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. Copyright 2012 www.environmentaleducation.com OSHA HAZARDOUS
WASTEOPERATIONS AND EMERGENCYRESPONSE40 HOUR TRAINING STUDENT
TRAINING HANDBOOK
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. 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. 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. 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. 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. 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
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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
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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
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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
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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
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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. 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
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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
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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
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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
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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
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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
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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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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. 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