Hazwoper hazardous waste site 40 hour student initial course manual

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Copyright 2012 www.environmentaleducation.com Hazwoper Hazardous Waste Site-40 Hour Course Description: This course provides occupational health and safety training to technical/field personnel involved in site activities including; initial site characterization, field investigation, and remediation operations. The basic components of the Program are designed to provide workers with training specific to the types of health and safety hazards present at typical. This course meets OSHA & EPA requirements. Those working in hazardous waste cleanups, including removal of PCBs, should attend. This five-day course satisfies the training requirements of 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response. To register for a course near you call 888.436.8338 or email [email protected] today. To register online follow the link below: http://www.environmentaleducation.com/store/viewCourse.asp?courseId=6 Environmental Education Associates is a leader in certified environmental and safety training, serving Metropolitan New York City, Long Island, and greater New York State with Training Centers in: Brooklyn, Buffalo, Rochester and Syracuse.

Transcript of Hazwoper hazardous waste site 40 hour student initial course manual

  1. 1. Copyright 2012 www.environmentaleducation.com Hazwoper Hazardous Waste Site-40 Hour Course Description: This course provides occupational health and safety training to technical/field personnel involved in site activities including; initial site characterization, field investigation, and remediation operations. The basic components of the Program are designed to provide workers with training specific to the types of health and safety hazards present at typical. This course meets OSHA & EPA requirements. Those working in hazardous waste cleanups, including removal of PCBs, should attend. This five-day course satisfies the training requirements of 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response. To register for a course near you call 888.436.8338 or email [email protected] today. To register online follow the link below: http://www.environmentaleducation.com/store/viewCourse.asp?courseId=6 Environmental Education Associates is a leader in certified environmental and safety training, serving Metropolitan New York City, Long Island, and greater New York State with Training Centers in: Brooklyn, Buffalo, Rochester and Syracuse.
  2. 2. Copyright 2012 www.environmentaleducation.com OSHA HAZARDOUS WASTEOPERATIONS AND EMERGENCYRESPONSE40 HOUR TRAINING STUDENT TRAINING HANDBOOK
  3. 3. Copyright 2012 www.environmentaleducation.com Table of ContentsIntroduction Section 1 Environmental and Safety Regulations Clean Air Act Clean Water Act Resource Conservation and Recovery Act (RCRA Comprehensive Environmental Compensation and Liability Act (CERCLA) Federal Insecticide, Fungicide, and Rodenticide Act Medical Waste Tracking Act Safe Drinking Water Act Toxic Substance Control Act Hazardous Materials Transportation Act Occupational Safety and Health Act Hazardous Waste Operations and Emergency Response Standard Hazard Communication Standard Hazardous Materials Identification Systems Section 2 Hazard Recognition Evaluation & Control Chemical HazardsPhysical HazardsBiological HazardsRadiation HazardsConfined Space HazardsPhysiological HazardsEnvironmental HazardsSection 3 Monitoring Instruments Characteristics of Air Monitoring InstrumentsHazardous AtmospheresInstrument ControlsCertificationDirect Read Instruments
  4. 4. Copyright 2012 www.environmentaleducation.com Section 4 Toxicology and Exposure Guidelines Routes of ExposureThe Dose-Response RelationshipSources of Toxicity Information Uses of Toxicity InformationHealth EffectsTypes of Toxic EffectsExposure GuidelinesSection 5 Respiratory Protection Respiratory HazardsThe Respiratory Protection Standard Respiratory Use and SelectionAir Purifying RespiratorsAtmosphere-Supplying RespiratorsSection 6 Protective Clothing and Safety Equipment Performance Requirements For Chemical Protective Clothing Chemical Resistance Classification of Chemical Protective Clothing Protective Materials Heat Stress Levels of Protection Section 7 Site Entry and Reconnaissance Initial AssessmentSite Safety PlanningInitial Site SurveySubsequent Site Characterization
  5. 5. Copyright 2012 www.environmentaleducation.com Section 8 Decontamination Decontamination Plan and ObjectivePrevention of Contamination Factors of ContaminationDecontamination MethodsSelection of Decontamination EquipmentZone LayoutDecontamination SolutionsStandard Operating ProceduresDecontamination of EquipmentDecontamination Worker Protection Medical Emergency DecontaminationEffectiveness of DecontaminationDisposal of Decontaminated MaterialsSection 9 Site Organization and Management OrganizationManaging Site OperationsSafety Meetings and InspectionsSection 10 Safety Planning/Emergencies and Emergency Preparedness Site Health and Safety Plan (HASP)Emergency Preparedness and Contingency Planning Confined Space ConcernsAppendix A Abbreviations and Acronyms Appendix B Glossary Appendix C References and Information Sources Appendix D OSHA Standard 29 CFR 1910.120
  6. 6. Copyright 2012 www.environmentaleducation.com HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSEHEALTH AND SAFETY TRAINING COURSETraining Objectives This course is designed for personnel who are involved with the investigation and remediation of uncontrolled hazardous waste sites, or who are active in other operations or activities at sites that use or used hazardous materials/substances or produced hazardous waste. To a lesser extent, it is designed for personnel who respond to accidents or releases of hazardous materials. It provides basic information needed to meet the requirements of 29 CFR 1910.120, "Hazardous Waste Operations and Emergency response." The course, along with this manual, provides specific information needed to evaluate site hazards and implement safety procedures to protect the health and safety of site personnel. The objective of this course is to instruct participants in the: Methods and procedures for recognizing, evaluating and controlling site hazards Concepts, principles, guidelines and regulations for protecting the health and safety of site personnel Fundamentals of management and organization of site operations Use of personal protective equipment and direct-reading monitoring instruments Manual Objectives This manual is a guidance document for personnel responsible for occupational health and safety at work sites containing hazardous materials/substances/waste or other hazardous conditions. It is intended for use as: A supplement to the HAZWOPER training course An educational tool to provide a comprehensive overview of health and safety protection at contaminated and hazardous substances/waste sites A reference document for site personnel to overview important aspects of health and safety This manual is not a detailed industrial hygiene textbook or a comprehensive book on occupational health and safety. It provides general guidance and must be used as a preliminary reference for developing proper safety guidelines and programs. The appropriateness of information provided should always be evaluated with regard to site-specific conditions. Other sources and experienced personnel should be consulted as necessary for the detail required to design and implement occupational health and safety programs at specific sites. Although this manual cites specific federal and/or State regulations it is not a definitive legal document and should not be used as such. Individuals responsible for the health and safety of site personnel should obtain and comply with the most recent, applicable regulations and are urged to consult with appropriate federal, provincial, state and local agencies. No warranty, guarantee, or representation, expressed or implied, is made by or on behalf of Environmental Education Associates as to the absolute correctness or sufficiency of any representation contained in this document. The mention of a product or company does not constitute endorsement by Environmental Education Associates.
  7. 7. Copyright 2012 www.environmentaleducation.com SECTION I. ENVIRONMENTAL AND SAFETY REGULATIONS SECTION OBJECTIVES After reading this section, the student will have an increased knowledge of: The basic environmental and safety regulations of the United States; Requirements for hazardous waste/material/substance site operations; Site safety requirements; The identification of regulatory agency responsibilities. SECTION OUTLINE This section is an overview of US environmental regulations and standards: U.S. Occupational Safety Regulations: Occupational Health and Safety Act, Hazardous Waste Operations and Emergency Response Standard, and the Hazard Communication Standard. U.S. Environmental Regulations: Clean Air Act, Clean Water Act, Resource Conservation and Recovery Act, Comprehensive Environmental Responsibility and Cleanup Liability Act, Federal Insecticide, Fungicide and Rodenticide Act, Emergency Planning and Community Right-To-Know Act, Hazardous Materials Transportation Act, Medical Waste Tracking Act, Safe Drinking Water Act, and the Toxic Substances Control Act. 1
  8. 8. Copyright 2012 www.environmentaleducation.com UNITED STATES ENVIRONMENTAL AND SAFETY REGULATIONS OVERVIEW 1.1.1 Clean Air Act Air pollution has long been a major domestic environmental problem. The most frequently cited air pollution tragedy occurred in the industrial town of Donora in Pennsylvania in November, 1948. During this smog event, nearly half of Donoras 14,000 residents became sick and 20 died from a four-day fog containing enormous loads of suspended particulates and acid mists converted from the emission of sulfur dioxide and nitrogen oxides. The extensive use of automobiles coupled with a prevalent Pacific high pressure system has kept Los Angeles, California on constant alert for air pollution episodes from photochemical smog or oxidants. The harmful effects of photochemical oxidants on the public health and welfare had been well documented. These modern air pollution problems from motor vehicle emissions are shared by many other urbanized metropolitan areas throughout the country. In response to these and other air pollution problems, the Clean Air Act (CAA) was enacted on December 17, 1963 as Public Law PL 88 - 206. Since its passage, air pollution research activities and investigations have identified additional or new air pollution problems. Consequently, the CAA has been amended 15 times. The last amendments (on October 22, 1990) triple the length of the previous Act and significantly increased its complexity with requirements milestones reaching well into the twenty-first century. PURPOSE The CAA and its amendments governs and guides the effort to: Improve the nation's air quality conditions to reduce and eventually eliminate adverse effects of air pollution on public health and welfare; Maintain and prevent designated areas from air-quality degradation, where existing air- quality conditions are documented to be in total compliance with the applicable national ambient air quality standards; Provide research, investigations, and surveys to gain required scientific data on national and global air pollution problems so that appropriate preventive measures can be developed and implemented; Develop effective and practical processes, methods, strategies, programs, and prototype devices for the prevention of air pollution and the reduction and elimination of mobile and stationary pollution sources; and 2
  9. 9. Copyright 2012 www.environmentaleducation.com Train personnel and disseminate information to the public so that environmentally sound, institutionally acceptable, and cost-effective air pollution control strategies, programs, and plans are implemented. BASIC ELEMENTS The 1990 Clean Air Act amendments contain 11 titles; Title I: Attainment and Maintenance of National Ambient Air and Quality Standards Title II: Mobile Sources Provisions Title III: Hazardous Air Pollutants Title IV: Acid Deposition Control Title V: Permits Title VI: Stratospheric Ozone Protection Title VII: Enforcement Title VIII: Miscellaneous Provisions Title IX: Research Title X: Disadvantaged Business Concerns Title XI: Employee Transition Assistance 1.1.2 Clean Water Act The Federal Water Pollution Control Act, commonly referred to as the Clean Water Act (CWA), was passed in 1956. The 1956 Act was amended by the Water Quality Act of 1965, the Clean Water Restoration Act of 1966, and the Water Quality Improvement Act of 1970. In 1972, the Federal Water Pollution Control Act Amendments, (PL 92-500) completely replaced the original 1956 Act and its amendments. Subsequent modifications to the CWA occurred through passage of amendments in each of the years 1973-1983, and again in 1987 (PL 100-4). PURPOSE The CWA is to provide for the restoration and maintenance of the chemical, physical, and biological integrity of the waters of the United States. This is reflected in a variety of national goal and policy statements included in the Act; (1) the elimination of pollutants discharged to navigable waters; (2) the maintenance of water quality sufficient for the protection and propagation of fish, shellfish, and wildlife and for recreation in and on the water; and (3) the prohibition of toxic discharges. 3
  10. 10. Copyright 2012 www.environmentaleducation.com BASIC ELEMENTS The CWA is divided into six titles, each of which is subdivided into multiple sections. The basic components of the six titles and their sections are: Title I: Research and Related Programs Title I encourages and supports (including financial assistance) the development of cooperative and other research, development, and demonstration programs and projects for better understanding and control of water pollution, including administration of such programs. Title II: Grants for Construction of Treatment Works The purpose and central focus of Title II is to require and assist (including financial support) the development and implementation of waste treatment management plans and practices intended to achieve the goals of the CWA. Title III: Standards and Enforcement Title III includes the related topics of effluent limitations; water quality standards and criteria; new source performance standards; inspections and monitoring; and enforcement. Title IV: Permits and Licenses Title IV is the permitting of dischargers and the management of pollutants in receiving waters. Title V: General Provisions This Title provides for the administrative management and oversight of the various programs and initiatives of the CWA. Title VI: State Water Pollution Control Revolving Funds Revolving funds were added to the CWA by the 1987 amendments (PL 100-4), as a means of financing the construction of municipal wastewater treatment facilities following the phase-out of funding under 201 of the CWA. 1.1.3 Resource Conservation and Recovery Act (RCRA) The Solid Waste Disposal Act (SWDA) was passed in 1965 with the purpose of funding research and providing technical assistance to state and local planners faced with the task of disposing of solid waste generated by residential, commercial and industrial. In 1970 SWDA was enlarged and restructured in the form of the Resource Recovery Act which promoted the adoption of sanitary landfills and encourage a shift from mere disposal toward conservation, recycling, and advanced control technology. Up to this point the legislation has focused mainly on the traditional kinds of municipal trash-paper, glass, cans, and garbage. However mounting scientific evidence indicated that waste generated by chemical and other industrial processes could be 4
  11. 11. Copyright 2012 www.environmentaleducation.com hazardous. Therefore, in 1976 Congress passed the Resource Conservation and Recovery Act (RCRA) as an amendment to the Solid Waste Disposal Act. Under RCRA, EPA set standards for generators and transporters of hazardous waste and for owners and operators of hazardous waste treatment, storage and disposal facilities. This cradle- to-grave system has brought under regulation over 52,000 waste generators, approximately 12,000 transporters, and 5,000 treatment, storage and disposal facilities. Congress reauthorized and amended RCRA in 1984, imposing new and far-reaching requirements and vastly expanding the size of the regulated community. The Hazardous and Solid Waste amendments (HSWA) of 1984 applied to 175,000 small quantity generators and owners of over 1 million underground storage tanks that had not been previously regulated. Additional controls were also placed on the disposal of wastes in landfills and on the burning of waste derived fuels. PURPOSE The RCRA establishes a national policy of the United States that, "wherever feasible, the generation of hazardous waste is to be reduced or eliminated as expeditiously as possible. Waste that is nevertheless generated should be treated, stored, or disposed of so as to minimize the present and future threat to human health and the environment. That policy is executed through the statement of 11 objectives to the Act: Providing tentacle and financial assistance to the states; Providing training grants; Prohibiting future open dumping and requiring the conversion of existing open dumps to suitable facilities; Assuring that hazardous waste practices are conducted in a manner that protects human health and the environment; Requiring that hazardous wastes are properly managed in the first instance thereby reducing the need for corrective action in the future; Minimizing the generation of hazardous waste; Establishing a Federal State partnership to implement the Act; Promulgating guidelines for solid waste collection, transport, separation, recovery, and disposal systems; Promoting research and development programs; 5
  12. 12. Copyright 2012 www.environmentaleducation.com Promoting demonstration projects; and Establishing a cooperative effort among federal, state, and private enterprise in order to recover valuable materials and energy from solid waste. BASIC ELEMENTS The RCRA is divided into nine main subsections (Subtitles A through I) which are implemented through the Code of Federal Regulations Title 40 (40 CFR) parts 240 through 300. The subtitles to cover the following subjects: Subtitle Subjects A General provisions including objectives and definitions B Authorization and structure of the agencies administering the law C Hazardous waste management D State and regional solid waste plans E Resource recovery F Federal responsibilities for compliance with the law G Miscellaneous provisions including citizen suits and imminent hazards H Research and development I Underground storage tanks 1.1.4 Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) In 1980, Congress enacted the Comprehensive Environmental Response, Compensation, and Liability Act, usually referred to as CERCLA or "Superfund". Extensive amendments to CERCLA were enacted in 1986 (Superfund Amendments and Reauthorization Act or "SARA"). CERCLA/SARA activities are typically funded out of a special "Superfund" trust fund, in lieu of general revenues which provide funding for most other Federal environmental programs. The fund was established by enacting special industry taxes. PURPOSE The scope of CERCLA/SARA is far broader than any other Federal environmental statutes. CERCLA/SARA covers all environmental media: air, surface water, groundwater, soil, and bio- hazards. CERCLAS/SARA provides for a Federal response to uncontrolled releases of hazardous 6
  13. 13. Copyright 2012 www.environmentaleducation.com substances from a vessel or any offshore or onshore facility and can cover any type of industrial, commercial, or non-commercial facility, even if there are other regulations affecting the facility. CERCLA/SARA vests the response authority with the President. The President, by Executive Order 12580 issued on January 23, 1987, delegated the overall lead responsibility for implementing CERCLA/SARA to the EPA. The Coast Guard was delegated the responsibility for emergency response actions in the coastal zone, Great Lakes, and harbors. The Department of Defense was made responsible for uncontrolled or unpermitted environmental releases of hazardous substances from its vessels and facilities, including defense installations and bases throughout the country. Evacuation and relocation responsibilities were delegated to the Federal Emergency Management Agency (FEMA). BASIC ELEMENTS Title I: Hazardous Substances Releases, Liability, Compensation Defines the reporting, cleanup, and response requirements for both past hazardous substance sites and those where there is a current unpermitted release or a threat of an unpermitted release into the environment of a hazardous substance, pollutant, or contaminent. This Title also defines the liabilities of a potentially responsible party. Title II: Hazardous Substance Response Revenue Act of 1980 Establishes the taxing authority under which the initial trust fund was established. Title III: Emergency Planning and Community Right-to-Know Established a new law, which requires establishment of State Emergency Response Commissions, Regional Emergency Planning Districts, and Local Emergency Planning Committees. It also requires that facilities that utilize certain chemicals participate in the emergency response local planning effort, including the identification of chemicals stored on site and their locations. Furthermore, this Title establishes requirements for notifying the public when releases of certain chemical substances occur and, under certain conditions for toxic chemical releases, and an annual report of the total amount of toxic chemicals released. The above information is usually available to the public upon request. Title IV: Radon Gas and Indoor Air Quality Research Establishes a research program on radon gas and indoor air quality to gather data and information and coordinate Federal, State and local and private development efforts relating to the improvement of indoor air quality. 7
  14. 14. Copyright 2012 www.environmentaleducation.com Title V: Amendments to the Internal Revenue Code of 1986 Establishes the funding source for the extension of CERCLA, as enacted by SARA, and a Leaking Underground Storage Tank Trust Fund and its revenue sources. CERCLA/SARA Liability Of Responsible Parties And Cost Recovery CERCLA/SARA authorizes EPA to draw on two types of resources to pay for waste site remediation: The Federal trust fund (Superfund), and responsible parties (RPs). CERCLA/SARA states that RPs may be under 107(d)(3) of CERCLA/SARA, any person who is liable for a release or threat of release of a hazardous substance that fails to properly provide for the removal or remedial action upon order of the President (or authorized representative), without sufficient cause, may be held liable for punitive damages in an amount up to three times the amount of the cost incurred for the site cleanup. These punitive damages are in addition to the other liabilities the RP may incur under CERCLA/SARA. These liability provisions mandate that CERCLA/SARA liabilities be: Retroactive, RPs are liable for acts or omissions occurring well before the date of CERCLAs enactment. Strict, it is irrelevant that a hazardous waste generator selected a licensed hauler to take waste to a licensed landfill, even under the conditions that all legal requirements at the time were fully met and/or that the parties used all due care; Jointly and several, one party out of many may be held liable for more than his/her share under fair allocations and may in fact be held liable for the entire cleanup cost. Title III of SARA will be discussed further in the following subsection. 1.1.4.1 Emergency Planning And Community Right-To-Know Act (Title III of SARA) When CERCLA was amended in 1986 by SARA, there were three Titles of SARA that did not directly amend the statutory provisions of CERCLA; that is, they were newly created sections that were added to CERCLA by Congress over the 19 months that SARA was debated. One of these, Title III, is called the Emergency Planning and Community Right-To-Know Act. Nothing in this new Act supersedes or amends the reporting requirements under CERCLA. This new Act builds upon CERCLA reporting requirements and provides a new Federal/State/local infrastructure to ensure that the response to reported releases may be better organized and would- be-disasters can be better headed off. This Act required the establishment of State Emergency Response Commissions, Emergency Planning Districts, and Local Emergency Planning 8
  15. 15. Copyright 2012 www.environmentaleducation.com Committees; and establishes the responsibility of each in creating and implementing the comprehensive emergency response plan required under 303. PURPOSE Enactment of this law was prompted by such disastrous chemical release incidents as in Institute, West Virginia and Bhopal, India. According to the Congressional Record, [Title III] will be critical to communities in alerting them to the dangerous chemicals present in their communities, and in laying the foundation for effective emergency response management. The right-to-know means public information about what hazardous substances are being stored and released into the environment in our communities. It means planning for emergency releases before they happen. It means that our citizens and our emergency response personnel will be safer and better prepared for the threats from chemical releases. It means that this nation will not tolerate Bhopal or Chernopyl-type tragedies. BASIC ELEMENTS Subtitle A Emergency Planning and Notification Subtitle B Reporting Requirements Subtitle C General Provisions 1.1.5 Federal Insecticide, Fungicide, and Rodenticide Act The Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) was enacted by Congress in 1947 to regulate the formulation and use of pesticides in the United States. A pesticide is defined as any substance intended to prevent, destroy, repel, or mitigate any pests (broadly including both plants and animals). The original Act was amended in 1972, 1975, 1978, 1980, and recently reauthorized in September, 1988. The 1972 amendment (Federal Environmental Pesticide Control Act, or FEPCA) was essentially a complete rewriting of the law. PURPOSE Prior to 1970 the United States Department of Agriculture (USDA) enforced FIFRA and was mainly concerned with the registration and labeling of pesticides. In 1970, the EPA was created and inherited the Pesticide Division from the USDA. As a result of the 1972 amendments to FIFRA, health and the environment became the main enforcement issues. 9
  16. 16. Copyright 2012 www.environmentaleducation.com BASIC ELEMENTS The key elements of FIFRA deal with the registration of pesticides and enforcement of the Act. They mainly apply to manufacturers, formulators, and distributors of pesticide. Regulations on the proper use, storage, and disposal of pesticides andpesticide containers may apply to all facilities. Key regulatory requirements under FIFRA are: Registration Classification of Pesticides Cancellation and Suspension Orders Protection of Trade Secrets Imports and Exports Storage and Disposal Pre-Disposal Procedures for Pesticides Disposal Procedures for Pesticides Disposal Procedures for Pesticide Containers and Residues Experimental Use Permits Pesticides Regulated Under Other Federal Statutes Disposal Procedures for Cancelled or Suspended Pesticides Storage Procedures for Pesticides and Pesticide Containers Disposal of Pesticides and Pesticide Containers 1.1.6 Medical Waste Tracking Act Recent public health concerns over the increasingly frequent appearance of medical wastes on public beaches and in the environment in general prompted Congress two amend RCRA (Subtitle J) through enactment of the Medical Waste Tracking Act of 1988. Regulations enacting the Medical Waste Tracking Act are promulgated in 40 CFR 259 (Standards for the Tracking and Management of Medical Waste) and are administered by the U.S. EPA. PURPOSE The 40 CFR 259 regulations established a two-year demonstration program in 1991 for tracking medical wastes, from generation to ultimate disposal. BASIC ELEMENTS Medical wastes are defined as " Any solid waste which is generated in the diagnosis, treatment, or immunization of human beings or animals, in research pertaining thereto, or in the 10
  17. 17. Copyright 2012 www.environmentaleducation.com production or testing of biologicals.. Specific types of wastes regulated in the tracking program include: Cultures and stocks of infectious agents and associated biologicals; Human pathological wastes, including tissues, organs, and body fluids; Human blood and blood products; All used sharp implements such as needles and scalpels, and certain other glassware items; Contaminated animal carcasses, body parts, and bedding of animals exposed to infectious agents in research; Wastes from patients isolated with highly communicable diseases, or isolated animals known to be infected with highly communicable diseases; and Unused but discarded sharps, including hypodermic needles, suture needles, syringes, and scalpel blades. The demonstration program includes specific requirements for segregating, packaging, labeling, marketing and storing medical wastes before they are shipped for disposal. The medical waste tracking and management system is fundamentally similar to RCRAs existing system for hazardous waste tracking and management. The medical waste demonstration system utilizes "Medical Waste Tracking Form, with "comeback" copies returned to the generator from the disposer, and custody information is required from the generator, transporter, and the disposer. 1.1.7 Safe Drinking Water Act The Safe Drinking Water Act (SDWA) was passed in 1974 to amend the earlier Public Health Service Act. The SDWA was subsequently amended in 1977, 1979, 1980, and 1986. The current, 1986 amendments are codified is public law 99 339. PURPOSE The purpose of the SDWA is to ensure the safety of public drinking water supplies. It extends to protection of underground sources (aquifers), through various means, including controls on the use of injection wells for the disposal of wastes. The 1986 amendments significantly increase the regulatory importance of the SDWA, reflecting the increasing public and political awareness of drinking water contamination issues. 11
  18. 18. Copyright 2012 www.environmentaleducation.com BASIC ELEMENTS Although many objective elements of the SDWA exist in parallel in the CWA, the SDWA is a separate regulatory program. This program provides for the following basic activities: EPA promulgation of National Primary Drinking Water Regulations (NPDWRs) and parallel Maximum Contaminant Level Goals (see LG's) for 83 contaminants, by June, 1989; EPA review and updating of the original list of 83 contaminants (followed by promulgation of supplemental NPDWRs and MCLGs, as necessary) every three years; EPA promulgation of National Secondary Drinking Water (SDWRs); EPA promulgation of regulations requiring specific water treatment techniques (filtration and disinfection), depending on the water source and other factors; and, Provisions to allow program delegation to the States. In addition, the 1986 amendments included assorted provisions to: Prevent the use of lead in water distribution systems, Control the use of underground injection wells, Recognize and protect "sole-source" aquifers, and Develop wellhead potential programs. 1.1.8 Toxic Substance Control Act In the late 1960s, national concern began to arise over the proliferation of toxic chemicals and other hazardous substances. Thousands of carcinogenic (cancer-causing), teratogenic (birth defect-causing), and mutagenic (genetic-damaging) substances were already present in the environment, an estimated 2 million chemical compounds have been identified, and thousands of new substances were being developed every year. PURPOSE Existing laws, such as the Clean Air Act, the Clean Water Act, the Resource Conservation and Recovery Act, regulate chemical substances only when they are released to the environment. Congress recognized the need for a law to require testing and controls of toxic chemicals having potential adverse health or environmental effects before their production phase; and hence, passed the Toxic Substances Control Act (TSCA, PL 94-469) in 1976. 12
  19. 19. Copyright 2012 www.environmentaleducation.com TSCA gives that EPA authority to (1) require testing of both existing and new chemical substances (including those propagated through genetic engineering) posing potential adverse effects of public health or the environment; and (2) regulate them, where necessary. This authority supplements 112 and 307, respectively, of the Clean Air Act and Clean Water Act, and also 6 of the Occupational Safety and Health Act (OSHA). In 1986, the Asbestos Hazard Emergency Response Act (PL-99-519) was added to the TSCA as Title II. This amendment established asbestos abatement programs in schools. BASIC ELEMENTS TSCA is composed of: Title I: Control of Toxic Substance (31 Sections); and Title II: Asbestos Hazard Emergency Response (14 Sections). 1.1.9 Hazardous Materials Transportation Act Prior to 1970, the existing regulations pertaining to transportation of hazardous material addressed only explosive or flammable material, and did not directly address the transport of other categories of hazardous materials or waste. These early regulations were provided by Chapter 7- Carriage of Explosives or Dangerous Substances, Title 46-Shipping. In 1970, recognition was given to the need for comprehensive regulations governing the transportation of hazardous materials. Section 1761 Public Law 91 48, enacted October 16, 1970 provided authority to the Department of Transportation (DOT) Secretary of Transportation to establish facilities and technical staff for evaluation of hazards involved in hazard materials transportation, a central reporting system for accidents, and preparation of recommendations regarding transportation of hazardous materials. This led to the development of the Transportation Safety Act of 1974, which was intended as an amendment to the existing regulations. Although the Transportation Safety Act of 1974 was not enacted as such, most of the provisions set forth in the Transportation Safety Act were included in the Hazardous Materials Transportation Act (HMTA), which was enacted on January 3, 1975. HMTA repealed Section 1761 of Public Law 91-458 and replaced it with Chapter 27 Hazardous Materials Transportation, which provided far broader and more specific authority to the Secretary, and which tasked the Secretary to take all steps necessary to bring orders, determinations, rules, and regulations into conformity with the purposes and provisions of Chapter 27. HMTA gave authority to the Secretary of Transportation to designate such quantity 13
  20. 20. Copyright 2012 www.environmentaleducation.com and form of materials by land, water, or air. Bulk shipments by water are excluded since these are regulated by the United States Coast Guard. PURPOSE HMTA establishes the authority of the Secretary of Transportation to protect the Nation against the risks to life and property which are inherent in the transportation of hazardous materials in commerce. This was accomplished by amending the existing fragmented regulations covering hazardous materials transportation (contained in titles for railroads, shipping, and transportation) and enacting new legislation under transportation that provided the Secretary with the authority to develop regulations governing the safety aspects of the packing, repacking, handling, labeling, marking, placarding, and routing of hazardous materials, and the manufacture, fabrication, marking, maintenance, reconditioning, repairing, or testing of packaging or containers in which hazardous materials are transported. HMTA also established the authority to develop criteria for handling hazardous materials including personnel training, type and frequency of inspections, equipment to be used for control of risks, specifications regarding equipment and facilities used in the handling and transport, and the system of monitoring safety assurance procedures. BASIC ELEMENTS The Hazardous Material Regulations (49 CFR 171 to 195) implementing HMTA are contained in Subchapter C of Title 49 of the Code of Federal Regulations and are administered by the Materials Transportation Bureau of DOT. The following list provides a summary of the regulations administered by DOT and provides citations of the sections which are of primary concern. General Information, Regulations, and Definitions 49 CFR 171 o Section 171.15 Immediate notice of certain hazardous material incident o Section 171.16 Detailed hazardous materials incident reports o Section 171.17 Hazardous substances discharge notification Hazardous Materials Tables and Communications Regulations 49 CFR 172 o Subpart B - Hazardous materials table (descriptions, shipping names, class, labeling) o Subpart C - Shipping papers (hazardous waste manifest) o Subpart D - Marking 14
  21. 21. Copyright 2012 www.environmentaleducation.com Section 172.304 - Marking requirements Section 172.308 - Authorized abbreviations Section 172.312 Hazardous substances o Subpart E Labeling o Subpart F Placarding Shippers General Requirements for Shipments and Packaging 49 CFR 173 o Subpart A- General Section 173.2 - Classification of a material having more than one hazard o Subpart B - Preparation of Hazardous Materials for Transportation o Subpart C - Explosives and blasting agents; definition and preparation o Subpart D - Flammable, Combustible, and Pyrophoric liquids; definitions and preparation o Subpart E Flammable Solids, Oxidizers, and organic peroxides o Subpart F - Corrosive Materials; definition and preparation o Subpart G - Compressed gases; definition and preparation o Subpart H - Poisonous materials, etiologic agents, and radioactive materials o Subpart K - Other regulated material; ORM - A o Subpart L - Other regulated material; ORM - B o Subpart M - Other regulated material; ORM - C o Subpart N - Other regulated material; ORM - D o Subpart O - Other regulated material; ORM - E Carriage By Rail 49 CFR 174 Carriage By Aircraft 49 CFR 175 Carriage By Vessel 49 CFR 176 Carriage By Public Highway 49 CFR 177 15
  22. 22. Copyright 2012 www.environmentaleducation.com Shipping Container Specifications 40 CFR 178 Specifications For Tank Cars 40 CFR 179 REVISIONS In 1990, the Department of Transportation promulgated a comprehensive revision of the hazard communication and packaging requirements of the Hazardous Materials Regulations. These regulations amend 40 CFR 107 and 171 through 179. The changes make the regulations more consistent with the international United Nations standards and approach to hazardous material transportation. A key feature of the revised regulations is the introduction of performance oriented packaging standard in accordance with the recommendations adopted by the United Nation's Committee on the Transport of Dangerous Goods. Besides establishing performance oriented packaging criteria, the revised regulations include; Consolidating hazardous materials tables into a single table; Eliminating approximately 100 packaging specifications; Replacing US measurement units with standard international units; Using class names, descriptions, and definitions based on UN recommendations; Using packaging group, vapor pressure and chemical compatibility as the basis for packaging requirements; Requiring vibration test for non-bulk packaging; Requiring minimum thicknesses for reuse of plastic and metal drums; Tightening packaging provisions for materials that are poisonous by inhalation; Establishing criteria for defining gases that are poisonous by inhalation; and, Replacing 100 DOT non-bulk packaging standards with 20 U.N. standards. Compliance dates for various segments of the new Hazardous Materials Regulations were: October 1, 1996 for the continued use of packaging authorized by September 30, 1991; 16
  23. 23. Copyright 2012 www.environmentaleducation.com October 1, 1994 for the continued use of packaging made obsolete by the new regulations; and, October 1, 1993 for all other provisions. 1.1.10 Occupational Safety And Health Act In reaction to significant loss of life and money resulting from job site injuries, the United States Congress enacted the Occupational Safety and Health Act in 1970 (OSH Act). The OSH Act was designed to achieve the goal of "assuring so far as possible every working man and woman in the Nation safe and healthy working conditions (29 USC 651(b)) and is administered by the Occupational Safety and Health Administration (OSHA). The OSH Act applies to 5.9 million employers and 88.7 million employees. The four (4) categories of people not covered under the Act are listed below. Almost all other workers, including consulting engineers and their employees, are covered. Self - employed persons; Farms at which only immediate members of farm employers family are employed; Workers covered by other legislations; State and local government employees. OSHAs ultimate goal is to promote health and safety in the work place. This strategy includes: Education and consultation; Civil citations; Criminal prosecution; and, State enforcement activities. PURPOSE OSHA established a National policy in the United States that is summed up in the Acts General Duty Clause (29 USC 654) which states that each employer: 1) Shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; 17
  24. 24. Copyright 2012 www.environmentaleducation.com 2) Shall comply with occupational safety and health standards promulgated under this Act. Also that each employee shall comply with occupational safety and health standards and all rules, regulations, and orders, issued pursuant to this Act which are applicable to his own actions and conduct. OSHA has the authority to promulgate national health and safety standards through its administrative rule making process, 29 USC 655. Standards are specific to an industry or particular work place environment. OSHA has two standing advisory committees: National Advisory Committee on Occupational Safety and Health Advisory Committee on Construction Safety and Health In addition, the National Institute for Occupational Safety and Health (NIOSH) makes recommendations for standards, conducts research, and provides technical assistance to OSHA. NIOSH may require employers to: Measure and report employee exposures to potentially hazardous materials; Provide medical examinations and tests to determine incidence of occupational illness among employers. BASIC ELEMENTS OSHA requirements are published in the following two standards: 29 CFR Parts 1900 to 1910: Occupational Safety and Health Standards; 29 CFR Part 1926: Construction Standards The following elements of 29 CFR 1910 are directly applicable to hazardous waste site work: Subpart C: General Safety and Health Provisions Subpart D: Walking and Working Surfaces Subpart E: Means of Egress Subpart H: Powered Platforms, Manlifts and Vehicle Mounted Work Platforms Subpart G: Occupational Health and Environmental Control, Ventilation, Noise, Ionizing and Non-Ionizing Radiation Subpart H: Hazardous Materials 18
  25. 25. Copyright 2012 www.environmentaleducation.com Subpart I; Personal Protection Subpart J: General Environmental Controls Subpart K: Medical and First Aid Subpart L: Fire Protection Subpart M: Compressed Gas and Compressed Air Equipment Subpart N: Materials Handling and Storage Subpart O: Machinery and Machine Guarding Subpart P: Hand and Portable Powered Tools Subpart Q: Welding, Cutting, and Brazing Subpart R: Special Industries Subpart S: Electrical Subpart T: Commercial Diving Operations Subpart Z: Occupational Health and Environmental Controls 1.1.10.1 Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard In response to the increasing worker population involved with hazardous waste site operations, OSHA promulgated HAZWOPER regulations in 1986. These regulations apply to workers at: 1) CERCLA (Superfund) or other Federally funded hazardous waste sites; 2) State or locally funded or voluntary cleanup of hazardous waste sites conducted at the direction of or recognized by State or regulatory agency; 3) Corrective actions at RECRA facilities; 4) Operations involving hazardous waste at RECRA facilities; 5) Emergency response operations involving hazardous waste/substances. PURPOSE The purpose of the HAZWOPER Standard is to provide regulations that are directly applicable to hazardous waste and selected hazardous material containing sites. BASIC ELEMENTS The general requirements of HAZWOPER are with their appropriate paragraphs noted: 19
  26. 26. Copyright 2012 www.environmentaleducation.com 1) Safety and health program (b) 2) Site characterization and analysis (c) 3) Site control (d) 4) Training (e) 5) Medical surveillance (f) 6) Engineering controls, work practices, and personal protective equipment (g) 7) Monitoring (h) 8) Informational programs (i) 9) Material handling (j) 10) Decontamination (k) 11) Emergency response at uncontrolled hazardous waste sites (l) 12) Illumination (m) 13) Sanitation (n) 14) New technology programs (o) 15) Certain operations conducted under RECRA (p) 16) Emergency response to releases by employees not previously covered (q) 1.1.10.2 Hazard Communication Standard OSHA Hazard Communication Standard was first promulgated in 1983, and is printed in 29 CFR Part 1910.1200. The Standard was developed to inform workers exposed to hazardous chemicals of the risks associated with those chemicals. The purpose of the Standard is to ensure that: The hazards of all chemicals produced or imported are evaluated, and Information concerning chemical hazards is transmitted to employers and employees. Hazard information must be transmitted from manufacturers to employers via material safety data and container labels. This information must be transmitted from employers to employees by 20
  27. 27. Copyright 2012 www.environmentaleducation.com means of comprehensive hazard communication programs which include material safety data sheets (MSDS), container labels, and employee information and training programs. PURPOSE The Federal Hazard Communication standard is designed to comprehensively address the issue of evaluating and communicating hazards. BASIC ELEMENTS The Hazard Communication Standard contains several basic requirements designed to protect the health and safety of employees. Not all these requirements must be met by all employers. For example, chemical manufacturers must comply with most of the hazard communicating requirements while employers having operations where hazardous chemicals are only handled in sealed containers must comply with only four requirements. The basic requirements of the Hazard Communication Standard are: Determine Hazards Evaluate chemicals produced in or imported into the U.S. to determine if those chemicals are hazardous. Consider available scientific evidence concerning such hazards and document the procedures used to determine the hazards of each chemical. Compose Material Safety Data Sheets (MSDS) Obtain or develop a material safety data sheet for each hazardous chemical. The MSDS must include information which reflects the scientific evidence used in making the hazard determination and must be updated within three months of learning significant information about the hazards of a chemical or ways to protect against the hazards. Provide Customers with MSDS and Warning Labels Provide customers with an MSDS and for each hazardous chemical they purchase with the initial shipment and with the first shipment after any update of the information contained in the MSDS. Place warning labels on each container of hazardous chemicals leaving the workplace which includes the identity of the chemical, appropriate hazard warnings, and the name and address of the manufacturer, importer or responsible party. Have a MSDS Available for Every Hazardous Chemical Keep a MSDS on file for every hazardous chemical present or used in the workplace. Keep MSDSs readily accessible during each work shift and inform employees how to obtain MSDSs. If employees travel between work places during a work shift, the MSDSs 21
  28. 28. Copyright 2012 www.environmentaleducation.com may be kept at a central location at the primary work place as long as information is immediately available in the event of an emergency. Label Containers Ensure that all containers of hazardous chemicals in the work place are clearly labeled with the identity of the hazardous chemical and appropriate hazard warnings. Do not remove or deface labels on incoming containers of hazardous chemicals. Inform and Train Employees Inform all employees before their initial assignment or whenever a new hazard is introduced into their work area of the requirements of the standard, operations in their work area where hazardous chemicals are present, and the location and availability of the written Hazard Communication Program. Train employees how to identify and protect themselves from chemical hazards in the work area, how to recognize the physical and health hazards of chemicals in their work area, and details of how to obtain and use the employers written hazard communication program and appropriate hazard information. Prepare a Written Hazard Communication Program Develop, implement, and maintain a written hazard communication program for each work place that describes how material safety data sheet, labeling, and employee information and training requirements will be met. The written program must also include a list of hazardous chemicals present in the work place and the methods which will be used to inform employees of the hazards associated with performing non-routine tasks and chemicals present in unlabeled pipes. 22
  29. 29. Copyright 2012 www.environmentaleducation.com SECTION II. HAZARD RECOGNITION, EVALUATION, & CONTROL SECTION OBJECTIVES After reading this section, the attendee will have an increased knowledge of: Different hazards associated with handling dangerous materials and/or contaminated site operations; The components and elements of the Workplace Hazard Response Model; The types of hazards to personnel may be exposed to including chemical, safety, biological, physical, radiation, confined space and medical hazards; The physical properties of chemicals that help to identify and evaluate hazards present during site investigations and operations. SECTION OUTLINE The following section presents an overview of hazard recognition, evaluation and control, to include; Recognition, evaluation, and control; Chemical hazards; Physical hazards including kinetic/mechanical, electrical, and acoustic; Biological hazards; Radiation hazards; Confined space hazards; and Medical hazards including heat stress, cold exposure, medical surveillance, medical emergencies and first aid. What do you consider the most serious hazard that you might encounter? It is probably the hazard that you fail to recognize! 23
  30. 30. Copyright 2012 www.environmentaleducation.com A typical worksite can be one where numerous hazardous situations are present. These situations include "typical" physical hazards, such as poor footing, through those where hazardous materials/waste is present, or has escaped into the environment. Hundreds of thousands of different chemicals are produced, stored, transported, and used annually. Contaminated site situations vary considerably and may require investigation, immediate control measures (emergency) or long-term cleanup activities (remedial action) to restore acceptable conditions. Contaminated sites typically pose hazardous environments for workers including risk of exposure to chemical, physical, radiological, and biological hazards. Activities that are required in order to remain safe while working at contaminated or hazardous substance/waste containing sites can be divided into five broad, interacting elements: Recognition: identification of the situation or substance involved and the characteristics which determine its degree of hazard; Evaluation: determination of impact or risk the hazardous situation or substance poses to the worker, or public health; Control: methods to eliminate or reduce the health and safety risk present; Information: knowledge gained about the conditions or circumstances particular to a work site; Safety: protection of site personnel from harm. These elements make up a system - an orderly arrangement of components that interact to accomplish a task. In contaminated or hazardous substance/waste containing site work, the task is to prevent or reduce any negative impact on the health of workers in the general public. To achieve this goal contaminated site personnel undertake a variety of activities; for example. developing health and safety plans (HASP), visual observations, air monitoring, air sampling, erecting fences, recordkeeping, evaluation, etc. These activities are all related and what occurs in one affects or is affected by the others. Recognition Recognizing the type and degree of the hazard present is usually one of the first steps when determining the level of occupational risk at a worksite. This initial step is required in accordance with federal occupational safety regulations. The hazardous situation involved must be identified. Then the physical and chemical properties which may make it hazardous, or capable of causing harm, are determined. These inherent properties are used, on a preliminary basis, to predict the behavior and anticipated problems associated with site activities. Hazard recognition may be easy, for example, unguarded moving parts or a transportation placard on a tanker. At a contaminated site containing hundreds of different chemicals, complete hazard identification is more difficult. The element of recognition, therefore, involves use of all available information (e.g. sampling results, historical data, visual observation, instruments, package labels, shipping manifests, existing documentation, witnesses, and other sources) to identify the substances. 24
  31. 31. Copyright 2012 www.environmentaleducation.com It is important to recognize hazards when working around hazardous material containers and drums. The recognition process should include a comprehensive characterization of drums and containers including radioactivity, leaking/deteriorated, bulging, and explosive/shock sensitive issues. Important information can be obtained by simply looking at a container. For instance, if the drum head configuration is "open-head (removable lid) then the drum most likely contains a solid or semi-solid material, while drums with bungs are designed to contain liquids. The presence of a liner may indicate that the material contained within is corrosive. The type of material the container is made from may also indicate the class of chemical. The presence of a crystalline material at the neck or opening of any container may indicate that the material inside is explosive or shock sensitive. All containers suspected of containing shock sensitive or explosive materials should be treated as containing such material. Bulging drums indicate that the internal pressure may have increased and the material inside may be volatile and flammable. A worksite may involve more than the presence of a hazardous material. It may contain a situation in which the normal safeguards associated with the materials are compromised, thus creating the chance of undesirable effects. For instance, gasoline can do harm because it's vapors can ignite and explode. However, the usual safety techniques for handling gasoline should prevent this from happening. Problems caused by the release of gasoline into the environment can be anticipated based on its chemical and physical properties. The harm that gasoline will do if released at a site, however, depends on site-specific conditions. A multitude of substances exhibit one or more characteristics of flammability, radioactivity, corrosiveness, toxicity, or other properties which classify them as hazardous. For any particular hazardous category, the degree of hazard varies depending on the substance. The degree of hazard is a relative measure of how hazardous a substance is. For instance, the Immediately Dangerous to Life or Health (IDLH) concentration of butyl acetate in air is 1,700 parts per million (ppm); the IDLH for sulfur dioxide is 100 ppm. Sulfur dioxide, therefore, is much more acutely toxic (has a higher degree of hazard) when inhaled at lower than IDLH concentrations than butyl acetate. Vapors from butyl acetate, however, have a higher degree of explosive hazard than sulfur dioxide vapors which are not explosive. Once the substance has been identified, its hazardous properties and its degree of hazard can be determined using various databases or reference materials. Although appropriate references give information about the substances physical/chemical properties and may give indications of its environmental behavior, additional data is required. Frequently, monitoring and sampling data is used to: (1) identify substances, (2) determine concentrations, (3) confirm dispersion patterns, and (4) verify the presence of material. Evaluation Recognition provides basic data about the likely presence of a hazardous situation or substance. Evaluation is defined as determining its effects, or potential impact, onsite worker, or public health. A hazardous situation/substance is a threat due to its physical and/or chemical characteristics. Its actual impact however, depends on the location of the situation/substance, the pathways of distribution, weather, and other site-specific conditions, such as topography, 25
  32. 32. Copyright 2012 www.environmentaleducation.com geochemistry, etc. Two measures of impact are: 1) The potential for harm from a health and safety risk, and 2) The adverse effects that have occurred. Risk is the chance of harm being done, a measure of the potential impact or effect. The presence of a hazardous substance is a risk, but if the material is under control, the risk is low; if uncontrolled, the risk increases. For harm to be done, a critical receptor must be exposed to the hazardous material, as may happen when a site worker handles the material or people live in the area affected by the material. Chlorine gas, for instance, is highly toxic and represents a risk. If chlorine gas is released during site operations, the risk to site workers is very great. If the substance were carbon dioxide rather than chlorine, the workers risk would be substantially less, since carbon dioxide is much less toxic than chlorine. Evaluating risk in these two examples is relatively simple. Much more complex are those episodes where many compounds are involved and a higher degree of uncertainty exists regarding their behavior in the environment and their contact with and effects on receptors. The completeness of information must also be assessed. Will a detailed site walk-over with monitoring of airborne vapors/dusts/mists provide more comprehensive information on what the material is, where it is, how it moves through the environment, what it will contact, and what is the associated risk? To evaluate completely the effects of a contaminated site, all substances must be identified, their dispersion pathways established, and for toxic chemicals, concentrations determined. Of primary importance to site workers is the application of this evaluation to the actual site work to be accomplished. Risk is assessed based on exposure (or potential exposure) to site personnel and determinations made relative to the institution of administrative control methods such as; health and safety plans, standard safety procedures, and the use of engineered controls such as; machine guarding and/or personal protective equipment. Control Control is a method (or methods) which prevents or reduces the risk of occupational exposure to site hazards. Preliminary control actions are instituted as rapidly as possible. As additional information is developed through recognition and evaluation, initial control actions are modified or others instituted. Control generally includes two primary methods: Administrative Controls, including health and safety planning, standard safety operating procedures, and Engineered Controls, including machine guarding, ventilation, and the use of personal protective equipment. 26
  33. 33. Copyright 2012 www.environmentaleducation.com Information An integral part of safe site work is information and information dissemination. All site safety activities evolve as additional information is subsequentially obtained. Information is a support and input element to recognition, evaluation, and control and provides data for decision-making. Information typically comes from three sources: 1) Intelligence: Information obtained from existing records or documentation, placards, labels, signs, special configuration of containers, visual observations, technical reports, and others. 2) Direct-reading instruments: Information is obtained from on-site, real-time instruments. 3) Sampling: Information obtained from collecting representative portions of appropriate media or material and subsequent laboratory analysis. Information acquisition, analysis, and decision-making are interactive processes that define the extent of the problem and the safe response to the defined problem. For sight safety activities to be effective, an information base must be established which is accurate, valid, and timely. Throughout site work decisions are based on the receipt and evaluation of good information and the development of a good knowledge base concerning health-related risk. Safety All worksite activities pose varying dangers to site personnel. An important consideration in all site activities is to protect the health and safety of site personnel. To do this requires that the chemical and physical hazards associated with each operation be assessed and methods implemented to prevent or reduce harm to site personnel. Safety considerations are an input to every activity and are and outcome of each contaminated site activity. For example, an outcome of identifying a specific chemical may be changes in safety requirements. Each worksite should, or must (depending on site conditions and location) have an effective health and safety program including; appropriate safety equipment, standardized safety procedures, an active training program, medical surveillance, and atmosphere monitoring. Relationship of Elements Recognition, evaluation, control, information, and safety describe the five elements required for safe site work. Each element includes a variety of activities or operations. These elements are not necessarily sequential steps for work site activities. In some situations, control measures can start before the substances are completely identified. In others, a more thorough evaluation of a hazardous materials presence or characteristic is required before effective control actions can be determined. Each element and activity are interrelated, for example: A supplied air respirator (control, safety) is required to sample drums of unknown liquids (recognition, evaluation). Once determined that the drums contain no hazardous chemicals (information), the supplied air respirator is no longer required (evaluation, safety) to continue handling the drums. This knowledge (information) also changes the safety requirements for adjacent site operations (evaluation, safety). 27
  34. 34. Copyright 2012 www.environmentaleducation.com The response system is a concept explaining, in general terms, the safety processes involved in determining health and safety risks for site workers. All site work requires the performance elements of recognizing, evaluating, and controlling hazards in order to perform site operations safely. To support these, information is needed and site personnel safety must be considered. 2.1 CHEMICAL HAZARDS What is a chemical? A chemical means any element, chemical compound or mixture of elements and/or compounds. What is a hazardous chemical? A hazardous chemical is any chemical that can pose a physical hazard or a health hazard. Chemicals are usually broken down into two types of hazards: those that pose a physical hazard, and those that pose a health hazard. Chemical hazards may be classified according to one of four general groups. These groups are toxic, fire/explosion, corrosive, and reactive. A material may also elicit more than one chemical hazard. For example, toxic and flammable vapors can be released from many volatile liquids. Hazardous atmospheres may result from the physical/chemical properties of the material or from chemical reactivity with other materials to which it is exposed. 2.1.1 Toxic Hazards Toxic materials cause local or systemic detrimental effects in an organism. Types of toxic hazards are categorized by the physiological effect they have on the organism. A material may induce more than one physiological response such as: the asphyxiation, irritation/allergic sensitization, systemic poisoning, mutagenesis, teratogenesis, carcinogenesis and/or death. The likelihood that any of these effects will be experienced by an organism depends on: (1) the inherent toxicity of the material; (2) the concentration and duration (acute or chronic) of exposure and; (3) the route of exposure (ingestion, inhalation, dermal). 2.1.2 Fire and Explosion Hazards Combustibility is the ability of the material to act as a fuel. Materials that can be readily ignited and sustain a fire are considered flammable. Fuel that will not sustain fire without a continued ignition source is called combustible. Three components are required for combustion to occur: fuel, oxygen, and activation energy (heat). The concentration of fuel and oxygen must be proportioned correctly to allow ignition and to maintain the burning process. Combustion is a chemical reaction that requires heat to proceed. 28
  35. 35. Copyright 2012 www.environmentaleducation.com That heat is either supplied by an ignition source or is maintained by the combustion. The relationship of these three components is illustrated by the fire triangle (Figure 1). Most fires can be extinguished by removing one of the three components. For example, water applied to a fire removes the heat, thereby extinguishing the fire. When a flammable material, is in the presence of oxygen, generates enough heat to self-ignite and combust, spontaneous combustion occurs. The fuel is the material that is oxidized. Since the fuel becomes chemically charged by the oxidizing process it is a reducing agent. This makes the second side of the tetrahedron. Fuels can be anything from elements (carbon, hydrogen, magnesium) to compounds (wood, paper, gasoline). FIGURE 1FIRE TRIANGLESome mixtures of reducing agents and oxidizing agents remain stable under certain conditions. However, when there is some activation energy, a chain reaction is started, which causes combustion. Triggers to this chemical reaction can be as simple as exposing the combination to light. Once the chain reaction begins, extinguishment entails interrupting the reaction. Scientists have known for many years that certain chemicals act as excellent extinguishing agents. However, they were at a loss to explain how these chemicals actually accomplished extinguishment, given the fire triangle model. With the development of the tetrahedron model (Figure 2) and the inclusion of the uninhibited chain reaction, a scientifically sound theory could be postulated. With this as the basis, the extinguishing capabilities of the halons and certain dry chemicals were possible. While oxygen is the usual oxidizing agent during the combustion process, there are chemicals that can burn without oxygen. For example, calcium and aluminum will burn in a nitrogen atmosphere. Because of this possibility a fire tetrahedron can better explain "burning" then the fire triangle. Therefore the fire tetrahedron contains an oxidizing agent that permits the fuel to burn. Another side of the tetrahedron represents temperature. The fact that temperature is used instead of heat is deliberate. Temperature is the quantity of the disordered energy, which is what initiates combustion. It is possible to have a high heat as indicated by a large reading of BTU and still not have combustion. The temperature is therefore the key ingredient and the one that influences the actions of the tetrahedron. 29
  36. 36. Copyright 2012 www.environmentaleducation.com FIGURE 2Fire TetrahedronFlammability is the ability of the material (liquid, solid or gas) to generate enough concentration of combustible vapors under "normal" atmospheric conditions to be ignited and produce a flame. It is necessary to have a proper fuel-to-air ratio (expressed as a percentage of fuel in air) to allow combustion. There is a range of fuel (flammable range) concentrations in air for each material that is optimal for the ignition and the sustenance of combustion. The lowest concentration of fuel in this range is the lower flammable limit (LFL). Concentrations less than the LFL are not flammable because there is too little fuel - that is, the mixture is to "lean." The highest ratio that is flammable is the upper flammable limit (UFL). Explosive gases/vapors exhibit an explosive range, which is similar to the flammable range. The upper explosive limit (UEL) and lower explosive limit (LEL) are similar to the UFL and LFL. Most reference books list either explosive limits or flammable limits and treat them identically. Concentrations greater than the UFL are not flammable because there is too much fuel displacing the oxygen (resulting in too little oxygen). This mixture is too "rich". Fuel concentrations between the LFL and UFL are optimal for starting and sustaining fire. Example: the LFL for benzene is 1.3% (13,000 ppm), the UFL is 7.1% (71,000 ppm), thus the flammable range is 1.3% to 7.1%. A flammable material is considered highly combustible if it can burn at ambient temperatures (Table 1). A combustible material is not necessarily flammable, because it may not easily ignite or the ignition may not be maintained. Some pyrophoric materials will ignite at room temperature in the presence of a gas or vapor or when a slight friction or shock is applied. Note that the US Department of Transportation (DOT), the Occupational Safety and Health Administration (OSHA), the National Institute for Occupational Safety and Health (NIOSH), and the National Fire Protection Association (NFPA) have established strict definitions for flammability based on the flash point of material. 30
  37. 37. Copyright 2012 www.environmentaleducation.com TABLE 1 FLAMMABLE COMPOUNDS AND ELEMENTS Flammable Liquids Flammable Solids Aldehydes Phosphorus Ketones Magnesium dust Amines Zirconium dust Ethers Titanium dust Aliphatic hydrocarbons Aluminum dust Aromatic hydrocarbons Zinc dust Alcohols Nitroaliphatics Pyrophoric Liquids Water-Reactive Flammable Solids Organometallic compounds Potassium Dimethyl zinc Sodium Tributyl aluminum Lithium An explosive is a substance that undergoes a very rapid chemical transformation producing large amounts of gases and heat. The gases produced, for example, nitrogen, oxygen, carbon monoxide, carbon dioxide, and steam, due to the heat produced, rapidly expand at velocities exceeding the speed of sound. This creates both a shockwave (high pressure wave front) and noise. A gas or vapor explosion is a very rapid, violent release of energy. If combustion is extremely rapid, a large amount of kinetic energy, heat, and gaseous products are released. The major factor contributing to the explosion is the confinement of a flammable material. When vapors or gases cannot freely dissipate, they enter the combustion reaction more rapidly. Confinement also increases the energy associated with these molecules, which enhances the explosive process. Poorly ventilated buildings, sewers, drums, and bulk liquid containers are examples of places where potentially explosive atmospheres may exist. 31
  38. 38. Copyright 2012 www.environmentaleducation.com There are several types of explosive hazards: High or detonating: Chemical transformation occurs very rapidly with detonation rates as high as 6000 m/second (21,120 feet/second). The rapidly expanding gas produces a shockwave which may be followed by combustion. Primary high explosive: Detonating wave produced in an extremely short period of time. May be detonated by shock, heat, or fiction. Examples are lead azide, Mercury fulminate, and lead styphnate. Secondary high explosive: Generally needs a booster to cause them to detonate. Relatively insensitive to shock, heat, or friction. Examples are tetryl cyclonite, dynamite, and TNT. Low or deflagrating: Rate of deflagration up to 304 meters/second (1000 feet/second). Generally combustion is followed by a shock wave. Examples are smokeless powder, black powder, and solid rocket fuel. The terms "high" or "low" does not indicate the explosion hazard (or power) but only the rate of chemical transformation. Explosions can occur as a result of reactions between many chemicals not ordinarily considered as explosives. Ammonium nitrate, a fertilizer, can explode under the right conditions. Alkali metals and water explode, as will water and peroxide salts. Picric acid and certain ether compounds become highly explosive with age. Gases, vapors, and finally divided particulates, when confined, can also explode if an ignition source is present. In summary, fires and explosions require fuel, air (oxygen), and an ignition source (heat). At a worksite, the first two are not easily controlled. Consequently, while working on the site where a fire hazard may be present, the concentration of combustible gases in air must be monitored, and any potential ignition source must be kept out of the area. The most dangerous flammable substances: Are easily ignited (e.g. pyrophorics). Require little oxygen to support combustion. Have low LFL/LEL and a wide flammable/explosive range. Hazards related to fires and explosions cause: Physical destruction due to shock waves, heat, and flying objects (projectiles). Initiation of secondary fires or creation of flammable conditions. Release of toxic and corrosive compounds into the surrounding environment. 32
  39. 39. Copyright 2012 www.environmentaleducation.com 2.1.3 Corrosive Hazards Corrosion is a process of material degradation. Upon contact, a corrosive material may destroy body tissues, metals, plastics, and other materials. Corrosivity is the ability of material to increase the hydrogen ion or hydronium ion concentration of another material; it may have the potential to transfer electron pairs to or from itself or another substance. A corrosive agent is the reactive compound or element that produces a destructive chemical change in the material upon which it is acting. Common corrosives are the halogens, acids, and bases (Table 2). Skin irritation and burns are typical results when the body contacts an acidic or basic material. The corrosiveness of acids and bases can be compared on the basis of their ability to dissociate (form ions) in solution. Those that form the greatest number of hydrogen ions (H+ ) are the strongest acids, while those that form the most hydroxide ions (OH- ) are the strongest bases. The measure of H+ concentration, in solution is called pH. Strong acids have a low pH (many H+ in solution) while strong bases have a high pH (few H+ in solution; many OH- in solution). The pH scale ranges from 0 to 14 as follows: < Increasing Acidity Neutral Increasing Basicity > pH = 0 l 2 3 4 5 6 7 8 9 10 11 12 13 14 Measurements of pH are valuable because they can be quickly done on site, providing immediate information on the corrosive hazard. When dealing with corrosive materials in the field, it is imperative to determine: How toxic is a corrosive material? Is it an irritant or does it cause severe burns? What kind of structural damage does it do, and what other hazards occur? For example, will it destroy containers holding other hazardous materials, releasing them into the environment? TABLE 2 CORROSIVES HALOGENS Bromine Chlorine Fluorine Iodine BASES (Caustics) Potassium hydroxide Sodium hydroxide ACIDS Acetic Acid Hydrochloric acid Hydrofluoric acid Nitric acid Sulfuric acid 33
  40. 40. Copyright 2012 www.environmentaleducation.com 2.1.4 Chemical and Reactivity A reactive material is one that undergoes a chemical reaction under certain specified conditions. The term "reactive hazard" refers to a substance that undergoes a violent or abnormal reaction in the presence of either water or normal ambient atmospheric conditions. Among this type of hazard are the pyrophoric liquids which will ignite in air at or below normal room temperature in the absence of added heat, shock, or friction, and the water-reactive flammable solids which will spontaneously combust upon contact with water (Table 3). TABLE 3 HAZARDS DUE TO CHEMICAL REACTIONS (INCOMPATIBILITIES) REACTANTS RESULT Acid and Water Heat Generation Hydrogen Sulphide and Calcium Hypochlorite Fire Picric Acid and Sodium Hydroxide Explosion Sulphuric Acid and Plastic Toxic Gas or Vapor Production Acid and Metal Flammable Gas or Vapor Production Chlorine and Ammonia Formation of a Substance with Greater Toxicity than the Reactants Peroxides and Organics or Liquid Oxygen and Petroleum Products Pressurization of Closed Vessels Formation of Shock or Friction Sensitive Compounds Fire Extinguisher Hydrochloric Acid and Chromium Solubilization of Toxic Substances Sodium or Potassium Cyanide and Water or Acid Vapor Dispersal of Toxic Dusts and Mists Ammonia and Acrylonitrile Violent Polymerization A chemical reaction is the interaction of two or more substances, resulting in chemical changes. Exothermic chemical reactions, which give off heat, can be the most dangerous. A separate source of heat is required to maintain endothermic chemical reactions. Removing the heat source stops the reaction. 34
  41. 41. Copyright 2012 www.environmentaleducation.com Chemical reactions usually occur in one of the following ways: Combination A + B AB Decomposition AB A + B Single replacement A + BC B+AC Double replacement AB + CD AD + CD The rate at which a chemical reaction occurs depends on various factors, such as the following: Surface area of reactants available at the reaction site (for example, a large chunk of coal is combustible, but coal dust is explosive) Physical state of reactants - solid, liquid, or gas Concentration of reactants Temperature Pressure Presence of a catalyst If two or more hazardous materials remain in contact indefinitely without reaction, they are compatible. Incompatibility, however, does not necessarily indicate a hazard. For example, acids and bases, both corrosive, react to form salts and waters, which may not be corrosive. Many operations on waste or accident sites involve mixing or unavoidable contact between different hazardous materials. It is important to know ahead of time if such materials are compatible. If they are not, then any number of chemical reactions could occur. The results could range from the formation of an innocuous gas to a violent explosion. Table 3 illustrates what happens when some incompatible materials are combined. The identity of unknown reactants must be determined by chemical analysis to establish compatibility. On the basis of their properties, a chemist then should be able to anticipate any chemical reactions resulting from mixing the reactants. Judging the compatibility of more than two reactants is very difficult; analysis should be performed on a one-to-one bases. Site personnel who must determine compatibles should refer to A Method for Determining the Compatibility of Hazardous Wastes (EPA 600/2-80-076), published by the United States Environmental Protection Agency Office of Research and Development. Final decisions about compatibilities should only be made by an experienced chemist. 35
  42. 42. Copyright 2012 www.environmentaleducation.com If materials are compatible they may be stored together in bulk tanks or transferred to tank trucks for ultimate disposal. It is necessary, then, to establish the compatibility of the materials through analysis prior to bulking them. Compatibility information is also very important in evaluating an accident involving several different hazardous materials. The ultimate handling and treatment of the materials may be partially based on such information. 2.1.5 Properties of Chemical Hazards Chemical compounds possess inherent properties which determine the type and degree of the hazard they represent. Evaluating risks of a contaminated site depends on understanding these properties and their relationship to the environment. The ability of a solid, liquid, gas or vapor to dissolve in a solvent is solubility. An insoluble substance can be physically mixed or blended in a solvent for a short time but is unchanged when it finally separates. The solubility of a substance is independent of its density or specific gravity. The solubility of a material is important when determining its reactivity, dispersion, mitigation, and treatment. Solubility can be given in parts per million (ppm) or milligrams per liter (mg/L). The density of a substance is its mass per unit volume, commonly expressed in grams per cubic centimeter (g/cc). The density of water is 1 g/cc since 1 cc has a mass of 1 g. Specific gravity (SpG) is the ratio of the density of a substance (at a given temperature) to the density of water at the temperature of its maximum density (40C). Numerically, SpG is equal to the density in g/cc, but is expressed as a pure number without units. If the SpG of a substance is greater than 1 (the SpG of water), it will sink in water. The substance will float on water if its SpG is less than 1. This is important when considering mitigation and treatment methods. The density of a gas or vapor can be compared to the density of the ambient atmosphere. If the density of a vapor or gas is greater than the ambient air, it will tend to settle to the lowest point. If vapor density is close to air density or lower, the vapor will tend to disperse in the atmosphere. Vapor density is given in relative terms similar to specific gravity. In settling, dense vapor creates two hazards. First, if the vapor displaces enough air to reduce the atmospheric concentration of oxygen below 16%, asphyxia may result. Second, if the vapor is toxic, then inhalation problems predominate even if the atmosphere is not oxygen deficient. If a substance is explosive and very dense, the explosive hazard may be close to the ground rather than at the breathing zone (normal sampling heights). The pressure exerted by a vapor against the sides of a closed container is called vapor pressure, and it is temperature dependent. As temperature increases, so does the vapor pressure, thus, more liquid evaporates or vaporizes. The lower the boiling point of the liquid, the greater the vapor pressure it will exert at a given temperature. Values for vapor pressure are most often given as millimeters of mercury (mm Hg) at a specific temperature. 36
  43. 43. Copyright 2012 www.environmentaleducation.com The boiling point is the temperature at which a liquid changes to vapor. That is, the boiling point is the temperature where the pressure of the liquid equals atmospheric pressure. The opposite change in phases is the condensation point. Handbooks usually list temperatures as degrees Celsius (o C) or Fahrenheit (o F). A major consideration with toxic substances is how they enter the body. With high-boiling-point liquids, the most common entry is by body contact. With low-boiling-point liquids, the inhalation route is the most common and serious. The temperature at which a solid changes phase to a liquid is the melting point. This temperature is also the freezing point, since a liquid can change phase to a solid. The proper terminology depends on the direction of the phase change. If a substance has been transported at a temperature that maintains a solid phase, then a change in temperature may cause the solid to melt. The particular substance may exhibit totally different properties depending on phase. One phase could be inert while the other highly reactive. Thus, it is imperative to recognize the possibility of a substance changing phase due to changes in the ambient temperature. The minimum temperature at which a substance produces enough flammable vapors to ignite is its flash point. If the vapor does ignite, combustion can continue as long as the temperature remains at or above the flash point. The relative flammability of a substance is based on its flash point. An accepted relation between the two is: FLAMMABILITY FLASH POINT High < 37.7o C (100o F) Moderate > 37.7o C (100o F) < 93.3o C (200o F) Relatively inflammable > 93.3o C (200o F) 2.2 PHYSICAL HAZARDS Safety is the condition of being secure from undergoing or causing injury, or loss. In this definition, safety requires a twofold posture, offensive and defensive. The offensive posture provides protection for actions one can control. The defensive posture is the awareness of factors or situations others may create. Care must be taken so that actions to protect or reduce accident potentials for one person do not set up conditions for subsequent accidents by others. 2.2.1 Kinetic/Mechanical Generally referred to as slip-trip-fall type of injuries, the kinetic/mechanical category includes "struck-by" injuries along with "striking" injuries. 37
  44. 44. Copyright 2012 www.environmentaleducation.com Workers must walk cautiously that a site to avoid tripping. Orphaned sites usually are seldom kept neat and tidy. Tidy. Train or other vehicle wrecks can produce debris that can increase the possibility of tripping. Problems at a hazardous waste site and an accident scene can be compounded by uneven terrain and mud, caused by rain or leaking chemicals. Walking on drums is dangerous. Not only can they tip over, but they can be so corroded that they cannot support a person's weight. If it is absolutely necessary to walk over drums, place a piece of plywood over several drums to serve as a platform. While this practice can be dangerous it will distribute the walker's weight over several drums. It is preferable to utilize a drum mover or grappler two-stage drums and make them more accessible. Walking around heavy and mechanical equipment poses risk for workers. Table 4 outlines methods for reducing this risk TABLE 4 REDUCING INJURIES FROM MECHANICAL EQUIPMENT Trained personnel in proper operating procedures per regulations/standards, e.g. Lock-out/tag-out Install adequate on-site roads, signs, lights, and devices Ensure appropriate guards and engineering controls are installed on machinery Use equipment is recommended by the manufacturer At the start of each shift, inspect equipment and vehicles Allow only essential people in the work area Prohibit all loose hair or clothing at the worksite Instruct operators and workers to immediately report all equipment abnormalities have a signal person directed the backing and movement of equipment Lower arm blades and buckets to the ground and set parking brakes before shutting off the engine Implement an ongoing maintenance program Store tools in a clean and secure area to prevent damage Keep all heavy equipment in the contaminated areas until the job is done. Completely decontaminate equipment before moving it to contaminated areas 2.2.2 Electrical Electrical hazards can exist at accident sites because of downed power lines or improper use of electrical equipment. The presence of underground electrical lines must be checked before any digging or excavating. When using cranes or material handlers, care must be taken that the machinery does not come in contact with any energized lines. They should be a 6.1 meter (20-foot) clearance between a crane and electric power lines unless lines have been de--energized or an insulating barrier has been erected. Shock is the primary hazard from electrical tools. Electrical shock may cause death or burns or falls that lead to injury. 38
  45. 45. Copyright 2012 www.environmentaleducation.com Ways for protecting personnel from shock are: Grounding equipment. Grounding drains current, due to a short-circuit, to earth. The ground wire is the third wire on three-pronged plugs. Equipment can also be grounded by a separate wire attached to the metal parts. Using double-insulated tools. These tools do not need to be grounded because they are: encased by a nonconductive material which is shatterproof, or have a layer of insulating material isolating the electrical components from a metal housing (use for more rugged design). This insulation is in addition to that found in regular tools. Double-insulated tools are identified by writing on the tool or by the symbol of a square within the square. Having overcurrent devices such as: (1) fuses, which interrupt current by melting a fusible metal strip, or (2) circuit breakers, which operate by temperature change or magnetic difference. Crane collapse into overhead power lines Some of the fallout Overcurrent devices open the circuit current automatically if the current is high from accidental ground, short circuit or overload. They should be selected based on type of equipment and capacity. A ground fault circuit interrupter (GFC I) device can be used to protect personnel and equipment. This device breaks a circuit when it detects low levels of the current leaking to ground. It is fast-acting to keep the size of the current and its duration so low that it cannot produce serious injury. This device only operates on line-to-ground fault currents and not on line-two-line contact. It is commonly used on construction s