| DIRECTIVE NUMBER: CPL 2-2.59A | EFFECTIVE DATE: April 24, 1998 |
| SUBJECT: Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases |
| Purpose: | This
instruction establishes policies and provides clarification to ensure uniform enforcement of paragraph (q) of the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), 29 CFR 1910.120 and 1926.65, which covers emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. |
| Scope: | This instruction applies OSHA-wide. |
| References: | 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response. 29 CFR 1926.65 Hazardous Waste Operations and Emergency Response OSHA Instruction CPL 2.94, OSHA Responses to Significant Events of Potentially Catastrophic Consequences. OSHA Instruction CPL 2.103, Field Inspection Reference Manual. OSHA Instruction TED 1.15, OSHA Technical Manual. |
| Cancellations: | OSHA Instruction CPL 2-2.59 dated October 25, 1993 is canceled. |
| State Impact: | This instruction describes a Federal Program Change that affects State Programs. See Paragraph VI. |
| Action Offices: | OSHA Regional and Area Offices |
| Originating Office: | Office of Health Compliance Assistance (OHCA) |
| Contact: | OHCA (202-219-8036) Room N-3467 200 Constitution Avenue, NW Washington, DC 20210 |
By and Under the Authority of
Charles Jeffress
Assistant Secretary
ABSTRACT
TABLE OF CONTENTS
APPENDIX A: PROCEDURES FOR REVIEWING AN EMERGENCY RESPONSE PLAN
APPENDIX B: GUIDANCE FOR 29 CFR 1910.120 EMERGENCY RESPONSE COMPLIANCE INSPECTION
APPENDIX C: INSPECTION PROCEDURES AT ONGOING OR RECENTLY COMPLETED EMERGENCY RESPONSE OPERATIONS
APPENDIX D: HAZWOPER INTERPRETIVE GUIDANCE
APPENDIX E: RELEASES OF HAZARDOUS SUBSTANCES THAT REQUIRE AN EMERGENCY RESPONSE
APPENDIX G: LIST OF ACRONYMS IN THIS DOCUMENT
APPENDIX H: REFERENCE MATERIALS FOR HAZWOPER
NOTE: In order to effectively enforce safety and health standards, guidance to compliance staff is necessary. Therefore, although adoption of this instruction is not required, States are expected to have standards, enforcement policies and procedures which are at least as effective as those of Federal OSHA.
(a) Where respiratory protection will be necessary, the CSHO shall adhere to the guidance set forth in the OSHA Technical Manual.
(a) Whenever CSHO's wear SCBA, a buddy system shall be employed wherein each CSHO who enters a danger area is accounted for by another identically equipped CSHO, who must remain in a safe location as a standby to assist in emergency rescue and decontamination if necessary. Two CSHOs, at a minimum, shall comprise a team to enter into the danger area while their respective buddies remain in a safe location.
(b) Appropriately equipped and trained personnel other than CSHOs (e.g., EPA personnel) may be substituted for the required number of CSHOs under the buddy system.
PROCEDURES FOR REVIEWING AN EMERGENCY RESPONSE PLAN
(See Appendix B for audit guidelines or self-audit.)
The function of this appendix is to present a thorough discussion of the required elements of an emergency response plan as required in 1910.120(q)(2), and to enable adequate technical review of emergency response plans during compliance inspections.
Are all the employees that are expected to respond:
Note: The term "outside parties" means outside responders (fire departments, police, private hazmat teams, emergency medical service personnel, and other pertinent components of the local, state, and federal emergency response system) and other employers in the surrounding area who could be affected by a hazardous substance emergency incident.
(a) CSHOs may ask the following questions:
(1) Does the plan address coordination with outside emergency response organizations?
(2) Have employers notified and coordinated their ERP with the organizations listed? CSHOs must verify with the local fire department that the employer has contacted them regarding the employer's emergency response capabilities and needs and the fire department's role, if any, in providing emergency response. The planning and coordination procedures in the employer's written emergency response plan should state the conditions or circumstances under which outside responders will provide emergency response to the site or facility. The CSHO should also verify with other randomly-selected emergency response organizations listed in the ERP that these outside parties are aware and capable of their role under the site's ERP.
(3) Are telephone numbers and contact personnel for in plant officials and local authorities correct?
(4) Do the employer's pre-emergency planning and coordination procedures address how outside parties are notified of a potential emergency situation and what role each would play in an incident? Verify whether the employer has conveyed these elements of the ERP by contacting several of the affected outside parties.
(5) Are outside responders aware of any circumstances that were either not disclosed or considered by the employer that would delay or prevent them from responding to an incident (e.g., distance, lack of training, etc.)?
(b) In addition, under SARA title III, facilities are required to share information on hazardous chemicals on site with the local emergency planning committee. You may refer industry personnel to the SARA title III hotline at 1-(800)-535-0202, or to the EPA Regional Offices. CSHOs are encouraged to refer to EPA facilities that have not complied with SARA title III.
(a) Personnel roles must be clearly defined. One method of doing this is to list job titles and describe their projected roles in emergency response operations. Although specific HAZWOPER titles are not required, employees should be designated to assume duties that parallel 29 CFR 1910.120(q)(6) and must be trained accordingly. For example, an employer may use the job title, "containment operator," to describe a responder whose responsibilities are equivalent to the first responder operations level. Employers would indicate in the ERP that the employee with this job title has acquired training equal to the first responder operations level, and CSHOs would cite any inadequacies in training under 29 CFR 1910.120(q)(6)(ii).
(b) Lines of authority must also be made clear in the ERP. The on-scene IC must be notified expeditiously by a predefined chain of communication in the event of a release that would require an emergency response. Although employees at the scene of the release may be expected to inform their supervisors (as opposed to the on-scene IC), the supervisor, unless properly trained, can do nothing other than call for the emergency response personnel and report what is known to be present.
(1) Are the lines of authority established in the emergency response plan that prescribe the roles and responsibilities of outside responders (e.g., fire, police, etc.) during a response?
(c) Provisions for employee training should be incorporated into the ERP. This might include a general outline of the training to be completed for each of the various levels of emergency responders addressed in the ERP, or reference to the location of the training manual. The plan should also address a schedule for required annual refresher training.
(d) The lines of communication need to be defined clearly in the ERP. Essentially all employees that may encounter a release that requires an emergency response should be addressed in the ERP and must understand to whom they are to report a release. These lines of communication can be developed for groups of employees in specific areas that would be required to report to the same individual in the event of an emergency. A system to communicate the need and method for evacuation of all employees who are not designated as emergency responders must be developed. These evacuation procedures should, at a minimum, meet the requirements of 29 CFR 1910.38(a).
(e) Means of communication to be used during an emergency response must be established and written into the ERP. This might include dedicated radio frequencies, hand signals, siren blasts, or any other system devised by the employer to alert employees that an emergency response operation has begun.
(a) This section of an ERP must define the types of releases that could potentially require an emergency response and should define what types of releases would not be an emergency, or, in other words, what may be handled as an incidental release. (See Appendix E of this instruction for criteria.)
(1) The ERP should include an inventory of the hazardous substances found on site, the quantities in which they are stored, and the consequences of an uncontrolled release. Scenarios or circumstances that trigger activation of the ERP should be described for the various hazardous substances stored in sufficient quantities to cause a potential emergency. Reasonably predictable worse-case scenarios must be made in the planning phase.
(2) Employees such as chemical process operators may be required to shut down processes, close emergency valves and otherwise secure operations that are not in the hot zone or danger area before evacuating in the event of an emergency. (See 29 CFR 1910.38(a)(2)(ii).) These procedures need to be delineated carefully, and employees must be trained to be able to perform these pre-evacuation procedures safely. Employees who perform these operations are not considered "emergency responders;" however, if they perform duties in the hot zone, or danger area, then they would be expected to be trained as emergency responders in accordance with 29 CFR 1910.120.
(3) Chemical process operators who have informed the incident command structure of an emergency, who have adequate PPE and training in the procedures they are to perform, and who employ the buddy system, may take limited action in the danger area (e.g., turning a valve) before the emergency response team arrives. The limited action taken by process operators must be addressed in the Emergency Response Plan. Once the emergency response team arrives, these employees would be restricted to the actions that their training level allows.
This limited action assumes that the emergency response team is on its way, their arrival is imminent, and that the action taken is necessary to prevent the incident from increasing in severity (i.e., to prevent a catastrophe). Employers must inform employees during their training that they are to evacuate when they lack the capabilities to respond in a safe manner and in accordance with the standard operating procedures defined in the emergency response plan.
If the process operator takes action beyond what they have been trained to do, and the action was comparable to the active role that a HAZMAT technician would take, CSHOs shall cite a violation of 29 CFR 1910.120(q)(6)(iii). If the operator takes action beyond that which they have been trained to do, and the action was comparable to the defensive role that a first responder at the operations level would take, CSHOs shall cite a violation of 29 CFR 1910.120(q)(6)(ii).
(a) The ERP should contain a map with safe places of refuge identified for each section of the area where HAZMAT emergencies could occur, if possible. Ideally, the map should contain the location of all buildings, structures, equipment, emergency apparatus, first aid stations, routes of entry and exit, emergency exit routes and alternate routes, staging areas, and safe places of refuge. The adequacy of safe refuge areas needs to be determined for the worst-case scenario.
(1) The safe places of refuge should be the areas where an accounting for all employees will be performed. This can be critically important for identifying individuals that did not get out, estimating where they may be, and initiating any rescue operation.
(2) Information on safe places of refuge must be given to the emergency response organization in a timely fashion.
(a) Areas surrounding the danger area need to be controlled during emergencies by prohibiting unauthorized personnel from entering the exclusion zone, or hot zone. Personnel expected to set up the exclusion zone must be trained to the first responder operations level. Once the exclusion zone is set, employees (preferably trained to the first responder awareness level) may control entry and exit in the area. An employee trained to the first responder awareness level may not set up safe distances because they lack knowledge regarding potential of exposure, explosion, or radiation. For example:
(1) An employee trained to the first responder awareness level could assist in preventing unauthorized entry into an emergency release area; while
(2) An employee trained to first responder operations level could set up the exclusion zone to determine how close to the accident cars should be permitted to drive.
(b) Methods of excluding areas and defining various zones need to be addressed in the ERP. Emergency responses are coordinated from a command post a safe distance away from the exclusion zone. The way this command post is assembled and its functions must also be addressed in the ERP. (See 29 CFR 1910.120 Appendix C, section 7., for further guidance.)
(a) All employees that are not trained in emergency response and who will not be needed during the response operation should be evacuated from the exclusion and decontamination zones. This aspect of the emergency response plan should be in compliance with 29 CFR 1910.38(a) as described in paragraph III.C. of this appendix. CSHOs must use 29 CFR 1910.38(a) as a model to evaluate the employer's "evacuation routes and procedures."
(a) The ERP must contain provisions for decontamination of emergency responders leaving the exclusion zone. Individuals who will assist the responders as they leave the exclusion area must be trained in decontamination procedures. These individuals should wear PPE at the same level or one level below the emergency responders they are supporting; the PPE level must be appropriate to the hazards.
(1) Decontamination of response equipment left in the exclusion zone and the contaminated area may be handled in the post-emergency response and therefore, decontamination procedures for these areas and equipment does not necessarily need to be part of the ERP.
(2) If emergency responders are expected to decontaminate their own equipment or the contaminated area, then the procedures to be followed must be included in the ERP. (See 29 CFR 1910.120, Appendix C, section 3., for further guidance.)
(a) The plan must provide for advance first aid personnel or better (who must be on standby, as per 29 CFR 1910.120(q)(3)(vi)), and list all qualified emergency medical personnel on site, their certifications and how best to contact them during an emergency.
(a) The plan must also address how employees will be informed that an emergency exists and how they should respond. The alarm system must inform "all affected employees" that an emergency exists and what their immediate response should be based on the alarm sequence. There are three important questions that need to be addressed:
Who needs to be made aware of the emergency?
What do they need to be told to do?
How will they be alerted?
(1) Depending on the size and the magnitude of the emergency "all affected employees" may include all employees, employees who work for other employers in the same facility or nearby facilities, or just employees from a limited area. If employers intend to evacuate people from a limited area, they must have alerting procedures in place that can communicate who must evacuate.
(2) The following list outlines the information necessary to inform the employees of what their immediate response should be. All of these criteria may not be applicable to all employers, depending on the size and nature of the place of work and the employer's preplanning efforts:
| - Notification. | Making the existence of the emergency situation known. |
| - Level & Type of Response. |
The required response based on the extent and type of emergency. |
| - Nature of the Response. | The type of emergency condition (explosion, chemical spill, medical). |
| - Location. | Critically important in large facilities. |
| - Ambient Conditions. | Environmental factors that influence evacuation or response procedures (wind speed and direction). |
(a) Emergency response plans are based on site specific needs and experience. It is important to consider previous emergency incidents in preparing an ERP. It is just as important to consider new information, experience, and incidents with the goal of enhancing the effectiveness of the ERP and keeping it current.
(1) Formalized procedures for the critique of an emergency response must be written into the ERP. Appropriate changes should be made in the ERP in accordance with the results of a critique of a specific incident.
(2) Time spent by emergency response employees reviewing incidents can be credited toward their refresher training requirements.
(a) This section of the ERP lists the inventory of PPE and emergency response equipment and materials. The ERP should include instructions on how the PPE and equipment and materials are to be used, their limitations, and in what situations emergency responders will use them.
(1) HAZWOPER requires the IC to be aware of the equipment and PPE available during an emergency. In addition, responders trained to the HAZMAT technician and HAZMAT specialist levels must be trained in the selection of and the proper use of PPE.
(2) Emergency responders must be made aware of the inventory in order to utilize the PPE and emergency response equipment effectively.
(a) Community emergency response agencies should be integral components of the community ERP. The community-wide ERP should spell out specific roles and responsibilities for various organizations or agencies, and will state which function each agency is expected to play in the event of an emergency. This predetermined role will be the basis for an agency's ERP.
GUIDANCE FOR 29 CFR 1910.120 EMERGENCY RESPONSE
COMPLIANCE INSPECTION
The function of this non-mandatory appendix is to supply the compliance officer guidance on pertinent information that should be collected relating to various subparagraph requirements in 1910.120(q), Emergency response to hazardous substance releases.
Y/N | ||
A.
________________________________________________________ ________________________________________________________ |
(q) | |
B.
________________________________________________________ |
(q)(1) | |
C.
________________________________________________________ ________________________________________________________ |
(q)(1) | |
D.
________________________________________________________ ________________________________________________________ |
1910.38(a) | |
E.
________________________________________________________ ________________________________________________________ |
1910.38(a) | |
F.
|
1910.38(a) | |
|
1910.38 (a)(1) | |
|
1910.38 (a)(2)(i) | |
|
1910.38 (a)(2)(iii) | |
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1910.38 (a)(3)(i) | |
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1910.38 (a)(3)(ii) | |
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1910.38 (a)(5)(i) | |
|
1910.38 (a)(5)(ii) | |
|
1910.38 (a)(5)(iii) | |
| ||
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||
NOTE:
|
1910.38 (a)(2)(v) | |
G.
________________________________________________________ ________________________________________________________ |
(q)(1) | |
H.
________________________________________________________ ________________________________________________________ |
(q)(1) | |
I.
________________________________________________________ ________________________________________________________ NOTE:
|
(q)(2)(xii) | |
J.
________________________________________________________ ________________________________________________________ |
(q)(2)(i) | |
|
(q)(2)(i) | |
|
(q)(2)(i) | |
|
(q)(2)(i) | |
K.
________________________________________________________ ________________________________________________________ |
(q)(2)(ii) | |
L.
(Suggestion: Determine if the employer established the kinds of emergencies that could
occur in the workplace, trained employees to recognize potential emergencies, and/or
installed monitoring devices to alert employees to an emergency.)
________________________________________________________ |
(q)(2)(iii) | |
M.
________________________________________________________ ________________________________________________________ |
(q)(2)(iv) | |
N.
________________________________________________________ ________________________________________________________ |
(q)(2)(v) | |
O.
(Suggestion: Check the evacuation routes and procedures against the requirements given
in 29 CFR 1910.38(a), emergency action plans.) |
(q)(2)(vi) | |
P.
________________________________________________________ |
(q)(2)(vii) | |
Q.
(Suggestion: Verify that emergency medical personnel are aware of their roles in an
emergency and trained to fulfill their roles.)
________________________________________________________ |
(q)(2)(viii) | |
R.
(Suggestion: If the emergency situation calls for special instructions, determine if the
emergency alerting system indicates the location of the hazard, the direction employees
should evacuate, what the hazard is, and any special PPE employees must don.)
________________________________________________________ |
(q)(2)(ix) | |
S.
________________________________________________________ ________________________________________________________ |
(q)(2)(xi) | |
T.
________________________________________________________ ________________________________________________________ |
(q)(2)(x) | |
U.
________________________________________________________ ________________________________________________________ NOTE:
|
(q)(1) |
A.
_______________________________________________________ _______________________________________________________ |
(q)(3) | |
B.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(3) | |
C.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(3)(vii) |
A.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(6) | |
B.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(6) | |
C.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(8) | |
D.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(8) |
A.
_______________________________________________________ _______________________________________________________ |
1910.120 (q)(9)(i) 1910.1020 | |
B.
_______________________________________________________ _______________________________________________________ |
1910.1020 |
NOTE:
A.
_______________________________________________________ _______________________________________________________ |
(q)(10) | |
B.
_______________________________________________________ _______________________________________________________ |
(q)(10) | |
C.
_______________________________________________________ _______________________________________________________ |
(q)(10) | |
D.
_______________________________________________________ _______________________________________________________ |
(q)(3)(iv) |
Opening questions:
____________________________________________________
(Employee's Name)
____________________________________________________
(Home Address)
____________________________________________________
| (Home Phone Number) | (Work Phone Number) |
____________________________________________________
(Employee Job title)
____________________________________________________
(Years Employed in Present Position)
A.
_______________________________________________________ _______________________________________________________ |
(q)(1) | |
B.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(2)(i) | |
C.
(Suggestion: Review with the employee the competencies for the level of training that the
employee has received.) |
(q)(6) | |
D.
_______________________________________________________ _______________________________________________________ |
(q)(6) | |
E.
_______________________________________________________ _______________________________________________________ |
(q)(6) (ii)-(iv) | |
F.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(10) 1910.133 1910.134 |
|
G.
_______________________________________________________ _______________________________________________________ |
(q)(6) (ii)-(iv) | |
H.
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||
|
(q)(3) | |
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(q)(3) | |
|
(q)(3)(vii) | |
|
(q)(3) | |
|
(q)(6)(v) | |
I.
_______________________________________________________ _______________________________________________________ |
(q)(8) | |
J.
_______________________________________________________ _______________________________________________________ NOTE:
|
(q)(9)(i) | |
K.
_______________________________________________________ _______________________________________________________ |
(q)(9)(ii) |
INSPECTION PROCEDURES AT ONGOING OR RECENTLY COMPLETED
EMERGENCY RESPONSE OPERATIONS
The function of this appendix is to provide guidance for inspection activity at ongoing or recently completed emergency response operations. The focus of this appendix is a review and discussion of the requirements of 29 CFR 1910.120(q)(3), Procedures for handling emergency response.
At ongoing or recently completed emergency response operations there is a shift in emphasis from the planning requirements of the standard toward the procedural requirements of the standard. An inspection of an actual emergency response should focus on the appropriate implementation of the emergency response plan and compliance with the requirements of 1910.120(q)(3).
If the employer fails to follow his/her emergency plan and also responds inappropriately, the CSHO should cite the employer for both actions. An example would be where an employer has designated the local fire department as the emergency responder, and then during an incident, fails to notify the department and sends in inadequately trained employees to respond to the incident. In that case, the employer should be cited under 1910.120(q)(1) and (q)(6).
(a) Be knowledgeable in the operations being implemented at the emergency response site.
(b) Have ability to identify existing hazards and to provide direction with respect to the safety of operations for the emergency at hand.
Note:
HAZWOPER INTERPRETIVE GUIDANCE
This appendix includes clarifications and interpretations that respond to the most frequently asked questions regarding 29 CFR 1910.120(q), Emergency response to hazardous substance releases. Where possible, clarifications are keyed to the most applicable paragraph or subparagraph of the HAZWOPER standard.
If an employee on a construction site is directed to engage in emergency response involving hazardous substances, then the employer is subject to all of the provisions of 29 CFR 1926.65(q). However, construction employers may direct that all of their employees evacuate in an emergency, and would comply with HAZWOPER paragraph (q) by having a written emergency action plan in accordance with 29 CFR 1926.35. (Employers who have 10 or fewer employees may communicate the emergency action plan verbally.)
(a) Shared Responsibility. Both contractors and their clients are responsible for complying with the OSHA regulations. OSHA considers personnel providers/contractors who send their own employees to work at other facilities (e.g., utility workers) to be employers whose employees may be exposed to hazards.
Since the contractor maintains a continuing relationship with employees, but it is the client who creates and controls the hazards, there is a shared responsibility for ensuring that employees are protected from workplace hazards. The client has the primary responsibility for such protection; however, the contractor-employer has a continuing responsibility under the OSH Act.
(b) Contracts. It is in the interest of the contractor-employer to ensure that all steps required in the OSHA standards have been taken by the client employer to ensure a safe and healthful workplace for the contracted employees. Written contracts with clients should clearly describe the responsibility of both parties in order to ensure that all requirements of the standards are met. (See OSHA Instruction CPL 2.103, the Field Inspection Reference Manual (FIRM), Chapter III.C.6., on Multi-employer Worksites.
(a) Hospitals with Responsibility Under the NCP. Hospitals, or other emergency medical services who are designated by the LEPC, SERC or local fire department, do not have to develop an entire emergency response plan for community emergency response because their role will be addressed in the contingency plan. The hospital should have designated decontamination areas, although areas dedicated solely to decontamination need not be set aside.
In terms of a community emergency response, a hospital is not expected to comply with 29 CFR 1910.120 if it has not been designated by a planning committee or by a hazardous waste site as a decontamination facility. The hospital may have responsibility under 1910.120(q) in terms of the potential for an emergency caused by the release of hazardous substances used at the hospital.
(b) training in Decontamination. Hospitals that will receive contaminated accident victims must stress decontamination and personal protective equipment (PPE) in the training for personnel designated to set up decontamination. For medical personnel who will receive and decontaminate accident victims, employers may develop an in-house training course that would focus on decontamination and PPE or provide additional training in decontamination and PPE after sending personnel to a standard "first responder operations level" course.
(c) Emergency Medical Services at Release Area. Facilities that create an emergency response plan under 29 CFR 1910.120 must coordinate with hospitals or other medical care providers prior to emergencies in case victims will need to be decontaminated at a hospital (29 CFR 1910.120(q)(2) and (l)(2) list "emergency medical treatment and first aid" as one of the elements to be covered in the emergency response plan). If a hospital is selected by a facility, it must be made aware of a facility's intent to use its services so that the hospital may ensure that it is prepared for its duties (e.g., has PPE, methods of containing the hazardous material and waste water, etc.)
Hospitals that employ emergency medical service personnel who would be exposed to hazardous substances because they are expected to treat contaminated patients at the release area (i.e., ambulance personnel), are required by 29 CFR 1910.120(q) to train these personnel to safely perform these duties.
Other medical personnel whose expected job duties do not include treating contaminated patients may be needed to respond to accidents where the chemical's hazards were unforeseen. These employees may be considered "skilled support personnel" and must be given an initial briefing that includes instruction in the wearing of appropriate PPE, any limitations of the PPE, the chemical hazards involved, and the facility's safety and health precautions.
Employee exposure or the reasonable possibility of employee exposure to safety or health hazards must consider all routes of entry (inhalation, ingestion, and skin absorption) without regard to the use of PPE. The exposure or potential exposure must be associated with a hazardous substance from operations addressed in (a)(1)(i-iv) or with the release of a hazardous substance during operations addressed in paragraph (a)(1)(v) of the standard. Safety hazards from a hazardous substance could include fire, explosion, corrosive action, etc., from flammables, corrosive materials, etc. associated with the work site or emergency site. Health hazards from a hazardous substance could include cancer or organ function impairment from toxic, carcinogenic, or infectious material associated with the work site or emergency site. Safety hazards from sources not specifically associated with the hazardous substances at the work site or the emergency site (e.g., trenching, moving machinery, slips, trips, and falls) do not require coverage under HAZWOPER. Employees are considered "exposed" when they encounter any amount of a hazardous substance in the work environment that could cause them harm.
(B) Any biological agent and other disease causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such persons or their offspring.
- Generally, police officers should be trained to the first responder awareness level, since they are likely to witness or discover a release of a hazardous substance.
- Fire fighters expected to respond to releases of hazardous substances must be trained to at least the first responder operations level, since they will respond to releases, or potential releases, of hazardous substances for the purpose of protecting nearby persons, property, or the environment.
If fire fighters are fully trained and equipped (which is a high degree of training), and have also received first responder operations level training, OSHA believes they have sufficient training to take aggressive action due to propane's relatively low toxicity. However, it would be only a technical violation of 29 CFR 1910.120(q)(6) for not having the additional training required of a HAZMAT technician if a fire fighter took aggressive action in the danger area during a propane fire or leak, was fully trained and equipped to handle the fire, and had first responder operations level training. In this circumstance OSHA would not issue a citation.
Employers who expect fire fighters to shut off a gasoline valve in the danger area, and who can show that employees are trained to the operations level and adequately trained in the hazards of gasoline, have committed a technical violation of 1910.120(q)(6)(iii) for such employees not having the training required of a HAZMAT technician.
NOTE: The fire and explosion hazards of propane and gasoline are very substantial. The interpretations herein are applicable only when fire fighters are fully trained and equipped to handle the explosion and fire hazards of propane, gasoline, or similar flammable gases and liquids.
A violation of training requirements that resulted in an actual injury to an employee during an emergency response by definition cannot be a "technical violation." Thus, if an injury occurred and the CSHO determined that the responders' training and experience were not sufficient for the tasks being performed, then a citation should be issued noting a violation of 29 CFR 1910.120(q)(6)(iii) and carrying a penalty that requires abatement. Whether abatement should require full training in all of the competencies of the HAZMAT technician level, or whether certain training requirements could safely be omitted, would depend on the training needed to safely perform the tasks in question.
If, however, the CSHO determined that the training that had been provided to the employees in question had been adequate, then the training violation would be considered a de minimis violation and no citation would be issued for inadequate training. In this situation the CSHO might determine that the cause of the injury was due to a violation of some other requirement of 29 CFR 1910.120 or other standards, for which a citation carrying a fine and requiring abatement would be appropriate.
"This enable[s] one individual to be in charge of managing the incident, rather than having several officers from different companies making separate, and sometimes conflicting, decisions. The individual in charge of the [incident command system] would delegate responsibility for performing various tasks..."
Consequently, the IC requires more training in general matters, plus extensive training in command and management.
NOTE: If an employer selects a single type of PPE for all releases that require an emergency response, the employer must be sure to evaluate the full range of performance criteria that PPE must meet, such as likely chemical exposures, heat stress, physical constraints, maintenance, and permeability.
The emergency response plan and training components may cover this by identifying the known hazardous substances that would cause, or have the potential to cause, an emergency if released. Where mixtures of hazardous substances may occur in an emergency and/or hazardous byproducts may be formed during an emergency, the plan must anticipate, identify, and include training components about these mixtures or byproducts.
Employees trained in this limited manner would only be able to respond to spills on site that involve the limited range of hazardous substances in which they are trained. For example, employees trained to respond only to releases of chlorine may not respond to a release of ethylene oxide, without broadening their limited training.
APPENDIX E: RELEASES OF HAZARDOUS SUBSTANCES THAT REQUIRE AN
EMERGENCY RESPONSE
The function of this appendix is to present a thorough discussion of the distinction between incidental releases of hazardous substances and releases that require an emergency response, and hence, compliance with the provisions of 1910.120(q), Emergency response to hazardous substance releases. This has been a point of considerable inquiry to and interpretation by OSHA.
An understanding of the distinction between an incidental release of a hazardous substance and a release that requires an emergency response is fundamental to proper compliance with the provisions of 29 CFR 1910.120(q). This part of the standard was written to cover a wide array of facilities and situations: "Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard." (29 CFR 1910.120(a)(1)(v))
Potential releases of hazardous substances in the workplace can be categorized into three distinct groups in terms of the planning provisions of 1910.120(q). These groups are:
1. Releases that are clearly incidental regardless of the circumstances,
2. Releases that may be incidental or may require an emergency response depending on the circumstances, and
3. Releases that clearly require an emergency response regardless of the circumstances.
The scope of the HAZWOPER standard does not cover the inevitable release of a hazardous substance that is limited in quantity and poses no emergency or significant threat to the safety and health of employees in the immediate vicinity. This type of release is referred to as an "incidental release" in 29 CFR 1910.120(a)(3), where "emergency response" is defined.
An incidental release is a release of hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up.
If the hazardous substances that are in the work area are always stored in very small quantities, such as a laboratory which handles amounts in pint sizes down to test tubes, and the hazardous substances do not pose a significant safety and health threat at that volume, then the risks of having a release that escalates into an emergency are minimal. In this setting incidental releases will generally be the norm and employees will be trained to protect themselves in handling incidental releases per the training requirements of the Hazard Communication standard (29 CFR 1910.1200).
For example, a tanker truck is receiving a load of hazardous materials at a tanker truck loading station. At the time of an accidental spill, the product can be contained by employees in the immediate vicinity and cleaned up utilizing absorbent without posing a threat to the safety and health of employees. As such, the employer may respond to such incidental releases (as permitted by 1910.120 definition: "Emergency Response" or "Responding to Emergencies").
This situation describes an "incidental spill" under the HAZWOPER. An incidental spill poses an insignificant threat to health or safety, and may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.
The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, corrosiveness, etc., as well as the particular circumstances of the release itself, such as quantity, confined space considerations, ventilation, etc., will have an impact on what employees can handle safely and what procedures should be followed. Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and personal protective equipment (PPE) at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.
These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental releases and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.
For example: A spill of the solvent toluene in a facility that manufactures toluene may not require an emergency response because of the advanced knowledge of the personnel in the immediate vicinity and equipment available to absorb and clean up the spill. However, the same spill inside a furniture refinishing shop with personnel that have had only the basic hazard communication training on toluene, may require an emergency response by more highly trained personnel. The furniture refinishing shop's emergency response plan in this case would call for evacuation for all but the most minor spills, while evacuation and emergency response would be necessary for only much larger spills at the chemical manufacturing facility.
There are releases of hazardous substances that pose a sufficient threat to health and safety that, by their very nature, require an emergency response regardless of the circumstances surrounding the release or the mitigating factors. An employer must determine the potential for an emergency in a reasonably predictable worst-case scenario (or "anticipated emergencies," 29 CFR 1910.120(q)(1)), and plan response procedures accordingly.
For example, a motor carrier is engaged in the transportation of hazardous materials. At the time of an accidental release, the product cannot be contained by employees in the immediate vicinity and cleaned up utilizing absorbent. Because of the larger problem, the motor carrier's employees evacuates the area and call for outside help, as instructed by employer.
In this instance, if in the event of a spill of a hazardous substance an employer instructs all of his/her employees to evacuate the danger area, then the employer may not be required to train those employees under 1910.120. However, the ability to decide whether a spill is an incidental spill or one requiring an emergency response requires training. Also, any employees who are expected to become actively involved in an emergency response due to a release of a hazardous substance are covered by 1910.120 and must be trained accordingly. (Note: OSHA has limited jurisdiction for over-the-road vehicle operation. In the instance of spills occurring while the material is on the vehicle or otherwise "in transportation," OSHA's HAZWOPER standard does not cover the operator per se. It does, however, cover emergency response personnel who respond to the incident. If the operator of the vehicle in transportation becomes actively involved in an emergency response, then he/she becomes an emergency responder and is covered by 1910.120(q).)
Table B.1. An emergency response includes, but is not limited to, the following situations:
1. The response comes from outside the immediate release area;
2. The release requires evacuation of employees in the area;
3. The release poses, or has the potential to pose, conditions that are immediately dangerous to life and health (IDLH);
4. The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit);
5. The release requires immediate attention because of imminent danger;
6. The release may cause high levels of exposure to toxic substances;
7. There is uncertainty that the employee in the work area can handle the severity of the hazard with the PPE and equipment that has been provided and the exposure limit could easily be exceeded; and
8. The situation is unclear, or data are lacking on important factors.
"Emergency response" is defined in 29 CFR 1910.120(a)(3) as follows:
"Emergency response" . . . means a response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.
The standard covers responses "by other designated responders." The use of the "or" means that responders are a separate group, different from employees within the immediate release area, directed to respond to the emergency by the employer. Employees working in the immediate release area (not just outsiders) are covered if the employer designates them as emergency responders. The standard, 29 CFR 1910.120(q), uses the term "responders" generally to refer to employees who respond to emergencies.
The Superfund Amendments and Reauthorization Act (SARA), the statute that mandated HAZWOPER, directs broad coverage of all employees responding to emergencies with no limitation on their location. SARA states, ". . . standards shall set forth responding requirements for training of workers who are responsible for responding to hazardous emergency situations who may be exposed to toxic substances." (See SARA 126(d)(4)) For an emergency to be covered by the standard, conditions causing a dangerous situation which involve hazardous substances are sufficient; there need not be both an emergency and a response by outside responders before the employer prepares for an emergency.
For example: A release of chlorine gas above the IDLH, obscuring visibility and moving through a facility, is an emergency situation even if the initial responders are from the immediate release area. Employees who would respond to this hypothetical situation, whether they work in the immediate area or come from outside, would need to act in accordance with 29 CFR 1910.120(q).
Employees must not be made to respond to releases in the immediate release area that would otherwise require outside assistance from a trained hazardous materials team merely because the definition of an emergency response states that an emergency response is ". . . a response effort by employees from outside the immediate release area."
Conversely, incidental releases of hazardous substances that are routinely cleaned up by those from outside the immediate release area need not be considered emergency responses solely because the employee responsible for cleaning it up comes from outside the immediate release area.
For example: Paint thinner is spilled in an art studio and the janitor is called from outside the immediate release area to mop it up. The janitor does not have to respond in accordance with 29 CFR 1910.120, although the janitor would be expected to understand the hazards associated with paint thinner through hazard communication training.
Other standards that impact emergency response to fires, chemical releases, or other incidents
should be part of an emergency response compliance evaluation. Flammable chemical spills and
other small fires are covered by 29 CFR 1910.156 as well as 29 CFR 1910.157. The "Process
Safety Management for Highly Hazardous Chemicals," 29 CFR 1910.119, and "Hazard
Communication," 29 CFR 1910.1200, as well as some of the specific expanded health standards
in Subpart Z would also apply. (See Appendix F, I. of this instruction.)
RELATIONSHIP OF 29 CFR 1910.120(q) WITH OTHER OSHA STANDARDS AND
OTHER AGENCY REGULATIONS
The function of this appendix is to explain the HAZWOPER standard's interface with other OSHA standards and Federal agency regulations as well as consensus guideline documents.
(a) The CSHO shall cite 29 CFR 1910.38(a) if an employer with more than 10 employees merely expresses the intent to evacuate all employees from the danger area, and would not allow employees to assist in handling the emergency, but does not have a written emergency action plan. This intent must have been communicated to employees, which the CSHO may verify by employee interviews.
(b) The CSHO shall cite 29 CFR 1910.38(a) and 29 CFR 1910.165, the Employee Alarm Systems standard (referenced in 29 CFR 1910.38(a)), if there are deficiencies found in a written emergency action plan or alarm system.
(c) The CSHO shall cite 29 CFR 1910.120(q)(1) if the employer does not have a written emergency action plan, and has not expressed any intention to employees (i.e., the employer has done absolutely nothing in planning for emergencies).
(d) The CSHO shall cite 1910.38(a)(2)(v) if the employer has not established reasonable procedures in the plan for notifying both inside and outside parties of incidents so that employees are not at risk. See Appendices A and B for examples.
(a) Response actions under the NCP will comply with the provisions for response action worker safety and health in 29 CFR 1910.120.
(b) In a response action taken by a responsible party, the responsible party must assure that an occupational safety and health program consistent with 29 CFR 1910.120 is made available for the protection of workers the response site.
(c) In a response taken under the NCP by a lead agency, an occupational safety and health program should be made available for the protection of workers at the response site, consistent with and to the extent required by, 29 CFR 1910.120. Contracts relating to a response action under the NCP should contain assurances that the contractor at the response site will comply with this program and with any applicable provisions of the OSH Act and State OSH laws.
(d) When a State, or a political subdivision of a State, without an OSHA approved State plan is the lead agency for response, the State or political subdivision must comply with standards in 40 CFR Part 311, promulgated by EPA pursuant to Section 126(f) of SARA.
(e) Requirements, standards, and regulations of the Occupational Safety and Health Act of 1970 (29 USC 651 et seq.) (OSH Act) and of State laws with plans approved under Section 18 of the OSH Act (State OSH laws), not directly referenced in paragraphs (a) through (d) of this section, must be complied with where applicable. Federal OSH Act requirements include among other things, Construction Standards (29 CFR Part 1926), General Industry Standards (29 CFR Part 1910), and the general duty requirement of section 5(a)(1) of the OSH Act. No action by the lead agency with respect to response activities under the NCP constitutes an exercise of statutory authority within the meaning of Section 4(b)(1) of the OSH Act. All governmental agencies and private employers are directly responsible for the health and safety of their own employees.
(a) When hazardous chemicals (as defined in 29 CFR 1910.1200) are kept in amounts equal to or greater than 10,000 pounds;
(b) When "extremely hazardous substances" (a list is provided in Federal EPA's regulation, 40 CFR Part 355 - Appendix A) are present in amounts greater than or equal to 500 pounds, or greater than or equal to the "threshold planning quantity," whichever is lower;
(c) When facilities are requested to submit an MSDS or Tier II form by the SERC, LEPC or fire department (the minimum "threshold" for reporting in response to requests is zero; i.e., anytime the SERC or LEPC or fire department makes a request).
NOTE: The facility's responsibility is further explained in 40 CFR Part 355 - Emergency Planning and Notification.
(a) Identification of facilities with reportable quantities, routes likely to be used for the transportation of extremely hazardous substances, and facilities contributing or subjected to additional risk due to their proximity.
(b) Emergency response methods and procedures to be followed by facility owners, local emergency responders, and emergency medical personnel.
(c) Designation of a community emergency coordinator and facility emergency coordinators, who shall make determinations necessary to implement the plan.
(d) Emergency notification procedures for the facility and community emergency coordinators.
(e) Methods for determining the occurrence of a release, and the population likely to be affected.
(f) A description and location of emergency equipment and facilities in the community, and identification of personnel responsible for equipment and facilities.
(g) Evacuation plans.
(h) training programs and their schedules for emergency responders.
(i) Methods and schedules for exercising the emergency plan.
NOTE: The provisions of the community emergency response plan are significant because 29 CFR 1910.120(q) allows community responders to use the plan developed under SARA title III in complying with OSHA. HAZWOPER paragraph (q) states that .... emergency response organizations who have developed and implemented programs equivalent to this paragraph for handling releases of hazardous substances pursuant to Section 303 of the SARA ... shall be deemed to have met the requirements of this paragraph.
(a) On June 20, 1996, EPA published the Risk Management Plan final rule (40 CFR 68). The RMP rule applies to all stationary sources with more than a threshold quantity of regulated substances in process on August 19, 1996. The list of regulated substances, promulgated separately, was published on January 31, 1994, amended on April 16, 1996, and is found in 40 CFR 68.130.
(b) EPA attempted to minimize inconsistencies between its RMP requirements and the chemical risk management requirements published by OSHA and DOT. The RMP's emergency response program requirements closely parallel the requirements of OSHA's PSM standard and contain many of the requirements of an emergency response plan under 29 CFR 1910.120(q). Nevertheless, the focus of the RMP rule is primarily on the safety and health of the public and the surrounding environment, versus HAZWOPER's emphasis on worker health and safety. Because an RMP must be provided to EPA, state and local government agencies, and to the public, outside responders should be familiar with emergency response plans for facilities with an RMP. Facilities who must comply with both EPA's RMP rule and OSHA's emergency response requirements under HAZWOPER may prepare an Integrated Contingency Plan (ICP) according to guidance published by the National Response Team in order to comply with both regulations (see paragraph II.G. of this appendix).
(a) DOT-Research and Special Programs Administration, 49 CFR Part 194, "Response Plans for Onshore Oil Pipelines."
(b) DOT-Research and Special Programs Administration, 49 CFR Part 130, "Oil Spill Prevention and Response Plans."
(c) DOT-USCG, 33 CFR Part 154, Subpart D and Part 155 , Subpart F, which address emergency response plan requirements for facilities and vessels.
LIST OF ACRONYMS IN THIS DOCUMENT
| CERCLA: | Comprehensive Environmental Response Compensation and Recovery Act of 1980 (also, Superfund) |
| CFR: | Code of Federal Regulations |
| CSHO: | Compliance safety and health officer |
| DOT: | U.S. Department of transportation |
| EPA: | U.S. Environmental Protection Agency |
| ERP: | Emergency response plan |
| EtO: | Ethylene oxide |
| FIRM: | Field Inspection Reference Manual |
| HAZCOM: | Hazard Communication standard, 29 CFR 1910.1200 (also, HCS) |
| HAZMAT: | Hazardous materials |
| HAZWOPER: | Hazards Waste Operations and Emergency Response standard, 29 CFR 1910.120 |
| HCS: | Hazard Communication standard, 29 CFR 1910.1200 (also, HAZCOM) |
| HMTUSA: | Hazardous Material transportation Uniform Safety Act of 1990 |
| IC: | [On-scene] incident commander |
| IDLH: | Immediately dangerous to life or health |
| LEPC: | Local emergency planning committee |
| MOU: | Memorandum of Understanding |
| MSDS: | Material safety data sheet |
| NCP: | National Contingency Plan |
| NFPA: | National Fire Protection Association |
| NIOSH: | National Institute of Occupational Safety and Health |
| NRC: | Nuclear Regulatory Commission |
| NRT: | National Response Team |
| OPA 90: | Oil Pollution Act of 1990 |
| OSC: | On-scene coordinator (term used in NCP) |
| OSHA: | Occupational Safety and Health Administration |
| OSH Act: | Occupational Safety and Health Act of 1970 |
| PPE: | Personal protective equipment |
| PRCS | Permit-required confined space |
| PSM: | Process Safety Management of Highly Hazardous Chemicals standard, 29 CFR 1910.119 |
| RCRA: | Resource Conservation and Recovery Act of 1976 |
| RRT: | Regional Response Team |
| SARA: | Superfund Amendments and Reauthorization Act of 1986 |
| SCBA: | Self-contained breathing apparatus |
| SERC: | State emergency response commission |
| TSDF: | treatment, storage and disposal facility (also, "TSD facility") |
| USCG: | United States Coast Guard |
| UST: | Underground storage tank |
REFERENCE MATERIALS FOR HAZWOPER
Emergency Response Guidebook, U.S. Department of transportation, Washington, DC, 1996.
Federal Register, Vol. 57, No. 95, May 15, 1992, pages 20944-20954: Hazardous Materials; training for Safe transportation; Final Rule. (49 CFR Parts 171-177)
Federal Register, Vol. 57, No. 36, February 24, 1992, pages 6356-6417: Process Safety Management of Highly Hazardous Chemicals; Explosives and Blasting Agents; Final Rule. (29 CFR 1910.119)
Federal Register, Vol. 56, No. 75, April 18, 1991, pages 15832-15833: Hazardous Waste Operations and Emergency Response; Final Rule; Corrections.
Federal Register, Vol. 55, No. 72, April 13, 1990, pages 14072-14075: Hazardous Waste Operations and Emergency response; Final Rule; Corrections.
Federal Register, Vol. 55, No. 18, January 26, 1990, pages 2776-2794: Accreditation of training Programs for Hazardous Waste Operations; Notice of Proposed Rulemaking.
Federal Register, Vol. 54, No. 120, June 23, 1989, pages 26654-26658: Worker Protection Standards for Hazardous Waste Operations and Emergency Response; Final Rule. (40 CFR Part 311)
Federal Register, Vol. 54, No. 42, March 6, 1989, pages 9294-9336: Hazardous Waste Operations and Emergency Response; Final Rule. (29 CFR Subpart 1910.120)
Federal Register, Vol. 52, No. 163, August 24, 1987, pages 31852-31886: Hazard Communication; Final Rule. (29 CFR 1910.1200)
Federal Register, Vol. 52, No. 85, May 4, 1987, pages 16241-16243: Hazardous Waste Operations and Emergency Response; Interim Final Rule; Corrections.
Federal Register, Vol. 51, No. 244, December 19, 1986, pages 45654-45675: Hazardous Waste Operations and Emergency Response; Interim Final Rule.
Health and Safety Audit Guidelines, SARA title I, Section 126, December 1989, United States Environmental Protection Agency: Office of Solid Waste and Emergency Response, Office of Emergency and Remedial Response, and Emergency Response Division. (EPA/540/G-89/010)
"Memorandum of Understanding Between the United States Coast Guard, U.S. Department of transportation, and the Occupational Safety and Health Administration, U.S. Department of Labor, Concerning Their Authority to Prescribe and Enforce Standards or Regulations Affecting the Occupational Safety and Health of Seamen Aboard Vessels Inspected and Certificated by the United States Coast Guard," March 4, 1983
OSHA Instruction CPL 2.94, July 22, 1991, "OSHA Response to Significant Events of Potentially Catastrophic Consequence."
OSHA Instruction CPL 2-2.30, November 14, 1980, "29 CFR 1913.10(b)(6), Authorization of Review of Medical Opinions."
OSHA Instruction CPL 2-2.32, January 19, 1981, "29 CFR 1913.10(b)(6), Authorization of Review of Specific Medical Information."
OSHA Instruction CPL 2-2.33, February 8, 1982, "29 CFR 1913.10, Rules of Agency Practice and Procedure Concerning OSHA Access to Employee Medical Records -- Procedures Governing Enforcement Activities."
OSHA Instruction CPL 2-2.45A, September 28, 1992, "29 CFR 1910.119, Process Safety Management of Highly Hazardous Chemicals -- Compliance Guidelines and Enforcement Procedures."
OSHA Instruction CPL 2-2.51, November 5, 1990, "Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120."
OSHA Instruction STP 2-1.154C, June 10, 1991, "Hazardous Waste Operations and Emergency Response; Final Rule and Corrections."
OSHA Instruction TED 1.15, September 22, 1995, "OSHA Technical Manual."
Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, NIOSH/OSHA/USCG/EPA; October 1985. (Publication Number: 85-115)
Recommended Practice for Responding to Hazardous Materials Incidents; National Fire Protection Association Standard 471; August 14 1992.
Standard for Professional Competence of Responders to Hazardous Materials Incidents; National Fire Protection Association Standard 472; August 14, 1992.
State of Washington Industrial Safety and Health Administration, May 3, 1991; "Inspection
Guidelines for Post-Emergency Response Operations Under WAC 296-62-300."