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August 25, 1997
II. OVERVIEW OF SITE TECHNOLOGIES AND ASSOCIATED OCCUPATIONAL HAZARDS
III. DESCRIPTION OF AUDITED SUPERFUND SITES
IV. AUDIT RESULTS
The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency's (EPA's) Office of Emergency and Remedial Response (OERR) participate jointly, through an interagency agreement, in activities that will ensure effective occupational safety and health oversight of Superfund remediation operations. A joint EPA-Labor Superfund Safety and Health Task Force coordinates these efforts. As part of this initiative, OSHA conducts in-depth safety and health evaluations of selected Superfund sites using various remediation technologies, including incineration, in-situ vitrification, soil washing and lead leaching, and low-temperature enhanced volatilization. These evaluations or audits are not enforcement actions. Rather, they are intended to assist the site contractors and Federal and State oversight personnel to improve their understanding and implementation of OSHA requirements and recommendations for site health and safety. Whenever an audit is conducted, occupational safety and health oversight personnel from the Federal and/or State office are invited to participate. This report summarizes the findings of audits and site safety and health plan (SSAHP) reviews performed for eleven Superfund sites between 1993 and 1996. An earlier report published in September, 1993, summarized site audits and SSAHP reviews that were conducted in 1992 and 1993.
Although a major objective of these evaluations is to assess compliance with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120), they also seek to evaluate the overall adequacy of each facility's safety and health program, as implemented by the contractors operating at each site, and to identify any factors that contribute to reduced program effectiveness. Emphasis falls on evaluating each employer's safety and health standard operating procedures (SOPs) and the adequacy of task- and operation-specific hazard analyses and emergency response programs. In addition, the evaluations extend to such areas as heat stress mitigation strategies, confined-space programs, and process safety management approaches used during remediation operations.
OSHA conducted site inspections and SSAHP reviews for eight of the eleven sites discussed in this summary report. These sites are listed in Table 1. Inspections of these sites were conducted by teams of four to six OSHA personnel. The audit teams generally spent three or four days at the site interviewing employees, safety and health personnel, union representatives, and site management personnel to evaluate the effectiveness of safety and health program implementation; conducting walk-through inspections to observe and document site conditions, operations, and safety and health program deficiencies; collecting wipe samples of work surfaces and in some cases, wipe samples of employees' skin; and reviewing each site's written safety and health plan, including the emergency response plan, operation-specific hazard analyses, and other relevant written safety and health programs and records.
The other three sites discussed in this report did not undergo site audits. OSHA did, however, thoroughly review their written SSAHPs and related documents. These sites are listed in Table 2.
Sections II through V of this report provide information on the operations and safety and health programs in place at each of the eleven sites and summarize the findings of the corresponding site inspections and SSAHP reviews. Section II presents an overview of technologies employed at these sites and associated occupational hazards. Section III provides a general description of the remediation operations at the Superfund sites, as well as brief descriptions of the eleven sites. Section IV presents the findings from each of the inspections, and Section V is an overall summary of these findings.
II. OVERVIEW OF SITE TECHNOLOGIES AND ASSOCIATED OCCUPATIONAL HAZARDS
This section summarizes the remediation technologies used across the eleven sites included in this review. These technologies ranged from thermal treatment methods such as incineration, thermal desorption, and enhanced volatilization, to more diverse methods such as in-situ vitrification, bioremediation and soil washing. A brief discussion of each treatment technology and the associated safety and health hazards follows. One of the sites did not treat the excavated sediment on-site, but instead shipped it off-site for treatment. For this site, a discussion of the unique sediment excavation method (dredging) used on the project and the associated health and safety issues is included in this report.
Four of the sites used thermal destruction facilities (TDFs) to incinerate hazardous waste. Incineration involves the use of controlled flame combustion to thermally destroy hazardous wastes. The technique is suitable for destroying most organic materials (volatile and nonvolatile), and pesticides and cyanides found in sludge, soils, and liquids having a high organic content. It is one of the most frequently selected technologies for treating hazardous contaminants at Superfund sites. An onsite incineration system contains several subsystems, including:
Other occupational hazards commonly found at Superfund incinerator sites include those associated with thermal stress, the use of heavy construction equipment, work in confined spaces, excavation and trenching operations, storage and handling of flammable materials such as motor fuels, walking and working surfaces, noise, hot and cold environments, and marine operations.
Low-Temperature Enhanced Volatilization
One site used low-temperature enhanced volatilization (LTEV) to decontaminate soil. An LTEV facility is similar to an incinerator except that the primary kiln volatilizes, rather than thermally destroys the contaminants. Soil is heated in the kiln to approximately 600 degrees F to volatilize contaminants. Emissions are forced through a baghouse to remove dust, and into a secondary combustion chamber where the contaminant vapors are thermally destroyed. Soils treated with LTEV emerge from the unit as "clean" soil rather than ash and salt, the end products of standard incineration.
This system presents many of the same health and safety hazards as incineration. Additional hazards associated with operation and maintenance of a LTEV system include increased noise exposure and potential exposure to oxides of nitrogen, carbon monoxide, and diesel exhaust in the feed preparation building. Maintenance on the system presents potential confined space hazards, mechanical hazards associated with moving equipment, and hazards associated with hot work.
Typically, this process is fueled by a large (i.e., 30,000 gallons) propane tank. This large volume of flammable gas presents a range of health and safety hazards associated with material handling and transfer operations, maintenance on lines, and storage.
Soil Washing and Lead Leaching
One site used a soil washing and lead-leaching technique designed to generate no waste streams. During this process, soil is excavated using heavy equipment; moved onto a screen conveyor, where it is screened by hand to remove solid waste objects (e.g., spent ammunition rounds); and then hauled to another location, where it undergoes the main part of the soil-washing process. The soil washing process involved:
Other occupational hazards at such an operation include the possibility of catching clothing or body parts in the conveyor belt system, mechanical hazards presented by the rotary washer and the failure to use proper lockout/tagout procedures, confined space entry hazards associated with cleaning and maintenance of storage tanks and process vessels, and electrical hazards.
Soil Vapor Extraction
One site used a process called soil vapor extraction to remove volatile organic compounds (VOCs) from the soil. Vapor extraction wells or perforated piping are installed in the soil; applying a vacuum then induces the movement of soil gases into the piping system. In their most basic form, these systems include:
In Situ Vitrification
One site used in situ vitrification (ISV) to treat contaminated soil. In an ISV system, a square array of electrodes are set into the soil and an electrical current is run between the electrodes, using a conductive mixture as a starter path. The flow of the current melts the soil and destroys organic components by pyrolysis. Nonvolatile components ultimately are encapsulated in a vitrified block.
An ISV treatment system consists of the following systems:
Exposure to hazardous materials can occur during installation of the electrodes, sampling and monitoring activities, entry into the off-gas hood, hood/stack decontamination, and in-process HEPA filter changeout. The expected route of exposure is dermal. Inhalation is not an expected route of exposure except under certain circumstances (see the discussion of confined spaces below).
Energized systems such as ISV also have potential electrical hazards. Employees should take extra precautions such as using electrically approved gloves and boots and removing metal objects such as glasses and jewelry when working around this system. In addition, hazardous ground potentials or "step voltages" may occur in the event of a high-voltage fault to ground. ISV is also a high-temperature process with numerous opportunities for employees to suffer accidental burns. Of special concern is entry into the off-gas hood after a melt has started. A vitrified block poses a burn hazard for several days after the completion of a melt.
Entry into the off-gas hood may also pose a confined space entry hazard. Volatile organic substances may accumulate in the atmosphere of the enclosed hood; once a melt has started, volatilized substances may collect inside the hood, creating a toxic or oxygen-deficient atmosphere.
ISV-related hazards may require the use of PPE as a preventive measure. In any environment where PPE is used, or work is performed outdoors, physical hazards such as heat and cold stress are also present.
Low-Temperature Thermal Desorption
One site used a low-temperature thermal desorption process to decontaminate excavated soil. Thermal desorption is a physical separation process that uses direct or indirect heat exchange to vaporize volatile and semivolatile organics, and higher boiling point compounds such as PCBs from soil, sludge, and various filter cakes. In the thermal desorption process the soil is dried or blended to adjust the moisture content as needed, and then heated to between 200 degrees and 1000 degrees F, depending on the type of thermal desorption system selected and the nature of the contaminants. Thermal desorption is not incineration, since the destruction of organic contaminants is not the desired result. The higher temperatures of some systems will, however, result in localized oxidation and/or pyrolysis. Following desorption, the organic vapors in the desorber off-gas are either oxidized in a secondary combustion chamber or condensed for reuse or destruction. The air pollution equipment needed to treat the exhaust gases varies depending on the technology and the nature of the contaminated media. Dust and particulates can be controlled with cyclones, baghouses, or venturi scrubbers; small amounts of acid vapor might require scrubbing; and residual organics can be condensed and/or captured in activated carbon adsorption units.
Thermal desorption units pose several health and safety hazards to the personnel required to assemble, maintain, and operate the equipment. Among them are chemical exposures from contaminated soils and process off-gases; heat stress from wearing PPE in process areas; thermal burns from contact with material and equipment; noise exposure; and electrical, pinch and crush, confined space, and fall hazards.
The fuel systems in several types of thermal desorption units can pose additional health and safety hazards to workers. Propane or other highly flammable or explosive fuels require special handling procedures and work practices for tasks performed in the vicinity of the fuel tanks or feedlines.
One site was preparing soil for treatment by bioremediation. After excavation, the soil is run through a shredder to reduce the particle size. The shredded soil is then treated using bioremediation.
Bioremediation and shredding units pose several health and safety hazards to the personnel required to assemble, maintain, and operate the equipment, including chemical exposures; exposure to the biological agent used; heat stress; noise exposure; electrical, pinch and crush, and fall hazards. The potential hazards associated with exposure vary with the biological agent used in the remediation system and the method of application. The primary potential routes of exposure are dermal and inhalation.
Dredging and Diving Operations
Activities on one of the audited sites included dredging sediment from the bottom of a river and using commercial divers to assist in the dredging process. Dredging operations use heavy equipment that must be secured to the shore when in the water. Workers face hazards such as potential contact with the contaminated sediments, mechanical hazards, fall hazards, and noise hazards. In addition, dredging in concert with the diving operations exposes divers not only to the inherent hazards of diving operations but also to possible injury resulting from contact with the dredging equipment. In this case, the contractor was conducting what it called "diver-assisted dredging," which involved the use of divers to manually direct the suction equipment to focus on specific areas of the bottom. This technique was being phased out at the site in favor of more traditional operations as the dredging moved further into the main navigation channel of the river.
Diving operations themselves present a unique set of hazards which are only compounded by the presence of hazardous materials in either the water or the sediment at the bottom of the water body. As a result, PPE serves several purposes. Exposure to hazardous contaminants can occur during the underwater portion of the diving operation, so specialized PPE such as dry suits, full-face positive pressure face masks, and outer gloves are necessary. Precautions against chemical exposure also need to be taken during the decontamination of the divers, which should take place as soon as possible after they leave the water.
Overhead obstructions caused by heavy equipment or boats may also be present in shallow water, and controlling boat traffic is essential. Other potential safety problems associated with diving operations are more generic in nature but no less important. For example, divers are exposed to significant physical stresses when working underwater, and thus must be continually monitored. Standard procedures call for divers to be working in pairs, with a backup diver ready to go and a dive master present. Divers' safety depends on the proper function of diving equipment, so diligent precautions against equipment malfunction are warranted. Such safety equipment as fail-safe regulators and underwater alarms should be standard. Other common types of safety equipment include chase boats, and down and up lines.
III. DESCRIPTION OF AUDITED SUPERFUND SITES
When EPA is unable to identify the responsible party for a Superfund site, or cannot reach an agreement with the responsible party, EPA performs the necessary remedial design and remedial action (RD/RA) activities. In such cases, EPA chooses between two contracting mechanisms to conduct the RD/RA: EPA may provide direct oversight of the RD/RA contractor under the Alternative Remedial Contracting Strategy; or EPA may request that a RD/RA be administered and implemented by the U.S. Army Corps of Engineers (USACE) or Bureau of Reclamation (BUREC) under an Interagency Agreement with EPA. In some instances, a state agency will assume responsibility for RD/RA and use its own contracting mechanisms.
Under any of these circumstances, the agency that issues the competitively bid contract provides oversight of the prime contractor selected to perform cleanup activities. The prime contractor is responsible for implementing cleanup procedures in accordance with the terms of the contract and for developing and implementing a safety and health program for the site. The prime contractor may procure the services of a number of subcontractors that specialize in various aspects of the cleanup activity such as operation of an incinerator or dredging.
Table 1 identifies the locations of the sites inspected, the prime contractor, major subcontractors responsible for remediation activities, and the state or Federal government agency responsible for remediation oversight. Table 2 provides similar information for those sites where OSHA only performed a SSAHP review. A brief description of activities performed at each of the sites listed in Tables 1 and 2 follows.
Table 1. Description of Superfund Sites Inspected by OSHA
Table 2. Description of Superfund Site SSAHPs Reviewed by OSHA
Remediation activities at American Thermostat included the excavation and thermal treatment of over 13,000 cubic yards of soil and sediments contaminated primarily with perchloroethylene, trichloroethylene, and solvents. The soil was excavated and treated using a thermal treatment unit called the low-temperature enhanced volatilization facility (LTEVF). The performance test for the site's thermal unit had just been completed at the time of the inspection, so there was limited activity.
Arlington Blending and Packaging (Arlington)
Arlington is the 2.5-acre site of a company that formulated technical grade chemicals, primarily pesticides. The site contained concrete pads from previously demolished buildings, non-native gravel, and a concrete block/sheet metal building. Site investigations identified chlordane, endrin, heptachlor, heptachlor epoxide, pentachlorophenol, and arsenic at concentrations above background levels in site soils and groundwater. Remediation activities included the excavation of soil and concrete slabs, demolition of the remaining building, pretreatment and stockpiling of soil, low-temperature thermal desorption of soil contaminants, handling of treated soil, site stabilization (if necessary), and wastewater treatment.
Baird & McGuire (Baird)
Baird is the 20-acre site of a former chemical mixing and batching company. Poor waste disposal practices resulted in the contamination of groundwater, soil, the municipal water supply, and a brook adjacent to the site. Over one hundred contaminants, including chlorinated and nonchlorinated volatile organics, heavy metals, pesticides, herbicides, and dioxins, had been identified in site soil and groundwater. Remediation activities included soil excavation and incineration, and groundwater treatment (the audit focused on the soil excavation and incineration portions of the project). Specific activities included site preparation, construction of a facility to house incinerator operations, incinerator installation, excavation and incineration of 155,000 cubic yards of soil, backfilling, and land restoration. The incinerator at this site is a portable unit that can be disassembled at the conclusion of site operations and reassembled at another site.
Brio Refining Site (Brio)
The Brio refining site is approximately 58 acres in size and is the location of a former chemical production, recovery, refinery, and regeneration facility. The site includes closed impoundments into which hazardous substances were disposed in bulk, storage tanks, and approximately 1,750 drums of hazardous substances. Remediation activities included the excavation and incineration of contaminated soil, installation of protective liners around selected pits, and the installation of a groundwater extraction system adjacent to a gully.
The Manistique Harbor site is a dredging project located on the Manistique River north of Manistique Harbor on Michigan's upper peninsula. A local paper manufacturing company used the river as a source of cooling water and as a discharge point for wastewater and other mill effluent. The paper manufacturing company has been identified as the source of polychlorinated biphenyls (PCBs), the contaminant of concern, in the river sediment. Portions of the river are currently being dredged and the contaminated sediment is being shipped to a remote disposal site. The waste sediment consists of wood chips, dirt, and sand. The wood chips contain the majority of the PCB contamination, which allowed for efficient waste segregation. Water removed with the sediment was treated at an onsite wastewater treatment plant constructed for the project.
Metaltec is the 16-acre site of a small metal casing fabrication plant and includes an unlined lagoon used for dumping waste solvents from the plant's operations. The waste solvents contaminated both the soil and groundwater on site and were the focus of the remediation efforts. Four parcels of land on the site were originally identified for remedial action. Soil remediation was completed on three of the four parcels in prior years; the remaining parcel included the area encompassing the unlined lagoon. Remediation activities included site mobilization (i.e., installation of trailers, utilities, and equipment; clearing and grubbing; grading roads; and construction of decontamination facilities, drainage pump stations, and a water treatment system), soil excavation, thermal processing of 7,700 cubic yards of soil, backfilling and regrading the excavated area, and site demobilization.
Remediation activities at North Cavalcade included the installation, operation, and closure of a bioremediation system to treat contaminated soil.
Sand Creek Corridor Site (Sand Creek)
Sand Creek is located in an industrial area that contains petroleum and chemical production and distribution facilities, trucking firms, warehouses, and residences. The site contains contaminated soil, sediment, groundwater, surface water, and buildings. The site audit addressed operations at three of the site's operable units which contain contaminated groundwater and soil contaminated with volatile organics, pesticides, herbicides, and metals. Remediation activities included vacuum extraction of volatile organics, excavation and containerization of soils, dismantling and demolition of buildings and structures, and drilling in support of groundwater monitoring efforts.
Twin City Army Ammunition Plant (Twin City)
Twin City is the 10-acre site of a former U.S. Army ammunition production facility. Attempted destruction of off-spec or damaged ammunition contaminated the soil with lead and other heavy metals including antimony, cadmium, chromium, copper, mercury, and nickel. Soil decontamination involved a new soil-washing and lead-leaching technique designed to generate no waste streams.
Vertac is divided into two parcels: Parcel 1 contained abandoned herbicide production facilities and equipment and current groundwater treatment facilities; Parcel 2 contained an incinerator and staging areas for drummed waste. The incineration operation involved thermal destruction of about 28,000 drums of waste 2,4-D and 2,4,5-T and 2,4,5-T still bottoms. Known contaminants included toluene, chlorobenzenes, chlorinated phenols, acids, dioxin, and the pesticides 2,4-D, and 2,4,5-T.
Wasatch Chemical (Wasatch)
Wasatch is an 18-acre site that formerly hosted operations for warehousing, producing, and packaging industrial chemical products, including pesticides, herbicides, fertilizers, and other industrial chemicals and cleaners. The site includes accumulated debris, as well as sludge and soil that are contaminated with semivolatile organics, volatile organics, metals, and various pesticides and herbicides. Remediation activities included the consolidation of contaminated site debris, sludge, soil, and dioxin wastes into the former evaporation pond located on the site; destruction of the organic chemicals in these materials using in situ vitrification; excavation and land framing of toluene- and xylene-contaminated soils; installation of a groundwater extraction and treatment system; and, as necessary, construction of a groundwater containment system and treatment facility. At the time of the audit, remedial action was nearly complete.
IV. AUDIT RESULTS
OSHA found multiple deficiencies in the design, management, and implementation of safety and health plans at all the sites that it visited, and in all of the plans reviewed. These deficiencies fell into twelve functional areas and were often common to all the sites. A discussion of the findings specific to each functional area follows. Note, for the remainder of this report, the identities of the sites are masked, and are referred to by a randomly assigned letter designation (Site A - K).
A. Safety and health supervisors at the site must be given the authority to exercise their judgment in matters of employee safety and health. Management decisions related to safety and health must reflect the judgment of such individuals.
Perhaps the most essential component of the safety and health program at a hazardous waste site is the development, management, and implementation of the program by a competent site safety and health supervisor who has the authority to make timely decisions as worksite conditions rapidly change. The safety and health supervisor must also have the flexibility to conduct any investigations necessary to fully characterize the hazards to which employees may be exposed and to ensure that the safety and health program is effective in mitigating those hazards. The need to grant appropriate authority to the site safety and health supervisor is addressed in paragraph (b)(2)(I)(B) of 29 CFR 1910.120 (HAZWOPER).
Sites B and H had on site qualified safety and health supervisors with the authority to exercise their judgment in matters of employee safety and health. At Site H, however, the related contractual agreement between the prime contractor and the lead government agency limited the health and safety manager's authority in areas such as downgrading PPE levels by establishing inflexible minimum PPE requirements. As a result, the PPE requirements used on the site at the time of the audit seemed excessive in light of site monitoring data and hazard determinations. This use of excessive PPE unnecessarily increased the risk of heat stress and other PPE-related hazards.
The safety and health programs at Sites F, G, J, and K did not establish clear lines of authority or communication in the area of site safety and health. At Site K, neither contractor's SSAHP established a chain-of-command for the site. Although the plan listed the safety and health responsibilities of the project manager, industrial hygienist, and site safety officer (SSO), it did not describe the lines of authority and communication among them. At Site G, the relationship between the health and safety officer (HSO) and SSO was not clear and it appeared that no single individual had overall authority for site safety and health. Site J's site management and health and safety management were handled from the headquarters office in another city. Site J had an operations manager on site whose responsibilities included day-to-day operations and compliance with the SSAHP, but this individual did not have a background in safety and health. Three or four years prior to the audit, a site health and safety manager was employed at the site, but his responsibilities were not reassigned after his departure and employee interviews indicated that since his departure, it was unclear who was overseeing worker safety and health. As a result, Site J workers developed a "make do" attitude regarding safety and health oversight. For example, Site J workers signed one another's confined space permits. At Site F, the SSAHP referred to safety and health personnel who were not mentioned in the organizational structure, making lines of authority ambiguous.
At Sites E and I, each prime contractor had designated a safety and health supervisor, but these individuals did not have the knowledge and/or authority necessary to implement the site safety and health plans or to verify compliance. The prime contractor's SSAHP at Site I designated a HSO, who was responsible for implementing the SSAHP and had the authority to shut down operations that pose a potential threat to site personnel. This HSO's area of expertise, however, was construction management. Accordingly, the audit team was concerned that he did not possess the necessary qualifications to manage the site safety and health program and felt that his lack of training could result in an inability to detect important safety and health deficiencies. Similarly, the site management personnel of the Site I subcontractor seemed unfamiliar with equipment maintenance, operating procedures, and audit procedures. As a result, most of the requirements related to these procedures had not been implemented. The Site I subcontractor also lacked a backup safety and health supervisor fully trained in site safety and health management.
The acting health and safety specialist (HSS) at Site E was a site worker who had held the position for one week. This individual stated to the audit team that he did not meet the corporate or SSAHP qualifications required to hold that position. Apparently, while the Site E contractor was waiting for the results of the LTEV performance test and the unit was not in operation, site management determined that less health and safety oversight was needed. The regular HSS was on a month's leave.
Responsibility for management of site safety and health at Site A was assigned to several individuals including the response manager, the Technical Assistance Team (TAT) health and safety officer (HSO), and the on-scene coordinator. It was not clear at the time of the audit which of these individuals actually fulfilled the role of full-time HSO, nor was it clear how these individuals would coordinate and communicate on overlapping health and safety issues. In addition, several site HSO responsibilities identified in the health and safety plan were not completed by any of the individuals listed in the organizational section.
B. The site-specific safety and health plan (SSAHP) must include procedures for implementing and enforcing safety and health rules for all persons on site, including employers, employees, outside contractors, and visitors.
To maintain adequate site control, the site safety and health supervisor must have the authority to enforce the SSAHP's rules on any individual present at the site, whether that individual is an employee or an outside contractor. If there is more than one SSAHP (i.e., if each contractor develops its own), OSHA considers it essential that the plans be integrated and enforced consistently to ensure that onsite personnel have a clear understanding of safety and health expectations, lines of authority, and emergency response actions.
The audit team found that at Sites B and H, safety and health personnel had sufficient authority in most cases to thoroughly implement the safety and health plans. To facilitate safety and health compliance, anyone who entered Site H, including delivery personnel, was required to view a brief video that summarized the site history and remediation operations, identified the hazardous substances monitored on site, and described site evacuation procedures. Site B's SSAHP did not mention specific subcontractors and their roles and responsibilities; however, it did indicate that the prime contractor had oversight responsibility for all safety and health activities and the authority to discontinue or modify site operations when unsafe conditions were detected.
The SSAHPs at Sites G and K did not establish clear lines of authority between the contractor and subcontractors. At Site K, neither the contractor's nor the subcontractor's SSAHP established a chain-of-command or lines of communication for the site, and neither plan mentioned the other contractor, despite the substantial impact each had on the other's operations. Additionally, management personnel and employees at Site K did not have a thorough understanding of their respective roles and responsibilities during site emergencies. At Site G, it was not clear whether subcontractors would be performing any portion of the work and, if so, how their respective SSAHPs would be integrated.
The SSAHPs at Sites F and I lacked organizational information, such as clear lines of authority and communication, necessary to ensure the implementation and enforcement of safety and health rules for all persons on site. The prime contractor's SSAHP at Site I contained a corporate hazard communication policy but not a site-specific one. The Site I subcontractor's SSAHP had not been revised since 1993 and did not reflect current site organization or lines of authority, nor did it contain site-specific detail about personnel roles and responsibilities or procedures for how site contractors would be informed of hazards. At Site F the organizational structure, including lines of authority and communication, was not clear. The SSAHP repeatedly referred to personnel who were not listed in the organizational structure. For example, the organizational structure did not contain information about "field crew members" who elsewhere in the plan were assigned specific safety and health or emergency response duties.
Site C's SSAHP clearly stated that safety and health requirements described in the plan apply only to the employees of the prime contractor and subcontrator, and to visitors under the direct control of the contractor. As a result, the SSAHP did not cover other individuals on site such as, EPA personnel; state and local government personnel; or employees, representatives, or contractors of the Potentially Responsible Party (PRP).
C. The safety and health program must effectively ensure that ongoing task-specific hazard analyses are conducted so that the selection of appropriate PPE can be made and modified as conditions warrant.
The OSHA standard (29 CFR 1910.120) mandates that site safety and health programs require task- and operation-specific hazard analyses be conducted at the site. These analyses are intended to ensure a comprehensive and systematic approach to hazard anticipation, recognition, and evaluation at hazardous waste sites. Since work operations and site conditions change at different stages of the remediation process, the potential hazards associated with each operation must be reevaluated periodically to ensure that employees receive appropriate protection. For example, as work progresses, all information and data on employee exposures obtained to date should be incorporated into the analysis to enhance and refine the evaluation. The results of air monitoring are an important source of site-specific information used for hazard analysis. The requirement to conduct task- and operation-specific hazard analyses and to incorporate the results of such analyses into the site-specific SSAHPs is contained in paragraph (b)(4)(ii)(A) of the HAZWOPER standard. Paragraph (h) of the standard also requires that employees be monitored to ensure adequate characterization of their exposures and that the results of all exposure monitoring be fed back into the hazard analysis process to ensure continuing improvement in site planning and procedures.
The OSHA audit teams found program deficiencies in two related areas: the development of task- and operation-specific hazard analyses; and the conduct of monitoring programs designed to characterize employee exposures to hazardous materials. These deficiencies are discussed in more detail below.
Task- and Operation-Specific Hazard Analyses
Six of the eleven sites evaluated (Sites A, B, F, G, I, and K) identified generic remediation hazards in their SSAHPs but did not address the hazards associated with site - and operation-specific tasks. For example, the SSAHP for Site B broadly described hazards such as "the potential for inhalation, ingestion, contact, and absorption of contaminants" or "heavy equipment and general construction hazards." The plan did not describe specific hazards (i.e., levels of specific chemical contaminants, the hazards related to the use of specific types of equipment) associated with specific workplace activities and their related control measures. These general analyses do not provide employees with sufficient information to enable them to work safely, nor do they enable the employer to determine the types and levels of controls necessary to protect workers from health and safety hazards.
In the absence of site-specific exposure information, the selection of PPE at these sites did not appear to be based on the performance characteristics of the PPE relative to the hazards and potential hazards. For example, at Site G, no rationale was provided for using modified Level C PPE for a few jobs for which use of a half-mask respirator is permitted. Additionally, the Site F site plan did not contain any site-specific PPE information that employees could use for site tasks and operations.
Employee Exposure Monitoring
Site C had one of the most comprehensive employee exposure monitoring programs of the sites reviewed. The Site C SSAHP described an extensive exposure assessment program that included both real-time monitoring with direct-reading instruments and personal air sampling. It also established action levels for explosive atmospheres, organic vapor concentrations, dust concentrations, and noise levels that trigger PPE use or evacuation. The SSAHP specified that personnel sampling is to be performed daily on all contractor personnel, unless monitoring data indicated that a lower frequency (e.g., once per week) would be acceptable. Personal sampling was conducted for the eight contaminants, which appeared to be the most common on site. Site characterization data, however, indicated the presence of other contaminants for which OSHA has monitoring requirements and/or PELs. The SSAHP mentioned the use of a data management system for recording monitoring results but did not describe procedures for data analysis or the use of monitoring data to revise the sampling plan.
The contractors at Sites H and K also conducted personnel monitoring activities; however, neither used this data to determine appropriate PPE levels. At Site K, real-time monitoring for total organics was conducted daily by both contractors; however, the air sampling records and corresponding results were not stored together on site, making it difficult to correlate results with sampling information, and therefore, to accurately assess risks to employees. PPE determinations at Site K were not always based on monitoring results. For example, both contractors used a modified Level C with full-face respirator although real-time air monitoring for volatile organics seldom showed detectable airborne levels of contaminants. In addition, the use of chemical protective clothing was not supported by air or surface contamination monitoring to determine the potential for dermal exposure and the appropriate PPE.
The contractor at Site H site had established area and personnel sampling consistent with HAZWOPER requirements. A photo ionization detector (PID) and a real-time aerosol monitor (RAM) were used on a daily basis to screen for potentially hazardous levels of contaminants. On a weekly basis, personal air samples were collected and submitted for laboratory analysis. PPE requirements, however, were often not based on this data because the oversight agency had established inflexible minimum PPE requirements. The audit team found many of the PPE requirements on Site H to be excessive in light of site monitoring data and hazard determinations.
Contractors at Sites B, D, G, I, and J had incomplete sampling practices and as a result were not able to evaluate PPE levels based on monitoring data. For example, both contractor's SSAHPs at Site I lacked provisions for monitoring site hazards such as metals, pesticides, herbicides, and semi-volatile organic compounds (SVOCs) that could not be evaluated with a PID. Since worker exposures to the range of hazards on site had not been characterized, PPE was not selected based on its performance relative to the nature and level of site hazards.
The sampling and monitoring frequencies specified in the Site B site contractor's SSAHP were not consistent with HAZWOPER requirements since the plan based monitoring frequency on prior sampling results alone, and did not consider other factors such as the performance of new or different tasks. The SSAHP did not include wipe sampling among the specified monitoring procedures despite the fact that most of the site's identified contaminants pose significant dermal exposure hazards. In addition, the plan included a monitoring technique that appeared to be unsuited to evaluation of airborne contaminant levels at the site. The Site B site SSAHP did address ambient air monitoring and personnel sampling; however, those requirements did not cover potential exposures to each of the hazardous substances identified on the site. As a result, site characterization data provided in the SSAHP did not provide the site-specific airborne exposure levels necessary to determine an appropriate level of PPE for each specific task.
The SSAHP for the contractor at Site G did not specifically identify the chemical contaminants for which employee exposure monitoring would be conducted, with the exception of some indicator tube samples. An appendix of the SSAHP contained NIOSH sampling methods; however, with the exception of measuring metal fume exposure during hot work, it described no program for personal sampling of employee exposures. It appeared that all employee exposure sampling was performed with direct-reading instruments. Site G's program did not address how the results of monitoring would be reported to affected employees, nor did it establish exposure limits or triggers for PPE selection and use.
Monitoring records maintained at the Site J provided no indication that any contractors were fulfilling regulatory or contractual requirements for monitoring. In an interview, an employee explained that the lack of personal monitoring was based on ambient air sampling results indicating that the levels of contaminants were too low to warrant personal sampling. The monitoring results available on site at the time of the audit were inadequate to justify this conclusion. At Site D, PPE selection was not based on monitoring data. For example, PPE was required in the support zone, although no surface sampling had been conducted to determine the need for PPE in that area.
Exposure monitoring had not been conducted at Site A. The decision not to conduct monitoring was appropriately documented in the site safety plan and was based on the nature of the contaminated material. The sediments were always saturated, and the likelihood of airborne concentrations of PCBs was extremely low. Area samples had been collected at the waste pad where the material was air-dried prior to shipping. Sample results were below the detectable limits. The site safety plan indicated, however, that noise monitoring was required, but neither area noise surveys nor personnel dosimetry had been conducted.
D. Task-specific hazard analyses must lead to the development of written standard operating procedures (SOPs) that specify the controls necessary to safely perform each task.
Detailed hazard analyses conducted for each site task and operation provide the basis for developing SOPs to protect employees from safety and health hazards. Written SOPs provide a mechanism for informing employees of procedures that ensure their safety and for enabling management to enforce hazard control procedures. Requirements for written safety and health SOPs are found in paragraphs (b)(4)(I) of the HAZWOPER standard.
None of the sites audited had developed comprehensive, site-specific SOPs that specify the controls necessary to complete each task. The contractor's SSAHP at Site B did discuss generic task-related hazards and SOPs; however, the task-specific SOPs lacked detail. For example, the SOPs did not specifically identify the site locations where hazards were likely to occur, nor did they specify the appropriate types of controls.
The prime contractor's SSAHPs for Sites D, F, and G and the subcontractor's SSAHP for Site I did not contain detailed discussions of specific work tasks to be performed by employees or the hazards associated with those tasks, and, as a result, SOPs associated with each job or task had not been prepared.
The contractor's SSAHP for Site C contained task- and operation-specific hazard analyses and safety and health procedures that covered general operations, but they were not specific enough for prescribing control methods and PPE for each job task. The plan identified some safety hazards for each operation but did not describe SOPs for protecting employees from these hazards. The SSAHP did, however, contain personnel and equipment decontamination procedures used at the site.
The SSAHP for Site A contained procedures and practices that did not reflect actual practices employed by workers onsite. Examples included PPE requirements, decontamination procedures, and work zone identification procedures.
E. Emergency response elements of the safety and health program must be fully implemented as described in the program.
The emergency response plan for a hazardous waste site is one of the key components of a site's SSAHP. Major elements of the emergency response plan include coordination with local organizations that provide emergency response services (i.e., fire department, health care facility, and local emergency response center), training employees in emergency response alarms and evacuation procedures, and conducting drills to determine the effectiveness of the emergency response plan. Requirements for developing and implementing emergency response plans are found in paragraph (l) of the HAZWOPER standard. The audit teams found that none of the sites had established comprehensive emergency response procedures consistent with the HAZWOPER requirements. The audit team at Site H did, however, conclude that an effective emergency response program was in place.
Deficiencies common to most sites were inaccurate emergency contact lists and a lack of communication with local emergency response organizations. Only Sites C and H, and one of the contractors at Site J had accurate site emergency contact lists and had contacted local emergency response organizations. The contractor at Site A had an accurate list of responders who were aware of the site location but unaware of the hazards associated with PCBs, the main contaminant at the site. At the Site H, local emergency response organizations indicated that they were familiar with the site and its emergency response requirements. Additionally, the Site H contractor paid for site-specific emergency response training consistent with the requirements of 1910.120(q) for members of the local fire department so that fire department personnel could respond to emergencies within the site's exclusion zone. This contractor also provided the fire department with weekly project status reports to inform firefighters of the location and nature of current site activities. One contractor at Site J provided the local hospital with necessary information about site hazards, and the hospital developed written procedures for treating potentially contaminated accident victims. The fire department near Site J, however, had been using MSDSs from 1985 as a characterization of site hazards, which indicated a failure to coordinate the site emergency response plan with local, state, and federal agencies. Notes of a meeting attended by local fire departments, EPA, and Site J contractors, however, indicated that fire prevention, firefighting procedures, and potential hazardous exposures occurring as the result of fire were discussed and that local fire response teams and other site contractors would be made aware of current hazards.
In contrast, contractors' emergency contact lists for Sites B, E, I, K, and the remaining contractors at Site J were inaccurate, and not all local emergency response organizations identified on the lists had been informed about the sites. This lack of coordination was particularly troublesome for Site E which is located in a rural area with no 911 service and relies largely on volunteer emergency response organizations. At Site I, the subcontractor had not informed personnel at the only area hospital with a burn unit about site hazards and potential emergency medical needs that could arise from the use of high-voltage power lines. In addition, although the Site J contractor discussed above had contacted the local fire department and medical center, the local hospital did not know about the presence of all of the Site J contractors.
Another deficiency common to many of the sites inspected was inadequate emergency response training. For example, at Site K, employees indicated that they had not been trained to use fire extinguishers, even though the written plan and site hazard communication training suggested that employees could be called upon to respond to small fires that could be controlled with onsite extinguishers. Similarly, the Site F plan did not contain a provision that all employees expected to use portable fire extinguishers must receive training in fire extinguisher use. At Site E, personnel had not been trained on how to shut off the LPG tank in case of an LPG line rupture or leak, even though a potential rupture or leak was discussed as a hazard in the SSAHP. Interviews at Site I indicated that emergency response planning and training had been poorly implemented and that training in emergency spill containment and fire extinguisher use had not been provided.
All contractors except for those at Sites C and H also had major deficiencies in their provisions for conducting emergency response drills. Site H was the only site at which the contractor conducted confined space rescue and emergency evacuation drills, as required by 1910.146(k)(1)(iii) and 1910.120(1)(3)(iv). In addition, the Site C SSAHP described procedures for employees to follow in the event of a fire, explosion, or equipment failure and contained procedures for using hand signals and emergency alarms.
In contrast, emergency evacuation procedures had not been rehearsed at Sites E and K, and some employees at the Site K expressed doubt that the employee alarm system (portable air horns) would be audible above site noise levels or would be accessible for all emergencies. The SSAHP at Sites B, G, I, and J did not establish provisions for emergency response rehearsals or drills. The Site G and I SSAHPs did not describe procedures for testing and maintaining alarm systems, while the SSAHP at Site F did not contain site-specific emergency alerting procedures, including the exact type and location of alarm systems. The written emergency response plan for Site E did not indicate the frequency of rehearsals, the location of evacuation alarms, the procedure to evacuate when those alarms went off, alternate evacuation routes, the radio channel to be used in emergencies, the location of assembly areas for onsite and offsite evacuation, or procedures for testing the alarm to determine its proper operation. In addition, the evacuation alarm in use at Site E was located only in the safety and health office and had not been tested. One Site J contractor did conduct emergency evacuation drills periodically throughout the year so that all employees had the opportunity to participate at least once annually; however, some employees stated that they had never participated in such drills. The emergency plan at Site C did not contain provisions for conducting periodic rehearsals or evacuation drills, and it was not clear whether site personnel had opportunities to rehearse emergency response situations with outside community organizations.
Site H was the only site at which the contractor had clearly established personnel roles and responsibilities during emergency response activities. At Site H, the prime contractor designated an onsite emergency response team made up of members who were trained in and responsible for confined space rescue and site evacuation assistance procedures. At least four emergency response team members were on-site during each shift and were distinguished from other personnel by green hardhats. The Site H prime contractor limited emergency response actions for most employees to spill containment activities. These employees were trained to evacuate the site in the event of other site emergencies or potential emergencies, and audit team interviews indicated that the employees were familiar with evacuation routes and procedures.
At Site K, rescue and medical duties for the site had not been planned and specified, and management personnel and employees did not have a thorough understanding of their respective roles and responsibilities during site emergencies. The Site B SSAHP mentioned that employees would be briefed on emergency evacuation routes, potential site emergencies, and employee roles and responsibilities; however, the plan provided no site-specific details describing these emergency response procedures. The SSAHPs at the Sites F and I lacked clear and consistent descriptions of personnel roles, lines of authority, and methods of communication during emergencies. For example, one section of the contractor's SSAHP for Site F required personnel to evacuate the site during an emergency, while other sections of the plan indicated that personnel may respond to spills, leaks, or fires. Neither contractors' SSAHPs at Sites C or G identified the individuals responsible for coordinating emergency response activities.
Many of the sites did not effectively identify the nature and location of potential emergencies. The contractors' SSAHPs at Sites A, B, F, and K did not include site-specific information about the nature and source of potential emergencies. The plan in effect at Site H did not provide a description of the nature and location of potential spill hazards and emergencies, nor did it indicate the type of spill containment equipment available or the locations on site where this and other emergency response equipment was stored. At Site I, hazards associated with the thermal oxidation unit had not been discussed in site-specific training. In addition, the Site I subcontractor's SSAHP lacked a description of the types of potential emergencies associated with site operations.
Other problems with the sites' emergency response procedures stemmed from deficiencies in the layout and content of the emergency information in the SSAHP. The contractors' SSAHPs at Sites F, G, and I did not include a site map illustrating emergency evacuation routes and designated rally points. The contractor at Site G, however, claimed that this information is disseminated to employees at safety briefings. The Site G SSAHP explained the basic equipment and procedures needed for emergency response but lacked important detail needed for successful implementation of the program. For example, the equipment list did not specify the number and locations of fire extinguishers. The plan called for emergency equipment to be available at all active work areas but did not identify specific locations. The Site G contractor's SSAHP referred to a separate contingency plan, which apparently described much of the information missing in this chapter, but did not state where this supplemental plan was kept on site. Similarly, the contractor's SSAHP at Site I did not contain a description or the location of site emergency response equipment and PPE. The emergency response plans of both Site K contractors were scattered throughout their respective SSAHP documents rather than being consolidated in a separate section of the document as required.
One specific concern that the audit team had at the Site J was the lack of emergency coordination between the prime contractor and subcontractors. Site J's prime contractor used an emergency contingency plan, prepared to comply with 40 CFR 264.50, Subpart D. The 40 CFR regulations have more limited worker safety and health requirements than 1910.120, which resulted in certain deficiencies in the emergency response plan. Subcontractor employees indicated uncertainty about correct evacuation procedures and stated that they were unaware that such a plan was currently in place. Due to the departure of the safety and health manager at this site, employees did not know who to call in an emergency or where the number would be listed.
F. All site control elements of the safety and health program must be fully implemented as described in the program.
The purpose of site control requirements is to ensure that only properly trained and authorized individuals enter those areas of the site with potential hazards, and that, in the event of an emergency, rapid assistance can be rendered to employees working in the exclusion zone. This section discusses the findings of two components of site control: the establishment and maintenance of site work zones and the establishment and implementation of appropriate confined space procedures.
Site Work Zones
One common deficiency in the sites reviewed was the lack of an accurate, up-to-date site work zone map. Of the sites reviewed, only the Site H contractor had established site work zones that were clearly marked on a site zone map. The SSAHP for Site G contained a general discussion of the types of work zones established at the site and the kinds of activities that took place within each zone; although the SSAHP claimed to contain a site map, the map was not available for review. The contractor's SSAHP at Site C contained one map that covered the entire site area, but it did not contain more detailed maps showing locations of support areas, exclusion zone boundaries, or decontamination facilities. The work zone maps for Sites B and D did not accurately reflect actual site work zones, and SSAHPs provided by contractors at the Sites I and K did not even contain site maps showing the location of work zones.
Site H was the only site at which the contractor had implemented comprehensive and effective site control elements. The Site H contractor had established site work zones, a buddy system, and site communication procedures consistent with 1910.120(d). This contractor had also established exclusion zones and contamination reduction zones to control migration of site contaminants to clean areas of the site when work within these areas introduced the potential for exposure to hazardous contaminants. The audit team supported this contractor's use of flexible and temporary work zone boundaries based on monitoring results and hazard determinations.
The contractor's site control elements at Site B were not comprehensive; however, the contractor's SSAHP did address site entry and training requirements and mandated that all personnel, including subcontractors and visitors, entering the exclusion zone, or decontamination zone meet HAZWOPER training requirements. Forty-hour training was required for personnel entering the exclusion zone and additional supervisory training was required for site supervisors.
Site control procedures described in the Site C contractor's SSAHP included maintenance of site control logs at each access point, use of red tape or chainlink fencing to demarcate hot zones, and use of the "buddy" system in all exclusion and contamination reduction zone areas. Site communications relied almost exclusively on visual sighting of employees; the plan did not describe the use of two-way radios. This suggested that all employees in hot zones can be observed continuously from the support zones.
Significant deficiencies in site control procedures existed at Site K. For example, the Site K subcontractor had not established a contamination reduction zone (CRZ), to physically separate the support zone from the exclusion zone, as required in the site plan. The bench where decontamination took place was only a few feet from the thermal unit and was not isolated from exclusion zone activities, employees moved freely between their work stations in the exclusion zone and the decontamination bench. In addition, the subcontractor did not conduct monitoring activities to support work zone designations. Neither Site K contractor used warning signs to delineate exclusion zones, as required by their respective health and safety plans.
At the time of the Site I audit, only two established work zones remained on site: an exclusion zone encompassing the waste treatment area and a clean zone encompassing the remainder of the site. According to the contractor's project manager, EPA approved this reduction in site work zones. As a result of this zone designation, workers exit the exclusion zone directly into a clean zone, removing and discarding PPE in a barrel adjacent to the operations trailer. The audit team took wipe samples from the surface of the discarded PPE and analyzed them for metals, pesticides, and SVOCs, but found no detectable contamination. The Site I contractor, however, did not have additional sampling data from different days or varying circumstances to verify that on a consistent basis, contamination was not being spread to clean areas of the site because of the lack of decontamination operations.
The Site E contractor had established fixed work zones based on the potential for exposure but adjusted the barriers to accommodate certain activities, such as thermal unit maintenance. While adjusting of work zone boundaries according to the potential for contamination is acceptable, worker behavior indicated confusion about the zone boundaries and associated work practices and PPE requirements. In addition, the audit team observed Site E workers leaving the exclusion zone without performing required decontamination procedures.
All contractors at Site J had deficiencies in their work zone practices. The contractors had established work zones based on the potential for exposure associated with specific work tasks. Temporary exclusion zones, demarcated by red tape, were established whenever maintenance tasks increased the potential for exposure to hazardous contaminants. These zones were removed once visual inspection by a safety technician indicated that the area was clean. The boundary between the clean support zone and the potential exclusion zone was not clearly demarcated. Employees were told that the boundary was an invisible line drawn between a nearby telephone pole and the corner of a drum storage building. Another problem was that the access road used to travel between the administrative offices and the support zone was used by another contractor to transport drums to the drum-handling building. Even though this situation presented potential contamination issues, vehicles used to transport personnel were not routinely decontaminated, thus increasing the possibility of contaminating the administrative offices. Wipe samples confirmed this concern. Also, drums and other debris were seen on the site of a small abandoned paint factory located near the access road between the administration trailer and the support zone. Although, potential hazards had not been characterized, the contractor still instructed employees not to go near the paint factory. This area, however, was identified as the most likely place for a drum to spill during transport, and emergency spill containment equipment was kept by the side of the road near the abandoned factory. This situation may represent a violation of the site characterization requirements of 1910.120(c), even though the prime contractor made it clear that it had not been given authorization to investigate whether the facility presented a potential hazard to its employees.
Another Site J contractor had no CRZ through which contaminated material was to be transported from the exclusion zone to the clean support zone. Additionally, this contractor did not consistently use the buddy system. For another contractor on Site J, the site was loosely zoned and characterized. Employees could generally indicate what areas were "hot," although they were not certain of specific hazards. Some employees were more concerned with the stability of site structures with sagging roofs and broken doors than with chemical hazards. The written description for the exclusion zone in one Site J contractor's SSAHP appeared inconsistent with the actual zone designations. According to this SSAHP, CRZs would be defined on a case-by-case basis, but in practice the entire northern parcel appeared to lack CRZs for personnel and equipment that met the criteria described in the Four-Agency Manual, EPA guidance documents, and other industry literature.
Site D lacked a sufficient CRZ and also lacked access/egress control for the exclusion zone. The site control plan did not accurately identify the function of the CRZ as a buffer zone between the exclusion zone and the support zone, and there was no buffer area between the decontamination pad and the road that runs adjacent to the pad, marked as a support zone. Also, an exclusion zone log-in procedure for tracking personnel who enter and exit this zone was not used on site as called for in the SSAHP.
The primary contractor at Site A had identified clean zones, buffer zones, and related site control procedures in its written plan; however, onsite implementation differed from those specified in the plan. For example, the exclusion zones identified in the plan at the upper pad of the wastewater treatment plant, the dredge area, and the solid waste storage area were marked with signs requiring PPE, but were not labeled with red banners as called for in the plan. In addition, the exclusion zones did not have controlled access through one point of entry as described in the plan, nor were the buffer zones established and demarcated with yellow banners.
The contractors' SSAHPs at Sites B, F, and K had general confined space provisions but lacked site-specific confined space procedures. For example, SSAHPs for the Site K contractor and subcontractor had written confined space entry programs, but the programs did not establish site-specific rescue procedures or identify the confined space hazards present on the site. The job hazard analyses for both programs failed to address site maintenance tasks that could involve confined space entry and hot work hazards. The programs also failed to identify the specific person or position responsible for supervising confined space entry procedures and the location of permit-required confined spaces on site. Interviews with both contractors indicated confusion about rescue procedures. Employees stated that they had received confined space training and were prepared to perform confined space rescue, but they had not rehearsed rescue procedures. In addition, the confined space entry permit form for both contractors did not ask for all required information. For example, the form did not require documentation of the duration for the permit, the intended communications procedures for entry operations, or documentation of hot work performed during confined space entry operations. Completed permits did not contain documentation of hot work performed during confined space entry operations, even though hot work had been performed during such operations at least twice during the project.
Similarly, the Site B contractor's SSAHP provided corporate policy and procedures for permit-required confined space entry but lacked the site-specific detail necessary to describe the application of the corporate policy to procedures at the site. For example, the SSAHP did not identify specific components of the thermal treatment unit that presented confined space hazards, nor did it describe the specific circumstances or procedures that would require employee entry into these areas. In addition, the plan stated that the contractor would maintain an onsite employee confined space rescue team, but did not identify the members of this team. The SSAHP for the Site F also contained a generic confined space entry program, but did not identify the specific location of confined space hazards present at the site.
Contractors at Sites E, H, and J had documented confined space programs but had not fully implemented these programs. The Site H contractor had established a permit-required confined space entry program consistent with HAZWOPER requirements; however, onsite procedures were not completely consistent with the written program or OSHA requirements. For example, the confined space permit form used at Site H was not the form included in the written program. The audit team also found evidence that employee training was insufficient for safe performance of assigned confined space entry duties. The audit team's review of canceled permits at Site H indicated that site personnel occasionally failed to record oxygen levels and other measured atmospheric concentrations as required by site SOPs. At Site E, the contractor's confined space permits had been developed and were required in the SSAHP, but may not have always been completed in actual practice. Names of authorized entrants and standby personnel and the identification of required PPE were not recorded on the entry permits. At Site J, the contractor's buddy system and confined space procedures were in place, although interviews suggested that employees assumed they would be responsible for confined space rescue and were unaware of requirements in 1910.146(k) to rehearse related rescue procedures.
The contractor at Site A had a written confined space program; however, the permits used onsite were different from those specified in the plan. In addition, confined spaces onsite were not labeled, rescue drills had not been conducted, and employee training records were not available onsite.
G. The safety and health program must include procedures for monitoring the effectiveness of PPE, decontamination procedures, and housekeeping programs.
Safety and health supervisors at hazardous waste sites need to evaluate the effectiveness of their safety and health programs on an ongoing basis to ensure that the established SOPs are appropriate. Monitoring the effectiveness of these programs is required under paragraph (b)(4)(iv) of the HAZWOPER standard. In general, audits discovered that safety and health personnel have not established objective procedures for monitoring the effectiveness of certain elements of their programs, in particular the use of PPE, decontamination procedures, and housekeeping procedures. The effectiveness of these program elements can be assessed in a variety of ways, such as the collection of wipe samples on decontaminated equipment and on surfaces in clean areas, analyzing the final decontamination rinse water for the presence of contaminants, or visual inspection of PPE for signs of leakage or failure.
Contractors at Sites C and H had acceptable programs for monitoring the effectiveness of PPE and decontamination procedures. The Site H contractor had established PPE and decontamination programs consistent with HAZWOPER requirements. The Site C contractor developed decontamination procedures that included specifications for periodically evaluating the effectiveness of decontamination methods through the performance of leak testing for PPE, visual observation of used PPE, wipe sampling of protective clothing surfaces, and chemical analysis of cleaning solutions. The contractor's PPE program at Site C included procedures for assessing the effectiveness of PPE, such as testing for leaks, visually observing PPE during use for signs of contamination, and recording actual and suspected PPE problems in the daily site log. In addition, the respiratory protection program that is part of the PPE program mandated the use of qualitative or quantitative fit testing at the time a respirator is assigned and semiannually thereafter. Responsibility for respirator cleaning, inspection, and maintenance rests with each employee; the safety and health officer determines whether employees are maintaining their respirators properly or if additional employee training is required.
Many other sites did not have effective monitoring programs in place. Neither of the Site K contractor or subcontractor SSAHPs included provisions for evaluating the effectiveness of decontamination procedures. According to these documents, the adequacy of equipment decontamination was determined by visual inspection alone. The equipment and personnel decontamination procedures of Site K's prime contractor were acceptable, but deficiencies existed in the subcontractor's procedures. The level of PPE used at Site K was not based upon site- and task-specific hazards, and the use of chemical protective clothing was not supported by measurements of surface contamination on the clothing. For example, for both contractors, existing monitoring data did not support the need for full-face respirators, making the associated limitations in worker communication, peripheral vision, and respiration unnecessary.
At Site I, personnel and equipment decontamination procedures were not monitored for their effectiveness in accordance with HAZWOPER requirements. The Site I subcontractor did not have provisions for particulate sampling, evaluating exposure to pesticides and herbicides, or evaluating the effectiveness of site zone boundaries and personnel decontamination procedures. Additionally, monitoring had not been conducted to verify that decontamination was not necessary for employees who leave the exclusion zone and enter a clean zone without undergoing decontamination.
The SSAHP developed by the Site G contractor did not indicate that the contractors routinely conducted job- or task-specific hazard analyses. In addition, the SSAHP did not specify that PPE selection for jobs and tasks must be based on the analysis of the health hazards associated with each job. Furthermore, the SSAHP contained no procedures for objectively determining the effectiveness of decontamination of personnel or equipment. The decontamination program required incineration of all materials that could not be readily decontaminated; such materials were placed in labeled disposal containers. The program, however, did not address storage of these materials until such time that the incinerator was operating.
Other than wipe sampling of clean areas, the Site J contractor did not implement procedures to evaluate the effectiveness of personal decontamination methods. Decontaminated equipment was tested by wipe sampling. Further decontamination was performed as necessary until wipe samples fell below the contractor's trigger levels.
Contractors at Sites B, D, E, and F had not evaluated the effectiveness of their PPE programs, and did not monitor decontamination procedures through the use of surface sampling or other quantitative means. At Site E, improper use of PPE was observed several times in the exclusion zone and monitoring data was not kept current in the computer when the SSO was off site for an extended period of time.
The contractor at Site A had no process in place to evaluate the effectiveness of its decontamination procedures.
H. Self-audit site inspection and abatement tracking programs must be formalized and effectively implemented.
The overall effectiveness of the safety and health program must be evaluated, in part, by conducting regular inspections and audits. In addition, the SSAHP should include a mechanism for following up on corrective actions recommended by the site safety and health officer during safety inspections. All hazard abatement actions identified by the site safety and health officer should be tracked to ensure that the corrective actions have been implemented and the hazard(s) have been controlled. The program should designate individuals to periodically inspect work areas and ensure that hazard abatement has been accomplished. Paragraph (b)(4)(iv) of the HAZWOPER standard contains the requirement that the site safety and health supervisor, or a knowledgeable designee, perform periodic inspections to evaluate the effectiveness of the program.
Site H was the only site for which the contractor had developed and effectively implemented inspection procedures consistent with the HAZWOPER requirements. Site safety technicians conducted daily and weekly inspections during each work shift. The technicians recorded deficiencies on an inspection checklist, and the site health and safety officer (HSO) and project manager reviewed and signed each checklist. The prime contractor then compiled a weekly "Observations Report" from the daily inspection records, which included a list of noted deficiencies and the necessary corrective actions. The deficiencies appearing on this report were carried forward to following weeks until corrective action was taken. The HSO also conducted a monthly safety and health inspection. A review of site records indicated that, in most cases, the contractor had implemented corrective actions in a timely fashion. In addition, the site walk-through suggested that site safety and health practices and procedures were generally effective.
The contractors' SSAHPs at Sites I and K required that safety and health program inspections be conducted; however, these requirements were not effectively implemented at either of these sites. Both Site K contractors required the HSO to conduct daily inspections, and both stated in their written plans that hazards would be immediately corrected. Neither contractor, however, had established hazard abatement procedures to ensure the prompt correction of hazards, and site records for both contractors indicated that hazard abatement activities were either not documented or not completed. For example, the subcontractor's daily safety log contained several notations of safety hazards, including an unstable concrete well and storage of diesel cans near the propane tank; however, later log entries and site records did not track the abatement of these hazards.
At Site I, the prime contractor's SSAHP required daily site inspections, the documentation of safety and health deficiencies, and the abatement of deficiencies. Records of site deficiencies, however, were kept intermittently, and hazard abatement was not documented. The subcontractor's SSAHP did not address site inspections and hazard abatement, but its TSCA permit application included requirements for site inspections. Inspection documentation, however, was not available on site, and the site manager was unaware of these written requirements. The site manager did, however, indicate that he conducted site inspections using a mental checklist, and that he conducted inspections of remediation equipment before each use.
The SSAHPs for contractors at Sites E, F, and G did not establish specific requirements for self-audits to identify and correct any deficiencies in the effectiveness of the plan. The Site F contractor's SSAHP stated that the health and safety manger is responsible for continued evaluation of the plan's effectiveness, but the SSAHP did not establish specific requirements. At Site E, the contractor used chronological notebooks to file all daily logs; however, health and safety program elements or related activities were not properly identified in the logs, making it difficult to verify compliance with the SSAHP or OSHA requirements or to determine whether recognized hazards had been abated.
I. Process safety management procedures for the treatment facility need to be improved.
Hazardous waste thermal treatment operations are a complex process in which a number of upset conditions can result in potential hazards to employees. These hazards typically occur when the upset condition causes a sudden increase in system pressure or a bypass of the pollution control equipment. Transportable thermal treatment devices are equipped with several safety interlock systems that trigger automatic equipment shutdown or interruption of waste feed when operating parameters fall outside the normal range. Safe operation of thermal treatment equipment, however, still relies heavily on the attention of the operator and the implementation of proper equipment maintenance and repair procedures. Although the thermal treatment sites inspected in this study do not generally fall within the scope of OSHA's process safety management standard (29 CFR 1910.119), the audit team applied many of the principles that formed the basis of that standard to evaluate each site's management procedures for ensuring the safe operation of the thermal treatment equipment. Some of these principles are maintaining accurate piping and instrumentation diagrams, developing and implementing written programs for regularly scheduled equipment maintenance, ensuring that safety equipment such as pressure relief devices are properly installed and operating, and keeping accurate records of repairs and modifications made to the system.
Site K's thermal treatment operation was found to be a relatively low-hazard process, with effective controls, interlocks, and automatic shutdown systems. The audit team did identify potential deficiencies in operator training and information, in equipment maintenance, and in emergency planning. For instance, no formal training had been provided for thermal unit operators and the thermal unit operator's manual was missing significant information (e.g., equipment maintenance procedures, normal operating limits and the consequences of deviations, and emergency shutdown conditions). The contractor did not have a written maintenance program for the thermal unit, and maintenance was limited to necessary repairs, with no regularly scheduled preventive maintenance. In addition, the contractor did not maintain maintenance and inspection schedules for components of major pieces of equipment, written operating procedures for different phases of unit operation such as start-up, normal operation, emergency shutdown, and normal shutdown, were not available.
The audit team did not conduct a formal incinerator process safety evaluation at Site H, but it did review reference manuals and interview employees about process safety procedures and training. The operator reference manual for the incinerator did not describe procedures for all phases of incinerator operation (i.e., start-up, shutdown, emergency shutdown, etc.). In addition, checklists for standard start-up and shutdown procedures were not available on site, although a site engineer stated that such checklists were being developed and that programmed controls prevented operators from omitting important start-up or shutdown procedures. Incinerator operators said they had received adequate training, despite the fact that only one day of site-specific operator training was provided. Logs of occurrences and upset conditions were maintained, but incinerator operators were unsure if these logs were reviewed for trends or common occurrences that could indicate future problems.
The audit team did not conduct a formal process safety evaluation at Site I. The team did, however, examine the written inspection program and the shift engineer logbooks maintained for each melt and interviewed employees about process safety procedures and training. In general, the written programs available on site adequately addressed equipment maintenance, operating procedures, and inspection procedures, but the contractor's site manager seemed unfamiliar with these programs, and most program requirements had not been implemented. For example, the contractor did not have written inspection records on site, even though the SSAHP required such records. In addition, documentation of the maintenance checks required by the contractor's spill prevention, control, and counter measures plan was not available on site.
J. Procedures to monitor and reduce heat stress need to be effective.
Perhaps the greatest health hazard facing hazardous waste site workers is heat stress, exacerbated by the use of impermeable chemical protective clothing. Ideally, a comprehensive heat stress program will contain several elements, including environmental and medical monitoring (i.e., measurements of pulse rate, oral temperature, and/or weight loss), issuance of heat alerts, implementation of work-rest regimens when site conditions warrant, provisions for fluid intake and shaded rest areas, and regular training of employees in recognizing the signs and symptoms of heat stress in themselves and their fellow workers.
For the most part, contractors at Sites C and H had established effective heat stress monitoring programs. The SSAHP for Site C contained detailed procedures designed to protect workers from heat and cold stress. These procedures included environmental sampling and medical monitoring of workers when ambient temperatures reach 70 degrees F, and heart rate and oral temperature monitoring at the beginning of each worker's rest period when ambient temperatures reach 80 degrees F. The contractor at Site C modified work and rest schedules based on the results of medical surveillance and monitored weight loss during hot periods to ensure employees maintained sufficient fluid intake. In addition, this contractor's SSAHP contained a comprehensive discussion of the signs, symptoms, and treatment of heat- and cold-related disorders.
The contractor at Site H had established SOPs for site hot work consistent with the HAZWOPER requirements. This contractor required initial body weight and pulse measurements and core temperature readings at fixed intervals during the work shift as well as exit body weight and pulse measurements. Workers were directed to stop work if their core temperature exceeded 100.4 degrees F or if they felt uncomfortable. Site records indicated that heat stress monitoring was conducted on a regular basis when the ambient air temperature reached or exceeded 70 degrees F.
Contractors at Sites E, F, G, and K referred to and/or performed some heat stress monitoring procedures, but none had a comprehensive heat stress plan.
Although an effective heat stress program, based on NIOSH recommendations, was included in the SSAHP for Site E, the procedures used on site varied from the program outlined in the SSAHP. Employee body temperature measuring and monitoring was not conducted as required by the SSAHP. The employee work/rest schedule was not actively monitored by the SSO to assure that the heat stress prevention plan was being followed. Employees monitored their own pulse and blood pressure prior to dressing out and before leaving decontamination areas, and they filled out log sheets that were maintained in the decontamination trailer. The lack of attention to heat stress monitoring, however, was evident in these daily logs. For example, for a caustic spill response performed by employees on site, the log indicated that one worker experienced heat exhaustion during the cleanup and was absent from work the next day, "likely due to heat exhaustion from the caustic spill." No other entries in the log discussed the use of heat stress monitoring or prevention practices, suggesting that such practices were not always implemented on the site.
The contractor's heat stress program at Site G called for measuring ambient temperature, instituting necessary controls, providing rest areas, and establishing work/rest schedules. The program, however, provided no details about when controls were to be implemented, what controls were to be implemented, when work/rest schedules were to be used, how to determine the appropriate schedule, or when to conduct medical monitoring for heat/cold stress. The plan referred to an appendix that contained a general corporate program for heat stress prevention. The corporate program mandated the development of a written procedure for operating groups, but this was not included in the SSAHP.
The heat stress plan at Site F detailed methods for monitoring worker's heart rate and oral temperature, but did not designate the personnel responsible for performing such monitoring, nor did it include information about the availability or location of instruments for actually monitoring such parameters. In addition, the plan did not identify or discuss the location and availability of drinking water.
The heat and cold stress program in the contractor's SSAHP at Site B appeared to be a statement of corporate policy and contained no details about site-specific heat stress or cold stress program procedures at the site. The SSAHP for Site J did not appear to have established heat stress SOPs, but indicated that workers should evaluate how they were feeling. The SSAHPs for Sites D and I had no discussion of heat stress.
The contractor SSAHP at Site A provided for heat stress monitoring to begin when the temperature rose above 70 degrees F. The OSC at this site indicated that this rarely happens during the summer months, and, thus, heat stress monitoring had not been conducted.
K. Employers must develop and implement training programs to inform workers of the degree of exposure they are likely to encounter and how they should avoid adverse situations.
Employers are required to develop and implement a program to inform workers performing hazardous waste operations of the level and degree of exposure they are likely to encounter. This information needs to be contained in the SSAHP. Employers are also required to develop and implement procedures that introduce workers to the most effective technologies that provide protection in hazardous waste operations. The employer must develop a training program for all employees exposed to safety and health hazards during hazardous waste operations. The training program should educate supervisors and workers to recognize hazards and prevent exposure to the hazards; to properly use and care for respirators and other personal protective equipment; to understand engineering controls and their use; to use proper decontamination procedures; and to understand the emergency response plan, medical surveillance requirements, confined space entry procedures, spill containment program, and any appropriate work practices.
With minor exceptions, contractors at Sites A, C, H, and K had implemented training programs that were generally consistent with the HAZWOPER requirements. Contractor records at Site H indicated that training was not only generally consistent with the HAZWOPER requirements, but was also well documented. At Site A, current 40-hour and 8-hour refresher certificates were available for all onsite workers; however, it was not clear when employees had received three days of supervised field experience as required by the HAZWOPER standard. Additionally, daily safety meetings were conducted at Site A but not documented. At Site K, both contractors appeared to provide training in accordance with HAZWOPER requirements. Records for both contractors indicated that site workers had received 40-hour initial training and 8-hour annual refresher training as appropriate, and project managers for both contractors had received supervisory training. In addition, the prime contractor maintained training records for other subcontractors used on the project, and the SSAHP required daily tailgate safety meetings. The contractor's SSAHP at Site C described the kind and amount of training required for four groups of employees: onsite supervisory personnel, general site workers, workers on site less that 30 days and not likely to be exposed above permissible or other published exposure limits, and nonexposed workers. The training specified for each of these groups was in accordance with HAZWOPER requirements; however, the SSAHP did not specify who provides the training or how its adequacy is verified. In addition to the required training, the SSAHP stated that all employees must participate in tailgate safety meetings at least once per week or before starting a new job or work task.
Other sites provided general provisions for acceptable training programs but lacked the site-specific detail necessary to implement a successful program. For example, the contractor's plan at Site F contained a requirement that all project field personnel receive training in accordance with applicable OSHA standards, including a minimum of 40 hours of hazardous waste operations training. The plan did not contain, however, the details of required site-specific training, such as the safe use of engineering controls and equipment on site. The contractor's SSAHP training program at Site G did not address how employees would be provided with three days of supervised field training as required under the HAZWOPER standard. Instead, site-specific training was provided in a briefing.
Some sites were not providing all training necessary. Contractor training records at Site E indicated, with minor exceptions, that 40-hour HAZWOPER training/refresher training was current for all workers; however, supervisor training was not provided by the corporate office and only one worker, an operations engineer who did not supervise others, had received supervisor training. In addition, the contractor produced no evidence that line supervisors had received at least 8 hours of supplemental supervisor training for hazardous waste supervisors. Contractor training records at Site J showed gaps of several years between initial and refresher training for some employees and no initial training documentation for one employee. Not all employees who performed supervisory duties were documented to have had supervisor training.
The contractor's SSAHP at Site B mandated that all personnel, including subcontractors and visitors, entering the exclusion or decontamination zone meet HAZWOPER training requirements. Forty-hour training was required for personnel entering the exclusion zone, and additional supervisory training was required for site supervisors. The SSAHP also required that documentation of three-day supervised field experience be submitted to the SSO along with other training documents, but the plan did not address how the contractor would provide supervised field experience for employees who had not received such experience or did not have the appropriate certification.
L. A medical surveillance program must be in place to assess and monitor the health and fitness of employees.
A medical surveillance program helps assess and monitor the health and fitness of employees working with hazardous substances.
The contractors at Sites A, E, H, and K and one subcontractor at Site I appear to have established medical surveillance programs that with minor exceptions were consistent with HAZWOPER requirements. Contractor records at Site H indicated that medical tests and procedures included annual examinations that addressed site-specific hazards and were provided with the frequency required by the standard. Records at Site K showed that employees of both contractors had received recent comprehensive medical examinations, and copies of the physician's written opinion were maintained for each employee. These medical records, however, contained no documentation of termination examinations. The project manager at Site K told the audit team that termination exams were made available to employees. At Site I, employee interviews indicated that the subcontractor had implemented a medical surveillance program and that examinations were offered on a schedule consistent with HAZWOPER requirements; however, records were not available for 8 of 14 employees covered by the program. The site manager said that these records were filed at company headquarters.
The contractors at Sites B, C, F, G, I, and J had significant deficiencies in their medical surveillance programs. Medical surveillance practices at Site B were not consistent with the requirements that all employees shall have termination physicals and that the examining physician shall be responsible for determining the need for additional monitoring. The contractor's SSAHP at Site B appeared to require termination physicals for exclusion zone personnel only and allowed the SSO to determine the need for additional monitoring. In addition, the SSAHP did not provide site-specific medical monitoring requirements or the schedule for providing medical exams. The plan did state, however, that all personnel, including subcontractors and visitors, entering the exclusion zone or decontamination zone must have received "appropriate medical monitoring" in accordance with HAZWOPER.
The schedule for providing medical surveillance at Site F did not include the required medical surveillance at termination of employment. At Site J, annual medical exams appeared to have been scheduled and documented appropriately for current employees, but only two termination examinations were documented, despite other known employee turnover discussed in interviews. The contractor's SSAHP at Site C did not describe a site-specific medical surveillance program that reflected site hazards. Sections of the SSAHP dealing with respirator use and heat stress, however, did require employees to be certified for fitness before being assigned to tasks where respirators were required or where heat stress hazards were present. The SSAHP for Site G referenced a corporate medical program that established a recommended content and frequency for medical examinations. The SSAHP, however, did not describe how the content of the medical program related to the employees' jobs, PPE use, health hazards present, or even whether the program was designed based on these considerations, as required in the corporate program. At Site I, the prime contractor had not implemented a medical surveillance program on site, and the project manager was unaware of these HAZWOPER requirements.
The safety and health programs at these sites were generally comprehensive in scope and oriented toward compliance with HAZWOPER and other applicable requirements; however, all lacked the degree of site-specific detail and trained management necessary for an effective safety and health program. The audits revealed consistent deficiencies attributable to a failure to apply professional judgment appropriately and to pay attention to meaningful details. These problems were evidenced in several ways: