HEALTH AND SAFETY 40-HOUR TRAINING

(165.5) presented by HazTrain, Inc.

for the U.S. Environmental Protection Agency's Environmental Response Team

Contract Number EP-W-09-006

ENVIRONMENTAL RESPONSE TRAINING PROGRAM (ERTP)

U.S. EPA

United States Environmental Protection Agency

Office of Solid Waste and Emergency Response (Superfund)

OSWER

OSRTI

Office of Superfund Remediation and Technology Innovation

Environmental Response Team

ERT

ERTP TRAINING COURSES

Are offered tuition-free for environmental and response personnel from federal, state, and local agencies Vary in length from one to five days Are conducted at EPA Training Centers and at other locations throughout the United States

ERTP TRAINING COURSES

Course Descriptions, Class Schedules, and Registration Information are available at: www.trainex.org
www.ertpvu.org

COURSE OBJECTIVES
Have the ability to locate the OSHA Regulations Understand basic health and safety concepts as applicable to OSHA 1910.120 Identify the chapters of OSHA 1910.120 that apply to your worksite Identify regulatory exposure limits for potential contaminants Discuss engineering controls, work practices, and PPE to minimize risk to workers

COURSE MATERIALS

Student Registration Card Student Evaluation Form Course Agenda Facility Information Student Handouts Course critique Certificate Issuance

FACILITY INFORMATION
Parking Classroom Restrooms Lunch Telephones Alarms and emergency exits

Please...
In consideration of your fellow students and the instructors, please silence all cell phones
VIBRATE MODE

Module 1 Objective
Comprehend the different paragraphs of OSHA 1910.120 Identify additional OSHA regulations that apply to 1910.120 Locate resources to assist in Health and Safety Planning

REGULATORY OVERVIEW

www.osha.gov

DOT

www.epa.gov

REGULATORY OVERVIEW
Regulatory guidance: OSHA 29 CFR 1910.120 CERCLA Comprehensive Environmental Response Compensation Liability Act SARA Section 126 Superfund Amendment Reauthorization Act EPA 40 CFR 311

What is CERCLA?
Passed by congress in 1980 due to national outcry over environmental disasters at Love Canal and elsewhere Goal is to locate, investigate, and clean-up the worst waste sites nationwide Nicknamed Superfund, created a 1.6 billion tax on the chemical and petroleum industries

Did You Know? There are over 76 million people living within four miles of Superfund sites.

What is Regulated under CERCLA?

Prohibitions and requirements for

closed and abandoned hazardous waste sites Liability to force those who poison the land to pay for its remediation. Short-term removals when a release requires prompt response and longterm response actions at sites listed on EPAs National Priorities List (NPL)

Superfund at a Glance
1,562 sites identified in 1980 30 years later, 341 sites have been cleaned For 2010, 1,279 sites remain on the list. The list is updated and prioritized every year. Most common contaminates:
asbestos, lead, mercury, radiation
There are currently approximately 2,500 sites waiting to be added to the list
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o Amended CERCLA in 1986 o Trust fund increased to $8.6 billion o Implemented EPCRA or SARA Title III o Directed OSHA to develop minimum training standards for operations at hazardous waste sites (HAZWOPER) o Final Rule March 1990
Bhopal 1984

REGULATORY OVERVIEW
Groups of workers: Mandatory cleanups at uncontrolled hazardous waste sites Voluntary cleanups at uncontrolled hazardous waste sites Corrective actions at Resource Conservation Recovery Act (RCRA) Treatment, Storage, and Disposal (TSD) facilities

REGULATORY OVERVIEW
Groups of workers: Routine hazardous waste operations at RCRA TSD facilities Emergency response without regard to location

REGULATORY OVERVIEW
OSHA 1910.120 Regulation
a. b. c. d. e. f.
Paragraph (a f): Scope, application, and definitions Safety and health program Site characterization and analysis Site control Training Medical surveillance

INTRODUCTION TO 29 CFR 1910.120

Hazardous Waste Operations and Emergency Response

paragraph (a); Scope, application, and definitions

Governmental body cleanup operations (b)-(o) Resource Conservation and Recovery Act (RCRA) corrective action clean-up operations, (b)-(o)
Voluntary cleanup operations (b)-(o)

paragraph (a); Scope, application, and definitions

Treatment, storage and disposal (TSD) facility haz waste operations, (p) Emergency response operations, (q)

paragraph (b); Safety and health program

General program requirements Organizational structure Comprehensive work plan Site-specific health and safety plan

Definitions

paragraph (c); Site characterization and analysis

Preliminary evaluation
Hazard identification Required information Personal protective equipment (PPE)

paragraph (c); Site characterization and analysis

Monitoring Risk identification

Employee notification

Definitions

paragraph (d); Site control

Written site control program Minimum elements of site control program Site maps and work zones Buddy system Site communications Procedures and practices Nearest medical assistance locations

paragraph (e); Training

Required for site work
Identifies areas of training Delineates employee categories and training levels

Employee certification/trainer qualification

Training Requirements for Uncontrolled HazWaste Sites

29 CFR 1910.120 (e)
General Site Workers - 40 hrs. off-site instruction & 3 days field experience Occasional Workers - 24 hrs. off-site instruction & 1 day field experience Workers in non-hazardous areas - 24 hrs. off-site instruction & 1 day field experience

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Requirements for Additional Training

Annual refresher training is required for all personnel at uncontrolled sites (One time) 8 hr. supervisor training is required for those personnel that supervise others at uncontrolled hazardous waste sites

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Definitions

paragraph (f); Medical surveillance

Employees who require medical surveillance Frequency of examinations

Contents and cost of medical examinations US EPA Health and Safety Manual Chapter I-2 www.epaosc.org

paragraph (f); Medical surveillance

Information provided to the physician
Physician's written opinion Recordkeeping requirements

Paragraph (g); Engineering controls, work practices, and personal protective equipment for employee protection
Hierarchy of controls
Engineered controls Administrative work practices Personal Protective Equipment

Objective
Maintain employee exposure below limits

paragraph (h); Monitoring

Determine appropriate level of employee protection Types of monitoring:
Initial entry

Periodic
High-risk employees

paragraph (i); Informational programs

Inform employees, contractors, subcontractors (or their representatives) involved in site work of the nature, level, and degree of exposure expected Requirement under paragraph (b)

paragraph (j); Handling drums and containers

Procedures for handling, sampling, labeling, transporting, and disposing of hazardous wastes, radioactive waste, shock-sensitive waste, and laboratory waste packs
Tank and vault procedures

paragraph (k); Decontamination

Procedures for: Routine and emergency decontamination of personnel and equipment Showers, changing rooms, commercial laundries, and cleaning establishments

Definitions

paragraph (l); Emergency response by employees at uncontrolled hazardous waste sites

Elements of an emergency response plan Procedures for handling emergency incidents Exemption if complying with 29 CFR 1910.38(a)
Procedures

Definitions

paragraph (m); Illumination

Minimum illumination intensity table
Based on types of operations performed

paragraph (n); Sanitation at temporary workplaces

Potable and nonpotable water separate
Toilet facilities, given number of employees Wash facilities near workplace Showers for operations >6 months Change rooms must meet 29 CFR 1910.141(e)

paragraph (o); New technology programs

Develop and implement procedures to improve protection Provide to OSHA upon request for evaluation and sharing

paragraph (p); Certain operations conducted under the Resource Conservation and Recovery Act of 1976 (RCRA)
Applies to TSD facilities regulated under 40 CFR Parts 264 and 265 Many sections refer to paragraphs (b) through (o)

Definitions

paragraph (q); Emergency response to hazardous substance releases

Emergency response personnel not identified in paragraphs (a)(1)(i) through (a)(1)(iv)
Exempt if covered under Emergency Planning and Community Right-To-Know Act of 1986

Emergency Response Training

29 CFR 1910.120 (q)

Awareness level Operations level Technician level Specialist level Incident Commander

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Awareness Level Training

Intended for those that may witness and report a spill only. No other actions can be taken Initial and refresher training required. OSHA has set no time limits on length of training

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Operations Level Training

Intended for those that will respond in a defensive mode only Initial training of 8 hrs. Annual refresher required

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Technician Level Training

Intended for those that will respond aggressively to a spill to stop the leak at the source Initial training of 24 hrs. Annual refresher training thereafter

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Specialist Level
Specialists have received technician level training and have additional knowledge of the chemicals/hazards involved Initial training of 24 hrs. Annual refresher training thereafter

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Incident Commander
Individuals are trained to the operations level and have authority to direct resources (equipment & personnel) Initial 24 hrs. training. Annual refresher training thereafter

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REGULATORY OVERVIEW
Appendix A Appendix B Appendix C Appendix D Appendix E
(Appendix A E): PPE Test Methods Levels of Protection Compliance Guidelines References Training Curriculum Guidelines

REGULATORY OVERVIEW
Potentially applicable OSHA regulations (not inclusive): 29 CFR 1910.38 29 CFR 1910.95 29 CFR 1910.1096 29 CFR 1910.134 29 CFR 1910.146 29 CFR 1910.147 Emergency Action Plans Occupational Noise Exposure Ionizing Radiation Respiratory Protection Confined Space Entry Lockout/tagout

Summary
Have the ability to locate the OSHA Regulations Understand basic health and safety concepts as applicable to OSHA 1929.120 Identify the chapters of OSHA 1912.120 that apply to your worksite Identify regulatory exposure limits for potential contaminants Discuss engineering controls, work practices, and PPE to minimize risk to workers

QUESTIONS ?