OSHA and Emergency Response The Occupational Safety and Health

Administration (OSHA) addresses responsibilities for employers with regards to disaster preparedness and response in several OSHA standards.

The following OSHA standards require employers to address emergency preparedness in some way:

OSHA’s Emergency Action Plans Emergency Action Plans (29 CFR

1910.38(a)) The OSHA Etool on Emergency Action Plans

can be found here.

1910.38 (a) Employer’s requiring some employees to use

portable fire extinguishers and others to evacuate Employers who must supply portable fire

extinguishers but require their employees to evacuate only

Employers who require employees to evacuate during certain emergencies e.g. total area flooding or, evacuation during a release of a toxic substance Ref: 1910.120(q)

Specific health standards – 1910.1047

OSHA’s Emergency Action Plans Businesses that deal with hazardous substances

(such as Ethylene Oxide , Methylenedianiline , or Butadiene ), or that are subject to the provisions of the Process Safety Management of Highly Hazardous Chemicals , Hazardous Waste Operations , or Grain Handling standards may also need to develop an emergency action plan in compliance with 29 CFR 1910.38(a) .

OSHA’s Emergency Action Plans Emergency action plans and rescue provisions

can also be found in the standards covering Permit Required Confined Spaces (29 CFR 1910.146), Fire Brigades (29 CFR 1910.156), and Hazard Communication (29 CFR 1910.1200).

OSHA’s Directive CPL 02-02-073 OSHA CPL 02-02-073 was issued April 24,

1998. This instruction updates enforcement

procedures for compliance officers who need to conduct inspections of emergency response operations.

National Response Plan and OSHA’s Role New guidance is provided on how the

HAZWOPER standard may apply to unique events such as terrorist attacks and addresses OSHA's role under the National Response Plan.

This instruction assists other Federal, State, and local personnel who have responsibilities under incident command systems and will assist in emergency response operations.

OSHA’s Role Under HSPD-5 OSHA's relationship with Homeland Security

Presidential Directive (HSPD-5), including discussion addressing the National Response Plan (NRP), the Worker Safety and Health Support Annex, and the National Incident Management System (NIMS).

Some Basic OSHA Expectations Employee protection is priority # 1 Fully consider the widest range of worst case

scenarios when deciding your emergency actions As the employer expects more from its

employees, OSHA expects more of the employer Plan, communicate and train --- train,

communicate and plan

So What Constitutes a Workplace Emergency? Webster - an unforeseen combination of

circumstances or the resulting state that calls for immediate action

An unexpected and uncontrolled event that has seriously harmed or threatens harm to workers

any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace

Fundamentals 29 CFR 1910.36 and 37 (emergency egress)

Sufficient # for the occupancy Exit ways and access thereto are unobstructed Exit ways and access thereto are clearly marked Exit signs are visible at night Emergency lighting is supplied when needed OSHA is the authority having jurisdiction

Fundamentals 1910.151 requires the availability of

emergency first aid Requires emergency body and eyes flushing

where contact with corrosives can occur 1910.124 – requires “appropriate first-aid

supplies” when employees work with dipping and coating chemicals

Designated First Aid Responders 1910.1030 – addresses protection required

against blood borne pathogens - your designated and collateral duty first aiders are covered ECP Training on Universal Precautions and the

standard HBV vaccinations and post exposure follow-up

Collateral Duty Exception

Personal Protective Equipment OSHA Subpart I – 1910.132-138

Assess your emergency plan to ensure that PPE needs have been anticipated

Provide the required PPE Train and re-train employees (as necessary) on its

use, maintenance and limitations Verify and then certify that training was

completed

Emergency Use Respiratory Protection Written program Provide a respirator for the worst case anticipated

use Inspect emergency use respirators monthly

Inspections must include certification Date, signature, findings, S/N and any actions taken e.g.

“Tank filled” Train employees on emergency use Medically evaluate employees

Broad Scope Emergency Standards Employee emergency response plans:

1910.38(a) Does your plan include evacuation? Is it required by a specific OSHA standard? If so, you must follow this standard The elements are an excellent starting point for

all evacuation plans

BEFORE the Emergency Occurs Plan safe evacuation for the range of anticipated emergencies Assign roles to execute the plan Identify the means to report emergencies Prepare written plan that describes roles and evacuation

procedures Train employees on the plan and assigned roles Implement and alarm system per 1910.165 Coordinate with outside responders as necessary Document your efforts, meeting minutes, training records,

disciplinary actions - employee declinations

During an Emergency If your planning and preparation is deficient,

your response certainly will be…. The larger, more newsworthy the event, the more

likely OSHA will be there OSHA will normally inspect the management of

both the emergency crisis and its consequence The more reasonably anticipated the emergency,

the higher the expectation that the employer will respond appropriately

Broad Scope Standards cont. Hazardous Waste Operations & Emergency

Response: 1910.120 (q) Applies anywhere an emergency chemical release

can occur All Haz-Mat responders are covered Performance Oriented

Prior to the Haz-Mat Emergency 1910.120(q) requires… A written plan, available upon request to OSHA that

considers…. Pre-planning and coordination w/outside parties Identified personnel roles, lines of authority, training

and communication e.g. the ICS system Training on emergency recognition and prevention Safe Distances and Refuge

.120(q) continued Site security and control Evacuation Routes and Procedures Decontamination Emergency Medical Treatment + First Aid Critique of Response and Follow-Up PPE and Emergency Equipment

During a Haz-Mat Emergency Based on the hazardous substances and/or

conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards encountered……

IC can appoint a safety officer to oversee personnel safety

Emergency Haz-Mat Roles During an Emergency The roles that you decide for your employees determine their

level of involvement and the amount of training First responder Awareness – Determines if ER needed and notify First responder Operations – Protect – Contain - Exclusion Zone Hazardous Materials Tech. – Control at source + Remediation Hazardous Materials Specialist –could be the “Safety Officer” –

liaison with outside responders Incident Commander Level – has Operations Level Training with

authoritative and unilateral decision making ability

Emergencies at Plants Covered by 1910.119 Focuses on preventing accidental releases. The employer must establish and implement an emergency

action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a).

The emergency action plan shall include procedures for handling small releases.

Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p) and (q).

.119 requires the training of on-site contractors.

Site Security Assess your liabilities and risks Identify your soft underbelly and firm it up The greater the consequence, the greater the

need for security Develop a security culture – employees and

contractors Develop a strong working relationship with

local police and first responders

Miscellaneous Emergency Related Issues Confined Spaces – Emergency Rescue Significant Spills must be reported to the

NRC 800-424-8802

Must report a fatality or hospitalization of 3 or more employees to OSHA within 8hrs.

Protecting Emergency Responders, Volume 1: Lessons Learned from Terrorist Attacks

Protecting Emergency Responders: Lessons Learned from Terrorist Attacks, sponsored by the National Institute for Occupational Safety and Health (NIOSH), summarizes the results of a conference held in New York City on Dec. 9-11, 2001, and organized by the RAND Science and Technology Policy Institute. Participants were emergency workers from around the country who responded to the bombing of the Alfred E. Murrah Building in Oklahoma City, the September 11th attacks on the World Trade Center and the Pentagon, and the anthrax incidents that occurred during autumn 2001.

Protecting Emergency Responders, Volume 2: Community Views of Safety and Health Risks and Personal Protection Needs

Firefighters, law enforcement officers, and emergency medical service responders play a critical role in protecting people and property in the event of fires, natural and man-made disasters, medical emergencies, terrorist and other criminal acts, and numerous other types of emergencies.

The authors examine the hazards that emergency responders face and the personal protective technology needed to contend with those hazards.

Protecting Emergency Responders, Volume 3: Safety Management in Disaster and Terrorism Response

This study provides recommendations for preparing for response to such disasters and other large-scale incidents.

It uses literature review, study interviews with members of the response community, and information gathered at the RAND Corporation-National Institute for Occupational Safety and Health workshop Protecting Emergency Responders: Safety Management in Major Disaster and Terrorism Response in Arlington, Va., on February 27, 2003.

Protecting Emergency Responders, Volume 4: Personal Protective Equipment Guidelines for Structural Collapse Events

This monograph serves as a technical source for National Institute for Occupational Safety and Health (NIOSH) incident commander guidelines for emergency response immediately following large structural collapse events.

It characterizes response activities and expected hazards, and develops guidelines for selecting appropriate personal protective equipment (PPE).