should be separated physically. If they are too close, cross-contamination may occur.

The sequence of the stations will address the outermost protective equipment and clothing first because those will be the most contaminated. As workers continue through the line, the levels of contamination should decrease.

During decon activities on the decon line, entry workers will be decontaminated and helped by decon station workers to remove personal protective equipment (PPE) and chemical protective clothing (CPC). Caution is required so that residual contaminants do not contact decon station workers’ skin or splash or drift toward them during the removal process.

Anyone assigned to decontaminate entry workers must wear the same level of PPE and CPC as the workers being decontaminated. In some instances, they may wear one level below what the entry workers are wearing. In other words, someone decontaminating a worker wearing a Level A ensemble will need to wear either a Level A ensemble or, if deemed appropriate, no less than a Level B ensemble.

However, those performing decon at one of the last stations, where levels of contaminants are much lower, may be able to downgrade their ensemble level.

The level of protection for decon-line workers depends on:

• Expected or visible contamination on entry workers,
• Type of contaminant and associated respiratory and skin hazards,
• Total vapor or gas concentrations in the CRC,
• Particulates and specific inorganic or organic vapors in the corridor, and
• Results of any swipe tests.

Employers must have specific procedures for the decontamination process and the order of stations in the decon line. Workers must be familiar with the procedures and have a chance to practice them before being stationed to help decontaminate coworkers or going through the decon line.

Equipment disposal or decon

All equipment used in the EZ or in the CRZ for decon procedures must also be decontaminated before it can enter the Support Zone. Any equipment, supplies, or protective equipment and clothing that cannot be decontaminated must be disposed of properly. These items may now be considered hazardous waste or hazardous materials and must be tagged or labeled as such.

Wash solutions, solvents, and rinse water should be collected and placed in appropriate containers with proper markings, labels, or tags for either disposal or treatment.

Any items that will undergo further decon later should be bagged in plastic and labeled as contaminated items.

If permeable clothing gets splashed by any hazardous substance, that clothing should immediately be removed and either discarded or decontaminated. The wearer should then proceed to the shower.

If commercial laundering facilities are used for PPE or clothing, the laundering facility must be made aware of the potential harmful effects of the hazardous substances. These items should be properly bagged and labeled for transport to the facility.

No one should remove PPE or CPC from the changing rooms without authorization.

Emergency and mass decon

• If a person’s life is in danger, decon should be delayed until the person is stabilized.
• The purpose of mass decon is to quickly remove contaminants from large populations of people, as after a widespread emergency release or a terrorist attack.

Emergency decon

What if a contaminated worker has a life-threatening illness or injury? That’s when emergency decon procedures kick in. If a person’s life is in danger, decontamination should be delayed until the person is stabilized. However, there are two exceptions to delaying decontamination:

• If, based on the condition of the victim, decon can be performed without interfering with life-saving techniques or first aid services; or
• If the injured or ill worker is contaminated with a highly toxic or corrosive substance that can cause severe injury or loss of life.

In other words, decon should be performed immediately if it will not interfere with saving a life or if it will prevent further severe injury or loss of life from extremely toxic or corrosive materials.

Some recommendations on dealing with contaminated personnel suffering from life-threatening injury or illness include:

• Always remove respirators and backpacks.
• Do not attempt to wash or rinse the victim onsite.
• Cut open and remove outer chemical protective clothing (CPC) if this can be done safely.
• If outer CPC cannot be safely removed, wrap the worker in plastic, rubber, or blankets to prevent the spread of contamination to medical personnel and transport vehicles.
• If the emergency is due to heat stress, cut off and remove CPC as quickly as possible. Heat stress can elevate to heatstroke, which can be deadly.
• Site personnel who are familiar with the incident should accompany the ambulance to the medical facility and bring information about the contaminant along for the physician.
• Consider the stretcher, transport vehicle, and emergency room to be contaminated areas.
• Once the victim is stabilized, decon the victim and any contaminated areas.
• Contain and properly tag or label all waste generated from the decon process.

Mass decon

The purpose of mass decon is to quickly remove contaminants from large populations of people, including the public, who have been exposed to an emergency release of a hazardous substance. Mass decon could also be applied after a terrorist attack using weapons of mass destruction (WMD).

Due to time constraints, initial mass decon may not be set up as fully as it would at an established hazardous waste cleanup operation. Water hoses are typically used for mass decon if the contaminant is not water reactive.

The most important thing is to address the potentially life-threatening needs of the people who have been exposed, but mass decon efforts also include decon of tools, equipment, buildings, roads, and anything else exposed during the incident.

A more formal decon setup may be installed while initial mass decon is going on. This greater level of decontamination may be needed if initial mass decon methods are proved ineffective.

If there is a need for mass decon, then local, state, and federal agencies will likely be involved. Decisions on how to handle the incident will be based on the size and severity of the incident.

Tents may be set up for medical attention and decon stations. Mass decon needs to be executed as soon as possible to limit exposures and the spread of contaminants. Extra help and supplies would likely be coming from surrounding areas.

Training

• Any employee expected to respond to an emergency situation must be trained on how to do so safely and effectively.

Emergency response personnel include any employees who are expected to respond to an emergency situation at a hazardous waste cleanup site. These employees need training in how to respond safely in a hazardous emergency situation that may expose them to hazardous substances.

Employers must train these employees in accordance with subparagraph (e)(7) of 29 CFR 1910.120 and 1926.65. Training must occur during times when the employees are being compensated.

An effective training program significantly reduces the number and severity of incidents from overexposure to health hazards.

Note: The Occupational Safety and Health Administration (OSHA) has stated in CPL 02-02-071 that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements. Computer-based training alone would not be sufficient. To provide all required training components, any computer-based training program must be supplemented by the opportunity for trainees to ask questions of a qualified trainer and must provide trainees with sufficient hands-on experience. Site- and task-specific training are also important.

Procedures for emergency response at hazardous waste cleanup sites

• Emergency response operations have four basic steps — notification, preparation, response, and termination.

Subparagraph (l)(3) of 29 CFR 1910.12 and 1926.65 does not specify much in the way of emergency response procedures. However, according to the Occupational Safety and Health Administration (OSHA), the employer must evaluate the incident and the site response capabilities and, based upon the information available at the time of the emergency, proceed with the “appropriate steps” to implement the site emergency response plan (ERP).

Most emergency response operations follow some basic steps. OSHA makes it clear that no one should rush into a situation where there has been an emergency release of hazardous substances. It is always important to stay clear of vapors, fumes, smoke, and spills to minimize any health and safety risks.

If a hazardous substance is released, an employee who is unauthorized to confine, contain, control, or clean up a release must leave the affected area immediately. The employee should pay attention to as many details as possible on the way out and, once in a safe area, follow the employer’s procedures for notifying appropriate personnel.

For employees who are authorized to respond to an emergency release, there are four basic steps in an emergency response operation:

1. Notification — Notify all onsite personnel of the emergency.
2. Preparation — Size up the situation by quickly evaluating casualties, hazards, and response capabilities and allocating personnel and equipment for response.
3. Response — Respond per appropriate steps in the ERP. This may include:
   • Taking rescue actions to stabilize, extricate, decontaminate, and transport victims;
   • Evacuating personnel and/or the public; and
   • Controlling the hazard itself.
4. Termination — Follow up with termination procedures by restocking all equipment and supplies, debriefing responders, critiquing the incident, and updating the ERP.

For more on procedures for emergency response, please refer to the Emergency response operations for hazardous substance releases section of this subject.

Alarms

According to subparagraph (l)(3)(vi) of 29 CFR 1910.120 and 1926.65, an employee alarm system must be installed at hazardous waste cleanup sites to:

• Notify employees of an emergency situation,
• Stop work activities if necessary,
• Lower background noise in order to speed communication, and
• Begin emergency procedures.

Check out 29 CFR 1910.165, the Employee Alarm System Standard, along with the Emergency response operations for hazardous substance releases section of this subject for more on internal communication.

Recognition, identification, and notification

• The first step after a release is to determine whether it’s incidental (able to be addressed by workers in the area without significant health or safety risk) or emergency (requiring more dramatic measures).
• Other steps include identifying the substance, notifying personnel in the area, and informing emergency response services and federal and state agencies as necessary.

If a release occurs, no one should rush in even if other personnel in the area appear to be injured or ill. Instead, it’s vital to take the time to identify what hazardous substance is involved (if possible) and make proper notifications that a release has happened, all the while staying clear of any vapors, fumes, smoke, and spills.

First, it must be identified whether the release is incidental or requires an emergency response:

• Incidental release — An incidental release has occurred when the release of a hazardous substance can be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. It does not pose a significant threat to health and safety of employees in the area or to those cleaning it up and does not have the potential to become an emergency within a short period.
• Emergency release — An emergency release has occurred when the release of a hazardous substance cannot be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. An emergency release does pose a significant threat to the health and safety of employees.

The following tools can be used to help figure out if any hazardous substances are involved in the release:

• The location of the release,
• The shapes and colors of containers,
• Any markings and color codes, and
• Human senses.

If it’s determined that an emergency release of a hazardous substance has occurred, the next step is to try to quickly identify, if possible, the hazardous substance or substances involved in the release. Tools available for identifying hazardous substances include:

• Labels and markings,
• Shipping papers,
• Safety data sheets (SDSs),
• Emergency Response Guidebook (ERG), and
• Air monitoring and field survey instruments.

Whether or not the substance can be identified, the next step is to make notifications.

All personnel in the immediate vicinity must be made aware of the situation. Work activities should be stopped, and everyone should head for a safe location to hear the notification.

When emergency response personnel are notified about the emergency, the ERP is activated. At this time, specific information will need to be provided, including:

• Location of the incident;
• Time of occurrence;
• A description of what happened;
• Any injuries or fatalities;
• Extent of the damage;
• Actions taken; and
• What response is needed from outside parties, such as fire department, ambulance, etc.

Both onsite and offsite personnel need to be notified. Directions for doing this should be included in the ERP.

For onsite notification, there may be an installed alarm system, sirens, bells, whistles, megaphones, dedicated radio frequencies, or a public address system.

Offsite notification will most often mean using a phone. All employees should be aware of how to contact local fire departments, police departments, ambulance services, and hospitals. Typically, this means dialing 911.

However, there may also be state and federal agencies that must be contacted. Information about who to call and where to find their phone numbers should be in the ERP.

Although notification activates the ERP, the release is not considered an emergency response operation until a trained emergency responder (who might be the employee handling the notification) gets involved or arrives at the scene.

Isolation and size up

• An emergency release must be isolated and sized up, which includes assessing the event, casualties, possible further events, and available resources.

The area of the release needs to be isolated, which means to make sure everyone is a safe distance away from the release and out of harm’s way.

If the substance has been identified, the safety data sheet (SDS) or Emergency Response Guide (ERG) can be used to help figure out how far away from the release people should be. It’s necessary to stay upwind, uphill, and upstream from the release.

What happened?

The situation should be sized up by gathering and assessing all the information available, which will help in making well-informed decisions about how to handle the situation. Determining what happened is part of sizing up the situation. In addition, it’s necessary to assess whether there are any casualties, what could still happen, and what resources are available.

Questions to ask when trying to assess what happened include:

• What was spilled?
• What type of spill occurred?
• What caused the spill?
• What’s the extent of the spill and the damage?

Are there any casualties?

Casualties must be assessed to determine what type of medical help and how many medical resources will be needed. Questions to ask when assessing casualties include:

• How many victims are there?
• Where are they located?
• What’s their condition?
• What treatment is required?
• Is anyone missing?

What could still happen?

A full assessment includes considering what could still happen. Questions to ask include:

• What types of substances are nearby?
• Could these substances react with the substance that was released?
• What’s the potential for fire, explosion, or more spills?
• Where are personnel relative to hazardous areas?
• Is there any potential danger to the public or the environment?

What resources are available?

Finally, the available resources should be assessed. Questions to ask when considering resources include:

• What medical resources are available for victim rescue, stabilization, and transport?
• What resources are available for hazard mitigation, such as personal protective equipment (PPE), chemical protective clothing (CPC), field survey equipment, communication equipment, and other supplies and equipment?
• How many trained responders are available?
• What will be needed from offsite sources?
• How long will it take for offsite resources to arrive?

Preparation for emergency response

• Steps to prepare for emergency response include determining what hazards exist, allocating personnel and equipment, securing the scene, and making an action plan before moving forward.

Determine hazards

Now that notifications have been made, the area has been isolated, and the situation has been sized up, it’s time to determine what hazards and risk would be involved in rescue and response.

• Are there IDLH (immediately dangerous to life or health) conditions?
• How long would it take to perform control measures?
• Would a self-contained breathing apparatus (SCBA) run out of air before the task can be accomplished?
• Should responders rotate?
• Is there enough lighting in the area?
• Is there a lot of smoke?
• Should responders use lifelines?

A crucial task here is to consider what could go wrong. The goal is to both get the release under control and rescue victims without causing injury or illness to the responders performing these tasks.

Allocate personnel and equipment

Personnel and equipment need to be assigned. All responders should know exactly which tasks they will be performing and verify all equipment and supplies needed are available, in good condition, and ready to go.

Secure the scene

To control access to the release area, three zones should be set up:

• Exclusion Zone — The Exclusion Zone (EZ) is an area surrounding the release that is contaminated from the hazardous substance. This is also referred to as the “hot zone.”
• Contamination Reduction Zone — The Contamination Reduction Zone (CRZ) is where decontamination occurs. It’s a transition area between the EZ and the clean area. A “hotline” separates the EZ from the CRZ.
• Support Zone — The Support Zone is the clean area. No one should be exposed to any hazardous substances in this area. The command post is always located in the Support Zone. A contamination control line separates the CRZ from the Support Zone.

The zones would be decided quickly based on information such as the hazardous substance, size of the release, isolation distance, and weather conditions like wind speed and direction. An employee trained as an operations-level first responder or higher may set up the EZ.

Each zone is marked with a barrier and/or signs. Barriers could be structures already in place, like the walls of a building, or temporary barriers could be quickly constructed, like fences or stanchions and ropes.

Signs are posted around the perimeter of the zones, and guards can be used to patrol the perimeter.

Access to the EZ and CRZ is controlled using a checkpoint. Only authorized personnel — responders who have proper training and are dressed and equipped to handle the conditions — are allowed to enter areas through the checkpoint.

Records should be kept on everyone who passes through the checkpoint. Information to record includes:

• Name,
• Time of entry,
• Anticipated exit time,
• Zones being entered,
• Name of team or “buddy,”
• The task being performed and its location, and
• Rescue and response equipment taken into the area.

Having security at access points to the EZ and CRZ will minimize potential contamination of workers, protect the public from a release, and prevent vandalism and theft. Unauthorized people will be prohibited from entering.

Note: Entry and exit from the EZ must be controlled by a first responder at the operations level or higher. An employee trained as an awareness-level first responder could assist in preventing unauthorized entry at the scene, as long as these activities are done at a safe remote location.

Make an action plan

Though it seems like many steps, all these tasks would be happening quickly. The last thing to do before actually taking action is to make an action plan. The response team should take a few minutes to assess all the information that has been gathered and make decisions about what actions to take.

As the response efforts unfold, this action plan should be checked. It may need to be revised based on new information.

Ground rules for emergency response

• Emergency response relies on a chain of command, in which the most senior official onsite is responsible for controlling and directing all response activities, and the responsibility is passed to any official with a higher rank who arrives.
• Steps for response are often done concurrently rather than consecutively.

Every emergency response to a hazardous substance release is unique, but certain ground rules will always be the same. These rules are required by the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. They provide consistency and are in place to help keep employees, the public, and the environment safe.

Emergency response always uses the chain of command. The most senior official onsite is responsible for controlling and directing all response activities. As more response personnel arrive, the position is passed up to any new official with a higher rank.

Steps for response can be and usually are done simultaneously. They do not have to be completed one after another. What this means is some responders may be rescuing victims while other responders are trying to get the release under control.

Some more ground rules may include:

• All responders must be wearing appropriate personal protective equipment (PPE) and chemical protective clothing (CPC) unless they are in the Support Zone.
• All responders exposed to air contaminants at an unknown concentration or at a concentration that is IDLH (immediately dangerous to life or health) must wear a positive pressure self-contained breathing apparatus (SCBA) until air monitoring data indicate that exposure levels are safe enough for other types of respirators to be used.
• The number of responders entering the Exclusion Zone (EZ) must be limited to only those who are performing tasks related to the emergency release.
• The “buddy system” must always be used for any responders entering the EZ.
• Backup and advanced first aid support personnel must be on standby with equipment and proper PPE and CPC.
• The type of communication to be used must be established.
• The conditions must be monitored continuously for any changes.
• The action plan must be updated as conditions change.

In addition, a Safety Official must be designated. This official can alter, suspend, or terminate activities if imminent danger exists, such as IDLH conditions. The Safety Official must be knowledgeable in emergency response and is responsible for identifying and evaluating any hazards that are present.

Helping victims

• Victims of emergency releases should be stabilized and removed from the area, and should be decontaminated before receiving medical treatment unless their condition is life-threatening.
• It may be necessary to delay rescue until conditions pose less risk to the rescuers.

Emergency releases may cause fatalities, injuries, and illnesses. That means medical treatment of injured or ill victims may be required during an emergency response effort. It may also be necessary to locate victims who are missing and assess their condition.

All victims should be stabilized and removed from the area. Stabilizing a victim may require first aid measures. Whether victims are decontaminated before leaving the Contamination Reduction Zone (CRZ) will depend on their medical condition.

When medical conditions are life-threatening, medical treatment takes precedence over decontamination. Measures can be taken to minimize the spread of contamination that include ensuring medical personnel have personal protective equipment (PPE) and placing sheeting over the victim and in transport vehicles.

Rescue attempts should always be weighed against putting the rescuers in harm’s way. The harsh reality is that there may be times when conditions dictate that rescue has to wait until the threat of danger to rescuers has subsided.

Evacuating or sheltering in place

• Conditions during emergency response may call for evacuating (moving people to a safe area) or sheltering in place (staying inside a building until the danger passes).

Depending on the conditions, it may be necessary to either evacuate personnel or have them shelter in place.

• Evacuate — To move people from a place of danger to a safe area in an organized manner.
• Shelter in place — To seek shelter inside a building and remain inside until the danger passes.

Employers should have two distinct signals in place, and personnel should be trained on both signals so they know what is expected of them when they notice a particular signal. Also, evacuation routes should be predetermined and addressed in the emergency response plan (ERP). All employees should be trained on where to go and the route to get there.

Sometimes it’s safer to shelter in place. An example would be if there are airborne contaminants that employees would have to travel through to evacuate. When sheltering in place, it may be necessary to close all windows and doors and turn off any ventilation, heating, or cooling systems to keep out contaminants.

Whether the situation calls for an evacuation or sheltering in place, there must be predetermined locations for each and a way to account for all personnel. This helps in identifying any personnel who did not get out to safety so a rescue can be planned.

If there is a safety threat to the public and a decision is made to either evacuate the public or have them stay inside and shelter in place, these activities are handled by government agencies like local fire and police departments. Communities may have public siren systems for alerting the public and use local television and radio stations to communicate the threat and what actions should be taken for safety.

Controlling the hazard

• The three primary methods for addressing an emergency release are to control, contain, and confine it.
• Control measures can be physical (such as patching a leak or diverting a flow) or chemical (such as burning, neutralizing, or converting a substance).

When addressing the hazards of an emergency release, an emergency responder has three potential methods:

• Control it — Actions to control the emergency and limit exposure and damages include:
  • Shutting off a valve,
  • Diking a spill,
  • Covering floor drains and sewers, and
  • Improving ventilation.
• Contain it — Containing a release might involve plugging or patching a leak to keep the remainder of the hazardous substance in its container.
• Confine it — Actions to confine a hazardous release and keep it from flowing any further could include:
  • Using absorbents,
  • Diverting a spill,
  • Building a dam, or
  • Digging a trench.

Anyone tasked with controlling, containing, and/or confining a hazardous substance release should be very alert and cautious. It’s important for employees to be aware of:

• The surroundings and any indication that conditions are changing;
• How they’re feeling; and
• How their work buddies are doing.

If any signs or symptoms of chemical exposure arise, it’s time to leave the area immediately. Once in a safe location, the next steps are to regroup, discuss the new information, and make changes to the action plan.

Advanced control measures

When taking control of an emergency release, responders typically use either physical or chemical approaches. A combination of physical and chemical approaches may be needed, depending on the situation. Factors to consider when deciding which approach(es) to use:

• What the release substance is and its hazards;
• The chemical properties of the substance, including whether it is in solid, liquid, or gaseous form;
• Whether the substance is under pressure;
• Whether the release is on land, in the air, or in water;
• What natural or man-made barriers are already in place; and
• Weather conditions, such as extreme heat and cold, wind speed and direction, and rain.

Before any approach is applied, it must be approved by the On-scene Incident Commander. No one should apply an approach unless trained to do so properly.

Some common physical approaches to taking control of a release include:

• Plug and patch — Using plugs and patching material on leaks from containers due to small holes, rips, or cracks. If the bung (or stopper) of a drum is loose, simply tightening it with a non-sparking bung wrench may also seal the leak.
• Damming or diking — Creating barriers to stop the flow of a spill. Some common materials to use are soil, sandbags, and concrete barricades.
• Booming — Using a flexible, floating barrier on a water surface, where it can soak up floating contaminants. Booms are often used on oil spills in bodies of water.
• Diversion — Placing an obstacle in the direct path of a flowing spill to divert it to a specific area where it is collected. Digging trenches or placing a boom to direct flow are two examples. Covering a drain diverts a spill too.
• Sorbents — Placing sorbent materials (such as towels, kitty litter, sawdust, clay, or phenolic granules) either directly on a spill or in its pathway to absorb the spill. Sorbents are not recommended for volatile liquids, however. After use, sorbent materials must be disposed of properly.
• Vapor dispersion — Spraying water at vapors to pull them from the air to the water. The contaminated water must then be collected and disposed of properly.
• Vapor suppression — Applying a foam blanket or other agent over a substance to suppress the vapors.
• Dilution — Diluting a substance with water to lower its concentration. This only works if the substance is water soluble and not water reactive.

Other physical approaches include, but are not limited to:

• Shutting off a valve;
• Rolling or tipping a leaking container so the hole is at the top;
• Covering the release;
• Rolling a leaking container into (or otherwise putting the container inside) a compatible overpack (oversized) container;
• Transferring the substance to a different container that is compatible, bonded, and grounded;
• Vacuuming the spill; and
• Venting gas from a container to alleviate pressure.

The most common chemical approach to take control of a release is to disperse the contaminant, rather than removing it. Let’s say the insoluble part of an oil spill has been removed from a water body. The next step might be to apply emulsifiers to the spill area to help break up (or disperse) any remaining oil.

Other chemical approaches include, but are not limited to:

• Burning or flaring the substance in a controlled manner;
• Converting the release to a gel;
• Converting the release to a solid;
• Neutralizing the release; and
• Using another chemical to react with the substance, changing it to a less hazardous substance.

Terminating the emergency response operation

Once the release is controlled, contained, and/or confined through physical and/or chemical approaches, as necessary, the senior official in charge of the emergency response operation will decide when to terminate the emergency response and move into post-emergency response efforts.

Elements of the emergency response plan

• Examples of information in the ERP include evacuation routes, decontamination procedures, personnel roles and training, safe distances, and emergency medical treatment and first aid.

The emergency response plan (ERP) is required to include several elements in order to provide a complete picture of the structure and function of the facility’s emergency response process.

Pre-emergency planning and coordination

When an emergency release occurs, any delays in action can cause life-threatening situations. Coordination with any outside parties listed in the plan must be pre-arranged. Employers can be cited if their ERP does not:

• Reflect pre-emergency planning and coordination with outside parties;
• Describe procedures or existing agreements addressing how outside parties will be notified of a potential emergency situation;
• Address expected roles of outside parties in providing emergency response; or
• Address existing factors, if any, that could delay or prevent outside parties from responding.

Personnel roles, lines of authority, training, and communication

Personnel roles must be clearly defined in the ERP. The ERP also lists the chain of command and lines of authority, including titles of key personnel and outside responders.

All personnel must know their roles for an emergency and have the required training. The employer must incorporate the provisions for employee training into the ERP. This might include a general outline of the training for each level of emergency responder, or just a reference to the location of the training manual. The plan should also address a schedule for required annual refresher training.

The ERP must clearly define the lines of communication so that employees encountering a release know who to report it to. The means of communication in an emergency must also be addressed. This might include radio frequencies, hand signals, siren blasts, light indicators, or any other system to alert personnel that an emergency response operation has begun.

Emergency recognition and prevention

The emergency recognition and prevention section of the ERP should include:

• An inventory of the hazardous substances onsite,
• How they are stored,
• The consequences of an uncontrolled release, and
• Scenarios or circumstances that would trigger emergency response for hazardous substances stored onsite.

Safe distances and places of refuge

This plan element should contain a map identifying safe places of refuge in each area where hazardous substance emergencies could occur. All employees would be accounted for in these areas, which is critical for identifying individuals who may need rescue.

Sometimes it’s safer to remain indoors than to evacuate. If an employer intends to use places of refuge as shelter-in-place areas, the ERP must include a shelter-in-place option, with a signal that is easily distinguishable from an evacuation signal, and personnel must be trained in the relevant procedures.

Site security and control

In an emergency release situation, the employer must control areas surrounding the danger area by prohibiting unauthorized personnel from entering. Methods for defining controlled areas are addressed in this ERP element. Emergency responses are coordinated from a command post a safe distance away from the emergency release area. The ERP addresses the setup and functions of this command post.

Personnel expected to set up boundaries designating safe and unsafe areas must be trained to the first responder operations level. (The first responder awareness level is not a sufficient level of training to set up safe distances because this level lacks knowledge on the potential for exposure, explosion, or radiation.)

Once these areas have been established, operations-level personnel must control entry and exit from the area of the release. Awareness-level personnel may assist in preventing unauthorized entry into the release area if they do so from a safe remote location.

Evacuation routes and procedures

This element of the ERP should identify how employees who are not part of the response operation will be notified to start evacuating, their evacuation routes, and where they should assemble so all personnel can be accounted for.

Decontamination

Decontamination procedures are also included in the ERP. These procedures must address decontaminating emergency responders leaving the Exclusion Zone (EZ). Personnel who assist in the decontamination process must wear personal protective equipment (PPE) at the same level or one level below the responders they are assisting.

If emergency responders are expected to decontaminate their own equipment or the EZ, then the ERP must include these procedures. Decontamination of response equipment left in the EZ and the contaminated area may be handled in the post-emergency response phase. Therefore, decontamination procedures for these areas and equipment do not necessarily need to be part of the ERP.

Emergency medical treatment and first aid

This element should identify all personnel with specialized training in Basic Life Support (BLS), their certifications, and the best way to contact them. These personnel must be no more than 3 to 4 minutes away. BLS refers to a unique group of trained individuals (e.g., emergency medical technicians, or EMTs) who have received an established level of specialized training that exceeds basic first aid skills. These personnel must be on standby, as per 29 CFR 1910.120(q)(3)(vi) or 1926.65(q)(3)(vi).

Emergency alerting and response procedures

This element of the plan should address procedures about how personnel will be informed of an emergency, including its type; how personnel should respond; and how they will be made aware of specific instructions, if necessary. The following information should be included, as applicable:

• Notification — Making the existence of the emergency situation known;
• Level and type of response — The required response based on the extent/type of emergency;
• Nature of the response — The type of emergency condition (explosion, chemical spill, medical);
• Location — The part of the facility affected (critically important in large facilities); and
• Ambient conditions — Environmental factors, such as wind speed and direction, that may influence evacuation or response procedures.

If the emergency situation calls for special instructions, determine if the emergency alerting system indicates the location of the hazard, the direction employees should evacuate, what the hazard is, and any special PPE employees must don.

Critique of response and follow-up

The goal of this plan element is to improve the ERP after an incident. It sets procedures to analyze and evaluate how the incident was handled. Any new information and experiences from the emergency response operation are shared and used to update the ERP. This plan element also contains procedures for follow-up activities, such as restocking supplies and PPE.

PPE and emergency equipment

This element of the ERP includes a listing of PPE and emergency response equipment and materials, including their locations, their instructions for use, their limitations, and in what situations emergency responders will use them.

Local and state emergency response plans

Community emergency response agencies should be integral components of the community ERP. This ERP element should spell out specific roles and responsibilities for various organizations or agencies and indicate which function each will play in an emergency. The employer’s ERP may reference or include all or applicable sections of a local ERP or state ERP.

Initial and refresher training

• Emergency responders must be trained in their roles and tasks, including yearly refresher training.
• “Specialist employees” refers to employees from offsite who assist or counsel the HAZMAT team personnel, such as technical, medical, and environmental experts.

Emergency responders must be trained prior to their participation in emergency response operations, and their training must be based on the functions and duties they will be expected to perform. Consequently, employers must evaluate the roles and tasks that employees will perform and train them appropriately. For example:

• If an employee is simply expected to notify the emergency response team upon discovery of an emergency release and evacuate from the area, the employee would be trained to the first responder awareness level.
• If an employee is responding initially in a defensive manner for the purpose of protecting nearby persons, property, or the environment from the effects of the release, but does not approach the point of release, that employee would be trained to the first responder operations level.
• If, however, the employee is expected to approach the point of release for the purpose of stopping the release, the employee would minimally need to be trained to the hazardous materials (hazmat) technician level.
• If an employee is expected to have more direct and specific knowledge of the various hazardous substances and to assist the hazmat technician in the response, the employee would minimally need to be trained to the hazmat specialist level.
• If the employee is expected to assume control of the incident scene, the employee would need training at the on-scene incident commander level.

In addition to the training levels established in the standard for emergency responders, two additional personnel classifications are provided:

• Skilled support personnel (SSP) — These are employees who are needed to temporarily perform immediate emergency support work (e.g., excavator, crane, or tow truck operators). SSP must be provided with an initial site briefing that covers personal protective equipment (PPE) use, the chemical hazards involved, and the tasks to be performed.
• Specialist employees — These are employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances. They may be called upon to provide technical advice or assistance at a hazardous substance release incident. This classification applies to employees from offsite who assist, counsel, or advise the on-scene incident commander or HAZMAT team. They provide technical assistance in operations such as servicing specific valves on a storage tank or a tank car, or in similarly skilled areas, in addition to offering advice. They could also include medical or environmental experts. Specialist employees may not enter the danger area unless they are fully trained in the use of the required PPE and are accompanied by a hazmat technician or hazmat specialist.

HAZWOPER emergency response training provisions

Emergency response training provisions under paragraph (q) of 29 CFR 1910.120 or 1926.65 are summarized in the table:

_{Table note: The training hours in the standard are minimums. HAZWOPER training programs often will exceed the 8- or 24-hour minimums in order to include all of the required subjects.}

Employees who must receive training as required by subparagraph (q)(6) of 1910.120 or 1926.65 must also receive refresher training or demonstrate competency at least annually. Refresher training is required because employees must stay up to date in their skills and knowledge.

The Occupational Safety and Health Administration’s (OSHA) intent is that employees should complete their refresher training within 12 months of their initial training. However, sometimes courses are missed due to unavoidable circumstances. In such an event, employees should take the next available refresher training course, with a record added to their personnel files indicating why the training has been delayed and when the training will be completed.

If an employee has gone without refresher training for more than 12 months, the employer must evaluate whether the initial comprehensive training needs to be repeated. The need to repeat initial training must be determined based on the employee’s familiarity with safety and health procedures and potential hazards.

Refresher training may be given in segments throughout the year as long as the required training is completed by the employee’s anniversary date. Time spent by emergency response employees reviewing incidents can also be credited toward their refresher training requirements.

Finally, the employer must have a “statement of training” or “statement of competency” for annual refresher training or competency for all employees trained in emergency response.

For more in-depth information on emergency response training, see section XI.E. to XI.I. in OSHA’s directive CPL 02-02-073, Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases.