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OSHA Compliance Issues:
Correcting Common Health
And Safety Program Deficiencies
At Remediation Sites
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Richard Fairfax, Column Editor,
Reported by MaryAnn Garrahan, Earl M. Cook, and Nina J. Baird
Introduction
In late 1992 the occupational Safety and Health Administration (OSHA) joined the
Environmental Protection Agency (EPA) in an interagency agreement, and participated with
EPA in forming the EPA/Labor Superfund Health and Safety Task Force.(1) Other organizations participating
in the task force include the National Institute for Occupational Safety and Health, the
Laborer's Safety and Health Fund of North America, the International Association of
Firefighters, the U.S. Army Corps of Engineers, the International Brotherhood of
Teamsters, the National Institute of Environmental Health Sciences, the Department of
Energy, and the International Union of Operating Engineers. The task force mission is to
evaluate and improve worker safety and health at hazardous waste facilities and to improve
communication among task force members. During a subsequent 34-month period, the task
force reviewed the safety and health plans of 18 Superfund remediation contractors and
conducted 10 comprehensive site audits. Based on the results of those audits and plan
reviews, the task force has prepared training and guidance material for both compliance
officials and hazardous waste contractors.
Conducting comprehensive site safety and health audits is one of the major initiatives
undertaken by the task force. These audits are performed by teams of OSHA professionals
who spend 3 to 4 days assessing a site's implementation of OSHA's Hazardous Waste
Operations and Emergency Response standard (HAZWOPER, 29 CFR 1910.120) and evaluating the
overall effectiveness of the site's safety and health program.(2) Audit team members examine each
contractor's written site safety and health plan and other program documentation;
interview employees, safety and health personnel, site management, and union
representatives; conduct walk-through inspections; collect wipe samples or air samples as
necessary; and talk with local emergency response agencies. Information collected during
these audits is used both to improve worker safety and health at the audited site and to
educate the task force about field conditions and field needs.
To date, task force audits have focused on sites using thermal technology, such as
incineration and low temperature thermal desorption. The pattern of deficiencies emerging
from these audits, however, resembles the citation pattern for hazardous waste sites in
general. Regardless of the treatment method being used, deficiencies most commonly
observed at hazardous waste sites involve the site's written safety and health plan,
engineering controls, work practices, and personal protective equipment (PPE). Additional
problem areas noted during task force audits include site monitoring practices and
emergency response programs. Wherever hazardous waste site operations are currently being
conducted, many of the following deficiencies and recommended corrective actions are
likely to be applicable.
Deficiency 1: Ineffective Management of Safety and Health Functions
Ineffective safety and health management increases the likelihood of deficiencies in
site safety and health practices at hazardous waste sites. At four of the ten sites
audited by OSHA audit teams, deficiencies in site safety and health practices were
directly attributable to a lack of knowledge and experience among on-site safety and
health personnel. At four additional sites, deficiencies existed because the site
management structure or contract language prevented on-site personnel from exercising
their judgment in matters of safety and health. At some of these sites, on-site personnel
were required to obtain approval for their day-to-day safety and health recommendations
from off-site decision makers who were not readily available. Where this occurred, the
time required to implement changes in safety and health procedures put employees at
increased risk. For example, OSHA audit teams found several instances in which on-site
safety and health personnel had recommended PPE downgrades based on site exposure
monitoring data. The downgrades were delayed, however, because contract language was
inflexible with regard to PPE requirements or because off-site safety and health decision
makers had not responded to the recommendations. The delays placed workers in
unnecessarily high levels of PPE with increased risk of heat stress, restricted vision,
impaired communication, and increased fatigue.
OSHA audit teams found another management problem common to multicontractor sites. Most
multicontractor sites had not integrated key aspects of their site safety and health
programs, nor had one individual been given overall safety and health enforcement
authority. At one site, for example, employees of two different contractors worked side by
side in different levels of PPE. At other sites, emergency communication procedures had
not been integrated among site contractors. Contractors working in close proximity on a
site used different alarm horn signals and different emergency radio frequencies. Because
they had not conducted an evacuation drill, the contractors were unaware that these
differences might cause confusion in an emergency. These types of inconsistencies in site
safety and health practices undermine the message that safety and health requirements
exist to protect the employee, and they may allow hazards to remain unabated, placing site
employees at increased risk.
Corrective Action: Plan for Effective Management of the Safety and Health Program
Implementing safety and health programs at hazardous waste sites can be costly. To
ensure that dollars are spent wisely, contractors should appoint well-qualified safety and
health personnel. When negotiating contracts with an oversight agency or contractor, it is
important to seek contract language that gives the safety and health program manager
authority to exercise judgment and to make appropriate changes to safety and health
procedures. The authority of the safety and health manager to enforce the safety and
health requirements should be documented in the safety and health plan. Similarly, clear
lines of authority between the prime contractor and subcontractors need to be established
and documented. One site safety and health supervisor should have site-wide authority to
enforce safety and health requirements.
Deficiency 2: Out-of-Date or Incomplete Written Site Safety and Health Plan
The site safety and health plan is another major source of citations at hazardous waste
sites. OSHA's audit teams reviewed many plans that had been developed during the early
phases of a project, before worker exposures were characterized. Because the plans had not
been updated, the listed exposure levels, descriptions of work practices, monitoring
protocols, and site PPE requirements did not reflect current on-site conditions.
Descriptions of site organizational structure and lists of emergency contacts also tended
to be inaccurate. Plans that did contain adequate site exposure data often lacked other
site-specific detail. General statements about good safety and health practice rather than
detailed descriptions of actual site safety and health practices were common in sections
addressing decontamination, spill containment, confined space, medical surveillance, and
heat stress.
Every written plan that the audit teams reviewed contained inadequate job hazard
analysis. Site tasks were grouped into overly broad categories, such as "incineration
activities." Hazards associated with site tasks were described in equally broad
terms, such as "exposure to contaminated materials" or "slips, trips, and
falls." None of the written plans provided hazard analyses for site maintenance
tasks, which can be some of the most hazardous jobs in industrial operations. The hazard
analyses were thus of little value to safety and health professionals needing to prescribe
appropriate control measures, or to workers needing training on the specific hazards
associated with their jobs.
Some plan elements were often missing altogether. In many plans reviewed by the audit
team, for example, the requirement for a materials handling and spill containment program,
as listed in HAZWOPER paragraph (b) (4) (ii)(J), had been overlooked.(2)
Corrective Action: Make the Written Safety and Health Plan a Site-Specific, Working
Document
Throughout the course of a remediation project, the contractor's written safety and
health plan must provide an accurate, detailed description of the contractor's safety and
health practices at that site. Boilerplate documents should be avoided. Instead, accurate
job hazard analyses need to be developed for each site task or operation, including
maintenance tasks, and the remainder of the plan's requirements must be based on those
analyses. Before completing the initial draft of a plan, the plan's contents should be
compared with the list of required elements in HAZWOPER paragraph (b)(4)(ii)(A-J).(2) To make the plan a working
document, both the job hazard analyses and the safety and health requirements that are
based on the hazard analyses should be updated regularly. An up-to-date written plan
documents current safety and health practices and can be used by contractors as a
checklist to ensure that effective site safety and health practices are being maintained.
Deficiency 3: Inadequate Monitoring of the Nature and Level of Hazardous Exposures
on Site
Measuring and documenting the level of employee exposures is a key element in any
safety and health program and a consistent area of deficiencies at hazardous waste sites.
Real-time monitoring for organic vapor and dusts is often the only method used to
initially characterize worker exposures and to monitor exposure levels throughout project
work, regardless of the potential contaminants identified in a site's Remedial
Investigation/Feasibility Study. OSHA audit teams visited several sites where worker
exposure to metals, pesticides, and semi-volatile organics had not been adequately
evaluated despite the fact that these contaminants were recognized hazards. Personal
sampling methods that could accurately characterize on-site exposure levels had not been
used, nor had dermal exposure to site contaminants been evaluated with wipe sampling, even
when the potential for dermal exposure was high.
Corrective Action: Implement an Effective Monitoring Program to Evaluate Site Hazards
OSHA's HAZWOPER requirements are primarily intended to control worker exposure to
hazardous substances. This can be accomplished only if site safety and health programs are
based on accurate characterization of potential worker exposures. Quantitative evaluation
of worker exposure levels provides the documentation necessary to support a site's initial
choice of hazard controls, while ongoing monitoring provides the basis for retaining or
modifying those controls. Often, monitoring results can be used to support a reduction in
controls, such as a PPE downgrade. Appropriate sampling methods must be used, however, and
a lack of exposure data cannot be used to justify a lack of controls.
Deficiency 4: Inappropriate Selection of PPE
Site PPE requirements are often developed when the site safety and health plan is
initially drafted. As a result, they are typically based on inadequate exposure
information, but are seldom modified, even when personal sampling data supporting
modifications become available. OSHA audit teams found many instances in which site plans
or contract specifications required inappropriate PPE. At one site where soil contaminated
with volatile organics was being remediated, for example, full-face air-purifying
respirators and Saranex-coated tyvek were required despite the absence of measurable
levels of airborne exposure and the absence of splash hazards. Workers using this
excessive PPE were placed at unnecessarily high risk of heat stress and could not see,
communicate, or move with ease. Such inappropriate PPE selection places a contractor in
noncompliance with HAZWOPER paragraph (g)(3) and OSHA's revised PPE standard, 29 CFR
1910.132(d), both of which require selection of PPE based on hazard evaluation.(2)
Corrective Action: Use Site Monitoring Data and Other Hazard Information to Document
the Basis for PPE Selection
Exposure monitoring results should be used to continually refine and improve job hazard
analyses and the corresponding PPE requirements. Although PPE may initially be selected
based on the results of real-time air sampling, PPE selection must be reviewed after
remediation work has begun and employee exposures have been characterized more fully with
personal air sampling and direct observation of potential exposures under actual working
conditions. Job hazard analyses that establish site PPE requirements based on accurate
site exposure data and an evaluation of other potential site hazards can be used to meet
the PPE hazard assessment requirements of 29 CFR 1910.132(d).(2)
Deficiency 5: Lack of a Program to Evaluate the Effectiveness of Safety and
Health Procedures and to Correct Deficiencies
Although most hazardous waste sites conduct site inspections as required under
HAZWOPER, inspection record keeping tends to be limited. In fact, none of the sites
visited by OSHA audit teams had a record keeping system that allowed personnel to track
the correction of deficiencies. When site personnel maintained safety and health log
books, they typically noted deficiencies but not the correction of those deficiencies. In
some cases, OSHA audit teams could not verify deficiency corrections at all, even after
interviewing site personnel.
OSHA audit teams also found that most sites did not evaluate the effectiveness of site
safety and health practices and procedures to confirm that they were controlling hazards.
Sampling at site zone boundaries and on decontaminated equipment and clothing was rarely
conducted, even though this type of sampling can provide objective evidence of the
effectiveness of site controls.
Corrective Action: Establish an Ongoing Program to Evaluate Site Safety and Health Procedures
Documentation is essential to demonstrate compliance with HAZWOPER's site inspection
and program evaluation requirements. After the site safety and health plan has been
implemented, the effectiveness of the control measures selected must be evaluated. Wipe
sampling can be used to assess decontamination methods and housekeeping procedures, for
example, while air and/or wipe sampling can be used to reevaluate and relocate site zone
boundaries. A written record of site inspections, noted deficiencies, and corrective
actions will bring a contractor into compliance with this HAZWOPER requirement.
Deficiency 6: Emergency Response Planning
Emergency response planning is a major area of deficiency at hazardous
waste sites. At sites visited by the audit teams, written emergency response plans seldom
included site-specific emergency scenarios and responses, and employees lacked site-specific
emergency response training. Employees interviewed by the audit team were uncertain of
their responsibilities during specific types of emergencies, such as confined space
rescue, spill containment, and fire suppression. Employee alarm systems were seldom tested
for audibility under normal operating conditions, and many employees had not participated
in evacuation drills. Emergency response plans at multiple-contractor sites were rarely
integrated.
OSHA's audit teams also found that many sites failed to communicate adequately with
local emergency responders. As a result, local fire fighters and medical personnel often
lacked information about these sites' emergency response requirements. At a rural site
storing 30,000 gallons of propane, for example, the emergency contact list contained
incorrect telephone numbers for the emergency dispatch service and fire fighting crew.
Moreover, local fire fighters had not been contacted about the site's fire hazards and
emergency response needs.
Corrective Action: Develop Site-Specific Emergency Response Plans and
Implement All Plan Requirement
Emergency response scenarios need to be developed for all potential site emergencies,
and employees must receive training in their roles for each scenario. An employee's role
in suppressing an incipient-stage fire, for example, is likely to differ from his or her
role in a confined space rescue or spill response. Employees must know where site
emergency response equipment is located and how to use this equipment. For example,
training in the location and use of fire extinguishers or spill absorbent is necessary if
employees are required to use them. Evacuation drills involving all site contractors and
all intended evacuation routes and rally points need to be conducted. The employee alarm
system must be tested during normal work operations. The accuracy of the site's emergency
response phone list should be verified and each response agency must be contacted to
confirm that the agency understands site hazards and emergency response needs.
Summary
Like all industry programs, site safety and health programs benefit from effective
planning, full implementation, and careful, ongoing management. Correcting common
deficiencies is important not only to protect the health and safety of hazardous waste
site workers, but also to maximize the benefit and cost effectiveness of site health and
safety programs. Programs that effectively prevent injury and illness save dollars. They
also avoid regulatory citations. Simple steps that can be taken to optimize the
functioning of a site safety and health program include:
- appointing well-qualified safety and health personnel who have the authority to make
site safety and health decisions;
- tailoring and updating the site safety and health plan to reflect on-site conditions and
work practices throughout the life of a project;
- quantifying worker exposure levels using appropriate sampling methods;
- selecting PPE based on accurate, site-specific job hazard analyses;
- evaluating safety and health procedures on an ongoing basis and documenting deficiencies
and corrective actions; and
- planning and practicing emergency response procedures thoroughly, so that on-site
personnel and local responders know how to respond to emergencies.
References
1. U.S. Environmental Protection Agency/U.S. Department of Labor,
Occupational Safety & Health Admin.: Interagency Agreement/Amendment DWl693592301-4.
USEPA, Washington, DC, (1995).
2. U.S. Department of Labor, Occupational Safety and Health
Administration: Title 29, Code of Federal Regulations, Part 1910. U.S. Government Printing
Office, Washington, DC (1995).
Disclaimer
The opinions, findings, and conclusions presented by the authors are not necessarily
those of the Occupational Safety and Health Administration. Any mention of materials or
products does not imply an endorsement by OSHA.
EDITORIAL NOTE:
MaryAnn Garrahan is an industrial hygienist with the Office of Technical Programs and Coordination
Activities. At the time of this publication she was with the Office of Health Compliance. She can be contacted at N-3655
200 Constitution Avenue, NW, Washington, D.C. 20210; telephone: (202) 693-2144. Earl Cook, now retired, was an industrial
hygienist with OSHA's Health Response Team. Located at USDOL OSHA, 8660 South Sandy Parkway, Sandy, Utah 84070-6424; telephone:
(801) 233-4900. Nina Baird is a senior scientist with ATL International. She can be contacted at ATL International, Germantown,
Maryland; telephone: (301) 972-4430. Currently, questions regarding hazardous material compliance issues should be directed to
Sven Rundman in the Office of Health Compliance at N-3467 200 Constitution Avenue, NW, Washington, D.C. 20210; telephone: (202)
693-2585 or Glenn Lamson, OSHA Health Response Team, USDOL OSHA 8660 South Sandy Parkway, Sandy, Utah 84070-6424; telephone:
(801) 233-4914.
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