Document gbx8ye0oK73kXOZZOw45Kopye
ABDOO118322
To: Central Safety Committee Members
Interoffice Communication
From: Dote:
Subject:
B. L. Trego December 14, 1989
HAZWOPER - WHAT*8 THAT?
OSHA'S new Hazardous Waste Operations Emergency Response (HAZWOPER), 1910.120, addresses the safety of workers dealing with hazardous waste. However, it is not just a hazardous waste worker standard. It not only protects fire fighters, police officers and ambulance and hazardous team members who respond to hazmat spills, it also protects workers at cleanup operations at waste dump sites, and waste treatment storage and disposal facilities approved by the EPA.
In our case, compliance with the final rule's require ments will be mostly a matter of fine tuning our existing programs and procedures. We need to get some procedures and training documented but all in all we are not in too bad of shape.
The following is a summary of the general requirements of the 1910.120 final rule which will pertain to plants such as ours:
A safety and health program designed to identify, evaluate, and control safety and health hazards and provide for emergency response.
Training of employees before they engage in hazardous waste operations or emergency response that could expose them to safety and health hazards.
The training requirements are as follows:
o New employees need twenty-four hours initial training by an instructor and an annual refresher of eight hours by the employer.
o Current employees need twenty-four hours initial training or previous work experience and/or training certified as equivalent by the employer and an eight-hour refresher annually.
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o On-site emergency response workers
must
receive
initial
training
necessary to protect themselves and
others and be able to show competency
annually. The employer must certify
this.
o Off-site emergency personnel require training specific to the level at which they respond.
Level 1 - First Responder - Awareness
First responder at this level is one who is likely to witness or discover a hazmat release. They must know:
1) What hazardous materials are and the risks associated with them.
2) Understand potential outcomes of a hazmat emergency.
3) Recognize hazardous materials and identify them.
4) Understand his role in the plan.
5) Realize need for more re sources and notifications.
Requires training or
ence in above
Demonstration
of
annually required.
proven experi competencies. competencies
Level 2 - First Responder - Operational
First responder at this level
responds to a hazmat emergency for
the purpose of protecting nearby
persons, property, or the environ
ment. They respond in a defensive
fashion.
Fire fighters fall into
this category.
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Level 2 - continued
1) Knowledge of basic hazard and risk assessment techniques.
2) Knowledge of personal
protective
equipment
available.
3) Understand terms.
basic
hazmat
4) Know how to control and contain hazmat within their capabilities.
5) Know how to decontaminate.
6) Understand
SOP's
and
terminating procedures.
Level 3 - Hazardous Materials Technician
These are people who respond to releases for the purpose of stopping the release.
1) Twenty-four hours training equal to Level 2.
2) Capable of implementing the
community
Emergency
Operations Plan.
3) Able to classify, identify
and verify known and unknown
materials
using
direct
reading instruments.
4) Able to function within assigned role in the Incident Command System.
5) Able to select and use selected hazmat response personal protective equipment and clothing.
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Level 3 - continued
6) Understand hazard and risk assessment techniques.
7) Be able to perform advanced control/containment operations.
8) Understand and implement decontamination procedure.
9) Understand basic chemical and toxicological terminology and behavior.
Level 4 - Hazardous Materials Specialist
These people respond with and support hazmat technicians. The duties are basically the same but they are generally more knowledgeable (usually in a certain task area). They act as liaison with local, state and federal governments.
1) At least twenty-four hours training equal to Level 3.
2) Know community plan.
emergency
3) Know state emergency response plan.
4) Able to develop a site safety and control plan.
5) Understand basic chemical,
radiological,
and
toxicological terminology and
behavior.
6) All knowledge that the Level 3 responder would have.
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Level 5 - On-Scene Incident Command
Normally the ranking fire or police officer at the scene is the Incident Commander. They need at least Level 2 training and experience plus the following:
1) Know and be able to implement
the
community
incident
command system.
2) Know how to implement the local Emergency Operation Plan.
3) Understand the hazards of
working
with
chemical
protective clothing.
4) Know the state emergency response plan and the federal emergency response team.
5) Know and understand the importance of decontamination procedures.
- Medical surveillance offered at least annually and at end of employment for exposed employees and respirator wearers.
Engineering controls, work practices, and personal protective equipment, or a combination of these must be implemented to reduce exposures below established exposure levels.
- Air monitoring with periodic monitors to assume proper PPE is being used.
Decontamination procedure.
Emergency response plan emergencies to address:
for
on-site
1) Personnel roles 2) Lines of authority 3) Training
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4) Communications 5) Emergency recognition and prevention 6) Evacuation routes and procedures 7) Emergency medical treatment 8) Emergency alarm system
Off-site emergency response plan.
What Does This Mean to Us at Aberdeen?
1) We have an acceptable safety and health program at this time.
2) Our initial training is adequate with
twenty hours the first week plus respirator
and fire training.
RCRA and first aid
training count, also. Our documentation at
this time is adequate, also. It will have
to be determined if earlier training
documentation is sufficient.
Since only eight hours of annual training is required, we fulfill that easily. We need to document very well to ensure compliance.
Off-site responder training is taken care
of by the requirement for tank car safety
training for all CTIRP personnel.
Dean
Honeycutt, Charles Worlow, Jim Edwards, and
myself have been trained and will arrange
for annual training to maintain our
competence level.
I feel that we are
hazardous material specialists or Level 4.
3) Our current medical surveillance program is adequate at this time. Some improvements can and will be made in the future.
4) We always attempt to maintain levels of exposure below established levels.
5) We take HNU instruments with us whenever we respond and are all proficient in its use.
6) We need to establish and practice a decontamination procedure? primarily for PA, lead and oils.
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7) Our existing Emergency Response Plan needs work but basically has the areas required by OSHA. A close review will be done this year.
8) An off-site emergency plan will need to be developed for Aberdeen area emergencies.
As you can see, we are not in too bad of shape but some effort will be required to get us into full compliance. Throughout the next few months, we will be working on the areas we are weak in. If you have any questions or desire more information, please give me a call at extension 3618.
B. L. Trego Safety Director rah