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OSC H&S Training for 2014

Andrew Smith

on 18 January 2015

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Transcript of HAZWOPER Jeopardy

For OSHA recordkeeping purposes, the local SHEMP Manager must document and report work-related injuries and illnesses that result in one or more of the following conditions:

• Death.

• One or more days away from work.

• Restricted work activity or job transfer (e.g., light duty).

• Medical treatment beyond first aid (For more...)

• Loss of consciousness.

• Any significant injury or illness diagnosed by a licensed health care professional.
• Any case involving cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum.

• Any needlestick injury or cut from a sharp object that is contaminated with another person’s blood or other potentially infectious material.

• Any case requiring an employee to be medically removed from work under the medical surveillance requirements of an OSHA standard (e.g., benzene, cadmium, formaldehyde, lead, and methylene chloride).

• Tuberculosis infection as evidenced by a positive skin test or diagnosis by a licensed health care professional after exposure to a known case of active tuberculosis.

• An employee’s hearing test reveals that the employee has experienced a standard threshold shift (STS) in hearing in one or both ears and the employee’s total hearing level is 25 decibels or more above audiometric zero in the same ear(s) as the STS.

Site Control Measures
Mixed Bag
10 Point - Answer:
Level D vis-a-vis Level A/B
Site work zones at level D sites are often less defined or "soft",
Workers become complacent or lax and start to treat the site as a construction zone and not a HAZWOPER site.
Confusion about where allowable to eat, smoke, or chewing gum.
Visitors may wander where they shouldn't.
OSCs need to put PRP contractor on notice early on to head this issue off. EPA has a higher standard to follow.
Support zone - May call for PPE due to heavy equipment and trucks.
Why a problem?
Poor adherence to use of PPE is visible by all. This can create awkward questions from the public and the press (and your own attorney).
You aren't following proper regulatory practices and thus run into issues with auditor.
It may actually be unsafe!
50 points
Site Control Measures for 50 points:

You have an asbestos site at an upscale residential neighborhood. Some residents still live there. Cleanup consists of handpicking ACM. It is dry so high potential for dust.

You have been paying attention in your annual H&S refresher and know that your HASP must discuss site control measures and decontamination procedures. What might you suggest for this site?
50 points answer:

Suggested ideas but ask Dan and Cathy:

Level-C with dry decon.
Use disposable outer clothing and dispose of at end of work shift.
Agree on soft-exclusion zones. i.e., exclusion zone in place while workers are active and at a set distance from workers.
Designate an area for deconing
Have on site handwashing stations
Have on site showers
Have boot scrapers
Be alert to workers transporting asbestos off-site contaminating vehicle and hotel room.
Procedures protect workers and public from real hazards as well as perceived hazards (aka, political deconning)

Decon for 50 points:

START comes back from a level-A response. The expensive CPC has gone through a gross decon at the site but now needs to go through a final decon before being stored away.

Joe the Contractor already has in mind four general decontamination approaches he will take depending on the physical/chemical characteristic of the contaminant.
What might these four contaminant characteristics be?

Recommended by Trellchem (Level-A CPC manufacturer).
50 points
50 points - Answer:

1) volatile - hang and air dry in warm temp
2) Soluble/reacts with water - e.g., acids/alkali; neutralize acid with baking soda and alkali with vinegar. Then rinse with warm water and detergent.
3) Insoluble with water - e.g., diesel/crude oil; Remove with solvent. Rinse with water/detergent;
4) Chemical warfare agents and biologicals - Soak with water/30% calcium hypochlorite (aka, chloride of lime or HTH [High Test Hypochlorite] tablets) slurry for 15 minutes. Rinse with water/detergent.
Decon for 10 points:

Decon tries to prevent what two things from happening?

Hint: 1) Decon of level-A suit in CRZ
2) Washing down dump truck tires or scraping boots
10 points - Answer:

1) Prevent contamination of personnel
2) Tracking contamination off site.
10 points
10 Points - Regulatory:

You need a dozer operator on scene to provide immediate emergency support work. The only, problem is the operator has not had HAZWOPER training. Can you still use this operator?
10 Point - Answer


10 points
For 30 Points: Respiratory Protection

An APR must be worn when the concentration of contaminant of concern is great than what limit?
30 points - Answer: PEL or REL
20 Points - Answer:

In the HASP; PPE Section
For 40 Points: PPE

PPE is the last line of defense against hazardous substances and safety and health hazards. Name four control options in order of precedence that must be implemented, if feasible, before PPE.
40 points - Answer:

1st: Hazard Elimination/Reduction
2nd: Engineering controls
3rd: Work practices
4th: Administrative controls
5th: PPE
A PPE program should include training and awareness that go over what elements [29 CFR 1910.120 (g)]?
List Site Control Measures you might discuss in your HASP?
10 point - Answer:
• Site work zones
• site communications including alerting means for emergencies
• the ‘‘buddy system’’
• the site map
• map to nearest medical assistance
• any standard operating procedures or safe work practices determined for this site
10 Point
20 Points
3 Points
40 Points
50 Points
40 points - Answer:
30 point answer:

Exclusion zone needs more buffer
Site Control Measures for 40 points:

At a typical EPA-lead cleanup (e.g., a drum site) with the typical START/ERRS contractor configuration,
who should address the ERP in their HASP?

Decon for 20 points:
20 point answer:

20 Points
30 points
40 Points
Not Decon for 20 points:

OSC Sibley decides he is going to conduct an overflight at an oil spill. After this particular flight what form is he going to have to fill out?
Decon for 30 points:

Name four common types of responses we do where dry decon is appropriate.

Bonus: Why is dry decon preferable to wet decon?
30 points - Answer:
1) Mercury
2) Asbestos
3) Drums
4) Oil spills

Bonus: Disposal costs are less
List things you would need to consider in a decon plan:

Bonus: A decon plan is part of what other plan?
40 points - Answer:

Determine the exclusion zones
Determine the number and layout of decontamination stations and equipment needed;
Determine appropriate decontamination methods;
Establish procedures to prevent contamination of clean areas;
Establish methods and procedures to minimize worker contact with contaminants during removal of personal protective clothing and PPE
Establish methods for disposing of clothing and equipment that are not completely decontaminated.

Bonus: The HASP
20 points Regulations:

What's the General Duty Clause all about?
20 Points - Answer

A catch-all regulation - You can be cited even if there is no standard.

The general duty provisions are used in inspections only where there are no specific standards applicable to the particular hazard involved. Any recognized hazard created in part by a condition not covered by a standard may be cited under the general duty clause.[2] A hazard is recognized if it is a condition that is (a) of a common knowledge or general recognition in the particular industry in which it occurred, and (b) detectable (1) by means of the senses (sight, smell, touch, and hearing), or (2) is such wide, general recognition as a hazard in the industry that even if it is not detectable by means of the senses, there are generally known and accepted tests for its existence which should are generally known to the employer. In addition, "Voluntary Standards" also meet the preceding criteria for identifying a hazard. Citations based on the general duty clause are limited to alleged serious violations (including willful and/or repeated violations which would otherwise qualify as serious violations, except for their willful or repeated nature).
20 points
30 Points - HAZWOPER:

HAZWOPER is a Performance-Based Standard. What does that mean?
3 points
For 40 points:
20 points
3 points
40 points answer
1) 112(r) - RMP
2) EPCRA - LEPCs develop community ERP
4 Points
50 points
50 points - Answer:

1) “Hazardous substance” under HAZWOPER references the DOT’s definition of “hazardous materials” under 49 CFR 171.18. - "OSHA is not amending its definition for 'hazardous substance' to include the petroleum exclusion reference by some of the commenters." [54 FR 9302]

2) § 300.150 Worker health and safety.
(a) Response actions under the NCP will comply with the provisions for response action worker safety and health in 29 CFR 1910.120
10 Point
10 Points - Mixed Bag:

Which OSC recently had a response in which the pump truck driver had HAZWOPER training but failed to mention no 8-hour refresher?
10 Point - Answer:
OSC Dan Heister
(Response Critque)
20 Points Mixed Bag:

What is a "Significant Exposure" and in which aspect of our H&S Program do we apply this term?
20 Points - Answer:

For the purposes of the Injury, Illness, and Exposure Reporting chapter, significant exposure means a known exposure:

• To a chemical, physical, biological, or ergonomic hazard that exceeds a limit (PEL, TLV, REL, etc.)
• That causes clinical signs or symptoms associated with a hazard in the workplace.
• From an event in the workplace with the likelihood of hazardous exposure (e.g., chemical spill, explosion).
• To the eye, mouth, other mucous membranes, non-intact skin, or parenteral contact with blood or other materials potentially infected with bloodborne pathogens.
• To an infectious disease.
• That requires follow-up medical evaluation and/or treatment (e.g., known exposure to anthrax).
30 Points - Answer: 1) Driving to the site 2) Earl Liverman
20 Points
OSHA & EPA 301 Injury, Illness and Near Miss Report
(within 24-hours)
Supervisor works with employee. SHEMP Manager evaluates within 2 weeks.
50 Points - Mixed Bag:

What is the purpose of the Informational Program?
Where can you find our Informational Program?
List some ways we can substantively implement it?
50 points - Answer:
1) To inform our contractors the nature, level and degree of exposure likely as a result of participation in a hazardous waste cleanup. This includes telling them about emergency response procedures (found in ERP), potential fire, explosion, health, safety, or other hazards. [HAZWOPER (b)(1)(iv) and (i)]

2) In the Safety and Health Program SOG.

3) Tell the contractor
Site history section of HASP
Tailgate safety briefing

Note: This requirement in HAZWOPER preceded the regulation for hazard communication program which is industry wide.
50 Points Mixed Bag
Shamelessly stolen from adam taylor - twitter @2footgiraffe
50 points - Answer:

• 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 procedures prior to, during, and after use
• evaluation of the effectiveness of the PPE program
• limitations during temperature extremes, heat stress, and other appropriate medical considerations

30 point answer:
Performance-based standards don’t tell you how to meet the standard.

We are allowed to determine how the program requirements will be met based on our needs and how we wish to go about meeting the requirements.

We can do whatever we think is best to comply as long as we meet the intent of the regulations. Some regulations have more specific constraints than others, but for the most part, we are given a reasonable amount of latitude as to HOW we are going to achieve compliance.

Regulatory models
Prescriptive-based - Speed limit
Management-based _RMP
Performance-based - HAZWOPER
20 points - Answer:

OSHA & EPA 301 Injury, Illness and Near Miss Report
(within 24-hours)
Supervisor works with employee. SHEMP Manager evaluates within 2 weeks.
What one word describes a very important consideration in a decon plan?
Hint: An ounce of it is worth a pound of cure.
A removal site is being investigated. What is likely the biggest hazard with this site?
Go to.....
SCBA if ppm > MUC
APR if PEL or REL < ppm < MUC
Voluntary if ppm < PEL or REL

IDLH = 85 ppm; REL = 1 ppm; PEL = 2 ppm
MUC = 1 ppm X 50 X 0.5 = 25 ppm

IDLH = 50 ppm; REL and PEL = 0.3 ppm
MUC = 0.3 ppm X 50 X 0.5 = 7.5 ppm

MUC = (PEL or REL) X (APF) X (EPA fudge factor)

Maximum Use Concentration (MUC)
Assigned Protection Factor (APF)
Immediately Dangerous to Life and Health (IDLH)
Permissible Exposure Limit (PEL)
Recommended Exposure Limit (REL)

At a HAZWOPER site, where does one document the PPE that will be worn?
1) CERCLA has oil exclusion clause
2) HAZWOPER is for hazardous waste operations

then why do we comply with HAZWOPER requirements at an oil spill?
ERPs are called for under 4 different regulatory settings. What are they?
40 Points - Mixed Bag:
OSC Neo goes out with CID to investigate a site and this happens:
What form is OSC Neo supposed to fill out?
What Is First Aid?

OSHA considers the following types of treatment to be first aid:

• Using non-prescription medications at non-prescription strength.
• Administering tetanus immunizations.
• Cleaning, flushing, or soaking wounds on the skin surface.
• Using wound coverings (such as bandages, Band-Aids®, gauze pads, etc.) or using Steri-StripsTM or butterfly bandages.
• Using hot or cold therapy.
• Using any totally non-rigid means of support (such as elastic bandages, wraps, or non-rigid back belts).
• Using temporary immobilization devices while transporting an accident victim (slings, splints, neck collars, or back boards).
• Drilling a fingernail or toenail to relieve pressure, or draining fluids from blisters.
• Using eye patches.
• Using simple irrigation or a cotton swab to remove foreign bodies not embedded in or adhered to the eye.
• Using irrigation, tweezers, a cotton swab or other simple means to remove splinters or foreign material from areas other than the eye.
• Using finger guards.
• Using massages.
• Drinking fluids to relieve heat stress.

First aid cases are not considered OSHA recordable injuries or illnesses.

Provide examples of issues adhering to H&S procedures at level-D sites that we might not have at level A/B sites.
Alconox MSDS -
Sodium Dodecyclbenzenesulfonate
Sodium Carbonate
Tetrasodium Pyrophosphate
Sodium Phosphate
Sodium Carbonate
Site Control for 30 points:

What's wrong with this setup?
OSHA Interpretation Nov 19, 1991 - "In general, the standard [HAZWOPER] applies to all operations described in the scope, 1910.120(a), and as described above, unless the employer can demonstrate that the operation does not involve employee exposure, or reasonable likelihood of exposure to safety and/or health hazards. Thus, if potential for exposure is extremely unlikely the standard would not apply".

"Yes, employees working on uncontrolled hazardous waste sites are covered whether the work they do is cleanup or non cleanup activity. However, employees are not covered if they work exclusively within uncontaminated areas of the hazardous waste site and are not exposed to health or safety hazards related to hazardous waste operations".

3. The training paragraph (e) changes wording not used or defined anywhere in the standard and uses "working on site" instead of performing cleanup, corrective actions, or voluntary cleanup activities. What is the definition of "working on site"?

"All employees who work on a hazardous waste site, which is covered by 29 CFR 1910.120, require training. Paragraph (e) recognizes that the risk of exposure to safety and health hazards exists in varying degrees. Your inquiry does not give sufficient details for a more specific response, however, it appears that the jobs you listed would typically fall under paragraph (e)(3)(ii). This subsection is for workers on site only occasionally, for a specific and limited task (as opposed to on site daily). In which case, the standard requires a minimum of 24 hours of off site training, and 8 hours of on-the-job training. The standard anticipates that this category of workers would not be exposed to chemicals above the permissible exposure limits (PELs), and would not be wearing respiratory protection".
No risk of exposure - Not subject to HAZWOPER
No risk of exposure above PEL - 24-hr off site/8 hr OJT
Employees who "work on site"
5. Training Requirements.

The interim final rule does not have a provision regarding training of less than 40 hours for employees involved in activities at cleanup sites. Prior to the publication of the final rule, OSHA has stated that for non-cleanup activities at designated cleanup sites the determination of the amount of training necessary for the workers to safely perform their job duties will be made on a case-by-case basis. As you are aware, the final standard addresses the issue of when less than 40 hours of training may be appropriate. It does not, however, provide for less than 24 hours of training.

In general, OSHA will be enforcing the need for a minimum of 24 hours of training regardless of the nature of the job. There may be isolated cases where OSHA's variance procedures may be appropriate or where OSHA would determine that a situation warrants a deminimis violation. (Note: Depending on the job duties of the workers involved in emergency response, less than 24 hours of training is allowable under the standard.)
1910.120 (q)(4) Skilled support personnel. Personnel, not necessarily an employer’s own employees, who are skilled in the operation of certain equipment, such as mechanized earth moving or digging equipment or crane and hoisting equipment, and who are needed temporarily to perform immediate emergency support work that cannot reasonably be performed in a timely fashion by an employer’s own employees, and who will be or may be exposed to the hazards at an emergency response scene, are not required to meet the training required in this paragraph for the employer’s regular employees. However, these personnel shall be given an initial briefing at the site prior to their participation in any emergency response. The initial briefing shall include instruction in the wearing of appropriate personal protective equipment, what chemical hazards are involved, and what duties are to be performed. All other appropriate safety and health precautions provided to the employer’s own employees shall be used to assure the safety and health of these personnel.
Mr. Acrylonitrile (aka Dan the Man) is at another AN response. A new START has been foisted upon him for this response, and aiming to impress eagerly proposes the use of a PID. While Dan does not usually suffer fools gladly, he instead sagely advises the young up-START to confirm the IP of AN. Why would he do that?

IP of AN = 10.75 eV
PID lamp energy is 10.6 eV

Other lamps are 9.5 eV and 11.7 eV
CAS 107-13-1

Engineering Control - Forced air for hazardous air environment
Administrative controls - 5 mph for fork lift
Work practices - frequent breaks and lots of fluids
Full transcript