OHSA 3 DB V

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit V Upon completion of this unit, students should be able to:

5. Describe the central tenets of a materials spill response plan. 5.1 Compare risk assessments of two hazardous materials at a workplace. 5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a

spill response program. Required Unit Resources Chapter 2: Hazardous Material Spills and Response, pp. 59–79 In order to access the following resources, click the links below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous

materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.120

Read pages 30–36 in the resource below. Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency

response (OSHA Document No. 3114-07R). U.S. Department of Labor. https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf

The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations. National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental

Protection Agency. https://www.epa.gov/sites/production/files/2014- 09/documents/cleannrt10_12_distiller_complete.pdf

Emergency service personnel can face many unique and dangerous situations, many of which may be unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations and best practices for protecting these workers. Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders

during treatment and transport of victims of hazardous substance releases (OSHA Document No. 3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS- respondersSM.pdf

Unit Lesson

Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation

The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites; certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency

UNIT V STUDY GUIDE Establishing and Maintaining a Hazardous Spill Response Program

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

responses to hazardous materials, which are covered in section (q) of the standard. The first step in compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by OSHA to be included in the EAP:

• pre-emergency planning and coordination with outside parties; • personnel roles, lines of authority, training, and communication; • emergency recognition and prevention; • safe distances and places of refuge; • site security and control; • evacuation routes and procedures; • decontamination; • emergency medical treatment procedures; • emergency alerting and response procedures; • critiques of response and follow-up; and • PPE and emergency equipment (OSHA, 1970).

Hazard Assessment

As you can see, developing a written EAP is quite detailed and takes time. One project that must be performed prior to developing the EAP is determining what hazardous materials may be present that would require an emergency spill response. The first step is typically conducting a hazard assessment. This process is used to identify the hazardous materials you have present at a site as well as the hazardous materials that are generated by the processes in your workplace. Remember that hazardous wastes are simply hazardous materials that are discarded. The presumption here is that you understand the various definitions of hazardous material. If not, the Environmental Protection Agency (EPA), OSHA, and the U.S. Department of Transportation (DOT) require the publishing of definitions and lists of substances that are considered hazardous. Perhaps the best source of information about any chemical is its safety data sheet (SDS). The term that is generally applied to the process of identifying hazards in a workplace is a job hazard analysis (JHA). The process is important enough that OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to use a specific method to identify hazards in the workplace. While there are many commercially available programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a

Two airmen inventory hazardous materials. (Wright, 2009)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

checklist to detail steps required for processes performed at a workplace, and then determine which hazards are associated with each step. An example of a JHA worksheet from the booklet is shown below.

Once you know what hazards are present in the workplace, you can determine what would happen if any of these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be adverse effects on people, property, or the environment? You then need to decide the probability of that spill or release happening. This process is commonly called a risk assessment. The risk assessment process can be used to rate the risks associated with hazardous materials at a workplace. This information can be valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix. There are many risk assessment matrices available. The matrix below was created just for this lesson.

Probability Very Likely

Likely Possible Unlikely Very Unlikely

Severity Rating

Health Outcome

5 4 3 2 1

5 Death or Permanent Total Disability

25 20 15 10 5

4 Permanent or Partial Disability

20 16 12 8 4

3 Injury or Illness With Lost Workdays

15 12 9 6 3

2 Injury or Illness With No Lost Workdays

10 8 6 4 2

1 First Aid Only or No Treatment

5 4 3 2 1

(OSHA, 2002)

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space. The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25, while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks associated with the release of compounds that are more similar in toxicity. Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill and the probability of such an event happening). The model uses the following seven events:

1. stressing event occurs (thermal, chemical, mechanical, human); 2. container breach occurs (detonating, rapid release, leak); 3. hazardous materials or energy escapes; 4. hazardous material engulfs danger zone (dispersion, path, pattern, distance); 5. hazardous material or energy impinges on receptors (transient, lingering, permanent); 6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);

and 7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).

Much of the information required for any risk assessment can be obtained from the SDS for that material or the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could result in a release. The model can also point to preventative measures. Another extremely important part of the EAP is to determine which personnel need to be trained on their responsibilities under the plan and how much training is required. Personnel who are expected to respond to a spill must have training, but do not forget that there may be employees whose job in an emergency is to simply evacuate safely. Do they know when, how, and where to evacuate? This training also needs to be conducted. For the first responders, those responsible for cleanup, and those directing the response and cleanup operations, various levels of training are prescribed in OSHA’s HAZWOPER Standard 29 Code of Federal Regulations (CFR) §1910.120(q). Be sure to check with state and local agencies for additional requirements. The different levels of response and the duration of the initial training for each level are summarized below.

Response Level Initial Training Duration First Responder Awareness Not Specified (Sufficient Training) First Responder Operations 8 Hours Hazardous Materials Technician 24 Hours Hazardous Materials Specialist 24 + Specialty Training On-Scene Incident Commander 24 Hours + ICS Training

(OSHA, 1970)

Emergency response exercise held in Nevada (National Nuclear Security Administration, n.d.)

OSH 2303, Hazardous Materials Safety 5

UNIT x STUDY GUIDE Title

Each of the training classes is required to cover specific rubrics designed to allow the responders to perform their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of the training. Workers in each of the categories must also have annual refresher training or demonstrate competency in each rubric area again. The regulation does not specify the length of the annual refresher training but says the training must provide enough content and last long enough so the workers can maintain their competency. Annual refresher training has traditionally been 8 hours in length. Another important step is to make sure that the correct equipment (including PPE) is present at the site. A spill response plan will not be effective if the PPE and other equipment available to responders is inadequate. The type and levels of equipment and PPE will vary depending on the hazardous materials that are present and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials (e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29 CFR §1910.134. The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs and then everyone frantically tries to remember who is supposed to do what, although this is often the case. Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the most effective response. When determining the best frequency for undertaking these exercises, consider that personnel and situations change often. Sports teams practice between games, right? Considering the dangers inherent in spill response, your team deserves no less.

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Engineers. National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.

http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous

materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.120

Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).

U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.

http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg

OSH 2303, Hazardous Materials Safety 6

UNIT x STUDY GUIDE Title

Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. In a previous unit, you were introduced to the software program that the Occupational Safety and Health Administration (OSHA) published to assist employers with developing a health and safety program. The software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0 webpage. If you did not already, download the software, and review the chapters on the emergency response plan and decontamination. Compare the guidelines in the software to the company where you currently work or a location with which you are familiar. How does the response plan at the company compare with the guidelines in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write your thoughts down in a personal journal.

OSH 2303, Hazardous Materials Safety 1

Course Learning Outcomes for Unit V Upon completion of this unit, students should be able to:

5. Describe the central tenets of a materials spill response plan. 5.1 Compare risk assessments of two hazardous materials at a workplace. 5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a

spill response program. Required Unit Resources Chapter 2: Hazardous Material Spills and Response, pp. 59–79 In order to access the following resources, click the links below. Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous

materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.120

Read pages 30–36 in the resource below. Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency

response (OSHA Document No. 3114-07R). U.S. Department of Labor. https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf

The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations. National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental

Protection Agency. https://www.epa.gov/sites/production/files/2014- 09/documents/cleannrt10_12_distiller_complete.pdf

Emergency service personnel can face many unique and dangerous situations, many of which may be unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations and best practices for protecting these workers. Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders

during treatment and transport of victims of hazardous substance releases (OSHA Document No. 3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS- respondersSM.pdf

Unit Lesson

Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation

The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites; certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency

UNIT V STUDY GUIDE Establishing and Maintaining a Hazardous Spill Response Program

OSH 2303, Hazardous Materials Safety 2

UNIT x STUDY GUIDE Title

responses to hazardous materials, which are covered in section (q) of the standard. The first step in compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by OSHA to be included in the EAP:

• pre-emergency planning and coordination with outside parties; • personnel roles, lines of authority, training, and communication; • emergency recognition and prevention; • safe distances and places of refuge; • site security and control; • evacuation routes and procedures; • decontamination; • emergency medical treatment procedures; • emergency alerting and response procedures; • critiques of response and follow-up; and • PPE and emergency equipment (OSHA, 1970).

Hazard Assessment

As you can see, developing a written EAP is quite detailed and takes time. One project that must be performed prior to developing the EAP is determining what hazardous materials may be present that would require an emergency spill response. The first step is typically conducting a hazard assessment. This process is used to identify the hazardous materials you have present at a site as well as the hazardous materials that are generated by the processes in your workplace. Remember that hazardous wastes are simply hazardous materials that are discarded. The presumption here is that you understand the various definitions of hazardous material. If not, the Environmental Protection Agency (EPA), OSHA, and the U.S. Department of Transportation (DOT) require the publishing of definitions and lists of substances that are considered hazardous. Perhaps the best source of information about any chemical is its safety data sheet (SDS). The term that is generally applied to the process of identifying hazards in a workplace is a job hazard analysis (JHA). The process is important enough that OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to use a specific method to identify hazards in the workplace. While there are many commercially available programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a

Two airmen inventory hazardous materials. (Wright, 2009)

OSH 2303, Hazardous Materials Safety 3

UNIT x STUDY GUIDE Title

checklist to detail steps required for processes performed at a workplace, and then determine which hazards are associated with each step. An example of a JHA worksheet from the booklet is shown below.

Once you know what hazards are present in the workplace, you can determine what would happen if any of these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be adverse effects on people, property, or the environment? You then need to decide the probability of that spill or release happening. This process is commonly called a risk assessment. The risk assessment process can be used to rate the risks associated with hazardous materials at a workplace. This information can be valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix. There are many risk assessment matrices available. The matrix below was created just for this lesson.

Probability Very Likely

Likely Possible Unlikely Very Unlikely

Severity Rating

Health Outcome

5 4 3 2 1

5 Death or Permanent Total Disability

25 20 15 10 5

4 Permanent or Partial Disability

20 16 12 8 4

3 Injury or Illness With Lost Workdays

15 12 9 6 3

2 Injury or Illness With No Lost Workdays

10 8 6 4 2

1 First Aid Only or No Treatment

5 4 3 2 1

(OSHA, 2002)

OSH 2303, Hazardous Materials Safety 4

UNIT x STUDY GUIDE Title

An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space. The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25, while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks associated with the release of compounds that are more similar in toxicity. Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill and the probability of such an event happening). The model uses the following seven events:

1. stressing event occurs (thermal, chemical, mechanical, human); 2. container breach occurs (detonating, rapid release, leak); 3. hazardous materials or energy escapes; 4. hazardous material engulfs danger zone (dispersion, path, pattern, distance); 5. hazardous material or energy impinges on receptors (transient, lingering, permanent); 6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);

and 7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).

Much of the information required for any risk assessment can be obtained from the SDS for that material or the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could result in a release. The model can also point to preventative measures. Another extremely important part of the EAP is to determine which personnel need to be trained on their responsibilities under the plan and how much training is required. Personnel who are expected to respond to a spill must have training, but do not forget that there may be employees whose job in an emergency is to simply evacuate safely. Do they know when, how, and where to evacuate? This training also needs to be conducted. For the first responders, those responsible for cleanup, and those directing the response and cleanup operations, various levels of training are prescribed in OSHA’s HAZWOPER Standard 29 Code of Federal Regulations (CFR) §1910.120(q). Be sure to check with state and local agencies for additional requirements. The different levels of response and the duration of the initial training for each level are summarized below.

Response Level Initial Training Duration First Responder Awareness Not Specified (Sufficient Training) First Responder Operations 8 Hours Hazardous Materials Technician 24 Hours Hazardous Materials Specialist 24 + Specialty Training On-Scene Incident Commander 24 Hours + ICS Training

(OSHA, 1970)

Emergency response exercise held in Nevada (National Nuclear Security Administration, n.d.)

OSH 2303, Hazardous Materials Safety 5

UNIT x STUDY GUIDE Title

Each of the training classes is required to cover specific rubrics designed to allow the responders to perform their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of the training. Workers in each of the categories must also have annual refresher training or demonstrate competency in each rubric area again. The regulation does not specify the length of the annual refresher training but says the training must provide enough content and last long enough so the workers can maintain their competency. Annual refresher training has traditionally been 8 hours in length. Another important step is to make sure that the correct equipment (including PPE) is present at the site. A spill response plan will not be effective if the PPE and other equipment available to responders is inadequate. The type and levels of equipment and PPE will vary depending on the hazardous materials that are present and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials (e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29 CFR §1910.134. The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs and then everyone frantically tries to remember who is supposed to do what, although this is often the case. Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the most effective response. When determining the best frequency for undertaking these exercises, consider that personnel and situations change often. Sports teams practice between games, right? Considering the dangers inherent in spill response, your team deserves no less.

References Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of

Safety Engineers. National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.

http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous

materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120). United States Department of Labor. https://www.osha.gov/laws- regs/regulations/standardnumber/1910/1910.120

Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).

U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.

http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg

OSH 2303, Hazardous Materials Safety 6

UNIT x STUDY GUIDE Title

Learning Activities (Nongraded) Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit them. If you have questions, contact your instructor for further guidance and information. In a previous unit, you were introduced to the software program that the Occupational Safety and Health Administration (OSHA) published to assist employers with developing a health and safety program. The software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0 webpage. If you did not already, download the software, and review the chapters on the emergency response plan and decontamination. Compare the guidelines in the software to the company where you currently work or a location with which you are familiar. How does the response plan at the company compare with the guidelines in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write your thoughts down in a personal journal.