00a -- title page

Midwest

Consortium for Hazardous Waste

WorkerTraining

8-Hour SupervisorDecember 2002

Copyright © 2002Midwest Consortium for Hazardous Waste Worker Training

Introduction

Acknowledgments

This curriculum has been developed by the Midwest Consortium for Hazardous Waste WorkerTraining under grant number D42 ES07200 and cooperative agreement number U45 ES06184from the National Institute of Environmental Health Sciences. As a group of trainers dedicated toproviding you with useful information to safeguard your health and safety, we encourage you tocomment on these materials. Please give your suggestions to those teaching the program inwhich you are now enrolled, or forward them to the Midwest Consortium for Hazardous WasteWorker Training, University of Cincinnati, P.O. Box 670056, Cincinnati, OH 45267-0056.

Warning

This material has been copyrighted by the Midwest Consortium for Hazardous Waste WorkerTraining. A recipient of the material, other than the Federal Government, may not reproduce itwithout permission of the copyright owner.

The material was prepared for use by experienced instructors in the training of persons who areor who anticipate being employed at a hazardous waste worksite. Authors of this material haveprepared it for the training of this category of workers as of the date specified on the title page.Users are cautioned that the subject is constantly evolving. Therefore, the material may requireadditions, deletions, or modifications to incorporate the effects of that evolution occurring after thedate of this material preparation.

Disclaimer

Under the Occupational Safety and Health Administration (OSHA) final rule, supervisors needtraining in their responsibilities within the safety and health program and its subject areassuch as the spill containment program, the personal protective equipment program, the medi-cal surveillance program, the emergency response plan and other areas.

For information about further training, consult the training instructor, your company safetyand health plan, or your company health and safety representative.

Introduction

Preface

You are here because you are or will be employed at a hazardous waste site. During thisprogram you will learn about the following topics:

� Motivating workers to use safe work practices.

� Investigating accidents.

� Monitoring for hazardous conditions.

� Site control.

� Personal protective equipment.

� Handling the media.

� OSHA inspections.

� Safety and health plans.

When you finish, you will be better able to:

� Investigate accidents and deal with the media.

� Synthesize information for problem-solving.

� Work with safety and health plans.

� Assess critical behaviors.

Introduction

Midwest Consortium for

Hazardous Waste Worker Training Programs

CEA

Shawn Hupka .......................................... 519-973-1116

CEA1550 HowardDetroit, MI 48216

Greater Cincinnati Occupational Health Center

LaVerne Mayfield ................................... 513-531-7101

Greater Cincinnati Occupational Health Center7030 Reading Rd., Ste. 540Cincinnati, OH 45237

DWEJ

Donele Wilkins ....................................... 313-821-1064

DWEJ4875 LakeviewDetroit, MI 48215

Fisk University

Robert Wingfield, Jr. .............................. 615-329-8626

Fisk UniversityDept. of ChemistryEnvironmental Justice Education & Research1000 17th Ave., N.Nashville, TN 37208-3051

Indiana University

David Jones ............................................ 800-488-8842

Indiana UniversityEnvironmental Management Institute5610 Crawfordsville Rd., Ste. 15Indianapolis, IN 46224

Lakeshore Technical College

Rich Hoerth ............................................ 888-468-6582

Hazardous Materials Training ProgramLakeshore Technical College1290 North Ave.Cleveland, WI 53015-1414

Michigan State University

Scott Tobey ............................................. 517-432-3981

School of Labor & Industrial RelationsMichigan State University200 S. KedzieEast Lansing, MI 48824

Ohio Environmental Council

Susan Studer-King ................................ 614-487-7506

Ohio Environmental Council1207 Grandview Ave., Ste. 201Columbus, OH 43212

SEMCOSH

John Reardon ......................................... 313-849-3345

SEMCOSH7752 W. Vernor, Ste. 103Detroit, MI 48216

The Three Affiliated Tribes

Cliff Whitman .......................................... 701-627-4569

The Three Affiliated TribesEmergency ManagementHc3 Box Z204 W. Main St.Environmental DivisionTribal Administration BuildingNew Town, ND 58763

University of Illinois

Symantha Aydt ....................................... 217-244-4099

Labor Education ProgramILIRUniversity of Illinois504 E. ArmoryChampaign, IL 61820

University of Kentucky

Philip Berger .......................................... 859-257-5741

425 Patterson Office TowerUniversity of KentuckyLexington, KY 40506

University of Louisville

Charles Najdek ....................................... 502-852-0364

Hazardous Materials Training CenterUniversity of Louisville—UCCPE/Shelby Campus101 Founders UnionLouisville, KY 40292

Introduction

University of Minnesota

Jeanne Ayers .......................................... 612-625-2946

Midwest Center for Occupational Health and SafetyUniversity of Minnesota2221 University Ave., SE, Ste. 350St. Paul, MN 55414

University of Tennessee

George Smelcer ..................................... 865-974-2009

University of TennesseeCenter for Industrial Services226 Capitol Boulevard Building, Ste. 606Nashville, TN 37219-1804

Midwest Consortium for Hazardous Waste Worker Training Programs, cont.

Introduction

AFSCME Training and Education Institute

James August ........................................ 202-429-1233Fax ........................................................... 202-223-3255

AFSCME Training and Education Institute1625 L St., NWWashington, DC 20036

George Meany Center for Labor Studies

Brenda Cantrell ...................................... 301-431-6400Fax ........................................................... 301-434-0371

George Meany Center for Labor StudiesRailway Workers Hazardous Materials Program10000 New Hampshire AvenueSilver Spring, MD 20903

International Association of Firefighters

Eric Lamar .............................................. 202-737-8484Fax ........................................................... 202-637-0839

International Association of Firefighters1750 New York Ave., NWWashington, DC 20006

International Chemical Workers Union

Larry Gregoire ........................................ 330-867-2444Fax ........................................................... 330-867-0544

International Chemical Workers Union1655 W. Market St.Akron, OH 44313

International Union of Operating Engineers

David M. Treanor .................................... 202-778-2643Fax ........................................................... 202-778-2691

International Union of Operating EngineersResearch and Education1125 Seventeenth Street, NWWashington, D.C. 20036

Kirkwood Community College

Douglas Feil ........................................... 319-398-5893Fax ........................................................... 319-398-5894

HMTRI, Kirkwood Community CollegeHazMat Training Research InstituteHealth Occupations6301 Kirkwood Blvd., SWP.O. Box 2068Cedar Rapids, IA 52406-2068

Other Training Programs Funded by the

National Institute of Environmental Health Sciences (NIEHS)

Laborers—AGC Education and Training Fund

Cindy Herleikson ................................... 703-960-3145Fax ........................................................... 703-960-3146

Laborers—AGC Education and Training FundRoute 97 and Murdock RoadP.O. Box 37Pomfret Center, CT 06259

National Puerto Rican Forum

Tipawan Reed ........................................ 312-926-5563Fax ........................................................... 312-362-6021

National Puerto Rican Forum180 N. Wabash, 4th Fl.Chicago, IL 60601

Paper, Allied Industrial, Chemical & EnergyWorkers International Union (PACE)

Michael Gill ............................................. 615-831-6781Fax ........................................................... 615-833-9332

Paper, Allied Industrial, Chemical & EnergyWorkers International Union (PACE)3340 Perimeter Dr.Nashville, TN 37211

Service Employees Internat’l Union, AFL-CIO

Michael Kushner .................................... 202-898-3385Fax ........................................................... 202-898-3403

Service Employees Internat’l Union, AFL-CIOOccupational Safety and Health1313 L Street, NWWashington, D.C. 20005

The Center to Protect Workers’ Rights

Kizetta Vaughn ....................................... 202-962-8999Fax ........................................................... 202-354-8015

The Center to Protect Workers’ Rights111 Massachusetts Ave., NWWashington, DC 20001

United Auto Workers

Luis Vazquez .......................................... 313-926-5563Fax ........................................................... 313-824-4473

United Auto WorkersHealth and Safety Department8000 E. Jefferson Ave.Detroit, MI 48214

Introduction

Other Training Funded by the National Institute of Environmental Health Sciences (NIEHS), cont.

University of Alabama—Birmingham

Dwight Alan Veasey ............................... 205-934-8752Fax ........................................................... 205-975-5087

University of AlabamaCenter for Labor Education and Research1043 Building 1021530 3rd Ave., S.Birmingham, AL 35294-4490

University of California

Marianne Brown ..................................... 310-794-5964Fax ........................................................... 310-794-6410

University of CaliforniaUCLA-LOSH ProgramSPPSR/IIR6350B Public Policy BuildingP.O. Box 951478Los Angeles, CA 90095-1478

University of Massachusetts—Lowell

Paul Morse ............................................. 978-934-4389Fax ........................................................... 978-452-5711

University of Massachusetts—LowellDept. of Health and Clinical SciencesCollege of Health ProfessionsNew England ConsortiumWeed Hall, Rm. 305Lowell, MA 01854

University of Medicine & Denistry of New Jersey

Mitchel A. Rosen .................................... 732-235-9452Fax ........................................................... 732-235-9460

University of Medicine & Dentistry of New JerseySchool of Public Health335 George St.Liberty Plaza, Ste. 2200P.O. Box 2688New Brunswick, NJ 08903

Xavier University of Louisiana

Myra M. Lewis ........................................ 504-304-3327Fax ........................................................... 504-304-3329

Xavier University of LouisianaDeep South Center for Environmental JusticeP.O. Box 37Campus Box 45BNew Orleans, LA 70125-1098

Introduction

Table of Contents

Motivating Safe Work Practices 1

Getting Workers to Comply With Safe Work Practices ................................................... 2

Job Safety Analysis ........................................................................................................... 2

Target Critical Behaviors ................................................................................................... 4

Participation ...................................................................................................................... 4

Feedback .......................................................................................................................... 6

Other Ideas ....................................................................................................................... 7

Feedback Charts ............................................................................................................... 8

An Example of a Feedback Chart ..................................................................................... 9

Activity 1 .......................................................................................................................... 12

Activity 2 .......................................................................................................................... 14

Rice Land Development

Company Exercise 15

Scope of Work .................................................................................................................. 16

Purpose of Work ............................................................................................................. 16

Property History .............................................................................................................. 17

Current Property Status .................................................................................................. 18

Exercise 1: Accident Investigation ................................................................................. 19

Dwyer Construction, Ltd. ................................................................................................. 20

Testimonies ..................................................................................................................... 21

First Aid Report ............................................................................................................... 26

Supervisor Accident/Incident Report ............................................................................... 29

Drainage ......................................................................................................................... 30

Gunto Remediation Company ......................................................................................... 31Testimonies.................................................................................................................................... 32

First Aid Report ..............................................................................................................................36

Supervisor Accident/Incident Report ............................................................................................. 39

Drum Sling ..................................................................................................................................... 40

Moreland Demolition Company ..................................................................................................... 41

Introduction

Testimonies ..................................................................................................................... 42

First Aid Report ............................................................................................................... 45

Supervisor Accident/Incident Report ............................................................................... 48

Crane Operation.............................................................................................................. 49

Exercise 2: Monitoring, Work Zones, and PPE .............................................................. 50

Environmental Health and Safety Sampling Results ....................................................... 51

Work Zones ..................................................................................................................... 52

Site Map .......................................................................................................................... 53

PPE for Dwyer Construction ........................................................................................... 54

PPE for Gunto Remediation ............................................................................................ 55

PPE for Moreland Demolition .......................................................................................... 56

Exercise 3: Dealing With the Media ................................................................................ 57

Exercise 4: OSHA Investigation ...................................................................................... 59

OSHA Complaint Forms.................................................................................................. 62

Exercise 5: Standard Operating Procedures ................................................................. 68

Site-Specific Program for

Rice Land Development Company 71

A. Site Description ........................................................................................................... 71

B. Entry Objectives .......................................................................................................... 71

C. On-Site Organization and Coordination .................................................................... 72

D. On-Site Control ............................................................................................................ 73

E. Hazard Evaluation ........................................................................................................ 73

F. Personal Protective Equipment ................................................................................... 75

G. On-Site Work Plans ..................................................................................................... 76

H. Communication Procedures ....................................................................................... 78

I. Decontamination Procedures....................................................................................... 78

J. Site Safety and Health Plan ......................................................................................... 79

Health and Safety Officer ................................................................................................ 79

Emergency Medical Care ................................................................................................ 79

Introduction

Available Medical Facility and Ambulance Service ......................................................... 79

Available First Aid Equipment ......................................................................................... 80

Emergency Medical Information ...................................................................................... 80

Emergency Phone Numbers ........................................................................................... 81

Environmental Monitoring ............................................................................................... 82

Emergency Procedures ................................................................................................... 82

Personal Monitoring ........................................................................................................ 84

Attachment A: Preliminary Organizational and Function Chart ................................... 84

MSDS: Trichloroethylene ................................................................................................. 86

Accident Investigation 97

Purposes of Accident Investigation ............................................................................... 99

Accident Investigation Procedures .............................................................................. 100

Interviewing Witnesses ................................................................................................. 102

Investigative Committee ................................................................................................ 103Supervisor’s Accident/Incident Report.........................................................................................105

Monitoring 107

Direct-Reading Instruments .......................................................................................... 108

Combustible-Gas Indicator (CGI) .................................................................................. 109

Flame Ionization Detector (FID) .....................................................................................110

Ultraviolet Photoionization Detector (PID) ......................................................................110

Colormetric Indicator Tube ............................................................................................. 111

Laboratory Analysis Instruments ..................................................................................112

Monitoring Methods ........................................................................................................114

Area Sampling................................................................................................................114

Monitoring for IDLH and Other Dangerous Conditions ...................................................114

Perimeter Monitoring ......................................................................................................115

Personal Monitoring .......................................................................................................115

Environmental Sampling ................................................................................................116

Water Sampling ..............................................................................................................116

Introduction

Soil Testing .....................................................................................................................116

Wipe (Swipe) Testing .....................................................................................................116

Variables Affecting Waste Site Exposure Assessment ................................................117

Site Control 119

Site Maps ........................................................................................................................ 120

Site Preparation .............................................................................................................. 122

Site Work Zones ............................................................................................................. 123

Exclusion Zone.............................................................................................................. 125

Contamination Reduction Zone ..................................................................................... 126

Support Zone ................................................................................................................ 127

The Buddy System ......................................................................................................... 128

Connumication Systems ............................................................................................... 129

Site Security.................................................................................................................... 131

Safe Work Practices ....................................................................................................... 132

Personal Protective Equipment 133

Respiratory Equipment .................................................................................................. 135

Facepieces .................................................................................................................... 135

Self-Contained Breathign Apparatus ............................................................................. 135

Supplied-Air Respirators ............................................................................................... 136

Combination SCBA/SAR ............................................................................................... 136

Air-Purifying Respirators ............................................................................................... 136

Air Supply Considerations ............................................................................................. 137

Federal Requirements for Respirators ......................................................................... 138

Chemical-Protective Clothing and Accessories .......................................................... 139

Types of Chemical-Protective Suits .............................................................................. 139

CPC Selection ............................................................................................................... 141

Accessories Used With CPC......................................................................................... 142

Head Protection ............................................................................................................ 142

Introduction

Eye and Face Protection ............................................................................................... 143

Ear Protection ............................................................................................................... 143

Gloves ........................................................................................................................... 143

Foot Protection .............................................................................................................. 143

Levels of Protection ....................................................................................................... 144

What Is Level A Protection? .......................................................................................... 144

What Is Level B Protection? .......................................................................................... 145What is Level C Protection? ........................................................................................................146

Typical Uses of Level D Equipment .............................................................................................147

The PPE Program ........................................................................................................... 148

Clothing Reuse.............................................................................................................. 149

Inspection ...................................................................................................................... 150

Maintenance and Storage ............................................................................................. 152

Selecting Respiratory Equipment ................................................................................. 153

Medical Fitness to Wear a Respirator ........................................................................... 154

Facial Hair and Respiratory Protection ........................................................................ 155

Fit Tests ........................................................................................................................... 156

Periodic Fit-Tests ........................................................................................................... 156

Routine User-Checks .................................................................................................... 158

Recordkeeping .............................................................................................................. 160

Emergency Procedures ................................................................................................. 160

Work Mission Duration .................................................................................................. 161

Handling the Media 163

Interview Techniques ..................................................................................................... 165

Crisis Communication Plan ........................................................................................... 167

OSHA Inspections 169

Opening Conference .....................................................................................................................170

Records Review ............................................................................................................................171

Introduction

Site Safety and Health Program.................................................................................... 171

Injury and Illness Records ............................................................................................. 173

Employee Exposure and Medical Records ................................................................... 173

Hazard Communication ................................................................................................. 173

Posting Requirements ................................................................................................... 174

Walk-Around Inspections .............................................................................................. 175

Closing Conference ....................................................................................................... 176

Follow-Up Actions ......................................................................................................... 177

Site-Specific Safety

and Health Plan 179

Site-Specific Safety and Health Plan ............................................................................ 181

Hazard Analysis for Site Tasks and Operations ............................................................ 182

Employee Training Assignments ................................................................................... 183

Personal Protective Equipment ..................................................................................... 184

Medical Surveillance Requirements .............................................................................. 184

Monitoring and Sampling .............................................................................................. 185

Site Control Measures................................................................................................... 186

Decontamination Procedures ........................................................................................ 187

Emergency Response Plan ........................................................................................... 188

Confined-Space Entry Procedures ................................................................................ 189

Pre-Entry Procedures.................................................................................................... 195

Entry Procedures .........................................................................................................................195

Post-Entry Procedures ................................................................................................................196

Midwest Consortium 1

Motivating Safe Work Practices

No one, brief training session can substitute for years of practical experience and intensivetraining in supervisory skills. What we hope to do in this program is to suggest several waysfor you to think about getting workers to do their jobs in a safe and productive way.

It all starts with you!

A safe work setting requires the cooperation of all employees of the company—from thenewest hourly worker to top management. It is well known that organizations with safe workpractices and high productivity are managed by people with a strong and active commitmentto safety. Safety-oriented management sets the tone, provides the needed equipment, en-courages safety training, gets workers involved with decisions about work practices, monitorshow safely people work, and rewards safe work practices.

When it comes to safety, you are part of management. You set the tone. If you ignore safetyrules, so will your workers. If you work safely, it is more likely that your crew also will worksafely. If you believe in and communicate the importance of safe work practices to workers,they will be more likely to engage in safe work practices.

As part of management, you are also responsible that the proper equipment is availableand is maintained in good working order. The best of intentions and attitudes will not protectyour workers if their chemical-protective clothing, respirators, eye protection, hearing protec-tion, and other safety equipment is not available and well-maintained. That is why other partsof this course address topics like respiratory and CPC programs.

Motivating SafeWork Practices

2 8-Hour Supervisors’ Course, Ver. 120302


Getting Workers to Comply With Safe Work Practices

In order to carry out your (and senior management’s) commitment to a safe and injury- andillness-free work setting, to set an example by working safely, and to provide proper and well-maintained protective equipment, you need a strategy to increase workers’ participation insafe work practices. There are several approaches to encouraging workers to comply withsafe work practices. These can be summarized by:

� Job safety analysis.

� Targeting critical behaviors.

� Participation.

� Feedback.

These strategies are undertaken after an analysis of each job has been conducted and thehazards identified. Then, for each hazard, the strategy can be implemented to help preventillness or injury.

Let’s look at each of these ideas separately and then see how we can put them together tocreate a work environment where safe work practices are the norm rather than the exception.

Job Safety Analysis

Job Safety Analysis (JSA) or Job Hazard Analysis (JHA) is a micro-level accident preventiontechnique in which each job is broken down into job elements or tasks, and for each element,specified hazards are identified and corrective actions specified. Thus the three major compo-nents of a job safety analysis are:

� Elements (tasks) of the job.

� Hazards associated with each task.

� Corrective actions to control or eliminate the hazards.

Job safety analysis must not be used as a tool for performance evaluation or for settingproduction standards. If this is done, it will invariably detract from the purpose of the JSA,which is to prevent accidents. Hostility towards the process of job safety analysis will result,and the credibility of the program will be determined, and “safety will get a bad name.” By thesame token JSAs must not be used in disciplinary actions, where the worker is accused ofrefusing to work as directed. Again, the sole purpose of the JSA is to encourage safe workpractices—nothing more, nothing less.



Workers should be integrally involved in writing and editing their JSAs. Workers havemore first-hand, direct experience with doing the job that they are usually given credit for.They know from their own experience what will work and what won’t. Supervisors andmanagers constructing JSAs should take advantage of this experience pool; part andparcel of this process will be a commitment expressed not to use the JSAs for the pur-poses described above.

JSAs should be periodically updated. This can be done via a joint labor/managementcommittee, through safety audits, “toolbox” safety meetings, and through accident inves-tigation. Nothing is necessarily cast in stone; technology, equipment, and safety regula-tions are in an almost constant state of flux.

And finally, JSAs must be short and compact. Three or four pages is probably too long.To be used, they must be short and sweet, and workers must have copies available. Manycompanies have their JSAs printed on cards and plasticized to protect against the weather.JSAs should be reviewed with workers at their initial training and periodically thereafter at“toolbox” meetings and other opportunities, and especially when workers are returningfrom lay-offs or vacations or are just beginning a new project.

Building the JSA

� Specify the job or task clearly, as well as the tools and equipment necessary to do the job,emergency information, and the effective date.

� List the job elements in the far left-hand column. Most jobs can be broken down into fourto ten major job elements. (This is a ball-park figure only.)

� In the middle column, list the hazard(s) associated with each job element. Try to charac-terize the nature of the hazard with terms such as “struck by, struck against, contact with,cuts by, slips on, caught in . . .,” and then list the specific object.

� On the far right column, list the corrective action. This would include the specific safe workpractice, the protective equipment and/or respirator, an engineering control, or other workmethod.

Repeat this process until all job elements have hazard and corrective actions listed forthem. Then have this draft reviewed with the affected workers for comments and criticisms. Itis best if comments are saved on a word processor, for quick revision and cloning to formJSAs for related job tasks.



Target Critical Behaviors

You have learned to analyze the hazards in each job as part of Job Safety Analysis. Effectivesafety programs target specific behaviors or actions. Proper performance of selected behav-iors will—in the long run—reduce workplace injuries and illness. As a supervisor, you havethe opportunity to help select critical behaviors through Job Safety Analysis (JSA) and to helpworkers increase the frequency with which they perform those critical activities safely.

For example, doing a positive and a negative fit check before donning an air purifying respi-rator (APR) will help assure that it protects the worker from exposure; this is a critical protec-tive behavior which you as a supervisor support, even though it takes time.

Using participation and feedback, you want to increase how often workers perform theselected tasks in ways that will reduce injury and illness to themselves and to other workers.

Participation

Worker participation in planning how work will be carried out and how to develop safe workpractices is an old idea that has become “hot” again. Why is worker participation in planningand carrying of safe work practice effective?

� Participation gives workers a sense of “ownership” in the activity. For that reason, they aremore likely to follow safe work practices.

� Participation leads to workers and supervisors setting higher goals for themselves. Howdoes setting goals impact worker performance?

When people are personally involved in setting goals for their own behavior, they tendto set high goals. As long as goals are realistically high, workers are likely to try toreach them and will likely succeed. For example, “Before I don my chemical-protec-tive clothing (CPC), I will check the cuffs for wear 100% of the time.” is better than,“Before I don my CPC, I will check the cuffs for wear 90% of the time.” The first goal isrealistically high and should produce safer CPC donning behavior.



When workers set specific goals rather than general goals, they are more likely to dobetter. For example, “Before I don my CPC, I will check the cuffs for wear 100% of thetime” is better than, “I will don my CPC correctly.” The first goal is much more specific thanthe second statement.

Notice that the idea of thinking about specific safe work behaviors also is part of properJob Safety Analysis (JSA).

The more that workers accept the goals that they set for themselves, the more likely theywill try to accomplish their goals. Workers are more likely to accept the goals they set forthemselves if they value the goals (we all value health), if the goals are specific , and if thegoals are realistically high.

� When workers participate in planning and implementing safe work practices, they come tobelieve correctly that top management is committed to their well-being and to a safeworking environment. Because of this belief, workers are more inclined to accept thegoals they set and to work to accomplish those goals.

� Participation of workers in planning and implementing safe work practices improves per-formance of the work crew because each worker can contribute his or her ideas on how toaccomplish the task safely. The more ideas thrown into the discussion, the more likely agood strategy will emerge. Participation allows for workers to use their training and ex-perience to create solutions to workplace problems.

� When workers participate in planning and implementing work strategies, they will gain asense of increased ability to perform their tasks competently. When people believe theycan do the task, they are more likely to do it. Participation and health and safety trainingboth lead to this sense of competence.

Remember that participation has value only if workers are appropriately trained on job tasks,if they have received adequate health and safety training, if you and they have the appropriatetools and equipment to perform the job safely, and if you and they have the support of topmanagement. When these aspects are met, you as a supervisor oversee a workplace wheresafety is achievable.



Feedback

What do we mean by feedback? Is feedback the same as a reward for a job well done? Isfeedback the same as punishment for a job poorly done? No. Feedback is different fromreward or punishment.

Feedback is simply information to the worker on how successful he or she is at achievingthe selected behaviors. You can provide feedback by displaying workers’ behavior on graphsor charts, or you can simply tell workers how well they are doing. Several examples of feed-back for a selected critical behavior. follow:

� Targeted Behavior: When drums are placed on a wooden pallet, the bottoms of thedrums should not overhang the pallet.

� Observe the Behavior: Keep track of how many times (and what percent of the time)drums are placed correctly with no overhang.

� Feedback: Display the percentage of times the drums were correctly placed. You can dothis at the safety “tailgate” or “tool box” meeting. You can simply tell the crew or, better yet,show it to them in a table or chart.

One of the important reasons for giving feedback to workers (and to supervisors) is that wetend to overestimate how often we do things correctly. In fact, using the methods describedabove may show that we perform tasks correctly a lot less often than we think.



Other Ideas

As we have talked about, your work group will do its job more safely when they:

� Participate in the job safety analysis, in proposing solutions, and in setting safety goals.

� Set realistically high specific safety goals.

� Receive feedback (information) on how well they are meeting the goals.

There are several other ideas that you might want to consider in your role as supervisor:

� Get involved in teaching safe work practices to your work group. Teaching safe workpractices is too important to leave to the specialists! Your involvement in teaching showsyour workers that safety is important. There is good evidence that production does notsuffer when supervisors are involved in teaching safe work practices.

� Use the buddy system. You already know that the buddy system is a Standard OperatingProcedure (SOP) in site work. This is an extension of that idea. Try to get pairs of workersto remind each other how to do the job properly, to encourage each other to work safely,or to discourage each other from taking unsafe short-cuts in doing the job.

� Show your workers some obstacles they might face in trying to work safely, and talk themthrough how they might overcome those obstacles. Obstacles to safe work practices willbe different from site to site and from job to job. This technique depends a lot on yourexperience and the experiences of your workers. This technique also works well becauseworkers have an opportunity to share their knowledge with others and be involved indescribing the obstacles to safe work practices and proposing solutions to overcome theobstacles.



Targeted Critical Behaviors M T W Th F M T W Th F

1.

2.

3.

4.

5.

Baseline Observation Feedback ObservationObservation

Feedback Charts

After you and your work group decide on the targeted critical behaviors that lead to accidents,injuries, or exposures, you (or another observer) randomly observe workers doing these tasksand record whether they are being done correctly.

During the first set of observations, no feedback is given to the workers. These are calledthe baseline observations. Baseline observations are important because they show workersthat they are not complying with safe work practices as often as they think they are.

During the second set of observations, group feedback is given to the workers abouttheir rates of compliance.

The observations are then summarized in a table like the one below. The results can also begraphed so that trends in the data can be seen more easily.

Depending on the physical layout of the work area, results can be posted on bulletin boardsor the wall or handed out to workers on a regular basis, maybe 3–4 times per week.

These tables become the basis for a discussion about worker compliance with safework practices.



An Example of a Feedback Chart

� A plus (+) sign in a box means that the behavior was done correctly.

� A minus (–) sign in a box means that the behavior was performed incorrectly.

� A blank (no + or –) box means that the behavior was not observed.

� We will be looking at workers’ performance across the five targeted critical behaviorstaken together.

Stack drums in rows, two drums wide,with an aisle between the rows. – + – – + + + + +


Number of targeted behaviors observed 5 3 5 4 2 5 4 5 4 3

Number performed correctly 4 1 2 2 0 2 4 4 3 3

Percent performed correctly 80% 33% 40% 50% 0% 40% 100% 80% 75% 100%


Make sure the bottom edges of the drumsdo not hang over the pallets. – – – – – – + + – +

Do not stand on a drum to take a samplefrom another drum. + + + + –

Read labels before handling a drum. + – – + – + + + +

Do not stack drums containing incompatiblechemicals next to each other. + – + – + + +

1.

2.

3.

4.

5.



The observation form and summary data point out two key conclusions that we havealready noted:

� The rate of compliance is typically low (baseline percents).

� Providing feedback on performance tends to improve compliance (feedback percents).

These two points are clear from looking at the percentages. Sometimes, the impact offeedback is not so dramatic. It may be useful to plot the percentages on a graph to see thepattern of results more clearly.

We looked at the set of five targeted behaviors in this analysis. It is also possible to look atchanges in compliance for each targeted behavior separately. One finding might be that therewas a dramatic improvement in targeted behavior #2.

Question for you:

What other patterns of worker compliance do you see in this table?



Baseline Observations

0%

20%

40%

60%

80%

100%

Do positive fit-check before donning the APR.

Do negative fit-check before donning the APR.

Check the cuffs on the CPC for a proper seal.

Review hand and arm signals before entering the hot zone.

Review work plan before entering the hot zone.

Monday Tuesday Wednesday Thursday Friday

It may be useful to plot the observations on a graph to see the pattern of results more clearly.



Activity 1

Your work group identified five critical behaviors that they may have not been doing properly.You observed and recorded whether they correctly performed these activities over a two-week period.

The first week is your baseline observation—when no feedback is given to the workers. Thesecond week you start giving group feedback to workers on their compliance. A summary ofyour observations over the two-week period is shown in the table below.

Do positive fit-check before donningthe APR. 20% 25% 20% 30% 25% 95% 70% 60% 50% 50%



Do negative fit-check before donning theAPR. 20% 25% 20% 30% 25% 95% 70% 60% 50% 50%

Check the cuffs on the CPC for a properseal. 55% 60% 60% 50% 40% 90% 80% 60% 40% 40%

Review hand and arm signals beforeentering the hot zone. 90% 50% 30% 20% 20% 90% 80% 70% 40% 40%

Review work plan before entering thehot zone. 100% 80% 70% 40% 40% 100% 95% 100% 90% 100%

1.

2.

3.

4.

5.

Average percent correct. 57% 48% 40% 34% 30% 94% 79% 70% 54% 56%

1. Interpret the results of two weeks of observations.

a. Compare baseline and feedback periods.



b. Look for trends within the baseline and feedback periods.

c. How effective was feedback in improving overall compliance?

d. Describe any interesting patterns you see for any one of the five targeted behaviors.

2. What might you do to increase their compliance with those five critical behaviors?



Critical Behaviors Obs. 1 Obs. 2 Obs. 3 Obs. 4 Obs. 5

1.

2.

3.

4.

5.

Activity 2


Rice Land Development Exercise

Rice Land DevelopmentCompany Exercise

During this exercise you will use a mock Site-Specific Safety Plan to investigate issues andanswer questions concerning operations at Rice Land Development Company. The Site-Spe-cific Safety and Health Plan included in this manual is not complete; it is for training purposesonly. While answering questions and solving problems for the Rice Land Development Com-pany Exercise, think about what would be useful that is not included.

Reference chapters follow this exercise. Refer to the specific topics as you completethe group activities:

� Site-Specific Safety and Health Plan.

� Accident Investigation.

� Monitoring.

� Site Control.

� Personal Protective Equipment.

� Handling the Media.

� OSHA Inspections.



Scope of Work for Rice Land Development Company Project

A. Purpose of Work

Rice Land Development Company has purchased 20 acres of land outside of Alerding, Tenn.from the Bank of Alerding (foreclosed property) and plans to construct an outlet store shop-ping mall on the purchased land. The land lies adjacent to Highway 27, which has directaccess to Interstate 40. Prior to purchase of the land by Rice Land Development Company, anenvironmental survey was performed on the property, and various types of contaminationwere found. Based on a cost versus risk analysis, Rice Land Development Company pro-ceeded with the purchase at a substantially reduced price and assumed responsibility for theremediation of environmental contamination that had been found to exist.

Prior to construction of the shopping mall, Rice Land has determined that four minorenvironmental projects must be completed as agreed upon by local and state authorities.They are:

A. Construction of perimeter surface water drainage and collection/sampling system.

B. Excavation and removal of 11 drums buried by past owner prior to foreclosure bythe bank.

C. Installation of two upgradient and four downgradient perimeter groundwater collectionwells and treatment of contaminated soil where necessary.

D. Demolition of prior owner’s automotive service building.

Rice Land Development Company has subcontracted item A to Dwyer Construction Ltd.,items B and C to Gunto Remediation Company, and item D to Moreland Demolition Company.



B. Property History

From 1820 until 1950, the 20 acres of land purchased by Rice Land was used for agricul-tural purposes by the Smith family. In 1950 the 20 acres were used by Jake Smith (de-scendent of the Smith family) to construct and operate an automotive service company.(Land was used as collateral.) Operation of the company continued for 36 years, duringwhich time Jake Smith became Mayor of Alerding (1982) and operation of the companywas turned over to his son Jack and his daughter Jill. In 1986 new regulations requiredremoval of the old steel gas tanks and installation of new fiberglass tanks. These changeswere made by Jack and Jill; however, it was necessary to put the property and building upas collateral to obtain a loan for the new tanks.

In 1988 Jack and Jill filed for bankruptcy because of poor business practices, and the Bankof Alerding foreclosed on the building and property.

During the 38 years of operation, the Automotive Service Company performed mainte-nance and repair work on all makes/models of American cars as well as providing gasoline forfueling cars. Most of the waste generated by the company was dumped into a soil pit backbehind the building in a small landfill approximately 200 yards by 50 yards. Through recordsearches and on-site inspection, the landfill is suspected to contain used tires, batteries,drums of solvent waste, used oil and oil filters, paint, paint thinners, and scrap metal.

Prior to his children filing for bankruptcy, Mayor Smith hired a company to removethe fiberglass gas tanks and any waste (tires, drums, scrap metal, etc.) obvious to aperson surveying the property. Fill dirt was then brought in as surface cover for areaswith discolored soil.



C. Current Property Status

Upon completion of the environmental survey by Rice Land Development, the following typesof contamination had been determined:

� Four drums of trichloroethylene.

� Four drums of benzene.

� Three drums of perchloroethylene.

It was suspected that the drums were rusted with bulging tops.

� Soil analysis showed slight concentrations of lead; however, high levels of halogenatedsolvents/oil/volatiles have been found.

� The Automotive Service Company building is approximately 8,000 square feet. It is a one-story cinder-block and transite panel structure with a concrete floor. There is a front en-trance and two back entrances, as well as four service bays for car maintenance. Thebuilding is standing vacant—no free-standing equipment or visible hazardous materials. Itis known that the building was painted with lead-based paint.



Exercise 1: Accident Investigation

Three companies will be performing different operations for Rice Land Development Com-pany. The companies and their operations are:

� Dwyer Construction, Ltd.

• Construction of perimeter surface water drainage and collection/sampling system.

� Gunto Remediation Company

• Installation of two upgradient and four downgradient perimeter groundwater col-lection wells.

• Excavation and removal of 11 drums buried by past owner prior to foreclosureby the bank.

� Moreland Demolition Company

• Demolition of prior owner’s automotive service building.

Select the company/operation which most closely describes a situation you might find atyour job. All of the exercises will be completed for this company/operation. Break into groupsso everyone who chose Dwyer Construction, Ltd. is sitting together, etc. Read the scenarioand interviews for the company you chose. Discuss the information as a group, and thencomplete the accident investigation form. Refer to the chapter on Accident Investigation.



Dwyer Construction, Ltd.

The drainage system will consist of a trench six-feet wide and six-feet deep which will encirclethe proposed mall. Drainage basins will be built throughout the mall site to collect parking lotrun-off. The basins will transport the run-off to the perimeter drainage system, which willconnect to stormwater collection basins at the creek.

On March 15, 2001, Dwyer Construction, Ltd. commenced work to build the perimeter sur-face water drainage and collection/sampling system. During the morning hours of the first dayof work, a comprehensive construction safety meeting was held to inform all workers of thesafety and health plan requirements. Review of all excavation permits was completed to en-sure that construction personnel knew the locations of all above/below-ground utilities. Exca-vation of the perimeter drainage system started on the north side of the proposed mall loca-tion and proceeded to the west, then south, then east, and finally back north towards thecreek, where collection basins were to be built.

The drainage system excavation was to be completed on March 28, 2001. On March 25,Susan Jones, a member of the excavation crew, encountered a concrete pipe in the trench onthe southeast perimeter side. The pipe turned out to be a concrete stormwater drainage linewith an unknown origination. It is suspected that the drainage line originated from the automo-tive service building. Ed Jacobs, the construction foreman, instructed the construction crew touncover the storm drainage pipe as much as possible (not remove it) and proceed with thetrench excavation so that they would reach the collection basins by the deadline.

On the afternoon of March 27, the construction crew had completed the drainage systemtrench. Morry Town, the project engineer, decided to take a sample of the storm pipe obstruc-tion that had been encountered on the southeast perimeter and send the sample to the lab forasbestos testing. The storm pipe remained intact so that if any rain was encountered, stormwaterflow would not be obstructed or changed in any way.

On the evening of March 27, four inches of rain fell at the site due to an isolated thunder-storm. The uncovered storm pipe collapsed in the trench and flooded the entire perimetertrench and the collection basins. On the morning of March 28 at 7:00 a.m. (40°F), Ed Jacobsinstructed Susan Jones, Paul Morris, and John Jacobson (the construction crew) to installsump pumps in the perimeter trench and collection basins. After the sump pumps had beeninstalled, the rainwater was pumped onto the ground or into the creek. No work zones hadbeen established, and Susan, Paul, and John were all dressed in Level D.

At 10:00 a.m. (65°F), Paul started to detect a solvent-like odor throughout the site. Susanand John were both feeling lightheaded. Paul radioed Ed at the Command Post and told himabout the odor. Ed decided to stop work operations until monitoring results could be obtained.Susan, Paul, and John all reported to First Aid while Vicki Black, the industrial hygienist,surveyed the area. Vicki discovered that the trench, collection basins, area top soil, and creekhad been contaminated with trichloroethylene, perchloroethylene, and possibly lead.



Testimonies

The Health and Safety Officer for Dwyer Construction, Ltd. is Emily Brown. She has inter-viewed the following crew members concerning their role in the accident that happened: Su-san Jones, Paul Morris, John Jacobson, Vicki Black, and Ed Jacobs. These interviews wereconducted on the afternoon of March 28, 2001.

Interview with Susan Jones

Emily: Susan, how did you discover the storm pipe?

Susan: We were digging when I hit it . . .with my shovel.

Emily: What did you do then?

Susan: Well, I told Mr. Jacobs about it. He said I should get as much dirt away from it as Icould and then keep on working.

Emily: Did you notice any funny smells at this time?

Susan: No. I’ve had bad allergies for several weeks, so my sense of smell isn’t too good.

Emily: When did you notice the funny smell on the 28th?

Susan: I never did. I told you I can’t smell good. I just started feeling real queasy and dizzy.Paul’s the one who noticed the smell. I’m not sure if John did or not. He was aboutto pass out.



Interview With Paul Morris

Emily: Please tell me what happened this morning.

Paul: Well, when we got to work, the storm pipe that Susan found a couple days agohad collapsed. The rain had flooded the trench and the collection basins. It wasa real mess.

Emily: What did you do then?

Paul: Ed told us to install sump pumps and pump all the water out. We didn’t know thestuff was anything but water.

Emily: Was any monitoring done before you started work?

Paul: Not that I know of. We were under the impression that this was a clean area. Noone even mentioned chemicals or thought it might be a possibility.

Emily: When did you suspect that contaminants may be present?

Paul: I think it was around 10:00. We’d been working for a couple hours when I noticed akind of sweet smell in the air. About that time John almost passed out. I called Edand told him about it, and he told us to get out. Hey, can you tell me if this stuff wesmelled is going to hurt us?



Interview With John Jacobson

Emily: How are you feeling, John?

John: O.K., I guess. I’ve stopped throwing up, so I guess that’s a good sign.

Emily: Please tell me what happened this morning.

John: I got contaminated, and I’m going to sue. I don’t know who I’m going to sue; but I’mgoing to hire a lawyer, and I’m going to make someone pay.

Emily: How did you get contaminated?

John: Pumping all that water out, that’s how! If Susan had never found that storm pipe,this wouldn’t have happened. It’s all her fault. And Mr. Jacobs wouldn’t let us doanything with it. He said it was harmless.

Emily: Did it occur to you that the pipe could contain hazardous materials?

John: No, but why should it? I’m not here to make decisions. I just follow orders.

Emily: So when you started pumping the water this morning, or following orders, as youput it, it never occurred to you that the water might be contaminated?

John: No; but like I said, I’m just here to do the work. Someone else gets paid to think. AllI know is I trusted Mr. Jacobs when he said the area was safe and no contaminantswere present. Then Susan had to find that pipe.



Interview With Vicki Black

Emily: Vicki, please tell me your version of the events this morning.

Vicki: Well, Ed radioed me a few minutes after 10:00 to report to the Command Post.When I got there he told me what happened and told me to go monitor the area.

Emily: What did you find?

Vicki: It’s in my report. I picked up readings of trichloroethylene and perchloroethyl-ene and saw all the broken lead-acid battery cases. The stuff is all over theplace. I think the chemicals came from the stormwater drainage line that wasfound a couple days ago.

Emily: If you had monitored first thing this morning, would you have been able to detectthe contaminants?

Vicki: Oh, sure. The levels are high enough that I could have picked them up.

Emily: Why didn’t you monitor this morning?

Vicki: I was helping on another project. Gunto Remediation had a drum breach yesterday,and I was doing some monitoring for them. Ed gave me permission. He didn’t thinkwe would be dealing with any hazardous materials over at the mall site.



Interview With Ed Jacobs

Emily: Ed, can you explain to me why no monitoring was performed around the storm pipethat was found?

Ed: I guess it’s all my fault. It never occurred to me that there could still be hazardousmaterials in that pipe after all these years. Morry had a sample of the pipe sent tothe lab for asbestos testing, but we haven’t gotten the results back yet. I guess witheverything that’s happened around here the last couple of days, I just haven’t beenthinking clearly.

Emily: Vicki said you told her she could help Gunto Remediation with their project?

Ed: Yeah, in hindsight I guess that was a bad decision. She approached me with it thismorning; and since we didn’t suspect there were any contaminants near the trenchsite, I thought it would be O.K.

Emily: You were aware of the history of this site, weren’t you?

Ed: I read the environmental survey, and it said all the contamination was around thelandfill. We weren’t supposed to encounter any. I mean, if I had suspected therewere contaminants out there, I sure wouldn’t have sent people out to work dressedin level D. We were just trying to get the project finished by the deadline.



First Aid Report

Date: March 28, 2001 Time: 10:10 a.m.

Name: Susan Jones SS #: 259-64-1259

Address: 1563 West Point Drive, Alerding, Tenn. Age: 36

Phone: 615-234-3355

Cause of Injury/Illness:

Inhalation of chemical substance. Believed to be a combination of trichloroethylene, perchlo-roethylene, and lead.

Symptoms of Injury/Illness:

Dizziness, irritation of the eyes, some queasiness in the stomach, slight headache, and con-fusion. No apparent skin irritation.

Preliminary Diagnosis:

Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Temperature and blood pressure are within normal range. Blood analysis forlead will be completed to ensure elevated levels do not occur.

Recommendations:

Rinse eyes with water to remove irritation. Fresh air, plenty of water, and rest. If symptomspersist, consult regular doctor. Decontaminate clothing, and wash skin thoroughly with soapand water.



First Aid Report


Name: Paul Morris SS #: 415-69-2690

Address: 127 Salem Road, Alerding, Tenn. Age: 45

Phone: 615-234-3355



Symptoms of Injury/Illness:

Irritation of the nose, severe headache, and confusion.


Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Temperature is within normal range. Blood pressure is slightly elevated. Bloodanalysis for lead will be completed to ensure elevated levels do not occur.

Recommendations:

Painkiller prescribed for headache. Fresh air, plenty of water, and rest. If symptoms per-sist, consult regular doctor. Decontaminate clothing, and wash skin thoroughly with soapand water.



First Aid Report


Name: John Jacobson SS #: 378-24-9023

Address: 1543 Essex Road, Apt. B-3, Alerding, Tenn. Age: 23

Phone: 615-234-3355



Symptoms of Illness:

Dizziness, severe nausea, and confusion. No apparent irritation to eyes, nose, or throat.


Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Temperature and blood pressure are within normal range. Blood analysis forlead will be completed to ensure elevated levels do not occur.

Recommendations:

Dilute material in stomach with water. If vomiting does not subside, consult regular doctor.Fresh air and rest. Decontaminate clothing, and wash skin thoroughly with soap and water.



Supervisor’s Accident/

Incident Report

Injured Employee: ____________________________________________________________________________

Age: _________ Sex: _________ Job Title: _________________________________________________

Type of Injury: _______________________________________________________________________________

Part of Body Affected: _________________________________________________________________________

Property Affected

Description Estimated Loss Estimated Repair Cost

__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

Employees Involved

Name Employee ID Number

__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

Date of Accident/Incident: ________________________ Time of Incident: ____________________________

Location of Incident: __________________________________________________________________________

Reported to: __________________________________ Job Title: __________________________________

Date Reported: ________________________________ Time Reported: _____________________________

Description of Accident/Incident:

Cause of Accident/Incident:

Responsibility:

Action Taken to Prevent a Similar Incident:

Additional Action That Should Be Taken:

Corrective actions and cause of the incident have been reviewed with the employee(s) concerned: � Yes � No

Supervisor’s Signature: ________________________________________________________________________

Job Title: ___________________________________________________________ Date: _______________



Drainage


1.

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3.

4.

5.



Gunto Remediation Company

Rice Land Development Company contracted with Gunto Remediation Company to:

� Excavate and remove 11 drums buried by the past owner of the land Rice Land isdeveloping.

� Install two upgradient and four downgradient perimeter groundwater collection wells andbioremediate any contaminated soil.

The upgradient wells were installed on the south side of the automotive service building,and the downgradient wells were installed below the creek. Gunto is in the process of exca-vating and removing the bulging drums. According to the environmental survey, there are:

� Four drums of trichloroethylene.

� Four drums of benzene.

� Three drums of perchloroethylene.

After excavation is complete, the drums will be transferred to a waste disposal facility.The drums are located approximately 5 feet below ground level. Surface grass and rockshave already been cleared away.

At the safety meeting on March 27, 2001, Tina Apple instructed the three environmentalfield team members (Andy Moore, Bob Green, and Chris Anderson) to start excavating andremoving the drums. She instructed them to wear Level C clothing since the materials in thedrums were contained. The work zones are as outlined on the site map in the Site-SpecificSafety and Health plan.

After the safety meeting Tina went home sick, which left Mike Fox in charge of the fieldteam members.

At approximately 3:30 p.m. the temperature had reached 70 degrees. Mike Fox was in ameeting with Jeff West, Project Engineer, at the Command Post. Andy Moore was operatinga backhoe to unearth the drums. Three drums of trichloroethylene had already been un-earthed and removed to surface level.

Bob Green and Chris Anderson are using a drum sling and forklift to load the bulging drumsonto a pick-up truck. The pick-up truck is located on the west side of the landfill, approximately15 feet from the excavation. Two drums have already been loaded. While the third drum isbeing lifted, it slips out of the sling, falls to the ground, and breaches. The entire contents ofthe drum (55 gallons) spill onto the ground. Both Bob and Chris are splashed by the contents.At this point Bob and Chris yell at Andy and tell him what has happened. Andy radios theCommand Post and tells Jeff that a drum has breached and that Bob and Chris are coming infor first aid. After terminating the conversation with Jeff, Andy stops work and leaves the site.



Testimonies

The Health and Safety Officer for Gunto Remediation Company is David Cohen. He hasinterviewed the following crew members concerning their role in the accident: Chris Ander-son, Bob Green, Tina Apple, Andy Moore, and Joshua Fox. The interviews were con-ducted during the afternoon of March 27, 2001.

Interview With Chris Anderson

Tina: Chris, please tell me your version of how the drum fell out of the sling.

Chris: Well, David, I was up on the forklift, so I couldn’t see exactly what Bob was doing. Idon’t think he was being real careful, though.

David: Why do you say that?

Chris: I’ve worked with Bob on other projects, and we haven’t had a drum breach before,but we have had them slip.

David: Did you tell anyone about this?

Chris: Yes, I mentioned it to Tina at the safety meeting this morning. She said she wouldtake care of it, and then she left. I guess she forgot.

Interview With Bob Green

David: Bob, please tell me your version of how the drum fell out of the sling.

Bob: David, I really don’t know. I loaded the drum in the sling the same as the previoustwo drums. They didn’t fall out of the sling.

David: Did you check the straps before telling Chris to start lifting the drum?

Bob: Of course I did. I know the proper procedure for lifting a drum.

David: Did you notice anything unusual about this particular drum or the sling?

Bob: No. I swear I strapped the sling on exactly the way I was supposed to. Hey, I gotsplashed with the stuff. Why would I do anything that would cause me to get splashedwith the stuff?

David: Who told you to use the sling?

Bob: Tina did in the safety meeting this morning.



Interview With Tina Apple

David: Tina, I realize you were home sick when the drum breached, but I have a couple ofquestions about the safety meeting that morning.

Tina: Sure, David. What do you want to know?

David: Why did you tell the environmental field team members to use a forklift and drumsling to load the drums on the truck?

Tina: There weren’t going to be a lot of drums to move, and it seemed like a pretty simplemethod.

David: Did Chris Anderson mention anything to you about Bob Green?

Tina: Yes, Chris told me that he didn’t have a lot of confidence in Bob’s ability to movedrums.

David: Did he say anything else?

Tina: Something about drums slipping on other projects. I didn’t take it too seriously.

David: Why not?

Tina: Oh, you know how Chris is. He complains about everyone, and nothing is evergood enough for him. It doesn’t take a lot of skill to put a drum in a drum sling. Iknow that, and you know that. I really thought he was blowing hot air, and I’m reallysick of his whining.

David: Did you investigate Chris’s comments?

Tina: No. Why should I? For crying out loud, David. I was sick. I wanted to go home. Whyshould I have taken the time to investigate some petty comments?

David: So you chose not to change the method of loading the drums, even though some-one had questioned Bob’s ability to complete the task?

Tina: Yeah, so what’s the big deal? We spilled a little TCE. It’s not like the ground wasn’talready contaminated with it.



Interview With Andy Moore

David: Andy, what can you tell me about the drum slipping out of the sling?

Andy: Not a whole lot. I was operating the backhoe when it happened. Guess it had tohappen eventually.

David: What do you mean?

Andy: Well, I didn’t want to say anything before, but Bob’s not real careful when usingslings. I know of a few other times when drums have slipped.

David: Why didn’t you say anything?

Andy: First off, I didn’t want to get Bob in trouble. Then I heard Chris talking to April aboutit, so I thought the problem was handled. Guess I should have known better.

David: What do you mean?

Andy: Their conversation didn’t seem real friendly. I’m not trying to throw stones at April,but she’s had a grudge against Chris ever since he showed her up in the safetymeeting last week. You remember . . . the issue about the well placement and hewas right and she was wrong. Anyway, after she finished her conversation withChris, I saw her talking to Mike and, as far as I know, she did not repeat Chris’scomments to Mike.

David: Where was Chris at this time?

Andy: He had stormed out of the room.

David: So you think that April may have let her personal feelings for Chris cloud her judge-ment of the situation and of Bob’s abilities?

Andy: I don’t know. I just know there has really been some friction between those twolately, and I don’t want to get caught in the middle of it.



Interview With Mike Fox

David: Did you attend the safety meeting this morning?

Mike: Yeah, I was there. What a mess. Tina conducted it, and I just sat in the back andlistened.

David: Did anything unusual occur?

Mike: I don’t know what you consider unusual. No one got killed,.ha, ha, ha. Seriously,Tina handed out the work assignments and discussed the work zones and personalprotective equipment.

David: Did you agree with her on the work assignments?

Mike: That doesn’t really matter. No one crosses Tina. She is still on the warpath afterChris when he questioned her judgement last week.

David: Did Tina and Chris have a conversation this morning?

Mike: Yeah, if you can call it that. Their eyes seemed to be spitting fire. I asked Tina whatit was all about, and she said nothing important. Hey, I don’t want this to sound likeTina doesn’t do a good job. She does, and I would trust her with my life. She justhas a real hard time getting respect around here since she’s a woman and all. Chriskept information from her last week on where to drill the wells just so he could showher up at the safety meeting. He still hasn’t forgotten that she got promoted toenvironmental engineer over him. He’s a real male chauvinist. He gets the wholecrew laughing at her, and she is just trying to do her job.

David: Were you aware that people were questioning Bob’s ability to strap on drum slings?

Mike: No, I was not. I haven’t been with this company very long. In fact, this is only mysecond project, and it is the first time I have ever worked with Bob. I wish someonehad mentioned it to me.



First Aid Report

Date: March 27, 2001 Time: 3:45 p.m.

Name: Chris Anderson SS #: 228-91-4781

Address: 42 Overton Rd., Alerding, Tenn.

Phone: 615-234-9523


Inhalation of trichloroethylene. Victim was also splashed with the chemical.


Irritation of throat. Dizziness and nausea. Slight skin irritation on wrists and throat.


Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Irritation to the skin is not severe. Temperature is within normal range. Bloodpressure is slightly elevated.

Recommendations:

Decontaminate clothing, and wash skin thoroughly with soap and water. Drink water to dilutesubstance in the stomach. Fresh air and rest. If irritation of the throat or skin irritation does notclear up, consult physician.



First Aid Report


Name: Bob Green SS #: 193-76-8924

Address: 893 Park Vista, Alerding, Tenn.

Phone: 615-234-9523


Inhalation of trichloroethylene. Victim was also splashed with the chemical.


Dizziness and nausea. Victim also suffering from excessive fatigue. Slight eye irritation.


Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Temperature and blood pressure are within normal range.

Recommendations:

Decontaminate clothing, and wash skin thoroughly with soap and water. Rinse eye with luke-warm water for 20 minutes. Drink water to dilute substance in the stomach. Fresh air and rest.



First Aid Report


Name: Andy Moore SS #: 432-90-4982

Address: 251 Bailey Dr., Alerding, Tenn.

Phone: 615-234-9523


Possible inhalation of trichloroethylene.


Slight headache.


May have been some inhalation of chemical fumes but in minimum amounts. Should have nolong-lasting effects. Temperature and blood pressure are within normal range.

Recommendations:

Decontaminate clothing, and wash skin thoroughly with soap and water. Fresh air and rest.




Incident Report


Age: _________ Sex: _________ Job Title: _________________________________________________

Type of Injury: _______________________________________________________________________________


Property Affected


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

Employees Involved


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________







Responsibility:





Job Title: ___________________________________________________________ Date: _______________



Drum Sling


1.

2.

3.

4.

5.



Moreland Demolition Company

Moreland Demolition is in charge of the tearing down and removal of the AutomotiveServices Building. The building fronts Highway 27 and is located adjacent to the intersec-tions of Highway 27 and Interstate 40. The building is a 100' x 80' one-story cinder-blockand transite panel structure situated on a 12" concrete slab footing. The south face of thebuilding (facing Highway 27) consists of an entrance to a small office on the west cornerand four repair bay entrances. The north face of the building has two exit doors that leadto storage areas. The interior was previously gutted, and all equipment has been removedfrom the repair bays. Although the debris has been removed from the building, a visualinspection of the area shows cracking and peeling paint and other paint residue coveringall interior surfaces and floors. Also visible are oil slicks around floor drains that are lo-cated in each of the four bays.

Demolition of the building began on March 24, 2000. A safety meeting was called on-site,and all employees were briefed on the requirements of the job. Due to the potential for dustconcentrations during demolition, air-purifying respirators were available for use during thedemolition activities. Standard PPE was required for the job (e.g., hardhats and steel-toedshoes). No other PPE was thought to be necessary. By March 27, all roofing and transite wallpanels were removed intact and stored at the east end of the building.

Removal of the concrete pad has begun. The pad is being jackhammered into a 6' x 6'section, and the demolition crew members are on the pad either operating jackhammers orhelping the crane operator with removal activities. Slab sections are being moved by thecrane operator to a dump truck. Removal activities are proceeding from east to west.

It is late afternoon on March 27, and the temperature has peaked for the day at 70 degrees.The crane is now situated on the east end of the building, and slab removal activities arealmost complete. The slabs are being lifted by the crane, and placed in a dump truck. JimBurkey is operating the crane, and Hank Chad is driving the dump truck. Denise Douglas,Daniel Long, and George Williams are affixing the cable to the slabs before they are lifted.While affixing the cabling to one of the last slab sections Daniel notices a viscous liquid seep-ing out from underneath. After the crane hook is connected, George signals for Jim to lift thesection. A pool of liquid becomes visible underneath the removed section. The crane haslifted the section approximately five feet into the air when the slab section falls back into thepool of liquid. The falling slab narrowly misses Denise. Denise, Daniel, and George are splashedby the liquid. In the commotion caused by the accident, the dump truck backs over the transitepanels that have been stored nearby.

At this point all work ceases. Denise, Daniel, and George all report to First Aid. Jim andHank take a sample of the unknown substance to the lab to be analyzed. Preliminary resultsshow the substance is a mixture of benzene and perchloroethylene.

Personnel returned to the site the next morning, March 28, to find that rain overnight haddrenched the area. Run-off from the area has contaminated other site areas.



Testimonies

The site supervisor for the Moreland Demolition Company is Melissa Vaughn. She has inter-viewed the following crew members concerning their role in the accident that happened: DeniseDouglas, Daniel Long, and George Williams. Ms. Vaughn has also interviewed the craneoperator, Jim Burkey, and the dump truck driver, Hank Chad.

Interview With Denise Douglas

Denise: Tell me what was going on when the slab fell.

Denise: I had been breaking up the slab all afternoon, and we were told to wrap it up beforeheading out. I was just finishing a chunk when I heard Daniel yell “look out.” I turnedaround and got a face full of the crap that went flying when the slab hit.

Melissa: So, you didn’t see what happened?

Denise: I just turned around as the slab hit the ground, but I think I heard the hook let go.Dan said that he did what he was supposed to. He thinks that the crane guy screwedup by trying to move the slab too high and too fast.

Melissa: Did anybody know that there was stuff under the slab?

Denise: While I was working on the slab, I saw that the dirt was getting black out towardsthat end of the building, but I didn’t think much of it. At the safety meeting they didn’tsay anything about crap being under the pad.

Melissa: Was there anything else that you saw that would be useful?

Denise: I think that the crane guy screwed up. The dump truck guy said that he wasn’t inposition to get the slab, and he was moving to get to where he needed to be.When he saw the slab begin falling, he got distracted and that’s when he ranover the pile of stuff.



Interview With Daniel Long

Melissa: Tell me what was going on when the slab fell.

Daniel: I had just finished hooking up to rigging and got the hook in place when Jim, thecrane operator, snapped the line and the thing jumped. It was swinging around allover the place, and then it let loose. I yelled for people to “look out.” I almost got hitwhen the thing fell, and I got that goo all over me. Man, it was everywhere.

Melissa: Did anybody know that there wasn’t solid groundwater under the slab?

Daniel: I saw stuff oozing out from under the slab. I was standing in it when I was hookingup the crane. There was nothing on the other end of the building. It just got baddown at the end. I was going to stop, but Jim was in a rush to get out of there.

Melissa: Did you see anything else?

Daniel: Not really, we were kind of covered in the stuff and just trying to get it off us. I heardthe dump truck run into the panels but didn’t see it happen. Jim had been in a fightwith the dump truck guy all day. They kept fighting over where he should positionthe truck.

Interview With George Williams


George: I was helping Daniel fix up the slabs. He and Jim were in this rush to get done. Jimhad been yelling at him all day about how slow he was. I don’t know if Daniel hadhooked things up right or if Jim was jacking the slabs around. I didn’t have anythingto do with it. Don’t let anyone tell you different. All I know is that the damn thing felland almost hit me. I got the crap in my eyes, and it really hurt. We were all lookingfor water to get the stuff off.

Melissa: Did you know the stuff was there before this happened?

George: We all saw that the dirt was getting black as we got to the end, but we didn’t thinkanything of it. We didn’t think that there was going to be a problem. There wouldn’thave been if the damn slab hadn’t fallen.


George: No, I didn’t see anything else. But I knew something was going to happen. Every-one was running around screaming at everyone else. Hank and I were talking be-fore the stuff happened. We knew something was going to happen. Jim was crazy.He had Hank driving the dump truck all over the place ’cause he said he couldn’tget the slabs in the truck. Hank ran into the panels because that crazy Jim wasdirecting her where to go instead of watching the slab being lifted.



Interview With Jim Burkey


Jim: I don’t know what was going on. George signaled to me that I could lift the slab. Istarted lifting it. It got up in the air about five feet, and then something shifted andthe thing started jumping around. I reacted as quick as I could, but before I shutthings down, the slab had fallen. I think that Daniel didn’t have the thing hooked upwhen George gave me the go-ahead to start lifting. Once it got into the air, therewas nothing I could do.


Jim: No one said anything to me. They all knew it was there, but they just wanted to getthe job done. If I would have known, I would’ve stopped work until someone couldsee what the stuff was. I know better than to mess with something when we don’tknow what it is.


Jim: I saw Hank run into the panels. I knew it was going to happen. He doesn’t payattention to what he’s doing. He is just too green to be doing the job that he is doing.He doesn’t know what you have to do when you are crane-loading.

Interview With Hank Chad


Hank: I really didn’t see the slab fall. I saw people running out trying to get to the water towash. Jim was motioning for me to back up, and I was following his directions whenthe slab fell. I don’t know how he could be watching what he was doing with the slabas well as giving me directions all at the same time.


Hank: Yeah. We all knew that there was crap there. The slabs were covered underneath.I thought that everyone knew about it. Nobody seemed to be concerned.


Hank: I didn’t see anything. I was just trying to see what Jim wanted. He couldn’t make uphis mind where he wanted me to be. He wasn’t real clear about how he wanted todo this job. We should have talked about it before we started working. He was insuch a rush that we were doing things on the fly when we should have been follow-ing procedures better. I know the procedures, and we sure weren’t following them.I know I should have done things right, but Jim can get things riled up when he is ona job.



First Aid Report


Name: Denise Douglas SS #: 589-25-1189

Address: Apt. C, 33 Chasteen Place., Alerding, Tenn.

Phone: 615-234-6376


Splashed with mixture of benzene and perchloroethylene. Inhalation of same substance. Vic-tim was not wearing respirator.


Dizziness and staggering gait. Skin shows some irritation on the hands and face.


Inhalation of chemical substances did occur but was considered minor. Should have no long-lasting effects. Irritation to the skin is not severe. Temperature is slightly elevated (99.2°).Blood pressure is normal.

Recommendations:

Decontaminate clothing, and wash skin and eyes thoroughly with soap and water. Drink waterto dilute substance in the stomach. Fresh air and rest. If irritation of the skin does not clear up,consult physician.



First Aid Report


Name: Daniel Long SS #: 459-82-1190

Address: Rural Route 65, Alerding, Tenn.

Phone: 615-234-6376


Splashed with mixture of benzene and perchloroethylene. Inhalation of same substance. Vic-tim was not wearing respirator.


Nausea and dizziness. Skin shows slight irritation and some blistering on the hands andarms. Victim seems very confused.


Inhalation of chemical substances did occur but was considered minor. Should have nolong-lasting effects. Irritation/blistering to the skin is not severe. Temperature and bloodpressure are within normal range.

Recommendations:

Decontaminate clothing, and wash skin thoroughly with soap and water. If skin irritation/blis-tering does not clear up, consult physician. Drink water to dilute substance in the stomach.Fresh air and rest.



First Aid Report


Name: George Williams SS #: 419-28-3671

Address: 7619 Ole Towne Drive, Alerding, Tenn.

Phone: 615-234-6376


Splashed with mixture of benzene and perchloroethylene. Victim was wearing respirator.


No visible signs of inhalation. Some skin dryness on arms and throat.


Inhalation of chemical substances did not occur. Dryness to the skin is not severe. Tempera-ture and blood pressure are within normal range.

Recommendations:

Decontaminate clothing, and wash skin thoroughly with soap and water. Fresh air and rest. Ifskin dryness does not clear up, consult physician.




Incident Report


Age: _________ Sex: _________ Job Title: _________________________________________________

Type of Injury: _______________________________________________________________________________


Property Affected


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

Employees Involved


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________







Responsibility:





Job Title: ___________________________________________________________ Date: _______________



Crane Operation


1.

2.

3.

4.

5.



Exercise 2: Monitoring, Work Zones, and PPE


New monitoring data for the sites have just been received. Using the monitoring data, theNIOSH Pocket Guide, and the chapters on monitoring, site control, and PPE, answer thefollowing questions for your chosen company/scenario. Refer to the site map for the locationof the sampling points.

� Which chemical appears to be the biggest threat to safety and health? Why?

� What level of PPE should be worn in the area your chosen company is working? Why?

� Where might additional hazardous materials be buried on the site? Why?

Gunto Remediation





Moreland Demolition







Environmental Health

and Safety Sampling Results

SamplingPoint Time TCE (ppm) Benzene (ppm) Perk (ppm)

1 10:30 a.m. < 1 < 1 < 1

4 11:00 a.m. 150 5 < 1

7 11:30 a.m. 20 5 1

10 12:00 p.m. < 1 < 1 < 1

14 12:40 p.m. 90 30 3

Lead concentrations of 0.001 mg/m3 were measured at the decon trailer. The sampler wasoperated for eight hours. A four-hour sample at the trench area contained 0.04 mg/m3.



Work Zones (See map.)

Using the monitoring data and the site map, determine if the location of work zones should bechanged for your chosen company/scenario.

� Select a recorder who will present your group’s site map on an overhead transparency.

� Read all the questions first, and discuss possible answers using the site plan.

� Draw or write the group’s answers on a scrap piece of paper first.

� Using colored markers, transfer the group’s answers to the transparency.

Questions

� Where should the control boundaries of the Exclusion (Contaminated or Hot) Zone be?Draw on the map.

� Where should the boundaries of the Contamination Reduction (Warm) Zone be? Draw onthe map.

� Where should the boundaries of the Support (Staging Area or Cold) Zone be? Draw onthe map.

� Where should the Decontamination Line be? Draw on the map.

� Where should the Site Security perimeter be? Draw on the map.

� Where should the evacuation routes be designed? Draw on the map.



Site Map

I-40

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Bay 1

Bay 2

Bay 3

Bay 4

11

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raile

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& S

how

er

Co

mm

an

d P

ost

Security

12

5

1

2

10

Sto

rm P

ipe

Obstru

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n

6

9

8

7

Ba

sin

& D

isch

arg

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14

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Personal Protective Equipment

for Dwyer Construction, Ltd.

The following protective clothing materials are required for the specific task with the an-ticipated exposures.

� Job Task: Installation of Sump Pump

� Potential Exposure: Perchloroethylene

Using the MSDS and any other resource material available to you, indicate the personalprotective equipment needed for the job above. Please mark all equipment or the “best”types of material that may apply.

Level of Protection: � A � B � C �D

Head/Eye Face

� Hard hat� Safety glasses� Face shield� Goggles

Hand Protection

� Neoprene� Nitrile� PVC� Viton� Underglove� Other, specify______________________

Body Protection

� Fully encapsulating suit,specify material ____________________

� Two-piece rainsuit,specify material ____________________

� One-piece splashsuit,specify material ____________________

� Tyvek™ suit� Tyvek™/Saranex™ suit� TyvekTM/Polyethylene suit

Respirator

� SCBA (open-circuit, pressure-demand)� Full-face respirator,

specify cartridge ___________________� Half-face respirator,

specify cartridge ___________________� Other, specify______________________

Foot Protection: Material

� Neoprene� Viton� Nitrile� Butyl

Foot Protection: Type

� Overboots� Safety shoes� Knee boots� Work boots




for Gunto Remediation Company


� Job Task: Evacuation of drums

� Potential Exposure: Trichloroethylene



Head/Eye Face


Hand Protection


Body Protection





Respirator











for Moreland Demolition Company


� Job Task: Removal of concrete slab

� Potential Exposure: Benzene



Head/Eye Face


Hand Protection


Body Protection





Respirator










Exercise 3: Dealing With the Media

The following article appeared in the morning paper on March 29, 2000.

Near-death experience at local construction site

ALERDING, Tenn.—Serious accidents and mis-takes have been occurring over the past twodays at the Rice Land Development Companyconstruction site. The accidents have resultedin hazardous chemicals being released into theatmosphere and potentially endangering thehealth of all workers at the site as well as thosein the surrounding community.

During the afternoon of March 27, employ-ees from Gunto Remediation Company improp-erly handled four drums of trichloroethylene,spilling all of the contents onto the ground. Thechemical penetrated the ground, possibly con-taminating the groundwater. Five employeeswere splashed with the chemical and immedi-ately rushed to first aid for treatment. No reporton their condition is available at press time.

During the same afternoon employees fromMoreland Demolition Company were lifting aslab of concrete when the slab fell off the crane.The slab hit two workers before falling into apool of an unknown liquid substance. The sub-stance splashed at least 50 feet into the air,

contaminating all the workers from MorelandDemolition. The workers hit with the slab weretaken to first aid and treated for possible con-cussions. The contaminated workers wererinsed off with water and sent home.

To make matters worse, the rain during theevening of March 27 caused an uncoveredstorm pipe, which Dwyer Construction had dis-covered, to collapse. The rain spread hazard-ous chemicals in the storm pipe throughout theentire Rice Land Development site. Dwyer Con-struction did not provide their workers with anypersonal protective equipment before sendingthem out to work the morning after the rain.

Workers at the Rice Land Development siteare angry and afraid. An unidentified sourcestated that “We were told there were no haz-ardous chemicals at this site. Now we’ve allbeen contaminated, and they expect us to cleanthe mess up.” Gunto Remediation, MorelandDemolition, Dwyer Construction, and Rice LandDevelopment representatives refused commentwhen reached by this newspaper.



When you reported for work on March 29th, there were representatives from three local TVstations as well as four newspapers. There were also representatives from the mayor’s office,two local radio stations, the Local Emergency Planning Committee, and the local Citizens’Environment Committee. Two residents at the nearby retirement community resumed their“sidewalk superintendent” positions. Everyone wanted to know what had happened, whatchemicals had been released, and what was being done to prevent further exposures. Therepresentative from the mayor’s office wanted to know if they needed to evacuate the town;the representative from the LEPC wanted to know why they hadn’t been told about the sever-ity of the contamination. You picked the wrong day to forget your stomach antacid.

Your responsibility is to quickly diffuse the situation. In your small groups, discuss the eventsthat have occurred. Select a recorder and map out the steps that should be taken to deal withthe media. Refer to the chapter in this manual on “Handling the Media.” Prepare a short pressstatement that focuses on the events surrounding the company/operation you have beenworking with. As a group you will then present your press statement to the rest of the class.The class will then have the opportunity to ask you questions and critique your statement.

Note: All press releases should be merged, so that only one message goes to the public.



Exercise 4: OSHA Investigation

An OSHA inspector has arrived on the site to investigate a complaint of unsafe working con-ditions by a worker. The OSHA inspector gave you a copy of the complaint form and asked tosee a copy of your site-specific safety and health program. Using the complaint form for thecompany/operation you have been working with and the following checklist, review in yoursmall groups the site-specific safety and health program to determine if it sufficiently coversthe hazards that are present at the site. Refer to the chapter on “OSHA Investigation” and“Site Safety and Health Plan.” The copy of 29 CFR 1910.120 appended to this manual mayalso be a helpful resource.

1. List specific rights and responsibilities of supervisors during an OSHA inspection.

2. Does the safety and health plan sufficiently describe the hazards that are present?

a. List the chemicals and quantities described in the plan.

b. List the hazards associated with the chemicals described in the plan.

c. List the decontamination procedures described in the plan.



3. What personal protective equipment is recommended to be used for the job tasks de-scribed for your company/operation? Is the PPE described sufficient to protect thesafety and health of the workers?

4. Have the workers been sufficiently trained to handle the hazards they might face com-pleting the job tasks?

5. Describe the medical surveillance program that has been established at the site.

6. Describe the schedule for periodic air monitoring.

7. What site control measures are described in the site safety and health plan?



8. Describe the emergency response procedures, including the lines of authority, for achemical spill.

9. Which sections of the Site-Specific Safety and Health Plan are deficient for your com-pany/operation?

As a group, select one section of the plan that is deficient and re-write it for your company/operation. Alternatively, complete a job hazard analysis for an activity at the company youused for this exercise. List any information you need that is not available.



Notice of Alleged Safety Health Hazards State Labor Cabinet

Department of Workplace Standards

Occupational Safety and Health Program

2. Company Name

_________________________________________________________________________________________________

3. Site Location (Street, City, State, Zip)

_________________________________________________________________________________________________

4. Mailing Address (if different) (Street, City, State, Zip)

_________________________________________________________________________________________________

5. Management Official 6. Telephone Number

_________________________________________________________________________________________________

7. Type of Business

_________________________________________________________________________________________________

8. Hazard Description—Describe briefly the hazard(s) which you believe exist. Include the approximate number of em-

ployees exposed to or threatened by each hazard.

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

9. Hazard Location—Specify the particular building or work site where the alleged violation exists.

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________


455 Highway 27, Alerding, TN

P.O. Box 19, Alerding, TN

S. Gunto 615-234-8932

Environmental Remediation

The hazard is exposure to trichloroethylene. We were loading a drum onto a truck when the drum

breached and spilled its contents. The drum slipped out of the drum sling we were using to

load it on the truck. Our supervisor had told us in the safety meeting that morning that we

should wear level C protection since the chemicals were contained in the drums. I received

burns to the wrists and throat. I also experienced dizziness and nausea. We were not wearing

respirators at the time of the exposure. The drum fell out of the sling because the worker who

put it in the sling doesn’t know how to do it. I informed our supervisor of that in the safety

meeting and she ignored my warnings. The entire contents of the breached drum spilled onto

the ground. If my supervisor had listened to me in the safety meeting, this accident could

have been avoided. Besides myself, one other worker was splashed with the chemical. We

suffered dizziness, nausea, fatigue, eye and throat irritation, and chemical burns.

At the Rice Land Development Company shopping mall project on Highway 27. The drum breached

next to the landfill behind the old Automotive Service Building.



X

X

X

Chris Anderson 615-234-9532

42 Overton Rd., Alerding, TN

Chris Anderson March 28, 2001

X

X

X

X

X

X






2. Company Name

_________________________________________________________________________________________________


_________________________________________________________________________________________________


_________________________________________________________________________________________________


_________________________________________________________________________________________________

7. Type of Business

_________________________________________________________________________________________________



_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________


_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________



P.O. Box 22A, Alerding, TN

M. Moreland 615-234-4532

Demolition

I got a mixture of benzene and perk splashed on me. It got on my face and I got skin irritation on my hands

and my face. I also almost got hit with a falling slab. The job task was to tear down an old automotive

service building. When a slab of concrete was being removed, it slipped off the crane and splashed me with

the chemicals. The chemicals were underneath the slab of concrete. There were three workers splashed, but

I think I got splashed the most. We all went to first aid and they sent us to decontamination. At the

decontamination trailer we got sprayed with water and sent home. The whole area is contaminated because of

the rain and they expect us to continue our work. They gave us some respirators to wear but I broke mine.

I need some clothing to protect my skin. They have not issued us any protective clothing except for the

respirators, hard hats, and steel-toed shoes. If we continue to work without more protection, more workers

are going to get exposed. One of the workers who got splashed got blisters on his skin. We all got some skin

irritation as well as dizziness, nausea, confusion, and I had some problems walking.

At the Rice Land Development Company mall project. It’s on HWY 27. The Automotive Service

Building is right there on the Highway. Well, it’s a little back from the highway, but you can

see it from HWY 27.



X

X

X

Denise Douglas 615-234-6376

Apt. C, 33 Chasten Place, Alerding, TN

Denise Douglas March 28, 2000

X

X

X

X

X

X

X

Laborers Union






2. Company Name

_________________________________________________________________________________________________


_________________________________________________________________________________________________


_________________________________________________________________________________________________


_________________________________________________________________________________________________

7. Type of Business

_________________________________________________________________________________________________



_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________


_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

_________________________________________________________________________________________________

Dwyer Construction Company


14 Builders Rd., Alerding, TN

R. Dwyer 615-234-5656

Construction

I have been exposed to perchloroethylene, trichloroethylene, and lead. During drainage

excavation a storm pipe was exposed. When it rained the other night, the storm pipe collapsed

in the trench and spilled the chemicals all over the place. The spill wasn’t discovered until

we had been exposed to the chemicals for three hours. No monitoring was done after the pipe

collapsed to determine if any chemicals were present. We were instructed on the morning of

the exposure to install sump pumps in the trench and catch basins. We were only wearing level

D clothing when we were exposed. We had been told there was no chance we would be exposed to

any hazardous chemical. I got some sever nausea and was pretty dizzy and confused. Two other

workers were exposed and they suffered nausea, dizziness, headaches, confusion, eye irrita-

tion, and nose irritation. We have to continue cleaning this mess up and no additional PPE has

been issued to us. I don’t want to be exposed again.

At the Rice Land Development Company shopping mall project. It’s on HWY 27. The whole trench

surrounding the proposed mall is contaminated.



X

X

X

John Jacobson 615-234-3355

1543 Essex Rd., Apt. B-3, Alerding, TN

John Jacobson March 29, 2001

UBC



Exercise 5: Standard Operating Procedures

For the section of the Site-Specific Safety and Health Plan or the Job Hazard Analysis thatyour group wrote for Exercise 4, list three relevant standard operating procedures (SOPs)which would improve health and safety. For each, describe the content which should be in-cluded in the best SOP. Be creative and make sure you include specific types of equipment, ortimes of the day, or materials to be used. SOPs help protect the safety and health of workers.Think about the scenario and describe how each SOP might have helped avoid an accident.OSHA standards and reference materials are provided; please ask the instructors.

Assuming this SOP is not in place, develop strategies of getting it implemented. Howwould you approach management to get needed equipment or supplies? List the barrierswhich might exist and approaches to resolving each issue. Will the workers need motiva-tion to comply with this SOP? List the barriers which might exist and approaches to re-solving each issue. A worksheet is provided on the next page.



How would you approach management to get needed equipment or supplies?

Barrier Resolution

_______________________________________________________________________

_______________________________________________________________________

_______________________________________________________________________

How would you motivate workers to comply with your group’s SOP?

Barrier Resolution

_______________________________________________________________________

_______________________________________________________________________

_______________________________________________________________________

Midwest Consortium This plan is for training purposes only. 71

Site-Specific Safety Program

Site-Specific Safety Programfor Rice Land Development Company

A. Site Description

Date: February 16, 2000

Location: 455 Highway 27, Alerding, Tenn.

Hazards: Chemical, biological, confined-space, heavy equipment, electrical

Area Affected: 20 acres; proposed mall development

Surrounding Population: 15,000

Topography: Dense forest surrounding open clay fill area

Weather Conditions: Prevailing wind from southwest; late afternoon showers are likely.

Additional Information: Most of the 20-acre site consists of clay fill dirt

B. Entry Objectives

A. Construction of perimeter surface water drainage and collection/sampling system aswell as installation of two upgradient and four downgradient perimeter groundwatercollection wells.

B. Excavation and removal of 11 drums buried by past owner prior to foreclosure by the bank.

C. Bioremediation of contaminated soil where necessary.

D. Demolition of prior owners’ automotive service building.

72 This plan is for training purposes only. 8-Hour Supervisors’ Course, Ver. 120302


C. On-Site Organization and Coordination

See Attachment A for the on-site organizational chart for the three contractors.

Potential outside agencies and contractors that may be required throughout this projectinclude the following:

Federal Agency Representatives

EPA Region IV........................................................... U.S. Helper ......... Atlanta, Ga. ................. 555-555-5555

State Agency Representatives

Tennessee Dept. of Env. and ConservationDiv. of Solid Waste Mgmt. ......................................... A. Helper............. Nashville, Tenn............ 555-555-5555

Tennessee Dept. of Env. and ConservationDiv. of Water Pollution Control ................................... B. Helper............. Nashville, Tenn............ 555-555-5555

Local Agency Representatives

Tennessee Dept. of Env. and ConservationDiv. of Solid Waste Mgmt. ......................................... C. Helper ............ Knoxville, Tenn. ........... 555-555-5555

Tennessee Dept. of Env. and ConservationDiv. of Water Pollution Control ................................... D. Helper ............ Knoxville, Tenn. ........... 555-555-5555

Contractors

Dwyer Construction, Ltd. ........................................... R. Dwyer ............. Alerding, Tenn. ............ 555-555-5555

Gunto Remediation Company ................................... S. Gunto ............. Alerding, Tenn. ............ 555-555-5555

Moreland Demolition Company ................................. M. Moreland........ Alerding, Tenn. ............ 555-555-5555

All personnel arriving or departing the site must log in and out with security. All activities onsite must be cleared through the Project Managers.



D. On-Site Control

Wackenhut, Inc. has been designated to coordinate access control and security on-site. Theestablished safe perimeter is as shown in Attachment B. No unauthorized person is allowedaccess to the site.

The on-site Command Post and staging area have been established at trailer A locatedat the security checkpoint. The prevailing wind is from the southwest. This location isupwind from the Exclusion Zone.

Control boundaries have been established in each project area. The zones are as shownon the site map. These boundaries are identified by:

� Red danger tape for the exclusion zone.

� Yellow caution tape for the contamination reduction zone.

� Blue tape for the support zone.

E. Hazard Evaluation

Substances that are known or suspected to be on site have been evaluated for their potentialhazards. Information sheets may be found on each of these substances in Attachment C.Known or suspected substances and their potential hazards are as follows:

� Trichloroethylene: 4 drums, toxic

� Benzene: 4 drums, toxic

� Perchloroethylene: 3 drums, toxic

� Lead: Slight concentration/soil, toxic



The concentrations will be determined by Industrial Hygiene (IH) monitoring. The followingadditional hazards are expected on site:

� Confined spaces.

� Motor vehicles.

� Slips, trips, and falls.

� Power tools.

� Snakes.

� Struck-by.

� Poison ivy.

� Ticks.



F. Personal Protective Equipment

Based on the evaluation of potential hazards, the following levels of personal protection havebeen designated for the applicable work areas or tasks:


� No suspected exposure.

� Recommended Level of Protection: Level D

� Recommended Clothing: Hard hat, goggles, work gloves, chemical-resistant overboots, andcoveralls

Gunto Remediation Company:

� Exposure to tricholorethylene, benzene, and perchloroethylene possible.

� Recommended Level of Protection: Level A

� Recommended Clothing: Positive-pressure SCBA, totally encapsulating chemical-pro-tective suit, inner and outer chemical-resistant gloves, hard hat under suit, chemical-resistant, and steel-toed boots

Moreland Demolition Company:

� Exposure to dust and possible lead.

� Recommended Level of Protection: Level C

� Recommended Clothing: Full-face respirator with dust cartridge, coveralls, hard hat, workboots, and work gloves



G. On-Site Work Plans

Work parties will perform the following tasks:

Project Manager

Oversees completion of project in accordance with budget and schedule.

Project Engineer

Ensures that construction, demolition, and environmental tasks are completed in accordancewith design and SOPs.

Construction Foreman

Oversees field construction crew.

Environmental Engineer

Oversees environmental field team members and conduct sampling.

Health and Safety Officer

Ensures compliance with health and safety plan. Can initiate “stop work.”

Public Relations Officer

Interfaces with regulatory agencies and community (press, local officials, etc.).

Security

Maintains access control.



Industrial Hygienist

Conducts air monitoring, establishes PPE requirements, and oversees medical surveillance.

Construction Crew

� Construct drainage system and collection basins.

� Demolish and remove building debris.

Environmental Field Team

� Install monitoring wells.

� Remove contaminated soil, drums, tires, and batteries.

Rescue Team

Consists of industrial hygienists and environmental engineers.

Decontamination Team

A central decontamination trailer has been set up to be used when needed.



H. Communication Procedures

Channel 1 has been designated as the radio frequency for personnel in the Exclusion Zone.For all other on-site communications, use channel 2.

Personnel in the Exclusion Zone should remain in constant radio communication or withinsight of the Project Manager. Any failure of radio communication requires an evaluation ofwhether personnel should leave the Exclusion Zone.

One horn blast, 2 minutes in duration, is the emergency signal to indicate that all personnelshould leave the Exclusion Zone and proceed to the assembly areas.

The following standard hand signals will be used in case of failure of radio communications:

Signal ..................................................... Meaning

Hand gripping throat..................................... No air

Hands on top of head ......... Cannot complete work

Thumbs up ..................................... Everything OK

Thumbs down........................... Everything not OK

Telephone communications to the Command Post should be established as soon as pos-sible. The phone number is 666.

I. Decontamination Procedures

Personnel leaving the Exclusion zones shall be thoroughly decontaminated in the decontami-nation trailer. Decontamination protocol will be determined by the industrial hygienist whenneeded. Equipment will remain on-site until completion of projects.



J. Site Safety and Health Plan

Health and Safety Officer

The designated health and safety officers for the three contractors are:

� Emily Brown, Dwyer Construction, Ltd.

� David Cohen, Gunto Remediation Company.

� Melissa Vaughn, Moreland Demolition Company.

The Health and Safety officers are directly responsible to the Project Manager for safetyrecommendations on-site. Anyone who will be working on the site is required to have a physi-cal examination and be approved for work by a physician before work commences.

Emergency Medical Care

Qualified EMTs on-site are:

� Vicki Black, Dwyer Construction Ltd.

� Jane Smith, Gunto Remediation Company.

� Mark Hall, Moreland Demolition Company.

Available Medical Facility

and Ambulance Service

Alerding General Hospital at 2727 Linda Road, Alerding, Tenn., 615-234-6543, is located 15minutes from this location.

Dr. Denny was contacted on 3/18/00 and briefed on the situation, the potential hazards, andthe substances involved. A map of alternative routes to this facility is available at the Com-mand Post.

Local ambulance service is available from Alerding Rescue Squad at 615-234-HELP.Their response time is 3 minutes. Whenever possible, arrangements should be made foron-site standby.



Available First Aid Equipment

The following first aid equipment is available at the decontamination trailer:

� First-aid kit.

� Emergency eye wash.

� Emergency shower.

Emergency Medical Information

Trichlorethylene

Move victim to fresh air. Remove contaminated clothing. If skin is contaminated, washskin with water and non-abrasive soap. If eye(s) is contaminated, flush with lukewarmwater for 20 minutes, holding eyelid open. If ingested, have victim drink 8 to 10 oz. waterto dilute in stomach. Provide comfort, warmth, and rest. Consult a physician and/or thenearest Poison Control Center for all exposures except minor instances of inhalation orskin contact. All first aid procedures should be periodically reviewed by a physician famil-iar with the material and its condition of use in the particular workplace. Refer to materialsafety data sheet for detailed information.

Benzene




Perchloroethylene


Emergency Phone Numbers

Police

Bill West .........................615–234–9999

Fire

Tom Stone ...................... 615–234–8976

Hospital

Dr. Denny ....................... 615–234–6543

Airport

Angie Cox ....................... 615–234–7732

Public Health Advisor

Bernard Robers .............. 615–234–6521



Environmental Monitoring

Environmental monitoring instruments available:

� hNU.

� Combustible-gas indicator.

� Colorimetric detector tubes.

� Heat dosimeters.

� Particulate grab samplers.

A chemical analysis lab exists on-site next to the decontamination trailer.

Emergency Procedures

The following standard emergency procedures will be used by on-site personnel. The Healthand Safety Officer and the Industrial Hygienist shall be notified of any on-site emergenciesand be responsible for ensuring that the appropriate procedures are followed.

Personnel Injury in the Exclusion Zone: Upon notification of an injury in the Exclusionzone, the designated emergency signal (1 horn blast, 2 minutes in duration) shall be sounded.All site personnel shall assemble at the decontamination trailer. The rescue team will enterthe Exclusion Zone (if required) to remove the injured person to the hotline. The Health andSafety Officer and the Project Manager should evaluate the nature of the injury, and theaffected person should be decontaminated to the extent possible prior to movement to theSupport zone. The on-site EMT shall initiate the appropriate first aid, and contact should bemade for an ambulance and with the designated medical facility (if required). No persons shallreenter the Exclusion Zone until the cause of the injury or symptoms is determined.



Personnel Injury in the Support Zone: Upon notification of an injury in the Support Zone,the Project Manager and Health and Safety Officer will assess the nature of the injury. If thecause of the injury or loss of the injured person does not affect the performance of site person-nel, operations may continue, with the on-site EMT initiating the appropriate first aid andnecessary follow-up as stated above. If the injury increases the risk to others, the designatedemergency signal (1 horn blast, 2 minutes in duration) shall be sounded, and all site person-nel shall move to the decontamination trailer for further instructions. Activities on-site will stopuntil the added risk is removed or minimized.

Fire and Explosion: Upon notification of a fire or explosion on site, the designated emer-gency signal (1 horn blast, 2 minutes in duration) shall be sounded and all site personnelassembled at the decontamination trailer. The fire department shall be alerted and all person-nel moved to a safe distance from the involved area.

Personal Protective Equipment Failure: If any site worker experiences a failure or alter-ation of protective equipment that affects the protection factor, that person and his/her buddyshall immediately leave the Exclusion zone. Reentry shall not be permitted until the equip-ment has been repaired or replaced.

Other Equipment Failure: If any other equipment on-site fails to operate properly, theProject Manger and Health and Safety Officer shall be notified and then determine the effectof this failure on continuing operations on-site. If the failure affects the safety of personnel orprevents completion of the Work Plan tasks, all personnel shall leave the Exclusion zone untilthe situation is evaluated and appropriate action taken.

Emergency Escape Route: The following emergency escape route is designated for usein those situations where egress from the Exclusion Zone cannot occur through the decon-tamination line: Four separate emergency assembly points have been established. Personnelfrom the Exclusion zone shall proceed to assembly point where red light is flashing.

In all situations when an on-site emergency results in an evacuation of the Exclusion Zone,personnel shall not reenter until:

� The conditions resulting in the emergency have been corrected.

� The hazards have been reassessed.

� The Site Safety Plan has been reviewed.

� Site personnel have been briefed on any changes in the Site Safety Plan.



Personal Monitoring

Heat Stress: The expected air temperature will be 80°F. If it is determined that heat stressmonitoring is required (mandatory if above 70°F), the following procedure must be followed:

� Heat stress dosimeter must be obtained from IH and worn.

Attachment A: Preliminary Organizational and Functional Chart

Construction, Ltd.

Project Manager .....................................Richard Dwyer ............................... 615–234–5656

Project Engineer .....................................Morry Town .................................... 615–234–7900

Construction Foreman ............................Ed Jacobs ...................................... 615–234–8822

Health & Safety Officer ...........................Emily Brown ................................... 615–234–9765

Public Relations Officer ..........................Marty Stein ......................................615–234–2115

Security .................................................. James Wright ................................. 615–234–4433

Industrial Hygienist .................................Vicki Black ..................................... 615–234–3377

Construction Crew ..................................Susan Jones .................................. 615–234–3355

...............................................................Paul Morris ..................................... 615–234–3355

............................................................... John Jacobson ............................... 615–234–3355




Project Manager .....................................Sam Gunto ..................................... 615–234–8932

Project Engineer ..................................... Jeff West ........................................ 615–234–3581

Environmental Engineers .......................Tina Apple ........................................ 615-234-0025

............................................................... Joshua Fox .................................... 615–234–0025

Health & Safety Officer ...........................David Cohen .................................. 615–234–6687

Public Relations Officer ..........................Susan Grant ................................... 615–234–8648

Security ..................................................Harold Smythe ............................... 615–234–9468

Industrial Hygienist ................................. Jane Smith ..................................... 615–234–6549

Environmental Field................................ Andy Moore ................................... 615–234–9523

Team Members .......................................Bob Green ..................................... 615–234–9523

...............................................................Chris Anderson .............................. 615–234–9523


Project Manager .....................................Mike Moreland ............................... 615–234–4532

Project Engineer .....................................Anita Highsmith .............................. 615–234–4457

Construction Foreman ............................Patrick Baskins .............................. 615–234–6322

Health & Safety Officer ...........................Melissa Vaughn.............................. 615–234–9975

Public Relations Officer ..........................Ron Michaels ................................. 615–234–3675

Security ..................................................Sandy Garcia ................................. 615–234–2536

Industrial Hygienist .................................Mark Hall ........................................ 615–234–2769

Construction Crew ..................................Denise Douglas ............................. 615–234–6376

...............................................................Daniel Long .................................... 615–234–6376

...............................................................George Williams ............................ 615–234–6376

...............................................................Doodle Burkey ............................... 615–234–6376

...............................................................Hester Chan ................................... 615–234–6376



Material Safety Data SheetCHEMINFO—Canadian Centre for Occupational Health and Safety

Section 1: Chemical Identification

CHEMINFO Record Number: 103

CCOHS Chemical Name: Trichloroethylene

Synonyms: Trichlorethylene, Ethylene trichloride

Trade Name(s): Trilene

CAS Registry Number: 79–01–6

PIN—(UN/NA Number[s]): 1710

RTECS Number(s): KX4550000

Chemical Family: Halogenated alkene

Molecular Formula: C2–H–C13

Structural Formula: C12C=CHC1

Section 2: Description

Appearance and Odour:Colourless liquid with chloroform-like odour.

Odour Threshold:21 ppm

Warning Properties:Poor—odour threshold is about half of the TLV. Irritation may occur at 30 ppm.

Composition/Purity:Triethanolamine or cresol may be added as antioxidants at concentrations below 1%.

Uses and Occurrences:Degreasing agent for metal; dry cleaning; thinner in some paints and adhesives.



Section 3: Hazards Identification

Potential Health Effects

Effects of Short-Term (Acute) Exposure:Inhalation: Vapours can cause irritation of the nose and throat at levels as low as 30 ppm. At 100–600 ppm,

there may be central nervous system depression characterized by dizziness, headache, vertigo, nausea, andexcessive fatigue. At high concentrations (above 1,000 ppm) loss of consciousness, tremors, lack of muscularcoordination, and visual disorder can occur.

Skin Contact: Prolonged contact with liquid can cause severe irritation and can lead to dermatitis. Chemicalburns have also been reported.

Eye Contact: Vapours can irritate the eyes. Liquid can cause reversible damage to the cornea.

Ingestion: Ingestion of trichloroethylene may be followed by vomiting, diarrhea, heart failure, pulmonary bleeding,damage to the nervous system and blindness.

Effects of Long-Term (Chronic) Exposure:Liver damage has been reported following long–term exposure to trichloroethylene. Injury to the nervous

system may occur, characterized by tremors, vertigo, decreased feeling in the hands, anxiety, slow down of theheart rate, and insomnia. Behavioural problems were also observed.

Carcinogenicity:In human studies, trichloroethylene exposure does not significantly increase the rate of cancer. There is

limited evidence of carcinogenicity in animal studies.

Teratogenicity and Embryotoxicity:Trichloroethylene can cross the placental barrier. Increased menstrual disorders in women and decreased

sexual potency in men have been reported following high–level exposures (100 to 630 ppm) which also causednervous system disturbances (4).

Mutagenicity:Limited human information is available; report of abnormal chromosomes in blood of workers with intense

exposure to trichloroethylene. Positive result in mutagenicity tests in mice (micronucleus test) and yeast and ina cell transformation test. Weak or negative results in several short–term tests in bacteria and mammalian cells.

Potential for Accumulation:Unlikely to accumulate: biological half–life about 41 h.



Section 4: First Aid Measures

Inhalation:Remove source of contamination or move victim to fresh air. If breathing has stopped, properly trained per-

sonnel should begin artificial respiration immediately. If heart has stopped, trained personnel should begincardiopulmonary resuscitation (CPR) immediately. Obtain medical attention.

Skin Contact:Remove contaminated clothing, shoes and leather goods (e.g. watchbands, belts). Wash gently and thor-

oughly with water and non–abrasive soap. If irritation persists, obtain medical attention. Completely decontami-nate clothing, shoes and leather goods before re–use or discard.

Eye Contact:Immediately flush the contaminated eye(s) with lukewarm, gently flowing water for 20 minutes, by the clock,

holding the eyelid(s) open. If irritation persists, obtain medical attention. Protect the eyes from light if painful.

Ingestion:Never give anything by mouth if victim is rapidly losing consciousness or is unconscious or convulsing. Do not

induce vomiting. Have victim drink 240 to 300 ml (8 to 10 oz.) of water to dilute material in stomach. If vomitingoccurs naturally, have victim lean forward to reduce risk of aspiration. Repeat administration of water. Obtainmedical attention immediately.

First Aid Comments:Provide general supportive measures (comfort, warmth, rest). Consult a physician and/or the nearest Poison

Control Centre for all exposures except minor instances of inhalation or skin contact. All first aid proceduresshould be periodically reviewed by a physican familiar with the material and its condition of use in the particularworkplace.

Section 5: Firefighting Measures

Flash Point:None by conventional test method

Lower Flammable (Explosive) Limit (LFL/LEL):8.0% at 25 deg C; 7.8% at 100 deg C (continuous contact with ignition source)

Upper Flammable (Explosive) Limit (UFL/UEL):10.5% at 25 deg C; 52% at 100 deg C (continuous contact with ignition source)

Autoignition (Ignition) Temperature:410 deg C (770 deg F)

Combustion and Thermal Decomposition Products:Phosgene, carbon monoxide, hexachlorobutene, dichloracetyl chloride, hydrogen chloride

Extinguishing Media:Water fog, dry chemical, carbon dioxide, foam



Firefighting Instructions:Use water–spray to keep fire–exposed containers cool. Water–spray may be used to flush spills away from

fire–exposed zone. Trichloroethylene vapour can burn with difficulty in the presence of a continuous ignitionsource. Its fire hazard is considered to be relatively low.

National Fire Protection Association (NFPA) Hazard Index:NFPA—Health: 2—Intense or continued (but not chronic) exposure could cause temporary incapacitation or

possible residual injury.

NFPA—Flammability: 2—Must be moderately heated or exposed to relatively high temperatures before igni-tion can occur.

NFPA—Reactivity: 0—Normally stable under fire conditions, and not reactive with water.

Section 6: Accidental Release Measures

Precautions:Restrict access to area until completion of cleanup. Ensure cleanup is conducted by trained personnel only.

Provide adequate personal protective equipment. Ventilate area. Remove sources of heat or flame to preventformation of hazardous decomposition products. Notify government environmental agencies if this material isreleased into the environment.

Clean-Up:Do not touch spilled material. Stop or reduce leak if safe to do so. Prevent material entering sewers or

confined spaces. Contain spill with earth, sand, or inert absorbent material. If it is feasible and can be donesafely, remove liquid by pumps or vacuum equipment. Place in suitable, covered, labelled containers. Soak upremaining spilled material with inert absorbent material and place in suitable, covered, labelled containers.Flush area with water. Contaminated absorbent may pose the same hazards as the spilled product. Large spills:Contact police, emergency services and supplier for advice.

Section 7: Handling and Storage

Handling:Do not use near welding operations, flames or hot surfaces. Avoid generating mists. Use in minimal quantities

in designated area with adequate ventilation. Wear appropriate personal protective equipment. Maintain trichlo-roethylene cleaning baths at neutral pH (e.g. with sodium carbonate).

Storage:Store in a cool, dry, well-ventilated area, out of direct sunlight and away from incompatible materials. Store in

suitable, labelled containers, kept closed and protected from damage. Limit quantity of material in storage. Keepstorage area separate from populated work area.



Section 8: Exposure Controls/

Personal Protection

NOTE: Exposure to this material can be controlled in many ways. The measures appropriate for a particular worksite depend on how thismaterial is used and on the extent of exposure. This general information can be used to help develop specific control measures. Ensure thatcontrol systems are properly designed and maintained. Comply with occupational, environmental, fire, and other applicable regulations.

Sampling and Analysis:Sampling should only be done by trained personnel using appropriate instrumentation and sampling strategy

(location, timing, duration, frequency, and number of samples). Interpretation of the sampling results is relatedto these variables and the analytical method. COLORIMETRIC–INDICATING (DETECTOR) TUBES: Commer-cially available. NIOSH METHOD(S): 127—NIOSH Manual of Analytical Methods. Vol. 1. DIRECT READINGINSTRUMENTS: The following device is commercially available: Infrared photometer (continuous sampling,portable or fixed).

Engineering Controls:Engineering control methods to reduce hazardous exposures are preferred. Methods include mechanical

ventilation (dilution and local exhaust), process or personnel enclosure, control of process conditions and pro-cess modification (e.g. substitution of a less hazardous material). Administrative controls and personal protec-tive equipment may also be required. Local exhaust ventilation with or without process enclosure may be nec-essary when there is large–scale use of this material or when the material is heated or a mist is created. Supplysufficient replacement air to make up for air removed by exhaust systems.

Personal Protective Equipment:If engineering controls and work practices are not effective in controlling exposure to trichloroethylene, then

wear suitable, approved respiratory protection. Have appropriate respiratory protection available for use inemergencies such as spills or fire. If respiratory protection is required, institute a complete, continuing respira-tory protection program including selection, fit testing, training, maintenance and inspection. Refer to the CSAStandard Z94.4–M1982, “Selection, Care, and Use of Respirators,” available from the Canadian StandardsAssociation, Rexdale, Ontario, M9W 1R3.

Respiratory Protection Guidelines:NIOSH RECOMMENDATIONS FOR TRICHLOROETHYLENE CONCENTRATIONS IN AIR (3): AT ANY DE-

TECTABLE CONCENTRATION: Positive pressure, full–facepiece SCBA; or positive pressure, full–facepieceSAR with an auxiliary positive pressure SCBA. ESCAPE: Gas mask with organic vapour canister; or escape–type SCBA. NOTE: The IDLH concentration for trichloroethylene is 1000 ppm. Carninogenic effects of thiscompound were not considered in determining the IDLH value. NOTE: NIOSH has classified this material as apotential occupational carcinogen, according to specific NIOSH criteria. This classification is reflected in theserecommendations for respiratory protection, which specify that only the most reliable and protective respiratorsbe worn at any detectable concentration. The requirements in Canadian jurisdictions may vary. ABBREVIA-TIONS: SAR = supplied–air respirator; SCBA = self–contained breathing apparatus. IDLH = Immediately Dan-gerous to Life or Health. NOTE: In these recommendations, the IDLH concentration is defined as the maximumconcentration which would not cause any escape–impairing symptoms or irreversible health effects to a personexposed for 30 minutes if the respirator failed. Recommendations apply only to NIOSH and MSHA (Mine Safetyand Health Administration) approved respirators.

Eye/Face Protection:Chemical safety goggles suitable for splash protection and/or a face shield.



Skin Protection:Impervious gloves, coveralls, boots, and/or other resistant protective clothing.

Resistance of Materials for Protective Clothing:VERY GOOD: Viton; GOOD: Nitrile/PVC; NBR; chlorobutyl; FAIR/POOR: Neoprene/SBR; polyurethane; CPE;

PVA; PVC; SBR; butyl; neoprene; nitrile; natural rubber. NOTE: Resistance of specific materials can vary fromproduct to product. Evaluate resistance under conditions of use and maintain clothing carefully.

Exposure Controls/Personal Protection Comments:Have a safety shower and eye–wash fountain readily available in the work area for emergency use. Keep

contaminated clothing in closed containers. Inform laundry personnel of contaminant’s hazards. Do not eat,drink or smoke in work area.

Exposure Guidelines:Threshold Limit Values (TLVs)/American Conference of Governmental Industrial Hygienists (ACGIH) /1992–93

Time-Weighted Average (TLV–TWA): (50 PPM (270 mg/m3))*

Short-Term Exposure Limit (TLV–STEL): 200 ppm (1,080 mg/m3))

TLV Comments: Notice of Intended Change: Reduction of the TLV–STEL to 100 ppm (537 mg/m3) anddesignation as a “Not suspected as a human carcinogen (A5)” have been proposed. CARCINOGEN A5 – Notsuspected as a Human Carcinogen: Substance is not suspected to be a human carcinogen on the basis ofproperly conducted human studies. Negative evidence of carcinogenicity in laboratory animals will be consid-ered if it is supported by other relevant data. BIOLOGICAL EXPOSURE INDICES (BEIs): The ACGIH hasadopted a BEI for this chemical. BEIs provide an indication of worker exposure by measuring the chemical or itsbreakdown products in the body or by measuring biochemical changes resulting from exposure to the chemical.Consult the BEI documentation for further information. NOTE: In many Canadian jurisdictions, exposure limitsare similar to the ACGIH TLVs. Since the manner in which exposure limits are established, interpreted, andimplemented can vary, obtain detailed information from the appropriate government agency in each jurisdiction.

Permissible Exposure Limits (PELs)/Final Rule Limits/Occupational Safety and Health Administration(OSHA):

Time-Weighted Average (PEL–TWA): 50 ppm (270 mg/m3)

Short-Term Exposure Limit (PEL–TWA): 200 ppm (1080 mg/m3)

Note: The OSHA PEL Final Rule Limits are currently non–enforceable due to a court decision. The OSHA PEL Transitional Limits are nowin force.

Permissible Exposure Limits (PELs)/Transitional Limits/Occupational Safety and Health Administration(OSHA):

Time-Weighted Average (PEL–TWA): Not established



Section 9: Physical

and Chemical Properties

Molecular Weight: 131.5

Conversion Factor: 1 ppm = 5.367 mg/m3; 1 mg/m3 = 0.186 ppm at 25 deg C

Melting Point: –73 deg. C (–99.4 deg F)

Boiling Point: 86.7 deg C (188 deg F)

Relative Density/Specific Gravity: 1.465 (water = 1)

Solubility in Water: Slight

Solubility in Other Liquids: Soluble in most organic solvents.

Vapour Density: 4.54 (air = 1)

Vapour Pressure: 57.8 mm Hg at 20 deg C

SaturationVapour Concentration: 10.2% at 25 deg C

Evaporation Rate: No data

pH Value: Not applicable

Critical Temperature: Not available

Section 10: Stability and Reactivity

Stability:Moderately stable. Decomposed slowly by light in presence of moisture.

Hazardous Polymerization:Does not occur.

Hazardous Decomposition Products:Hydrogen chloride

Incompatibility—Materials to Avoid:ALUMINUM POWDER—may be violent reaction if traces of acid are present. GRANULAR BARIUM OR

MAGNESIUM—can react violently. STRONG OXIDIZING AGENTS (e.g. perchlorates, peroxides)—may reactviolently. STRONG BASES—may form flammable dichloroacetylene.

Corrosivity to Metals:Not corrosive



Section 11: Toxicological Information

LD50 (rat, oral): 4,920 mg/kg

LCLO (rat): 8,000 ppm; 4–hour exposure

Teratogenicity and Embryotoxicity:In several studies, rats and mice were exposed to trichloroethylene vapour (100–1800 ppm) for 4–7 hours/

day during critical periods of pregnancy. There were some signs of maternal toxicity at the higher concentrations(300–1800 ppm). Trichloroethylene was not teratogenic in any study. The highest concentration caused slightdelayed growth (4,5).

Reproductive Toxicity:Exposure of male mice at 450 ppm for 24 hours had no effect on fertility (5). Exposure of female mice at 1800

ppm for 3 weeks did not affect fertility or mating (4).

Mutagenicity:Trichloroethylene caused increased numbers of micronuclei in the bone marrow of mice (4). Two other in vivo

tests (spot test in mice and sperm anomaly test in mice) gave limited evidence of a positive response (4). Adominant lethal test in mice was negative (4,5). Negative or inconclusive results were obtained in bacterial tests(e.g. Ames test) and several tests using cultured mammalian cells (1,4). Trichloroethylene was positive in amammalian cell transformation test and in tests in yeast (1,4).

Carcinogenicity:Mice given 455 g/kg over a period of 78 weeks developed liver tumors. Rats exposed to 150 ppm for 7 hours

daily, intermittent, for 2 years developed lung and skin tumors. These results are regarded as “limited” evidenceof carcinogenicity because mouse liver and rat lung are highly susceptible sites of tumor development.

Section 12: Ecological Information

NOTE: This section is under development.

Section 13: Disposal Considerations

Review federal, provincial and local government requirements prior to disposal. Disposal by secure landfill maybe acceptable. Incineration in a facility designed to burn chlorinated solvents may be acceptable.



Section 14: Transport Information

Transportation of Dangerous Goods (TDG) Shipping Information

Shipping Name and Description: Trichloroethylene (R1120)

Product IdentificationNumber (PIN): 1710

Classification: 6.1—Poisonous substance; 9.2—Substance hazardous to the environment

Special Provisions: 109, 110

IMO Classification: 6.1

ICAO Classification: 6.1

Packing Group: III

Section 15: Regulatory Information

Workplace Hazardous Materials Information System (WHMIS)

Proposed WHMIS Classification:D1B - Poisonous and infectious material—Immediate and serious effects—Toxic

D2B - Poisonous and infectious material—Other effects—Toxic

WHMIS Health Effects:Eye irritation—toxic—other

Mutagenicity—toxic—other

TDG class 6.1 group III—toxic—immediate

WHMIS Ingredient Disclosure List:Included for disclosure at 1% or greater



Detailed WHMIS Classification According to Criteria:CLASS A—COMPRESSED GAS: Does not meet criteria

CLASS B—FLAMMABLE & COMBUSTIBLE MATERIAL: Does not meet criteria

CLASS C—OXIDIZING MATERIAL: Does not meet criteria

CLASS D—POISONOUS AND INFECTIOUS MATERIAL. DIVISION 1—IMMEDIATE AND SERIOUS TOXICEFFECTS: Meets criteria for “Toxic material”; TDG class 6.1, packing group III

Acute Lethality: Does not meet criteria

CLASS D—POISONOUS AND INFECTIOUS MATERIAL. DIVISION 2—OTHER TOXIC EFFECTS: Meetscriteria for “Toxic material.” See detailed evaluation below.

CHRONIC HEALTH EFFECTS: Insufficient data

CARCINOGENICITY: Does not meet criteria; not in reference lists

TERATOGENICITY AND EMBRYOTOXICITY: Does not meet criteria. Not teratogenic; slight fetotoxicity atdoses causing signs of maternal toxicity.

REPRODUCTIVE TOXICITY: Insufficient data

MUTAGENICITY: “Toxic”; positive result in micronucleus test

RESPIRATORY SENSITIZATION: Does not meet criteria; not reported as human respiratory sensitizer.

SKIN SENSITIZATION: Does not meet criteria

SKIN IRRITATION: Insufficient data

EYE IRRITATION: “Toxic”

CLASS E—CORROSIVE MATERIAL: Does not meet criteria

CLASS F—DANGEROUSLY REACTIVE MATERIAL: Does not meet criteria

OSHA Hazard Communication Evaluation:Meets criteria for hazardous material, as defined by 29 CFR 1910.1200.



Section 16: Other Information

Selected Bibliography:(1) Fielder, R.J., et al. Trichloroethylene (toxicity review 6). Health and Safety Executive, 1982.

(2) Health assessment document for trichloroethylene (review draft) (EPA-600/8-82-0068). EPA, December1983

(3) NIOSH pocket guide to chemical hazards. NIOSH, June 1990. p. 216–217

(4) Royal Society of Chemistry. Organo-chlorine solvents: health risks to workers. Commission of the Euro-pean Communities, 1986. p. 93–130

(5) Barlow, S.M., et al. Reproductive hazards of industrial chemicals: an evaluation of animal and humandata. Academic Press, 1982. p. 556–565

Information on chemicals reviewed in the CHEMINFO database is drawn from a number of publicly availablesources. A list of general references used to compile CHEMINFO records is available in the main databasemenu.

Review/Preparation Date:1987-01-06

Revision Indicators:TLV-TWA; 1993-01

TLV-STEL; 1993-01

TLV comments; 1993-01

PEL-TWA; 1993-03

PEL-STEL; 1993-03

NFPA (health); 1993-03

NFPA (flammability); 1993-03

NFPA (reactivity); 1993-03

REGULATORY INFORMATION; 1993-03

Trans PEL-TWA; 1993-04


Accident Investigation

Accident InvestigationAccident investigation is a very important tool for supervisors in their effort to provide asafe workplace. Rather than perceiving this process as a mechanism for blame setting,the supervisor should engage in the accident investigation for the purpose of preventingsimilar incidents. It is important for the supervisor to maintain accurate and completerecords and reports for all occupational injuries and illnesses.

Accident investigations are conducted to collect the data for the accident reports. The re-sults of the investigations are used to develop procedures and prevent future accidents. Acci-dent investigation procedures:

� Provide information needed to determine problem areas.

� Identify the workplace factors and/or SOPs that contributed to the accident.

� Identify aspects in the management system which contributed to the accident.

� Determine alternative actions and programs to prevent a recurrence of the accident.

An accident investigation results in procedures to help prevent similar accidents in the fu-ture. For this reason it is important to investigate and report all accidents. Even if the event didnot result in injury, illness, or property damage, it should be reported, investigated, and pre-ventive actions implemented. Joint labor-management investigations provide the widest pos-sible input and may increase the rapid implementation of program and work practices changes.



As a supervisor, you may be responsible for assuring conduct of the accident investiga-tions. Elements to consider when analyzing the quality of an investigation include:

� Accuracy and clarity of the description of events leading up to the accident.

� Identification and description of all causal and contributing factors.

� Timeliness.

� Review and sign-offs to document implementation of corrective actions.

� Corrective actions already taken.

� Recommendations for additional corrective actions.



Purposes of Accident Investigation

An accident is an unplanned, undesired event which may result in personal injury, illness, orproperty damage. The accident investigation will determine what happened, how it happened,and why it happened. A thorough accident investigation will:

� Document the nature and extent of the accident.

� Improve SOPs.

� Motivate safe work practices.

� Dispel any undue concern workers may have about the accident.

Accident investigations demonstrate both labor and management’s concern, improve over-all performance, and upgrade management and labor procedures. Accident investigationsshould be focused on finding the root cause or causes of the accident to improve safety andefficiency, not finding fault or placing blame. Qualifications of a good accident investigationteam include:

� Technical knowledge.

� Objectivity, curiosity, and honesty.

� Familiarity with the job, process, or operation.

� Communication skills.

� Documenting information gathered.

� An analytical approach to information analysis.



Accident Investigation Procedures

Conditions which may result in an accident include, but are not limited to:

� Improper or defective tools.

� Lack of or inadequate training on a procedure or a job.

� Lack of or ineffective machinery guards.

� Lack of, or improper, or inappropriate, or inadequate, or ill fitting, or not using personalprotective equipment.

� Lack of, or ineffective, or not following the standard operating procedure.

� Defective equipment.

� Lack of proper fall protection.

� Inappropriate design of materials or packaging.

� Inappropriate supervision resulting in rushing, cutting corners, long hours, and fatigue.

� Environmental factors (heat, cold, dark).

� Improper material handling.

� Poor communication.

� Physical hazards (slips, trips, falls).

� Poor housekeeping.

The following steps should be followed during an accident investigation:

� Provide/obtain medical treatment if an injury or illness occurs.

� Secure the area.

� Preserve evidence.

� Obtain approval before removing or moving anything on the accident site.

� Notify appropriate personnel.



It is also important to:

� Record the positions of victims and items.

� Take photos of the accident scene.

� Interview witnesses.

� Form an investigation committee for each injury.

� Write a formal report on the accident and the investigation.

Collection and evaluation of factual evidence is crucial to an accident investigation. Evi-dence is fragile, and it can be lost, distorted, or broken.

Loss of evidence occurs when it is forgotten, overlooked, or unrecorded by the witnesses. Itcan occur by physical means when misplaced, taken, cleaned up, or destroyed.

Evidence is distorted when witnesses remember incorrectly the events of the accident.Witnesses may also rationalize, misrepresent, or misunderstand the events. Physical evi-dence may be distorted when it is moved, altered, disfigured, misinterpreted, or supplemented.

Breakage of evidence may occur when the people involved are transferred to a different jobor are influenced by outside sources. There may also be some personal conflicts which affectthe way a witness recalls an accident occurring. Evidence may be broken by physical meanssuch as being dispersed, scattered, or taken apart. When conducting an investigation it isimportant to:

� Find the relevant facts.

� Evaluate the facts.

� Reconstruct the accident sequence.

� Develop valid conclusions.

� Report factual findings.

� Recommend corrective actions.



Interviewing Witnesses

One of the most important steps in an accident investigation is interviewing the witnesses.Witnesses can be an excellent source of information about the causes of the accident.Witnesses can forget details, so interview the witnesses as soon as possible after theaccident occurs so valuable information is not lost.

Three main purposes for interviewing witnesses are: first, to investigate the evidence; sec-ond, to check the known facts; and third, to secure and check new facts. Unfortunately, wit-nesses may not always be reliable. Some witnesses may be friendly, while others may beunwilling or hostile. It is important to put the witness at ease and explain that you are lookingfor the cause of the accident, not the person to blame.

The witness may not have good powers of observation or, out of fears for self-preserva-tion, deliberately lie about what they witnessed. Witnesses may be involved in the inves-tigation for egotistical reasons, or they may just want to please. An accident investigationcan be a very emotional process. As an accident investigator, it is your responsibility togather the facts and determine what actually occurred. You don’t want witnesses to drawconclusions. You are looking for a factual—in so far as possible—rendering of the eventsleading to, during, and immediately after the accident or “near miss.” Steps to follow wheninterviewing a witness include:

� Interview the witness privately in a neutral territory.

� Have the witness tell the story in his/her own words.

� Listen to what the witness says, and keep interruptions to a minimum.

� Ask questions such as who, what, when, where, why, and how.

� Ask the witness about possible corrective measures to prevent the accident from occur-ring again.

� Thank the witness for helping in the investigation, and leave the door open for laterquestioning.

� Document the information discussed in the interview.



Two questions that are helpful in any interview are:

� “Is there anything else we should know?”

� “Who else should we question?”

Always try to end an interview on a positive note. In fact, try to be positive throughout theentire interview process. Avoid using threatening or violent words. Don’t act suspicious. Con-duct the interview in layman’s language. Be friendly and assist the witness with descriptionsby providing props such as photos and drawings.

Investigative Committee

As a supervisor, you may be required to oversee an accident investigation; however, a jointlabor-management health and safety committee or other such team may be present with theresponsibility to investigate all accidents and “near misses.” Management should developstandard operating procedures for conducting joint labor-management or team investigations.The procedures should include:

� Designation of the individual in charge.

� Training of team members.

� Methods to notify team members when an accident occurs.

� Instructions on PPE or equipment to be brought to the scene.

� Transportation and communication needed.

� Methods to secure the site.

� Provision for access of team members to the site.

� Photographic/video capability.

� Procedures and equipment needed to preserve fragile, perishable, or transient evidence.

� Development of the accident report.



The accident investigation team should be an integral part of the entire investigation. Theteam is responsible for getting to the accident scene before the physical evidence is dis-turbed, except in the instance of chemical spills. Photographs and sketches or diagrams shouldbe made of the accident scene before it is restored. The accident investigation team shouldalso determine what evidence needs to be preserved. Additional responsibilities of the acci-dent investigation team include:

� Identifying the people involved in the accident as well as any eyewitnesses.

� Interviewing the witnesses.

� Documenting the sources of information.

� Reviewing all sources of potentially useful information.

Sources of information include operating logs, equipment manuals, weather reports, in-spection and test records, standard operating procedures, health and safety plans, past re-lated accidents, MSDSs, and training records including hazard communication programs, etc.As head of the investigation team, your responsibilities should include:

� Presiding over meetings.

� Determining the line of investigation to be pursued.

� Assigning tasks.

� Investigating all possible data sources.

� Advising interested parties of the investigation’s progress.

� Supervising preparation of the final report.

� Acting as liaison between employee representative(s), governmental agencies, and themedia.

Conducting a comprehensive accident investigation can be time-consuming work. Prob-lems to avoid include:

� Failure to cross-check information sources and analytical methods.

� Failure to investigate in sufficient scope and depth.

� Assuming the obvious.

� Failure to determine the root cause and fix it.

A sample Supervisor’s Accident/Incident Report is included on the next page.




Incident Report


Age: _________ Sex: _________ Job Title: _________________________________________________

Type of Injury: _______________________________________________________________________________


Property Affected


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________

Employees Involved


__________________________________________________________________________________________

__________________________________________________________________________________________

__________________________________________________________________________________________







Responsibility:





Job Title: ___________________________________________________________ Date: _______________


Monitoring

MonitoringIdentifying hazardous substances at a work site is very important for the safety and health ofworkers. Substance levels can be detected through the use of monitoring instruments such asoxygen meters, combustible-gas indicators, and colorimetric tubes.

Exposure levels and explosive limits have been determined through government agenciessuch as OSHA and NIOSH and by private and non-government agencies like ACGIH. Theselevels and limits are used to determine proper protective equipment and to ensure a saferwork environment. Monitoring is done to detect potential hazards to:

� Determine whether hazardous materials are present under normal operations.

� Determine possible immediate effects of hazards, especially conditions which are imme-diately dangerous to life and health (IDLH).

� Determine when sudden releases of toxic materials occur that would require a change inwork practice or donning of a specific type of protective equipment.

� Determine that no hazardous substances remain after a sudden release.

Concentrations are measured by monitoring in order to:

� Determine worker exposure level.

� Determine the extent of hazardous conditions.

� Determine community exposure.

� Assist in planning work activity.

� Provide records of exposure.

� Provide a historical record and submit it to regulatory agencies.

� Determine whether employees need medical assistance.


Monitoring

Direct-Reading Instruments

Direct-reading instruments provide immediate information on the presence or absence of ahazard and may also give data regarding the extent of contamination. Direct-reading instru-ments are available for many hazards including specific organic gases or vapors, oxygen,radiation, heat, noise, and total flammables. Results from direct-reading instruments are ex-tremely useful. They can be used for:

� Evaluating a confined space.

� Determining surface radiation contamination.

� Evaluating explosion potential and IDLH atmospheres.

Disadvantages of a direct-reading instrument include:

� It may not be sensitive enough to detect low levels of contaminants. (A reading of“zero” may mean contaminants are present but at levels below the detection level ofthe instrument.)

� Most of the measuring instruments cannot identify a specific contaminant or distinguishone contaminant from another.

� Instruments equipped with alarms may give a false alarm; however, any alarm should beconsidered real until an investigation is conducted.

� It may give an inaccurate reading because of background levels or the presence of chemi-cals other than the one being sampled (cross-sensitivity).

� Instruments may require factory maintenance.

Some direct-reading instruments include:

� Combustible-Gas Indicator (CGI).

� Flame Ionization Detector (FID) with Gas Chromatography Option.

� Gamma Radiation Survey Instrument.

� Portable Infrared (IR) Spectrophotometer.

� Ultraviolet (UV) Photoionization Detector (PID).

� Sound Level Meter (SLM).

Several are described on the following pages.


Monitoring

Combustible-Gas Indicator (CGI)

The CGI measures the concentration of a flammable vapor or gas in air, indicating the resultsas a percentage of the lower explosive limit (LEL) of the calibration gas.

� The LEL of a combustible gas or vapor is the lowest concentration by volume in air whichwill explode, ignite, or burn when there is an ignition source.

� The upper explosive limit (UEL) is the maximum concentration by volume in air which willexplode, ignite, or burn when there is an ignition source.

� Above the UEL there is insufficient oxygen to support combustion. Below the LEL there isinsufficient fuel to support ignition.

� The LEL is equivalent to the Lower Flammable Limit (LFL).

The operation of most combustible-gas indicators requires the presence of sufficient oxy-gen; therefore, most CGIs are dual-purpose oxygen and LEL meters. Always measure oxy-gen first. CGI meters may be read from a digital panel or a meter indicator.

For example, if the meter reads 0.5 or 50 (depending on the read-out), this means that 50percent of the concentration of combustible gas needed to reach an unstable flammable orcombustible situation is present. If the LEL for the gas is 5 percent, then the meter indicatesthat 50% of this volume or 2.5 percent is present. If a concentration greater than the LEL andlower than the UEL is present, then the meter needle will stay beyond the 100 percent level.This indicates that the ambient atmosphere is readily combustible. When the atmosphere hasa gas concentration above the UEL, the meter needle will rise above the 100 percent markand then return to zero (peg-out). Peg-out occurs because the gas mixture in the combustioncell is too rich to burn.

A reading of 10% of the LEL is considered potentially explosive.


Monitoring

Flame Ionization Detector (FID)

The FID detects many airborne organic gases and vapors. Inside the detector chamber the airis exposed to a hydrogen flame which ionizes the organic vapors. When most organic vaporsburn, the molecules are broken apart; positively charged ions are produced which can becollected by a negatively charged electrode. Thus an electric field is produced in the device.The strength of the electric field is proportional to the hydrocarbon concentration. Drawbacksof this instrument include:

� It cannot detect inorganic gases and vapors.

� Its sensitivity is dependent on the contaminant.

� It cannot identify specific compounds.

� Its sensitivity to cold temperatures.

Ultraviolet Photoionization

Detector (PID)

The PID detects many organic gases and vapors and some inorganics.

An example of a PID is the HNU Photoionization Detector (HNU P101). Three differentprobes are available for the HNU; selection is based on the anticipated contaminants. Selec-tion of the probe, requirements for calibration, and the complexity of operation require thatonly persons specially trained in its use be allowed to operate the unit and interpret results.Other drawbacks of the PID include its:

� Inability to detect methane.

� Inconsistent responses when gases are mixed.

� Sensitivity to high humidity.


Monitoring

Colorimetric Indicator Tube

The direct-reading colorimetric indicator tubes are widely accepted as a quick method forestimating the concentration of gases and vapors.

The colorimetric tube is a glass tube filled with a solid material gel that has been impreg-nated with an indicator chemical. The ends of the tube are broken off, and it is connected to apiston cylinder, or bellows-type pump, that pulls a known volume of contaminated air throughthe tube. The contaminant reacts with the indicator chemical in the tube, producing a colorchange the length of which is proportional to the contaminant’s concentration. There are dif-ferent tubes for different gases or vapors. Accuracy is + or –25% at best.

Some factors to be aware of when considering use of the colorimetric tube are:

� The tubes are subject to chemical interferences.

� The treated gel is heat-sensitive.

� The tubes have a shelf life.

� The pump must be checked for leaks and calibrated before and after each use.

� The operator must judge the length of the stain.


Monitoring

Laboratory Analysis Instruments

Another approach to air sampling requires analyzing samples in a laboratory. These instru-ments are generally used following site characterization to evaluate “full-shift” or other per-sonal exposure.

Sampling may occur over a very brief period (e.g., 15–30 minutes) or over a longer period(e.g., 8 hours).

A pump is used to draw air into a collection bag or through sampling media which traps thecontaminant of interest.

The proper selection and calibration of the pump is critical to the sampling process.

Solid-sorbent tubes are used to collect insoluble or nonreactive gas and vapor contaminant.One of the most widely used solid sorbents for organic vapor sampling is activated charcoal.For those air contaminants that are not efficiently collected from activated charcoal, silica gelcan be used.

Passive monitors are badges which are clipped to the worker’s clothing. These monitorsare available for a wide variety of contaminants including:

� Organic vapors.

� Carbon monoxide.

� Sulfur dioxide.

� Formaldehyde.

� Ammonia.


Monitoring

Dusts, fibers, and moths are trapped on filters. These are analyzed by a number of methodsto determine concentration of all airborne particles, to estimate fiber concentration, and/or toidentify concentration of a specific component. Methods include:

� Weighing.

� Microscopy.

� Chemical analysis.

A major disadvantage of long-term air monitoring is the time required to obtain data. Thetime lag between sampling and obtaining the analytical results may be days to weeks, de-pending on the location of the laboratory. However, data from personal air sampling is consid-ered the most accurate information on employee exposure.

One alternative to a remote-site laboratory is to have a laboratory on the site. This approachis expensive and may be cost-effective only for large, long-term remediation activities.


Monitoring

MONITORING METHODS

The information gathered during initial site characterization is used to develop the monitoringprogram. Ongoing results from the program serves as the basis for selecting the appropriatepersonal protective equipment.

Area Sampling

Area sampling involves the collection of samples at fixed locations at the site. The samplingequipment may be mounted on a tripod or other fixed structure or moved through the areamanually. Examples of area monitoring include:

� Monitoring for IDLH conditions.

� Monitoring in a confined space.

� Perimeter (fence line) monitoring.

� Monitoring for heat stress.

� Monitoring noise with a sound level meter.

Monitoring for IDLH and

Other Dangerous Conditions

Air monitoring must be conducted as part of initial entry to identify any IDLH condition. Otherdangerous conditions which may be evaluated by area monitoring include:

� Exposure to a radioactive material.

� Flammable or explosive atmospheres.

� Oxygen-deficient environments.

Area monitoring may also be used as an initial estimate of personal exposure to toxic chemi-cals at or above the permissible exposure limit or guideline.

Monitoring personnel and all site workers always need to be aware that conditions cansuddenly change from nonhazardous to hazardous.


Monitoring

Perimeter Monitoring

Perimeter or “fence line” monitoring measures contaminant migration away from the siteof generation and enables the Site Safety Officer to evaluate the potential for exposure tonearby residents. Since fixed-location samples may reflect exposures either upwind ordownwind from the site, wind speed and direction data are needed to interpret the sampleresults accurately.

Personal Monitoring

The monitoring of employees at high risk of exposure is required under 29 CFR 1910.120(h)(4).Samples are collected in the breathing zones of employees.

If workers closest to the source are not significantly exposed, then all other workers arepresumably not significantly exposed and probably do not need to be monitored. If the work-ers likely to have the highest exposure have exceeded the permissible exposure limits, thenthe monitoring should continue to determine all workers above those limits.

After the actual clean-up phase of the hazardous waste operation begins, personal air sam-pling can be conducted.


Monitoring

Environmental Sampling

Sampling other than air monitoring may be performed at sites. Water sampling, soil testing,wipe testing, compatibility testing, or drum sampling may occur. Specific SOPs for these pro-cedures are detailed in the safety and health plan.

Water Sampling

Sampling and analysis of water from wells, ponds, streams, and effluent groundwater may beperformed at a work site to determine if any wastes are present.

Soil Testing

Soil testing may be done at a work site and neighboring property to determine if waste hasmigrated and been released to the soil. Soil testing will indicate how much, if any, contamina-tion there is, how deep it is, and the limits of the area contaminated.

Wipe (Swipe) Testing

Surfaces may be tested by wipe testing to determine if any contaminants are present. Thistesting is done by wiping a surface with a piece of cloth or other material according to speci-fied procedure and then submitting the samples for analysis.


Monitoring

Variables Affecting Waste Site Exposure Assessment

Hazardous waste site characteristics may complicate collection of samples to evaluate expo-sure. Variables which can affect airborne or surface concentrations include:

Temperature: An increase in temperature increases the vapor pressure of most chemicals.

Wind Speed: An increase in wind speed can accelerate the evaporation of liquids. Dusts andparticulate-bound contaminants may become airborne.

Rainfall: Rainfall can cover liquid or solid surface contamination, thereby altering the rate ofairborne emissions. Rainfall may dilute the contaminants, causing run-off to other areas.Rainfall may dilute well contents.

Work Activities: Work activities often require the mechanical disturbance of contami-nated materials, which may change the concentration and composition of airbornecontaminants.

Suit Material: Contamination may affect the surface or texture of PPE, making collectionof a swipe sample difficult.

Rust, Corrosion: Deteriorated containers may require additional caution prior to samplecollection.


Monitoring


Site Control

Site ControlSite control is required under 29 CFR 1910.120(d). Prior to clean-up work, proceduresare required to control employee exposures. A full program is required during remediationactivities in order to minimize potential contamination of workers, protect the public, andprevent entry by unauthorized persons.

The importance of site control should never be underestimated. Site control is especiallyimportant in emergency situations. An effective site control program contains procedures toreduce worker and public exposure to chemical, physical, biological, and safety hazards.

The site control program is established in the planning stages of a project and then modifiedbased on new information and site assessments. The appropriate sequencing of the imple-mentation of these control measures is determined on a site-specific basis.


Site Control

Site Maps

The required site map should show all features of the work and surrounding area, including:

� Topographic features.

� Prevailing wind direction.

� Drainage.

� Location of buildings.

� Containers.

� Impoundments.

� Pits.

� Ponds.

� Tanks.

� Roadways.

� Perimeter security fences.

Site maps can then be used when:

� Planning remediation activities.

� Assigning work teams.

� Identifying access routes and evacuation routes.

� Predicting potential migration of contaminants.

� Identifying areas of the site that require use of personal protective equipment.

� Conducting daily briefing of the work teams.


Site Control

The map must be prepared prior to site entry and updated when necessary to reflect informa-tion gained during remediation, including:

� Changes in site topography/layout.

� Newly identified hazards.

� New work activities/equipment.

� Changing exit/entry routes.

� Decontamination line relocation.

Dated overlays may be used to help portray information without cluttering the map.


Site Control

Site Preparation

Proper preparation of a site for clean-up activity is necessary to ensure that remediationoperations go smoothly and that worker safety is protected. If site preparation is not con-ducted properly, contamination may be spread to larger areas, requiring more extensive workactivities. Steps to complete during site preparation prior to any clean-up activities are:

� Review site characterization reports.

� Secure the site.

� Design traffic-flow patterns to ensure safe and efficient operations.

� Construct roadways to provide ease of access and a sound roadbed for heavy equipmentand vehicles.

� Construct operation pads for mobile facilities and temporary structures.

� Construct loading docks, processing and staging areas, and decontamination pads.

� Identify physical hazards; eliminate where possible.

� Install skid-resistant strips and other anti-skid devices on slippery surfaces.

� Provide adequate illumination and sanitation facilities for work activities.

� Assume that all preparation work is done in accordance with applicable federal, state, andlocal ordinances and codes.

Site preparation is a team activity. Safety, health, construction, and local authorities may beinvolved in the process.


Site Control

Site Work Zones

Site work zones are established to ensure that:

� Personnel are properly protected against hazards specific to the area where they areworking.

� Contamination is confined to the designated area.

� Personnel can be located and evacuated in an emergency.

There is no rule on the number of work areas that can be created at the site. The numbershould be kept to a minimum in order to assure proper monitoring of activities.

For each work area, zones are defined in order to contain contaminants. Three differentareas are marked off:

� Contaminated or high hazard.

� Less contaminated or decreasing hazard.

� Clean or no hazard.

These areas are called different names depending upon the contractor. Several ways ofnaming these areas are shown below.

Potential forHazardous Exposure Scheme 1 Scheme 2 Scheme 3

High Hot Zone Exclusion Zone Danger Zone

Medium Warm Zone Contamination Decontamination ZoneReduction Zone

Low/None Cold Zone Support Zone Clean Zone


Site Control

It is important to remember that one zone has a high potential of exposure unless PPE andwork practices are used to reduce the potential. Decontamination occurs in the middle area.The area with no expected hazards is where the work activities are assigned and training isconducted, and it is the only area accessible to untrained visitors.

Boundaries are drawn among these zones. These boundaries also have different names,depending upon the contractor. Usually the entire site is secured by fencing which will keepout the curious or people unaware of the activities being conducted. The Hot Zone (Exclusion,Danger) is also marked with visibly different fencing and work signs in order to help assurethat only properly protected workers enter. The area where decontamination occurs is markedto isolate those specific activities; this area is sometimes called the Contamination ReductionCorridor or the Decon Line. The Cold/Support/Clean Zone is marked by hazard tape or someother sign to alert site workers to the lowest level of potential exposure. The boundarieschange as the work at the site is conducted. The designation of the zones is based on:

� Hazards identified.

� Types of operations conducted.

� Flow of personnel and equipment.

� Sampling and monitoring results.

� Potential for contamination transfer to other zones.

To prevent spread of contamination from contaminated to clean areas, movement of per-sonnel and equipment among these zones is carefully planned to minimize movement. Iffeasible, it is better to have separate personnel and equipment entrances and exits.


Site Control

Exclusion Zone

(Hot Zone/Danger Zone)

The primary activity performed in this area is clean-up work, such as drum movement, drumstaging, and materials bulking.

The establishment of this zone is based on the results of the site characterization and anynew data acquired during remediation. Factors include:

� Visual survey of the immediate site environment.

� The location of:

• Hazardous substances.

• Drainage leachate potential.

• Visible surface discolorations.

� Survey data indicating possible presence of:

• Combustible gases.

• Organic and inorganic gases, particulates, or vapors.

• Ionizing radiation.

� Results of soil and water sampling.

� Distances needed to isolate emergency conditions (explosion or fire).

� Physical area necessary for remediation equipment operations.

� Meteorological conditions.

The control of access to this area is essential to assure that only properly trained andequipped personnel enter the contamination area and that proper procedures are followedafter exit. The work practices and required PPE for each activity to be performed are detailedin the comprehensive work plan.


Site Control

Contamination Reduction Zone

(Warm Zone/Decontamination Zone)

This zone (CRZ) is designed to reduce the probability that the clean area will become con-taminated. As one moves from the contaminated to the clean areas, the degree of contamina-tion decreases. Distance, together with decontamination of workers and equipment, limits thetransfer of hazardous substances into clean areas.

Where the decontamination process occurs, at least two types of decontamination stationsare set up: one for personnel and one for heavy equipment. This area must be well-designedto facilitate:

� Decontamination of equipment, personnel, and samples.

� Emergency response: transport for injured personnel such as stretchers, first-aid equip-ment, and containment equipment such as fire extinguishers.

� Equipment resupply: air tank changes, personal protective clothing and equipment, sam-pling equipment and tools.

� Sample packaging and preparation for on-site or off-site laboratories.

� Worker temporary rest area:

• Toilet facilities

• Benches

• Liquids—water and other potable liquids should be clearly marked.

• Shade

• Wash facilities—located near drinking facilities to allow employees to wash before drinking

• Regular cleaning and inspection

� Drainage of water and other liquids that are used during decontamination.

� Communication with work teams.

� Site security.


Site Control

Support Zone

(Cold Zone/Clean Zone)

This area contains the administrative and other support functions needed to keep the opera-tions at the site running smoothly. Any function that need not or cannot be performed in acontaminated or potentially contaminated area is performed here.

Personnel in this zone are responsible for alerting the proper agency in the event of anemergency. Emergency telephone numbers, evacuation route maps, and appropriate emer-gency vehicle keys are kept here. Facilities include:

� Command post.

� Medical station.

� Equipment and supply centers.

� Administration.

� Field laboratory.

The following factors are useful in siting this area:

� Accessibility: Topography, open space available, locations of highways and railroad tracks,ease of access for emergency vehicles.

� Resources: Adequate roads, power lines, telephones, shelter, and water.

� Visibility: Line-of-sight to all ongoing site activities.

� Wind Direction: Upwind of the highest hazard area.

� Distance: As far from the highest hazard area as practical.


Site Control

The Buddy System

Activities to remediate the site are conducted with a buddy who is able to:

� Provide the partner with assistance.

� Observe the partner for signs of chemical or heat exposure.

� Periodically check the integrity of the partner’s protective clothing.

� Notify the Command Post or others if emergency help is needed.

The buddy system alone may not be sufficient to ensure that help will be provided in anemergency; for example, both may be struck by a falling object. At all times, workers inthe high-hazard area should be in line-of-sight contact or able to communicate with theCommand Post.


Site Control

Communication Systems

Two sets of communication systems must be established on-site:

� Internal communication among personnel on-site

� External communication between on-site and off-site personnel

Internal communication is used to:

� Alert team members to emergencies.

� Pass along safety information, such as the amount of air time left before the next restperiod.

� Communicate changes in the work to be accomplished.

� Maintain site control.

Common internal communication devices include:

� Radios.

� Noisemakers, such as

• Bells.

• Compressed air horns.

• Megaphones.

• Sirens.

� Visual signals, including

• Flags.

• Flares.

• Hand signals.

• Lights.


Site Control

Training and practice are needed to use any of these communication methods successfully.Radios must be verified to not pose hazards or interfere with other communication signals.Where visual signals are used, it is necessary to ensure that all workers are identifiable sothat the commands are addressed to the appropriate worker. Noise makers must be appropri-ate for the location and audible throughout all occupied zones. External communication isnecessary to:

� Report an emergency and coordinate response.

� Report to local agencies.

� Contact essential off-site personnel/contractors.

Primary external communication devices include the telephone and radio.


Site Control

Site Security

Site security is necessary to:

� Prevent the exposure of unauthorized, unprotected people to site hazards.

� Prevent vandalism.

� Prevent theft.

� Avoid interference with safe work practices.

Site security can be maintained during working hours by:

� Maintaining security at the entry/exit points.

� Establishing a system to identify authorized persons and the areas in which theymay work.

� Assigning responsibility for enforcing authority for entry and exit requirements.

� Erecting a fence or other physical barrier around the site or posting signs around theperimeter and using guards to patrol the perimeter.

� Evaluating all visitors to make sure they have a valid purpose for entering the site.

� Having trained site personnel accompany visitors and providing them with the appro-priate equipment.

Site security can be maintained during off-duty hours by:

� Using security guards to patrol the site boundary.

� Enlisting public enforcement agencies, such as the local police department.

� Securing equipment.

� Providing alarm systems and/or video surveillance equipment.


Site Control

Safe Work Practices

To maintain a strong safety awareness and document safe procedures at a site, detailedstandard operating procedures (SOPs) are developed describing how each operation is to beconducted. Separate SOPs may be necessary for the same operation, depending upon whichzone it is conducted in. All SOPs for the site are contained in the comprehensive work plan.

The following list details some of the elements in an SOP for visitors entering the Support/Cold/Clean Zone:

� No smoking, tobacco, snuff, eating, gum, drinking, or application of cosmetics in the zone.

� No matches or lighters in the zone.

� Check in at the Command Center immediately upon entering the zone.

� Check out at the Command Center immediately before leaving the zone.

� Always be accompanied by assigned site personnel.

In addition to a description of work practices (e.g., use of powered hand tools, bungremoval, drum sampling), written programs such as Respiratory Protection and HazardCommunication may be included as SOPs. Changes in any SOP must be reviewed withthe appropriate workers prior to implementation.



PersonalProtective Equipment

The purpose of personal protective equipment (PPE) and clothing is to shield or isolateindividuals from the chemical, physical, and biological hazards that may be encounteredwhile performing job duties.

PPE helps to minimize personal exposures and protect personnel from injury. While PPEhelps to confine the contaminant, it is not a substitute for proper hazardous material control.PPE can be selected to help protect your:

� Respiratory system.

� hands.

� Skin.

� Eyes.

� Face.

� Feet.

� Head.

� Body.

� Hearing.



Occupational Safety and Health Administration (OSHA) regulations in 29 CFR 1910.132through 1910.137 covers PPE requirements, as follows:

� General requirements

� Eye and face protection

� Respiratory protection

� Occupational head protection

� Occupational foot protection

� Electrical protective devices

Under 29 CFR 1910.120, OSHA also requires that workers be trained in the proper use ofPPE. Training is necessary because it:

� Allows the user to become familiar with the equipment in a nonhazardous situation.

� Increases user understanding of the equipment.

� Makes the user aware of equipment capabilities and limitations.

� Assures better recognition of need for PPE maintenance.

Understanding how to use PPE properly and how to recognize signs of PPE failure increasethe protection for the user.

To choose proper personal protective equipment, it is necessary to understand the hazardsand the types of equipment available to protect against the hazard.



Respiratory Equipment

Respirators generally fall within two categories. Atmosphere-supplying respirators are thosewith an air source. Atmosphere-supplying respirators consist of two types:

� Self-contained breathing apparatus (SCBA).

� Supplied-air respirators.

Air-purifying respirators are those that remove contaminants from the air.

Respirators can also be differentiated by the type of air flow supplied to the facepiece.Positive-pressure respirators maintain a positive pressure in the facepiece during both inhala-tion and exhalation. Negative-pressure respirators draw air into the facepiece via the negativepressure created by user inhalation. Only positive-pressure respirators are to be used at ahazardous waste site.

Facepieces

Different types of facepieces are available for use with the various types of respirators. Full-face masks cover the face from the hairline to below the chin and provide eye protection.These masks may be used with either air supply or air-purifying respirators. Half-face maskscover the face from below the chin to over the nose and do not provide eye protection. Theyare rarely used with supplied-air respirators.

Self-Contained

Breathing Apparatus

A self-contained breathing apparatus (SCBA) consists of a full facepiece connected by a hoseand a regulator to an air bottle that is carried by the wearer.

SCBAs operate in the open-circuit mode; that is, the unit supplies clean air to the wearerfrom a bottle, and the wearer exhales air directly to the atmosphere. Bottles are available withoperating time from 30 to 60 minutes.

The bottle is equipped with an alarm to warn the wearer when the air supply is getting low—usually about 5 minutes remaining.



Supplied-Air Respirators

Supplied-air respirators (SARs) supply breathing air to a facepiece via a supply line from astationary source. The air source for SARs may be compressed air cylinders or a compressorthat purifies and delivers ambient air to the facepiece.

SARs must be operated in positive-pressure mode and used with an escape air supply.

Combination SCBA/SAR

This combination respirator is a relatively new piece of equipment that uses a regulator tocombine the features of an SCBA with an SAR. The user can operate these dual-purposeunits in the SCBA or SAR mode through either manual or automatic switching of air sources.

The worker using this respirator can enter into and exit from an area using the self-con-tained air supply, then work for extended periods within a contaminated area while connectedto the air line. Sixty minutes of self-contained air is typically provided.

Air-Purifying Respirators

An air-purifying respirator (APR) consists of a facepiece and an air-purifying filter or cartridge.This filter or cartridge is generally a removable component of the facepiece. The air-purifyingrespirator works by selectively removing specific airborne contaminants from ambient air.This removal is done by filtration, absorption, adsorption, or chemical reactions.

To aid in the selection and use of filters and cartridges, it is required that they be color-coded to indicate the type of protection they offer.



Air Supply Considerations

Duration of air supply must be considered before planning any work activity requiring use ofan SCBA. Certain factors can reduce the rated operating time. The following factors affectoperating time, and work actions/operating time must be adjusted accordingly:

� Work rate: Actual in-use duration of SCBAs may be reduced by one-third to one-halfduring strenuous work.

� Fitness: Physically fit individuals utilize oxygen more efficiently and can extract moreoxygen from a given volume of air than unfit individuals. Fit individuals increase theSCBA operating time.

� Body size: Large individuals consume oxygen at a higher rate than small individuals.Larger individuals decrease the SCBA operating time.

� Breathing patterns: Quick, shallow, irregular breaths use air more rapidly than deep,regularly spaced breaths.

� Distance from air source can only be 300' when using an SAR.



Federal Requirements for Respirators

Federal regulations require that respirators be tested. If specifications are met, approval num-bers are then clearly written on the respiratory equipment.

The level of protection provided by a respirator is indicated by the respirator “protectionfactor.” This number indicates the relative difference in concentrations of substances outsideand inside the facepiece that can be maintained by the respirator. For example, if a full-facerespirator has a protection factor of 50, a properly fitted and trained worker can wear thisrespirator in an atmosphere containing chemicals at concentrations that are up to 50 timeshigher than the appropriate limits. (Note: This protection factor is not applicable when IDLHconditions exist or when the cartridge limit is exceeded.) Appropriate limits for airborne con-centrations are specified by:

� OSHA Permissible Exposure Limits (PELs).

� American Conference of Governmental Industrial Hygienists Threshold Limit Values (TLVs).

� NIOSH Recommended Exposure Limits (RELs).

� Other Published Exposure Limits (for example—American National Standards Insti-tute [ANSI]).

Only the OSHA PELs are legally enforceable. The TLVs, RELs, and others are recom-mended guidelines.

A written Respirator Program is required for any worksite where respirators may be used.The elements are listed in 29 CFR 1910.134. The program should be evaluated at leastannually or as requirements change, and it should be modified to reflect changes in workactivities.



Chemical-Protective Clothing and Accessories

Chemical-Protective Clothing (CPC) consists of special clothing worn to prevent chemicalsfrom coming into contact with the body. CPC generally includes eye/face protection, boots,gloves, and suits/coveralls. CPC is used to protect employees from both chemical and physi-cal hazards that they are likely to encounter while performing their tasks. The proper use ofCPC can prevent or reduce exposure to a harmful substance. CPC is an important part of ahazardous waste site worker’s personal protective equipment (PPE).

Chemical-protective clothing is made of special materials which are chemical-resistant; thatis, they act as a barrier to keep chemicals from coming in contact with the wearer’s skin.Different materials provide protection from different types of chemicals. It is important to se-lect CPC which is designed to protect against the specific chemical or type of chemical whichmay be encountered during routine work in the facility. Otherwise, you might not be protected,even when you think you are.

Types of Chemical-Protective Suits

Chemical-protective suits are of two general types, totally encapsulating and par-tially encapsulating.

Totally Encapsulating Chemical-Protective Suit (TECP):

Provides head-to-toe coverage to protect the wearer from chemicals. These are the large“moon suits” which have special seams and zippers to prevent chemicals from leaking intothe suit. These suits have a face shield which is made as part of the hood. These suits arevery bulky to wear, and the wearer can become very hot while working. These are the onlysuits that are considered vapor-resistant. TECP suits protect workers from hazards which areidentified during site characterization. TECP suits must pass a specific positive air pressuretest and be capable of preventing inward test gas leakage of more than 0.5%. Specific infor-mation about pressure tests can be found in OSHA 1910.120, an appendix to this manual.



Partially Encapsulating Suit

Provides good protection from chemicals and may or may not have face shields. These suitsare used when less skin protection is needed. The hood can either be part of the suit ordetached. This type of CPC includes suits which look like totally encapsulating suits but havenot passed the manufacturer’s pressure test.

Disposable suits, which provide limited protection from chemicals, can be used in conjunc-tion with these chemical-protective suits. These disposable suits can either be worn on top ofother suits to protect the suits or on the inside of other suits to protect the wearer from chafing.

Employees at hazardous waste sites are generally not responsible for CPC purchase orselection; however, it is important for workers to understand the considerations which go intoselecting CPC. The process by which the selection is made should be detailed in the employer’ssafety and health plan. Questions about CPC selection may be addressed to the personresponsible for the selection. The type of chemical-protective suits selected will depend onthe type and nature of potential exposure. For example, totally encapsulating suits may berequired to be worn by persons overpacking drums, whereas, partially encapsulating suitsmay be required while operating a remote drum handler. Generally, the level of protectionprovided will be re-evaluated as additional site information is gained. Guidelines for selectionof PPE, including CPC suits, are presented in the table on the following page.



Chemical resistance: Different materials are resistant to different chemicals. Managementshould provide CPC which will provide protection against the chemicals likely to be en-countered at the site. This rule is true for whole-body as well as hand and foot protection.

Physical integrity: Construction of the suit is important for the proper functioning of the CPC.Seams and zippers should provide solid barriers to chemicals and should be constructed toprovide some flexibility.

Resistance to temperature extremes: Heat and cold can adversely affect CPC. Clothingwhich will be worn in cold temperatures could crack or become ineffective against chemi-cals. Likewise, heat may destroy the chemical resistance of clothing or even melt it.

Ability to be cleaned: Clothing must be able to be cleaned and decontaminated after eachuse. If this is not possible, the clothing must be disposed of after use.

Cost: Initial and ongoing costs of purchasing PPE can be important considerations for man-agement. However, buying less expensive, inferior products which do not adequately pro-tect employees can be more expensive in the long run due to medical costs, lost work time,or, at worst, loss of human life.

Flexibility: Materials need to be flexible enough for the wearer to move and work safely. Overlyrigid suits can result in unnecessary accidents from slips, trips, and falls. Gloves which aretoo rigid may create gripping problems that may lead to other hazards.

Size: CPC should be available in a variety of sizes to accommodate the height and weight ofthe worker. Suits that are too small will tear easily and provide no protection. Suits that aretoo large will make walking and/or working difficult. Safety boots that are too big will createboth tripping and comfort problems.

Design: CPC should be designed so that all required respiratory PPE can be used at thesame time.

CPC Selection Guidelines



Accessories Used With CPC

Leggings and sleeve protectors: Commonly worn over non-encapsulating suits. They pro-tect against splashes on the chest, forearms, and legs. This type of protection is useful forsampling, labeling, and analysis operations. Use only when there is a low probability of totalbody contact with contaminants.

Cooling garment: Cooling is accomplished by pumping cool air through the suit, insertingice into jacket pockets, or pumping chilled liquid through tubes encased in clothing. A coolinggarment helps to protect against heat stress. Some of the problems associated with coolinggarments are:

� Pump circulating cool air. Require 10 to 20 ft3 of respirable air per minute, which isuneconomical.

� The ice method poses ice storage and recharge problems.

� The chilled water method poses ice storage and dexterity problems.

Head Protection

Hard hats protect against blows to the head, but the helmets must meet OSHA Standard 29CFR 1910.135.

Eye and Face Protection

Eye and face protection is provided by full-face respirators. For workers wearing an APR orno respirator, the following may be used:

� Face Shields: Provide full-face coverage, but are difficult to wear over a half mask. Faceshields protect against chemical splashes. They must be suitably supported to preventthem from shifting and exposing a portion of the face or from obscuring vision. Faceshields provide limited eye protection.

� Safety Glasses: Protect against large particles and projectiles.

� Goggles: Protect against chemicals, splashes, large particles, and projectiles.Can trap vapors.

Eye and face protection is covered by 29 CFR 1910.133.



Ear Protection

Ear plugs and muffs protect against the effects of noise. Ear protection must comply withOSHA regulation 29 CFR 1910.95. Use of hearing protection is described in the SOP for theHearing Conservation Program.

Gloves

Gloves may be separate or attached to other protective clothing. Wear the jacket or shirt cuffover the glove to prevent liquid from entering the glove. In many situations, the cuff-to-gloveseam is taped to further prevent exposure.

Foot Protection

Different types of safety boots help protect feet from coming in contact with chemicals orphysical hazards. All boots must meet the specifications required under OSHA 29 CFR1910.136. Safety boots constructed with steel materials help protect against compres-sion, crushing, or punctures to the foot. Safety boots constructed from nonconductive,spark-resistant materials or coatings help protect against electrical hazards, ignition ofcombustible gases, or vapors. It is important for all boots to provide good traction.



Levels of Protection

The EPA has developed guidelines for different levels of protection. The guideline consists offour levels of conditions, ranging from extremely hazardous conditions that require extensiveprotection (Level A) to situations where only basic work wear (Level D) is required.

For each of these levels, PPE (CPC and respiratory protection) is listed. When using theEPA guidelines, you should compare the conditions at the work site with the conditions listedunder each level.

There may be situations where site conditions are questionable as to which level is mostsuitable. In these situations, judgement calls must be made: When in doubt, choose the moreprotective level.

What Is Level A Protection?

The following constitutes Level A equipment; it may be used as appropriate:

� Positive-pressure, pressure-demand, full-facepiece SCBA or positive-pressure supplied-air respirator with escape SCBA (NIOSH-approved).

� Totally encapsulating chemical-resistant suit.

� Inner and outer chemical-resistant gloves.

� Disposable protective suit, gloves, and boots (depending on suit construction, may beworn over totally encapsulating suit).

� Coveralls.*

� Long underwear.*

� Hard hat (under suit).*

� Chemical-resistant boots with steel toe and shank.

*Optional

Note: Suit must be properly equipped with a pass-through air-line connection, referred to as an air-line egress.



What Is Level B Protection?

The following constitutes Level B equipment; it may be used as appropriate:

� Positive-pressure, full-facepiece SCBA or positive-pressure, pressure-demand, supplied-air respirator with escape bottle (NIOSH-approved).

� Hooded chemical-resistant clothing or non-gas-tight totally encapsulating chemical-resistant suit.


� Outer chemical-resistant boots with steel toe and shank.

� Boot covers: outer, chemical-resistant (disposable).*

� Hard hat.*

� Face shield.*

*Optional

New Level B chemical-resistant clothing is designed to go over the SCBA tank. If appropri-ate for the potential exposures, this CPC should be used to protect the SCBA and prevent itscontamination.



What Is Level C Protection?

The following constitutes Level C equipment; it may be used as appropriate:

� A full-face or half-mask air-purifying respirator (NIOSH-approved).

� Hooded chemical-resistant clothing.


� Coveralls.*

� Boots (outer), chemical-resistant, steel toe and shank.*

� Boot covers: outer, chemical-resistant (disposal).*

� Hard hat.*

� Escape mask.*

� Face shield.*

*Optional



Typical Uses of

Level D Equipment

Level D protection is worn by those who may be exposed only to nuisance contaminationwhile working with hazardous materials. Typically, workers involved with support activitiessuch as equipment supply, maintenance, off-site vehicle operation, or supervision/manage-ment will wear Level D.

Level D may appear similar to “typical work clothes.” Differences include the chemical-resistant boots and steel shank.

A critical step in the CPC selection process that is often overlooked is continuing to evaluatethe CPC’s effectiveness throughout its usage. The risk of exposure to a hazardous chemicalmay increase as workers are required to perform different tasks or as information about thesite increases. Reasons to upgrade the level of protection include:

� The newly documented presence of dermal hazards.

� The possibility of gas or vapor emission.

� A change in the work task that will increase contact or potential contact with hazardousmaterials.

� A request by the individual performing the task.

Reasons to downgrade the level of protection include:

� Soil analysis indicating that a dermal hazard is not present in this work area.

� A change in the site conditions that decreases the hazards.

� Use of remote mechanical equipment to reduce potential contact with the hazardousmaterials.



The PPE Program

All hazardous waste operations falling under 29 CFR 1910.120 are required to have a per-sonal protective equipment program. The elements required are:

� PPE selection based upon site hazards.

� PPE use and limitations of the equipment.

� Work mission duration.

� PPE maintenance and storage.

� PPE decontamination and disposal.

� PPE training and proper fitting.

� PPE donning and doffing procedures.

� PPE inspection and procedures prior to, during, and after use.

� Evaluation of the effectiveness of the PPE program.

� Limitations during temperature extremes, heat stress, and other appropriate medicalconsiderations.

Training is an essential component of an effective PPE program. For PPE that is rou-tinely used, evaluation of program effectiveness may include periodic monitoring of don-ning and doffing procedures and routine inspection of the equipment. PPE used only foremergency situations must be donned/doffed periodically and inspected routinely to helpassure readiness.



Clothing Reuse

Chemicals that have begun to permeate clothing may not be removed during decontamina-tion and may continue to diffuse through the material towards the inside surface, becoming ahazard for the next wearer. It is important to check the clothing inside and out for discolora-tion, moisture, cracking, or other evidence of contamination.

There is little documentation on clothing reuse. When determining if clothing should bereused, consider:

� The permeation rates.

� The toxicity of contaminants.

� How carefully the clothing is decontaminated.

� Whether decontamination is degrading the material.

Wipe tests may be used to evaluate whether permeation has occurred.

Remember that negative chemical or observation test results do NOT preclude the possibil-ity that an absorbed chemical will reach the suit interior.



Inspection

The required SOP for PPE inspection includes the procedures used at each use or at the timeof storage, including:

� Inspection and operational testing of equipment received from the factory or distributor.

� Inspection of equipment as it is issued to workers.

� Inspection after use or training and prior to maintenance.

� Periodic inspection of stored equipment.

� Periodic inspection when a question arises concerning the appropriateness of the se-lected equipment or when problems with similar equipment arise.

Detailed inspection recommendations are sometimes available from the manufacturer.It is helpful to develop an inspection checklist to document the item, data, person doingthe evaluation, and the results.

Records of all inspection procedures should also be kept. Individual identification numbersmay be assigned to reusable clothing and used to reference records of its inspection. Inspec-tion records should include:

� The item ID number.

� Date of inspection.

� Name of the inspector.

� Any unusual conditions or findings.



When using PPE, employees have a responsibility to monitor the effectiveness of the cloth-ing and equipment. Any perceived problems or difficulties while in PPE must be reported.Some of these problems may be:

� Degradation of the protective ensemble.

� Perception of odors, in supplied air or through APR.

� Skin irritation.

� Unusual residues on PPE.

� Discomfort.

� Resistance to breathing in respirator.

� Fatigue.

� Interference with vision or communication.

� Restriction of movement.

� Dizziness, rapid pulse, nausea, or chest pain.

The buddy in the work team must alert the appropriate person if problems are identified withthe partner’s PPE or the partner exhibits unusual behavior.



Maintenance and Storage

Procedures for inspection, maintenance, and storage of PPE must be explicitly specified toensure that the appropriate steps are taken, and ONLY by individuals who are properly trained.This SOP is required regardless of whether the employer or employee supplies the PPE.Clothing must be properly stored to prevent damage and malfunction due to:

� Dust.

� Moisture.

� Sunlight.

� Damaging chemicals.

� Extreme temperatures.

� Impact.

The following may be included in this SOP:

� Store in area separate from street clothing.

� Store in well-ventilated area with good air flow around each item.

� Store different types of materials and gloves separately (prevents issuing the wrongmaterial).

� Store and hang protective clothing according to manufacturer’s directions.



Selecting Respiratory Equipment

The selection of respiratory equipment begins with the determination of the level of protectionneeded based on the site conditions. Guidance on respiratory protection selection is given in29 CFR 1910.120 and 1910.134. Factors to consider include:

� The nature of the hazard.

� The activity to be performed.

� The period of time for which respiratory protection must be worn.

� Mobility of the worker.



Medical Fitness to Wear a Respirator

Before an employee receives clearance to wear a respirator, a medical review must be per-formed by a licensed physician. This review helps assure that employees are physically ca-pable of performing the job with the added stress of a respirator. Medical examinations arerequired for all employees who may work in atmospheres containing overexposure to hazard-ous substances for 30 days or more a year or as required by OSHA 1910.134.

Examinations should be conducted at least once every twelve months for each employee,unless the physician believes a longer interval (not greater than two years) is appropriate. It isimportant that the physician understands the worker’s job tasks.

Some medical conditions which may prevent an individual from wearing a respiratorinclude:

� Lung disease.

� Claustrophobia.

� Severe high blood pressure.

� Heart disease.

Other circumstances which may prevent a worker from wearing a specific type of respiratorinclude:

� Contact lenses.

� Eyeglasses.

� Moustache.

Special eyeglass kits are available for full-facepiece respirators.



Facial Hair and Respiratory Protection

Section 29 CFR1910.134/1926.103b, Definitions, states:

Tight fitting facepiece means a respiratory inlet covering that forms a completeseal with the face.

Additionally, Appendix A of 1910.134 (mandatory), states:

The test shall not be conducted if there is any hair growth between the skin andthe facepiece sealing surface, such as stubble, beard growth, beard, mustache,or sideburns which cross the respirator sealing surface.

OSHA’s interpretation of this section is that there cannot be any facial hair when using anyrespirator which relies upon a good face-to-facepiece seal, such as any tight-fitting (as op-posed to helmet or loose-fitting hood) air-purifying respirator. Even several days’ beard growthor a heavy stubble can reduce the possibility of a face-to-facepiece seal.

The question often comes up, “Can an employer force an employee to shave his beardbecause he will have to wear a respirator?” The answer depends in part on whether theworkplace is unionized. There have been cases where arbitration has decided on this ques-tion in the favor of the employer as well as cases that were settled in the worker’s favor. Thedecision will turn on the facts of each individual case. You should consult your employeerepresentative for more information.

In a non-union workplace, the employer is free to impose work rules on the employeeand change them at any time consistent with the employment contract. Nothing in OSHAregulations prevents the employer from making such a change and, in fact, the law re-quires employees to obey OSHA standards.

In a unionized workplace, the employer cannot normally change working conditions unilat-erally unless the collective bargaining agreement gives him or her that right or unless theunion clearly gives up that right. Where this is not the case, the employer must normallybargain with the union for changes in wages, hours and working conditions that occur duringthe life of the collective agreement.

There are arbitration cases that have decided this question both in the employer and union’sfavor. The decision will turn on the facts of each individual case. You should consult yourunion representative for more information.



Fit Tests

A respirator will be effective only if there is a good seal between the facepiece and the wearer’sface. Therefore, all persons wearing respirators must first be fit-tested. Fit-testing includesqualitative and quantitative testing.

Because many different face shapes exist, the manufacturers have a number of sizes. Thepurpose of fit testing is to find the manufacturer/size combination which offers the best protec-tion. Factors such as beards, weight loss or gain, dentures, dental work, or facial injury canchange the shape of the face, thus potentially changing the fit and efficiency of the respirator.If for any reason any of these factors exist, retesting is required.

Periodic Fit-Tests

Two types of fit-testing, qualitative (QLFT) and quantitative (QNFT), may be used to deter-mine the size and model of respirator that an individual should wear, as well as how good theface-to-facepiece seal is. These tests should be repeated periodically to document therespirator’s effectiveness.

Qualitative Testing (with irritant or smelly substance)

Purpose: Checks effectiveness of respirator in preventing substances from en-tering the facepiece.

Method: While wearing a respirator, an individual enters a chamber or an atmospherewhere a test substance has been released. The test substance could besmelly (banana oil), an irritant (special smoke tube), sweet (saccharin solu-tion), or bitter (Bitrex™). The wearer should not be able to detect the sub-stance.

Requirements: This test is required by OSHA 1910.134 (f) (1) and must be done at leastonce a year.



There are several important cautions to qualitative fit-testing.

� Some of the test substances may irritate the eyes or cause coughing.

� A poor sense of smell or taste may result in an inaccurate test.

� Fit-testing is often done in “ideal” environments. The fit may change after wearing therespirator several hours or during strenuous activity.

Quantitative Testing (results in a numerical estimate of fit)

Purpose: Measures effectiveness of respirator in preventing substance from enteringthe facepiece.

Methods: While wearing a respirator modified with a probe, an individual enters a cham-ber. A test substance is released, and the concentrations in the air insideand outside the respirator are measured. (Another version of this method isavailable which does not require a chamber or a test substance. The dustwhich naturally occurs in the air is measured both inside and outside therespirator.)

The test is repeated while the person performs specific tasks (speaking,running in place, etc.) which may affect fit.

Requirements: Annually at a minimum.

This test provides an objective assessment of the effectiveness of the respirator. It mea-sures the fit factor (FF), which is a comparison of the concentration of the substance outsidethe mask to the concentration of the substance inside the mask. This FF is useful in determin-ing whether the respirator will effectively protect the wearer from specific chemicals. A disad-vantage to this test is that special equipment and trained personnel are needed to administerit, although a microcomputer and software accessories can perform the calculations required.



Routine User-Checks

Two types of checks, positive- and negative-pressure checks, or the manufacturers recom-mendation should be done each time a respirator is donned and before each use in the fieldto check the seal of the respirator. Manufacturer recommended checks can be used if theyare available. User-checks do not replace yearly fitting but provide a routine assessment as towhether the fit is still adequate.

Positive-Pressure Check

Purpose: Checks the apparatus for leaks at valves or other points.

Method: Wearer covers the exhalation valve with hand and gently blows out. Theface fit is considered satisfactory if a slight positive pressure can be built upinside the facepiece without any evidence of outward leakage at the seal.

Requirements: Should be done before each use.

Negative-Pressure Check

Purpose: Checks the facepiece-to-face seal.

Method: The APR wearer places hands over cartridges and inhales gently so thefacepiece collapses slightly. The inhalation should be held for ten seconds.No outside air should be felt leaking into the facepiece.

Requirements: Should be done before each use.

Positive- and negative-pressure checks can be done quickly and easily in the field. They do,however, have the disadvantage of relying on the wearer’s ability to detect the leaks.



In addition to these fit checks, it is essential that the wearer check the unit for proper valves,cartridges, and other fillings, as appropriate, before each use. Following use, the unit shouldalso be checked; deteriorated straps, valves, etc. must be reported promptly to ensure thatrepairs are made before the next use.

During use, perceived problems or difficulties with the respiratory equipment should bereported. Some of these problems may be:

� Degradation.

� Perception of odors.

� Skin irritation.

� Discomfort.

� Resistance to breathing.

� Fatigue due to respirator use.

� Interference with vision or communication.

� Restriction of movement.

� Personal responses such as rapid pulse, nausea, and chest pain.



Recordkeeping

The SOP for respirator fit testing and training is part of the PPE program. The results of fittesting become part of the employee’s medical record and are retained for the duration ofemployment plus 30 years; see 29 CFR 1910.1020. These records should include the follow-ing information:

� Type of respirator fit test used.

� Specific make and model of respirator tested.

� Name of person tested.

� Name of test operator.

� Date of test.

� Results of fit test.

Emergency Procedures

Possible emergency uses of respirators should be identified prior to initiating remediationactivities and an appropriate Emergency Response Plan developed. Specialized respiratortraining may be required for emergency response activities.



Work Mission Duration

It is necessary to determine the length of a proposed work mission before workers actuallybegin the work in their PPE. Some of the factors which may be considered in determining thelength of a mission/job are:

� Air supply needs.

� Suit/ensemble permeation and penetration by characteristics.

� Ambient temperature.

� Availability of back-up work teams.

� PPE supply.

� Capacity of treatment or repack facilities.

� Need for laboratory analysis of samples.


Handling the Media

Handling the MediaEveryone is interested in events that happen around them and in the community. The mediaplay an important role in keeping people informed. Because of the potential hazards at wastesite operations, the public is usually very interested in all site-related activities. Concernsrange from safety and health protection for the employees and the environment to job securityand layoffs.

Community members are becoming increasingly informed and proactive in environmentalissues. They want to know that everything is being done correctly and complies with thesafety and health regulations passed by federal and state agencies. Nobody wants his or herhealth or the environment sacrificed for a profit.

At any remediation site there is usually a designated representative or department whichacts as a liaison with the media and the public. It is the goal of this public relations departmentto relay information to the public. It is very important to be honest with the public about emer-gency situations and hazardous operations. Poor communication can lead to:

� Loss of company credibility.

� Loss of public trust.

� Poor relationships with state and local officials.

� Employee dissatisfaction and turnover.

� Political impact.


Handling the Media

A good relationship with the media can help maintain relations with employees, sharehold-ers, regulators, and the community. There are several different types of communication. Inaddition to press releases, other channels can be used to give information to and interact withthe public. These include:

� Networking with volunteer organizations, community-based organizations, and pro-fessional organizations.

� Posters.

� Videotapes.

� Pamphlets.

� Brochures.


Handling the Media

Interview Techniques

People are most familiar with the newspapers, radio, and television media. While it is theresponsibility of the public relations department to interact with the news media, situationsmay arise where you, as a supervisor, may be called upon to assist in a technical capacity. Forthis reason it is important for you to be familiar with interview techniques. Before agreeing toan interview, it is important to consider:

� The nature of the event or activity being covered.

� Whether “cameras will be rolling.”

� The kinds of questions that may be asked.

� The level of training of the reporter.

� Background information available to the reporter.

Print and radio reporters want the information as succinct as possible, while television broad-cast reporters want much of the information in a visual form. Reporters from trade magazinesseek technical information. The following are some characteristics of a good public relationsspokesperson:

� Knowledge and credibility.

� Ability to provide additional information as follow-up.

� Composure and tact.

� Ability to translate technical information into common terms.

Before you agree to an interview, find out who will be asking the questions and whattopics the reporter will want to cover. Make sure the reporter is aware of any topics youcannot discuss. Find out how long the interview will be, the format, and if anyone else willbe at the interview.


Handling the Media

To prepare for an interview, obtain accurate and complete background information. De-termine what information is appropriate, and review any areas you do not want to discuss.Prepare a list of likely questions, and organize your information into key points and mes-sages. Practice using non-technical personnel as your audience, critique the practicesession, and revise your approach when necessary. Be prepared to respond “I do notknow” when appropriate. An honest lack of information is much better than later beingshown to have been in error.

When the press arrives, assume that everything is on the record. If possible before theinterview, list for the reporters any topics you cannot discuss. Stress your interest in providingaccurate information to the reporters, and offer to obtain additional information if deemednecessary. Always be cordial and professional. Alert them of any possible interruptions.

During the interview be honest and accurate, and stick to your key points. State conclusionsfirst, and back them up with facts. Avoid negative statements. If you don’t know an answer,admit it and offer to find the answer if possible. Keep answers simple, factual, and non-tech-nical. If a question is asked that you cannot answer, explain why instead of saying “no com-ment.” If you make a mistake, state that you didn’t give an adequate answer and would like toclear up the confusion.

After the formal interview has concluded, remember that everything you say is still on therecord, so be careful around microphones and tape recorders. Make sure the reporters knowthey can call you to clear up any ambiguities. If you find any errors in their report, call them topoint out what was wrong.

The five most frequent interview failures are:

� Not anticipating what questions will be asked.

� Not developing key messages in advance.

� Not sticking to the facts.

� Not being positive during the interview.

� Not remaining calm throughout the interview.


Handling the Media

Crisis Communication Plan

When an emergency occurs, there is no time to prepare for the press; anticipate their arrivalwith any emergency response personnel. Specific plans must be made in advance for dealingwith the media in this situation. Such a plan is referred to as a crisis communication plan. Themedia and the public will want to know what happened, who was involved, where the incidentoccurred, why the incident occurred, what is being done at the scene, and how a secondoccurrence will be prevented. A good crisis communication plan includes:

� Who, by name, will communicate with the media and the public.

� What types of information will be communicated.

� Sources of current information.

Without some kind of crisis communication plan, you risk relaying wrong or misleadinginformation. This error can result in unnecessary anxiety and loss of credibility, which mayharm the reputation of your company.

One person should be responsible for communicating with the media. When an emergencyoccurs, the designated person will answer questions and provide information. It is very impor-tant that the spokesperson have access to complete, accurate, and reliable information as thesituations change.

Often in emergency situations, the spokesperson will need to assimilate information quicklyfrom other people in the company. Company executives, lawyers, and engineers may becalled upon to provide information. One of the best sources of information is the supervisorsor workers who were directly involved with the emergency and can explain what happenedand how the emergency was handled.

All employees who might be approached by a media representative must be familiar withthe plan before an emergency occurs. Planning is an essential first step in providing orga-nized, accurate information to the public.

As a supervisor, you should be prepared to assist in supplying information to the spokesper-son named in the crisis communication plan. At times you may be asked to communicateinformation to the media and answer their questions. If you have not been authorized toanswer questions, refer the reporters to the designated spokesperson. Make sure other em-ployees are aware of this policy.

Remember, in dealing with the media, always be honest, cordial, and professional.


Handling the Media


OSHA Inspections

OSHA InspectionThere are several different reasons that an OSHA inspector may enter your worksite for aninspection. They are:

� Imminent danger situations.

� Fatality/catastrophe investigations.

� Complaint investigations.

� Referral investigations.

� Follow-up inspections.

� Monitoring inspections.

� Programmed inspections.

� Health inspections.

Imminent danger situations and fatality/catastrophe investigations are extremely seriousreasons for an inspection. During a fatality/catastrophe investigation, the OSHA inspector willtry to determine the cause of the accident and whether an OSHA violation occurred.

A complaint investigation occurs when OSHA receives a formal complaint regardingyour worksite. Referral investigations result from OSHA receiving a referral on your worksitefrom another agency or from an OSHA inspector not trained to evaluate the specific po-tential hazard. Follow-up and monitoring inspections are done to evaluate abatement sta-tus of violations.

Programmed inspections and health inspections are comprehensive in nature; they aresometimes called “wall-to-wall” inspections. The OSHA inspector will review records and writ-ten programs, conduct a walk-around inspection, and determine the need to collect samplesto characterize exposure. OSHA inspections are part of an ongoing process to help assurethe safety and health of workers.


OSHA Inspections

Opening Conference

At the opening conference the OSHA inspector explains the reason for the inspection. A jointopening conference includes the employer as well as the employee representative. Separateopening conferences will be conducted for the employer and the employee representative ifeither party chooses not to have a joint conference.

During the opening conference the scope of the inspection is explained. The inspectiongenerally includes:

� Private employee interviews.

� Physical inspection of the workplace and records.

� Possible referrals.

� Discrimination protection provisions.

� Closing conference.

At multi-contractor worksites, the opening conference may be done initially with the primarycontractor, followed by each subcontractor.

The OSHA inspector will provide a copy of the OSHA poster, blank OSHA-300 Form, appli-cable OSHA regulations, and other appropriate informational handouts and materials, if notalready in your possession. Additional information the inspector will discuss includes:

� Legislative Limitations: If the employer is covered by any exemptions or limitations inthe current Appropriations Act or in Chapter II.

� Employer Name: The correct legal name of the company, what type of legal entity thecompany is, and whether the company is a subsidiary of another business entity.

� Coverage: Verification that the employer is covered under the Act.

� Trade Secrets: If there are areas in the operation that contain or might reveal tradesecrets.

� Photographs and Videotapes: If the employer objects to photographs or videotapesbeing taken.

� Potential Hazards: Any safety and health hazards that the walk-around party may beexposed to during the inspection.


OSHA Inspections

Records Review

An inspection at a hazardous waste site will include a records review. During the recordsreview a lost workday injury (LWDI) rate will be calculated. This count does not apply if a LWDIrate has been calculated during the current calendar year or if the establishment meets one ofthe deletion criteria. In addition, the inspector may request access to records and writtenprograms, including:

� Site safety and health program.

� Injury and illness records (OSHA 300 and 300A).

� Employee exposure and medical records.

� Hazard communication program.

Site Safety and Health Program

The required document must be on site for review by the inspector. Included are all the writtenprograms required by 29 CFR 1910.120. An evaluation of the employer’s health and safetyprogram will cover the following elements:

� Comprehensiveness: The degree to which the program covers the hazards normallyencountered through the employer’s operations.

� Communication: The employees’ awareness of the safety and health program and themeans used to disperse the information. This includes evaluating the frequency of safetymeetings and distribution of informational booklets or memorandums.

� Enforcement: The OSHA inspector will evaluate the degree to which the employer en-forces the OSHA standards. This includes the methods used to enforce the standards(warnings, disciplinary action, etc.) and the effectiveness of the methods.

� Safety/Health Training Program: An evaluation of any safety and health training pro-gram, including any special training needed for the hazards that will be encountered at theemployer’s worksite. This also includes a review of any ongoing or periodic training orretraining of workers.

� Investigations: An analysis of the employer’s efforts to conduct accident/injury/illnessinvestigations and whether corrective and preventive actions have been implemented.


OSHA Inspections

� Monitoring: Includes a program for self-inspection, maintenance schedules, inspectionrecords, sampling and calibration procedures, ventilation measurements, preventive main-tenance programs, laboratory services, use of industrial hygienists and accredited labora-tories, and compliance with applicable monitoring standards.

� Medical: The inspector will determine if all medical surveillance requirements are beingcomplied with. This includes whether replacement and periodic examinations are beingprovided by the employer and the extent of the medical examinations.

� Recordkeeping: An evaluation of the recordkeeping program is not limited to OSHA-required records. The inspector will check for any information pertinent to the inspection,which may include employee exposure and medical records and employee access torecords.

� Compliance: This includes any engineering controls, work practice and administra-tive controls, and personal protective equipment utilized by the employer for compli-ance purposes.

� Regulated Areas: The inspector will verify that all regulated areas are clearly identifiedand maintained according to the criteria of the applicable standard.

� Emergency Procedures: The employer’s emergency program will be evaluated to deter-mine if potential emergency procedures are covered in the emergency response plan, ifemergency conditions have been explained to the employees, and if a training programexists that covers emergency response procedures.


OSHA Inspections

Injury and Illness Records

The OSHA 300A data is used to calculate the LWDI rate. If the injury and illness records wereexamined in the current calendar year by an OSHA inspector, only the data generated sincethe last inspection needs to be examined. The OSHA 200 forms will be examined if:

� The data was not available during the last inspection.

� The calendar year has changed since the last inspection and new OSHA 200 data isavailable.

Employee Exposure

and Medical Records

The inspector will verify that the employee exposure and medical records are kept in accor-dance with the medical surveillance recordkeeping requirements of 29 CFR 1910.1020. AnOSHA inspector’s access to medical records is authorized under Other Regulations and Pro-cedures, 29 CFR 1913.10(b)(4), for the purpose of verifying the existence of the records.Review of the records’ accuracy may require a written access order or employee consent.

Hazard Communication

For materials at the worksite covered by the Hazard Communication Standard (29 CFR1910.1200), the inspector will verify that the requirements of the standard have been met andthat the program is effective. Verification will be accomplished by reviewing the written pro-gram and interviewing employees to determine whether the training is effective. Employeeresponses will be documented for the case file.


OSHA Inspections

Posting Requirements

Under 29 CFR 1903 and 1904, an employer is required by OSHA to post various informationfor employees to read. During an inspection, an OSHA inspector will verify that the followinginformation has been posted in an accessible location for employees to read:

� OSHA poster informing employees of their rights and responsibilities under the Act.

� During the month of February, the Log and Summary of Occupational Injuries andIllnesses (OSHA 300A).

� Current citations.

� Petitions for Modifications of Abatement Date (PMAs).


OSHA Inspections

Walk-Around Inspection

An OSHA safety and health inspection includes a walk-around inspection or survey of theworksite. A partial or narrowly focused inspection may be expanded for a number of rea-sons, including:

� Lack of a comprehensive safety and health program.

� Deficiencies in specific programs such as respiratory protection and personal protectiveequipment, hazard communication, lock-out/tag-out, wire rope inspection for cranes, orfire protection.

� Noted apparent violations of safety and health standards.

� Concentrations of injuries and illnesses in specific worksite areas.

� High injury and illness rate as compared to the industry (SIC code).

The employer will be notified immediately if it is determined that the inspection should beexpanded. Any observed violations will be documented. Note: A Federal Appeals Court rulinglimits inspections to the purpose stated in the original opening conference (April 1994).

During any safety and health inspection, the OSHA inspector will become familiar with theworksite layout, processes, and hazards. The inspector will observe employee activities andinterview them to evaluate compliance with health and safety training and identify employeeconcerns.

During the walk-around inspection, compliance with specific OSHA performance standardswill be evaluated. These performance standards include hazard communication and lock-out/tag-out. Also, the inspector will check areas and conditions that received citations in the pastto ensure abatement or to determine abatement progress. This may require monitoring activi-ties. If sampling is required, a sampling strategy will be developed based on the potentialchemical and physical hazards.

For health inspections, any relevant information about potential exposure to chemical haz-ards or physical hazards will be recorded. Material Safety Data Sheets will be collected whenavailable and if needed. When observing employee activities, the inspector will estimate thenumber of employees at each operation and whether they are involved in stationary or tran-sient activities. The duration and frequency of cyclic work will also be recorded, as well as adescription of potential exposures during each phase of the cycle.

When the inspector determines there is a need, photographs and videotapes will be taken,labeled, and placed in the case file. OSHA personnel preserve the confidentiality of all infor-mation or investigations that may reveal a trade secret. If the OSHA inspector observes aviolation of a law that is enforced by another government agency, a referral will be sent to theappropriate agency.


OSHA Inspections

Closing Conference

In general, during the closing conference the OSHA inspector will describe any apparentviolations found during the inspection and indicate the applicable sections of the standards.Both the employer and the employee representative will be advised of their rights to partici-pate in additional conferences, meetings, and discussions. Specifically, the OSHA inspectorshould assure that the employer has a copy of “Employer Rights and Responsibilities Follow-ing an OSHA Inspection” (OSHA-3000), which explains the employer’s responsibilities andcourses of action if a citation is issued.

If a citation is issued, the original is sent to the employer. A letter explaining the employer’sright to an informal conference, and the requirement that any Notice of Intent to Contest mustbe in writing, is enclosed. Any proposed penalty, notification of assessment of interest, oradditional charges for nonpayment and administrative costs is enclosed.

If the employer knowingly provides false information about efforts to correct cited condi-tions, recordkeeping, or any matter related to the Act, criminal penalties may be broughtagainst the employer.

Employers are prohibited from discharging or discriminating in any way against employeeswho have exercised their rights under the Act, such as those who make a safety and healthcomplaint or request an OSHA inspection. OSHA will investigate any complaints by employ-ees who feel they have been discriminated against. If OSHA finds probable cause, legalaction against the employer may be initiated on behalf of the employees whose rights wereviolated.

The OSHA inspector will discuss any conditions considered de minimis and explain thatthese conditions will be reviewed by the Area Director along with the apparent violations. Ifthe conditions are classified as de minimis, they will not be included on the citation. A condi-tion is considered de minimis when it has no direct or immediate relationship to employeesafety and health or when the condition is the result of a slight deviation by the employer to thestandard but the intent of the standard is still intact.

The inspector will explain any apparent serious violations that were observed but are notwithin the inspector’s expertise. These violations will be referred to the inspector’s supervisorand may result in additional inspections at a later date.


OSHA Inspections

Follow-Up Actions

Citation Posting: The citation, or a copy of it, must be posted upon receipt at or near the placewhere the violation occurred for three days or until the violation is corrected, whichever islonger. The purpose is to inform the employees of any hazards to which they may be exposed.If the citation is amended, a copy of the amended citation must be posted along with theoriginal citation. If the citation is contested, the citation must still be posted.

Informal Conference: Any time a citation is issued, the employer has the right to request aninformal conference with the OSHA Area Director. In fact, employers are strongly encouragedto request a conference. Informal conferences give the employer the opportunity to:

� Resolve disputed citations and penalties without resorting to the litigation process.

� Obtain a clearer understanding of the specific health and safety standards which apply.

� Discuss possible ways to correct the conditions.

� Ask questions concerning any proposed penalties.

� Discuss any difficulties with proposed abatement dates.

� Ask questions about other employee safety and health practices.

� Learn more about existing OSHA programs and services.

An informal conference does not extend the 15-day working-day period an employer has tocontest a citation. Also, an oral statement of disagreement during an informal conferencedoes not meet the requirements of a written Notice of Intent to Contest.

Complying With Citation and Notification of Penalty: If the citation and penalty are notcontested, the cited conditions must be corrected by the abatement date, and the penaltiesmust be paid.

Penalties: Penalties must be paid within 15 days after the employer receives the citationand notification of penalty. If the penalty or citation is contested, the penalties do not have tobe paid until a final decision is made.


OSHA Inspections

Contesting Citation and Notification of Penalty: To contest a citation, penalty, and/orabatement date, the OSHA Area Director must be notified in writing within 15 working daysafter receipt of the citation and notification of penalty. The written notification (Notice of Intentto Contest) must be postmarked no later than 15 working days after receipt of the citation, orthe citation will become a final order. The Notice of Intent to Contest must clearly state what isbeing contested.

Petition for Modification of Abatement Date: Abatement dates are set based on theinformation available when the citation is issued. If circumstances prevent the employer frommeeting the abatement date and the 15 working-day contest period has expired, the employermay submit a petition requesting a modification of the abatement date. If the employer doesnot achieve abatement for uncontested violations by the abatement date, OSHA can imposeadditional penalties of up to $7,000 per day per violation.

Variance: Employers may apply to OSHA for a temporary variance when a standard ispassed and the employer is unable to comply by the effective date because of the unavailabil-ity of required materials, equipment, or personnel. Employers may also apply for a permanentvariance if they can prove that their methods of operation are just as safe and healthful asthose proposed by a OSHA standard.

OSHA-Funded State Consultation Services: OSHA has available consultation servicesfor high-hazard small businesses. It provides free on-site and off-site assistance includinghazard surveys, assistance with correcting cited and uncited hazards, assistance with safetyand health programs, and training and education.


Site-Specific Health & Safety Plan

Site-SpecificSafety & Health Plan

Under 29 CFR 1910.120(b) employers are required to develop and implement a writtensafety and health program for their employees involved with hazardous waste site opera-tions. The development of a safety and health program is an essential aspect of protect-ing the health and safety of workers. It is through thorough planning that potential hazardsmay be anticipated and steps taken to minimize the risk of harm to workers, the public,and the environment.

The safety and health program establishes policies and procedures to protect workers andthe public from the potential hazards posed by hazardous waste site work. The purpose of thesafety and health program is to document measures to minimize accidents and injuries thatmay occur during normal daily activities or during adverse conditions such as hot or coldweather. The program must:

� Identify, evaluate, and control safety and health hazards.

� Provide for emergency response.



A written safety and health program includes the following subjects:

� The organizational structure.

� A comprehensive workplan.

� A site-specific safety and health plan.

� The safety and health training program.

� The medical surveillance program.

� Standard operating procedures for safety and health.

� Any necessary interface between general program and site-specific activities.

The site-specific safety and health plan is a crucial element in a written safety and healthprogram. As a supervisor, you may be required to assist in developing the plan as well asimplementing it. The purpose of the site-specific safety and health plan is to identify worktasks, as well as to identify, evaluate, and plan for controlling risks.



Site-Specific Safety and Health Plan

The site-specific safety and health plan must be kept on-site. Before site activities are initi-ated, employees must be briefed on the contents of the site-specific plan. Inspections must beconducted periodically by the site safety and health officer to determine the effectiveness ofthe plan. Information and data gathered during site characterization and analysis must beused to update the plan. It is the responsibility of the employer to update and/or correct anydeficiencies found in the effectiveness of the site-specific plan. There are three categories ofsite work activities:

� Site characterizations.

� Remedial clean-up actions.

� Emergencies.

Site-specific safety plans can vary in length depending on the category of work activity,information available, and complexity of the hazards.

A site-specific safety and health plan addresses the safety and health hazards of eachphase of site operations and includes the requirements and procedures for worker protection.These include:

� Safety and health risk or hazard analysis for each site task and operation found in theworkplan.

� Employee training assignments.

� PPE to be used by workers for each site task and operation.

� A medical surveillance program.

� Frequency and types of air monitoring, personnel monitoring, and environmental sam-pling techniques and instrumentation to be used.

� Site control measures.

� Decontamination procedures.

� An emergency response plan including procedures and equipment.

� Confined-space entry procedures.

� A spill containment program.

Considerations required to develop each of these parts of the plan are described below.



Hazard Analysis for

Site Tasks and Operations

The hazard analysis is one of the most important activities in developing the safety and healthplan. Determination of what should be incorporated for all of the other elements of the plan isbased on the results of the hazard analysis. The hazard analysis is a risk characterizationwhich includes, but is not limited to:

� Site location and name.

� Site description.

� Chemicals and quantities involved.

� Hazards associated with each chemical.

� Behavior and dispersion of material involved.

� Types of containers, storage, or transportation methods.

� Physical hazards.

� Sources of prevailing weather information and forecast.

� Surrounding populations and land use.

� Ecologically sensitive areas.

� Facility records.

� Preliminary assessment reports.

� Off-site surveys.

� Topographic and hydrologic information.

When possible, this information can be referenced from other available sources such assite characterization reports. The site-specific plan must be updated as new information isgained during the remediation.



Employee Training Assignments

The HAZWOPER regulation (29 CFR 1910.120 [e]) requires that people who work at hazard-ous waste sites receive health and safety training. The site-specific safety and health programplan must document the duration, content, and completion of training to assure that personnelare adequately trained to perform their job duties and handle the hazardous situations theymay encounter.

� General site workers and equipment operators must receive 40 hours of training off-siteand three days of supervised on-site training. Managers and supervisors who routinelywork at a site must receive 40 hours of training off-site, three days of supervised on-sitetraining, and an additional eight hours of specialized supervisor training.

� Workers who are on-site only occasionally for a specific limited task and will not be ex-posed above the permissible or published exposure limits must receive 24 hours of train-ing off-site and one day of supervised on-site training.

� Workers who are regularly on-site but who work in areas that do not require respira-tory protection must receive 24 hours of training off-site and 1 day of supervised on-site training.

� Any worker that receives 24 hours of off-site training who becomes a general site workeror is required to wear a respirator must receive an additional 16 hours of off-site trainingand an additional two days of supervised on-site training.

� All site workers and supervisors must complete 8 hours of refresher training each year.

Training must be completed before site activities begin or before a new worker enters thesite. As a supervisor, you may be required to determine how many hours of training eachworker needs. Your decision is based on each worker’s job duties and the hazards associatedwith them. For a more specific explanation of the training requirements, refer to paragraph (e)of HAZWOPER (29 CFR 1910.120).




The selection of personal protective equipment (PPE) to be worn by a worker is based on thechemicals or physical hazards involved and the job tasks to be completed. The safety andhealth plan must outline what PPE is to be used during each site operation. Factors to con-sider when selecting PPE include:

� Hazards/chemicals involved.

� Route of exposure.

� Job/task duration.

� Weather conditions.

� Chemical resistance and physical integrity of the suits available.

� The nature of the job/task (characterization, remediation, emergency).

Medical Surveillance Requirements

The medical surveillance program describes site-specific medical surveillance requirements.Depending upon the site hazards and required protective equipment, workers may be re-quired to pass a physical examination before entering the site. Any employee who becomes illor develops signs or symptoms of possible overexposure is also included in the program.

Generally, the site-specific safety and health plan describes medical facilities available on-site, the names and phone numbers of emergency personnel, and provisions for use of localmedical facilities.



Monitoring and Sampling

The monitoring and sampling section of the safety and health plan describes the program/schedule for periodic air monitoring, personnel monitoring, and environmental sampling. Thisprogram is very important because it allows for constant re-evaluation of the hazards at thesite. The types of instrumentation and sampling/analysis methods are detailed. Also, if thereare any limitations to the monitoring/sampling schedule, they must be explained. Limitationsmay include:

� Time lapse in getting monitoring/sampling results back.

� Unknown constituents.

� Inadequate instrumentation.

� Other chemicals that may interfere with detecting the chemical of interest.

� Need to keep equipment ready for use if an emergency occurs.

� Required volume.



Site Control Measures

The site control program includes a site map, site work zones, the use of the buddy system,site communications, Standard Operating Procedures (SOPs), and identification of the near-est medical facility. The site map shows:

� Topographic features (elevation, waterways, vegetation).

� Wind direction.

� Drainage.

� The location of buildings, containers, impoundments, pits, ponds, roadways, and tanks.

� Perimeter security fences.

Site maps are used to help plan activities, select PPE, assign personnel to work zones,identify potential hazards, and identify access and evacuation routes. Site maps are modifiedduring remediation site work to reflect changes resulting from the work.

Site maps are used in conjunction with results from air and environmental monitoring todetermine where to place the exclusion zone, the contamination reduction zone, and thesupport zone. It is important to update site maps whenever new information is obtained sozones may be adjusted accordingly.

Whenever required site control information is found in other parts of the safety andhealth plan, it need not be repeated; for example, the medical facility is likely to be de-scribed in Medical Surveillance.



Decontamination Procedures

The decontamination section of the safety and health plan establishes decontamination pro-cedures for personnel and equipment. Include a layout of the decontamination line, proce-dures to follow during decontamination, a list of equipment and supplies, and steps to set upthe decontamination line.

Soap and water are the most frequently used decontamination solutions. In some circum-stances, a neutralizing foam or spray may be more effective. The choice of decontaminationsolutions depends on the chemicals which have contaminated the PPE or equipment. In someinstances you may not be able to decontaminate at all, and the PPE or equipment will have tobe considered hazardous waste.

When determining the decontamination procedures, refer to the hazard analysis and PPEprogram to choose the best decontamination methods for the chemicals and hazards in-volved. Chemical safety handbooks, MSDSs, and vendor information may also be useful.



Emergency Response Plan

Every safety and health plan must include an emergency response plan (ERP) meeting therequirements of paragraph (l) of HAZWOPER (29 CFR 1910.120). The emergency responseplan must include:

� Pre-emergency planning.

� Personnel roles, lines of authority and communication.

� Emergency recognition and prevention.

� Safe distances and places of refuge.

� Site security and control.

� Evacuation routes and procedures.

� Decontamination procedures not previously covered by the site-specific plan.

� Emergency medical treatment and first aid, including hospital locations.

� Emergency alerting and response procedures.

� Critique of response and follow-up.

� PPE and emergency equipment.

Site topography, layout, and prevailing weather conditions from the site control plan arereferenced or copied into the ERP. Procedures for reporting incidents to local, state, andfederal government agencies are detailed. It is important to integrate the ERP with the disas-ter, fire, and/or emergency response plans of local, state, and federal agencies. HAZWOPERalso requires that the ERP be rehearsed and reviewed regularly.



Properties of Confined Spaces

� Limited ways to get in and out of the space

� Not intended for continuous human occupancy

� Bodily entry is possible and work can be performed.

Confined-Space Entry Procedures

As an emergency responder, you may be called upon to work in confined spaces to controlreleases or rescue victims. A confined space generally has three distinct properties which setit apart from other areas and dramatically increase the risk of injury or illness.

Some common confined spaces that are found at manufacturing facilities include, but arenot limited to:

� Ditches, culverts, and ravines.

� Excavations and trenches.

� Tank cars.

� Vaults.

� Sewer system with manhole entrance.

� Vats.

� Tanks.

The OSHA Permit-Required Confined-Space Entry Standard (29 CFR 1910.146) re-quires that the employer survey all confined spaces and designate those for which apermit is required. REMEMBER that in an emergency, the hazards of a space may change.For example, a ditch not usually containing any hazard could be a catch basin for spilledmaterial. Although not designated a permit-required confined space, it has become oneas a result of the release.



A permit-required confined space (permit space) means a confined space that has one ormore of the following characteristics:

� Contains or may contain a hazardous atmosphere.

� Contains a material that may engulf an entrant.

� Has an internal configuration such that an entrant could be trapped or asphyxiated byinwardly converging walls or by a floor which slopes downward and tapers to a smallercross-section.

� Contains any other recognized serious safety or health hazard.

Rescue personnel must be informed of the hazards before entry.

Entry into confined spaces poses many dangers. Chemical vapors can accumulate quicklyin confined spaces. A confined space might also contain a material that could trap a worker ora moving part that could trap or injure. Entry into confined spaces may block your view of whatelse is happening around you.

Lack of natural ventilation makes it easier for toxic or flammable materials to accumulate.Something as simple as rusting metal or the operation of fuel-powered engines can depletethe existing oxygen supply. Decaying organic materials such as plants or animals can createhydrogen sulfide gas.

Many toxic gases don’t have any warning properties, so emergency responders about toenter the confined space have no way of knowing what hazards they might face without firsttesting the air. The most common confined-space injuries are asphyxiation from lack of oxy-gen, being overcome by very high concentrations of toxic vapors, or rapid skin absorption oforganic solvents.



Other common confined-space hazards involve explosions or fires. Getting in and out ofa confined space can cause injuries and hinder rescue efforts in emergencies. Respond-ers who may be required to rescue victims must be provided training in the types of spacesat the facility.

Several steps must be taken to make work safer in confined spaces. Careful advance plan-ning for confined-space entry can help minimize the risk of injury. This advance planning mustinclude the following points:

� Identifying confined spaces. (Determine which require a permit to enter.)

� Developing written standard operating procedures (SOPs).

� Arranging for and strategically locating adequate supplies of air-supplying respirators andprotective and life-saving equipment.

� Training personnel who must enter permit-required confined spaces to deal with emer-gency events.

� Training personnel how to monitor and properly safeguard the space before andduring entry.

� Posting a qualified and trained safety attendant who is ready to provide assistance, ifrequired, outside the confined-space entrance at all times.

� Training personnel to recognize when the hazards of a confined space may have changed.

The hazards of confined-space entry are further reduced by:

� Monitoring confined spaces before entry and during work for oxygen deficiency and flam-mable or toxic atmospheres. Monitoring must be conducted throughout the space, notjust at the entry point.

� Providing appropriate ventilation before and during the work.

� Complying with the permit and logging system. Under this system, confined-space entryis permitted only after information about oxygen and toxic and flammable vapor levels hasbeen collected. The permit must be signed by a responsible manager. No personnel canenter the confined space without a signed entry permit. Permits are valid only for a spe-cific date, time, and place.

A confined-space entry SOP minimizes danger by trying to control factors that may causeor contribute to accidents or emergencies through careful monitoring, training, and planning.These required standard procedures are an administrative control. Examples of a confined-space entry log and a confined-space entry permit are located on the next two pages.

Other samples can be found in 29 CFR 1910.146, Appendix D.



Location of Confined Space

Personnel

Instruments

Confined-Space Entry Log of

Personnel and Check-In/Check-Out

Building ______________________________ Process or Area ____________________________

Person in Charge __________________________

Date of Entry __________________________ Title _____________________________________

Personnel Authorized to Enter Confined Space Job Title Work Location in Confined Space

Stand-by Employee(s) 1. ______________________________ 2. ______________________________

Calibration of Instrumentation Instrument Readings

Combustible- Sampling Time of Combustible Other

Oxygen Unit Gas Unit Point Location Readings Oxygen % Gas % LEL Chemicals

Check-In/Check-Out

Authorized Personnel in Confined Space Ventilation of Confined Space

Signature of Time Provided Time Period Discharge

the Personnel Into Space Out of Space Yes No of Ventilation Air Volume



1. Name/location of area __________________________________________

2. Time and date of entry _________________________________________

3. Personnel who will enter ________________________________________

4. Have all valves/electrical equipment been locked? Yes � No �

5. Have all lines been broken, blanked off, or isolated? Yes � No �

6. Combustible-gas meter test results _______________________________

7. Oxygen meter test results _______________________________________

8. Hydrogen sulfide test results ____________________________________

9. Other air monitoring test results __________________________________

10. Warning signs posted? Yes � No �

11. Respirators worn? (List type.) ____________________________________

12. Lifeline and safety winch? Yes � No �

13 Other safety equipment used? ___________________________________

14. Intrinsically safe equipment and non-sparking tools? Yes � No �

Sign after checking personally:

1. ___________________________ 3. ___________________________

2. ___________________________ 4. ___________________________

This permit must be filled out before any entry can occur and

returned to the Safety Officer for filing when work is completed.

Confined-Space Entry Permit



The confined-space entry program must be in writing. The initial training of attendant, entrant,supervisor, and rescue workers is detailed; and documentation of annual retraining for theseindividuals is detailed. All procedures to be used during activities related to the entry areincluded. The program must include a description of procedures to:

� Prevent unauthorized entry.

� Identify/evaluate hazards prior to entry.

� Provide means/practices for safe entry.

� Provide equipment for testing, monitoring, ventilating, communication, PPE, lighting, bar-ring and shielding, safe access/egress, and rescue and emergency.

� Evaluate conditions during operations.

� Provide at least one attendant.

� Provide adequate response capability.

� Designate roles and responsibilities.

� Summon rescue/emergency personnel.

� Carry out the permit system.

� Coordinate operations if multiple employers are represented.

� Provide for conclusion of entry.

� Review operation.

� Review program.

� Provide training.

Important examples of pre-entry, entry, and post-entry procedures are listed on thefollowing page.



Pre-Entry Procedures

� Install signs and barricades, and secure the perimeter.

� Isolate space from unauthorized personnel.

� Obtain and fill out a confined-space permit.

� Test and continually monitor the atmosphere.

� Ventilate and reset space.

� Must use retrieval lines with harness.

Entry Procedures

� Chief entry worker makes initial atmospheric tests within space, with oxygen levels al-ways being measured first. Attendant remains outside at all times and records atmo-spheric readings on the confined-space permit.

� Attendant maintains continuous communication (visual or radio) with lead entrant worker.

� Retrieval lines are manned outside by rescue personnel or tied off at a secure fixture.

� Under no circumstance shall workers enter an IDLH environment without wearing a har-ness and retrieval line.

� Protective equipment must be appropriate for the hazards.

� Chief entrant worker and attendant have authority to evacuate the space.

� All housekeeping duties must be performed during or after the work is completed.



Post-Entry Procedures

� If any problems were encountered, have follow-up critique to resolve.

� Check all equipment; repair as necessary and store.

� Complete report.

Annually, the entire program should be reviewed and updated.

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