PAGE 1 OF 10 SCOPE This procedure applies to all employees and subcontractors, premises and work sites where there is a substantial potential for the catastrophic release of hazardous substances. PURPOSE This standard practice establishes the corporate policy, individual responsibilities and administrative procedures required to ensure compliance regarding OSHA requirements as well as serving as a formal health and safety plan for the Company s employees regarding Hazardous Waste Operations Emergency Response and the Resource Conservation Recovery Act. A written copy of this policy is available to any contractors or subcontractors employed by the Company as well as its employees, their representatives and any OSHA, federal state or local employees who have regulatory authority over the affected job site. DEFINITIONS Buddy System: a system of organizing employees into groups so that each employee is observed by at least one other employee in the group. Employee: any person employed by the Company including subcontractor personnel. Health Hazard: any chemical, mix of chemicals or pathogen for which there is statistically significant evidence of acute or chronic negative health affect in exposed employees as defined by OSHA 1910.1200 appendix A. Immediately Dangerous to Life or Health (IDLH): atmospheric concentration of any substance which poses an immediate threat to life or inhibits an individual s ability to escape a dangerous atmosphere. Permissible Exposure Limit (PEL): the upper limit of exposure by skin absorption, inhalation or other method as defined by OSHA 29 CFR Part 1910, Subparts G and Z. Qualified Person: a person with the specific training, knowledge and experience in the area that they have the responsibility and authority to control. Supervisor: the person directly responsible for planning, controlling and monitoring the execution of activities.
PAGE 2 OF 10 WORK PLAN Preliminary Site Evaluation and Entry On sites where there exists the possibility for the catastrophic release of hazardous or toxic substances the Company shall conduct a preliminary evaluation of the hazards that exist at the site. This evaluation shall be conducted by a qualified person, and shall be reviewed immediately after initial entry for completeness and accuracy. Prior to entering the worksite the following information must be established: 1. Location and approximate size of the worksite 2. Description of the job task to be performed at the site 3. How long employees will be working at the site 4. Site layout and accessibility by road, water or air 5. Safety and health hazards that will be encountered on site 6. Possible pathways for hazardous substance dispersion 7. Status and capabilities of the emergency response teams in place who will provide assistance to onsite employees in the event of an emergency 8. Hazardous substances and hazards to health that may be encountered at the site as well as their chemical and physical properties. Pre-entry Briefing Before any person is allowed to enter a site where there exists the substantial potential for the catastrophic release of hazardous substances the Company shall conduct a pre-entry briefing based on the observations made during the preliminary site evaluation to inform employees of the possible hazards that may exist at the site and what precautions are to be taken to mitigate those risks. Initial Personal Protective Equipment Personal protective equipment for use during initial site entry will be determined by the initial assessment of risks for that site. The PPE selected must conform to OSHA standards by ensuring that the employee is not exposed to any hazard beyond its OSHA defined PEL. When the preliminary site evaluation may not have been sufficient to identify the hazards on a site entry personnel shall be equipped with Level B PPE as described by OSHA 1910.120 appendix B. Once the specific site hazards have been identified proper PPE shall be selected to suit the situation. Initial Entry Direct Read Monitoring When initial site evaluation indicates the potential for IDLH conditions or ionizing radiation or when the initial evaluation may have been insufficient to determine site conditions direct reading instruments shall be used to identify IDLH conditions and ionizing radiation. The entry party must also use visual observation to detect evidence of any potential IDLH or other dangerous condition. Operating Controls and Procedures
PAGE 3 OF 10 For any worksite covered by this standard the hazardous conditions and materials identified are to be identified for communication to employees. The risks posed include but are not limited to: 1. Exposures exceeding the PEL 2. IDLH concentrations 3. Skin irritation and absorption hazards 4. Eye irritation hazards 5. Explosion and flammability risks 6. Oxygen deficiency Employee Notification Information concerning the physical, chemical and toxicological properties of the hazardous substances present at the job site are to be communicated to the employees who may encounter them during the course of the work they will perform. (Ref S220). Site Safety and Health Plan A written site-specific plan is to be developed for every job covered by this policy. The plan is to address the safety and health hazards for each area of operation at the site as well as including the requirements and procedures for protecting employees. This plan shall include: 1. A safety and health risk assessment for each task and area 2. Employee training assignments to comply with OSHA 1910.120(e) as covered below in Training 3. The appropriate PPE for each area and task being performed 4. The medical surveillance requirements of each area and task 5. Frequency and type of air, personnel, and environmental sampling or monitoring to be performed; the instruments to be used in these sampling procedures, and the methods for maintaining and calibrating the equipment to be used 6. Site control measures per OSHA 1910.120(d) as outlined below 7. Decontamination procedures per OSHA 1910.120(k) as outlined below 8. An emergency response plan per OSHA 1910.120(l) as outlined below 9. Procedures for confined space entry (ref S260) 10. A spill containment program meeting the requirements of OSHA 1910.120(j) Site Control A site control program is to be formulated as part of the site Health and Safety program after the initial assessment and modified as new information becomes available. This site control program is to include at a minimum: 1. A site map containing site work zones 2. Delineation of the site chain of command extending to the state level 3. Provision for the use of the Buddy System 4. Site communications procedures and emergency alarms 5. Safe work practices 6. Location of nearest medical assistance
PAGE 4 OF 10 Emergency Response For sites where there is a substantial potential for the catastrophic release of hazardous substances the Company must prepare an Emergency Response Plan. At a minimum this plan is to include explanations of: 1. Preplanning and coordination with area emergency services and support personnel 2. Employee roles, lines of authority, proper training and communication 3. How to recognize and prevent possible emergencies 4. Minimum safe distances and areas of refuge in emergency situations 5. Proper control and site security measures 6. Routes and procedures that must be followed in evacuations 7. Decontamination procedures not covered by the site safety and health plan 8. First aid and emergency medical treatment 9. Emergency alerting and response procedures 10. Critique of response and follow-up 11. PPE and emergency equipment at the site Training for proper emergency response procedures must be completed before an employee is required to respond to a real emergency. This training is to include the content of the Emergency Response Plan, the standard operating procedures for the job, and the proper PPE and procedures for responding to an emergency situation. Advanced training is not required for all employees at a site if: There are already enough fully trained employees to handle an emergency situation. Arrangements have been made in advance for an outside emergency response team with proper training to respond to emergencies in a timely manner. In these cases employees must receive sufficient training to recognize an emergency situation and summon qualified personnel without attempting to institute control actions for which they have not been trained. All training is to be certified and recorded for reference by the Company. Incident Command System Administration In the event of an emergency involving the release of hazardous substances the senior emergency response official responding shall become the person in charge of the site-specific Incident Command System (ICS). As new emergency response units arrive this position is to pass up the line of authority previously established. All emergency operations are to be conducted through the senior official, assisted by the senior officials present from each employer. The senior official in the ICS is responsible for: 1. Identifying to the fullest extent possible all hazardous substances and conditions present 2. Employing site analysis to determine appropriate engineering controls, maximum exposure limits and hazardous substance handling procedures 3. Determining, based on the hazards present, appropriate emergency operations 4. Ensuring that appropriate PPE is worn during emergency operations 5. Control the number of people at the emergency site
PAGE 5 OF 10 6. Designating a safety officer to identify and evaluate hazards and provide direction regarding the safety of operations Decontamination Before the Company s employees or equipment may begin work at a site where the potential to hazardous substances a decontamination procedure must be developed and implemented. Standard operating procedures shall be used minimize and control employee contact with hazardous substances or contaminated equipment. Employees, clothing and equipment leaving areas where hazardous substances are present must be properly decontaminated. Any discarded clothing or equipment must also be properly decontaminated and disposed of by proper methods. The site safety and health supervisor shall monitor the decontamination program for employee compliance and effectiveness. Shortcomings of the decontamination program are to be addressed immediately to protect the environment and the health of the Company s employees. Equipment and solvents used in the decontamination process must be decontaminated or discarded appropriately. Decontamination areas shall be located in geographical areas that will minimize exposure of uncontaminated employees and equipment to contaminated employees and equipment. Protective clothing and equipment must be cleaned, laundered, repaired, maintained, and/or replaced as necessary to maintain effectiveness. In the event that an employee s non-impermeable clothing becomes wetted with a hazardous substance the employee must immediately remove the clothing and proceed to the shower or appropriate personal decontamination facility. The contaminated clothing must be completely decontaminated per the Company s decontamination policy before it may be removed from the work zone. Employees may not remove protective clothing or equipment from the change rooms unless they have been specifically authorized to do so. Any contaminated clothing or equipment that is sent to a commercial laundering facility for cleaning must be appropriately tagged regarding the hazardous material with which it is contaminated, and the laundry facility informed as to the potentially harmful effects of exposure to the contaminants. Where change rooms, showers or other decontamination facilities are required they shall be constructed and operated in order to meet the requirements of OSHA 1910.141. Personal Protective Equipment Personal protective equipment shall be selected to protect the Company s employees based on the hazards identified during the site analysis. The selection process is to be based on the performance characteristics of the equipment relative to the duration and nature of the tasks to be performed and the limitations of the site. In situations where there exists an IDLH or potential IDLH condition positive pressure supplied air breathing apparatus shall be used. Where there exists a skin absorption hazard that creates the potential for IDLH conditions totally encapsulating chemical protective suits meeting the Level A requirements as defined by OSHA 1910.120 Appendix B are to be worn. As site conditions change the selection of PPE shall also change. Greater risks will require higher levels of PPE, and decreases in risks or hazard levels will warrant a decrease in PPE levels. The selection and maintenance of PPE is to be determined by the guidelines of the Company s PPE policy (S150) and the sitespecific safety and health plan. At a minimum the PPE plan must discuss:
PAGE 6 OF 10 1. PPE selection based on the hazards at the site 2. Use and limitations of the PPE selected 3. Duration of work activities 4. Storage and maintenance of PPE 5. Decontamination and disposal procedures for used PPE 6. Fitting and training for proper PPE use 7. Donning and doffing procedures 8. Inspection procedures to be completed before, during and after use 9. An evaluation of the effectiveness of the PPE program 10. PPE limitations due to temperatures, work stresses and other employee medical concerns Post-Emergency Response Operations The Company does not conduct post emergency response operations, instead contracting such work to qualified clean-up professionals. TRAINING General Prior to beginning work at any site where there is a significant potential for the catastrophic release of hazardous or toxic chemicals the Company requires that all employees receive sufficient training. This training shall be based on the duties and functions to which they will be assigned and the area in which they will conduct work operations. This training is to include: 1. Names of personnel responsible for site Safety and Health and their alternates 2. Safety, health and other significant hazards present at the site 3. Proper use of personal protective equipment 4. Work practices to be followed to minimize hazards 5. Proper use of engineering controls and equipment at the site 6. Medical surveillance requirements including symptoms of overexposures to site hazards 7. Decontamination procedures, the content of the emergency response plan, confined space entry procedures and the Company s spill containment program for the site. Job Specific Training Workers who are on site only occasionally for a specific limited task and who are unlikely to be exposed to hazards in excess of the PEL shall receive a minimum of 24 hours instruction off site and work for one day under the direct supervision of a trained, experienced supervisor. Workers who are regularly on site in areas that have been monitored and in which it has been determined that the exposure levels are below the PEL without the use of a respirator and there are no health hazards and there is no possibility of an emergency developing shall receive 24 hours of instruction off site and work for one day under the direct supervision of a trained, experienced supervisor.
PAGE 7 OF 10 Workers who have received 24 hours of training and are to fill positions requiring 40 hours of training, including those who will be required to use respirators, must complete the additional 16 hours of offsite training and two days of supervised work required. General workers who will be exposed or potentially exposed to hazardous substances or health hazards must receive 40 hours of instruction off site and work a minimum of three days under the direct supervision of a trained experienced supervisor. On-site management and supervisors who are directly responsible for or directly supervise employees engaged in hazardous waste operations must complete 40 hours of off site training and three days work under the direct supervision of a trained, experienced instructor. They must also complete an additional 8 hours of site-specific training including the employer s: Safety and health program Safety and health employee training program Personal protective equipment program Spill containment program Health hazard monitoring procedures and techniques Managers and supervisors who will only be directly responsible for employees who need 24 hour training are only required to complete the 24 hour training program and one day of direct supervision in addition to the 8 hour training program listed above. Upon completion of the OSHA 24 or 40 hour training course employees are to be certified by the trainer. A written certificate shall be issued to those who have completed the course, and no employee who lacks this certification shall be allowed to work at a site where hazardous waste operations are in effect. Employees who are required to have completed the 40 hour course must receive annual refresher courses of 8 hours, preferably covering any incidents that occurred in the past year. If an employee has sufficient previous equivalent training or certification the Company is not required to complete the training process again however, the employee must receive appropriate site-specific training before beginning a job at a new site. Emergency Response Training First Responder Awareness Level First responders at the awareness level are those employees who are likely to witness or discover the release of a hazardous substance and have the training to notify the appropriate authorities of the situation. They do not have the training to begin a control operation. Their training is to include: 1. Understanding what hazardous substances are and what risks they may pose in an emergency 2. Knowledge of the potential outcomes of an emergency situation involving hazardous substances 3. Ability to recognize hazardous substances in case of emergency 4. To the extent that is feasible: the ability to identify the hazardous substances present at the site 5. An understanding of the first responder at the awareness level s role in the Emergency Response Plan (site security and control, the DOT Emergency Response Guidebook) 6. An understanding of when help is needed and the proper way to notify the communications center First Responder Operations Level
PAGE 8 OF 10 First responders at the operations level are employees who have received sufficient training to begin responding to the release of a hazardous substance. They ensure that other employees are evacuated from the area and attempt to mitigate the effect of the release on property and the environment. They not to attempt to stop the release, they are to respond defensively from a safe distance in an attempt to control the release and limit exposures. They require 8 hours of training, which must be documented, including the training required of first responders at the awareness level as well as knowledge of: 1. Basic techniques for hazard and risk assessment 2. How to select and use the PPE provided to first responders at the operations level 3. Basic hazardous materials terminology 4. Control, containment and confinement operations using the resources and PPE at their disposal 5. Basic decontamination procedures 6. The standard operating and termination procedures relevant to their response zone Hazardous Materials Technician Hazardous materials technicians respond to a hazardous material release in order to attempt to stop the release. They are trained to approach the release site in an attempt to patch or otherwise stem the release. These employees are required to have a much higher level of training, a minimum of 24 hours which must be documented and which is to include the training required of a first responder at the operations level as well as: 1. How to implement the emergency response plan 2. The classification, verification and identification of known and unknown materials using field survey instruments and equipment 3. Ability to function in an assigned role in the ICS 4. Understanding of how to select and use the specialized chemical PPE issued to hazardous materials technicians 5. Operational understanding of hazard and risk assessment techniques 6. Advanced control, containment and confinement operations using the resources and PPE at their unit s disposal 7. Decontamination procedures and how to implement them 8. Understanding termination procedures relevant to their response zone 9. Basic toxicological and chemical behavior and terminology Hazardous Materials Specialist Hazardous materials specialists are advanced versions of hazardous materials technicians. They perform many of the same functions, but are required to have a more specific knowledge of the materials they may be called upon to contain. Hazardous materials specialists act as the site liaison with federal, state and local authorities regarding site activities. Hazardous materials specialists shall have at least 24 hours of training, which is to be documented, including the requirements for hazardous materials technicians as well as the competency to: 1. Implement the local emergency response plan 2. Complete the classification, identification and verification of known and unknown substances using advanced survey equipment and instruments 3. Know the state emergency response plan 4. Select and use proper specialized chemical PPE as provided to a hazardous materials specialist
PAGE 9 OF 10 5. Utilize advanced hazard and risk analysis techniques 6. Perform advanced control, containment and confinement operations using the resources and PPE at their unit s disposal 7. Define and implement decontamination procedures 8. Develop a site safety and control plan 9. Understand chemical, radiological and toxicological terminology and behavior On Scene Incident Commander An on scene incident commander is trained to take control of the scene after the incident progresses beyond the first responder awareness level. This person is required to receive 24 hours of training, which is to be documented, equal to the first responder operations level, and is also required to: 1. Have knowledge of and the ability to implement the employer s incident command system 2. Be capable of implementing the employer s emergency response plan 3. Be familiar with the hazards and risks of performing work in chemical protective clothing 4. Know how to implement the local emergency response plan 5. Be familiar with the state emergency response plan and the Federal Regional Response Team 6. Know proper decontamination procedures and their importance Instructor Training Instructors who teach any of the documented training listed above must have successfully passed a training course for teaching the subject that they taught or the training and/or academic credentials and instruction experience required to demonstration competent instructional skills as well as an understanding of the subject material they are to teach. Refresher Training Refresher training or competency testing for the documented training requirements listed above must be completed at least annually. The refresher training must be of sufficient duration and content to assure that the individuals maintain their competency. This training is to be documented. If testing is used to demonstrate competency then the method and results of this testing must also be recorded. MEDICAL SURVEILANCE Employees who are exposed to hazardous substances or health hazards more than 30 days per year, employees who are required to wear respirators more than 30 days per year and members of HAZMAT teams shall be included in a medical surveillance program. Medical surveillance shall occur: 1. Prior to assignment
PAGE 10 OF 10 2. At least once every 12 months unless a physician requests a longer period 3. At termination of employment of reassignment to an area that is not covered unless the employee has had an examination in the last 6 months 4. As soon as possible if an employee observes symptoms of overexposure or is exposed to levels above the PEL during an emergency situation 5. More frequently if determined necessary by the attending physician Employees who may have been overexposed to hazardous substances or health hazards from an emergency response or hazardous waste operation are required to see a physician as soon as possible after the incident and as many times as the physician requires for follow-up observations. Medical examinations are to be conducted by a licensed physician at no cost to the affected employee and at a reasonable time and place. The Company shall provide the consulting physician the following information: 1. A copy of OSHA 1910.120 and its appendices 2. Description of the employee s duties as they relater to the employee s exposure 3. Anticipated or observed exposure levels for the employee 4. Description of the personal protective equipment used 5. Information from previous medical exams that are not readily available to the physician 6. Information required by OSHA 1910.134 The Company shall obtain and furnish the employee with a copy of the physician s opinion including: 1. Whether the employee has any detected medical problem that would place the employee at increased risk to their health due to the involvement in hazardous waste response or operations or respirator use 2. Any recommendations regarding work limitations 3. Results of the medical examination and tests 4. A statement that the employee has been informed of the results of the medical examination and a synopsis of any medical issues which require further examination or treatment 5. The written opinion obtained by the employer shall not contain specific findings or diagnoses not related to occupational exposures Records shall be kept of all medical monitoring for the period specified by OSHA 1910.1020. These records shall include at a minimum: 1. The name and social security number of the employee 2. Physicians opinions and recommendations and the results of any examinations and tests performed 3. Any medical complaints the employee had regarding exposure to hazardous substances 4. A copy of the information provided to the examining physician except for the OSHA standards