Site-Wide Health and Safety Plan for the Anniston PCB Site ... · for the Anniston PCB Site...
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H E A L T H & S A F E T Y P L A N
Site-Wide Health and Safety Plan for the
Anniston PCB Site
Revision 0
Anniston, Alabama
June 2004
Anniston PCB Site Site-Wide HASP
Revision: 0 Date: June 2004
Health and Safety Plan
for the Anniston PCB Site
Anniston, Alabama
June 2004 Revision 0
Approved By: __________________________________________________________________________________ Craig Branchfield: Anniston PCB Site Manager Date __________________________________________________________________________________ John Loper: CERCLA Manager Date __________________________________________________________________________________ Gayle Macolly: OU-1/OU-3 RI/FS Manager Date __________________________________________________________________________________ Alan Fowler: OU-2/OU-4 RI/FS Manager Date __________________________________________________________________________________ Charles Haury, CIH, CSP: HSO, OU-1/OU-3 Date __________________________________________________________________________________ Greg Ertel, CIH, CSP: HSO OU-2/OU-4 Date
05/06/04 HASP Acknowledgement.doc
Anniston PCB Site Anniston, Alabama
Health and Safety Plan Acknowledgment
I have read the Health and Safety Plan for the Anniston PCB Site, or its contents have been presented to me, and I understand the contents and I agree to abide by its requirements.
Name (Print) Signature Representing Date
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Table of Contents
Section 1. Introduction..............................................................................................................1-1 1.1 General.............................................................................................................................1-1 1.2 Background ......................................................................................................................1-2
1.2.1 Anniston Residential (OU-1) ...............................................................................1-3 1.2.2 Anniston Non-Residential (OU-2) .......................................................................1-3 1.2.3 Facility (OU-3) .....................................................................................................1-4 1.2.4 Choccolocco Creek (OU-4).................................................................................1-4
1.3 Policy Statement ..............................................................................................................1-4 1.4 Definitions.........................................................................................................................1-5
Section 2. Roles and Responsibilities .....................................................................................2-1 2.1 Project Personnel.............................................................................................................2-1
2.1.1 Anniston PCB Site Manager ...............................................................................2-2 2.1.2 CERCLA Manager ..............................................................................................2-2 2.1.3 Operable Unit RI/FS Managers...........................................................................2-2 2.1.4 Health and Safety Officer (HSO).........................................................................2-3 2.1.5 Health and Safety Coordinator (HSC).................................................................2-3 2.1.6 Site Safety Officer (SSO) ....................................................................................2-4 2.1.7 Subcontractors ....................................................................................................2-6
2.2 All On-Site Personnel.......................................................................................................2-6 2.3 Visitors..............................................................................................................................2-7 2.4 Stop Work Authority .........................................................................................................2-7
Section 3. Project Hazards and Control Measures .................................................................3-1 3.1 Introduction.......................................................................................................................3-1 3.2 Field Activities, Hazards, and Control Procedures ..........................................................3-1
3.2.1 Task 1 – Mobilization/Site Survey.......................................................................3-2 3.2.2 Task 2 – Water, Soil, and Air Sampling ..............................................................3-3 3.2.3 Task 3 – Drilling and Monitoring Well Installation ...............................................3-5
3.2.3.1 Geoprobe® Hazards and Control Procedures ....................................3-5 3.2.3.2 Drilling..................................................................................................3-7
3.2.4 Task 4 – Residential Sampling and Excavation................................................3-12 3.2.5 Task 5 – Sediment Sampling and Processing ..................................................3-13
3.2.5.1 Vibracoring/Sediment Sampling ........................................................3-13 3.2.5.2 Manual Coring ...................................................................................3-16
3.2.6 Task 6 – Biota Sampling ...................................................................................3-17 3.2.6.1 Electrofishing .....................................................................................3-18
3.2.7 Task 7 – Personnel and Equipment Decontamination......................................3-20 3.2.7.1 Personnel Decontamination ..............................................................3-20 3.2.7.2 PPE and Equipment Decontamination..............................................3-21
3.2.8 Task 8 – Demobilization....................................................................................3-24 3.3 Chemical Hazards..........................................................................................................3-25
Section 4. General Safety Practices.........................................................................................4-1 4.1 General Safety Rules .......................................................................................................4-1 4.2 Incident Investigation .......................................................................................................4-2 4.3 Safe Work Observation ....................................................................................................4-2 4.4 Activity Hazard Analysis (AHA) ........................................................................................4-3
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4.5 Buddy System ..................................................................................................................4-3 4.6 Heat Stress.......................................................................................................................4-4 4.7 Cold Stress.......................................................................................................................4-8 4.8 Biological Hazards .........................................................................................................4-11
4.8.1 Tick-Borne Diseases .........................................................................................4-12 4.8.2 Poisonous Plants ..............................................................................................4-13 4.8.3 Snakes ..............................................................................................................4-13 4.8.4 Dogs ..................................................................................................................4-14 4.8.5 Spiders ..............................................................................................................4-14 4.8.6 Mosquitoes........................................................................................................4-15 4.8.7 Bees, Ants and Other Insects ...........................................................................4-16
4.9 Noise ..............................................................................................................................4-17 4.10 Spill Control ....................................................................................................................4-17 4.11 Sanitation .......................................................................................................................4-18
4.11.1 Break Area ........................................................................................................4-18 4.11.2 Potable Water ...................................................................................................4-18 4.11.3 Sanitary Facilities ..............................................................................................4-18 4.11.4 Lavatory ............................................................................................................4-19
4.12 Emergency Equipment...................................................................................................4-19 4.13 Lockout/Tagout Procedures...........................................................................................4-19 4.14 Electrical Safety .............................................................................................................4-20 4.15 Lifting Safety ..................................................................................................................4-21 4.16 Ladder Safety.................................................................................................................4-22 4.17 Carbon Monoxide...........................................................................................................4-23 4.18 Hot Work Safety Program ..............................................................................................4-25 4.19 Confined Space Entry ....................................................................................................4-28
4.19.1 Confined Space Identification and Designation ................................................4-29 4.19.2 Duties of Personnel...........................................................................................4-29 4.19.3 Procedures for Permit Space Entry ..................................................................4-31
Section 5. Personal Protective Equipment ..............................................................................5-1 5.1 Levels of Protection..........................................................................................................5-1
5.1.1 Level D Protection...............................................................................................5-1 5.1.2 Modified Level D Protection ................................................................................5-1 5.1.3 Level C Protection...............................................................................................5-2
5.2 PPE Selection ..................................................................................................................5-3 5.3 Site Respiratory Protection Program ...............................................................................5-3 5.4 Using PPE........................................................................................................................5-4
5.4.1 Donning Procedures ...........................................................................................5-4 5.4.2 Doffing Procedures .............................................................................................5-5
Section 6. Air and Noise Monitoring ........................................................................................6-1 6.1 Air Monitoring ...................................................................................................................6-1 6.2 Noise Monitoring ..............................................................................................................6-1 6.3 Monitoring Equipment Maintenance and Calibration .......................................................6-1 6.4 Action Levels ....................................................................................................................6-2
Section 7. Work Zones and Decontamination .........................................................................7-1 7.1 Work Zones ......................................................................................................................7-1
7.1.1 Authorization to Enter..........................................................................................7-1 7.1.2 Site Orientation and Hazard Briefing ..................................................................7-1 7.1.3 Certification Documents ......................................................................................7-1
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7.1.4 Entry Log.............................................................................................................7-2 7.1.5 Entry Requirements ............................................................................................7-2 7.1.6 Emergency Entry and Exit...................................................................................7-2 7.1.7 Contamination-Control Zones .............................................................................7-2 7.1.8 Exclusion Zone....................................................................................................7-2 7.1.9 Contamination-Reduction Zone ..........................................................................7-3 7.1.10 Support Zone ......................................................................................................7-3 7.1.11 Posting ................................................................................................................7-3 7.1.12 Site Inspections...................................................................................................7-3
7.2 Decontamination ..............................................................................................................7-3 7.2.1 Personnel Decontamination................................................................................7-4 7.2.2 Equipment Decontamination...............................................................................7-4 7.2.3 Personal Protective Equipment Decontamination ..............................................7-4
Section 8. Training and Medical Surveillance .........................................................................8-1 8.1 Training ............................................................................................................................8-1
8.1.1 General................................................................................................................8-1 8.1.2 Basic 40-Hour Course.........................................................................................8-1 8.1.3 Supervisor Course ..............................................................................................8-2 8.1.4 Site-Specific Training ..........................................................................................8-2 8.1.5 Daily Safety Meetings .........................................................................................8-2 8.1.6 First Aid and CPR ...............................................................................................8-3
8.2 Medical Surveillance ........................................................................................................8-3 8.2.1 Medical Examination ...........................................................................................8-3 8.2.2 Pre-Placement Medical Examination ..................................................................8-3 8.2.3 Other Medical Examinations ...............................................................................8-4 8.2.4 Periodic Exam .....................................................................................................8-4 8.2.5 Medical Restriction..............................................................................................8-4
Section 9. Emergency Procedures...........................................................................................9-1 9.1 General.............................................................................................................................9-1 9.2 Emergency Response......................................................................................................9-1
9.2.1 Fire ......................................................................................................................9-1 9.2.2 Contaminant Release..........................................................................................9-2
9.3 Medical Emergency..........................................................................................................9-2 9.3.1 Emergency Care Steps .......................................................................................9-2
9.4 First Aid – General ...........................................................................................................9-3 9.4.1 First Aid – Inhalation ...........................................................................................9-3 9.4.2 First Aid – Ingestion ............................................................................................9-4 9.4.3 First Aid – Skin Contact.......................................................................................9-4 9.4.4 First Aid — Eye Contact......................................................................................9-4
9.5 Reporting Injuries, Illnesses, and Near-Miss Incidents ....................................................9-4 9.6 Emergency Information ....................................................................................................9-5
9.6.1 Directions to Regional Medical Center................................................................9-6 9.6.2 Map to Regional Medical Center.........................................................................9-6
Section 10. References .............................................................................................................10-1
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Tables 2-1 Key Personnel 3-1 Minimum Safe Overhead Electrical Clearances 4-1 Work/Rest Schedule 4-2 Chill Temperature Chart 4-3 Carbon Monoxide Exposure Guidelines 5-1 PPE Selection Matrix 6-1 Action Levels for Air 9-1 Emergency Contacts Figures 1-1 Location Map 2-1 Project Organization Chart 9-1 Regional Medical Center Attachments A Underground/Overhead Utility Checklist B Sediment Sampling Checklist C PCB Chemical Hazard Information and Material Safety Data Sheet D Parathion Chemical Hazard Information and Material Safety Data Sheet E Paranitrophenol Chemical Hazard Information and Material Safety Data Sheet F Incident/Near-Miss Investigation Report G Safe Work Observation Form H Air Monitoring Form I Health and Safety Inspection Form J Safety Meeting Log K Hot Work Permit L Confined Space Entry Checklist M Confined Space Entry Permit Appendices (Electronic Only) 1 NTC Removal Action Supplemental Sampling Health and Safety Plan for the Anniston PCB Site
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Distribution List
Organization Individual Number of Copies
Solutia Inc. Craig R. Branchfield 2
The Loper Group, Inc. John R. Loper 1
Monsanto Company Peter L. Virden Jr. 1
USEPA Pamela Scully 6 /10 (hard copy/electronic)
Whateley Drake LLC G. Douglas Jones 1
Dahl Environmental Services Thomas Dahl 1
Golder Associates, Inc. Gayle Macolly 1
Golder Associates, Inc. Charles Haury, CIH, CSP 1
Blasland, Bouck & Lee, Inc. Alan S. Fowler 1
Blasland, Bouck & Lee, Inc. Greg N. Ertel, CIH, CSP 1
ADEM Philip Davis 1
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Acronyms and Abbreviations
ACGIH American Conference of Governmental Industrial Hygienists AHA Activity Hazard Analysis ANSI American National Standards Institute AOC Administrative Order on Consent BBL Blasland, Bouck & Lee, Inc. °C degrees Celsius CFR Code of Federal Regulations CD partial consent decree CO Carbon Monoxide COC constituent of concern CPR cardiopulmonary resuscitation CSM conceptual site model CRZ contamination-reduction zone dBa decibles adjusted DEET diethyltoluamide EMS Emergency Medical Services EZ exclusion zone °F degrees Fahrenheit Facility the Parties’ Anniston Facility FM Factory Mutual Engineering Corporation FSP field sampling plan Golder Golder Associates, Inc. GFCI ground-fault-circuit interrupter HASP health and safety plan HSO health and safety officer HSC health and safety coordinator LEL lower explosive limit MCC Monsanto Chemical Company mph miles per hour MSDS Material Safety Data Sheet NEC National Electrical Code NESC National Electrical Safety Code NIOSH National Institute for Occupational Safety and Health NTC Removal Agreement Non-time Critical Removal Agreement NRR noise reduction rating OSHA Occupational Safety and Health Administration OU operable unit Parathion ethyl parathion PCB polychlorinated biphenyl PEL Permissible Exposure Limit PID photoionization detector PFD personal floatation device PNP paranitrophenol PPE personal protective equipment psi pounds per square inch
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PVC polyvinyl chloride RCRA Resource Conservation and Recovery Act RFI RCRA Facility Investigation RFI/CS RCRA Facility Investigation/Confirmatory Sampling RI/FS Remedial Investigation/Feasibility Study Site Anniston PCB Site SSO Site safety officer Swann Swann Chemical Company SWO Safe Work Observation SZ support zone ta adj adjusted air temperature TLV Threshold Limit Value The Parties Pharmacia Corporation and Solutia Inc., as signatory parties to the CD UL Underwriters Laboratory USCG United States Coast Guard USEPA United States Environmental Protection Agency VOCs volatile organic compounds
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1. Introduction
1.1 General
This Site-Wide Health and Safety Plan (Site-Wide HASP) has been prepared for the Anniston Polychlorinated
Biphenyl (PCB) Site (Site) (Figure 1-1) as a deliverable under the Partial Consent Decree (CD) for the Site
(Docket No. CV-02-PT-0749-E) entered by the United States District Court for the Northern District of
Alabama on August 4, 2003. The Site-Wide HASP addresses activities described in the Remedial
Investigation/Feasibility Study (RI/FS) Work Plan developed for the Site (Blasland, Bouck & Lee, Inc. [BBL],
2004) for the four Operable Units (OUs) identified in the Phase I Conceptual Site Model (CSM) Report (BBL,
2003). The Phase I CSM Report was approved by the United States Environmental Protection Agency
(USEPA) on March 5, 2004 (approval received March 8, 2004). Project activities may include the following:
• Mobilization/Site Survey;
• Groundwater Sampling;
• Soil Sampling;
• Air Sampling
• Residential Sampling and Excavation;
• Sediment Sampling
• Biota Sampling;
• Equipment Decontamination; and
• Demobilization.
While investigative and remedial activities in addition to those listed above may be conducted at the Site, this
Site-Wide HASP provides the framework and flexibility for these activities to be addressed through updates to
this plan. The Site-Wide HASP has been prepared on behalf of Pharmacia Corporation and Solutia Inc. as
signatory parties to the CD (herein after referred to as “the Parties”). The objective of this Site-Wide HASP is
to provide a mechanism for establishing safe working conditions at the Site. The safety organization,
procedures, and protective equipment have been established based on an analysis of potential hazards. Specific
hazard control methodologies have been evaluated and selected to minimize the potential of injury, illness, or
other hazardous incident.
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1.2 Background
The Site is located in the north-central part of Alabama (Figure 1-1) and has been evaluated extensively over the
past 20 years. Manufacturing operations at the Parties’ Anniston Facility (Facility) began in 1917 with the
production of ferro-manganese, ferro-silicon, and ferro-phosphorous compounds and, later, phosphoric acid, by
the Southern Manganese Corporation. In 1927, the production of organic chemicals began with the introduction
of biphenyl, which remains a major product of the Facility. In 1930, Southern Manganese Corporation became
Swann Chemical Company (Swann); in May 1935, Swann was purchased by Monsanto Chemical Company
(MCC). Solutia, the present owner, was created as a spin-off of MCC in 1997.
A variety of organic and inorganic chemicals have been produced at the Facility during its history, including
PCBs, ethyl parathion (parathion), paranitrophenol (PNP), and phosphorus pentasulfide. Polyphenyl
compounds, which are used in a variety of heat-transfer fluid, plasticizer, and lubricant applications, are
currently manufactured at the Facility. PCBs were produced at the Facility from the late 1920s to 1971 by
reacting chlorine and biphenyl. Chlorine was also produced at the Facility between the 1950s and 1969 for the
sole purpose of supporting PCB manufacturing. Additional historical manufacturing information is presented in
the Resource Conservation and Recovery Act (RCRA) Facility Investigation/Confirmatory Sampling (RFI/CS)
Report (Golder Associates, Inc. [Golder], 2002).
The Anniston PCB Site includes both the Facility itself and areas beyond the Facility boundaries. The
geographical expanse of the overall Site is extensive, so the Site has been segmented into four Operable Units.
The Facility is defined as Operable Unit 3 (OU-3), and includes the manufacturing plant and two landfills. The
rest of the Site (the Off-Facility areas) is divided into OUs 1, 2, and 4, and includes the in-stream and 100-year
floodplain areas of Snow Creek, a 37-mile reach of Choccolocco Creek between its confluence with Snow
Creek and Lake Logan Martin. The geographic boundaries of the Site, including the extent of Off-Facility
areas, will be refined throughout the RI/FS process as additional data are collected.
Activities conducted under this Site-Wide HASP may occur in any of the four OUs. Each OU is briefly
described in the following subsections, and depicted on Figure 1-1.
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1.2.1 Anniston Residential (OU-1)
OU-1 consists of residential properties that will be addressed in accordance with the Non-Time Critical
Removal Agreement (NTC Removal Agreement) (Appendix G to the CD). The definition of this OU was
selected based on the specific land use classification addressed by the NTC Removal Agreement, and the unique
and specific requirements identified under the NTC Removal Agreement that are separate and distinct from the
broader requirements of the CD. Work conducted under this OU will generally be limited to those residential
areas upstream of Highway 78. Residential properties located in the Oxford Lakes Neighborhood Zone (Zone
OLN) as defined in the Removal Agreement are also included in this OU. The process for further identifying
the geographic limits of OU-1 is presented in the Non-Time Critical Removal Supplemental Sampling and
Analysis Plan (Solutia, 2004). There is also an OU-1 specific HASP that has been submitted to the USEPA for
approval under the NTC removal agreement. The OU-1 HASP is included electronically as Appendix 1 to this
Site-Wide HASP (Solutia, 2003). A subcontractor-specific HASP for the removal of PCB-containing soils with
concentrations equal to or greater than 1 milligram per kilogram (mg/kg) will be prepared and submitted under
separate cover prior to the commencement of work under the NTC Removal Agreement.
1.2.2 Anniston Non-Residential (OU-2)
OU-2 includes non-residential properties of the Site upstream of Highway 78 up to and surrounding the On-
Facility area (OU-3). The geography of this area includes properties that are immediately north and east of the
On-Facility area that were historically part of the “On-Site” area, and non-residential areas that have historically
been addressed under the Administrative Order on Consent (AOC) (USEPA, 2001) (e.g., the 11th Street Ditch
and West 9th Street Creek). The lateral bounds of this OU potentially include both floodplain and non-
floodplain properties. Given the immediate focus on the residential portions of the Site (OU-1), the lateral
extent of OU-2 will be refined once the sampling of residential areas has been sufficiently implemented. Near-
term investigative activities under this OU are anticipated to include soil and air sampling as well as habitat and
species identification. A subcontractor-specific HASP for remedial activities to be performed at the 11th Street
Ditch, in accordance with an approved Removal Response Action Plan (Roux Associates, Inc. 2001) submitted
under the AOC, will be prepared following completion of the contractor selection process prior to field
mobilization.
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1.2.3 Facility (OU-3)
This OU consists of the Facility itself including the plant Site, the South Landfill, and the West End Landfill.
Keeping this as a separate OU builds upon the significant remedial measures implemented to date at the Facility
and reflects the maturity of these efforts with regard to the RI/FS process (RI completion/FS initiation). In
addition, the consistent industrial character of this area and associated deed restrictions differentiate it from
other areas of the Site. Investigative activities in this OU are anticipated to include soil and groundwater
sampling and field observation of habitat and species identification.
1.2.4 Choccolocco Creek (OU-4)
This OU includes Choccolocco Creek and its floodplain downstream to Lake Logan Martin. It also includes the
lower end of Snow Creek and its floodplain downstream of Highway 78 to the confluence of Snow and
Choccolocco Creeks. This small portion of Snow Creek is more characteristic of Choccolocco Creek than the
upper reaches of Snow Creek and hence, it has been included in this OU. The floodplain and creek areas of this
OU are being kept together within one OU because a single receptor could experience multiple exposure
pathways that include both the creek and floodplain areas. Characterization activities under this OU are
anticipated to include biota, soil, and sediment sampling. Additional characterization activities may be added as
the field sampling plans (FSPs) for the OU are developed.
1.3 Policy Statement
Work activities at the Site will be carried out in a manner that protects the safety and health of contractors’
employees and the Parties’ employees and, where applicable, the public. The basic provisions of this plan are
mandatory for all personnel and contractors assigned to the project. In addition, all visitors must abide by the
requirements of this plan.
To that end, the objective of this Site-Wide HASP is to provide general health and safety information regarding
Site conditions and pertinent activities to allow contractors to develop individual Site-specific HASPs as
necessary. Work at OUs 1 and 3 will be conducted under the direction of Golder, while work at OUs 2 and 4
will be conducted under the direction of BBL. Activities carried out by employees of Golder, BBL,
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subcontractors to either Golder or BBL, and contractors to the Parties who are under the direction of Golder or
BBL will be carried out in accordance with the provisions of this Site-Wide HASP. Contractors who are hired
to carry out a unique activity(ies) that is not addressed in this Site-Wide HASP will develop a Site-specific
HASP to outline the health and safety measures that will be implemented during the course of their efforts.
Each contractor’s HASP will be specific to the Site and to the task(s) that the contractor will be conducting. The
requirements in each contractor’s Site-specific HASP must be equivalent to or more stringent than those of this
Site-Wide HASP. Each Site-specific HASP will be distributed electronically and incorporated as an appendix to
this Site-Wide HASP.
The general safety procedures and protective equipment requirement presented in this general Site-Wide HASP
have been established based on an analysis of potential physical, chemical, and biological hazards. The hazard
control methodologies presented are intended to minimize the potential for accident or injury.
This Site-Wide HASP prescribes the procedures that must be followed during activities at the Site. Operational
changes that could affect the health and safety of personnel, the community, or the environment will not be
made without prior approval of the OU RI/FS Manager and the health and safety officer (HSO). This document
will be reviewed periodically to confirm that it is current and technically correct. Any changes in conditions at
the Site and/or the scope of work (as described above) will require a review of, and modification to, this Site-
Wide HASP. As indicated, such changes will be completed in the form of an addendum or a revision to the
Site-Wide HASP.
This Site-Wide HASP provides guidance in order to comply with applicable state and federal Occupational
Safety and Health Administration (OSHA) regulations, USEPA regulations, and the Parties’ health and safety
policies and procedures.
1.4 Definitions
The following definitions (listed alphabetically) are applicable to this Site-Wide HASP:
• Contamination-Reduction Zone (CRZ) - Area between the exclusion zone and support zone that
provides a transition between contaminated and clean areas. Decontamination stations are located in this
zone.
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• Exclusion Zone (EZ) - Any portions of the Site where hazardous substances are present, or are
reasonably suspected to be present, and pose an exposure hazard to on-Site personnel.
• Incident - All losses, including first-aid cases, injuries, illnesses, near misses, spills/leaks, equipment
and property damage, motor vehicle accidents, regulatory violations, fires, and business interruptions.
• Near Miss - An incident in which no injury, illness, motor vehicle accident, equipment or property
damage, etc., occurred, but in which, under slightly different circumstances, could have occurred.
• On-Site Personnel - All of the Parties’ employees and subcontractor personnel involved with the
project.
• Project - All on-Site work performed under the scope of work.
• Site - The area described in Section 1.1, where the work is to be performed by the Parties’ personnel and
subcontractors.
• Support Zone (SZ) - All areas of the Site, except the EZ and CRZ. The SZ surrounds the CRZ and EZ.
Support equipment and break areas are located in this zone.
• Subcontractor - Includes contractor personnel hired by the Parties.
• Visitor - All other personnel, except the on-Site personnel.
• Work Area - The portion of the Site where work activities are actively being performed. This area may
change daily as work progresses and includes the SZ, CRZ, and EZ. If the work area is located in an
area on Site that is not contaminated or suspected of being contaminated, the entire work area may be a
SZ.
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2. Roles and Responsibilities
2.1 Project Personnel
All of the Parties’ and contractor/subcontractors’ personnel must adhere to the procedures outlined in this Site-
Wide HASP during the performance of their work. Each person is responsible for completing tasks safely and
for reporting any unsafe acts or conditions to his/her supervisor. No person may work in a manner that conflicts
with these procedures. After due warnings, the OU RI/FS Manager will dismiss from the Site any person or
subcontractor who violates safety procedures.
All of the Parties’ and contractor/subcontractors’ personnel will receive training in accordance with applicable
regulations and be familiar with the requirements and procedures contained in this Site-Wide HASP prior to
initiating Site activities. This training will be documented for each individual. In addition, all personnel will
attend an initial hazard briefing prior to beginning work at the Site as well as daily safety meetings.
Any contractor or subcontractor conducting work at the Site is responsible for protection and health and safety of
their own employees, which may include the use of this document. However, any company which uses this
document for field activities must clearly identify the lines of authority for health and safety within their
organization, and evaluate whether the health and safety procedures outlined in this Site-Wide HASP are
appropriate for those activities.
The health and safety position requirements and lines of authority are described below, and key personnel are
identified in both Table 2-1 (see page 2-5) and Figure 2-1 (note that Figure 2-1 also depicts quality assurance
positions that while not directly applicable to the Site-Wide HASP, are important to the integrity/conduct of the
overall project). Compliance with this document will require that each contractor or subcontractor provide names
for the roles of the HSO, Health and Safety Coordinator (HSC), and Site Safety Officer (SSO). One individual may
be named to multiple roles. The names shall be presented in the initial Site health and safety briefing to all on-Site
personnel working for that company.
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If the health and safety procedures outlined in this Site-Wide HASP are deemed to be inadequate for the work to be
conducted, or if the work activities are not addressed in this plan, an addendum (or revision) to this plan must be
prepared.
Use of this document also requires that a qualified HSO, HSC, or designee be on Site during all field activities
to oversee implementation of this plan. To be qualified, an HSO, HSC, or designee must have at least two years
field experience in health and safety at hazardous waste sites.
2.1.1 Anniston PCB Site Manager
The Anniston PCB Site Manager has overall responsibility for projects associated with the Site. The Anniston
PCB Site Manager has final authority for decisions made by the contractors and subcontractors implementing
the activities described in the RI/FS Work Plan for the Site.
2.1.2 CERCLA Manager
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) Manager has overall
responsibility for the management and technical oversight of the Anniston PCB Site CERCLA project. The
CERCLA Manager offers technical and management support to the Anniston PCB Site Manager.
2.1.3 Operable Unit RI/FS Managers
RI/FS Managers will be established for work conducted at the OUs. One person will be responsible for OUs 1
and 3, and another will be responsible for OUs 2 and 4. The OU RI/FS Managers are responsible for providing
resources so that project activities are completed in accordance with this Site-Wide HASP and for meeting all
regulatory and contractual requirements. The OU RI/FS Managers are also responsible for confirming that the
SSO has the equipment, materials, and qualified personnel to fully implement the safety requirements of this
Site-Wide HASP and/or that those subcontractors assigned to this project meet the minimum requirements. It is
also the responsibility of the OU RI/FS Managers to perform the following duties:
• Consult with the HSO on Site health and safety issues.
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• Review Safe Work Observation (SWO) Forms.
• Verify that all incidents are thoroughly investigated.
• Approve, in writing, addenda or revisions to this Site-Wide HASP.
2.1.4 Health and Safety Officer (HSO)
The HSO or his/her designee has overall responsibility for the technical health and safety aspects of the project,
including review and approval of this Site-Wide HASP. Inquiries regarding health and safety procedures,
project procedures, and other technical or regulatory issues should be addressed to this individual. The HSO or
his/her designee must approve revisions or addenda to this Site-Wide HASP.
2.1.5 Health and Safety Coordinator (HSC)
The HSC is responsible for field health and safety issues, including the execution of this Site-Wide HASP.
Questions in the field regarding health and safety procedures, project procedures, and other technical or
regulatory issues should be addressed to this individual. The HSC will advise the OU RI/FS Managers on health
and safety issues and will establish and coordinate the project air monitoring program if one is deemed
necessary (see Section 6.1, Air Monitoring). The HSC is the primary Site contact on health and safety matters. It
is the responsibility of the HSC to perform the following duties:
• Verify that subcontractors meet health and safety requirements prior to commencing work.
• Suspend work or modify work practices, as necessary, for personal safety, protection of property, and
regulatory compliance.
• Provide on-Site technical assistance, if necessary.
• Participate in all Incident Investigations and confirm that they are reported to the HSO and OU RI/FS
Manager within 24 hours.
• Coordinate Site and personal air monitoring, as required, including equipment maintenance and
calibration.
• Conduct Site safety orientation training and safety meetings.
• Verify that personnel and subcontractors have received the required physical examinations and medical
certifications.
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• Review Site activities with respect to compliance with this Site-Wide HASP.
• Maintain required health and safety documents and records.
• Assist the SSO in instructing field personnel on project hazards and protective procedures.
• Review SWO Forms.
2.1.6 Site Safety Officer (SSO)
The SSO is responsible for implementing this Site-Wide HASP, including communicating requirements to on-
Site personnel and subcontractors. The SSO will be responsible for informing the OU RI/FS Managers of
changes in the work plan, procedures, or Site conditions so that those changes may be addressed in this Site-
Wide HASP. Other responsibilities are to:
• Consult with the HSC on Site health and safety issues.
• Stop work, as necessary, for personal safety, protection of property, and regulatory compliance.
• Obtain a Site map and determine and post routes to medical facilities and emergency telephone
numbers.
• Notify local public emergency representatives (as appropriate) of the nature of the Site operations, and
post their telephone numbers (e.g., local fire department personnel who would respond for a confined-
space rescue).
• Observe on-Site project personnel for signs of ill-health effects.
• Investigate and report any incidents to the HSC.
• Verify that all on-Site personnel have completed applicable training.
• Verify that on-Site personnel are informed of the physical, chemical, and biological hazards associated
with the Site activities and of the procedures and protective equipment necessary to control the hazards.
• Issue/obtain any required work permits (hot work, etc.).
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Table 2-1
Key Personnel
Role Name Address/Telephone No.
Anniston PCB Site Manager Craig Branchfield
702 Clydesdale Avenue
Anniston, AL 36201-5328
(256) 231-8404
CERCLA Manager John Loper
702 Clydesdale Avenue
Anniston, AL 36201-5328
(256) 231-8420
RI/FS Manager (OU-1/OU-3) Gayle Macolly
702 Clydesdale Avenue
Anniston, AL 36201-5328
(256) 231-8412
RI/FS Manager (OU-2/OU-4) Alan Fowler
100 Cummings Center
Suite 322G
Beverly, MA 01915-6112
(978) 921-0442
Health and Safety Officer (OU-
1/OU-3) Charles Haury, CIH, CSP
8933 Western Way
Jacksonville, FL 32256
(904) 363-3430
Health and Safety Officer (OU-
2/OU-4) Greg Ertel, CIH, CSP
155 Corporate Woods
Suite 150
Rochester, NY 14623-6715
(585) 292-6740
Health and Safety Coordinator (OU-
1/OU-3) TBD TBD
Health and Safety Coordinator (OU-
2/OU-4) TBD TBD
Site Safety Officer TBD TBD
TBD = to be determined
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2.1.7 Subcontractors
Subcontractors and their personnel must understand and comply with applicable regulations and Site
requirements established in this Site-Wide HASP. Subcontractors who are conducting unique activities that are
not addressed under the Site-Wide HASP must prepare their own Site-specific HASPs; each Site-specific HASP
must be consistent with (or more stringent than) the requirements of this Site-Wide HASP and will be included
as an appendix to this document.
All subcontractor personnel will receive training in accordance with applicable regulations and be familiar with
the requirements and procedures contained in this Site-Wide HASP prior to initiating Site activities. All
subcontractor personnel will attend an initial hazard briefing prior to beginning work at the Site. Additionally,
on-Site subcontractor personnel must attend and participate in the daily Site safety meetings.
Subcontractors must designate individuals to function as the HSO, HSC, and SSO. A subcontractor may
designate one person to perform the duties of both the HSC and the SSO. However, depending on the level of
complexity of a contractor’s scope of work, it may not be feasible for one person to perform both functions
satisfactorily.
2.2 All On-Site Personnel
All on-Site personnel (including subcontractors) must read and acknowledge their understanding of this Site-
Wide HASP before commencing work, and abide by the requirements described in this document. All on-Site
personnel must sign the Acknowledgement Form (included immediately after the title page) after reviewing this
Site-Wide HASP.
All of the Parties’ and subcontractor personnel will receive training in accordance with applicable regulations
and be familiar with the requirements and procedures contained in this Site-Wide HASP prior to initiating Site
activities. In addition, all on-Site personnel will attend an initial hazard briefing prior to beginning work at the
Site as well as the daily safety meetings.
On-Site personnel will immediately report the following to the SSO or HSC:
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• personal injuries and illnesses, no matter how minor;
• unexpected or uncontrolled release of chemical substances;
• symptoms of chemical exposure;
• unsafe or hazardous situations;
• unsafe or malfunctioning equipment;
• changes in Site conditions that may affect the health and safety of project personnel;
• damage to equipment or property;
• situations or activities for which they are not properly trained; and
• near misses.
2.3 Visitors
All visitors to Site work areas must check in with the SSO. Visitors will be cautioned to avoid skin contact with
materials that may be, or are suspected to be, impacted by constituents of concern (COCs).
Visitors requesting to observe work at the Site must don appropriate personal protective equipment (PPE) prior
to entry to the work area and must have the appropriate training and medical clearances to do so. If respiratory
protective devices are necessary, visitors who wish to enter the work area must have been respirator-trained and
fit-tested for a respirator within the past 12 months.
2.4 Stop Work Authority
Every employee of the Parties and their contractors and subcontractors is empowered, expected, and has the
responsibility to stop the work of another co-worker if the working conditions or behaviors are considered
unsafe.
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3. Project Hazards and Control Measures
3.1 Introduction
Field activities will include the following tasks:
• Task 1 – Mobilization/Site Survey;
• Task 2 – Water, Soil, and Air Sampling;
• Task 3 – Drilling and Monitoring Well Installation;
• Task 4 – Residential Sampling and Excavation;
• Task 5 – Sediment Sampling and Processing
• Task 6 – Biota Sampling;
• Task 7 – Personnel and Equipment Decontamination; and
• Task 8 – Demobilization.
3.2 Field Activities, Hazards, and Control Procedures
The following task safety analyses identify potential health, safety, and environmental hazards associated with
each type of field activity listed above. Because of the complex and changing nature of field projects,
supervisors must continually inspect the Site to identify hazards that may affect on-Site personnel, the
community, or the environment. The SSO must be aware of these changing conditions and discuss them with the
OU RI/FS Manager whenever these changes impact employee health, safety, the environment, or performance
of the project. The SSO will keep on-Site personnel informed of the changing conditions and the OU RI/FS
Manager will write and/or approve addenda or revisions to this Site-Wide HASP as necessary.
Each field activity is described below, along with a discussion of potential hazards and control measures for
each activity.
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3.2.1 Task 1 – Mobilization/Site Survey
Appropriate permits will be obtained by the OU RI/FS Manager or designee prior to starting this task.
Site mobilization and area reconnaissance will include establishing staging and decontamination locations,
determining the location of utilities and other installations, and establishing work areas. Mobilization may also
include setting up equipment and establishing a temporary Site office. A break area will be set up outside
regulated work areas. Mobilization may involve clearing areas for the SZ and CRZ.
During this initial phase, the OU RI/FS Manager will walk the Site to confirm the existence of anticipated
hazards and to identify safety and health issues that may have arisen since the writing of this plan. These
activities will be coordinated with personnel representing the Parties. The hazards of this phase of activity are
associated with heavy equipment operation, manual materials handling, installation of temporary on-Site
facilities, and manual Site preparation.
Hazards
Manual materials handling and manual Site preparation may cause blisters, sore muscles, and joint and skeletal
injuries; and may present eye, contusion, and laceration hazards. Installation of temporary field office and
support facilities may expose personnel to electrical hazards, underground and overhead utilities, and physical
injury due to the manual lifting and moving of materials. The work area presents slip, trip, and fall hazards from
scattered debris and irregular walking surfaces. Rainy weather may cause wet, muddy, and/or slick walking
surfaces and unstable soil. Freezing weather hazards include frozen, slick, and irregular walking surfaces.
Utility verification should be done well in advance of activities at a particular location. Attachment A provides
an example check list for use in verifying the location of buried or overhead utilities.
Environmental hazards include plants such as poison ivy and poison oak; aggressive fauna such as ticks,
mosquitoes, dogs, bees, ants, spiders, and snakes; weather such as sun, lightning, rain, and heat- or cold-related
illnesses; and pathogens such as rabies and blood-borne pathogens.
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Control of Hazards
The primary controls for mobilization-related hazards include the following:
• selection, inspection, and use of the proper equipment;
• employee qualifications and training;
• establishment of work zones (EZ, CRZ, and SZ);
• use of a ground guide to position or move vehicles;
• use of the buddy system and internal and external communication systems; and
• appropriate PPE for each task (in most, but not all , cases Level D will be adequate.)
More detailed guidance on the control procedures for these hazards is presented in Section 4. Control
procedures for biological hazards are discussed in Section 4.8.
3.2.2 Task 2 – Water, Soil, and Air Sampling
Field sampling operations may consist of the collection of groundwater, surface water, soil, and air samples for
field screening and/or subsequent laboratory analysis. The physical hazards of this operation are primarily
associated with the sample collection methods and procedures implemented.
During the course of this project, several different sampling methodologies may be used based on equipment
accessibility and the types of materials to be sampled. These sampling methods may include hand
auger/sampling probes or hand trowel sampling operations for soils, use of a mechanical pump and bailer for
groundwater, and use of tedlar bags for air sample collection. Sample media are manually transferred to sample
containers for screening or shipment to an analytical laboratory for analysis. The primary hazards associated
with the specific sampling collection procedures are not generally serious and are briefly described below.
Hazards
Inhalation and absorption of COCs are the primary routes of exposure associated with sampling due to the
manipulation of sample media and equipment, manual transfer of media into sample containers, and proximity
of operations to the breathing zone. During this project, several different sampling methodologies may be used
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based on equipment accessibility and the types of materials to be sampled. For example, during groundwater
sampling, methods may include hand or mechanical bailing. The primary hazards associated with these and
other sampling procedures are not generally serious; however, other operations in the area, or the conditions
under which samples must be collected may present chemical and physical hazards. The hazards associated
with sampling procedures are generally limited to strains or sprains from hand bailing, and other activities and
potential eye hazards. Chemical hazards include contact with media containing Site COCs and potential contact
with chemicals used as preservatives or for field analyses.
Sample collection may occur in locations accessible to vehicular traffic. In such locations, Site personnel must
isolate the work area with barricades, signs, cones, caution tape, or other appropriate means to alert passing
motorists to the presence of an active work area. Also, personnel who are exposed to vehicular traffic must
wear an outer layer of orange warning garments such as vests, jackets, or shirts. If work is performed in
darkness, workers will be outfitted with reflective garments of either orange, white (including silver-coated
reflective coatings or elements that reflect white light), yellow, fluorescent red-orange, or fluorescent yellow-
orange.
The flora and fauna of the Site that may present hazards are poison ivy, poison oak, ticks, ants, mosquitoes,
dogs, bees, spiders, and snakes. The work area presents slip, trip, and fall hazards from scattered debris and
irregular walking surfaces. Rainy weather may cause wet, muddy, slick walking surfaces and unstable soil.
Freezing weather hazards include frozen, slick, and irregular walking surfaces.
Control of Hazards
Dermal exposure can be controlled during sampling activities by wearing a minimum of Level D protection.
Placement of tools and equipment on the ground should be avoided to minimize contact with poisonous or
irritating flora and fauna. Air monitoring may be conducted during groundwater sampling in OU-3 to assess the
potential for exposure to airborne COCs. If the results of air monitoring indicate the presence of organic vapors
in a concentration causing concern, personnel will upgrade to Level C protection. Section 6.1, Air Monitoring,
describes air monitoring requirements and action levels. Each level of personal protection is described in
Section 5, Personal Protective Equipment. Control procedures for environmental and general hazards are
discussed in Section 4, General Site Safety Procedures
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3.2.3 Task 3 – Drilling and Monitoring Well Installation
This task includes the installation of soil borings or monitoring wells at specified locations. The collection of
soil samples will involve the use of direct push type boring equipment (Geoprobe® or equivalent) or a
conventional drill rig. The equipment poses a hazard if it is not properly operated.
3.2.3.1 Geoprobe® Hazards and Control Procedures
Hazards
The primary physical hazards for this activity are associated with the use of the Geoprobe® equipment. The
equipment is hydraulically powered, and uses static force and dynamic percussion force to advance small-
diameter sampling tools.
Accidents can occur as a result of improperly placing the equipment on uneven or unstable terrain, or failing to
adequately secure the equipment prior to the start of operations. Overhead utility lines can create hazardous
conditions if contacted by the equipment. Underground installations such as electrical lines, conduit, and
product lines pose a significant hazard if contacted.
Slippery work surfaces can increase the likelihood of back injuries, overexertion injuries, and slips and falls.
The most common type of accident that occurs in material handling operations is the “caught between” situation
when a load is being handled and a finger or toe gets caught between two objects.
The equipment produces impact noise from the action of the soil-probing hammer.
Control of Hazards
The operator of the equipment must possess required state or local licenses to perform such work. All members
of the crew shall receive Site-specific training prior to beginning work.
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The operator is responsible for the safe operation of the rig, as well as the crew’s adherence to the requirements
of this HASP. The operator must ensure that all safety equipment is in proper condition and is properly used.
The members of the crew must follow all instructions of the operator, wear all personal protective equipment,
and be aware of all hazards and control procedures. The operator and crew must participate in the daily safety
meetings and be aware of all emergency procedures.
Each day, prior to the start of work, the rig and associated equipment must be inspected by the operator. The
following items must be inspected:
• Vehicle condition;
• Proper storage of equipment;
• Condition of all hydraulic lines;
• Fire extinguisher;
• Eyewash kit; and
• First aid kit.
The rig must be properly leveled prior to beginning work. The wheels must be chocked.
All sampling locations will be inspected by the equipment operator prior to the deployment of the equipment to
verify a stable surface exists. This is especially important in areas where soft, unstable terrain is common.
Before beginning any intrusive activity, the existence and location of underground pipe, conduit, electrical
equipment, and other installations will be determined. This will be done, if possible, by contacting the
appropriate client representative or outside line locating service to mark the location of the lines. If knowledge
of the area is incomplete, an appropriate device, such as a magnetometer, will be used by a trained contractor to
locate the line. The Underground/Overhead Utility Checklist shall be used to document that nearby utilities
have been marked on the ground, and that each drilling location has been cleared. The checklist shall be in the
possession of the SSO prior to commencement of the intrusive investigation at that point of the Site (see
Attachment A). During any subsurface drilling, boring, or sampling the first five feet of the entry will be made
with minimal force using manual tools such as a post-hole digger or manual direct push method. If any
evidence of a product line or underground utility is encountered a new sampling location will be selected.
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Dermal exposure can be controlled during sampling activities by wearing a minimum of Level D protection.
Placement of tools and equipment on the ground should be avoided to minimize contact with poisonous or
irritating flora and fauna. Air monitoring may be conducted when using a Geoprobe® in OU-3 to assess the
potential for exposure to airborne COCs. If the results of air monitoring indicate the presence of organic vapors
in a concentration causing concern, personnel will upgrade to Level C protection. Section 6.1, Air Monitoring,
describes air monitoring requirements and action levels. Each level of personal protection is described in
Section 5, Personal Protective Equipment. Control procedures for environmental and general hazards are
discussed in Section 4, General Site Safety Procedures
If equipment is operated in the vicinity of overhead power lines, the power to the lines must be shut off or the
equipment must be positioned and blocked such that no part, including cables, can come within the minimum
clearances as follows:
Table 3-1
Minimum Safe Overhead Electrical Clearances (all equipment)
Nominal System
Voltage
Minimum Required
Clearance
0-50kV 10 feet
51-100kV 12 feet
101-200kV 15 feet
201-300kV 20 feet
301-500kV 25 feet
501-750kV 35 feet
751-1,000kV 45 feet
3.2.3.2 Drilling
Hazards
The primary physical hazards for this activity are associated with the use of the drilling rig. Rig accidents can
occur as a result of improperly placing the rig on uneven or unstable terrain, or failing to adequately secure the
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rig prior to the start of operations. Underground and overhead utility lines can create hazardous conditions if
contacted by drilling equipment. Tools such and equipment such as elevators, cat lines, and wire rope have the
potential for striking, pinning, or cutting personnel. Worn or frayed wire rope presents a laceration hazard if
loose wires protrude from the main bundle.
Cat lines are used on drilling rigs to hoist material. Accidents that occur during cat line operations may injure
the employee doing the rigging as well as the operator. Minimal hoisting control causes sudden and erratic load
movements, which may result in hand and foot injuries.
Slippery work surfaces can increase the likelihood of back injuries, overexertion injuries, and slips and falls.
The most common type of accident that occurs in material handling operations is the "caught between" situation
when a load is being handled and a finger or toe gets caught between two objects. Pipes and/or rolling stock can
shift and/or fall from a pipe rack or truck bed.
Control of Hazards
All drillers must possess required state or local licenses to perform such work. All members of the drill crew
shall receive Site-specific training prior to beginning work.
The driller is responsible for the safe operation of the drill rig as well as the crew's adherence to the
requirements of this HASP. The driller must ensure that all safety equipment is in proper condition and is
properly used. The members of the crew must follow all instructions of the driller, wear all personal protective
equipment, and be aware of all hazards and control procedures. The drill crews must participate in the daily
safety meetings and be aware of emergency procedures.
Each day, prior to the start of work, the drill rig and associated equipment must be inspected by the driller and/or
drill crew. The following items must be inspected:
• Vehicle condition;
• Proper storage of equipment;
• Condition of all wire rope;
• Fire extinguisher;
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• Eyewash kit; and
• First aid kit.
The drill rig must be properly blocked and leveled prior to raising the derrick. Blocking provides a more stable
drilling structure by evenly distributing the weight of the rig. Proper blocking ensures that differential settling of
the rig does not occur. When the ground surface is soft or otherwise unstable, wooden blocks, at least 24" by
24" and 4" to 8" thick shall be placed between the jack swivels and the ground. The emergency brake shall be
engaged, and the wheels that are on the ground shall be chocked. The leveling jacks shall not be raised until the
derrick is lowered. The rig shall be moved only after the derrick has been lowered.
All drilling sites will be inspected by the driller prior to the location of the rig to verify a stable surface exists.
This is especially important in areas where soft, unstable terrain is common.
Before drilling, the existence and location of underground pipe, electrical equipment, and gas lines will be
determined. Public utility companies and property owner representatives will be contacted to mark the location
of existing lines. If necessary, an appropriate device, such as a magnetometer will be used buy a trained
contractor to locate the line prior to commencement of intrusive activities. The Underground/Overhead Utility
Checklist shall be used to document that nearby utilities have been marked on the ground, and that the drill site
has been cleared. The checklist shall be in the possession of the SSO prior to commencement of the intrusive
investigation at that point of the Site (See Attachment A). During any subsurface drilling, boring, or sampling
the first five feet of the entry will be made with minimal force using manual tools such as a post-hole digger or
manual direct push method. If any evidence of a product line or underground utility is encountered a new
sampling location will be selected.
Under no circumstances will personnel be permitted to ride the traveling block or elevators, nor will the catline
be used as a personnel carrier.
If drilling is conducted in the vicinity of overhead power lines, the power to the lines must be shut off or the
equipment must be positioned and blocked such that no part, including cables can come within the minimum
clearances as presented in Table 3-1:
When the drill rig is in transit, with the boom lowered and no load, the equipment clearance must be at least 4
feet for voltages less than 50kV, 10 feet for voltages of 50 kV to 345 kV, and 16 feet for voltages above 345 kV.
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Drillers should never engage the rotary clutch without watching the rotary table, and ensuring it is clear of
personnel and equipment.
Unless the drawworks is equipped with an automatic feed control, the brake should not be left unattended
without first being tied down. Drill pipe, auger strings, or casing should be picked up slowly. Drill pipe should
not be hoisted until the driller is sure that the pipe is latched in the elevator, or the derrickman has signaled that
he may safely hoist the pipe.
During instances of unusual loading of the derrick or mast, such as when making an unusually hard pull, only
the driller should be on the rig floor; no one else should be on the rig or derrick.
The brakes on the drawworks of the drill rig should be tested by the driller each day. The brakes should be
thoroughly inspected by a competent individual each week.
A hoisting line with a load imposed should not be permitted to be in direct contact with any derrick member or
stationary equipment, unless it has been specifically designed for line contact.
Workers should never stand near the borehole whenever any wire line device is being run.
Hoisting control stations should be kept clean and controls labeled as to their functions.
Only experienced workers will be allowed to operate the cathead controls. The kill switch must be clearly
labeled and operational prior to operation of the catline. The cathead area must be kept free of obstructions and
entanglements.
The operator should not use more wraps than necessary to pick up the load. More than one layer of wrapping is
not permitted.
Personnel should not stand near, step over, or go under a cable or catline that is under tension.
Employees rigging loads on catlines shall:
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• Keep out from under the load;
• Keep hands and feet where they will not be crushed;
• Be sure to signal clearly when the load is being picked up;
• Use standard visual signals only and not depend on shouting to coworkers; and
• Make sure the load is properly rigged, since a sudden jerk in the catline will shift or drop the load.
When two wires are broken or rust or corrosion is found adjacent to a socket or end fitting, the wire rope shall
be removed from service or resocketed. Special attention shall be given to the inspection of end fittings on
boom support, pendants, and guy ropes.
Wire rope removed from service due to defects shall be cut up or plainly marked as being unfit for further use as
rigging.
Wire rope clips attached with U-bolts shall have the U-bolts on the dead or short end of the rope; the clip nuts
shall be re-tightened immediately after initial load carrying use and at frequent intervals thereafter.
When a wedge socket fastening is used, the dead or short end of the wire rope shall have a clip attached to it or
looped back and secured to itself by a clip; the clip shall not be attached directly to the live end.
Protruding ends of strands in splices on slings and bridles shall be covered or blunted.
Except for eye splices in the ends of wires and for endless wire rope slings, wire rope used in hoisting, lowering,
or pulling loads, shall consist of one continuous piece without knot or splice. An eye splice made in any wire
rope shall have not less that five full tucks.
Wire rope shall not be secured by knots. Wire rope clips shall not be used to splice rope.
Eyes in wire rope bridles, slings, or bull wires shall not be formed by wire clips or knots.
Pipe and auger sections shall be transported by cart or carried by two persons. Individuals should not carry auger
or pipe sections without assistance.
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Workers should not be permitted on top of the load during loading, unloading, or transferring of pipe or rolling
stock.
Employees should be instructed never to try to stop rolling pipe or casing; they should be instructed to stand
clear of rolling pipe.
Slip handles should be used to lift and move slips. Employees are not permitted to kick slips into position.
When pipe is being hoisted, personnel should not stand where the bottom end of the pipe could whip and present
a hazard striking them.
Pipe and augers stored in racks, catwalks, or on flatbed trucks should be secured to prevent rolling.
Dermal exposure can be controlled during sampling activities by wearing a minimum of Level D protection.
Placement of tools and equipment on the ground should be avoided to minimize contact with poisonous or
irritating flora and fauna. If necessary, based on field observations and Site conditions, air monitoring may be
conducted during drilling in OU-3 to assess the potential for exposure to airborne COCs. If the results of air
monitoring indicate the presence of organic vapors in a concentration causing concern, personnel will upgrade to
Level C protection. Section 6.1, Air Monitoring, describes air monitoring requirements and action levels. Each
level of personal protection is described in Section 5, Personal Protective Equipment. Control procedures for
environmental and general hazards are discussed in Section 4, General Site Safety Procedures
3.2.4 Task 4 – Residential Sampling and Excavation
This task involves household surface dust sampling, as well as surface and subsurface soil sampling followed by
potential excavation of PCB-containing soil (including locating and marking underground utilities) and transport
of removed soil and debris to the designated disposal facility(ies). Activities will be performed in accordance
with all applicable OSHA regulations. Detailed hazard and control information for residential sampling and
excavation can be found within Section 4 of the NTC Removal Action Supplemental Sampling Health and
Safety Plan for the Anniston PCB Site (Docket No. CV-02-PT-0749-E) (Solutia, 2003 – included electronically
as Appendix 1 to this document.) Details of the excavation portion of this task, including a subcontractor-
specific HASP, will be submitted to USEPA under separate cover prior to commencement of work.
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3.2.5 Task 5 – Sediment Sampling and Processing
Sediment sampling will involve collecting samples and preparing them for subsequent field and/or laboratory
analysis. Vibracoring and/or manual coring methods may be utilized during this work.
In general, the primary hazards for sediment sampling include the following:
• working near and around water (drowning, hypothermia);
• caught-between injuries;
• ergonomic stresses; and
• exposure to chemical and biological (water-borne bacteria and microorganisms) hazards, extreme
weather, plants, and insects.
The primary controls for these hazards include the following:
• using only United States Coast Guard- (USCG-) approved equipment, including boats and personal
flotation devices (PFDs);
• completion of the Sediment Sampling Checklist (Attachment B);
• use of the buddy system and internal and external communication systems; and
• appropriate PPE for each task.
More specific hazards/controls related to vibracoring and manual coring are described in greater detail below.
3.2.5.1 Vibracoring/Sediment Sampling
Hazards
Working from a boat presents the obvious hazard of drowning, but several other hazards exist. Other ships and
pleasure craft may be present. Visibility can be hampered due to fog and rain. Water can become rough due to
weather and/or the passing of another vessel. Powered craft carry a fuel supply which has the potential for fire
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or explosion if vapors accumulate and reach an ignition source. Weather, currents, and other watercraft may
also pose significant hazards to the crew.
Many of the physical hazards of vibracoring activities are associated with the equipment, sample collection
methods, procedures utilized, and the Site environment. Specific vibracore hazards include impact from moving
parts, pinch points, wire rope, use of a winch or windlass, overhead hazards, and noise. There exists a potential
for incidents involving personnel being struck by or struck against objects resulting in fractures, lacerations,
punctures, or abrasions. Manual equipment handling may cause blisters, sore muscles, and joint and skeletal
injuries, and may present eye, contusion, and laceration hazards. Walking and working surfaces may involve
slip, trip, and fall hazards due to slippery, unstable, and irregular walking surfaces.
Inhalation and absorption (contact) of COCs are the primary routes of entry associated with sediment sampling
due to the manipulation of sample media and equipment, manual transfer of media into sample containers, and
proximity of operations to the breathing zone.
Environmental hazards while conducting vibracore activities from a boat include weather, such as sunlight, heat
or cold, lightning, and rain as well as pathogens such as fecal coliform and bloodborne pathogens.
Chemical hazards may include contact with sediment, surface water, or other environmental media containing
COCs.
Control of Hazards
At a minimum, each employee working from a boat is required to participate in a boating safety training session
conducted prior to beginning field operations. The training session shall provide instruction on the following
topics: proper boat and safety equipment inspections; content and frequency of equipment safety inspections;
proper use of onboard safety equipment, including fire extinguisher, radio or cellular phone, flares, horn, etc.;
proper procedures on the completion and filing of a float plan; appropriate boating “rules-of-the-road;”
emergency procedures in the event of capsizing or being thrown overboard; and different types of PFDs and
their proper inspection and use.
On-Site personnel working over, adjacent to, or near water, where the danger of drowning exists, must wear a
USCG-approved PFD. Prior to and after each use, the PFD must be inspected for defects, which would alter its
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effectiveness. Defective units must be removed from service. Ring buoys with at least 90 feet of line must be
provided and readily available for emergency rescue operations. Distance from ring buoys shall not exceed 200
feet. At least one boat must be immediately available at locations where personnel are working over or adjacent
to water.
Prior to each day or shift of operations, a vessel inspection must be conducted by the vessel operator. This
inspection shall be conducted in accordance with accepted USCG inspection procedures and applicable state
boating safety inspection procedures. The inspection must verify that necessary safety equipment is aboard and
functioning properly and that all members of the crew are aware of proper procedures that are to be followed on
the water. In addition, this information shall be reviewed during the daily safety meeting to ensure the
procedures have been followed and all crew members are satisfied as to their completion.
It will be the responsibility of the SSO to verify that the daily boat/equipment inspections are completed and
documented and that daily safety meetings are conducted. The following safety procedures shall be observed at
all times:
• Vessels shall not be overloaded with equipment or personnel.
• A minimum of two persons shall be on board during all boat operations.
• Loads shall be distributed evenly throughout the vessel.
• Type I, II, or III PFDs shall be worn at all times when working on or adjacent to the water.
• All PFDs shall be properly inspected to verify that appropriate USCG approvals and ratings information
is available.
• At least one Type IV PFD (seat cushion, ring buoy) shall be available on board.
• An audible signal/alarm (capable of being heard up to 0.5 mile away) shall be maintained in each vessel.
• Each vessel shall be equipped with a ship-to-shore radio, cellular phone, and/or “walkie-talkie” capable
of contacting the USCG, marine police, or other onshore station for help in an emergency.
• Each vessel shall be equipped with some type of visual display signal/device (e.g., flares or appropriate
distress flag).
• All powerboats shall have a valid state registration. This registration shall be maintained on the boat,
and as necessary be made available for USCG or marine police inspection.
• At a minimum, each powerboat shall be equipped with a Type 4-A, 10-B, C-rated fire extinguisher.
• Boats shall not be operated at night without proper lighting and the capability for making visual distress
signals.
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In addition to PFDs, personnel who are working from a boat when water temperatures are below 50 degrees
Fahrenheit (ºF) must be equipped with thermal protective clothing/equipment (e.g., wet suits, dry suits). The
thermal protective clothing must be adequate to protect personnel from hypothermic effects of immersion in
water at the temperatures encountered.
Prior to initiating any activities, Site conditions will be discussed with all employees. Hazards will be identified
and protective measures will be explained. Equipment will be inspected and in proper working condition.
Extreme care will be taken when loading and unloading material and equipment. Proper lifting techniques must
be employed and two-person lifting techniques or mechanical assistance shall be provided for lifting heavy
items. PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2. Hearing
protection must be utilized during generator operation. Air sampling in the processing area will be performed in
accordance with procedures outlined in Section 6.1. The results of air sampling may dictate upgrading to Level
C PPE. Avoidance of biological hazards as discussed in Section 4.8 will be implemented.
3.2.5.2 Manual Coring
Sediment samples may be collected manually from a boat or by wading into the water. This section outlines the
precautions that will be taken by on-Site personnel in these cases.
Hazards
Working from a boat presents the obvious hazard of drowning, but several other hazards exist. Other ships and
pleasure craft may be present. Visibility can be hampered due to fog and rain. Water can become rough due to
weather and/or the passing of another vessel. Powered craft carry a fuel supply which has the potential for fire
or explosion if vapors accumulate and reach an ignition source. Weather, currents, and other watercraft may
also pose significant hazards to the crew. Other hazards while coring from a boat are similar to those presented
in Section 3.2.5.1 (Vibracoring).
Control of Hazards
Given the similarity between this approach and that of collecting samples via vibracoring, refer to Section
3.2.5.1 for information relative to controls.
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Sampling activities may also be carried out using hip waders and the required level of PPE. Waders must be
inspected prior to donning for holes, punctures, tears, or any other defect (i.e., missing straps) that would allow
water to enter. Personnel must wear a USCG-approved PFD or buoyant work vest during all activities
conducted in water. Prior to each use, the PFD or work vest must be inspected for defects that may alter its
strength or buoyancy. Defective units must be tagged “Do Not Use” and removed from service. The “buddy
system” will be strictly adhered to during any water-related activities. At no time will anyone enter the water
without another individual readily available to contact emergency services.
In addition to the drowning hazards associated with working on or near the water, there exists the possibility for
slips, trips, or falls caused by slippery, unstable, and irregular walking surfaces. Waders used for sampling
activities must be properly sized and provide the wearer with adequate traction.
PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2. Air sampling in the
processing area will be performed in accordance with procedures outlined in Section 6.1. The results of air
sampling may dictate upgrading to Level C PPE.
3.2.6 Task 6 – Biota Sampling
Biota sampling activities may involve a potential for exposure to physical and health hazards. Hazards may also
be associated with the Site and the environmental conditions present during the collection of these organisms.
Hazards
The physical hazards of biota sampling activities are primarily associated with the Site environment. There
exists a potential for incidents involving personnel being struck by or struck against objects resulting in
fractures, lacerations, punctures, or abrasions. Manual materials handling may cause blisters, sore muscles, and
joint and skeletal injuries; and may present eye, contusion, and laceration hazards. Walking and working
surfaces during sampling activities my involve slip, trip and fall hazards due to slippery, unstable, and irregular
walking surfaces. Boating and drowning hazards exist and will present potential hazards for employees working
in, or near water, or working from a boat or a barge. Electrical hazards are potentially present from
electrofishing techniques that may be utilized to collect resident fish.
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Chemical hazards may include contact with soil, sediment, surface water, or other environmental media
containing Site COCs and potential contact with chemicals used for biota sample preservation and equipment
decontamination procedures.
Control of Hazards
During sampling activities, a minimum of Level D protection will be worn. A USCG-approved PFD will be
worn if sampling occurs in open waters. Prior to initiating any biota sampling activities, the Site conditions will
be discussed with all employees. Hazards will be identified and protective measures will be explained.
Equipment will be inspected and in proper working condition. Extreme care will be taken when loading and
unloading samples and sampling equipment. Proper lifting techniques must be employed and mechanical
assistance shall be provided for large lifting tasks. Safety procedures outlined throughout the document shall be
implemented. PPE will initially be Level D or Modified Level D as outlined in Section 5.1.1 and 5.1.2 with a
PFD. Air sampling in the processing area will be performed in accordance with procedures outlined in Section
6.1. The results of air sampling may dictate upgrading to Level C PPE. Avoidance of biological hazards as
discussed in Section 4 will be implemented. Equipment shall be operated only by authorized personnel who
have been trained in accordance with the manufacturer’ instructions and recommendations. .
3.2.6.1 Electrofishing
Portable electrofishing equipment may be used to collect specimens from various areas of the Site. All
unauthorized or non-essential personnel will be moved to a safe distance away from active electrofishing
activities. The use of such equipment involves potential hazards related to the high voltage output. Because
water is an excellent conductor of electricity, the operator of the electrofisher must observe certain precautions
in order to avoid injury.
The electrofisher operates by sending current through the cathode, through the water, and to the anode. The
equipment operator must become part of the circuit in order to be shocked. Touching the cathode and anode
simultaneously would complete the circuit and result in a severe electric shock. Although touching only one of
the electrodes would not result in a shock, operators are not permitted to touch the electrodes.
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Symptoms of electric shock range from muscle contraction (unable to let go), potential lung paralysis,
ventricular fibrillation, heart paralysis, severe burns, and death.
General Electrofishing Safety Procedures
The following general safety procedures apply to all types of electrofishers, and should be observed at all times:
• Use electrical lineman gloves of at least 5,000-volt rating. If the gloves become very wet inside, stop
electrofishing and dry them thoroughly.
• Remove wristwatch, rings, and other metal jewelry which is not protected by an insulated material.
• Use only dip nets with insulated or non-conductive handles.
• Make all electrical connections before turning on the power.
• Be sure all personnel are aware that electrofishing is going to begin and that they are clear of electrodes
before turning on the power.
• The equipment must include a switch that keeps the circuit open unless actively and continuously
closed. The operator also will have access to an emergency shut-off switch.
• Operate within acceptable power ranges to prevent overloading the equipment and minimize the
potential of fire hazard.
• During electrofishing, the high voltage flashing light and/or audible tone generator should be working.
• Do not touch people, equipment, or metal objects with the anode or cathode probes/surfaces.
• Wear polarized sunglasses to detect sub-surface hazards and obstacles.
• Turn the power off immediately if a problem occurs and also when the unit is not in use.
The following safety procedures apply specifically to the different types of electrofishing equipment that may be
used.
Backpack Electrofishers
The following safety procedures, including the general procedures listed above, should be observed at all times:
• Use water-tight wading hip boots or chest waders. If the waders or boots become wet inside, stop
electrofishing and dry them thoroughly.
• Operate slowly and carefully to prevent tripping on objects in the stream.
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• Sampling must cease if persons, pets, or livestock are observed in the water or on shore within 12
meters of the electrofishing unit.
• To prevent overloading the unit, do not touch the cathode with the anode.
• Check that the mercury tilt switch shuts off the power when the unit is tipped more than 45° from
vertical.
• Backpack electrofishers add a burden to the user, requiring careful body positioning in order to avoid
back strain.
3.2.7 Task 7 – Personnel and Equipment Decontamination
3.2.7.1 Personnel Decontamination
All personnel that have entered the EZ will be decontaminated prior to leaving the zone.
Hazards
Personnel involved in decontamination activities may be dermally exposed to COCs if decontamination
procedures are not followed.
Control of Hazards
All personnel wearing Modified Level D or Level C protective equipment in the EZ must undergo personal
decontamination prior to entering the SZ. The following materials will be available for decontamination as
needed: galvanized wash tub, tap water, plastic sheeting, alkaline soap solution (Alconox® or other heavy duty
detergent), long handle scrub brushes, disposable plastic to cover the station area, disinfectant wipes to clean the
inside of a respirator, and distilled water in a squeeze bottle for rinsing The personnel decontamination area will
consist of the following stations at a minimum:
• Station 1: Personnel leaving the contaminated zone will remove the gross contamination from their outer
clothing and boots.
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• Station 2: Personnel will remove their outer garments and gloves and dispose of them in properly labeled
containers. Personnel will then decontaminate their hard hats and boots with an aqueous solution of
detergent or other appropriate cleaning solution. These items will then be hand carried to the next station.
• Station 3: Personnel will thoroughly wash their hands and face before leaving the CRZ. Respirators will
be sanitized and then placed in a clean plastic bag.
3.2.7.2 PPE and Equipment Decontamination
All vehicles that have entered the EZ will be decontaminated at the decontamination pad prior to leaving the
zone. If the level of vehicle contamination is low, decontamination may be limited to rinsing of tires and wheel
wells with water. If the vehicle is significantly contaminated, steam cleaning or pressure washing with manual
scrub brushing of vehicles and equipment may be required.
Operations that have the potential to generate or release hazardous material will be conducted in a controlled
area using the appropriate engineering controls. Specific decontamination techniques will be established based
on Site conditions and tasks. Decontamination procedures will be reviewed with all personnel on Site. The
following materials will be available for decontamination as needed: galvanized wash tub, tap water, plastic
sheeting, alkaline soap solution (Alconox® or other heavy duty detergent), long handle scrub brushes,
disposable plastic to cover the station area, disinfectant wipes to clean the inside of a respirator, and distilled
water in a squeeze bottle for rinsing. If the vehicle is significantly contaminated, steam cleaning or pressure
washing with manual scrub brushing of vehicles and equipment may be required. A decontamination pad on a
suitable surface (concrete or paved area) with polyethylene sheeting or other appropriate containment system
will be established COC-impacted equipment will be determined “clean” through visual inspection of all
equipment.
The decontamination facility will be inspected on a daily basis for evidence of leaks or loss of integrity to the
containment system. If any deficiencies are noted, they will be corrected immediately. All waste water and
waste materials generated on Site will be contained in the decontamination system for characterization and
proper disposal.
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Hazards
Personnel involved in decontamination activities may be dermally exposed to contaminated materials and
chemicals brought to the Site as part of the project work. Personnel involved in decontamination including
pressure washing activities may also be exposed to volatile emissions from heavily soiled equipment, high-
pressure water spray, and noise.
Pressure washing is the process of using a stream of water at high pressure to clean or prepare surfaces by
removing foreign matter and contaminants. The hazards of high-pressure water cleaning are related to the high
pressure of the water, which may exceed 10,000 pounds per square inch (psi) at the nozzle.
Contact with the water spray may cause severe lacerations, which may then be contaminated with hazardous
material. Because of the high pressure involved, the opportunity for slicing or injecting the water stream
through soft tissues of the body exists. Pressure washers will also cut through bone at high enough pressures. A
second hazard is repetitive motion, or cumulative trauma disorder. These serious disorders are related to
repeatedly squeezing the trigger or constantly fighting the pressure of the spray gun with the forearm or wrist.
When pressure washing or steaming the health and safety precautions outlined below must be observed.
Pressure washing presents a splash hazard. Protection against splashes to face and skin is mandatory. The
pressure washer is not to be pointed at a person at any time. Steam cleaning presents a thermal burn hazard in
addition to the hazards presented by pressure washing. Adequate protection from the hot surfaces must be
provided.
Control of Hazards
All personnel will review the operating procedures and PPE prior to decontamination. Personnel involved in
decontamination activities must wear PPE that is appropriate for the task (generally Level D) and no more than
one level below the level worn by personnel working in the EZ. Only persons trained in the use and
maintenance of a pressure washer may use such equipment.
Where and whenever possible, single-use, external protective clothing must be used for work within the EZ or
CRZ. This protective clothing must be disposed of in properly labeled containers. Reusable protective clothing
will be rinsed at the Site with detergent and water. The rinsate will be collected for disposal.
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When removed from the CRZ, the respirators will be thoroughly cleaned with soap and water. The respirator
face piece, straps, valves, and covers must be thoroughly cleaned at the end of each work shift, and ready for use
prior to the next shift. Respirator parts may be disinfected with a solution of bleach and water, or by using a
spray disinfectant.
The following general requirements are provided for high-pressure water cleaning activities:
• The gun, pressure piping, pressure hose ends, and couplings will have a burst pressure of at least four
times the operating pressure.
• No equipment or component of such equipment will be operated beyond the manufacturer's
specifications or beyond the rated working pressure.
• The maximum operating pressure will be permanently displayed on the pumping unit.
• Safety glasses, face shield, hearing protection, and safety shoes will be worn during operation.
• Hands should be alternated frequently during long periods of use.
• Operators should be rotated periodically.
• A washer with a gun that supplies water to the wand in a straight line as opposed to supplying water
through the grip will be used. This eliminates the gun's twisting motion.
• The equipment will be maintained in good condition.
• The releasing the trigger must stop the flow of water. The trigger must not be tied back to keep it in an
“on” position.
• A hose safety shroud will be placed on hoses whenever operating pressure exceeds 2,000 psi.
• The pressure control will be a "deadman" type to safely reduce the nozzle discharge pressure when
control is released.
• The pressure discharge gauge indicating pump pressure will be clearly visible for monitoring pump
pressure.
• A pressure relief device set to relieve at 110% of the maximum working pressure of the unit or its
components, whichever is lower, will be installed on the pump. The relief will be clearly marked and
displayed on the device.
• A strainer or filter should be installed on the water supply system to prevent debris from entering the
water blasting units and clogging the gun, control, or other device.
• If a water line breaks, it may whip about; therefore, relieve the pressure before trying to grab the line.
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3.2.8 Task 8 – Demobilization
Demobilization involves removing all tools, equipment, supplies, and vehicles brought to the Site. The hazards
of this phase of activity are associated with heavy equipment operation and manual materials handling.
Hazards
Manual materials handling may cause blisters, sore muscles, and joint and skeletal injuries and may present eye,
contusion, and laceration hazards. Heavy equipment operation presents noise and vibration hazards and hot
surfaces to operators. Personnel in the vicinity of heavy equipment operation may be exposed to physical
hazards resulting in fractures, contusions, and lacerations and may be exposed to high noise levels. The work
area presents slip, trip, and fall hazards from scattered debris and irregular walking surfaces. Rainy weather may
cause wet, muddy, and slick walking surfaces and unstable sediment. Freezing weather hazards include frozen,
slick, and irregular walking surfaces.
Environmental hazards include plants, such as poison ivy and poison oak; aggressive fauna, such as ticks,
mosquitoes, dogs, bees, ants, spiders, and snakes; weather, such as sun, lightning, rain, and heat- or cold-related
illnesses; and pathogens, such as rabies and bloodborne pathogens.
Control of Hazards
The primary controls for these hazards include the following:
• selection, inspection, and use of the proper equipment;
• employee qualifications and training;
• establishment of work zones: EZ, CRZ and SZ, with adequate containment areas;
• use of the buddy system and internal and external communication systems; and
• appropriate PPE for each task (generally Level D).
Control procedures for these hazards are discussed in more detail in Section 4. Section 4.8 presents control
measures for biological hazards.
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3.3 Chemical Hazards
The chemical hazards associated with Site activities are related to inhalation, ingestion, and dermal exposure to
soil, sediment, surface water, and groundwater containing COCs. Although PCBs are the primary COC at the
Site, parathion and paranitrophenol (and breakdown products) may be encountered in groundwater. Specific
health and safety information regarding PCBs, parathion, and paranitrophenol are found in the Chemical Hazard
Information Tables in Attachment C, D and E respectively. The Material Safety Data Sheet (MSDS) for these
chemicals are also included in these Attachments.
The potential for inhalation of COCs during Site activities is low. The potential for dermal contact during Site
activities is moderate
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4. General Safety Practices
4.1 General Safety Rules
At least one copy of this Site-Wide HASP must be in a location at the Site that is readily available to personnel,
and all project personnel shall review the plan prior to starting work. General safety rules for Site activities
include, but are not limited to, the following:
• All work performed on the Facility property will be conducted in accordance with Facility-specific
health and safety requirements.
• Consume or use food, beverages, chewing gum, and tobacco products only in the SZ or other designated
area outside the EZ and CRZ. Cosmetics must not be applied in the EZ or CRZ.
• Wash hands before eating, drinking, smoking, or using toilet facilities.
• Wear all PPE as required and stop work and replace damaged PPE immediately.
• Secure disposable coveralls, boots, and gloves at the wrists and legs and confirm closure of the suit
around neck.
• Upon skin contact with materials that may be impacted by COCs, remove contaminated clothing and
wash the affected area immediately. Contaminated clothing must be changed. Any skin contact with
materials potentially impacted by COCs must be reported to the SSO or HSC immediately. If needed,
medical attention should be sought.
• Practice contamination avoidance. Avoid contact with surfaces either suspected or known to be
impacted by COCs, such as standing water, mud, or discolored sediment. Equipment must be stored on
elevated or protected surfaces to reduce the potential for incidental contamination.
• Remove PPE as required in the CRZ to limit the spread of COC-containing materials.
• At the end of each shift, or as required, dispose of all single-use coveralls, soiled gloves, and respirator
cartridges in receptacles designated for this purpose.
• Do not remove materials containing Site COCs from protective clothing or equipment by using
compressed air, shaking, or any other means that disperses contaminants into the air.
• Inspect all non-disposable PPE for contamination in the CRZ. Any PPE found to be contaminated must
be decontaminated or disposed of appropriately.
• Recognize emergency signals used for evacuation, injury, fire, etc.
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• Report all injuries, illnesses, near misses, and unsafe conditions or work practices to the SSO or HSC.
• Use the “buddy system” during all operations requiring Level C PPE and, when appropriate, during
Level D operations.
• Obey all warning signs, tags, and barriers. Do not remove any warnings unless authorized to do so.
• Use, adjust, alter, and repair equipment only if trained and authorized to do so and in accordance with
the manufacturer’s directions.
• Personnel are to perform only tasks for which they have been properly trained and will advise their
supervisor if they have been assigned a task for which they are not trained.
• The presence or consumption of alcoholic beverages or illicit drugs during the workday, including
breaks, is strictly prohibited. If your job requires equipment operation, let your supervisor know if you
must take prescription or over-the-counter drugs that state “do not operate heavy equipment,” or “may
cause drowsiness.”
• Remain upwind during Site activities whenever possible.
• Be aware of your surroundings. Watch out for uneven or slippery terrain. The majority of injuries
occur due to slips, trips, and falls.
4.2 Incident Investigation
An incident is any of the following events: first aid cases, injuries, illnesses, near misses, spills/leaks, equipment
and property damage, motor vehicle accidents, regulatory violations, fires, and business interruptions. All
incidents shall be investigated within 24 hours and reported to the OU RI/FS Manager and the HSO.
The purpose of an incident investigation is to prevent the recurrence of a similar hazardous event. An incident
investigation is set up so that all incidents in are reviewed in the same manner. Using the information gathered
during an incident investigation, appropriate measures will be taken to protect personnel from the hazard in
question. The Incident/Near-Miss Investigation Report is included in Attachment F.
4.3 Safe Work Observation
The SSO or the HSC will perform the SWO according to a schedule established by the HSC (see Section 7.1.12
for more information and Attachment G for the SWO Form). The purpose of the SWO is to identify and correct
potential hazards and to positively reinforce behaviors and practices that are correct. The SSO or HSC must
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identify potential deviations from safe work practices that could possibly result in an incident and take prompt
corrective action. The SWO process includes the following steps:
• Identify tasks that have the greatest potential for hazardous incidents.
• Review the standard procedure for completing the task.
• Discuss with the observed employee the task and the SSO/HSC role in observing the task.
• Observe the employee completing the task.
• Reference the SWO Form for criteria. Complete the form, documenting positive actions as well as areas
in need of improvement.
• Discuss the results of the SWO with the employee. Discuss any corrective action that is necessary.
• Implement corrective action.
• Communicate the results of the SWO and corrective action to the OU RI/FS Manager and the HSO.
4.4 Activity Hazard Analysis (AHA)
AHA is a tool used to identify potential hazards and to develop corrective or protective systems to eliminate the
hazard. An AHA lists the potential hazards associated with an activity and shall be performed prior to
implementing any major investigation or remedial activity and will be included in OU-specific or contractor-
specific HASPs. Hazards may be physical, such as lifting hazards or eye hazards, or environmental, such as
those related to weather or biological hazards (stinging insects, snakes, etc.). After identifying the hazards
associated with an activity, control measures are evaluated and protective measures or procedures are then
instituted. AHAs are reviewed periodically to confirm that the procedures and protective equipment specified
for each activity are current and technically correct. Any changes in Site conditions and/or the scope of work
may require a review and modification to the AHA in question. During this review process, comments on the
AHA and its procedures should be obtained from personnel associated with the activity being analyzed.
4.5 Buddy System
On-Site personnel must use the “buddy system” as required by operations. Use of the buddy system is required
during all operations requiring Level C PPE and, when appropriate, during Level D operations. Crew members
in Level C PPE must observe each other for signs of chemical exposure and heat or cold stress. Indications of
adverse effects include, but are not limited to:
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• changes in complexion and skin coloration;
• changes in coordination;
• changes in demeanor;
• excessive salivation and pupillary response; and
• changes in speech pattern.
Crew members must also be aware of the potential exposure to possible safety hazards, unsafe acts, or non-
compliance with safety procedures.
Field personnel must inform their partners or fellow crew members of non-visible effects of exposure to toxic
materials that they may be experiencing. The symptoms of such exposure may include, but are not limited to:
• headaches;
• dizziness;
• nausea;
• blurred vision;
• cramps; and
• irritation of eyes, skin, or respiratory tract.
If protective equipment or noise levels impair communications, pre-arranged hand signals must be used for
communication. Personnel must stay within line of sight of another team member.
Less stringent use of the buddy system is beneficial during operations requiring Level D PPE to the extent that
someone other than the person performing the activity knows where work is being performed and what activities
are being performed, especially if work is being performed in isolated areas, around water, or in extreme
temperatures.
4.6 Heat Stress
Heat stress is caused by several interacting factors, including environmental conditions, clothing, and workload,
as well as the physical and conditioning characteristics of the individual. Since heat stress is one of the most
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common illnesses associated with heavy outdoor work conducted with direct solar load and, in particular,
because wearing PPE can increase the risk of developing heat stress, workers must be capable of recognizing the
signs and symptoms of heat-related illnesses. Personnel must be aware of the types and causes of heat-related
illnesses and be able to recognize the signs and symptoms of these illnesses in both themselves and their co-
workers.
Heat rash is one of the most common problems in hot work environments. Commonly known as prickly heat, a
heat rash is manifested as red papules and usually appears in areas where the clothing is restrictive. As sweating
increases, these papules give rise to a prickling sensation. Prickly heat occurs in skin that is persistently wetted
by unevaporated sweat, and heat rash papules may become infected if they are not treated. In most cases, heat
rashes will disappear when the affected individual returns to a cool environment.
Heat cramps are usually caused by performing hard physical labor in a hot environment. These cramps have
been attributed to an electrolyte imbalance caused by sweating. It is important to understand that cramps can be
caused both by too much and too little salt.
Cramps appear to be related to a lack of water replenishment. Because sweat is a hypotonic solution (plus or
minus 0.3% NaCl), excess salt can build up in the body if the water lost through sweating is not replaced. Thirst
cannot be relied on as a guide to the need for water; instead, water must be taken every 15 to 20 minutes in hot
environments.
Under extreme conditions, such as working for 6 to 8 hours in heavy protective gear, a loss of sodium may
occur. Drinking commercially available carbohydrate electrolyte replacement liquids is effective in minimizing
physiological disturbances during recovery.
Heat exhaustion occurs from increased stress on various body organs due to inadequate blood circulation,
cardiovascular insufficiency, or dehydration. Signs and symptoms include pale, cool, moist skin; heavy
sweating; dizziness; nausea; headache, vertigo, weakness, thirst, and giddiness. Fortunately, individuals in this
condition respond readily to prompt treatment.
Heat exhaustion should not be dismissed lightly, however, for several reasons. One is that the fainting associated
with heat exhaustion can be dangerous because the victim may be operating machinery or controlling an
operation that should not be left unattended; moreover, the victim may be injured when he or she faints. Also,
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the signs and symptoms seen in heat exhaustion are similar to those of heat stroke, which is a medical
emergency.
Workers suffering from heat exhaustion should be removed from the hot environment, given fluid replacement,
and be encouraged to get adequate rest.
Heat stroke is the most serious form of heat stress. Heat stroke occurs when the body’s system of temperature
regulation fails, and the body’s temperature rises to critical levels. This condition is caused by a combination of
highly variable factors and its occurrence is difficult to predict.
Heat stroke is a medical emergency. The primary signs and symptoms of heat stroke are elevated or erratic
pulse; confusion; irrational behavior; loss of consciousness; convulsions; a lack of sweating (usually); hot, dry
skin; and an abnormally high body temperature. If body temperature is too high, it causes death. The elevated
metabolic temperatures caused by a combination of workload and environmental heat load, both of which
contribute to heat stroke, are also highly variable and difficult to predict.
If a worker shows signs of possible heat stroke, professional medical treatment should be obtained immediately.
The worker should be placed in a shady area and the outer clothing should be removed. The worker’s skin
should be wetted and air movement around the worker should be increased to improve evaporative cooling until
professional methods of cooling are initiated and the seriousness of the condition can be assessed. Fluids should
be replaced as soon as possible. The medical outcome of an episode of heat stroke depends on the victim’s
physical fitness and the timing and effectiveness of first-aid treatment.
Regardless of the worker’s protestations, no employee suspected of being ill from heat stroke should be sent
home or left unattended unless a physician has specifically approved such an order.
Proper training and preventive measures will help avert serious illness and loss of work productivity. Preventing
heat stress is particularly important because once someone suffers from heat stroke or exhaustion, that person
may be predisposed to additional heat injuries.
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Safety Precautions for Heat Stress Prevention
Heat stress monitoring and work-rest cycle implementation should commence when the ambient adjusted
temperature exceeds 72°F. A minimum work-rest regimen and procedures for calculating ambient adjusted
temperature are described in Table 4-1.
Table 4-1
Work/Rest Schedule1
Adjusted Temperature2
Work/Rest Regimen
Normal Work Ensemble3
Work/Rest Regimen
Impermeable Ensemble
90ºF (32.2ºC) or above After each 45 minutes of work After each 15 minutes of work
87.5º-90ºF (30.8º-32.2ºC) After each 60 minutes of work After each 30 minutes of work
82.5º-87.5ºF (28.1º-30.8ºC) After each 90 minutes of work After each 60 minutes of work
77.5º-82.5ºF (25.3º-28.1ºC) After each 120 minutes of work After each 90 minutes of work
72.5º-77.5ºF (30.8º-32.2ºC) After each 150 minutes of work After each 120 minutes of work
1 For work levels of 250 kilocalories/hour (light to moderate type of work) 2 Calculate the adjusted air temperature (ta adj) by using this equation: ta adj oF = ta oF + (13 x % sunshine). Measure
air temperature (ta) with a standard mercury-in-glass thermometer, with the bulb shielded from radiant heat. Estimate
percent sunshine by judging what percent time the sun is not covered by clouds that are thick enough to produce a
shadow. (100% sunshine = no cloud cover and a sharp, distinct shadow; 0% sunshine = no shadows.) 3 A normal work ensemble consists of cotton coveralls or other cotton clothing with long sleeves and pants. 4 Rest cycle is assumed to last 5-15 minutes.
Source: The information presented above was generated using the information provided in the American Conference of Governmental
Industrial Hygienists (ACGIH) Threshold Limit Values [TLV] Handbook (2003a).
In order to determine whether the work-rest cycles are adequate for the personnel and specific Site conditions,
additional monitoring of individual heart rates will be conducted during the rest cycle. Personnel are
responsible for monitoring their own heart rates. To check the heart rate, count the radial pulse for 30 seconds at
the beginning of the rest period. If the heart rate exceeds 110 beats per minute, shorten the next work period by
one-third and maintain the same rest period.
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Additionally, one or more of the following control measures can be used to help control heat stress and is
mandatory if any worker has a heart rate (measure immediately prior to rest period) exceeding 115 beats per
minute:
• Site workers will be encouraged to drink plenty of water and electrolyte replacement fluids throughout
the day.
• On-Site drinking water will be kept cool (50 to 60°F).
• A work regimen that provides adequate rest periods for cooling down will be established, as required.
• All personnel will be advised of the dangers and symptoms of heat stroke, heat exhaustion, and heat
cramps.
• Cooling devices, such as vortex tubes or cooling vests, should be used when personnel must wear
impermeable clothing in conditions of extreme heat.
• Employees should be instructed to monitor themselves and their buddy (if applicable) for signs of heat
stress, and to take additional breaks as necessary.
• A shaded rest area must be provided. All breaks should take place in the shaded rest area.
• Employees must not be assigned to other tasks during breaks.
• Employees must remove impermeable garments during rest periods. This includes white Tyvek®-type
garments.
• All employees must be informed of the importance of adequate rest, acclimation, and proper diet in the
prevention of heat stress disorders.
4.7 Cold Stress
Cold stress normally occurs in temperatures at or below freezing or under certain circumstances in temperatures
of 40°F. Extreme cold for a short time may cause severe injury to exposed body surfaces or result in profound
generalized cooling, causing death. Areas of the body that have high surface area-to-volume ratio, such as
fingers, toes, and ears, are the most susceptible. Two factors influence the development of a cold-weather injury:
ambient temperature and the velocity of the wind. For instance, 10°F with a wind of 15 miles per hour (mph) is
equivalent in chilling effect to still air at -18°F. An equivalent chill temperature chart relating the actual dry-bulb
temperature and wind velocity is presented in Table 4-2.
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Table 4-2
Chill Temperature Chart
Actual Temperature Reading (ºF)
Estimated Wind
Speed (in mph)
50 40 30 20 10 0 -10 -20 -30 -40 -50 -60
Equivalent Chill Temperature (ºF)
Calm 50 40 30 20 10 0 -10 -20 -30 -40 -50 -60
5 48 37 27 16 6 -5 -15 -26 -36 -47 -57 -68
10 40 28 16 4 -9 -24 -33 -46 -58 -70 -83 -95
15 36 22 9 -5 -18 -32 -45 -58 -72 -85 -99 -112
20 32 18 4 -10 -25 -39 -53 -67 -82 -96 -110 -121
25 30 16 0 -15 -29 -44 -59 -74 -88 -104 -118 -133
30 28 13 -2 -18 -33 -48 -63 -79 -94 -109 -125 -140
35 27 11 -4 -20 -35 -51 -67 -82 -98 -113 -129 -145
40 26 10 -6 -21 -37 -53 -69 -85 -100 -116 -132 -148
(Wind speeds
greater than 40
mph have little
additional
effect.)
Little Danger
Maximum danger of false
sense of security.
Increasing Danger
Danger from freezing
of exposed flesh
within 1 minute.
Great Danger
Flesh may freeze within 30
seconds.
Trench foot and immersion foot may occur at any point on this chart.
This chart was developed by the U.S. Army Research Institute of Environmental Medicine, Natick, MA.
[Source: ACGIH TLV Handbook, 2003a]
Local injury resulting from cold is included in the generic term frostbite. There are several degrees of tissue
damage associated with frostbite. Frostbite of the extremities can be categorized into:
• Frost Nip or Incipient Frostbite – Characterized by sudden blanching or whitening of skin.
• Superficial Frostbite – Skin has a waxy or white appearance and is firm to the touch, but tissue beneath
is resilient.
• Deep Frostbite – Tissues are cold, pale, and solid; extremely serious injury.
Systemic hypothermia is caused by exposure to freezing or rapidly dropping temperature. It can be fatal. Its
symptoms are usually exhibited in five stages:
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1) shivering;
2) apathy, listlessness, sleepiness, and (sometimes) rapid cooling of the body to less than 95°F;
3) unconsciousness, glassy stare, slow pulse, and slow respiratory rate;
4) freezing of the extremities; and
5) death.
Trauma sustained in freezing or sub-zero conditions requires special attention because an injured worker is
predisposed to secondary cold injury. Special provisions must be made to prevent hypothermia and secondary
freezing of damaged tissues in addition to providing for first-aid treatment. To avoid cold stress, Site personnel
must wear protective clothing appropriate for the level of cold and physical activity. In addition to protective
clothing, preventive safe work practices, additional training, and warming regimens may be used to prevent cold
stress.
Safety Precautions for Cold Stress Prevention
The following safety precautions should be followed to prevent cold stress:
• At air temperature of 0°F or less, mittens should be used to protect the hands. For exposed skin,
continuous exposure should not be permitted when air speed and temperature results in a wind chill
temperature of -25°F.
• At air temperatures of 36°F or less, field personnel who become immersed in water or whose clothing
becomes wet must be immediately provided with a change of clothing and be treated for hypothermia.
• If work is done at normal temperature or in a hot environment before entering the cold, the field
personnel must confirm that their clothing is not wet as a consequence of sweating. If clothing is wet,
field personnel must change into dry clothes prior to entering the cold area.
• If the available clothing does not give adequate protection to prevent hypothermia or frostbite, work
must be modified or suspended until adequate clothing is made available or until weather conditions
improve.
• Field personnel handling evaporative liquid (e.g., gasoline, alcohol, or cleaning fluids) at air
temperatures below 40°F must take special precaution to avoid soaking of clothing or gloves with the
liquids because of the added danger of cold injury due to evaporative cooling.
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• Employees should be instructed to monitor themselves and their buddy for signs of cold stress and to
take additional breaks if necessary.
Safe Work Practices
The following safe work practices must be employed to prevent cold stress:
• Direct contact between bare skin and cold surfaces (< 20°F) should be avoided. Metal tool handles
and/or equipment controls should be covered by thermal insulating material.
• For work performed in a wind chill temperature at or below 10°F, workers should be under constant
protective observation (buddy system). The work rate should be established to prevent heavy sweating
that will result in wet clothing. For heavy work, rest periods must be taken in heated shelters and
workers should be provided with an opportunity to change into dry clothing if needed.
• Field personnel should be provided the opportunity to become accustomed to cold-weather working
conditions and required protective clothing.
• Work should be arranged in such a way that sitting or standing still for long periods is minimized.
• During the warming regimen (rest period), field personnel should be encouraged to remove outer
clothing to permit sweat evaporation or to change into dry work clothing. Dehydration, or loss of body
fluids, occurs insidiously in the cold environment and may increase susceptibility to cold injury due to a
significant change in blood flow to the extremities. Fluid replacement with warm, sweet drinks and
soups is recommended. The intake of coffee should be limited because of diuretic and circulatory
effects.
4.8 Biological Hazards
Hazards may include ticks, poisonous plants, snakes, dogs, spiders, mosquitoes, and bees.
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4.8.1 Tick-Borne Diseases
Hazards
Rocky Mountain Spotted Fever: This disease is transmitted via the bite of an infected tick. The tick must be
attached 4 to 6 hours before the disease-causing organism (Rickettsia rickettsii) becomes reactivated and can
infect humans. The primary symptom of Rocky Mountain Spotted Fever is the sudden appearance of a
moderate-to-high fever. The fever may persist for 2 to 3 weeks. The victim may also have a headache, deep
muscle pain, and chills. A rash appears on the hands and feet on about the third day and eventually spreads to all
parts of the body. For this reason, Rocky Mountain Spotted Fever may be confused with measles or meningitis.
The disease may cause death if untreated, but if identified and treated promptly, death is uncommon.
Lyme Disease: This disease is transmitted primarily via the bite of an infected deer tick, which is smaller and
redder than the common wood tick. It may also be transmitted by immature ticks, which are small and hard to
see. The tick may be as small as a period on this page. Symptoms of Lyme disease include a rash or a peculiar
red spot, like a bull’s eye, which expands outward in a circular manner. The victim may have headache,
weakness, fever, a stiff neck, and swelling and pain in the joints, and eventually, arthritis.
Control of Hazards
Tick repellant containing diethyltoluamide (DEET) should be used when personnel are working in tick-infested
areas, and pant legs should be tucked into boots. In addition, workers should search the entire body every 3 or 4
hours for attached ticks. Ticks should be removed promptly and carefully without crushing, since crushing can
squeeze the disease-causing organism into the skin. A gentle and steady pulling action should be used to avoid
leaving the head or mouth parts in the skin. Hands should be protected with surgical gloves when removing
ticks.
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4.8.2 Poisonous Plants
Hazards
Poisonous plants (e.g., poison ivy, poison sumac, and poison oak) may be present in the work area. Personnel
should be alerted to their presence and instructed on methods to prevent exposure.
Control of Hazards
The main control is to avoid contact with the plant, cover arms and hands, and frequently wash potentially
exposed skin. Particular attention must be given to avoiding skin contact with objects or protective clothing that
have touched the plants. Treat every surface that may have touched the plant as contaminated, and practice
contamination avoidance. If skin contact is made, the area should be washed immediately with soap and water,
and observed for signs of reddening.
4.8.3 Snakes
Hazards
The possibility of encountering snakes exists, specifically for personnel working in wooded/vegetated areas.
Snake venoms are complex and include proteins, some of which have enzymatic activity. The effects produced
by venoms include neurotoxic effects with sensory, motor, cardiac, and respiratory difficulties; cytotoxic effects
on red blood cells, blood vessels, heart muscle, kidneys, and lungs; defects in coagulation; and effects from local
release of substances by enzymatic actions. Other noticeable effects of venomous snakebites include swelling,
edema, and pain around the bite, and the development of ecchymosis (the escape of blood into tissues from
ruptured blood vessels). Snakes encountered may range from common garter and watersnakes to rat snakes,
king snakes, and pit vipers.
Control of Hazards
To minimize the threat of snakebites, all personnel walking through vegetated areas must be aware of the
potential for encountering snakes and the need to avoid actions potentiating encounters, such as turning over
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logs. If a snakebite occurs, an attempt should be made to safely identify the snake via size and markings. The
victim must be transported to the nearest hospital within 30 minutes. First aid consists of applying a constriction
band and washing the area around the wound to remove any unabsorbed venom.
4.8.4 Dogs
Hazards
Sampling is to take place on residential property. In some instances residents may have dogs, which may be
unfriendly to field personnel.
Control of Hazards
The sampling team will not sample properties where dogs are loose in the yard without the immediate and
constant presence of the dog owner. In most cases, the samplers should not proceed to conduct sampling unless
the dog is restrained. Additionally, the sampling team should be aware that wild, stray or unleashed dogs might
be present in the residential neighborhoods. If such dogs are encountered, the sampling team should not
approach or provoke the animals but they may report the animal(s) to the Anniston Police Department Animal
Control, if encountered within city limits. The Anniston Police Department can be reached at (256) 238-1800.
Otherwise, Calhoun County Animal Control may be called. Calhoun County Animal Control can be reached at
(256) 310-4268. Mace may be used as a deterrent, if attacked.
4.8.5 Spiders
Hazards
The possibility of personnel encountering spiders exists during work activities.
Two spiders are of primary concern: the black widow and the brown recluse. Both prefer dark, sheltered areas
such as basements, equipment sheds and enclosures, and around woodpiles or other scattered debris. The black
widow is shiny black, approximately one inch long, and found throughout the United States. There is a
distinctive red hourglass marking on the underside of the black widow’s body. The bite of a black widow is
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seldom fatal to healthy adults, but effects include respiratory distress, nausea, vomiting, and muscle spasms. The
brown recluse is smaller than the black widow and gets its name from its brown coloring and behavior. The
brown recluse is more prevalent in the southern United States. It has a distinctive violin shape on the top of its
body. The bite of the brown recluse is painful, and the bite site ulcerates and takes many weeks to heal
completely.
Control of Hazards
To minimize the threat of spider bites, all personnel walking through vegetated areas must be aware of the
potential for encountering these arachnids. Personnel need to avoid actions that may result in encounters, such as
turning over logs and placing hands in dark places such as behind equipment or in corners of equipment sheds or
enclosures. If a spider bite occurs, the victim must be transported to the nearest hospital as soon as possible.
First aid consists of applying ice packs and washing the area around the wound to remove any unabsorbed
venom.
4.8.6 Mosquitoes
Hazards
Personnel may be exposed to mosquitoes during work activities. Typical exposure to mosquitoes does not
present a significant hazard. However, if West Nile virus is prevalent in the area, exposure to this virus is
increased. West Nile virus results in flu-like symptoms and can be serious if not treated or in immune
compromised individuals.
Control of Hazards
To minimize the threat of mosquito bites, all personnel working outside must be aware of the potential for
encountering mosquitoes and implement the basic precautions listed below:
• Avoid working at dawn or dusk when mosquitoes are most active.
• Prevent accumulation of standing water at the work Site.
• Apply an insect repellent that contains DEET to exposed skin and to clothing.
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• Wear light-colored clothes, preferably with long sleeves and full-length pants.
• Do not touch any dead birds or animals that are encountered.
If dead birds are detected near the Site, report them to the local County Health Department. If individuals
experience flu-like symptoms, a doctor or the HSO should be contacted for more information.
4.8.7 Bees, Ants and Other Insects
Hazards
A variety of Insects may be present at the Site. Although stings or bites can be painful, they rarely cause death.
However, some people have a severe reaction to an insect bite or sting that can result in a life-threatening
condition.
Control of Hazards
To minimize the threat of bites or stings, all personnel should implement the following precautions:
• Apply insect repellant as described above.
• Wear proper protective clothing.
• When working in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.
• Use caution when opening monitoring well caps; inspect potential nesting areas before entering casing,
vaults, etc. If desired, leather gloves may be worn.
• Field personnel who may have insect allergies should provide this information to the HSO prior to
commencing work. If allergic to bees, employee must bring an epi-pen.
• Mark and avoid fire ant mounds and bee hives
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4.9 Noise
Hazards
Exposure to noise over the appropriate action level can cause temporary impairment of hearing; prolonged and
repeated exposure can cause permanent damage to hearing. The risk and severity of hearing loss increase with
the intensity and duration of exposure to noise. In addition to damaging hearing, noise can impair voice
communication, thereby increasing the risk of accidents on Site.
Control of Hazards
All personnel must wear hearing protection, with a noise reduction rating (NRR) of at least 20 decibels adjusted
(dBA), when noise levels exceed 85 dBA. When it is difficult to hear a co-worker at normal conversation
distance, the noise level is approaching or exceeding 85 dBA and hearing protection is necessary. All Site
personnel who may be exposed to noise must also receive baseline and annual audiograms and training as to the
causes and prevention of hearing loss. Noise monitoring is discussed in Section 6, Air and Noise Monitoring.
Whenever possible, equipment that does not generate excessive noise levels will be selected. If the use of noisy
equipment is unavoidable, barriers or increased distances will be used to minimize worker exposure to noise, if
feasible.
4.10 Spill Control
All personnel must take every precaution to minimize the potential for spills during Site activities. All on-Site
personnel must immediately report any discharge, no matter how small, to the SSO.
Spill control equipment and materials will be located on Site in the areas that present the potential for discharge.
All sorbent materials used to clean up spills will be containerized and labeled appropriately. In the event of a
spill, the SSO will follow the emergency provisions in Section 9, Emergency Procedures, to contain and control
released materials and to prevent their spread to off-Site areas.
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4.11 Sanitation
Site sanitation will be maintained according to appropriate federal, state, and local requirements as described in
the following sections.
4.11.1 Break Area
Breaks must be taken in the SZ, away from the active work area, after Site personnel go through
decontamination procedures. There will be no smoking, eating, drinking, or chewing gum or tobacco in any area
other than the SZ.
4.11.2 Potable Water
The following rules regarding potable water apply to all field operations:
• An adequate supply of potable water will be provided at each project location. Potable water must be
kept away from hazardous materials or media and contaminated clothing or equipment.
• Portable containers used to dispense drinking water must be capable of being tightly closed and must be
equipped with a tap dispenser. Water must not be consumed directly from the container (drinking from
the tap is prohibited) or removed from the container by dipping.
• Containers used for drinking water must be clearly marked and must not be used for any other purpose.
• Disposable drinking cups must be provided. A sanitary container for dispensing cups and a receptacle
for disposing of used cups is required.
4.11.3 Sanitary Facilities
Access to facilities for washing before eating, drinking, or smoking, or alternative methods such as waterless
hand cleaner and paper towels, will be provided.
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4.11.4 Lavatory
If permanent toilet facilities are not available, an appropriate number of portable chemical toilets will be
provided. This requirement does not apply to mobile crews or to normally unattended Site locations so long as
employees at these locations have transportation immediately available to nearby toilet facilities.
4.12 Emergency Equipment
Adequate emergency equipment for the activities being conducted on Site and as required by applicable sections
of 29 Code of Federal Regulations (CFR) 1910 and 29 CFR 1926 will be on Site prior to commencing project
activities. Personnel will be provided with access to emergency equipment including, but not limited to, the
following:
• Fire extinguishers of adequate size, class, number, and location as required by applicable sections of 29
CFR 1910 and 1926;
• Industrial first-aid kits of adequate size for the number of personnel on Site; and
• Emergency eyewash and/or shower if required by operations being conducted on Site.
4.13 Lockout/Tagout Procedures
Lockout/tagout procedures are necessary when working around or with a variety of equipment and energy
sources that can present significant life-threatening hazards to workers. Unexpected start-up of equipment or
exposure to hazardous energy must be controlled.
Lockout is the placement of a device that uses a positive means, such as lock, to hold an energy or material-
isolating device such that the equipment cannot be operated until the lockout device is removed. If a device
cannot be locked out, a tagout system shall be used. Tagout is the placement of a warning tag on an energy or
material isolating device indicating that the equipment controls may not be operated until the tag is removed by
the individual who attached the tag. Locks and tags will be issued to authorized personnel by the SSO.
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Personnel involved in lockout/tagout activities must be trained according to their role and level of responsibility.
In lockout/tagout procedures there are two types of personnel: authorized personnel and affected personnel.
Authorized personnel are trained and experienced in the hazards and control measures who locks out or tags out
machines or equipment in order to perform servicing or maintenance on that machine or equipment. Affected
personnel become authorized personnel when their duties include performing servicing or maintenance covered
under this section. Authorized personnel possess the skills knowledge or certifications to implement the
lockout/tagout program.
Affected personnel are those job requires him/her to operate or use a machine or equipment on which servicing
or maintenance is being performed under lockout or tagout, or whose job requires him/her to work in an area in
which such servicing or maintenance is being performed. Personnel who may work on or around equipment that
may utilize the lockout/tagout procedure must be considered affected employees, unless they are specifically
prevented from doing so. Affected personnel are not allowed to lockout/tagout equipment or work on machines
or equipment when the guards have been removed.
Contractors performing activities involving locking out or tagging out must have a written lockout/tagout
program that includes provisions to meet OSH 29 CFR 1910.147.
4.14 Electrical Safety
Electricity may pose a particular hazard to Site workers due to the use of portable electrical equipment. If wiring
or other electrical work is needed, a qualified electrician must perform it.
General electrical safety requirements include:
• All electrical wiring and equipment must be of a type listed by Underwriters Laboratory (UL), Factory
Mutual Engineering Corporation (FM), or other recognized testing or listing agency.
• All installations must comply with the National Electrical Safety Code (NESC), the National Electrical
Code (NEC), or USCG regulations.
• Portable and semi-portable tools and equipment must be grounded by a multi-conductor cord having an
identified grounding conductor and a multi-contact polarized plug-in receptacle.
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• Tools protected by an approved system of double insulation, or its equivalent, need not be grounded.
Double-insulated tools must be distinctly marked and listed by UL or FM.
• Live parts of wiring or equipment must be guarded to prevent persons or objects from touching them.
• Electric wire or flexible cord passing through work areas must be covered or elevated to protect it from
damage by foot traffic, vehicles, sharp corners, projections, or pinching.
• All circuits must be protected from overload.
• Temporary power lines, switchboxes, receptacle boxes, metal cabinets, and enclosures around
equipment must be marked to indicate the maximum operating voltage.
• Plugs and receptacles must be kept out of water unless of an approved submersible construction.
• All extension cord outlets must be equipped with ground-fault-circuit interrupters (GFCIs).
• Attachment plugs or other connectors must be equipped with a cord grip and be constructed to endure
rough treatment.
• Extension cords or cables must be inspected prior to each use and replaced if worn or damaged. Cords
and cables must not be fastened with staples, hung from nails, or suspended by bare wire.
• Flexible cords must be used only in continuous lengths without splice, with the exception of molded or
vulcanized splices made by a qualified electrician.
4.15 Lifting Safety
Using proper lifting techniques may prevent back strain or injury. The fundamentals of proper lifting include:
• Consider the size, shape, and weight of the object to be lifted. A mechanical lifting device or additional
persons must be used to lift an object if it cannot be lifted safely alone.
• Hands and the object should be free of dirt or grease that could prevent a firm grip.
• Gloves must be used and the object inspected for metal slivers, jagged edges, burrs, or rough or slippery
surfaces.
• Fingers must be kept away from points that could crush or pinch them, especially when putting an
object down.
• Feet must be placed far enough apart for balance. The footing should be solid and the intended pathway
should be clear.
• The load should be kept as low as possible, close to the body with the knees bent.
• To lift the load, grip firmly and lift with the legs, keeping the back as straight as possible.
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• A worker should not carry a load that he or she cannot see around or over.
• When putting an object down, the stance and position are identical to that for lifting; the legs are bent at
the knees, and the back is straight as the object is lowered.
4.16 Ladder Safety
When portable ladders are used for access to an upper landing surface, the ladder side rails shall extend at least 3
feet above the upper landing surface to which the ladder is used to gain access; or, when such an extension is not
possible because of the ladder’s length, then the ladder shall be secured at its top to a rigid support that will not
deflect, and a grasping device, such as a grabrail, shall be provided to assist employees in mounting and
dismounting the ladder. In no case shall the extension be such that ladder deflection under a load would, by
itself, cause the ladder to slip off its support.
• Ladders shall be maintained free of oil, grease, and other slipping hazards.
• Ladders shall not be loaded beyond the maximum intended load for which they were built, nor beyond
their manufacturer’s rated capacity.
• Ladders shall be used only for the purpose for which they were designed.
• Non-self-supporting ladders shall be used at an angle such that the horizontal distance from the top
support to the foot of the ladder is approximately one-quarter of the working length of the ladder (the
distance along the ladder between the foot and the top support).
• Wood job-made ladders with spliced side rails shall be used at an angle such that the horizontal distance
is one-eighth the working length of the ladder.
• Fixed ladders shall be used at a pitch no greater than 90 degrees from the horizontal, as measured to the
back side of the ladder.
• Ladders shall be used only on stable and level surfaces unless secured to prevent accidental displacement.
• Ladders shall not be used on slippery surfaces unless secured or provided with slip-resistant feet to
prevent accidental displacement. Slip-resistant feet shall not be used as a substitute for care in placing,
lashing, or holding a ladder that is used upon slippery surfaces, including, but not limited to, flat metal or
concrete surfaces that are constructed so they cannot be prevented from becoming slippery.
• Ladders placed in any location where they can be displaced by workplace activities or traffic, such as in
passageways, doorways, or driveways, shall be secured to prevent accidental displacement, or a barricade
shall be used to keep the activities or traffic away from the ladder.
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• The area around the top and bottom of ladders shall be kept clear.
• The top of a non-self-supporting ladder shall be placed with the two rails supported equally unless it is
equipped with a single support attachment.
• Ladders shall not be moved, shifted, or extended while occupied.
• Ladders shall have non-conductive siderails if they are used where the employee or the ladder could
contact exposed energized electrical equipment.
• The top most step of the ladder should not be used as a step, nor should any step above a step on a ladder
that is labeled “not a step”.
• Cross-bracing on the rear section of stepladders shall not be used for climbing unless the ladders are
designed and provided with steps for climbing on both front and rear sections.
• Ladders shall be inspected by the HSO for visible defects on a daily basis and after any occurrence that
could affect their safe use.
• Portable ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or
steps; broken or split rails; corroded components; or other faulty or defective components shall either be
immediately marked in a manner that readily identifies them as defective, or be tagged with “Do Not
Use” or similar language, and shall be withdrawn from service.
• Fixed ladders with structural defects, such as, but not limited to, broken or missing rungs, cleats, or steps;
broken or split rails; or corroded components; shall be withdrawn from service.
• Ladder repairs shall restore the ladder to a condition meeting its original design criteria, before the ladder
is returned to use.
• Single-rail ladders shall not be used.
• When ascending or descending a ladder, the user shall face the ladder.
• Each employee shall use at least one hand to grasp the ladder when progressing up and/or down the
ladder.
• Employees shall not climb any ladder while carrying items with their hands.
4.17 Carbon Monoxide
When working indoors with any type of gasoline, diesel or liquid petroleum gas powered equipment carbon
monoxide (CO) is a significant hazard. Recognize that a single generator, propane heater or propane fork truck
can quickly generate CO above the permissible exposure level regardless of the size of the room. The following
guidelines will be implemented to mitigate any CO issues.
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• Utilize remotely powered equipment whenever possible. Validate that the exhaust from the generating
unit is not being sucked or blown back into the building.
• Use an approved exhaust extension for stationary work. Run the extension to the outside of the
building.
• Do not use unvented gas or kerosene space heaters in enclosed spaces
• Do not sit in running cars for extended periods of time; if it is necessary to be in an idling vehicle, leave
windows partially opened
• When operating any fossil-fueled equipment indoors, ensure that all pre-operation equipment checks are
completed and that the equipment is running to specifications. Smokey exhaust, sputtering, backfires,
etc. all indicate an equipment problem requiring immediate service.
• Provide ventilation within the building regardless of the weather outdoors. Open vents and intakes as
well as entry and overhead doors.
• Utilize large fans to move air into or out of the building. Sometimes better results can be achieved by
blowing air out than bringing it in. For stationary work be sure to move fresh air through the breathing
zone of employees.
• Operate a properly calibrated CO meter (such as the Multi-Rae) within the worker breathing zone
before, during, and after equipment operation. Recognize that a CO alarm requires immediate action.
Stop work, shut down engines, and move to the outdoors until the alarm subsides and it is safe to
reenter. Exposure guidelines for CO are listed in the following table.
Table 4-3
Carbon Monoxide Exposure Guidelines
Parameter
Reading in Work Area/
Worker Breathing Zone
Action
Carbon
Monoxide
0 ppm to 20 ppm
> 20 ppm
Normal operations; continue monitoring
Stop work, evacuate confined space/work area;
investigate cause of reading, and ventilate area
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Symptoms of Carbon Monoxide Exposure
CO is called the silent killer because it has no odor and it slowly overcomes those who are overexposed.
Symptoms include: headache, fatigue, shortness of breath, nausea, and dizziness. Employees in the same room
may or may not have all symptoms simultaneously. As with all work, use the buddy system to keep each other
safe and observe signs and symptoms of overexposure.
Treatment of Carbon Monoxide Exposure
Employees who are or may be experiencing any of the symptoms of CO poisoning, must notify others in the
area and get fresh air immediately. Windows and doors should be opened for more ventilation, any combustion
equipment should be turned off, and the building should be evacuated. Exposed individuals should seek medical
treatment if symptoms persist since overexposure can result in loss of consciousness and death. A doctor should
be contacted immediately for a proper diagnosis and told that CO poisoning is may be the reason. Prompt
medical attention is important if any individuals experience symptoms of CO poisoning while operating fuel-
burning devices.
4.18 Hot Work Safety Program
The purpose of the Hot Work Safety Program is to protect all personnel from hazards associated with activities
producing sparks, flames, or other ignition sources, and to prevent the loss of property due to fire. To effectively
comply with the provisions of the OSHA standards governing fire prevention and hot work activities, the Hot
Work Safety Program establishes procedures to ensure that physical and chemical fire hazards present in the
workplace are isolated from hot work activities. The Hot Work Safety Program is applicable to all welding,
cutting, burning, grinding, and other spark producing work activities. Contractors may utilize their own hot
work safety procedures as long as the requirements of this section are met.
Conditions Prohibiting Hot Work
Hot work activities are prohibited in areas of the project Site as follows:
• In areas where the requirements of the Hot Work Safety Program cannot be met. In these areas, the hot
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work is prohibited and alternative methods shall be employed;
• In areas potentially containing explosive atmospheres due to the presence of flammable gases, vapors,
liquids, or dusts; and
• Within 50 feet of an area where flammable or combustible liquids or gases are used or stored.
Hot work activities shall not be conducted within the areas outlined above. All on-Site personnel are
responsible for preventing hot work activities within prohibited areas. Additionally, no hot work will be
conducted on any surface covered with a protective coating whose flammability is not known. Employees
conducting hot work activities on toxic preservative coatings shall wear appropriate respiratory protection and
the preservative coatings shall be removed a sufficient distance from the area to be heated.
Hot Work Permits
A hot work permit is required for welding, cutting, burning, grinding, or spark producing work conducted
outside of designated hot work areas. This section outlines the preparation, issuance, use, and tracking of hot
work permits. Contractors may utilize their own hot work permits if they meet the requirements of this section.
This procedure has been developed to ensure basic precautions for fire prevention and employee safety are
implemented prior to and during hot work activities outside of designated hot work areas. The hot work permit
contains a checklist to be completed by the authorized personnel conducting the hot work activities. The hot
work permit, Attachment K, must be reviewed by the SSO and the HSC prior to the start of hot work activities.
The checklist is designed to ensure the following measures are addressed.
• If possible, the object or equipment on which the hot work is to be conducted shall be moved to a
designated hot work area.
• If an object or equipment on which hot work is to be conducted cannot be moved, all moveable fire
hazards shall be moved at least 50 feet from the hot work operation.
• If an object or equipment on which hot work is to be conducted cannot be moved, or all fire hazards
cannot be removed, then guards, barriers, or screens shall be used to confine any heat, sparks, and slag,
and to protect the immovable fire hazards.
• All floor, wall, and window openings or cracks within a 35-foot radius shall be protected to prevent
exposure of combustible material to heat, sparks, or slag.
• Suitable fire fighting equipment shall be on-hand for immediate use.
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• If hot work takes place in an area where flying sparks and slag may injure personnel working near,
above, or below the hot work operation, then additional precautions shall be implemented to prevent
injury to the personnel (i.e. screens, barriers, caution tape, PPE, etc.).
• A fire watch will begin before hot work is initiated and will continue during and for a minimum of 30
minutes after the hot work concludes to ensure that there are no smoldering fires. A fire watch is
required whenever hot work is performed outside of designated hot work areas.
• Verify that flammable and combustible materials adjacent to the opposite side of metal partitions, walls,
ceilings, or roofs which are likely to be ignited by conduction or radiation are protected by guards,
barriers, screens, or are moved 50 feet away from the metal partitions, walls, ceilings, or roofs.
• If hot work is to be conducted in a confined space, the requirements for the confined space entry must
be reviewed and followed.
• Hot work will not be performed in areas where other workers may be affected unless adequate
engineering or administrative controls are used to prevent personnel exposure.
• Welding, cutting, and other hot work will not be undertaken unless adequate ventilation, PPE, and well
maintained equipment are used by trained and authorized personnel.
• After welding and cutting has been completed, the area will be thoroughly cleaned, and equipment
returned to its proper location.
• All personnel involved in hot work activities shall use appropriate PPE.
If any of the basic requirements for fire prevention cannot be implemented prior to or during hot work
conducted outside a designated hot work area, then the hot work activities will not be conducted. At the
conclusion of the hot work activities, the hot work permit will be provided to the HSC for recordkeeping.
Fire Watch Procedures
A fire watch is required whenever hot work is performed outside designated hot work areas. Fire watch
personnel shall be provided by the contractor performing the hotwork. Fire watch personnel are required to
meet the following requirements.
• Fire watch personnel must have fire-extinguishing equipment readily available and ready for immediate
use.
• Fire watch personnel must be trained in the use of the fire fighting equipment provided.
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• Fire watch personnel must be familiar with the procedure to sound the fire alarm in the event of a fire
and know the location of the nearest telephone.
• All fire watch personnel shall use appropriate PPE.
• Fire watch personnel must watch for fires, try to extinguish them if safe to do so, or otherwise activate
the fire alarm system.
• If a fire cannot be extinguished with one fire extinguisher, the area shall be evacuated, the fire alarm
system shall be activated, and the appropriate professional fire fighting organization contacted.
• Fire watch personnel must maintain a fire watch for at least 30 minutes after the hot work operations are
completed.
If any of the above requirements cannot be met, hot work shall not be conducted.
4.19 Confined Space Entry
Personnel conducting confined space entry activities or conducting activities near confined spaces which may
create a hazard inside the space must meet the regulatory requirements outlined in 29 CFR 1910.146: Permit-
Required Confined Spaces. Each contractor shall provide qualified/competent and trained personnel as defined
in 29 CFR 1910.146, who are responsible and have authority over confined space entry activities conducted by
the contractor. The following sections include potential hazards and safety procedures associated with confined
space and confined space-related activities. Contractors must implement their written confined space entry
program, meet the minimum requirements outlined herein, and meet the requirements of in 29 CFR 1910.146.
A confined space is defined as a space large enough and so configured that an employee can bodily enter and
perform assigned work, has limited means for entry or exit, and is not designed for continuous employee
occupancy. Potentially contaminated confined spaces may pose additional hazards such as air contamination,
flammable or explosive atmosphere, and oxygen deficiency. Confined space entry may pose the possibility of
engulfment. Personnel must be properly trained in order to supervise and participate in confined space entry
procedures or serve as standby attendants. Requirements and procedures for working in confined spaces are
discussed below.
All confined spaces shall be initially considered permit-required.
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4.19.1 Confined Space Identification and Designation The HSC is responsible for identifying confined spaces into which their personnel or contractors will enter.
Entry is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into
the space. The Confined Space Entry Checklist (Attachment L) and Confined Space Entry Permit (Attachment
M) must be filled out prior to the start of confined space activities.
4.19.2 Duties of Personnel
Each confined space being entered shall have a minimum of one (1) dedicated attendant and one other support
person (who may have other duties) within sight or call.
Duties of Entrants:
• Know the hazards that may be faced during entry, including information on the mode, signs or symptoms,
and consequences of the exposure.
• Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to
enable the attendant to alert entrants of the need to evacuate the space.
• Alert the attendant whenever:
- The entrant recognizes warning signs or symptoms of exposure to a dangerous situation, or
- The entrant detects a prohibited condition;
• Exit from the permit-required confined space (permit space) as quickly as possible whenever:
- An order to evacuate is given by the attendant or the entry supervisor,
- The entrant recognizes warning signs or symptoms of exposure to a dangerous situation,
- The entrant detects a prohibited condition, or
- An evacuation alarm is activated.
Duties of Attendants:
• Knows the hazards that may be faced during entry, including information on the mode, signs or
symptoms, and consequences of the exposure.
• Is aware of possible behavioral effects of hazard exposure in authorized entrants.
• Continuously maintains an accurate count of authorized entrants in the permit space and accurately
identifies who is in the permit space by tagging the lifelines with the entrant's name, and recording the
names of the entrants.
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• Remains outside the permit space during entry operations until relieved by another attendant.
• Communicates with authorized entrants as necessary to monitor entrant status and to alert entrants of the
need to evacuate the space.
• Monitors activities inside and outside the space to determine if it is safe for entrants to remain in the space
and orders the authorized entrants to evacuate the permit space immediately under any of the following
conditions:
- If the attendant detects a prohibited condition;
- If the attendant detects the behavioral effects of hazard exposure in an authorized entrant;
- If the attendant detects a situation outside the space that could endanger the authorized entrants, or
- If the attendant cannot effectively and safely perform all his duties.
• Summon rescue and other emergency services as soon as the attendant determines that authorized entrants
may need assistance to escape from permit space hazards.
• Takes the following actions when unauthorized persons approach or enter a permit space while entry is
underway:
- Warn the unauthorized persons that they must stay away from the permit space;
- Advise the unauthorized persons that they must exit immediately if they have entered the permit
space; and
- Inform the authorized entrants and the entry supervisor if unauthorized persons have entered the
permit space.
• Performs non-entry rescues.
• Performs no duties that might interfere with the attendant's primary duty to monitor and protect the
authorized entrants.
Duties of Entry Supervisors:
• Knows the hazards that may be faced during entry, including information on the mode, signs or
symptoms, and consequences of the exposure.
• Verifies, by checking that the appropriate entries have been made on the permit, that all tests specified by
the permit have been conducted and that all procedures and equipment specified by the permit are in place
before endorsing the permit and allowing entry to begin.
• Terminates the entry and cancels the permit as required.
• Removes unauthorized individuals who enter or who attempt to enter the permit space during entry
operations.
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• Determines that entry operations remain consistent with terms of the entry permit and that acceptable
entry conditions are maintained.
• Documents on the entry permit incidents or circumstances requiring review of the confined space entry
program. Such incidents include:
- Unauthorized entry;
- The detection of a condition/hazard not authorized by the permit;
- The occurrence of an injury or near-miss during entry;
- A change in use or configuration of the space; or
- Employee complaints about the program.
• Prescribes procedures for coordination of entry when personnel from multiple employers will work
simultaneously. Contractors shall follow all confined space entry procedures.
4.19.3 Procedures for Permit Space Entry
Procedures for inspecting, monitoring and testing the confined space to verify that acceptable conditions exist
prior to and throughout the entry operation are described in this section.
The acceptable entry conditions for entry into each space are outlined in Table 6-1. The confined space must be
isolated to prevent the introduction of contaminants during entry. Isolation must include disconnecting or
installing slip blanks into lines leading to the space. To prevent injury from physical hazards within the space,
lockout, tagout, tryout and return to service procedures must be implemented for potential sources of hazardous
energy. When isolation is not practical or possible (as in sewer entry) entry conditions must be continuously
monitored.
Atmospheric hazards must be eliminated or controlled to meet the requirements specified in the table below. If
necessary, the space shall be purged or inerted, then ventilated to the extent necessary to meet the criteria in the
table below. Ventilation equipment may be needed to maintain these conditions. In addition, a Multi RAE
instrument (or equivalent) with PID, Oxygen, LEL, CO, and Hydrogen sulfide sensors shall be available for
testing each confined space. All equipment shall be maintained in such quantity and condition, per
manufacturer recommendations, to adequately monitor and assess all confined space entries. Permit
requirements for confined spaces shall be tested continuously to detect changes in atmospheric conditions.
Priority for atmospheric hazard testing shall be oxygen, combustible gases, and then toxic gases.
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Provisions for continuous communication between entrants and attendants shall consist of powered
communication equipment (i.e., radio). Powered communication equipment with the appropriate National
Electric Code (NEC) rating shall be provided. If this is not practical or possible, portable air horns must be
provided to all entrants and attendants. The code for air horn blasts is as follows:
• 1 Horn Blast = Are you OK?
• 2 Horn Blasts = Yes, I am OK.
• 3 Horn Blasts = Exit the confined space immediately.
In addition to the PPE required for the task as specified in Table 5-1, PPE worn during confined space entry
should include protective suits, boots, and gloves, face, head, and foot protection; and a chest or parachute
harness with approved lifelines at least ½ inch in diameter and 2,000 pounds test. (NOTE: Wristlets may be used
only when a harness presents a greater hazard to the employee and wristlets are the safest, most effective
alternative). All lifelines shall be secured to a mechanical device or fixed point outside the confined space.
Mechanical devices shall be used for all vertical entry permit spaces greater than five feet deep.
In addition, lighting and electrical shall be of the appropriate NEC rating. Rating should be Class I, Division I
unless the space specifically meets other rating requirements. Protective barriers are to be used to protect
entrants from external pedestrian, vehicle or equipment hazards. Ladders shall meet the requirements of 29 CFR
1926 Subpart X, Ladders. Lifelines must be attached to a mechanical device outside the space such that a rescue
can begin as soon as the rescuer becomes aware that a rescue is necessary.
Before entry is authorized, the contractor’s Entry Supervisor shall complete and sign the contractor’s entry
permit according to their written confined space program and document that all pre-entry requirements have
been met and that acceptable entry conditions exist. The complete permit shall be posted at the primary
entrance to the permit space. See Attachment M for an example of a confined space entry permit.
Entry permits are valid for a maximum of one work shift, and shall be canceled by the Entry Supervisor when
the shift ends, confined space operations are complete, or whenever a prohibited condition arises in or near the
space. All confined spaces shall be securely closed or barricaded whenever the entry permit is canceled. Each
contractor’s entry permit must be completely executed and include all required information.
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The SS0/HSS or client shall arrange for outside rescue services. The rescue personnel must be offered an
opportunity to inspect the space, and practice a rescue if necessary. The means for summoning rescue services
must be clearly communicated and documented on the contractor’s entry permit.
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5. Personal Protective Equipment
5.1 Levels of Protection
PPE is required to safeguard Site personnel from various hazards. Varying levels of protection may be required
depending on the levels of COCs and the degree of physical hazard. This section presents the various levels of
protection and defines the conditions of use for each level.
5.1.1 Level D Protection
The minimum level of protection that is required of Site personnel and subcontractors is Level D, which is worn
when Site conditions present minimal dermal exposure hazard and no inhalation hazard. Level D protection
includes the following equipment:
• work clothing as prescribed by weather;
• steel-toe work boots, meeting American National Standards Institute (ANSI) Z41;
• safety glasses with side shields or goggles, meeting ANSI Z87;
• hard hat, meeting ANSI Z89, when falling object hazards are present;
• hearing protection (if noise levels exceed 85 dBA, then hearing protection with a USEPA NRR of at
least 20 dBA must be used); and
• PFD if working near or on water where the potential for drowning exists.
5.1.2 Modified Level D Protection
Modified Level D will be used when airborne contaminants are not present at levels of concern, but Site
activities present an increased potential for dermal contact with contaminated materials. Modified Level D
consists of:
• nitrile gloves worn over nitrile surgical gloves;
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• latex/polyvinyl chloride (PVC) overboots when contact with COC-impacted media is anticipated;
• steel-toe work boots, meeting ANSI Z41;
• safety glasses or goggles, meeting ANSI Z87;
• face shield in addition to safety glasses or goggles when projectiles or splash hazards exist;
• hard hat, meeting ANSI Z89 when falling object hazards are present;
• hearing protection (if noise levels exceed 85 dBA, then hearing protection with a USEPA NRR of at
least 20 dBA must be used);
• Tyvek® suit (polyethylene coated Tyvek® suits for handling liquids) when body contact with COC-
impacted media is anticipated; and
• PFD if working near or on water the potential for drowning exists
5.1.3 Level C Protection
Level C protection will be required when the airborne concentration of COCs reaches one-half of the OSHA
Permissible Exposure Limit (PEL) or American Conference of Governmental Industrial Hygienists (ACGIH)
Threshold Limit Value (TLV) (ACGIH, 2003a and 2003b). The following equipment will be used for Level C
protection:
• full-face, National Institute for Occupational Safety and Health (NIOSH)-approved air-purifying
respirator with a combination cartridge (GME P-100, or equivalent);
• Tyvek® suit with ankles and cuffs taped to boots and gloves;
• nitrile outer gloves worn over nitrile surgical gloves;
• steel-toe work boots, meeting ANSI Z41;
• chemical-resistant boots with steel toes or latex/PVC overboots over steel-toe boots;
• hard hat, meeting ANSI Z89;
• hearing protection (if noise levels exceed 85 dBA, then hearing protection with a USEPA NRR of at
least 20 dBA must be used); and
• PFD if working near or on water where the potential for drowning exists.
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5.2 PPE Selection
PPE will be selected based on the potential for contact, Site conditions, ambient air quality, and the judgment of
supervising Site personnel and health and safety professionals. The PPE used will be chosen to be effective
against the COCs present on Site.
Specifically, the level of PPE selected will be based on air monitoring of the work environment and an
assessment by the SSO and HSC of the potential for skin contact with COCs. The PPE selection matrix is
presented in Table 5-1. This matrix is based on information available at the time this plan was written.
Table 5-1
PPE Selection Matrix
Task Anticipated Level of Protection
Mobilization/Site Survey Level D
Water, Soil, and Air Sampling Level D/Modified Level D/Level C
Drilling and Monitoring Well Installation Level D/Modified Level D/Level C
Residential Sampling and Excavation Level D/Modified Level D/Level C
Sediment Sampling Level D with PFD/Modified Level D with PFD/Level C
with PFD
Biota Sampling Level D with PFD/Modified Level D with PFD/Level C
with PFD
Personnel and Equipment Decontamination Level D/Modified Level D/Level C
Demobilization Level D
5.3 Site Respiratory Protection Program
Respiratory protection is an integral part of employee health and safety at the Site due to potentially hazardous
concentrations of airborne COCs. The Site respiratory protection program will consist of the following elements
(at a minimum):
• All on-Site personnel who may use respiratory protection will have an assigned respirator.
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• All on-Site personnel who may use respiratory protection will have been fit-tested and trained in the use
of a full-face air-purifying respirator within the past 12 months.
• All on-Site personnel who may use respiratory protection must, within the past year, have been
medically certified as being capable of wearing a respirator. Documentation of the medical certification
must be provided to the HSC prior to commencing Site work.
• Only cleaned, maintained, NIOSH-approved respirators will be used.
• If respirators are used, the respirator cartridge is to be properly disposed of at the end of each work shift
or when load-up or breakthrough occurs.
• Contact lenses are not to be worn when a respirator is worn.
• All on-Site personnel who may use respiratory protection must be clean-shaven. Mustaches and
sideburns are permitted, but they must not touch the sealing surface of the respirator.
• Respirators will be inspected and a negative-pressure test performed prior to each use.
• After each use, the respirator will be wiped with a disinfectant, cleansing wipe. When used, the
respirator will be thoroughly cleaned at the end of the work shift. The respirator will be stored in a clean
plastic bag, away from direct sunlight in a clean, dry location in a manner that will not distort the face
piece.
5.4 Using PPE
Depending on the level of protection selected, specific donning and doffing procedures may be required. The
procedures presented in this section are mandatory if Modified Level D or Level C PPE is used. All personnel
entering the EZ must don the required PPE in accordance with the requirements of this Site-Wide HASP. When
leaving the EZ, personnel will remove the PPE in accordance with the doffing procedures to minimize the
spread of COCs.
5.4.1 Donning Procedures
These procedures are mandatory only if Modified Level D or Level C PPE is used on Site:
• Remove bulky outerwear. Remove street clothes and store in clean location.
• Put on work clothes or coveralls.
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• Put on the required chemical-protective coveralls.
• Put on the required chemical-protective boots or boot covers.
• Tape the legs of the coveralls to the boots with duct tape.
• Put on the required chemical-protective gloves.
• Tape the wrists of the protective coveralls to the gloves.
• Don the required respirator and perform appropriate fit check (Level C).
• Put hood or head covering over head and respirator straps and tape hood to face piece (Level C).
• Don remaining PPE, such as safety glasses or goggles and hard hat.
When these procedures are instituted, one person must remain outside the work area to confirm that each person
entering has the proper protective equipment.
5.4.2 Doffing Procedures
The following procedures are only mandatory if Modified Level D or Level C PPE is required for the Site.
Whenever a person leaves the work area, the following decontamination sequence will be followed:
• Upon entering the CRZ, rinse contaminated materials from the boots or remove contaminated boot
covers.
• Clean reusable protective equipment.
• Remove outer gloves, tyvek coverall, and respirator (Level C). Remove inner gloves after all potential
of handling of contaminated articles is completed. All disposable PPE should be placed in plastic bags
that are labeled with contaminated-waste labels.
• Wash hands, face, and neck (or shower if necessary).
• Proceed to clean area and dress in clean clothing.
• Clean and disinfect respirator (Level C) for next use.
All disposable equipment, garments, and PPE must be bagged in plastic bags labeled for disposal. See Section
7.2 for detailed information on decontamination stations.
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6. Air and Noise Monitoring
6.1 Air Monitoring
Air monitoring for volatile organic compounds (VOCs) using a PID is recommended in OU-3 during tasks 2 and
3 (unless pervious knowledge of a particular well indicates that it is free of VOCs). Air monitoring for
particulates using a MIE data ram particulate monitor or the equivalent will occur during excavation if dusty
conditions arise. If entering a confined space, a multi RAE instrument (or equivalent) with PID, oxygen, LEL,
CO and hydrogen sulfide sensors will be used. Once initiated, monitoring will occur at least hourly and more
frequently if action levels are exceeded. The HSC will be responsible for monitoring, visually assessing for dust
and will initiate particulate monitoring and/or upgrade PPE requirements according to Table 6-1.
Monitoring data, should it be required, will be recorded on the Air Monitoring Form (Attachment H).
6.2 Noise Monitoring
Noise monitoring may be conducted using a rated sound level meter as required. Hearing protection is
mandatory for all employees in noise hazardous areas, such as around heavy equipment. As a general rule,
sound levels that cause speech interference at normal conversation distance should require the use of hearing
protection.
6.3 Monitoring Equipment Maintenance and Calibration
All direct-reading instrumentation calibrations should be conducted under the approximate environmental
conditions under which the instrument will be used. Instruments must be calibrated before and after use, and the
readings and any necessary adjustments noted. All air monitoring equipment calibrations, including the
standard used for calibration, must be documented on a calibration log or in the field notebook. All completed
documentation/forms must be reviewed by the HSC and maintained by the SSO.
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All air-monitoring equipment will be maintained and calibrated in accordance with the specific manufacturer’s
procedures. Preventive maintenance and repairs will be conducted in accordance with the respective
manufacturer’s procedures. When applicable, only manufacturer-trained and/or authorized personnel will be
allowed to perform instrument repairs or preventive maintenance.
If an instrument is found to be inoperative or suspected of giving erroneous readings, the HSC must be
responsible for immediately removing the instrument from service and obtaining a replacement unit. If the
instrument is essential for safe operation during a specific activity, that activity must cease until an appropriate
replacement unit is obtained. The HSC will be responsible for confirming that a replacement unit is obtained
and/or repairs are initiated on the defective equipment.
6.4 Action Levels
Table 6-1 presents action levels for air that will be used to determine the procedures and protective equipment
necessary based on conditions as measured at the Site.
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Table 6-1
Action Levels for Air
Parameter Reading Action
Airborne Particulates 0 to < 1.5 mg/m3
> 1.5 mg/m3 to 2.5
mg/m3
> 2.5 mg/m3
Normal operations; continue hourly breathing zone monitoring
Initiate dust suppression measures; if suppression measures are
insufficient to reduce particulates below 2.5 mg/m3 upgrade to
Level C and increase monitoring frequency to every 15 minutes
Stop work notify the HSO (or whatever term they are using)
Volatile Organics 0 ppm to 5 ppm
5 ppm to 20 ppm
> 20 ppm
Normal operations with hourly monitoring
Investigate cause of readings to determine source; increase
monitoring frequency to every 15 minutes
Stop work and contact HSO
Hydrogen Sulfide 0 ppm to < 5 ppm
> 5 ppm
Normal operations
Stop work, evacuate confined spaces/work area, investigate cause
of reading, and ventilate area
Oxygen < 19.5%
> 19.5% to < 23.5%
> 23.5%
Stop work, evacuate confined spaces/work area, investigate cause
of reading, and ventilate area
Normal operations
Stop work, evacuate confined spaces/work area, investigate cause
of reading, and ventilate area
Flammable Vapors
(LEL)
< 10% LEL
> 10% LEL
Normal operations
Stop work, ventilate area, investigate source of vapors
Carbon Monoxide 0 ppm to < 20 ppm
> 20 ppm
Normal operations
Stop work, evacuate confined spaces/work area, investigate cause
of reading, and ventilate area
Note: Mg/m³= milligrams per cubic meter Ppm= parts per million
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7. Work Zones and Decontamination
7.1 Work Zones
7.1.1 Authorization to Enter
Only personnel with the appropriate training and medical certifications will be allowed to work at the project
Site. The SSO will maintain a list of authorized persons; only personnel on the authorized-persons list will be
allowed to enter the Site work areas.
7.1.2 Site Orientation and Hazard Briefing
No person will be allowed in the work area during Site operations without first being given a Site orientation
and hazard briefing. This orientation will be presented by the SSO or HSC and will consist of a review of this
Site-Wide HASP. This review must cover the chemical, physical, and biological hazards; protective equipment;
safe work procedures; and emergency procedures for the project. Following this initial meeting, safety meetings
will be held each day before work begins.
All people entering the Site work areas, including visitors, must document their attendance at the orientation and
hazard briefing, as well as at the daily safety meetings, on the forms included with this plan.
7.1.3 Certification Documents
A training and medical file may be established for the project and kept on Site during all Site operations.
Records of completion of specialty training, such as first aid/cardiopulmonary resuscitation (CPR), as well as
current medical clearances, will be maintained in that file. All of the Parties’ employees and
contractor/subcontractor personnel must provide their training and medical documentation to the HSC prior to
starting work.
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7.1.4 Entry Log
A log-in/log-out sheet will be maintained on Site by the SSO. Personnel must sign in and out on a log sheet as
they enter and leave the work area, and the SSO may document entry and exit in the field notebook.
7.1.5 Entry Requirements
In addition to the authorization, hazard briefing, and certification requirements listed above, no person will be
allowed in any Site work area unless they are wearing the minimum PPE as described in Section 5.
7.1.6 Emergency Entry and Exit
People who must enter the work area on an emergency basis will be briefed of the hazards by the SSO. All
activities will cease in the event of an emergency. People exiting the work area because of an emergency will
gather in a safe area for a head count. The SSO is responsible for confirming that all people who entered the
work area have exited in the event of an emergency.
7.1.7 Contamination-Control Zones
Contamination-control zones are maintained to prevent the spread of contamination and to prevent unauthorized
people from entering hazardous areas.
7.1.8 Exclusion Zone
The EZ is the defined area where there is a possible respiratory and/or contact health hazard. An EZ may consist
of a specific work area or may be the entire area of potential contamination. All employees entering an EZ must
use the required PPE and must have the appropriate training and medical clearance for hazardous waste work.
Cones, caution tape, or a Site diagram will identify the location of each EZ.
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7.1.9 Contamination-Reduction Zone
The CRZ or transition area will be established, if necessary, to perform decontamination of personnel and
equipment. All personnel entering or leaving the EZ will pass through this area to prevent any cross-
contamination. Tools, equipment, and machinery will be decontaminated in a specific location. All personnel
will be decontaminated on Site adjacent to the EZ. Personal protective outer garments and respiratory
protection will be removed in the CRZ and prepared for cleaning or disposal. This zone is the only appropriate
corridor between the EZ and the SZ.
7.1.10 Support Zone
The SZ is a clean area outside the CRZ located to prevent employee exposure to hazardous substances. Eating
and drinking will be permitted in the support area only after proper decontamination. Smoking may be permitted
in the SZ, subject to Site requirements.
7.1.11 Posting
Work areas will be prominently marked and delineated using cones, caution tape, or a Site diagram.
7.1.12 Site Inspections
The SSO will conduct a daily inspection of Site activities, equipment, and procedures to verify that the required
elements are in place. The Health and Safety Inspection Form in Attachment I may be used as a guide for daily
inspections. A SWO must also be completed (at a frequency determined by HSC) and forwarded to the OU
RI/FS Manager for review.
7.2 Decontamination
Decontamination procedures are briefly described below, and presented in more detail under Task 7 in Section
3.2.7.
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7.2.1 Personnel Decontamination
All personnel wearing Modified Level D or Level C protective equipment in the EZ must undergo personal
decontamination prior to entering the SZ. The personnel decontamination area will consist of the following
stations, at a minimum:
• Station 1 – Personnel leaving the contaminated zone will remove the gross contamination from their
outer clothing and boots.
• Station 2 – Personnel will remove their outer garments and gloves and dispose of them in properly
labeled containers. Personnel will then decontaminate their hard hats and boots with an aqueous solution
of detergent or other appropriate cleaning solution. These items will then be hand-carried to the next
station.
• Station 3 – Personnel will thoroughly wash their hands and face before leaving the CRZ. Respirators
will be sanitized and then placed in a clean plastic bag.
7.2.2 Equipment Decontamination
All vehicles that have entered the EZ will be decontaminated at the decontamination pad prior to leaving the
zone. If the level of vehicle contamination is low, decontamination may be limited to rinsing tires and wheel
wells with water. If the vehicle is significantly contaminated, steam cleaning or pressure washing of the vehicle
and equipment may be required.
7.2.3 Personal Protective Equipment Decontamination
Where and whenever possible, single-use, external protective clothing must be used for work within the EZ or
CRZ. This protective clothing must be disposed of in properly labeled containers. Reusable protective clothing
will be rinsed on Site with detergent and water. The rinsate will be collected for disposal.
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When removed from the CRZ, the respirator will be thoroughly cleaned with soap and water. The respirator face
piece, straps, valves, and covers must be thoroughly cleaned at the end of each work shift and ready for use prior
to the next shift. Respirator parts may be disinfected with a solution of bleach and water or by using a spray
disinfectant.
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8. Training and Medical Surveillance
8.1 Training
8.1.1 General
All on-Site project personnel who work in areas where they may be exposed to Site COCs must be trained as
required by OSHA Regulation 29 CFR 1910.120 (HAZWOPER). Field employees also must receive a minimum
of three days of actual field experience under the direct supervision of a trained, experienced supervisor.
Personnel who completed their initial training more than 12 months prior to the start of the project must have
completed an eight-hour refresher course within the past 12 months. The SSO must have completed an
additional eight hours of supervisory training and must have current first-aid and CPR certificates.
8.1.2 Basic 40-Hour Course
The following is a list of the topics typically covered in a 40-hour HAZWOPER training course:
• general safety procedures;
• physical hazards (fall protection, noise, heat stress, cold stress);
• names and job descriptions of key personnel responsible for Site health and safety;
• safety, health, and other hazards typically present at hazardous waste sites;
• use, application, and limitations of PPE;
• work practices by which employees can minimize risks from hazards;
• safe use of engineering controls and equipment on Site;
• medical surveillance requirements;
• recognition of symptoms and signs that might indicate overexposure to hazards;
• worker right-to-know (Hazard Communication OSHA 1910.1200);
• routes of exposure to contaminants;
• engineering controls and safe work practices;
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• components of a health and safety program and a Site-specific HASP;
• decontamination practices for personnel and equipment;
• confined-space entry procedures; and
• general emergency response procedures.
8.1.3 Supervisor Course
Managers and supervisors must receive an additional 8 hours of training, which typically includes:
• general Site safety and health procedures;
• PPE programs; and
• air monitoring techniques.
8.1.4 Site-Specific Training
Site-specific training will be accomplished by having on-Site personnel read this Site-Wide HASP or attend a
thorough Site briefing by the OU RI/FS Manager, SSO, or HSC on the contents of this Site-Wide HASP before
work begins. The review must include a discussion of the chemical, physical, and biological hazards; protective
equipment and safety procedures; and emergency procedures.
8.1.5 Daily Safety Meetings
Daily safety meetings will be held to cover the work to be accomplished, hazards anticipated, PPE and
procedures required to minimize Site hazards, and emergency procedures. The SSO or HSC should present these
meetings prior to beginning the day’s fieldwork. No work will be performed in an EZ before the daily safety
meeting has been held. The daily safety meeting must also be held prior to new tasks and repeated if new
hazards are encountered. The Safety Meeting Log is included in Attachment J.
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8.1.6 First Aid and CPR
At least one employee current in first aid and CPR will be assigned to the work crew and will be on Site during
operations. Refresher training in first aid (triennially) and CPR (annually) is required to keep the certificate
current. These individuals must also receive training regarding the precautions and protective equipment
necessary to protect against exposure to bloodborne pathogens.
8.2 Medical Surveillance
8.2.1 Medical Examination
All personnel who are potentially exposed to Site COCs must participate in a medical surveillance program as
defined by OSHA at 29 CFR 1910.120(f).
8.2.2 Pre-Placement Medical Examination
All potentially-exposed personnel must have completed a comprehensive medical examination prior to
assignment and periodically thereafter as defined by applicable regulations. The pre-placement and periodic
medical examinations typically include the following elements:
• medical and occupational history questionnaire;
• physical examination;
• complete blood count, with differential;
• liver enzyme profile;
• chest X-ray, at a frequency determined by the physician;
• pulmonary function test;
• audiogram;
• electrocardiogram for persons older than 45 years of age or if indicated during the physical examination;
• drug and alcohol screening, as required by job assignment;
• visual acuity; and
• follow-up examinations, at the discretion of the examining physician or the corporate medical director.
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The examining physician will provide the employee with a letter summarizing his/her findings and
recommendations, confirming the worker’s fitness for work and ability to wear a respirator. Documentation of
medical clearance will be available for each employee during all project Site work.
Subcontractors will certify that all their employees have successfully completed a physical examination by a
qualified physician. The physical examinations must meet the requirements of 29 CFR 1910.120 and 29 CFR
1910.134. Subcontractors will supply copies of the medical examination certificate for each on-Site employee.
8.2.3 Other Medical Examinations
In addition to pre-employment, periodic, and exit physicals, personnel may be examined:
• at employee request after known or suspected exposure to toxic or hazardous materials; and
• at the discretion of the HSC, HSO, or occupational physician in anticipation of, or after known or
suspected, exposure to toxic or hazardous materials.
8.2.4 Periodic Exam
Following the pre-placement examination, all employees must undergo a periodic examination, similar in scope
to the pre-placement examination. For employees potentially exposed more than 30 days per year above the
applicable PELs, the frequency of periodic examinations will be annual. For employees potentially exposed less
than 30 days per year above the applicable PELs, the frequency for periodic examinations will be 24 months.
8.2.5 Medical Restriction
When the examining physician identifies a need to restrict work activity, the employee’s supervisor must
communicate the restriction to the employee and the HSC. The terms of the restriction will be discussed with the
employee and the supervisor.
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9. Emergency Procedures
9.1 General
Prior to the start of operations, the work area will be evaluated for the potential for fire, contaminant release, or
other catastrophic event. Unusual conditions or events, activities, chemicals, and conditions will be reported to
the SSO/HSC immediately.
The SSO/HSC will establish evacuation routes and assembly areas for the Site. All personnel entering the Site
will be informed of these routes and assembly areas.
9.2 Emergency Response
If an incident occurs, the SSO or HSC should take the following steps:
• Evaluate the incident and assess the need for assistance and/or evacuation.
• Call for outside assistance as needed.
• Confirm that the OU RI/FS Manager is notified promptly of the incident.
• Take appropriate measures to stabilize the incident scene.
9.2.1 Fire
In the case of a fire on Site, the SSO/HSC will assess the situation and direct fire-fighting activities. The
SSO/HSC will confirm that the OU RI/FS Manager is immediately notified of any fires. Site personnel will
attempt to extinguish the fire with available extinguishers, if safe to do so. In the event of a fire that Site
personnel are unable to safely extinguish with one fire extinguisher, the local fire department will be summoned.
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9.2.2 Contaminant Release
In the event of a contaminant release, the following steps will be taken:
• notify SSO/HSC immediately;
• evacuate immediate area of release;
• conduct air monitoring, using equipment and action levels discussed in Section 6, to determine needed
level of PPE; and
• don required level of PPE and prepare to implement control procedures.
The SSO/HSC has the authority to commit resources as needed to contain and control released material and to
prevent its spread to off-Site areas.
9.3 Medical Emergency
All employee injuries must be promptly reported to the HSC/SSO, who will:
• confirm that the injured employee receives prompt first aid and medical attention;
• in emergency situations, see that the worker is transported by appropriate means to the nearest urgent
care facility (normally a hospital emergency room); and
• notify the OU RI/FS Manager, and appropriate contacts as soon as possible after the injured employee is
safely evacuated.
9.3.1 Emergency Care Steps
Upon entering an accident area, Site personnel must follow the emergency care steps listed below. The steps are
to be performed by trained first aid/CPR providers.
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• Survey the scene. Determine whether it is safe to proceed. Try to determine whether the conditions that
caused the incident are still a threat. Protect yourself from exposure before attempting to rescue the
victim.
• Do a primary survey of the victim. Check for airway obstruction, breathing, and pulse. Assess likely
routes of chemical exposure by examining the eyes, mouth, nose, and skin of the victim for symptoms.
• Phone Emergency Medical Services (EMS). Give the location, telephone number used, caller’s name,
what happened, number of victims, victim’s or victims’ condition, and help being given.
• Maintain airway and perform rescue breathing as necessary.
• Perform CPR as necessary.
• Do a secondary survey of the victim. Check vital signs and do a head-to-toe exam.
• Treat other conditions as necessary. If the victim can be moved, take him/her to a location away from
the work area where EMS can gain access.
9.4 First Aid – General
All persons must report any injury or illness to their immediate supervisor or the SSO. Trained personnel will
provide first aid. Injuries and illnesses requiring medical treatment must be documented. The SSO and HSC
must conduct an incident investigation as soon as emergency conditions no longer exist and first aid and/or
medical treatment has been confirmed. Incident investigation reports must be completed and submitted to the
OU RI/FS Manager within 24 hours after the incident.
If first aid treatment is required, first aid kits are kept at the CRZ. If treatment beyond first aid is required, the
injured person(s) should be transported to the medical facility. If the injured person is not ambulatory, or shows
any sign of not being in a comfortable and stable condition for transport, then an ambulance and/or paramedics
should be summoned. If there is any doubt as to the injured worker’s condition, it is best to let the local
paramedic or ambulance service examine and transport the worker.
9.4.1 First Aid – Inhalation
Any employee complaining of symptoms of chemical overexposure as described in Section 4.5 will be removed
from the work area and transported to the designated medical facility for examination and treatment.
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9.4.2 First Aid – Ingestion
Call EMS and consult a poison control center for advice. If available, refer to the MSDS for treatment
information. If the victim is unconscious, keep him/her on his/her side and clear the airway if vomiting occurs.
9.4.3 First Aid – Skin Contact
Project personnel who have had skin contact with contaminants will, unless the contact is severe, proceed
through the CRZ to the wash area. Personnel will remove any contaminated clothing and then flush the affected
area with water for at least 15 minutes. The worker should be transported to the medical facility if he/she shows
any sign of skin reddening, irritation, or if he/she requests a medical examination.
9.4.4 First Aid — Eye Contact
Project personnel who have had contaminants splashed in their eyes or who have experienced eye irritation
while in the EZ must immediately proceed to the eyewash station in the CRZ. Do not decontaminate prior to
using the eyewash. Remove whatever protective clothing is necessary to use the eyewash. Flush the eye with
clean running water for at least 15 minutes. Arrange prompt transport to the designated medical facility.
9.5 Reporting Injuries, Illnesses, and Near-Miss Incidents
Injuries and illnesses, however minor, will be reported to the SSO immediately. The SSO will complete an
injury report (see Attachment F – Incident/Near-Miss Investigation Report) and submit it to the HSO and the
OU RI/FS Manager within 24 hours. Near-miss incidents are situations in which no injury or property damage
occurred, but under slightly different circumstances an injury or property damage could have occurred. Near
misses are caused by the same factors as injuries; therefore, they must be reported and investigated in the same
manner.
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9.6 Emergency Information
The means to summon local public response agencies such as police, fire, and ambulance will be reviewed in the
daily safety meeting. These agencies are identified in Table 9-1.
Table 9-1
Emergency Contacts
EMERGENCY/CONTINGENCY CONTACT TELEPHONE LIST
LOCAL EMERGENCY CONTACTS
PHONE
NUMBER
FIRE DEPARTMENT 911
POLICE 911
AMBULANCE 911
The Parties (Craig Branchfield) (256) 231-8404
HOSPITAL : Regional Medical Center
400 East 10th Street
Anniston, AL 36207
(256) 235-5121
Poison Control Center (800) 222-1222
National Response Center (800) 424-8802
USEPA (Pam Scully) (404) 562-4300
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9.6.1 Directions to Regional Medical Center
From the West: Take Highway 202 East. Pass through the intersection with Quintard Avenue, Highway 202
becomes 9th Street. The Regional Medical Center is 1.5 blocks ahead on the left.
From the South: Take Quintard Avenue North to 9th Street. Turn right on 9th Street. The Regional Medical
Center is 1.5 blocks ahead on the left.
9.6.2 Map to Regional Medical Center
A map showing the location of the regional medical center with respect to the OUs is included as Figure 9-1.
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10. References
American Conference of Governmental Industrial Hygienists (ACGIH). 2003a. Threshold Limit Values
Handbook.
ACGIH. 2003b. Guide to Occupational Exposure Values.
Blasland, Bouck & Lee, Inc. (BBL). 2000. Off-Site RCRA Facility Investigation (RFI) Report, June 2000.
BBL. 2003. Phase I Conceptual Site Model Report for the Anniston PCB Site, April 2003.
BBL. 2004. Remedial Investigation/Feasibility Study Work Plan for the Anniston PCB Site, April 2004.
Contaminant Control, Inc. 2003. Residential Soil Removal Project, Health and Safety Plan. September 2003.
Golder Associates Inc. (Golder). 2002. RFI/CS Report for the Anniston, Alabama Facility, October 2002.
Golder. 2004. Operable Unit 3 Field Sampling Plan Anniston PCB Site, April 2004.
Roux. 2001. Removal Response Action Work Plan, 11th Street Ditch, Anniston PCB Site, Anniston, Alabama, July 9, 2001.
Solutia Inc. (Solutia). 2003. NTC Removal Action Supplemental Sampling Health & Safety Plan. Anniston PCB Site. September 2003.
Solutia. 2004. Non-Time Critical Removal Supplemental Sampling and Analysis Plan, Revision 1. March 2004.
United States Environmental Protection Agency (USEPA). 2001. Administrative Order on Consent (AOC). Docket No. CER-04-2002-3752. October 3, 2001.
Figures
LOCATION MAP
5/06/04 SYR-D54-LAS, DJH10293004/10293G19.CDR
FIGURE
1-1
Atlanta, GA
Birmingham, AL
Anniston, AL
ANNISTON PCB SITEANNISTON, ALABAMA
SITE-WIDE HEALTH AND SAFETY PLAN
APPROXIMATE SCALE
LEGEND
APPROXIMATE CHOCCOLOCCO CREEK WATERSHED BOUNDARY AS DELINEATED IN BASINS 2.0 (USEPA,1999)
AOC B AREA
PROJECT ORGANIZATIONCHART
05/27/04 SYR-D90-MFEU:/Solutia/HASP/Fig 2-1.CDR
FIGURE
2-1
ANNISTON PCB SITEANNISTON, ALABAMA
SITE-WIDE HEALTH AND SAFETY PLAN
Alan Fowler
OU-2/OU-4 QA Officer
OU-2/OU-4 Health and Safety OfficerOU-1/OU-3 Health and Safety Officer
Dennis Capria
Greg Ertel, CIH, CSPCharles Haury, CIH, CSP
Project Staff and Subcontractors
Anniston PCB Site Manager
Craig Branchfield
CERCLA Manager
John Loper
Lori Anne Hendel
OU-1/OU-3 QA Officer
Gayle Macolly
OU-1/OU-3 RI/FS Manager OU-2/OU-4 RI/FS Manager
FIGURE
ANNISTON PCB SITEANNISTON, ALABAMA
SITE-WIDE HEALTH AND SAFETY PLAN
9-1
REGIONAL MEDICAL CENTER
05/27/04 SYR-D90-MFEU:/SOLUTIA/HASP/Fig9-1.cdr
OXFORD
SN
OW
CR
EE
K
CHOCCOLOCCOCREEK
Solutia
OU-1 and 2
OU-3
OU-4
Choccolocco Creek
Snow Creek
2500 0 2500 5000 Feet
Regional Medical Center400 East 10th St, Anniston
Regional Medical Center
Attachments
Attachment A
Underground/Overhead Utility Checklist
05/27/04 Attach A Utility Checklist.doc
Anniston PCB Site Anniston, Alabama
Underground / Overhead Utility Checklist
Project Name: Date:
Project Number: Location:
Prepared By: Site Safety Officer: This checklist must be completed for any intrusive subsurface work such as excavation or drilling. It documents that overhead and underground utilities in the work area are identified and located. The Site Safety Officer shall request utility markouts before the start of field operations to allow the client and utility companies sufficient time to provide them. If complete information is not available, a magnetometer or other survey shall be performed to locate obstacles prior to intrusive subsurface activities. Procedure: A diagram of the work area depicting the proposed location of intrusive subsurface work sites (i.e., boring locations, excavation locations) must be attached to this form. The diagram must clearly indicate the areas checked for underground structures / utilities, and overhead power lines. This form and the diagram must be signed by the Site Safety Officer, the OU RI/FS Manager, and the CERCLA Manager.
Type of Structure Present Not Present Method of Markout
Electric Power Line
Natural Gas Line
Telephone Line
Water Line
Product Line
Sewer Line
Steam Line
Drain Line
Underground Tank
Underground Cable
Overhead Power Line
Overhead Product Line
Other (Specify)
Reviewed By
Name Job Title Date
CERCLA Manager
OU RI/FS Manager
Site Safety Officer
Attachment B
Sediment/Surface Water Sampling Checklist
SEDIMENT/SURFACE WATER SAMPLING CHECKLIST Project Name/Number Date Location Prepared By OU RI/FS Manager
This checklist must be completed for any sediment or surface water sampling. It documents that the required, permits, notifications, procedures and equipment are in place prior to commencing sampling activities. The OU RI/FS Manager or representative shall identify the need for and arrange to obtain sampling permits, clearance or right-of-way access from the appropriate entity during project planning.
Procedure Prior to any work on a navigable waterway or any activity that requires access the following items will be completed:
Activity:
Required for project:
Completed:
Comments:
Access rights to property YES NO YES NO
Activity planned that impedes traffic on navigable waterway
YES NO YES NO
Notification and approval
obtained from United States
Coast Guard and/or other
regulating authority (County,
US Parks Service, EPA)
YES NO YES NO
Buoys, signs markings or
other forms of notification
present
YES NO YES NO
Other (Specify)
Boating/Water Safety Checklist:
Activity: Required for project: Requirement: Comments:
Working on over or near
water (within 6 feet) YES NO
PFD Available for all
personnel
Boat has current registration,
has been inspected and
loaded safely YES NO
Capacity, load distribution
PFDs and throwable
floatation device available
Fire extinguisher on board
Boat operator has appropriate
training (USCG Boating
Safety Course or equivalent) YES NO
Sampling on or near water
below 50 degrees Fahrenheit YES NO
Cold water immersion suit for
affected personnel
Method of communication
available YES NO
Radio, cell phone or
scheduled check-in
CERCLA Manager Date
OU RI/FS Manager Date
Site Safety Officer Date
Attachment C
PCB Chemical Hazard Information Table and Material
Safety Data Sheet
Anniston PCB Site Anniston, Alabama
Health and Safety Plan
Attachment C CHEMICAL HAZARD INFORMATION
Attach C ChemHzdTbl.doc Page 1 of 2 5/6/2004
Substance [CAS Number]
IP1 (eV)
Odor Threshold
(ppm) Route2 Symptoms of Exposure Treatment TWA3 STEL4 Source5
IDLH (NIOSH
)6 Polychlorinated biphenyls (PCB) [1336-36-3] Aroclor 1242 [53469-21-9] and Aroclor 1254 [11097-69-1]
NA ND Inh Abs Ing Con
Aroclor 1242: irritated eyes; chloracne; acne-form dermatitis; liver damage; reproductive effects; mildly toxic by ingestion; poison by subcutaneous route – carcinogenic Aroclor 1254: irritated eyes; chloracne, acne-form dermatitis; liver damage; reproductive effects; poison by intravenous route; moderately toxic by ingestion and intraperitoneal routes – carcinogenic
Eye: Irrigate immediately Skin: Soap wash immediately Breath: Respiratory support Swallow: Immediate medical
attention
Aroclor 1242: 1 mg/m3 (skin) 1 mg/m3 (skin) 0.001 mg/m3
Aroclor 1254:
0.5 mg/m3 (skin) 0.5 mg/m3 (skin)
0.001 mg/m3
PEL TLV REL
PEL TLV REL
Ca
(5 mg/m3)
Ca (5 mg/m3)
NOTES: 1IP = Ionization potential (electron volts). 2Route = Inh, Inhalation; Abs, Skin absorption; Ing, Ingestion; and Con, Skin and/or eye contact. 3TWA = Time-weighted average. The TWA concentration for a normal workday (usually 8 or 10 hours) and a 40-hour work week, to which nearly all workers may be repeatedly
exposed, day after day without adverse effect. 4STEL = Short-term exposure limit. A 15-minute TWA exposure that should not be exceeded at any time during a workday, even if the TWA is not exceeded. 5PEL = Occupational Safety and Health Administration (OSHA) permissible exposure limit (29 CFR 1910.1000, Table Z). 5TLV = American Conference of Governmental Industrial Hygiene (ACGIH) threshold limit value – TWA. 5REL = National Institute for Occupational Safety and Health (NIOSH) recommended exposure limit. 6IDLH = Immediately dangerous to life or health (NIOSH). Represents the maximum concentration from which, in the event of respirator failure, one could escape within 30 minutes
without a respirator and without experiencing any escape-impairing or irreversible health effects. NE = None established. No evidence could be found for the existence of an IDLH (NIOSH Pocket Guide to Chemical Hazards, Pub. No. 90-117, 1990, 1997). C = Ceiling limit value which should not be exceeded at any time. Ca = Carcinogen. NA = Not applicable. ND = Not Determined. LEL = Lower explosive limits. LC50 = Lethal concentration for 50 percent of population tested. LD50 = Lethal dose for 50 percent of population tested. NIC = Notice of intended change (ACGIH).
Anniston PCB Site Anniston, Alabama
Health and Safety Plan
Attachment C CHEMICAL HAZARD INFORMATION
Attach C ChemHzdTbl.doc Page 2 of 2 5/6/2004
References:
American Conference of Governmental Industrial Hygienists (ACGIH) Guide to Occupational Exposure Values, 2003, compiled by the ACGIH.
ACGIH Threshold Limit Values, 2003, compiled by the ACGIH
Amoore, J. and E. Hautula, “Odor as an Aid to Chemical Safety,” Journal of Applied Toxicology, 1983.
Clayton, George D. and F.E. Clayton, Patty’s Industrial Hygiene and Toxicology, 3rd ed., John Wiley & Sons, New York.
Documentation of TLVs and BEIs, American Conference of Governmental Industrial Hygienists, 5th ed., 1986.
Fazzuluri, F.A., Compilation of Odor and Taste Threshold Values Data, American Society for Testing and Materials, 1978.
Gemet, L. and J. Van, Compilation of Odor Threshold Values in Air and Water, CIVO, Netherlands, 1977.
Gemet, L. and J. Van, Compilation of Odor Threshold Values in Air and Water, Supplement IV, CIVO, Netherlands, 1977.
Lewis, Richard J., Sr., 1992, Sax’s Dangerous Properties of Industrial Materials, 8th ed., Van Nostrand Reinhold, New York.
Micromedex Tomes Plus (R) System, 1992, Micromedex, Inc.
National Institute for Occupational Safety and health Pocket Guide to Chemicals, Pub. 1990, No. 97-140, National Institute for Occupational Safety and Health, 2003.
Odor Threshold for Chemicals with Established Occupational Health Standards, American industrial Hygiene Association, 1989.
Respirator Selection Guide, 3M Occupational Health and Safety Division, 1993.
Verschuseren, K., Handbook of Environmental Data on Organic Chemicals, Van Nostrand and Reinhold, 1977.
Warning Properties of Industrial Chemicals – Occupational Health Resource Center, Oregon Lung Association.
Workplace Environmental Exposure Levels, American Industrial Hygiene Association, 1992.
Material Safety Data Sheet Collection
Genium Publishing Corp. 1171 RiverFront Center Amsterdam, NY 12010
(518) 842-4111
Polychlorinated Biphenyls (PCBs)
POL2140
Issue Date: 2002-02
Copyright © 2002 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Section 1 - Chemical Product and Company Identification 54 Material Name: Polychlorinated Biphenyls (PCBs) CAS Number: 1336-36-3 Chemical Formula: Unspecified or Variable Structural Chemical Formula: (C12H10-x)Clx Synonyms: AROCLOR; AROCLOR 1221; AROCLOR 1232; AROCLOR 1242; AROCLOR 1248; AROCLOR 1254;
AROCLOR 1260; AROCLOR 1262; AROCLOR 1268; AROCLOR 2565; AROCLOR 4465; AROCLOR 5442; 1,1'-BIPHENYL,CHLORO DERIVS; BIPHENYL,POLYCHLORO-; CHLOPHEN; CHLOREXTOL; CHLORINATED BIPHENYL; CHLORINATED DIPHENYL; CHLORINATED DIPHENYLENE; CHLORO 1,1-BIPHENYL; CHLORO 1,1-BIPHENYL-; CHLORO BIPHENYL; CLOPHEN; CLOPHEN A 60; DYKANOL; EPA PESTICIDE CHEMICAL CODE 017801; FENCLOR; FENCLOR 42; INERTEEN; KANECHLOR; KANECHLOR 300; KANECHLOR 400; MONTAR; MONTER; NOFLAMOL; PCB; PCBS; PHENOCHLOR; PHENOCLOR; POLYCHLORINATED BIPHENYL; POLYCHLORINATED BIPHENYLS; POLYCHLORINATED BIPHENYLS (PCB'S); POLYCHLOROBIPHENYL; PYRALENE; PYRANOL; SANTOTHERM; SANTOTHERM FR; SOVOL; THERMINOL; THERMINOL FR-1
General Use: Used as dielectric fluids in transformers and capacitors. Prior to 1972, were used as hydraulic and other industrial fluids (e.g., in vacuum pumps, as lubricants and cutting oils), in paints, inks and fire retardants.
Also used in heat transfer systems; gas-transmission turbines; carbonless reproducing paper; adhesives; as plasticizer in epoxy paints; fluorescent light ballasts; wax extenders; coolants; dedusting agents; pesticide extenders; surface treatment and coatings; sealants; caulking material.
This is one of a group of once widely used industrial chemicals whose high stability contributed both to their commercial usefulness and the long term deleterious environmental health effects. Consequently their use has been phased out. Their manufacture in the U.S.A. was discontinued in 1977.
Section 2 - Composition / Information on Ingredients Name CAS % polychlorinated biphenyls (PCB's) 1336-36-3 100
OSHA PEL No data found.
ACGIH TLV No data found.
NIOSH REL No data found.
Section 3 - Hazards Identification
21
0—
Fire Diamond 0 1 2 3 4
FlammabilityToxicity
Body ContactReactivity
Chronic
ChemWatch Hazard Ratings
Min Low Moderate High Extreme
2
0
1
HMIS
Health
Flammability
Reactivity
ANSI Signal Word
Warning!
����� Emergency Overview ����� Oily liquid, white crystalline solid, or hard resin. Severely irritating. Suspect cancer hazard. Chronic: chloracne, GI disturbances, neurological symptoms, liver enlargement, menstrual changes, bronchitis. Possible reproductive and teratogenic effects.
Potential Health Effects Target Organs: skin, liver, eyes, mucous membranes, respiratory system Primary Entry Routes: inhalation, skin contact, ingestion
2002-02 Polychlorinated Biphenyls (PCBs) POL2140
Copyright © 2002 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 2 of 6
Acute Effects Inhalation: Not normally a hazard due to nonvolatile nature of product. Inhalation of vapor is more likely at higher
than normal temperatures. The vapor/mist is discomforting and may be extremely toxic if inhaled. Eye: The vapor/liquid is moderately discomforting and may be harmful to the eyes. Skin: The liquid is harmful to the skin, it is rapidly absorbed and is capable of causing skin reactions. Exposure to material may result in a dermatitis, described as chloracne, a persistent acneiform characterized by
comedones (white-, and black- heads), keratin cysts, and inflammed papules with hyperpigmentation and an anatomical distribution frequently involving the skin under the eyes and behind the ears. It occurs after acute or chronic exposure to a variety of chlorinated aromatic compounds by skin contact, ingestion or inhalation and may appear within days and months following the first exposure. Other dermatological alterations including hypertrichosis (the growth of excess hair), an increased incidence of actinic or solar elastosis (the degeneration of elastic tissue within muscles or loss of dermal elasticity produced by the effects of sunlight), and Peyrone's disease (a rare progressive scarring of the penile membrane).
Ingestion: Considered an unlikely route of entry in commercial/industrial environments. The material is moderately discomforting to the gastrointestinal tract and may be harmful if swallowed in large
quantity. Ingestion may result in nausea, pain, vomiting. Vomit entering the lungs by aspiration may cause potentially lethal
chemical pneumonitis. Digestion may lead to nausea, vomiting, abdominal pain, anorexia, jaundice and liver damage, coma and death.
Headache, dizziness, lethargy, depression, nervousness, loss of libido, muscle, joint pains may be found. Symptoms appear after a latent period of 5 to 6 months. PCB's may appear in breast milk of exposed mothers and in newborn infants.
Carcinogenicity: NTP - Class 2B, Reasonably anticipated to be a carcinogen, sufficient evidence of carcinogenicity from studies in experimental animals; IARC - Group 2A, Probably carcinogenic to humans; OSHA - Not listed; NIOSH - Not listed; ACGIH - Not listed; EPA - Class B2, Probable human carcinogen based on animal studies; MAK - Not listed.
Chronic Effects: People occupationally exposed to PCB's have relatively high PCB residue levels in blood plasma. Symptoms include chloracne dermatitis and degreasing the skin, pigmentation of skin and nails, excessive eye discharge, swelling of eyelids, transient visual disturbances, distinctive hair follicles, edema of the face and hands.
In common with other polyhalogenated aromatic hydrocarbons, the chlorinated biphenyls exhibit dioxin-like behavior. Polyhalogenated aromatic hydrocarbons (PHAHs) comprise two major groups. The first group represented by the halogenated derivatives of dibenzodioxins (the chlorinated form is PCDD), dibenzofurans (PCDF) and biphenyls (PCB) exert their toxic effect (as hepatoxicants, reproductive toxicants, immunotoxicants and procarcinogens) by interaction with a cytostolic protein known as the Ah receptor. In guinea pigs the Ah receptor is active in a mechanism which "pumps" PHAH into the cell whilst in humans the reverse appears to true. This, in part, may account for species differences often cited in the literature. This receptor exhibits an affinity for the planar members of this group and carries these to the cellular nucleus where they bind, reversibly, to specific genomes on DNA.
This results in the regulation of the production of certain proteins which elicit the toxic response. The potency of the effect is dependent on the strength of the original interaction with the Ah receptor and is influenced by the degree of substitution by the halogen and the position of such substitutions on the parent compound.
The most potent molecule is 2,3,7,8-tetrachlorodibenzo-p-dioxin (TCDD) while the coplanar PCBs (including mono-ortho coplanars) possess approximately 1% of this potency. Nevertheless, all are said to exhibit "dioxin-like" behavior and in environmental and health assessments it has been the practice to assign each a TCDD-equivalence value.
The most subtle and important biological effects of the PHAHs are the effects on endocrine hormones and vitamin homeostasis. TCDD mimics the effect of thyroxin (a key metamorphosis signal during maturation) and may disrupt patterns of embryonic development at critical stages. Individuals from exposed wildlife populations have been observed to have altered sexual development, sexual dysfunction as adults and immune system suppression.
Immunotoxic effects of the PHAHs (including the brominated congener, PBB) have been the subject of several studies. No clear pattern emerges in human studies however with T-cell numbers and function (a blood marker for immunological response) increasing in some and decreasing in others.
Three incidences have occurred which have introduced abnormally high levels of dioxin or dioxin-like congeners to humans. The explosion at a trichlorophenol-manufacturing plant in Seveso, Italy distributed TCDD across a large area of the country-side, whilst rice-oil contaminated with heat-transfer PCBs (and dioxin-like contaminants) has been consumed by two groups, on separate occasions (one in Yusho, Japan and another in Yu-cheng, Taiwan). The only symptom which can unequivocally be related to all these exposures is the development of chloracne, a disfiguring skin condition, following each incident. Contaminated oil poisonings also produced eye-discharge, swelling of eyelids and visual disturbances. The Babies born up to 3 years after maternal exposure (so-called "Yusho-babies") were characteristically brown skinned, colored gums and nails and (frequently) produced eye-discharges. Delays in intellectual development have been noted. It has been estimated that Yu-cheng patients consumed an average level of 0.06 mg/kg body weight/day total PCB and 0.0002 mg/kg/day of PCDF before the onset of symptoms after 3 months. When the oil was withdrawn after 6 months they had consumed 1 gm total PCB containing 3.8 mg PCDF.
2002-02 Polychlorinated Biphenyls (PCBs) POL2140
Copyright © 2002 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 3 of 6
Preliminary data from the Yusho cohort suggests a six-fold excess of liver cancer mortality in males and a three-fold excess in women.
Recent findings from Seveso indicate that the biological effects of low level exposure (BELLEs), experienced by a cohort located at a great distance from the plant, may be hormetic, i.e. may be protective AGAINST the development of cancer.
TCDD induces carcinogenic effects in the laboratory in all species, strains and sexes tested. These effects are dose-related and occur in many organs.
Exposures as low as 0.001 ug/kg body weight/day produce carcinoma. Several studies implicate PCBs in the development of liver cancer in workers as well as multi-site cancers in animals. The second major group of PHAH consists of the non-planar PCB congeners which possess two or more ortho-substituted halogens. These have been shown to produce neurotoxic effects which are thought to reduce the concentration of the brain neurotransmitter, dopamine, by inhibiting certain enzyme-mediated processes.
The specific effect elicited by both classes of PHAH seems to depend on the as much on the developmental status of the organism at the time of the exposure as on the level of exposure over a lifetime.
Section 4 - First Aid Measures Inhalation: Remove to fresh air. Lay patient down. Keep warm and rested. If breathing is shallow or has stopped, ensure clear airway and apply resuscitation. Transport to hospital or doctor. Eye Contact: Immediately hold the eyes open and flush continuously for at least 15 minutes with fresh running water.
Ensure irrigation under eyelids by occasionally lifting the upper and lower lids. Transport to hospital or doctor without delay. Removal of contact lenses after an eye injury should only be undertaken
by skilled personnel. Skin Contact: Immediately remove all contaminated clothing, including footwear (after rinsing with water). Wash affected areas thoroughly with water (and soap if available). Seek medical attention in event of irritation. Ingestion: Contact a Poison Control Center. DO NOT induce vomiting. Observe the patient carefully. Never give liquid
to a person showing signs of being sleepy or with reduced awareness; i.e. becoming unconscious. Give water (or milk) to rinse out mouth. Then provide liquid slowly and as much as casualty can comfortably drink. Transport to hospital or doctor without delay.
After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Treat symptomatically. If large amounts are ingested, gastric lavage is suggested. For splash in the eyes, a petrolatum-based ophthalmic ointment may be applied to the eye to relieve the irritating effects of PCBs.
If electrical equipment arcs over, PCB dielectric fluids may decompose to produce hydrogen chloride (HCl), a respiratory irritant. [Monsanto] Preplacement and annual medical examinations of workers, with emphasis on liver function, skin condition, reproductive history, is recommended.
Section 5 - Fire-Fighting Measures Flash Point: > 141 °C Autoignition Temperature: 240 °C LEL: Not applicable UEL: Not applicable Extinguishing Media: Foam.Alcohol stable foam. Dry chemical powder. General Fire Hazards/Hazardous Combustion Products: Noncombustible liquid.
POLLUTANT -contain spillage. Decomposes on heating and produces acrid black soot and toxic fumes of aldehydes, hydrogen
chloride (HCl), chlorides and extremely toxic polychlorinated dibenzofuran (PCDF), polychlorinated dibenzodioxin (PCDD).
Fire Incompatibility: Reacts vigorously with chlorine (Cl2). Fire-Fighting Instructions: POLLUTANT -contain spillage. Noncombustible. Clear area of personnel and move upwind. Contact fire department and tell them location and nature of hazard. Wear full body protective clothing with breathing apparatus. Prevent, by any means available, spillage from entering
drains or waterways. Use fire fighting procedures suitable for surrounding area. Cool fire-exposed containers with water spray from a protected location. Avoid spraying water onto liquid pools. If safe to do so, remove containers from path of fire. Equipment should be thoroughly decontaminated after use.
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Section 6 - Accidental Release Measures Small Spills: POLLUTANT -contain spillage. Clean up all spills immediately. Environmental hazard - contain spillage. Avoid breathing vapors and contact with skin and eyes. Wear protective clothing, impervious gloves and safety glasses. Contain spill with sand, earth or vermiculite. Wipe up and absorb small quantities with vermiculite or other absorbent material. Place spilled material in clean, dry, sealable, labeled container. Large Spills: POLLUTANT -contain spillage. Clear area of personnel. Contact fire department and tell them location and nature of hazard. Wear full body protective clothing with breathing apparatus. Prevent, by any means available, spillage from entering
drains or waterways. Stop leak if safe to do so. Contain spill with sand, earth or vermiculite. Collect recoverable product into labeled containers for recycling. Absorb remaining product with sand, earth or vermiculite. Collect residues and seal in labeled drums for disposal. After clean-up operations, decontaminate and launder all protective clothing and equipment before storing and reusing. If equipment is grossly contaminated, decontaminate and destroy. If contamination of drains or waterways occurs, advise emergency services. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).
Section 7 - Handling and Storage Handling Precautions: Do not allow clothing wet with material to stay in contact with skin Use good occupational
work practices. Observe manufacturer's storing and handling recommendations. Atmosphere should be regularly checked against established exposure standards to ensure safe working conditions are
maintained. Avoid all personal contact, including inhalation. Wear protective clothing and gloves when handling containers. Avoid physical damage to containers. Use in a well-ventilated area and Use only in completely enclosed system. Avoid contact with incompatible materials. When handling, DO NOT eat, drink or smoke. Wash hands with soap and water after handling. Work clothes should be laundered separately: NOT at home. Recommended Storage Methods: Packaging as recommended by manufacturer. Check that containers are clearly labeled. Metal can or metal drum or Steel drum with plastic liner. Regulatory Requirements: Follow applicable OSHA regulations.
Section 8 - Exposure Controls / Personal Protection Engineering Controls: Provide adequate ventilation in warehouse or closed storage areas. If inhalation risk of overexposure exists, wear NIOSH-approved organic-vapor respirator. In confined spaces where there is inadequate ventilation, wear full-face air supplied breathing apparatus. Personal Protective Clothing/Equipment Eyes: Safety glasses with side shields; chemical goggles. Full face shield. Contact lenses pose a special hazard; soft lenses may absorb irritants and all lenses concentrate them. Hands/Feet: Impervious gloves or Viton gloves or Polyethylene gloves or PVC gloves. Protective footwear.
2002-02 Polychlorinated Biphenyls (PCBs) POL2140
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Other: Impervious protective clothing. Overalls. Impervious apron. Eyewash unit. Ensure there is ready access to a safety shower.
Section 9 - Physical and Chemical Properties Appearance/General Info: Clear, colorless to yellow-green, mobile oily to viscous liquid, or sticky to hard resin, or
white crystalline solid, depending on degree of chlorination. Slightly soluble in glycerol and glycols. Soluble in organic solvents and lipids. Viscosity range: 71 - 2500 Saybolt unit sec. at 38 °C. PCBs are resistant to chemical and biological degradation and because of their solubility in fats and oils they tend to be concentrated in living organisms. The highly chlorinated PCBs are retained in animal's bodies longer and seems to delay the excretion of the lower chlorinated PCB's. They have become widely dispersed in the world-wide environment and in the food-chain since their introduction in 1929. They are now recognized internationally to be a major environmental pollutant, their persistence causing ecological damage via water pollution. Consequently loss of PCBs to the environment is to be avoided at all costs.
Physical State: Liquid Vapor Pressure (kPa): Negligible Formula Weight: 188.66 - 395 Specific Gravity (H2O=1, at 4 °C): 1.18 - 1.8 Water Solubility: Solubility in water extremely low Evaporation Rate: Non Vol. at 38 °C
pH: Not applicable pH (1% Solution): Not applicable. Boiling Point Range: 340 °C (644 °F) to 375 °C
(707 °F) Decomposition Temperature (°C): 375-550
Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Product is considered stable. Hazardous polymerization will not occur. Storage Incompatibilities: Avoid storage with oxidizers. Segregate from chlorine. Avoid contamination of water, foodstuffs, feed or seed.
Section 11 - Toxicological Information TOXICITY IRRITATION Oral (human) LDLo: 500 mg/kg Nil reported Oral (rat) LD50: 3980 mg/kg
See NIOSH, RTECS TQ1350000, for additional data.
Section 12 - Ecological Information Environmental Fate: PCBs are mixtures of different congeners of chlorobiphenyl and the relative importance of the
environmental fate mechanisms generally depends on the degree of chlorination. In general, the persistence of PCBs increases with an increase in the degree of chlorination. Mono-, di- and trichlorinated biphenyls (Aroclor 1221 and 1232) biodegrade relatively rapidly, tetrachlorinated biphenyls (Aroclors 1016 and 1242) biodegrade slowly, and higher chlorinated biphenyls (Aroclors 1248, 1254, and 1260) are resistant to biodegradation. Although biodegradation of higher chlorinated congeners may occur very slowly on an environmental basis, no other degradation mechanisms have been shown to be important in natural water and soil systems; therefore, biodegradation may be the ultimate degradation process in water and soil.
If released to soil, PCBs experience tight adsorption with adsorption generally increasing with the degree of chlorination. PCBs will generally not leach significantly in aqueous soil systems; the higher chlorinated congeners will have a lower tendency to leach than the lower chlorinated congeners. In the presence of organic solvents PCBs may leach quite rapidly through soil. Vapor loss from soil surfaces appears to be an important fate mechanism with the rate of volatilization decreasing with increasing chlorination. Although the volatilization rate may be low, the total loss by volatilization over time may be significant because of persistence and stability. Enrichment of the low Cl PCBs occurs in the vapor phase relative to the original Aroclor; the residue will be enriched in the PCBs containing high Cl content.
2002-02 Polychlorinated Biphenyls (PCBs) POL2140
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If released to water, adsorption to sediment and suspended matter will be an important fate process; PCB concentrations in sediment and suspended matter have been shown to be greater than in the associated water column. Although adsorption can immobilize PCBs (especially the higher chlorinated congeners) for relatively long periods of time, eventual resolution into the water column has been shown to occur. The PCB composition in the water will be enriched in the lower chlorinated PCBs because of their greater water solubility, and the least water soluble PCBs (highest Cl content) will remain adsorbed. In the absence of adsorption, PCBs volatilize relatively rapidly from water. However, strong PCB adsorption to sediment significantly competes with volatilization, with the higher chlorinated PCBs having longer half-lives than the lower chlorinated PCBs. Although the resulting volatilization rate may be low, the total loss by volatilization over time may be significant because of persistence and stability. PCBs have been shown to bioconcentrate significantly in aquatic organisms. If released to the atmosphere, PCBs will primarily exist in the vapor-phase; the tendency to become associated with the particulate-phase will increase as the degree of chlorination of the PCB increases. The dominant atmospheric transformation process is probably the vapor-phase reaction with hydroxyl radicals which has estimated half-lives ranging from 12.9 days for monochlorobiphenyl to 1.31 years for heptachlorobiphenyl. Physical removal from the atmosphere, which is very important environmentally, is accomplished by wet and dry deposition.
Ecotoxicity: Aquatic toxicity: 0.278 ppm/96 hr/bluegill/TLm/fresh water 0.005 ppm/336-1080 hr/pinfish/TLm/salt water; Waterfowl toxicity: LD50 2000 ppm (mallard duck); Food chain concentration potential: High
Henry's Law Constant: 5 x10-5 BCF: bioconcentrate in tissue Biochemical Oxygen Demand (BOD): very low Soil Sorption Partition Coefficient: Koc = 510 to 1.33 x104
Section 13 - Disposal Considerations Disposal: Recycle wherever possible. Consult manufacturer for recycling options. Follow applicable federal, state, and local regulations. Due to their environmental persistence and potential health hazards, PCBs cannot be disposed of in landfills or
dumped at sea. The only environmentally acceptable method for the disposal of PCBs is by high temperature incineration.
All wastes and residues containing PCB's (e.g., wiping cloths, absorbent material, used disposable protective gloves, contaminated clothing, etc.) should be collected, placed in proper containers, labelled and disposed of in accordance with applicable regulations.
Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101):
Shipping Name: POLYCHLORINATED BIPHENYLS
Hazard Class: 9 ID No.: 2315 Packing Group: II Label: Miscellaneous Dangerous Goods[9]
Additional Shipping Information: PCB'S
Section 15 - Regulatory Information EPA Regulations:
RCRA 40 CFR: Not listed CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per CWA Section 307(a) 1 lb (0.454 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Not listed TSCA: Listed
Section 16 - Other Information Disclaimer: Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s
responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Attachment D
Parathion Material Safety Data Sheet
Material Safety Data Sheet Collection
Genium Publishing Corp. 1171 RiverFront Center Amsterdam, NY 12010
(518) 842-4111
Parathion
PAR6840 Temp: was 0946.html
Issue Date: 2003-02
Copyright © 2003 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Section 1 - Chemical Product and Company Identification 46/57 Material Name: Parathion CAS Number: 56-38-2 Chemical Formula: C10H14NO5PS Structural Chemical Formula: (C2H5O)2P(S)OC6H4NO2 EINECS Number: 200-271-7 Synonyms: AAT; AATP; AC 3422; ACC 3422; ALKRON; ALLERON; AMERICAN CYANAMID 3422;
APHAMITE; ARALO; B 404; BAY E-605; BAYER E-605; BLADAN; BLADAN F; COMPOUND 3422; COROTHION; CORTHION; CORTHIONE; DANTHION; O,O-DIAETHYL-O-(4-NITRO-PHENYL)-MONOTHIOPHOSPHAT; DIETHYL PARA-NITROPHENOL THIOPHOSPHATE; 0,0-DIETHYL 0-(P-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL O-(4-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL O-(P-NITROPHENYL) PHOSPHOROTHIOATE; DIETHYL 4-NITROPHENYL PHOSPHOROTHIONATE; DIETHYL P-NITROPHENYL PHOSPHOROTHIONATE; DIETHYL P-NITROPHENYL THIONOPHOSPHATE; 0,0-DIETHYL 0-P-NITROPHENYL THIOPHOSPHATE; DIETHYL P-NITROPHENYL THIOPHOSPHATE; O,O-DIETHYL O-4-NITROPHENYL THIOPHOSPHATE; O,O-DIETHYL O-P-NITROPHENYL THIOPHOSPHATE; DIETHYL PARATHION; O,O-DIETHYL-O-(4-NITRO-FENIL)-MONOTHIOFOSFAAT; O,O-DIETHYL-O-P-NITROFENYLESTER KYSELINY THIOFOSFORECNE; O,O-DIETHYL-O(P-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL-O-(4-NITROPHENYL) PHOSPHOROTHIOATE; O,O-DIETHYL-O-(P-NITROPHENYL)THIONOPHOSPHATE; DIETHYLPARATHION; DIETIL TIOFOSFATO DE P-NITROFENILA; O,O-DIETIL-O-(4-NITRO-FENIL)-MONOTIOFOSFATO; O,O-DIETYL-O-P-NITROFENYLTIOFOSFAT; DNTP; DPP; DREXEL PARATHION 8E; E 605; E 605 F; E 605 FORTE; ECATOX; EKATIN WF & WF ULV; EKATOX; ENT 15,108; EPA PESTICIDE CODE 057501; EPA SHAUGHNESSY CODE: 057701; ETHLON; ETHYL PARATHION; ETILON; ETYLPARATION; FOLICLAL; FOLICOL E605; FOLIDOL; FOLIDOL E; FOLIDOL E & E 605; FOLIDOL E605; FOLIDOL OIL; FOSFERMO; FOSFERNO; FOSFEX; FOSFIVE; FOSOVA; FOSTERN; FOSTOX; GEARPHOS; GENITHION; KOLPHOS; KYPTHION; LETHALAIRE G-54; LIROTHION; MURFOS; NIRAN; NIRAN E-4; P-NITROPHENOL O-ESTER WITH O,O-DIETHYLPHOSPHOROTHIOATE; NITROSTIGMIN; NITROSTIGMINE; NITROSTYGMINE; NIUIF-100; NIUIF 100; NOURITHION; OLEOFOS 20; OLEOPARAPHENE; OLEOPARATHION; OMS 19; ORTHOPHOS; PAC; PACOL; PANTHION; PARADUST; PARAMAR; PARAMAR 50; PARAPHOS; PARATHENE; PARATHION; PARATHION ETHYL; PARATHION-AETHYL; PARATHION-ETHYL; PARAWET; PENNCAP E; PESTOX PLUS; PETHION; PHENOL,P-NITRO-,O-ESTER WITH O,O-DIETHYLPHOSPHOROTHIOATE; PHOSKIL; PHOSPHEMOL; PHOSPHENOL; PHOSPHOROTHIOIC ACID,O,O-DIETHYL O-(4-NITROPHENYL) ESTER; PHOSPHOROTHIOIC ACID,O,O-DIETHYL-O-(4-NITROPHENYL) ESTER; PHOSPHOROTHIOIC ACID,O,O-DIETHYL-O-(P-NITROPHENYL) ESTER; PHOSPHOSTIGMINE; RB; RHODIASOL; RHODIATOX; RHODIATROX; SELEPHOS; SIXTY-THREE SPECIAL E.C. INSECTICIDE; SIXTY-THREE SPECIAL EC INSECTICIDE; SNP; SOPRATHION; SOPROTHION; STABILIZED ETHYL PARATHION; STATHION; STRATHION; SULPHOS; SUPER RODIATOX; T-47; THIOFOS; THIOMEX; THIOPHOS; THIOPHOS 3422; THIOPHOSPHATE DE O,O-DIETHYLE ET DE O-(4-NITROPHENYLE); TIOFOS; TOX 47; VAPOPHOS; VITREX
Derivation: From sodium ethylate, thiophosphoryl chloride, and sodium p-nitrophenate. General Use: A restricted use pesticide in the US; used as an insecticide for wheat and nuts and as an acaricide.
Section 2 - Composition / Information on Ingredients Name CAS % Parathion 56-38-2 ca 98% vol, technical grade. Also available commercially as an emulsifiable concentrate of 50% or less, 15% or 25% wettable powders, dustable powder, granules, and aerosol. Discontinued formulations include parathion plus chlorbenside.
Trace Impurities: O,O-diethyl thiophosphorylchloride; O,O-triethyl thiophosphate; O,O-diethyl S-ethyl thiophosphate; O,O- diethyl S-ethyl dithiophosphate; nitro-phenetole; nitrophenol; parathion isomers and the dithio analogue of parathion.
OSHA PEL TWA: 0.1 mg/m3; skin.
OSHA PEL Vacated 1989 Limits TWA: 0.1 mg/m3; respirable.
ACGIH TLV TWA: 0.1 mg/m3; skin.
NIOSH REL TWA: 0.05 mg/m3; skin.
IDLH Level 10 mg/m3.
DFG (Germany) MAK TWA: 0.1 mg/m3; skin, simple asphyxiant, measured as inhalable fraction of the aerosol.
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Section 3 - Hazards Identification
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FlammabilityToxicity
Body ContactReactivity
Chronic
ChemWatch Hazard Ratings
Min Low Moderate High Extreme
4
1
1
HMIS
Health
Flammability
Reactivity
ANSI Signal Word
Danger! Poison
����� Emergency Overview ����� Yellowish (when pure) to brown liquid (technical grade) at temperatures > 43 °F (6 °C); faint garlic-like odor. Highly toxic by all routes of exposure. Handle with extreme caution.
Potential Health Effects Target Organs: Respiratory system, central nervous system (CNS), cardiovascular system (CVS), eyes, skin, blood
cholinesterase. Primary Entry Routes: Inhalation, skin/eye contact/absorption, ingestion. Acute Effects The onset of signs and symptoms usually is prompt, but may be delayed up to 12 hr. Systemic Effects by all routes: Nausea, vomiting, abdominal pain, diarrhea, excessive salivation, sweating, headache,
giddiness, vertigo (dizziness), weakne ss, blurring or dimness of vision, miosis or mydiasis (dilatation of the pupils), tearing, bradycardia (slow heart beat), tachycardia (fast heart beat), cardiac irregularities (arrhythmias, compl ete heart block), loss of muscle coordination, slurred speech, muscle twitching (particularly tongue and eyelids), generalized profound weakness, confusion, disorientation, drowsiness, difficulty in breathing, excessive secretion of saliva and mucus, cyanosis, rales, high blood pressure, random jerky movements, incontinence, convulsions, coma, and death due to respiratory paralysis. Inhalation: Difficulty breathing, tightness in the chest, wheezing, rales, increased rate of respiration, headache,
rhinnorrhea (runny nose), and excessive bronchial secretions. Laryngeal spasms and excessive salivation may add to respiratory distress, and cyanosis (blue discoloration of skin and mucous membranes due to deficient oxygenation of the blood) may also occur. Pulmonary edema (fluid in the lungs) may occur in severe cases. Ocular (eye) effects include miosis (pinpoint pupils), tearing, and blurring of distant vision.
Eye: (See ocular effects above produced with inhalation.) One drop of parathion in the eye can be fatal; it is absorbed from the cornea and conjunctiva.
Skin: Skin absorption produces localized sweating and muscular twitching in the immediate area, usually occurring within 15 min to 4 hr. Dermal sensitization may occur.
Ingestion: Nausea, vomiting, loss of appetite, abdominal cramps, and diarrhea occur within 15 min to 2 hr. Carcinogenicity: NTP - Not listed; IARC - Group 3, Not classifiable as to carcinogenicity to humans; OSHA - Not
listed; NIOSH - Not listed; ACGIH - Class A4, Not classifiable as a human carcinogen; EPA - Class C, Possible human carcinogen; MAK - Not listed.
Medical Conditions Aggravated by Long-Term Exposure: Glaucoma; CVS, hepatic and renal disease; and CNS abnormalities.
Chronic Effects: Individuals may become even more susceptible to parathion's toxic effects after repeated exposure. Parathion binds irreversibly to cholinesterase, causing its depletion, and this is presumably the reason for increased susceptibility to parathion in chronic exposure. Effects include headache, dizziness, fatigue, loss of appetite, memory loss, insomnia, disorientation, muscular twitching and trembling, and occasionally neuritis (an inflammatory or degenerative lesion of a nerve) and paresis (slight or partial paralysis).
Other Health Effects: Parathion is converted in the body in part to paraoxon, an active cholinesterase inhibitor. Parathion has been fetotoxic, but not teratogenic in laboratory animals. It has induced DNA damage in rodents, mutations in Salmonella, and sister chromatid exchanges in vitro (outside the body in an artificial environment).
Section 4 - First Aid Measures Inhalation: Remove exposed person to fresh air and support breathing as needed. Eye Contact: Do not allow victim to rub or keep eyes tightly shut. Gently lift eyelids and flush immediately and
continuously with flooding amounts of water until transported to an emergency medical facility. Consult a physician or ophthalmologist immediately.
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Skin Contact: Quickly remove contaminated clothing. Immediately and thoroughly wash exposed area (including hair and beneath nails) with soap and water, followed by a 95% ethanol wash, and finally, a second soap and water wash. Tincture of green soap contains 30% ethanol and is recommended for dermal decontamination.
Ingestion: Never give anything by mouth to an unconscious or convulsing person. Contact a poison control center. Unless the poison control center advises otherwise, have the conscious and alert person drink 1 to 2 glasses of water. Do not induce vomiting due to potential coma and seizures and increased risk of aspiration of gastric contents.
After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: Delayed respiratory crisis may occur 2 to 3 weeks after acute exposure. Delayed polyneuropathy of the mixed sensory-motor type may occur 6 to 21 days after acute exposure. Recovery may be slow or incomplete. Measure the urinary metabolite, p-nitrophenol, within 48 hr of exposure, to assess parathion absorption. Red blood cell cholinesterase depression to levels substantially below pre-exposure levels (at least 50% and usually much lower) is verification of poisoning.
Treatment: As soon as cyanosis has been overcome, give intravenously, 2 to 4 mg of atropine. Repeat this dose of atropine at 5- to 10-minute intervals until signs of atropinization appear. If muscarinic symptoms reappear, repeat the atropine dose. Maintain a mild degree of atropinization for at least 48 hr. For moderate-to-severe cases, inject 1 to 2 g of 2-PAM intravenously at a rate not in excess of 500 mg/min. If muscle weakness has not been relieved, or if it recurs within 20 min, a second dose of 1 g is indicated. 2-PAM is ineffective if aging, a process of converting to the monoethylphosphoryl enzyme, has occurred. Aging occurs over the following 24 to 48 hr after exposure. Morphine, aminophyline, and phenothiazines are contraindicated.
Section 5 - Fire-Fighting Measures Flash Point: 392 °F (200 °C), Open Cup Autoignition Temperature: None reported. LEL: None reported. UEL: None reported. Flammability Classification: Class IIIB Combustible Liquid Extinguishing Media: For small fires, use dry chemical, CO2, water spray, or standard foam. For
large fires, use water spray, fog, or standard foam. Do not scatter material with high pressure water hoses.
General Fire Hazards/Hazardous Combustion Products: Carbon monoxide, and oxides of nitrogen, phosphorus, and sulfur. Containers may explode in the heat of fire.
Fire-Fighting Instructions: If feasible and without undue risk, move containers from fire hazard area. Otherwise, cool fire-exposed containers until well after the fire is extinguished. Do not release runoff from fire control methods to sewers or waterways. Dike for later disposal. Because fire may produce toxic thermal decomposition products, wear a self-contained breathing apparatus (SCBA) with a full facepiece operated in pressure-demand or positive-pressure mode. Structural firefighter's protective clothing is not effective. Wear chemical protective clothing which is specifically recommended by the manufacturer. Unless stated by the clothing manufacturer, it may not provide thermal protection.
Section 6 - Accidental Release Measures Spill/Leak Procedures: Immediately notify safety personnel, evacuate all unnecessary personnel, shut off heat and
ignition sources, and isolate and ventilate area. Cleanup personnel should protect against inhalation and skin or eye contact.
Small Spills: Treat spilled material with alkaline substances such as sodium carbonate (soda ash), sodium bicarbonate (baking soda), calcium hydroxide (slaked lime), lime or lime water when in dilute solution, and calcium carbonate (crushed limestone). Take up with sand or other noncombustible material (vermiculite) or collect for reclamation.
Large Spills: For large spills, dike far ahead of liquid spill for later disposal. Do not release into sewers or waterways. Further decontaminate with alkaline treatment or concentrated alkaline detergent.
Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).
Section 7 - Handling and Storage Handling Precautions: Avoid inhalation and any bodily contact. Wear appropriate personal protective clothing and
equipment. Once on the skin, parathion is very difficult to remove. Parathion residues have been found on the hands of one worker 2 months after last known contact. Practice meticulous personal hygiene procedures.
Never eat, drink, or smoke in work areas. Practice good personal hygiene after using parathion, especially before eating, drinking, smoking, using the toilet, or applying cosmetics.
Recommended Storage Methods: Store in tightly closed containers in a cool ,well-ventilated area away from heat and ignition sources and strong oxidizers and alkaline materials. Protect containers against physical damage and corrosion. Store in areas where any spillage from containers will not endanger workers or contaminate other materials.
Regulatory Requirements: Follow applicable OSHA regulations.
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Section 8 - Exposure Controls / Personal Protection Engineering Controls: Enclose all operations to prevent dispersion into workplace. Provide general or local exhaust
ventilation systems to maintain airborne concentrations below OSHA PELs (Sec. 2). Local exhaust ventilation is preferred because it prevents contaminant dispersion into the work area by controlling it at its source.
Administrative Controls: Consider preplacement and periodic medical exams with emphasis on the respiratory system, nervous system, CVS, eyes, skin (dermatitis), and blood (cholinesterase levels). Obtain blood levels of both red blood cell and plasma cholinesterase as a baseline. Remove from exposure any person whose red blood cell cholinesterase falls to or below 40% of the preexposure baseline until the activity returns to within 80% of the preexposure baseline.
Personal Protective Clothing/Equipment: Wear chemically protective gloves, boots, aprons, and gauntlets to prevent any skin contact. For parathion concentrations 30-70%, Teflon and Saranex, with breakthrough times >4 hr, are recommended materials for protective clothing. Natural rubber is not recommended. Parathion penetrates leather. Do not wear leather items, canvas shoes, or sneakers. Wear protective eyeglasses or chemical safety goggles, per OSHA eye- and face-protection regulations (29 CFR 1910.133). Contact lenses are not eye protective devices. Appropriate eye protection must be worn instead of, or in conjunction with contact lenses. Respiratory Protection: Seek professional advice prior to respirator selection and use. Follow OSHA respirator
regulations (29 CFR 1910.134) and, if necessary, wear a MSHA/NIOSH-approved respirator. For concentrations <= 0.5 mg/m3, wear any chemical cartridge respirator with organic vapor cartridge(s) in combination with a dust, mist, and fume filter or any supplied- air respirator. For concentrations <= 1.25 mg/m3, wear any supplied-air respirator operated in a continuous-flow mode; or an air- purifying respirator with organic vapor cartridge(s) in combination with a dust, mist, and fume filter. For concentrations <= 2.5 mg/m3, wear any chemical cartridge respirator with a full facepiece and organic vapor cartridge(s) in combination with a high- efficiency particulate filter; or any supplied-air respirator that has a tight-fitting facepiece and is operated in a continuous-flow mode; or any powered, air-purifying respirator with a tight-fitting facepiece and organic vapor cartridge(s) in combination with a high-efficiency particulate filter; or any SCBA with a full facepiece; or any supplied-air respirator with a full facepiece. For concentrations <= 10 mg/m3, wear any supplied-air respirator operated in a pressure-demand or other positive-pressure mode. For emergency or nonroutine operations (cleaning spills, reactor vessels, or storage tanks), wear an SCBA that has a full facepiece and is operated in a pressure-demand or other positive-pressure mode. Warning! Air-purifying respirators do not protect workers in oxygen-deficient atmospheres.
Other: Take a shower, washing completely, and change to clean clothes. Separate contaminated work clothes from street clothes. Launder before reuse. Make available hydrogen peroxide or hypochlorous acid (dilute) to decontaminate badly contaminated clothing before it is to be laundered. Remove parathion from your shoes and clean personal protective equipment. Dispose of leather items by incineration. Make emergency eyewash stations, safety/quick-drench showers, and washing facilities available in work area.
Section 9 - Physical and Chemical Properties Appearance/General Info: Yellowish (when pure) to brown (technical grade); faint garlic-like odor. Physical State: Liquid at temperatures > 43 °F (6 °C) Odor Threshold: 0.470 mg/m3 Vapor Pressure (kPa): 3.78 x 10-5 mm Hg at 68 °F
(20 °C) Formula Weight: 291.27 Specific Gravity (H2O=1, at 4 °C): 1.26 at 77 °F
(25 °C) Refractive Index: 1.5370 at 77 °F (25 °C) Boiling Point: 707 °F (375 °C)
Freezing/Melting Point: 43 °F (6 °C) Viscosity: 15.30 cP at 77 °F (25 °C) Surface Tension: 39.2 dyne/cm at 77 °F (25 °C) Water Solubility: 12.4 mg/L at 68 °F (20 °C) Other Solubilities: Alcohols, esters, ethers, chloroform,
ketones, aromatic hydrocarbons, and animal and vegetable oils; practically insoluble in petroleum ether and kerosene.
Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Parathion is stable in distilled water in acid solution; hydrolyzes in the
presence of alkaline material and slowly decomposes in air. Hazardous polymerization does not occur. Avoid contact with incompatibles and heat and ignition sources.
Storage Incompatibilities: Strong oxidizers, alkaline materials, and endrin. It will attack some forms of plastics, rubber, and coatings.
Hazardous Decomposition Products: Thermal oxidative decomposition of parathion can produce carbon monoxide and oxides of nitrogen, phosphorus, and sulfur.
2003-02 Parathion PAR6840
Copyright © 2003 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 5 of 6
Section 11 - Toxicological Information Acute Oral Effects: Rat, oral, LD50: 2 mg/kg. Human, oral, LDLo: 171 µg/kg. Acute Inhalation Effects: Rat, inhalation, LC50: 84 mg/m3/4 hr; toxic effects included tremor, convulsions or effect on seizure threshold, and dyspnea. Acute Skin Effects: Rat, skin, LD50: 6800 µg/kg produced toxic effects included tremor, convulsions or effect on seizure threshold and excitement. Rabbit, skin, LD50: 15 mg/kg. Human, skin, LDLo: 7143 µg/kg. Other Effects: Rat, oral: 234 mg/kg/90 days/intermittent; toxic effects included kidney, ureter, and bladder changes and multiple enzyme effects. Rat, oral: 1260 mg/kg/80 weeks/continuous; produced adrenal cortex tumors. Rat, oral: 360 µg/kg administered to the female 2-22 days of pregnancy and 15 days after birth; toxic effects included biochemical and metabolic effects on the newborn and other postnatal measures or effects. Mutagenicity: Human, fibroblast: 10 µmol/L caused unscheduled DNA synthesis.
See NIOSH, RTECS TF4550000, for additional data.
Section 12 - Ecological Information Environmental Fate: If released to water, little parathion will be lost through volatilization. Photolysis will be
important in surface waters. Bioconcentration of parathion in aquatic systems will be moderate to low. Biodegradation generally occurs with a half-life of several weeks, but in well acclimated water, complete degradation may occur in 2 weeks. The presence of photosensitizers, free radicals, hydrogen peroxide, or algae may accelerate degradation considerably. When parathion is sprayed on a field, it will exist primarily as an aerosol in the source area (field half-life: 5 min for conversion to paraoxon in summer sunlight; considerably slower after sunset). It may be scavenged by rain. Parathion absorbs strongly to soils. It degrades by both biological and soil-catalyzed hydrolysis. On the surface, photolysis may occur. At ordinary levels of application, parathion is degraded within weeks, but at very high levels of applications, residues will persist; persistence is dependent on soil type.
Ecotoxicity: Fulvous whistling duck, oral, LD50: 0.125 to 0.250 mg/kg; Daphnids, EC50: 0.60 µg/L/48 hr at 59 °F (15 °C); Aquatic Toxicity 0.32 ppm/mosquito fish/acute toxicity/fresh water; 1.6 ppm/96 hr/minnow/TLm/fresh water
Henry's Law Constant: 1.21 x 10-6 atm-m3/mole BCF: Parathion does not build up in the food chain. Octanol/Water Partition Coefficient: log Kow = 3.93, 3.40, 3.47
Section 13 - Disposal Considerations Disposal: Parathion is a potential candidate for rotary kiln, fluidized bed, or liquid injection incineration. For
wastewater treatment, consider reverse osmosis. Contact your supplier or a licensed contractor for detailed recommendations. Follow applicable Federal, state, and local regulations. Handle empty containers carefully as hazardous residues may remain. Triple rinse containers with alkaline detergent and properly dispose of wash water.
Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101):
Shipping Name: Parathion Hazard Class: 6.1 ID No.: NA2783 Packing Group: I; II Label: Poison
Section 15 - Regulatory Information EPA Regulations:
RCRA 40 CFR: Listed P089 CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per RCRA Section 3001 10 lb (4.535 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Listed RQ: 10 lb TPQ: 100 lb
2003-02 Parathion PAR6840
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TSCA: Not listed
Section 16 - Other Information Disclaimer: Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s
responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Attachment E
Paranitrophenol (PNP) Material Safety Data Sheet
Material Safety Data Sheet Collection
Genium Publishing Corp. 1171 RiverFront Center Amsterdam, NY 12010
(518) 842-4111
p-Nitrophenol
NIT5320 Issue Date: 2003-02
Copyright © 2003 by Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Section 1 - Chemical Product and Company Identification 56a/ 57 Material Name: p-Nitrophenol CAS Number: 100-02-7 Chemical Formula: C6H5NO3 Structural Chemical Formula: O2NC6H5OH EINECS Number: 202-811-7 Synonyms: 4-HYDROXYNITROBENZENE; P-HYDROXYNITROBENZENE; MONONITROPHENOL; NIPHEN;
4-NITROFENOL; P-NITROFENOL; 4-NITROPHENOL; P-NITRO-PHENOL; P-NITROPHENOL; PARA-NITROPHENOL; PARANITROFENOL; PARANITROFENOLO; PARANITROPHENOL; PHENOL,4-NITRO; PHENOL,4-NITRO-; PHENOL,P-NITRO-; PNP
General Use: indicator in 0.1% alcohol solution, intermediate in organic synthesis, production of parathion, fungicide for leather, indicator in water analysis, bactericide
Section 2 - Composition / Information on Ingredients Name CAS % p-nitrophenol 100-02-7 100
OSHA PEL No data found.
ACGIH TLV No data found.
NIOSH REL No data found.
Section 3 - Hazards Identification
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Fire Diamond 0 1 2 3 4
FlammabilityToxicity
Body ContactReactivity
Chronic
ChemWatch Hazard Ratings
Min Low Moderate High Extreme
ANSI Signal Word
Danger! Corrosive
����� Emergency Overview ����� Colorless to slightly yellow to brown crystals/prisms/solid; odorless. Irritating. Poison. Other Acute Effects: cyanosis; effects may vary from mild irritation to severe destruction of tissue. Chronic Effects: mutagenic effects.
Potential Health Effects Target Organs: eyes, skin, respiratory system, nervous system, blood Primary Entry Routes: accidental skin and eye contact, inhalation of generated dusts Acute Effects Inhalation: The dust is harmful and discomforting to the upper respiratory tract. Persons with impaired respiratory
function, airway diseases, or conditions such as emphysema or chronic bronchitis may incur further disability if excessive concentrations of particulate are inhaled. Inhalation of nitrophenols may produce mucous membrane irritation and systemic poisoning. The nitrophenols produce central and peripheral vagus stimulation, central nervous system depression, methemoglobinemia, and observable cyanosis with blue lips, earlobes and fingernails. Although signs may be absent, flushed face, headache and euphoria are common. Moderate exposures may produce weakness, dizziness, lightheadedness, increasingly severe headache, ataxia and shallow respiration, drowsiness, nausea, vomiting, confusion, lethargy and stupor. High concentrations may produce tachycardia, convulsions and coma.
Eye: The dust is mildly corrosive and discomforting to the eyes and is capable of causing burns. Skin: The solid/dust is discomforting to the skin. Toxic effects may result from skin absorption. Direct contact may
produce irritation and/or systemic poisoning.
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Ingestion: The solid/dust is discomforting to the gastrointestinal tract and harmful if swallowed. The substance and/or its metabolites may bind to hemoglobin inhibiting normal uptake of oxygen. This condition, known as "methemoglobinemia", is a form of oxygen starvation (anoxia). Symptoms include cyanosis (a bluish discoloration to skin and mucous membranes) and breathing difficulties. Symptoms may not be evident until several hours after exposure. At about 15% concentration of blood methemoglobin there is observable cyanosis of the lips, nose and earlobes. Symptoms may be absent although euphoria, flushed face and headache are commonly experienced. At 25-40%, cyanosis is marked but little disability occurs other than that produced on physical exertion. At 40-60%, symptoms include weakness, dizziness, lightheadedness, increasingly severe headache, ataxia, rapid shallow respiration, drowsiness, nausea, vomiting, confusion, lethargy and stupor. Above 60% symptoms include dyspnea, respiratory depression, tachycardia or bradycardia, and convulsions. Levels exceeding 70% may be fatal.
Carcinogenicity: NTP - Not listed; IARC - Not listed; OSHA - Not listed; NIOSH - Not listed; ACGIH - Not listed; EPA - Not listed; MAK - Not listed.
Chronic Effects: Chronic exposure to nitrophenols may produce kidney and liver damage. Studies in mammals show changes in neurohumoral regulation and pathology. Colitis, enteritis, hepatitis, gastritis, hyperplasia of the spleen and neuritis may occur.
Section 4 - First Aid Measures Inhalation: • If dust is inhaled, remove to fresh air. • Encourage patient to blow nose to ensure clear breathing passages. • Rinse mouth with water. Consider drinking water to remove dust from throat. • Seek medical attention if irritation or discomfort persist. Eye Contact: • Immediately hold the eyes open and flush with fresh running water. • Ensure complete irrigation of the eye by keeping eyelids apart and away from eye and moving the eyelids by
occasionally lifting the upper and lower lids. • Seek medical attention if pain persists or recurs. • Removal of contact lenses after an eye injury should only be undertaken by skilled personnel. Skin Contact: • Immediately remove all contaminated clothing, including footwear (after rinsing with water). • Wash affected areas thoroughly with water (and soap if available). • Seek medical attention in event of irritation. Ingestion: Contact a Poison Control Center. If more than 15 minutes from a hospital: • INDUCE vomiting with IPECAC SYRUP, or fingers down the back of the throat, ONLY IF CONSCIOUS. Lean
patient forward or place on left side (head-down position, if possible) to maintain open airway and prevent aspiration. NOTE: Wear a protective glove when inducing vomiting by mechanical means.
• SEEK MEDICAL ATTENTION WITHOUT DELAY. • In the meantime, qualified first-aid personnel should treat the patient following observation and employing supportive
measures as indicated by the patient's condition. • If the services of a medical officer or medical doctor are readily available, the patient should be placed in his/her care
and a copy of the MSDS should be provided. • If medical attention is not available on the worksite or surroundings send the patient to a hospital together with a copy
of the MSDS. After first aid, get appropriate in-plant, paramedic, or community medical support. Note to Physicians: For acute or short-term repeated exposures to phenols/cresols: • Phenol is absorbed rapidly through lungs and skin. Massive skin contact may result in collapse and death. • Ingestion may result in ulceration of upper respiratory tract; perforation of esophagus and/or stomach, with attendant complications, may occur. Esophageal stricture may occur.
• An initial excitory phase may present. Convulsions may appear as long as 18 hours after ingestion. Hypotension and ventricular tachycardia that require vasopressor and antiarrhythmic therapy, respectively, can occur.
• Respiratory arrest, ventricular dysrhythmias, seizures and metabolic acidosis may complicate severe phenol exposures so the initial attention should be directed towards stabilization of breathing and circulation with ventilation, intubation, intravenous lines, fluids and cardiac monitoring as indicated.
• Vegetable oils retard absorption; do NOT use paraffin oils or alcohols. Gastric lavage, with endotracheal intubation, should be repeated until phenol odor is no longer detectable; follow with vegetable oil. A saline cathartic should then be given. ALTERNATELY: Activated charcoal (1g/kg) may be given. A cathartic should be given after oral activated charcoal.
• Severe poisoning may require slow intravenous injection of methylene blue to treat methemoglobinemia. • Renal failure may require hemodialysis. • Most absorbed phenol is biotransformed by the liver to ethereal and glucoronide sulfates and is eliminated almost completely after 24 hours.
BIOLOGICAL EXPOSURE INDEX - BEIThese represent the determinants observed in specimens collected from a healthy worker who has been exposed at the Exposure Standard (ES or TLV): Determinant Index Sampling Time Comments Methemoglobin 1.5% of During or B,NS,SQ
2003-02 p-Nitrophenol NIT5320
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in blood hemoglobin end of shift B: Background levels occur in specimens collected from subjects NOT exposed NS: Non-specific determinant; also observed after exposure to other materials SQ: Semi-quantitative determinant - Interpretation may be ambiguous; should be used as a screening test or confirmatory test.
Section 5 - Fire-Fighting Measures Flash Point: 192 °C Autoignition Temperature: 283 °C Extinguishing Media: Water spray or fog. Foam. Dry chemical powder. BCF (where regulations
permit). Carbon dioxide. General Fire Hazards/Hazardous Combustion Products: • Combustible. • Slight fire hazard when exposed to heat or flame. • Heat may cause expansion or decomposition leading to violent rupture of containers. • On combustion, may emit toxic fumes of carbon monoxide (CO). • May emit acrid smoke. May emit poisonous fumes. Other combustion products include carbon
dioxide (CO2) and nitrogen oxides (NOx). Fire Incompatibility: Avoid contamination with oxidizing agents i.e., nitrates, oxidizing acids, chlorine bleaches, pool
chlorine etc. as ignition may result. Fire-Fighting Instructions: • Contact fire department and tell them location and nature of hazard. • Wear full body protective clothing with breathing apparatus. • Prevent, by any means available, spillage from entering drains or waterways. • Use water delivered as a fine spray to control fire and cool adjacent area. • Avoid spraying water onto liquid pools. • Do not approach containers suspected to be hot. • Cool fire-exposed containers with water spray from a protected location. • If safe to do so, remove containers from path of fire. Equipment should be thoroughly decontaminated after use.
Section 6 - Accidental Release Measures Small Spills: • Remove all ignition sources. • Clean up all spills immediately. • Avoid contact with skin and eyes. • Control personal contact by using protective equipment. • Use dry clean up procedures and avoid generating dust. • Place in a suitable labeled container for waste disposal. Large Spills: • Clear area of personnel and move upwind. • Contact fire department and tell them location and nature of hazard. • Wear full body protective clothing with breathing apparatus. • Prevent, by any means available, spillage from entering drains or waterways. • No smoking, bare lights or ignition sources. • Increase ventilation. • Stop leak if safe to do so. • Water spray or fog may be used to disperse/absorb vapor. • Contain or absorb spill with sand, earth or vermiculite. • Collect recoverable product into labeled containers for recycling. • Collect solid residues and seal in labeled drums for disposal. • Wash area and prevent runoff into drains. • After clean up operations, decontaminate and launder all protective clothing and equipment before storing and reusing. • If contamination of drains or waterways occurs, advise emergency services. Regulatory Requirements: Follow applicable OSHA regulations (29 CFR 1910.120).
Section 7 - Handling and Storage Handling Precautions: • Avoid all personal contact, including inhalation. • Wear protective clothing when risk of overexposure occurs. • Use in a well-ventilated area. • Prevent concentration in hollows and sumps. • DO NOT enter confined spaces until atmosphere has been checked. • Do not allow material to contact humans, exposed food or food utensils. • Avoid smoking, bare lights or ignition sources. • When handling, DO NOT eat, drink or smoke. • Avoid contact with incompatible materials. • Keep containers securely sealed when not in used.
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• Avoid physical damage to containers. • Always wash hands with soap and water after handling. • Working clothes should be laundered separately. Launder contaminated clothing before reuse. • Follow good occupational work practices. • Observe manufacturer's storage/handling recommendations. • Atmosphere should be regularly checked against established exposure standards to ensure safe working conditions are
maintained. Recommended Storage Methods: Glass container. Plastic container. Metal can. Metal drum. Check that all containers
are clearly labeled and free from leaks. Regulatory Requirements: Follow applicable OSHA regulations.
Section 8 - Exposure Controls / Personal Protection Engineering Controls: Local exhaust ventilation usually required. If risk of overexposure exists, wear NIOSH-
approved respirator. Provide adequate ventilation in warehouse or closed storage area. Personal Protective Clothing/Equipment: Eyes: Safety glasses with side shields. Chemical goggles. Full face shield. Contact lenses pose a special hazard; soft
lenses may absorb irritants and all lenses concentrate them. Hands/Feet: Wear chemical protective gloves, e.g. PVC. Wear safety footwear. Other: • Overalls. • PVC Apron. • PVC protective suit may be required if exposure severe. • Eyewash unit. • Ensure there is ready access to a safety shower.
Section 9 - Physical and Chemical Properties Appearance/General Info: Colorless to slightly yellow, odorless crystals; sweetish then burning taste. Freely soluble
in alcohol, chloroform and ether, also soluble in solutions of fixed hydroxides and carbonates. Physical State: colorless to slightly yellow to brown
crystals, prisms, or solid Vapor Pressure (kPa): 2.2 mm Hg at 146 °C Vapor Density (Air=1): 1.244 at 65 °C Formula Weight: 139.11 Specific Gravity (H2O=1, at 4 °C): 1.27 at 20 °C
Boiling Point: Decomposes at 279 °C (534 °F) Freezing/Melting Point: 113 °C (235.4 °F) to 114 °C
(237.2 °F) Water Solubility: 1600 x10 at 25 °C
Section 10 - Stability and Reactivity Stability/Polymerization/Conditions to Avoid: Product is considered stable. Hazardous polymerization will not occur. Storage Incompatibilities: Avoid reaction with oxidizing agents, bases and strong reducing agents.
Section 11 - Toxicological Information Toxicity Irritation Oral (rat) LD50: 250 mg/kg Nil reported Bacterial cell mutagen.
See NIOSH, RTECS SM2275000, for additional data.
Section 12 - Ecological Information Environmental Fate: When released on land, it will biodegrade with a half-life of approximately a day. If released in
water, it will also primarily biodegrade with a half-life of approximately 1-8 days. Half-lives will be markedly shortened when the microorganisms are well acclimated. Half-lives will be much longer in marine waters. Photolysis may also be important in clear surface waters (half-lives 2-14 days); being somewhat faster when the water is acidic or contains nitrate or nitrite ions. Adsorption to sediment should be minor under most circumstances and little or no bioconcentration should take place. If released into the atmosphere, it will be predominately adsorbed to particulate matter or be in aerosols. It will be subject to gravitational settling and photolyze with a half-life that may range from hours to a week or more.
Ecotoxicity: LC50 Pimephales promelas (fathead minnow) 41.0 (37.7-44.6) mg/l 96 hr, wt 84 mg, flow-through bioassay, dissolved oxygen 7.4 (4.6-8.8) mg/l, water hardness 44.9 (42.4-46.6) mg/l as CaCO3, pH 6.9-7.7, alkalinity 42.9 (39.6-61.4) mg/l CaCO3; LC50 Daphnia magna (Cladoceran) 35,000 ug/l/24 hr /Conditions of bioassay not specified
BCF: fathead minnow 79 Octanol/Water Partition Coefficient: log Kow = 1.91
2003-02 p-Nitrophenol NIT5320
Copyright © 2003 Genium Publishing Corporation. Any commercial use or reproduction without the publisher’s permission is prohibited. Page 5 of 5
Soil Sorption Partition Coefficient: Koc = estimated at 21
Section 13 - Disposal Considerations Disposal: • Consult manufacturer for recycling options and recycle where possible. • Follow applicable local, state, and federal regulations. • Incinerate residue at an approved site. • Recycle containers if possible, or dispose of in an authorized landfill.
Section 14 - Transport Information DOT Transportation Data (49 CFR 172.101):
Shipping Name: NITROPHENOLS Hazard Class: 6.1 ID No.: 1663 Packing Group: III Label: Harmful[6]
Section 15 - Regulatory Information EPA Regulations:
RCRA 40 CFR: Listed U170 Toxic Waste CERCLA 40 CFR 302.4: Listed per CWA Section 311(b)(4), per RCRA Section 3001, per CWA Section 307(a) 100
lb (45.35 kg) SARA 40 CFR 372.65: Listed SARA EHS 40 CFR 355: Not listed TSCA: Listed
Section 16 - Other Information Disclaimer: Judgments as to the suitability of information herein for the purchaser’s purposes are necessarily the purchaser’s
responsibility. Although reasonable care has been taken in the preparation of such information, Genium Publishing Corporation extends no warranties, makes no representations, and assumes no responsibility as to the accuracy or suitability of such information for application to the purchaser’s intended purpose or for consequences of its use.
Attachment F
Incident/Near-Miss Investigation Report
05/27/04 Page 1 of 3 Attach D Near Miss Form.doc
Anniston PCB Site Anniston, Alabama
Incident / Near-Miss Investigation Report
OSHA Recordable Lost Workday Injury Restricted Duty Injury
First Aid Injury Vehicle Accident Equipment Damage
Fire Spill / Leak Near Miss
Date of Incident: Incident Number:
Every employee injury, accident, and near miss must be reported within 24 hours of the injury. If the incident results in hospitalization, an immediate report must be made by telephone to the OU RI/FS Manager and the Health and Safety Officer.
Project Information
Project Name: Project #
Location of Incident:
Employee
Name: Employee Number:
Employment Status: Regular Part Time How long in present job?
Injury or Illness Information
Where did the incident / near miss occur? (number, street, city, state, zip):
Employee’s specific activity at the time of the incident / near miss:
Equipment, materials, or chemicals the employee was using when the incident / near miss occurred (e.g., the equipment employee struck against or that struck the employee; the vapor inhaled or material swallowed; what the employee was lifting, pulling, etc.):
Describe the specific injury or illness (e.g., cut, strain, fracture, etc.):
Body part(s) affected (e.g., back, left wrist, right eye, etc.):
Name and address of treatment provider (e.g., physician or clinic): Phone No.:
If hospitalized, name and address of hospital: Phone No.:
Date of injury or onset of illness: / / Time of event or exposure: AM PM
Did employee miss at least one full shift’s work? No Yes, 1st date absent (MM/DD/YYYY) / /
Has employee returned to work? Regular work Restricted work No Yes, date returned (MM/DD/YYYY) / /
To whom reported: Other workers injured / made ill in this event? Yes No
Description of Incident / Near Miss: (Describe what happened and how it happened.)
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Incident / Near-Miss Investigation Report
Motor Vehicle Accident (MVA) Company Vehicle?
Yes No
Accident Location (street, city, state)
Vehicle Towed?
Yes No
Other Vehicle?
Yes No
# Vehicles Towed:
# of Injuries:
Spill Material Spilled: Quantity: Source: Agency Notifications:
Cost of Incident $
Third Party Incidents Name of Owner:
Address:
Telephone:
Description of Damage:
Witness Name:
Address:
Telephone:
Witness Name:
Address:
Telephone:
# Root Cause and Contributing Factors: Conclusion (Describe in Detail Why Incident / Near Miss Occurred) 1 2 3 4 5 Root Cause(s) Analysis (RCA): 1. Lack of skill or knowledge. 5. Correct way takes more time and / or requires more
effort. 2. Lack of or inadequate operational procedures or work
standards. 6. Short-cutting standard procedures is positively
reinforced or tolerated. 3. Inadequate communication of expectations regarding
procedures or work standards. 7. Person thinks there is no personal benefit to always
doing the job according to standards. 4. Inadequate tools or equipment. 8. Uncontrollable.
# RCA #
Solution(s): How to Prevent Incident / Near Miss From Reoccurring
Person Responsible Due Date Closure
Date
Investigation Team Members Name Job Title Date
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Incident / Near-Miss Investigation Report
Results of Solution Verification and Validation
Reviewed By Name Job Title Date OU RI/FS Manager
OU Health and Safety Officer
Attachment G
Safe Work Observation Form
` Anniston PCB Site Anniston, Alabama
Safe Work Observation Form
Anniston PCB Site Anniston, Alabama
Observer Name Observer Title Project/Project Number
Date _ Project Type / Task Observed Time ____ AM PM
Background Information
List Critical Work Procedures
List Issue/Items Requiring Corrective Action
Root Cause Analysis 1. Employee lacks the skill or knowledge to carry out duties 5. Employee chose not to take the time or put forth the effort to do the job
properly 2. Procedures, work standards, or expectations were not communicated 6. Supervisor did not require the employee to follow the standard procedure 3. Procedures or work standards were not developed or were inadequate 7. Employee doesn’t see any advantage to doing the job to standard. 4. Equipment, systems, or tools were inadequate 8. Uncontrollable.
Criterion # RCA # Corrective Action Identified
Responsible Individual
Due Date
Closure Date
Results of Corrective Action
Reviewed by Date Reviewed by Date
` Anniston PCB Site Anniston, Alabama
Environmental Operations
PRE-TASK PREPARATION Correct Questionable Comments
1. Health and Safety Plan / MSDSs on site 2. Employee familiar / trained on task 3. OSHA-required training/medical surveillance 4. Utility mark out / check performed 5. Traffic hazard addressed / work area marked 6. Walking / working surfaces free of hazards 7. Tailgate safety meeting performed 8. Impact on nearby residence/business evaluated 9. Communicates intentions to other personnel 10. Knowledge of emergency procedures 11. Distance between equipment and power lines 12. Personal protective equipment 13. Air monitoring equipment on site, calibrated 14. First aid kit / fire extinguisher on site 15. One person trained in first aid / CPR 16. Work zones established and marked PERFORMING TASK 17. Employee trained in task to be performed 18. Correct body positioning 19. Proper lifting / pushing / pulling techniques 20. Keep hands / body away from pinch points 21. Walking / working surfaces kept clear of debris 22. Faces traffic as appropriate 23. Vehicles/ barricades to protect against traffic 24. Drill rig located properly, blocked / chocked 25. Drill rig moved only with derrick lowered 26. Excavator located on stable ground 27. Eye contact made with equipment operator 28. Spoil at least 2 feet back from edge of excavation 29. Excavation shored/sloped/benched 30. Excavation entry controlled 31. Equipment/tools used properly 32. Electrical equipment connected through GFCI 33. Power tools handled properly 34. Electrical cords inspected / in good condition 35. Follows lockout / tagout procedures 36. Air monitoring conducted/action levels understood 37. Equipment decontaminated properly 38. Personnel decon prior to eating/drinking/smoking 39. Decontamination effective POST – TASK 40. Procedures / AHA adequate 41. Equipment / tools stored properly 42. Proper storage of soil / water / waste material 43. Work area secured 44. Other
Attachment H
Air Monitoring Form
05/27/04 Attach F Air Form.doc
Anniston PCB Site Anniston, Alabama
Air Monitoring Log
Project: Monitoring Instruments:
Date:
Air Monitor: Level of Protection:
Activity:
Time
Location
Instrument Reading
Comments
Attachment I
Health and Safety Inspection Form
05/27/04 Page 1 of 3 Attach G H&S Insp Form.doc
Anniston PCB Site Anniston, Alabama
Health and Safety Inspection Form
Project Name: Date:
Project Number: Location:
Prepared By: Site Safety Officer:
Auditor: Health & Safety
Coordinator On Site:
YES NO N/A COMMENTS
GENERAL
Is the HASP on site?
Is the HASP finalized and approved?
Is the OSHA poster displayed?
Are emergency telephone numbers posted?
Is emergency eyewash immediately available?
Is an emergency shower immediately available?
Are emergency notification means available (radio, telephone)?
Is a first-aid kit immediately available?
Is the first-aid kit adequately stocked?
Is there a proper sanitation facility on site?
DOCUMENTATION AND RECORDKEEPING Are only personnel listed and approved in the HASP on site?
Are all personnel properly trained? (Check company-issued wallet cards.)
Is the daily field log kept by the Site Safety Officer?
Are levels of PPE recorded?
Are contaminant levels recorded?
Are site surveillance records kept by HSC?
Is a copy of current fit test records on site?
Are calibration records maintained for air monitoring equipment?
Are accident / incident forms on site?
Are field team review sheets signed?
Are additional hospital route directions available?
Is the visitors’ logbook being accurately maintained?
Are MSDSs available for all chemicals on site?
Are HASP revisions recorded?
Is the first-aid kit inspected weekly?
Are daily safety meetings held?
Are emergency procedures discussed during safety meetings?
05/27/04 Page 2 of 3 Attach G H&S Insp Form.doc
Anniston PCB Site Anniston, Alabama
Health and Safety Inspection Form
YES NO N/A COMMENTS
EMERGENCY RESPONSES Is a vehicle available on site for transportation to the hospital?
Are fire extinguishers on site and immediately available at designated work areas?
Is at least one person trained in CPR and first aid on site at all times during work activities?
Do all personnel know who is trained in CPR / first aid?
PERSONAL PROTECTIVE EQUIPMENT (PPE)
Is proper PPE being worn as specified in HASP?
Level of PPE being worn.
Is PPE adequate for work conditions?
If not, give reason.
Upgrade/downgrade to PPE level.
Does any employee have facial hair that would interfere with respirator fit?
If yes, willing to shave, as necessary?
Fit-tested within the last year? (Documentation present)
If Level B, is a back-up / emergency person suited up (except for air)?
Does the HSC periodically inspect PPE and equipment?
Is the PPE not in use properly stored?
Is all equipment required in the HASP on site?
Properly calibrated?
In good condition?
Used properly?
Other equipment needed?
List.
Is monitoring equipment covered with plastic to minimize contamination?
PERSONNEL AND EQUIPMENT DECONTAMINATION
Is the decontamination area properly designated?
Is appropriate cleaning fluid used for known or suspected contaminants?
Are appropriate decontamination procedures used?
Are decontamination personnel wearing proper PPE?
Is the equipment decontaminated?
05/27/04 Page 3 of 3 Attach G H&S Insp Form.doc
Anniston PCB Site Anniston, Alabama
Health and Safety Inspection Form
YES NO N/A COMMENTS
PERSONNEL AND EQUIPMENT DECONTAMINATION (continued)
Are sample containers decontaminated?
Are disposable items replaced as required?
WORK PRACTICES
Was proper collection and disposal of potentially contaminated PPE performed?
Was proper collection and disposal of decontamination fluid performed?
Is water available for decontamination?
Is the buddy system used?
Is equipment kept off drums and the ground?
Is kneeling or sitting on drums or the ground prohibited?
Do personnel avoid standing or walking through puddles or stained soil?
Are work zones established?
If night work is conducted, is there adequate illumination?
Is smoking, eating, or drinking in the exclusion or CRZ prohibited?
To the extent feasible, are contaminated materials handled remotely?
Are contact lenses not allowed on site?
Is entry into excavations not allowed unless properly shored or sloped?
Is a competent person on site during excavation?
Are all unusual situations on site listed in HASP?
If not, when?
Action taken?
HASP revised?
CONFINED SPACE ENTRY
Are employees trained according to 1910.146 – Confined Space Entry?
Are all confined spaces identified? If not, list:
Is all appropriate equipment available and in good working order?
Is equipment properly calibrated?
Are confined space permits used?
Are confined space permits completely and correctly filled out?
*N/A = Not Applicable
Attachment J
Safety Meeting Log
05/27/04 Attach H Safety Mtg Log.doc
Anniston PCB Site Anniston, Alabama
Safety Meeting Log
Project: Location: Date / Time: Activity: 1. Work Summary 2. Physical Chemical Hazards 3. Protective Equipment/Procedures 4. Emergency Procedures Is there anyone with any medical conditions that they would like the team to know about? For example: Medic Alert, allergic to bee stings, nitro for chest pains, etc. Location of medical equipment: fire extinguishers, first aid kit, route to hospital, auto-injectors, etc. 5. Signatures of Attendees
Attachment K
Hot Work Permit
05/27/04 Attach I Hot Work Permit.doc
Anniston PCB Site Anniston, Alabama
Site Hot Work Permit
Permit #:
Project:
ALL COPIES OF PERMIT MUST REMAIN AT
JOB SITE UNTIL THE WORK IS COMPLETE
Location and Description of Hot Work:
Checklist YES NO N/A COMMENT
Is there any alternate procedure to use instead of hot work?
Is it possible to move the hot work to a designated hot work area?
Is it possible to move all fire hazards at least 35 feet away? If all fire hazards cannot be removed, can guards, barriers, or screens be used to confine any heat, sparks, or slag, and to protect the immovable fire hazards?
Are there any flammable or combustible liquid storage areas within 50 feet? Is the area where the work is to be performed free of combustible material to heat, sparks, flying sparks, or slag?
Are combustible materials adjacent to the opposite side of partitions, walls, or ceilings protected by guards or moved 35 feet away from the surface?
Is everything moved or protected that could be damaged by sparks or water?
Is suitable fire extinguishing equipment on hand and ready for immediate use?
Is the sprinkler system in the area operational? Are the surrounding employees in an area where flying sparks and slag may injure them?
Have precautions been implemented to prevent injury to employees?
Has the area supervisor been notified?
Is a fire watch in place?
Is hot work to be conducted in a confined space? Is appropriate personal protective equipment and respiratory protection being used?
The area where hot work is being conducted must remain attended for at least 30 minutes after completion of the work. Monitoring Frequency: Continuous Every 30 min. Other
Monitor’s Name: _________________________________
Hot Work Air Monitoring Parameters Time of Reading
% Oxygen>19.5% % LEL <10% Other
Air Monitor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time
Attachment L
Confined Space Entry Checklist
06/02/04 Attach L CSE Checklist.doc
Anniston PCB Site Anniston, Alabama
Confined Space Entry Checklist
Permit #:
Project:
ALL COPIES OF PERMIT MUST REMAIN AT
JOB SITE UNTIL THE ENTRY IS COMPLETE
Location and Description of Confined Space:
Checklist YES NO N/A COMMENT Are all lines to and from confined space blanked, capped, or isolated? Electrical service locked out (entrant with key)? Are mechanical devices / systems restrained and locked out? Is explosion-proof electrical equipment in use? Are ladders secured at top? Is the ground fault circuit interrupter checked and functioning? Are all ignition sources identified and isolated? Are respirators and air supply equipment in proper condition? Are safety harnesses and lifelines in proper condition? Is required PPE being used? Is monitoring equipment calibrated and functioning properly? Is atmospheric testing completed? Is a trained attendant on standby? Is emergency equipment ready for use? Are rescue provisions in place? Are warning signs posted? Is ventilation equipment functioning properly? Is the retrieval system functioning properly? Communication device for entrance and attendants? Is the area secured to eliminate unauthorized entry? Are entry personnel trained for confined space entry? Is the confined space entry permit completed and posted? Are the permanent ladder rungs in safe condition? Monitoring Frequency: Continuous 5 min. 10 min. 30 min.
Monitor’s Name: _________________________________
Confined Space Air Monitoring Parameters Time of Reading % Oxygen>19.5% % LEL <10% CO <20 ppm Other
Pre-Entry
Entry Supervisor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time Air Monitor ________________________________________________________________ Print Name _______________________________________________________________________________________________________ Signature Date Time
Attachment M
Confined Space Entry Permit
06/03/04 Attach M CSE Permit.doc
Anniston PCB Site Anniston, Alabama
Confined Space Entry Permit
Project Name: Date / Time:
Project Number: Location:
Prepared By: Health and Safety Coordinator:
Location and Description of Confined Space:
Rescue Contact and Phone Number:
Entry Objectives:
Equipment / Materials Required for Entry:
Time of Entry: Expiration of Entry:
Required Respirator for Entry:
Required Protective Clothing for Entry:
Monitoring Interval: Continuous 5 minutes 10 minutes 15 minutes 30 minutes
Air Monitoring Requirements
Calibrated Monitor For Monitoring Equipment
Date / Time By
% O2
% of LEL
H2S
CO
Other:
Other:
Entrants and Attendants
Number of Entrants: Number of Attendants:
Names of Entrants Names of Attendants
Entry Supervisor Authorizing Confined Space Entry Permit
Print: Date: Time:
Signature: Date: Time:
Entry Supervisor Canceling Confined Space Entry Permit
Print: Date: Time:
Signature: Date: Time:
Appendix 1
NTC Removal Action Supplemental Sampling Health
and Safety Plan
NTC Removal Action Supplemental Sampling
Health & Safety Plan
Anniston PCB Site, Anniston Alabama
September 2003 Revision 0
September 2003
Report on
NTC REMOVAL ACTION SUPPLEMENTAL SAMPLING HEALTH AND SAFETY PLAN
FOR THE
ANNISTON PCB SITE
(Docket No. CV-02-PT-0749-E)
Prepared for:
United States Environmental Protection Agency Waste Management Division
Atlanta Federal Center 61 Forsyth Street, S.W.
Atlanta, GA 30303
Prepared by:
Solutia Inc. 702 Clydesdale Avenue
Anniston, Alabama 36201
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1
TITLES AND APPROVALS
The undersigned certify that this Solutia Inc. (Solutia) NTC Removal Action Supplemental
Sampling Health and Safety Plan is approved and will be utilized for the Anniston PCB Site
(Site) activities in Anniston, Alabama defined by the United States Environmental Protection
Agency (EPA) Non-Time Critical Removal Agreement.
____________________________________ ______________________________ Craig Branchfield Date Solutia Project Manager
____________________________________ ______________________________ John Loper Date
CERCLA Manager
____________________________________ ______________________________ Gayle Macolly Date NTC Removal Action Manager
____________________________________ ______________________________ Charles Haury, CIH Date Health and Safety Officer
____________________________________ ______________________________ Gina Monroy Date Health and Safety Coordinator
____________________________________ ______________________________ Michael Price Date Site Safety Officer
September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page i of iii
TABLE OF CONTENTS
Titles and Approvals Table of Contents SECTION PAGE
1.0 INTRODUCTION ....................................................................................................1
2.0 SITE DESCRIPTION...............................................................................................2 2.1 General Information........................................................................................2 2.2 Site and Work Description ..............................................................................2
3.0 HEALTH AND SAFETY ORGANIZATION AND COORDINATION....................3 3.1 Solutia Project Manager..................................................................................3 3.2 CERCLA Manager.........................................................................................3 3.3 NTC Removal Action Manager .......................................................................3 3.4 Sampling Health and Safety Officer.................................................................3 3.5 Sampling Health and Safety Coordinator ..........................................................4 3.6 Sampling Site Safety Officer...........................................................................4 3.7 Project Personnel............................................................................................5
4.0 HAZARD EVALUATION........................................................................................6 4.1 General..........................................................................................................6 4.2 Field Activities...............................................................................................6 4.3 Activity-Specific Hazards ...............................................................................6 4.4 Chemical Hazards...........................................................................................7
4.4.1 Exposure Via Ingestion.......................................................................7 4.4.2 Exposure Via Dermal Contact.............................................................8 4.4.3 Exposure Via Inhalation ......................................................................8
4.5 Physical Hazards ............................................................................................8 4.5.1 Operation of Drilling Equipment .........................................................9 4.5.2 Confined Space Entry.........................................................................9 4.5.3 Heat Stress .........................................................................................9
4.5.3.1 Operational Guidance.................................................................................. 10 4.5.4 Cold Stress....................................................................................... 12 4.5.5 Noise ............................................................................................... 13 4.5.6 Manual Lifting ................................................................................. 13 4.5.7 Slip, Trip and Fall Hazards................................................................ 14 4.5.8 Electrical Equipment......................................................................... 14
4.6 Biological Hazard......................................................................................... 14 4.6.1 Insect Bites and Stings ...................................................................... 14 4.6.2 Tick Bites ........................................................................................ 14 4.6.3 Snake Bites ...................................................................................... 16 4.6.4 Dogs................................................................................................ 16
September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page ii of iii
TABLE OF CONTENTS (Continued)
4.6.5 Plants............................................................................................... 16
5.0 TRAINING REQUIREMENTS..............................................................................18 5.1 Basic Training.............................................................................................. 18 5.2 Pre-Work Briefing ........................................................................................ 18 5.3 Daily Briefings ............................................................................................. 18 5.4 First Aid and CPR........................................................................................ 19 5.5 Documentation ............................................................................................. 19 5.6 Hazard Communication ................................................................................ 19
6.0 SITE CONTROL....................................................................................................20 6.1 General........................................................................................................ 20 6.2 Daily Start Up.............................................................................................. 20
7.0 AIR MONITORING...............................................................................................21
8.0 WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS .................................................................................................22 8.1 General........................................................................................................ 22 8.2 Respiratory Protection Program..................................................................... 22 8.3 PPE Protection Summary .............................................................................. 23
8.3.1 Level D Equipment........................................................................... 23 8.3.2 Level C Equipment ........................................................................... 23
9.0 DECONTAMINATION PROCEDURES................................................................25 9.1 General........................................................................................................ 25 9.2 Contamination Prevention ............................................................................. 25 9.3 Decontamination Equipment ......................................................................... 26 9.4 Personnel Decontamination........................................................................... 26 9.5 Equipment Decontamination ......................................................................... 27
9.5.1 Respiratory Protective Equipment...................................................... 27 9.5.2 Drilling and Sampling Equipment ...................................................... 27
10.0 EMERGENCY RESPONSE PROCEDURES.........................................................29 10.1 General........................................................................................................ 29 10.2 Emergency Notifications ............................................................................... 29 10.3 Evacuation Routes ........................................................................................ 29 10.4 Emergency Equipment and First Aid Requirements ........................................ 29
10.4.1 Emergency Equipment and First Aid Supplies .................................... 29 10.4.2 Fire Extinguishers............................................................................. 29
September 2003 Anniston PCB Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page iii of iii
TABLE OF CONTENTS (Continued)
11.0 MEDICAL SURVEILLANCE PROGRAM............................................................30
12.0 RECORD KEEPING AND REPORTS...................................................................31 12.1 General Record Keeping ............................................................................... 31 12.2 Training Records .......................................................................................... 31 12.3 Daily Field Information................................................................................. 31 12.4 Accident Reporting ....................................................................................... 32 12.5 Project Completion Activities........................................................................ 32
13.0 REFERENCES.......................................................................................................33
In Order Following
Page 33
TABLES TABLE 1 Regulatory and Recommended Exposure Limits for Selected Chemicals for
the Individual Properties TABLE 2 Heat Stress: Basis for Work Schedule TABLE 3 NTC Removal Action Sampling PPE Requirements TABLE 4 Emergency Phone Numbers Anniston PCB Site
FIGURES
FIGURE 1 General Work Area FIGURE 2 Outline for Level C Decontamination FIGURE 3 Outline for Level D Decontamination FIGURE 4 Site and Hospital Location
APPENDICES APPENDIX A Health and Safety Plan Addendum/Revision Form APPENDIX B Toxicological Data for Selected Chemicals APPENDIX C OSHA 101 Form for Occupational Injuries and Illnesses APPENDIX D Health and Safety Plan Signature Form APPENDIX E “Tailgate” Safety Meeting Form
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 33
1.0 INTRODUCTION
This Supplemental Sampling Health and Safety Plan (Sampling HSP) has been prepared in
accordance with the requirements of the Non-Time Critical Removal Agreement (NTC Removal
Agreement) included as Appendix G to the Partial Consent Decree (Docket No. CV-02-PT-0749-
E) between the United States Environmental Protection Agency (EPA) and Solutia Inc. (Solutia).
The Partial Consent Decree was entered by the United States District Court for the Northern
District of Alabama on August 4, 2003 (EPA, 2002). The NTC Removal Agreement provides for
the performance of a removal action in connection with residential properties that may contain
soil with polychlorinated biphenyls (PCBs) located in and around Anniston, Calhoun County,
Alabama. These residential properties are included within the Anniston PCB Site (Site) as
defined by the Partial Consent Decree.
This Sampling HSP has been developed for the protection of the project team and other persons
that may be exposed to hazards associated with sampling activities at the Site. The purpose of
this Sampling HSP is to assign responsibilities, establish personnel protection standards, specify
and establish safe operating procedures and practices, and provide for contingencies that may
arise while conducting sampling activities at the Site.
This Sampling HSP has been prepared based upon the requirements pertaining to hazardous
waste activities outlined in the following regulations, guidelines, and manuals:
• Code of Federal Regulations (CFR), Title 29, part 1910 (29 CFR 1910);
• Guidelines prepared by National Institute for Occupational Health and Safety (NIOSH), Occupational Safety and Health Administration (OSHA), U.S. Coast Guard (USCG), and the U.S. Environmental Protection Agency (USEPA); and
• Manual entitled “Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (1985).”
This Sampling HSP is based on the information available concerning the possible chemical and
physical hazards found on the Site. As additional site-specific information becomes available,
this Sampling HSP may be modified accordingly. The form for completing the Sampling HSP
Addendum/Revision is presented in Appendix A.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 2 of 33
2.0 SITE DESCRIPTION
2.1 General Information
The removal action activities are being conducted in accordance with the NTC Removal
Agreement between the EPA and Solutia. EPA has designated Ms. Pam Scully, as EPA’s
Remedial Project Manager. Solutia has designated Mr. Craig Branchfield as its Project Manager.
Mr. Branchfield is located at Solutia’s Anniston facility at:
Solutia Inc.
702 Clydesdale Avenue
Anniston, Alabama 36201
(256) 236-8404
2.2 Site and Work Description
The Site consists of residential properties located in and around Anniston, Calhoun County,
Alabama. Work tasks may include the following:
• sampling surface soils in residential yards;
• sampling soils in residential yards at depth by hand and/or mechanical boring advancement methods; and
• sampling dust in residences.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 3 of 33
3.0 HEALTH AND SAFETY ORGANIZATION AND COORDINATION
The key personnel listed below will be responsible for the supervision and implementation of the
requirements outlined in the Sampling HSP for the Site.
• Solutia Project Manager: Craig Branchfield (Solutia Inc.)
• CERCLA Manager: John Loper (The Loper Group, Inc.)
• NTC Removal Action Manager: Gayle Macolly (Golder Associates, Inc.)
• Sampling Health and Safety Officer: Charles Haury (Golder Associates, Inc.)
• Sampling Health and Safety Coordinator: Gina Monroy (Golder Associates, Inc.)
• Site Safety Officer: Michael Price (Genesis Project, Inc.)
3.1 Solutia Project Manager
The Solutia Project Manager has overall responsibility for projects associated with the Solutia,
Anniston, Alabama facility. The Solutia Project Manager has final authority for decisions made
by the response team associated with the Anniston PCB Site removal actions.
3.2 CERCLA Manager
The Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
Manager has overall responsibility for the management and technical oversight of the Anniston
PCB Site CERCLA project. The CERCLA Manager offers technical and management support to
the Solutia Project Manager.
3.3 NTC Removal Action Manager
The NTC Removal Action Manager has overall responsibility for the management and technical
oversight of the Anniston PCB Site Removal Action project. The NTC Removal Action Manager
is a liaison between the Solutia Project Manager and/or CERCLA Manager and the Site Sampling
Manager. The NTC Removal Action Manager assesses final data and reports findings to the
CERCLA Manager and Solutia Project Manager.
3.4 Sampling Health and Safety Officer
The Health and Safety Officer (HSO) is the primary reviewer of the Sampling HSP and is
responsible for health and safety technical support.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 4 of 33
3.5 Sampling Health and Safety Coordinator
The Health and Safety Coordinator (HSC) is responsible for the implementation of the Sampling
HSP at the Site. The responsibilities of the HSC include:
• functioning as the communications liaison between project team and HSO and as such reports directly to the HSO and Site Sampling Manager;
• informing personnel of potential hazards associated with the Site;
• maintaining current documentation of the Site personnel’s health and safety training;
• working closely with the SSO regarding health and safety issues; and
• approving changes in the Sampling HSP.
3.6 Sampling Site Safety Officer
The Site Safety Officer (SSO) is the sampling contractor’s representative responsible for the on-
Site enforcement of the policies and provisions contained in the Sampling HSP. The
responsibilities of the SSO include:
• ensuring that each member of the investigative team is up to date on safety training (e.g., OSHA 40-hour Hazardous Waste Operations and Emergency Response (HAZWOPER), OSHA 8-hour refresher, cardiopulmonary resuscitation (CPR), and first aid, as necessary);
• meeting with the HSC to evaluate sampling operations and understand sampling strategies;
• assisting the HSC in enforcing the Sampling HSP;
• functioning as the communications liaison on safety issues between the project field team and the HSC and the Site Sampling Manager;
• ensuring that the necessary safety equipment is available and operational, including both personal protective equipment and monitoring equipment;
• calibrating monitoring equipment on a daily basis and recording results in field logs;
• ensuring that monitoring equipment is operating correctly, and providing maintenance when required;
• making recommendations to change protection levels of personal protective equipment (PPE);
• implementing proper decontamination and emergency procedures;
• defining work zones;
• conducting on-Site health and safety meetings before on-Site activities begin;
• ensuring that workers have read the Sampling HSP and signed the acknowledgement form;
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 5 of 33
• authorizing stop-work, which will be executed upon determination of an imminent safety hazard emergency situation or other potentially dangerous situations; and
• initiating and implementing changes to the Sampling HSP.
3.7 Project Personnel
Personnel of the sampling contractor involved in on-Site sampling will be responsible for:
• reading the Sampling HSP and signing the acknowledgement form;
• following the Sampling HSP requirements;
• following the recommendations of the SSO;
• reporting any health and safety issues or hazards they feel are not addressed in the Sampling HSP;
• taking precautions to prevent accident and injury to themselves and to other personnel;
• immediately notifying the SSO of any accidents or medical problems; and
• reporting any unsafe conditions.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 6 of 33
4.0 HAZARD EVALUATION
4.1 General
This section presents chemical and physical hazard information to be used for the development of
health and safety protocols for on-Site activities. The goals of the hazard evaluation are twofold:
1) to summarize available chemical information and the corresponding impacts on worker health
and safety; and 2) to adequately describe the physical hazards associated with the Site. This
information is important in the development of action levels to be used for the determination of
levels of respiratory and dermal protection. The judgment of the SSO will provide the basis for
upgrading or downgrading levels of protection. The main constituents of concern at the Site are
PCBs, which may be present in the soils at the Site.
4.2 Field Activities
Field activities that may be performed during the sampling event include:
• site reconnaissance;
• surface and subsurface soil sampling; and
• dust sampling.
Each of these activities involves different potential hazards and requires different levels of
protection.
4.3 Activity-Specific Hazards
The potential health and safety hazards associated with the types of activities to be performed at
the Site are described below:
• Site Reconnaissance
These are non-intrusive tasks and will typically be performed prior to sampling.
Therefore, the potential hazards to personnel performing these tasks are anticipated to be
low.
• Surface and Subsurface Soil Sampling
The potential hazards associated with this activity include inhalation or dermal contact
with potentially impacted soils and physical hazards, such as slips, falls, or sprains.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 7 of 33
When sampling is conducted using mechanical means such as a drilling rig, the following
steps are typically involved:
• positioning the rig over the sample location;
• retrieving subsurface soil boring; and
• sampling solids and abandoning the borehole.
Three types of potential hazards are associated with these steps. The primary hazard is
dermal contact with potentially impacted materials, water, and/or equipment. The second
hazard is contact with underground and overhead utilities. The third and less likely
hazard is potential exposure to dust during soil boring retrieval and sampling activities.
• Dust Sampling
This is a non-intrusive task and will typically be performed within a residence.
Therefore, the potential hazards to personnel performing these tasks are anticipated to be
low. However, the potential hazards associated with this activity include inhalation or
dermal contact with potentially impacted dust.
4.4 Chemical Hazards
There is a potential for the sampling workers to be exposed to chemical hazards. The primary
pathway for exposure to occur is dermal contact with chemicals of concern potentially associated
with the soil samples. Secondary pathways for exposure include inhalation of particulate
materials, and possible ingestion if personal hygiene is inadequate. Table 1 lists known exposure
limits for chemicals that may be encountered during sampling of residential properties. Appendix
B presents additional information on health effects from exposure to these chemicals.
4.4.1 Exposure Via Ingestion
Exposure via ingestion can be prevented through the use of the following guidelines:
• prohibiting eating, drinking, smoking, and the application of cosmetics in the work area; and
• requiring workers to wash hands and face prior to consuming food, beverages, or smoking.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 8 of 33
4.4.2 Exposure Via Dermal Contact
Exposure via dermal contact can be prevented through the use of PPE and caution taken in
handling liquids and solids in the work zone. The level of PPE required is described in Section
8.3. It is important that a common sense approach be taken in preventing dermal contact.
Precautions should be taken to prevent touching unprotected portions of the skin (particularly
eyes, nose or mouth) when handling liquids or solids in the work zone.
4.4.3 Exposure Via Inhalation
Practices to be employed to minimize potential airborne exposure when performing these
activities should include:
• standing upwind of the field activity;
• recognizing potential warning properties of chemicals and of dust that may be present during field activities (e.g., odor, irritation, nausea, etc.); and
• wearing appropriate PPE including respiratory protection if directed by the SSO.
The SSO will be responsible for assessing the sampling work areas for dust that could possibly
present exposure via inhalation. In the unlikely event that excessive dust is generated during
sampling, personnel will be required to wear NIOSH approved respiratory protection equipped
with P-100 Particulate filter cartridge. Dust control techniques, such as low volume water
spraying or fogging, may be used to minimize the potential for inhalation of particulates.
4.5 Physical Hazards
The following physical hazards must be recognized and controlled during field activities:
• operation of heavy equipment;
• heat stress;
• cold stress;
• noise;
• manual lifting;
• slip, trip and fall; and
• electrical equipment.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 9 of 33
4.5.1 Operation of Drilling Equipment
Precautions must be taken when working around drilling equipment. The moving of the
equipment from location to location within the Site is of particular concern. Drilling equipment
operators must obey Site-specific safety requirements, and traffic control must be strictly
followed.
Except where electrical distribution and transmission lines have been de-energized and visibly
grounded, drilling equipment will be operated near power lines in accordance with the guidelines
specified in 29 CFR 1926.
4.5.2 Confined Space Entry
Workplaces that are not intended for human occupancy are defined as confined spaces. Limited
openings hinder proper ventilation, escape, and rescue; therefore, creating a potentially life
threatening situation for a worker.
Confined space entry is not anticipated for Site operations. However, if confined space entry is
required, it will not be undertaken without prior approval from the Site Sampling Manager, HSC
and SSO. Any confined space entry will be governed by OSHA regulation, 29 CFR 1910.146.
4.5.3 Heat Stress
High ambient temperature can result in health effects ranging from transient heat fatigue, physical
discomfort, reduced efficiency, personal injury, increased accident probability, to serious illness
or death. Heat stress is of particular concern when chemical protective clothing1 is worn, since
these garments prevent evaporative body cooling. Wearing personal protective equipment puts a
worker at considerable risk of developing heat stress.
Heat stress is caused by a number of interacting factors, including environmental conditions,
clothing, workload, and the individual characteristics of the worker. Because heat stress is
probably one of the most common (and potentia lly serious) illnesses at sites, regular monitoring
and other preventive measures are vital.
1 Note: Chemical protective clothing is defined as, but not limited to: Clothing constructed of Tyvek, or
coated-Tyvek, PVC rain suits or coveralls, and CPF Series Coveralls.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 10 of 33
Heat stress manifests in progressive stages, increasing in severity. The initial stage is commonly
termed heat fatigue, which is usually transient, and subsides with rest and replenishment of fluids.
Heat fatigue is characterized by discomfort, and reduced mental awareness, with a greater effect
in unacclimated workers. Medical treatment is usually not needed.
Heat exhaustion can result from sustained exertion in heat, combined with failure to replace water
and salts lost in sweat. Symptoms include fatigue; nausea; headache; clammy, moist skin, which
may be flushed or pale; and skin eruptions (red face or rash). If any of these signs are observed,
the personnel should stop work immediately and seek medical attention. Replacement of water
and salts is required for recovery; victims may faint upon standing. Electrolyte replacement
fluids should be taken until urine volume increases.
Heat syncope results in fainting, and is caused by standing immobile in heat. It is caused by
pooling of venous blood in the dilated vessels of the skin and lower body. Recovery is complete
and rapid following rest in a recumbent position at a cool location.
The most serious heat illness is heat stroke. Heat stroke is a MEDICAL EMERGENCY,
treatment must be immediate, and professional medical attention must be obtained. Heat stroke is
caused by a combination of factors including heavy exertion in heat, inadequate replacement of
fluids, poor physical condition, and individual susceptibility. Failure of the sweat response
occurs, leading to a rapidly accelerated increase in core temperature. The victim usually has hot,
dry red skin, and if conscious, is confused; convulsions may be present. The victim must be
cooled immediately. Heat stroke is fatal if treatment is incomplete or delayed.
As with any illness, the best cure is prevention. Heat stress is most likely early in the summer,
prior to acclimatization. Full acclimatization takes from 5 to 7 consecutive days of controlled
exertion in heat.
4.5.3.1 Operational Guidance
A work/rest schedule should be developed prior to initiating field activities, whenever ambient
temperatures are greater than 70º F and chemical protective clothing is used; and when
temperatures are greater than 85º F without chemical protective garments. The schedule must be
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constantly assessed to ensure effectiveness, and may need to be modified during the workday.
Table 2 presents the heat stress-monitoring basis. Note that personnel performing physically
more demanding work may need a more restrictive schedule.
Increasing Work Rate
1. If a worker's heart rate does not increase, or increases only slightly (l0% or less for the heart rate) from the baseline readings after the first work cycle, the work period (according to the established work-rest regimen) can be increased by 20%.
2. The worker will be monitored closely after the next work cycle period and if there are still no significant increases in heart rate, the work period can be increased by an additional 10% and the rest period remains the same.
3. Increases in the work period can be made throughout the shift if there are no significant increases in the physiological monitoring indices.
4. Note that the increases to the work period are made based on the work-rest regimen established prior to initiation of work activities.
Decreasing Work Rate
1. Count the radial pulse as early as possible in the rest period.
2. If a worker's heart rate exceeds 110 beats per minute immediately after a work period, shorten the next work cycle by 30% and keep the rest period the same.
3. If the heart rate still exceeds the 110 beats per minute after the next work period, shorten the following work cycle by 30%.
4. Continue to shorten the employee's work cycle until the heartbeat is below 110 beats per minute.
Adequate liquids must be provided to replace lost body fluids. Personnel must replace water and
salt lost from sweating. Personnel must be encouraged to drink more than the amount required to
satisfy thirst. Thirst satisfaction is not an accurate indicator of adequate salt and fluid
replacement.
Replacement fluids can be a 0.1% salt-water solution, a commercial mix, such as Gatorade,
Poweraide, Quik Kick or equivalent, or a combination of these with fresh water. Personnel
should be encouraged to salt their foods more heavily. Salt pills are prohibited.
The replacement fluid temperature should be kept cool. Cooling devices such as vortex tubes or
cooling vests can be worn beneath protective garments. Breaks are to be taken in a cool, shaded
rest area (<80° F). Personnel shall remove chemical protective garments during rest periods.
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Personnel shall not be assigned other tasks during rest periods. Personnel shall be informed of
the importance of adequate rest and proper diet in the prevention of heat stress. Personnel shall
be informed of the harmful effects of excessive alcohol consumption in the prevention of heat
stress.
Individuals with pre-existing medical conditions or restrictions contraindicating exposure to
elevated environmental heat are precluded from assignments that involve exposure to high
temperatures. Healthy individuals will vary significantly in their tolerance to heat, and heat
tolerance can be affected by minor illnesses (cold, flu) and by prescription and over-the-counter
medications. The heart rate measure is only a part of the overall situation to be considered; other
objective, and subjective symptoms of heat stress, such as: extreme fatigue, nausea,
disorientation, light-headedness, and breathlessness must be fully considered when evaluating the
adequacy of control measures. The heart rate measure will provide guidance that can be
significantly different for each member of a field team based on their acclimatization, physical
fitness and heat tolerance. If it is critical that team members use the same work/break schedule,
the schedule that accommodates the least heat-tolerant team member will be observed.
Training
Those personnel (including workers, supervisors, and contractor personnel) potentially exposed to
heat stress conditions shall have been trained in the following:
1. Sources of heat stress, influence of protective clothing, and importance of acclimatization;
2. How the body handles heat;
3. Heat related illnesses;
4. Preventative/corrective measures; and
5. First aid procedures.
4.5.4 Cold Stress
Critical factors in preventing cold stress disorders are adequate clothing and staying dry. The SSO
and Sampling Team Manager will ensure the capability to quickly move individua ls who become
wet to a sheltered, warm area. The following specific steps will be taken [adapted from the
ACGIH TLV booklet (ACGIH 2002)].
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• If ambient temperatures are 40º F or below, site training will include prevention of cold injury, cold-injury symptoms, and cold-injury first aid.
• If ambient temperatures are 40º F or below, and there is a potential for workers to become significantly wet (splashed or soaked), the SSO will ensure that at least one of the following controls is in place:
° a sufficient supply of dry, warm clothing is immediately available;
° personnel wear clothing appropriate for water contact (e.g., immersion-survival suits, neoprene chest waders, wet suit,); or
° a heated break area is immediately available.
• A heated break area will be provided if ambient temperatures are below 32º F.
• At a minimum, breaks will be taken in a warm area every 120 minutes if ambient temperatures are below 32º F.
• Workers will be allowed to take unscheduled breaks, if needed, in a warm area.
• If the equivalent chill temperature (temperature combined with the effect of wind) is less than −29° F, outdoor work will be discontinued or effective engineering controls such as windscreens, temporary shelters, or portable heating units will be used.
4.5.5 Noise
Hearing protection may be required during drilling operations. Training on the proper use of
hearing protection will be conducted as a part of the health and safety briefing conducted by the
SSO prior to on-Site work.
4.5.6 Manual Lifting
Activities may require personnel to move large, heavy objects by hand. The human body is
subject to severe damage in the forms of back injury and hernia if caution is not observed when
handling, lifting, or moving these large, heavy objects.
General Rules
• Get a good footing.
• Place feet about one shoulder width apart.
• Bend at knees to grasp weight.
• Keep the back straight.
• Get a firm hold.
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4.5.7 Slip, Trip and Fall Hazards
Ground survey should be made at the site to identify any holes or possible trip hazards.
Walkways should be maintained clear of debris and in a dry condition. Tools and clothing should
be stored when not in use and should not be left on the ground.
4.5.8 Electrical Equipment
Extension cords used with portable electric tools and appliances shall be three-wire and grounded.
Plugs shall conform to the type and configuration required by the OSHA Construction Standards.
4.6 Biological Hazard
4.6.1 Insect Bites and Stings
Insects may be present at this site. Although they can be painful, they rarely cause death.
However, some people have a severe allergic reaction to an insect bite or sting that can result in a
life threatening condition. The following is a list of preventive measures:
• Apply insect repellent prior to fieldwork and or as often as needed throughout the work
shift.
• Wear proper protective clothing (work boots, sock and light colored pants).
• When walking in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.
• Field personnel who may have insect allergies should provide this information to the HSO prior to commencing work.
• Mark and avoid fire ant mounds.
4.6.2 Tick Bites
The Center for Disease Control (CDC) has noted the increase of Lyme Disease and Rocky
Mountain Spotted Fever (RMSF) resulting from bites from infected ticks that live in and near
wooded areas, tall grass, and brush. Ticks are small, ranging in size up to about one quarter inch.
They are sometimes difficult to see. The tick season extends from spring through summer. When
embedded in the skin, they may look like a freckle. Lyme disease has occurred in 43 states, with
the heaviest concentrations in the Northeast (Connecticut, Massachusetts, New Jersey, New York,
Pennsylvania), the upper Midwest (Minnesota and Wisconsin), and along the northern California
coast. It is caused by deer ticks and lone star ticks which have become infected with spirochetes.
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Deer ticks may range in size from one-eighth inch in size up to one-quarter inch in size and can
be black or brick red in color. Lone star ticks are larger and chestnut brown in color.
RMSF has occurred in 36 states, with the heaviest concentrations in Oklahoma, North Carolina,
South Carolina, and Virginia. It is caused by Rocky Mountain wood ticks, and dog ticks which
have become infected with rickettsia. Both types of ticks are black in color.
Standard field gear (work boots, socks and light-colored coveralls) provides good protection
against tick bites, particularly if the joints are taped. However, even when wearing field gear, the
following precautions should be taken when working in areas that might be infested with ticks:
• When in the field, check yourself often for ticks, particularly on your lower legs and
areas covered with hair. Look for "a freckle that moves".
• Spray outer clothing, particularly your pant legs and socks, BUT NOT YOUR SKIN, with an insect repellent.
• When walking in wooded areas, avoid contact with bushes, tall grass, or brush as much as possible.
• If you suspect that a tick is present, remove it with tweezers only, and not with matches or a lit cigarette. Grasp the tick with the tweezers and pull gently. If it resists, cover the tick with salad oil for about 15 minutes to asphyxiate it, then remove it with tweezers. Do not use nail polish or any other type of chemical. Be sure and remove all parts of the tick's body. Once removed, disinfect the area with alcohol, or a similar antiseptic.
• Look for signs of the onset of Lyme disease, such as a rash that looks like a bulls-eye or an expanding red circle surrounding a light area on the skin, frequently with a small welt in the center. This rash can appear from several days to several weeks after the tick bite.
• Also look for signs of the onset of RMSF, an inflammation or rash comprising many red spots under the skin, which appears 3 to 10 days after the tick bite. The rash frequently occurs on the ankles and wrists.
The first symptoms of either disease are flu-like chills, headache, dizziness, fatigue, stiff neck,
and bone pain. If immediately treated by a physician, most individuals recover fully in a short
period of time. If not treated, more serious symptoms can occur.
If you believe you have been bitten by a tick, or if any of the signs and symptoms noted above
appears, contact the SSO. The SSO has the authority to authorize a physician visit for an
examination and possible treatment.
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4.6.3 Snake Bites
There are poisonous snakes in Calhoun County, Alabama. If bitten by a snake, remain calm, keep
the affected area below the level of the heart and walk, do not run, to the nearest aid station for
assistance. The SSO will designate someone to immediately transport the victim to the closest
medical facility for treatment or send for appropriate medical assistance, whichever is faster. The
following precautions should be used when working in areas with snakes:
• Wear appropriate protective equipment (work boots, snake chaps).
• Be alert and aware of surroundings.
• Avoid walking in wooded areas and through bushes, tall grass or brush as much as possible.
4.6.4 Dogs
Sampling is to take place on residential property. In some instances residents may have dogs,
which may be unfriendly to samplers. The sampling team will not sample properties where dogs
are loose in the yard without the presence of the dog owner on-hand. In most cases, the samplers
should not proceed to conduct sampling unless the dog is restrained. Additionally, the sampling
team should be aware that wild or unleashed dogs might be present in the residential
neighborhoods. If such dogs are encountered, the sampling team should not approach or provoke
the animals. Mace may be used as a deterrent, if attacked.
4.6.5 Plants
The potential for contact with poisonous plants exists when performing fieldwork in Alabama.
Poison ivy, sumac, and oak may be present on site. Poison ivy can be found as vines on tree
trunks or as upright bushes. Poison ivy consists of three leaflets with notched edges. Two-
leaflets form a pair on opposite sides of the stalk, and the third leaflet stands by itself at the tip.
Poison ivy is red in the early spring and turns shiny green later in the spring. Poison sumac can
be present in the form of a flat-topped shrub or tree. It has fern-like leaves, which are velvety
dark green on top and pale underneath. The branches of immature trees have a velvety "down."
Poison sumac has white, "hairy" berry clusters. Contact with poison ivy, sumac or oak may lead
to a skin rash, characterized by reddened, itchy, blistering skin which needs first aid treatment.
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Poison ivy barrier cream and cleanser will be used at the discretion of the SSO. Site workers will
apply the barrier cream prior to working in areas where exposure to the poisonous plants exists.
Subsequently, the cleanser will be used at the end of the work shift to remove oils, which remain
on the skin from exposure to the plants.
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5.0 TRAINING REQUIREMENTS
5.1 Basic Training
Consistent with 29 CFR 1910.120, OSHA Hazardous Waste Operations, personnel performing
fieldwork associated with the NTC Removal Action activities must have received formal off-Site
hazardous waste training (with three days on-the-job training) prior to on-Site work. This
consists of 40 hours of initial training and 8 hours of annual refresher training for field staff.
Managers and supervisors must receive an additional 8 hours of specialized off-Site training
geared toward their supervisory responsibilities. Excluded from this responsibility are workers
who will not have the opportunity to contact Site hazards such as truck drivers. Personnel
responsible for field activities must be familiar with and have access to this Sampling HSP.
5.2 Pre-Work Briefing
A health and safety meeting will be conducted by the SSO prior to commencing field activities.
The meeting will address the following topics;
• contents of the approved Sampling HSP;
• discussion of work tasks and potential hazards;
• identification of evacuation routes and routes to the hospital;
• locations of site emergency equipment and supplies;
• discussion of personal protective equipment (PPE) requirements and action levels;
• review of the OSHA 101 form (Appendix C) to be filled out in the event of an injury or illness caused by work at the site; and
• reminder that unsafe work practices or conditions should be reported to the SSO.
The health and safety site-specific training described above will also be conducted for new
personnel assigned to the Site. Following the briefing, personnel will be required to signify that
they have read and understood the contents of this Sampling HSP by signing the Health and
Safety Plan Review Signature Form (Appendix D).
5.3 Daily Briefings
At the beginning of each day, the SSO (or designee) will review on-Site work activities and
outline Site conditions with respect to modifications of work plans and health and safety plans.
Personnel will be briefed and updated on any changes in safety procedures and sign a “Tailgate”
Safety Meeting Form found in Appendix E.
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5.4 First Aid and CPR
The SSO will identify those individuals having First Aid and CPR training. At least one
individual in the sampling team will have current First Aid and CPR training. Training will be
consistent with the requirements of the American Red Cross.
5.5 Documentation
Documentation of training requirements is the responsibility of each employer. Written
documentation verifying compliance with 29 CFR 1910.120 must be submitted to the SSO.
Documentation of workers current training credentials (40-Hour Training, 8-Hour Refreshers, 8-
hour Supervisory Training, and medical respirator clearance) will be kept on-Site and submitted
to the Solutia representative on request. No one will be allowed to work on-Site without the
appropriate training and medical clearances.
5.6 Hazard Communication
In accordance with the OSHA Hazard Communication Standard (29 CFR 1910.1200 and 29 CFR
1926.59), copies of material safety data sheets (MSDS) for chemical materials brought on-Site
will be available in the field office or from the SSO. The MSDS training will be conducted by
the SSO in accordance with 29 CFR 1910.1200 and 29 CFR 1926.59 and the sampling
contractor’s hazard communication program. The training will be conducted in conjunction with
the pre-work briefing. Training will include, but may not be limited to all hazards or potential
hazards associated with any chemical materials on-Site. Appendix B contains the MSDSs for on-
Site Hazardous Materials.
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6.0 SITE CONTROL
6.1 General
Site control measures will be implemented by members of the field sampling team to control
access and minimize the potential for the spread of impacted materials to non-impacted areas.
The work area will be divided into three different zones as determined by the HSC:
• The Exclusion (or Work) Zone: Consists of those areas, which are considered, affected or potentially affected by chemical constituents. Only the necessary number of workers with proper protective equipment will be allowed in this area.
• The Contamination Reduction Zone (CRZ): In this area personal decontamination procedures will be implemented.
• The Support (or Clean) Zone: This area will be used primarily for field command operations.
6.2 Daily Start Up
The following procedures will be followed prior to daily Site start up:
• The SSO (or designee) will review on-Site work activities with respect to modifications of the work plans and health and safety plans, and brief and update personnel;
• Safety and monitoring equipment will be checked for proper function; and
• The SSO will visually assess dust conditions in the work area.
Start-up activities shall be documented in the Site logbook.
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7.0 AIR MONITORING
Air monitoring for volatile organic compounds (VOCs) is not anticipated during field sampling
activities because the chemicals listed in Table 1 are not volatile under normal outdoor
conditions. Air monitoring for particulates is not anticipated during field sampling activities
because the field activities do not create dusty conditions. However, the SSO will be responsible
for visually assessing for dust and will be responsible for recommendations to upgrade PPE
requirements.
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8.0 WORK TASKS AND PERSONAL PROTECTIVE EQUIPMENT REQUIREMENTS
8.1 General
The level of protection required for each area of the sampling involving field activities will be
based on the recognized hazards of the chemicals of potential concern, most likely routes of
exposure (e.g., dermal, ingestion and possibly inhalation) and on observations for dust. The
purpose of PPE is to ensure that the individual is protected from the hazards encountered in the
course of the project. The elements involved in PPE include protective clothing, eye and face
protection, and respiratory protection that may be used by individuals involved in sampling field
activities.
8.2 Respiratory Protection Program
No respirators are currently anticipated to be required for this project. Personnel required to wear
a respirator must comply with the requirements outlined in this program. Personnel who will be
involved with sampling activities must first be cleared by the HSO. These personnel must also
have been trained in the selection, operation, and maintenance of air purifying respirators in
accordance with OSHA Standard 29 CFR 1910.134. Respiratory protection will be upgraded to
Level C at the judgment of the HSC and/or SSO. The NIOSH Respirator Decision Logic will be
used to determine appropriate respiratory protection.
Prior to using a respirator, personnel must be properly fit tested. The fit test will be conducted by
the HSC if proof of a previous fit test has not been documented within the last year. The fit test
will be performed using the appropriate challenge aerosol for the type of respirator selected (e.g.,
irritant smoke, isoamyl acetate (e.g., banana oil), or saccharin aerosol). Records of fit tests will
be maintained in project files and with the HSC.
Special lens holders, glasses, or both may be required for full-face respirators. Persons requiring
corrective lenses and a full-face respirator shall have a specific respirator fitted with the
corrective lens prescription prior to the initiation of field activities. Contact lenses shall not be
worn while performing fieldwork. Beards, long sideburns, and mustaches that interfere with the
proper fit of a respirator are prohibited.
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A respirator will be assigned to each person who may have to use one during field activities. It is
the individual’s responsibility to properly operate and maintain the respirator. Personnel will be
responsible for cleaning, disinfecting, inspecting, and storing their respirator before and after each
use. Personnel will report any problems with respirators to the HSC.
8.3 PPE Protection Summary
A description of minimum requirements for Level C and Level D protection is summarized
below. When using Level C criteria, the buddy system must be used; at least two persons must
conduct the work. Planned field activities will be initiated at Level D protection. The HSC will
decide if an upgrade to Level C is necessary due to airborne dust. If PPE above Level C is
deemed necessary, then field activities will cease pending assessment by the SSO, HSC and HSO.
8.3.1 Level D Equipment
• boots with steel toes and shank;
• Neoprene or Nitrile chemical resistant outer gloves (optional);
• disposable latex inner gloves;
• boot covers (disposable - at the determination of the SSO);
• safety glasses (face shield and/or goggles when needed for chemical splash protection such as in the plant area);
• hard hat (optional - at the determination of the SSO, when required by Solutia or when over-head hazards exist);
• thermal/weather protection (coat, overalls, sweater, hat, rain gear, cool vest, heat stress monitors, optional - at the determination of the SSO or by personal choice);
• ear protection to be worn when working around drill rigs and other loud equipment; and
• long sleeve shirt (optional – at the determination of the SSO or when required by Solutia) and long pants.
8.3.2 Level C Equipment
• minimum half-face air purifying respirator (NIOSH approved) equipped with a compatible cartridge combination of HEPA filter for dust as determined by the SSO;
• Tyvek coveralls;
• safety boots with steel toe & shank;
• Nitrile or Neoprene chemical resistant outer gloves (optional);
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• disposable latex inner gloves;
• boot covers (optiona l - at the determination of the SSO);
• hard hat (optional - at the determination of the SSO or when required by Solutia);
• face shield and/or goggles when needed for chemical splash protection (optional - at the determination of the SSO);
• thermal/weather protection (optional - at the determination of the SSO);
• ear protection to be worn when working around drill rigs and other loud equipment; and
• long sleeve shirt and long pants.
A summary of PPE requirements for the project specific tasks is provided in Table 3.
Modifications in the personal protective equipment requirements outlined in this document may
be necessary as new conditions and/or tasks warrant. Addenda and revisions to this HSP will be
made only by the SSO, the HSC or the HSO, and shall be documented using the
Addendum/Revision Record found in Appendix A.
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9.0 DECONTAMINATION PROCEDURES
9.1 General
Decontamination procedures reduce the potential for transport of chemicals of concern outside of
the work area. Decontamination procedures also protect workers from potential exposure that
may occur during removal of personal protective equipment. It is important that decontamination
is handled in an organized, step-wise manner. If decontamination is conducted improperly,
inhalation or dermal contact with constituents of concern may occur.
Decontamination consists of thoroughly decontaminating reusable PPE and general equipment,
and washing face and hands before leaving the Site. Disposal of wastes generated from
decontamination procedures will be the responsibility of Solutia.
9.2 Contamination Prevention
The prevention of contamination is the first step towards providing a clean and safe work place.
Contamination prevention should minimize worker exposure and help ensure valid sample results
by precluding cross-contamination. Procedures for contamination avoidance include:
Personnel
• Do not walk through areas of obvious or known contamination; walking through puddles or mud, and kneeling on the ground shall be avoided.
• Make sure personal protective equipment has no cuts or tears prior to wearing.
• Fasten closures on suits.
• Particular care should be taken to protect any skin injuries.
• Stay upwind of dust.
Equipment and Samples
• Monitoring equipment shall not be placed on potentially contaminated surfaces.
• Limit the amount of contamination that comes in contact with heavy equipment and vehicles.
• If contaminated tools are to be placed on non-contaminated equipment/vehicles for transport to the decontamination area, use plastic wrap or sheeting to keep the equipment clean.
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9.3 Decontamination Equipment
The following materials will be available for decontamination as needed:
• galvanized wash tub;
• tap water;
• plastic sheeting;
• alkaline soap solution (Alconox, or other heavy-duty detergent);
• long handle scrub brushes;
• disposable plastic to cover the station area;
• disinfectant wipes to clean inside of respirator; and
• distilled water in a squeeze bottle for rinsing.
9.4 Personnel Decontamination
Diagrams of general work areas and outlines for Level C and Level D decontamination are
presented on Figures 1 through 3. The following minimum procedures for Level C
decontamination will be followed prior to leaving the work area:
Exiting Exclusion Zone
Equipment drop 1. Upon exiting the exclusion or work zone, workers will deposit their equipment on a plastic drop cloth in the designated area. Soil and sediment sampling equipment will be wiped clean with a damp cloth, as required. During hot weather, a cool-down station may be set up in this area.
Contamination Reduction Zone
Outer Garment, Boots, and Gloves Wash and Rinse
2. Workers will scrub outer boots, outer gloves, and coveralls with a long handled brush and soap and water. Workers will then rinse with plenty of water.
Outer Boot and Glove Removal 3. Once completed with rinsing, workers will remove outer gloves and outer boots and discard them.
Air Purifying Respirator 4. Workers will receive a new respirator cartridge (or mask), outer gloves, and outer boots for return to the work/exclusion zone.
Outer Garment Removal 5. If workers are not returning to the work/exclusion zone, they will remove their coveralls and deposit them in separate containers.
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Respirator Removal 6. Once coveralls are deposited, respirators may be removed. Respirators will be washed in soap solution and rinsed in water. The inside of the respirators will be cleaned with an alcohol wipe. Inner gloves will be removed and discarded.
Support Zone
Field Wash 7. Thoroughly wash hands and face. Shower as soon as possible.
During this procedure, methods for properly disposing of contaminated personal protective
clothing or equipment must be followed to reduce the possibility of contacting potentially
contaminated media. Decontaminated PPE and trash will be placed in DOT-approved drums or
roll-offs for disposal.
9.5 Equipment Decontamination
9.5.1 Respiratory Protective Equipment
When respiratory protective equipment is required, there is a high potential for these units to
become contaminated. At the end of each workday, respirators will be thoroughly
decontaminated. During decontamination, this equipment will be properly disassembled
(according to manufacturer specifications), washed with soap and water, rinsed in water, cleaned
with an alcohol wipe and allowed to dry before reassembly. Disassembly and reassembly shall be
performed by personnel trained in this task.
9.5.2 Drilling and Sampling Equipment
At the discretion of the SSO, decontamination procedures may be used on a daily basis to address
potential contamination or equipment that will move between clean and contaminated areas
without leaving the work area. Brushes and other similar tools will be used to manually remove
gross materials from tires, tracks, and other portions of the equipment.
A steam cleaner may be used to decontaminate equipment at the completion of the project and for
any equipment leaving the Site from a contaminated work area. Personnel should exercise caution
when using a steam cleaner. The high-pressure steam can cause severe burns. Protective gloves,
safety glasses with side shields or face shield, hard hats, steel-toed boots, and Tyvek suit or rain
gear will be worn when using the steam cleaners. Small equipment will be decontaminated as per
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procedures referenced in Section 9.5.1. Water from the decontamination process will be captured
for appropriate disposal.
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10.0 EMERGENCY RESPONSE PROCEDURES
10.1 General
The following procedures should be implemented in the event of an emergency. The SSO will
act as the field sampling Emergency Coordinator. The SSO is responsible for investigating
emergency situations arising from the sampling work and has the authority to modify or stop
sampling activities in order to reduce potential hazards until the hazards have been identified and
corrective actions taken. If the emergency situation requires fire, police, or medical personnel,
the telephone numbers listed in Table 4 should be used to contact the appropriate emergency
personnel.
10.2 Emergency Notifications
Telephone numbers for fire department, ambulance, police, and medical facilities are listed in
Table 4. In the event of an emergency, the EPA RPM, Solutia Project Manager, and Sampling
Team Leader should also be notified as soon as possible.
10.3 Evacuation Routes
In the event of an emergency, evacuation routes must be followed by Site personnel. Figure 4
identifies the location of the hospital. During an evacuation, the HSC will be responsible for
conducting a head count to ensure that sampling personnel have safely exited the Site.
10.4 Emergency Equipment and First Aid Requirements
10.4.1 Emergency Equipment and First Aid Supplies
A fully equipped first aid kit will be maintained at the Site. The kit will contain a minimum of
two pairs of latex gloves to be worn by first aid providers, and a CPR barrier mask to be used
during CPR. Portable eye wash containers, filled with sterile rinse solutions, will be located in
each field-sampling vehicle.
10.4.2 Fire Extinguishers
A portable fire extinguisher with combination Class ABC rating will be maintained on each drill
rig.
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11.0 MEDICAL SURVEILLANCE PROGRAM
A medical surveillance program will be in compliance with 29 CFR 1910.120 and implemented
for field personnel. This medical program assures that personnel are physically able to perform
the assigned work. The program also monitors the personnel’s health and provides medical care
for occupational injury or illness. Contractors and subcontractors shall certify that their own
personnel are medically fit for the intended work.
Specialized blood chemistry programs are not required unless exposure to a particular chemical
of concern is suspected. Should this situation occur, the site HSO should be consulted. The HSO
and HSC will make a determination of any requirement for special monitoring.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 31 of 33
12.0 RECORD KEEPING AND REPORTS
12.1 General Record Keeping
The SSO will maintain logs covering the implementation of the sampling activities. Copies of
logs and reports will be kept by the SSO. Medical clearance records of field personnel will be
maintained by the SSO. Certification of employee training and field experience will also be
maintained by the SSO. Copies of respirator fit test records will be kept at the Site and/or in
personnel medical files.
Sampling personnel will be required to read and understand this Sampling HSP. Signed
statements will be maintained at the Site.
12.2 Training Records
Training records will be prepared by the SSO for personnel involved in field activities. At a
minimum, these records will include:
• employee’s name;
• verification of pre-work physical examination (e.g., medical clearance);
• Sampling HSP training verification (Pre-Work Briefing);
• “tailgate” safety meeting roster with topics;
• MSDS training verification; and
• respirator fit test records.
12.3 Daily Field Information
The daily field information will be noted on the Field Sampling Logs and/or the Daily Summary
Logs by the SSO or their designee. The information will contain:
• date;
• area (site-specific) checked;
• personnel in specific area;
• equipment being utilized by personnel;
• PPE being used by site personnel in sampling work areas; and
• PPE maintenance records.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 32 of 33
The HSC and/or SSO will note items that pose potential health and safety risks or inconsistencies
with the Sampling HSP, and the actions taken to address the situation.
A separate sign-in log will be maintained for visitors to the Site and will include name, date, time
in-out, company name, and signature. Visitors to Site areas other than the support zone require
training and medical monitoring consistent with 29 CFR 1910.120.
12.4 Accident Reporting
Field personnel shall report any job-related accident or injury immedia tely to the SSO or
Sampling Team Leader. Upon receiving appropriate medical attention, an accident report will be
filled out by the SSO and injured employee using an OSHA Form 101 (Appendix C).
Photographs shall be taken of the accident location if it involved an identifiable physical hazard
(e.g., fall hazard, unguarded machinery, etc.). One copy of this report will go to the field
log/files, and one copy will go to the HSO with distribution to the Solutia Project Manager. This
report will be filed and forwarded within 24 hours.
12.5 Project Completion Activities
At the completion of sampling, the SSO will provide documentation of the project Sampling HSP
implementation, including the following:
1. The SSO will provide decontamination records for equipment to be removed from the Site at the completion of this phase of activities. These records will be maintained in the permanent project file.
2. The medical records for any personnel involved in a work-related accident or illness will be updated by the SSO. These updates will be sent for inclusion in the personnel medical files. Exposure and medical monitoring records will be maintained as per 29 CFR 1910.120.
3. An OSHA 300 log will be kept for recording lost workdays, restricted duties, and OSHA-recordable injuries or fatalities. The log will be prepared by the SSO and kept on Site until completion of the sampling. At that time, it will be forwarded to the sampling contractor’s office to be retained for five years.
4. If no work-related accidents or illnesses occurred during sampling, a statement to this effect will be placed in the file.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 33 of 33
13.0 REFERENCES Code of Federal Regulations, Title 29, Part 1910, Subsections 120, 134 and 1200. Agency for Toxic Substances and Disease Registry (ATSDR). Toxicological profile for (certain
chemicals). American Conference of Government Industrial Hygienists (ACGIH), “Threshold Limit Values
for Chemical Substances and Physical Agents and Biological Exposure Indices”, 2002 and TLV Documentation Guide.
National Institute of Occupational Health and Safety (NIOSH), “Pocket Guide to Chemical
Hazards”, Latest Edition. NIOSH/OSHA/USCG/EPA “Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities,” 1985. NIOSH, “NIOSH Respirator Decision Logic,” May 1987. United States Environmental Protection Agency, 2002. Partial Consent Decree, United States of
America v. Pharmacia Corporation (p/k/a/Monsanto Company) and Solutia Inc. Civil Action No. CV-02-PT-0749-E. October 2002. Effective date August 4, 2003.
TABLES
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1
TABLE 1
REGULATORY AND RECOMMENDED EXPOSURE LIMITS
FOR SELECTED CHEMICALS FOR THE INDIVIDUAL PROPERTIES
Compound OSHA
PEL
ACGIH TLV
STEL
Chlorinated Biphenyls (42% chlorine)
1 mg/m3 (skin) 1 mg/m3 (skin) --
Chlorinated Biphenyls (54% chlorine)
0.5 mg/m3 (skin) 0.5 mg/m3 (skin) --
Lead 0.05 mg/m3 0.05 mg/m3 -- ACGIH TLV - American Conference of Governmental Industrial Hygienists’ Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices 2002 PEL - Permissible Exposure Limit STEL - Short Term Exposure Limit -- - No value established.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1
TABLE 2
HEAT STRESS: BASIS FOR WORK SCHEDULE
FREQUENCY OF MEASUREMENT
AMBIENT TEMPERATURE (°F)
NORMAL WORK
CLOTHING1
IMPERMEABLE WORK
CLOTHING
70° – 80°
N/A
90 MIN
80° -85°
120 MIN
60 MIN
85° -90°
90 MIN
30 MIN
> 90°
60 MIN
15 MIN
1Normal work clothing is cotton coveralls, or other cotton clothing with long sleeves and pants.
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1
TABLE 3
NTC REMOVAL ACTION SAMPLING PPE REQUIREMENTS
Task Respiratory Clothing Gloves Boots Other *
Soil Sampling NA Level D L, N (optional)
B SG (HH/HP with
drill rig) Decontamination NA Level D L, N
(optional) B SG
Borehole Backfilling
NA Level D L, N (optional)
B SG
NOTES:
B = Steel-toe work boots C = Cotton overalls F = Steel-toe fireman’s boots HH = Hard hat HP = Hearing Protection L = Latex N = Nitrile NA = Not Anticipated S = Surgical SG = Safety glasses T = Tyvek W = Work Gloves * = Depending on Area
September 2003 Anniston PCB Site Revision 0 Supplemental Sampling Health and Safety Plan Solutia Inc. Page 1 of 1
TABLE 4
EMERGENCY PHONE NUMBERS – ANNISTON PCB SITE
Emergency Services Telephone Numbers
Police 911
Fire 911
Hospital 256-236-2210
Poison Control 911
Solutia Inc. personnel to be notified in case of emergency:
Craig Branchfield 256-231-8404
EPA personnel to be notified in case of emergency:
Pam Scully 404-562-4300
FIGURES
CHECKEDDRAWN REVIEWED DATE SCALE FILE NO. JOB NO. DWG NO./REV NO. FIGURE
TITLECLIENT/PROJECT
Atlanta, Georgia
SDP September 2003 N/A 943-3680.CER HASP.cdr
Anniston PCB SiteNTC Removal Action Supplemental Sampling
Health and Safety Plan
1
General Work Area
Hot Line
ContaminationControl Line
WIND DIRECTION
Command Post
SUPPORT ZONE
CONTAMINATIONREDUCTION ZONE
EXCLUSION ZONE
CONTAMINATIONAREA
AccesControlPoints
CONTAMINATIONREDUCTIONCORRIDOR
The size of each work zone will depend onsite specific conditions; e.g., extent ofcontamination, drilling requirements, etc.
CHECKEDDRAWN REVIEWED DATE SCALE FILE NO. JOB NO. DWG NO./REV NO. FIGURE
TITLECLIENT/PROJECT
Atlanta, Georgia
SDP N/A 943-3680048 HASP.cdr 2
Outline for Level C Decontamination
SegregatedEquipment Drop
Outer Garment,Boots, and GlovesWash and Rinse
Boots, Gloves,and Outer GarmentRemoval
RespiratoryProtectionRemoval
Field Wash
Outer Boot andGlove Removal
CartridgeChange
Hot Line
ContaminationControl Line
EXCLUSION ZONE
CONTAMINATIONREDUCTION ZONE
SUPPORT ZONE
MinimumDecontamination Layout
LEVEL CPROTECTION
The decontamination corridoris approximately 5 ft by 10 ft.
September 2003
Anniston PCB SiteNTC Removal Action Supplemental Sampling
Health and Safety Plan
CHECKEDDRAWN REVIEWED DATE SCALE FILE NO. JOB NO. DWG NO./REV NO. FIGURE
TITLECLIENT/PROJECT
Atlanta, Georgia
SDP N/A 943-3680.CER HASP.cdrSeptember 2003
Anniston PCB SiteNTC Removal Action Supplemental Sampling
Health and Safety Plan
3
Outline for Level D Decontamination
SegregatedEquipment Drop
Outer Garment,Boots, and GlovesWash and Rinse
Boots, Gloves,and Outer GarmentRemoval
Field Wash
Hot Line
ContaminationControl Line
EXCLUSION ZONE
CONTAMINATIONREDUCTION ZONE
SUPPORT ZONE
MinimumDecontamination Layout
LEVEL DPROTECTION
The decontamination corridoris approximately 5 ft by 10 ft.
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APPENDIX A
Health and Safety Plan Addendum/Revision Form
HEALTH AND SAFETY PLAN ADDENDUM/REVISION Date:____________________________________________________________________
Site Designation/Location:____________________________________________________
Subject:__________________________________________________________________
Addendum: _______________________________________________________________
Affected Health and Safety Plan Section: _________________________________________
Revision: ________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
________________________________________________________________________
Requested by: Signature: ____________________________________________________
Printed Name:_________________________________________________
Title:________________________________________________________
Effective Date: ____________________________________________________________
Approved By: Signature: ____________________________________________________
Printed Name:_________________________________________________
Title:________________________________________________________
CONCURRENCE (by Project Manager and Health and Safety Officer or Health and Safety
Coordinator):
Effective Date: ____________________________________________________________
Approved By: Signature: ____________________________________________________
Printed Name:_________________________________________________
Title:________________________________________________________
NOTES/REMARKS:
________________________________________________________________________
________________________________________________________________________
APPENDIX B
Toxicological Data for Selected Chemicals
APPENDIX C
OSHA 101 Form for Occupational Injuries and Illnesses
APPENDIX D
Health and Safety Plan Signature Form
HEALTH AND SAFETY PLAN SIGNATURE FORM Each field team member shall sign this section after site-specific training is completed and before
being permitted to work on site.
I have read, understand and agree to comply with the provisions of the above-referenced
Supplemental Sampling Health and Safety Plan for work activities at this Site.
Date:____________________________________________________________________
Trainer’s Printed Name:______________________________________________________
Trainer’s Signature:_________________________________________________________
Trainer’s Title: ____________________________________________________________
Name Printed Signature Date
APPENDIX E
"Tailgate" Safety Meeting Form
“TAILGATE” SAFETY MEETING FORM The following personnel were present at the “tailgate” (daily pre-job) safety briefing
conducted at (time):___________________________________________________
on (date): __________________________________________________________
at (location): ________________________________________________________
by (printed name):__________________________________________________
(signature):_____________________________________________________
(title): ________________________________________________________
and have read the above plan, are familiar with its provisions and the following discussed topics:
________________________________________________________________________
________________________________________________________________________
Name Printed Signature Date