Oil spill emergencies may pose safety and health hazards for workers in an impacted area. Workers whose job sites are at or near the site of an oil spill are likely to be among the victims of an incident, or may need to shelter in place or evacuate to safety. Response, cleanup, and recovery workers—particularly oil spill emergency response workers who are trying to stop or contain the discharge of oil —may be at particularly high risk for exposure to health and safety hazards, including fires, oxygen deficiency, exposure to carcinogens, and other chemical hazards, heat and cold stress, safety hazards associated with working around heavy equipment and other hazards when in or around affected areas. Workers and employers of workers in both categories (response workers and all other workers) should be prepared to respond appropriately following an oil spill incident or other emergency situation.
During oil spill emergencies, employers should be prepared to protect emergency response recovery, and cleanup workers from health and safety hazards. This page highlights some of the responsibilities of the employer to ensure adequate management of worker safety and health during oil spill response, recovery, and cleanup operations as well as post-emergency response.
This page is organized by four major sections, with subsections as outlined below:
- OSHA's Role in Emergency Response and Recovery
- Hazard Information
- Exposure Assessment and Monitoring
- Guidance on Selection of Protective Clothing
- Reuse of Personal Protective Equipment
- Use of Respiratory Protection
- Voluntary Use of Respirators
- Medical Surveillance
- Medical Management
During the response to, and recovery from, emergencies or disasters, OSHA helps protect the safety and health of response and recovery workers. In addition to OSHA’s enforcement and compliance assistance activities, OSHA can provide technical assistance and support to federal, state, local, tribal, territorial, and insular area agencies under the National Contingency Plan. The National Contingency Plan section of this webpage provides additional information on this topic.
OSHA recognizes that many employers (plan holders and OSROs) involved in oil spill response, recovery, and cleanup operations make well-considered efforts to protect the health and safety of their workers.
This section provides detailed information on health effects of crude oil and dispersant exposure. Airborne exposure may cause health effects from chemical exposure to fresh crude oil, weathered oil, dispersants, oil/dispersant mixtures, cleaning agents, and other chemicals (e.g., diesel emissions). Employers should evaluate worker exposures and health effects from such chemical hazards across all response activities.
Employers must ensure that Safety Data Sheets (SDSs), are readily accessible to workers for all hazardous chemicals during an oil spill, including the type of crude oil, any dispersant products used, all cleaning products, any pesticides (e.g., wasp/hornet killer), as well as engine oils and lubricants, fuels, and propane gas, if used.
The expandable boxes below provide additional information about three potential chemical hazards:
- Crude oil.
- Dispersants, including mixed exposure to crude oil and dispersants.
- Cleaning agents.
- Crude Oil
Crude oil is a complex mixture of chemical constituents including various alkanes (butane, pentane, and hexane); aromatic hydrocarbons (benzene, ethyl benzene, toluene, and xylenes); cycloalkanes; other nitrogen, oxygen, and sulfur compounds (hydrogen sulfide); and trace metals such as iron, nickel, copper and vanadium. The National Institute for Occupational Safety and Health (NIOSH) Pocket Guide to Chemical Hazards provides more information about these workplace chemicals and their hazards. The NIOSH Pocket Guide to Chemical Hazards is available at: http://www.cdc.gov/niosh/npg/.
Some constituents of crude oil can have significant toxicity. For example, several aromatic hydrocarbons are considered to be hazardous air pollutants (HAPs) and human carcinogens. The International Agency for Research on Cancer (IARC) indicates that for crude oil, there is inadequate evidence for the carcinogenicity in humans, although there is limited evidence for carcinogenicity in experimental animals.1
Hydrocarbon exposure from crude oil constituents will vary based on its exposure to the atmosphere, time in the marine aquatic and coastal environment, treatments with dispersants and interaction of the chemicals, wave action, and heat. Generally, the more “aged” or “weathered” crude oil is (by mixing with seawater and traveling long distances from the source), the lower are the concentrations of volatile organic compounds (VOCs). Although it generates less VOCs, weathered crude oil still contains harmful chemicals that can cause skin irritation and other irritant reactions. Thus, use of gloves and protective clothing is recommended to minimize skin contact with weathered oil, including oil deposited on the shore (“tarballs” or “tarpatties”). Appropriate hand hygiene facilities should be readily available to clean incidental skin exposures.
Weathered crude oil is unlikely to pose an inhalation risk although a potential risk does exist for it to be aerosolized into respirable airborne droplets or volatilized by activities such as pressure washing. Even though detection of hydrocarbon “odors” is common in areas contaminated by crude oil, odor is not a reliable indication of a health hazard. Some individuals, though, are bothered by odors and can develop symptoms (e.g., may report dizziness, nose and throat irritation, headache and/or nausea). These individuals may need medical evaluation when symptoms occur, especially if severe or persistent. Individuals with severe or persistent symptoms should be relocated to perform tasks where symptoms can be alleviated.
Currently, there is an incomplete understanding about the human health toxicity associated with the use of large amounts of dispersant; about the toxicity of the mixed exposure to large amounts of crude oil, dispersants, and combustion products together; and the cumulative effect of such exposures occurring over a long duration. Because knowledge about potential inhalational exposures to the mixed exposure of crude oil, dispersant, and combustion products is incomplete and still evolving, it is prudent to reduce the potential for adverse health effects by the use of engineering controls, administrative controls (including safe work practices), and PPE, including respirators when appropriate.
Aerial and boat spraying are the most common delivery systems for dispersant application.
- Aerial Spraying. Aircraft provide the most rapid method of applying dispersants to an oil spill. For aerial spraying, the dispersant is applied undiluted. Careful selection of spray nozzles is critical to achieve desired dose levels, since droplet size must be controlled.
- Boat Spraying. Dispersant may also be applied by workboats equipped with spray booms mounted ahead of the bow wake. The preferred and most effective method of application from a workboat is to use a low-volume, low-pressure pump so the chemical can be applied undiluted.
- Cleaning Agents
Employers must provide safe working conditions for response, recovery, and cleanup workers using cleaning agents. When cleaning chemicals are hazardous, employers must train workers on safe work practices for using these chemicals. Safe work practices when using cleaning chemicals include:
- Warning workers not to mix cleaning products that contain bleach and ammonia;
- Making sure that workers know which cleaning chemicals must be diluted and how to correctly dilute the cleaners they are using;
- Thoroughly reviewing and training workers on the use, storage, and emergency spill procedures for cleaning chemicals;
- Reviewing the proper PPE needed, such as gloves and goggles, and providing the proper PPE to the workers using the cleaning product;
- Ensuring that all containers of cleaning products and chemicals are labeled to identify their contents and hazards;
- Operating ventilation systems as needed during cleaning tasks to allow sufficient air flow and prevent buildup of hazardous vapors; and
- Providing workers with a place to wash up after using cleaning chemicals.
Worker training must be provided if the cleaning chemicals are hazardous. Training must be provided in a manner and language that workers understand. This training must be provided BEFORE the worker begins using the cleaner. The following are important issues to be discussed with workers during training:
- Never mix different cleaning chemicals together. Dangerous gases can be released.
- Cleaning chemicals should not be used to wash hands. Wash hands with water after working with a cleaning chemical, especially before eating, drinking, or smoking.
The first step in protecting workers from physical hazards is to perform a job hazard analysis (JHA). A JHA focuses on job tasks to identify inherent hazards and implement protective controls. See OSHA’s Job Hazard Analysis page, which provides information for all employers on conducting a systematic hazard analysis.
The expandable boxes below provide additional information about three potential physical hazards:
- Heat stress: from temperature, humidity, or work load.
- Cold stress: from temperature, wind, or cold water immersion.
- Fatigue: from work schedules and hours.
- Heat Stress
Oil spill response, recovery, and cleanup workers may be at significant risk for developing heat stress, depending on the location, working environment, working conditions, and job tasks being performed during the response, cleanup, and recovery operations. Excessive exposure to hot environments can cause a variety of heat-related problems, including heat stroke, heat exhaustion, heat cramps, and fainting. Heat can also increase the risk of injuries in workers from sweaty palms, fogged-up safety eyewear, and dizziness. Protective clothing and other PPE will increase the risk of heat-related problems. PPE should be selected to minimize heat stress on the wearer.
Workers at greater risk of heat stress include those who are 65 years of age or older, are overweight, have heart disease or high blood pressure, or take medications that may be affected by extreme heat. Heat stroke is the most serious heat-related disorder and occurs when the body becomes unable to control its temperature; the body's temperature rises rapidly, the sweating mechanism fails, and the body is unable to cool down. Heat stroke can cause death or permanent disability if emergency treatment is not given.
Employers should note that requiring or allowing workers to use certain types of PPE, particularly dermal PPE, that is not required for their specific job task, will increase the potential for the development of heat stress.
Prevention of heat stress in workers is important. A heat stress program should be developed that includes the following elements:
- A training program informing workers about the effects of heat stress, and how to recognize heat-related illness symptoms and prevent heat-induced illness;
- A heat acclimatization program for new workers or workers returning to work from absences of three or more days;
- Specific procedures to be followed for heat-related emergency situations; and
- Provisions to administer first aid immediately to workers displaying symptoms of heat-related illness.
Additional elements of a heat stress program may include the following:
- Addressing and reducing physical demands on workers;
- Using relief workers or assigning extra workers for physically demanding jobs;
- Providing cool water to workers—avoiding drinks with caffeine, alcohol, or large amounts of sugar;
- Establishing specific work-rest regimens based on the physical demands and environmental heat-related conditions;
- Scheduling work cycles to coincide with cooler temperatures in the day or night;
- Providing cool and shady areas for use during rest breaks; and
- Monitoring workers through a buddy system for signs of heat stress.
Several resources about preventing heat stress are available at the following websites:
- Cold Stress
Workers who are exposed to extreme cold, work in cold environments, have prolonged contact with cold water in rivers, along shorelines, or the ocean, may be at risk of cold stress. Extreme cold exposure, including from water, is a dangerous situation that can bring on health emergencies in susceptible people, such as those without adequate shelter, outdoor workers, and those who work in an area that is poorly insulated or without heat.
What constitutes cold stress and its effects can vary across different areas of the country. In regions relatively unaccustomed to winter weather, near freezing temperatures are considered factors for cold stress. Whenever temperatures drop decidedly below normal and as wind speed increases, heat can more rapidly leave a worker’s body. These weather-related conditions may lead to serious health problems.
- Hypothermia. When exposed to cold temperatures, a worker’s body begins to lose heat faster than it can be produced. Prolonged exposure to cold will eventually use up the body's stored energy. The result is hypothermia, or abnormally low body temperature. A body temperature that is too low affects the brain, making the victim unable to think clearly or move well. This makes hypothermia particularly dangerous because a worker may not know it is happening and will not be able to do anything about it. Symptoms of hypothermia can vary depending on how long a worker has been exposed to the cold temperatures. Early symptoms include shivering, fatigue, loss of coordination, and confusion and disorientation. Late symptoms include no shivering, blue skin, dilated pupils, slowed pulse and breathing, and loss of consciousness
- Frostbite. Frostbite is an injury to the body that is caused by freezing. Frostbite causes a loss of feeling and color in the affected areas. It most often affects the nose, ears, cheeks, chin, fingers, or toes. Frostbite can permanently damage body tissues, and severe cases can lead to amputation. In extremely cold temperatures, the risk of frostbite is increased in workers with reduced blood circulation and among workers who are not dressed properly. Symptoms of frostbite include reduced blood flow to hands and feet (fingers or toes can freeze); numbness; tingling or stinging; aching; and bluish or pale, waxy skin.
- Trench Foot. Also known as immersion foot, trench foot is an injury of the feet resulting from prolonged exposure to wet and cold conditions. Trench foot can occur at temperatures as high as 60°F if the feet are constantly wet. Injury occurs because wet feet lose heat 25 times faster than dry feet. Therefore, to prevent heat loss, the body constricts blood vessels to shut down circulation in the feet. Skin tissue begins to die because of lack of oxygen and nutrients and due to the buildup of toxic products. Symptoms of trench foot include reddening of the skin, numbness, leg cramps, swelling, tingling pain, blisters or ulcers, bleeding under the skin, and gangrene (the foot may turn dark purple, blue, or gray).
Cold water immersion creates a specific condition known as immersion hypothermia. It develops much more quickly than standard hypothermia because water conducts heat away from the body 25 times faster than air. Typically people in temperate climates do not consider themselves at risk from hypothermia in the water, but hypothermia can occur in any water temperature below 70°F. Survival times can be lengthened by wearing proper clothing (wool and synthetics and not cotton), using a personal flotation device (PFD, life vest, immersion suit, dry suit), and having a means of both signaling rescuers (strobe lights, personal locator beacon, whistles, flares, waterproof radio) and having a means of being retrieved from the water.
Prevention of cold stress in workers is important. A cold stress program should be developed that includes the following elements:
- Recognize the environmental and workplace conditions that may be dangerous.
- Learn the signs and symptoms of cold-induced illnesses and injuries and what to do to help workers. Train workers about cold-induced illnesses and injuries.
- Encourage workers to wear proper clothing for cold, wet, and windy conditions, including layers that can be adjusted to changing conditions.
- Be sure workers in extreme conditions take a frequent short break in warm dry shelters to allow their bodies to warm up.
- Try to schedule work for the warmest part of the day.
- Avoid exhaustion or fatigue because energy is needed to keep muscles warm.
- Use the buddy system—work in pairs so that one worker can recognize danger signs.
- Drink warm, sweet beverages (sugar water, sports-type drinks) and avoid drinks with caffeine (coffee, tea, sodas or hot chocolate) or alcohol.
- Eat warm, high-calorie foods such as hot pasta dishes.
- Remember, workers face increased risks when they take certain medications, are in poor physical condition or suffer from illnesses such as diabetes, hypertension, or cardiovascular disease.
Several resources about preventing cold stress are available at the following websites:
- Fatigue Prevention
Oil spill response, recovery, and cleanup workers often work longer shifts and more consecutive shifts than the typical 40-hour work week. Working longer hours may increase the risk of work injuries and accidents and can contribute to poor health. Fatigue and stress from strenuous work schedules can be compounded by heavy physical workloads, unfavorable environmental conditions (e.g., damaged infrastructure, hazardous materials and debris, sparse living conditions), long commutes, and personal demands on workers.
Crashes are the leading cause of death for oil and gas extraction workers. CDC’s fact sheet titled, Oil and Gas Workers: How to Prevent Fatigued Driving at Work, gives workers information about fatigue and tips to stay safe behind the wheel. CDC also has a fact sheet for employers titled, Oil and Gas Employers: How to Prevent Fatigued Driving at Work, with recommended strategies on how to manage fatigued driving among their workers.
Employers (plan holders and OSROs) involved in oil spill response, recovery, and cleanup operations should have management plans in place to minimize fatigue risks, recognize hazards, and provide regular opportunities for worker rest and recovery. The National Response Team (NRT) has prepared guidance and checklists for managing fatigue during disaster recovery operations.
Employers should consider the following general guidelines:
- Regular Rest: Establish at least 10 consecutive hours per day of protected time off-duty in order to obtain 7-8 hours of sleep. Rest and a full complement of daily recovery sleep are the best protections against excessive fatigue in sustained operations. Allowing only shorter off-duty periods (e.g., 4-5 hours) can compound the fatigue of long work hours.
- Rest Breaks: Frequent brief rest breaks (e.g., every 1-2 hours) during demanding work are more effective against fatigue than a few longer breaks. Allow longer breaks for meals.
- Shift Lengths: Five 8-hour shifts or four 10-hour shifts per week are usually tolerable. Depending on the workload, 12-hour days may be tolerable with more frequent interspersed rest days. Shorter shifts (e.g., 8 hours), during the evening and night, are better tolerated than longer shifts. Fatigue is intensified by night work because of nighttime drowsiness and inadequate daytime sleep.
- Workload: Examine work demands with respect to shift length. Twelve-hour shifts are more tolerable for “lighter” tasks (e.g., desk work). Shorter work shifts help counteract fatigue from highly cognitive or emotionally intense work, physical exertion, extreme environments, or exposure to other health or safety hazards.
- Rest Days: Plan one or two full days of rest to follow five consecutive 8-hour shifts or four 10-hour shifts. Consider two rest days after three consecutive 12-hour shifts.
Workers may experience stress and fatigue when they respond to both natural (e.g., earthquakes, hurricanes) and manmade environmental disasters (e.g., oil spill emergencies). Risk assessments conducted by employers should also evaluate oil spill response, recovery, and cleanup worker’s mental and emotional health. The expandable box below provides additional information about traumatic incident stress.
- Traumatic Incident Stress Prevention
Oil spill response, recovery, and cleanup workers are at risk of feeling uncomfortable levels of stress from what mental health professionals refer to as a traumatic incident. The term traumatic is used because of an unexpected and troubling change in the natural order of things, such as the untimely death or injury of oil-covered wildlife and the impact on fishing communities and the environment. It is important that employers and workers monitor workers’ health and well-being throughout their activity periods for response, recovery, or cleanup work, and even months after their work has ended.
Evaluation criteria for traumatic incident stress hazards may include physical complaints; thinking problems (e.g., inability to concentrate); and changes in behavior, mood, and irritability. Employers should ensure that workers maintain adequate nutrition, hydration, and rest to alleviate risks to mental and emotional health. Workers can also work in pairs to look out for each other using a buddy system.
Recommendations to help manage worker stress and fatigue during and after oil spill response, recovery, and cleanup operations can be found on the following websites:
- Psychological Resiliency
The Additional Resources page includes a section with selected information on psychological resilience for emergency response, recovery, and cleanup workers. See the Psychological Resilience During an Emergency Response section.
Workers’ Rights and Employers’ Responsibilities
Section 11(c) of the OSH Act, 29 USC 660(c), prohibits employers from retaliating against workers for raising concerns about safety and health conditions. Additionally, OSHA’s Whistleblower Protection Program enforces the provisions of more than 20 industry specific federal laws protecting employees from retaliation for raising or reporting concerns about hazards or violations of various airline, commercial motor carrier, consumer product, environmental, financial reform, food safety, health insurance reform, motor vehicle safety, nuclear, pipeline, public transportation agency, railroad, maritime, and securities laws. OSHA encourages workers who suffer such retaliation to submit a complaint to OSHA and should contact OSHA as soon as possible in order to file their complaint within the legal time limits, some of which may be as short as 30 days from the date they learned of or experienced retaliation. An employee can file a complaint with OSHA by visiting or calling his or her local OSHA office, sending a written complaint via fax, mail, or email to the closest OSHA office, or filing a complaint online. No particular form is required and complaints may be submitted in any language.
An oil spill emergency response should include a coordinated, comprehensive, and routine air sampling plan for all response worksites among the responsible party and those government agencies and NGOs (and their contractors) that are conducting sampling activities. A comprehensive exposure assessment of response work activities involves evaluation of multiple different work settings, each with its own set of exposure variables. These work settings involve changing weather conditions, various types and amounts of VOCs being released, work tasks resulting in potential skin and inhalational exposures, and exposure to wildlife and physical hazards, such as heat, snakes, and insects. Some response workers may be engaging in activities that may be unfamiliar, thus increasing the potential for injury or exposure.
Respiratory protection precautions are necessary for uncharacterized chemical exposures until the need for such precautions has been ruled out by comprehensive assessment of exposures to toxic chemical agents during work activities under a variety of relevant conditions. Quantitative methods for area and personal breathing zone sampling should follow an approved, standardized, and representative air sampling plan coordinated among the responsible party and all government agencies and NGOs (and their contractors) that are conducting sampling activities. Routine, ongoing exposure assessment should continue as part of a comprehensive worker safety and health program.
Occupational Exposure Sampling
Samples should be collected to characterize all work operations involved in the oil spill response, recovery, and cleanup operations. For a large oil spill or a SONS sampling strategy, if appropriate, job tasks could be separated into general zones of work activities, such as off-shore, near-shore, and on-shore operations.
Table 5 provides examples of air sampling activities that could be included in a sampling strategy for an oil spill emergency. A sampling strategy may include the types of samples listed below:
- Personal Samples: may involve direct reading instruments and perform full-shift sampling in the actual breathing zone of workers.
- Area Samples: perform sampling in areas that are periodically frequented by workers but the samples are not taken from the breathing zone of workers.
- Bulk Samples: perform, if possible, at each location sampled (e.g., using a glass vile).
- Direct Reading Samples: perform sampling directly over locations (e.g., inside bags of contaminated materials) that do not represent worker exposure but provide information on the types of chemicals that may be coming off contaminated materials.
Oil spill response, recovery, and cleanup workers may need a variety of PPE. Administrative controls and engineering controls should be utilized first to minimize the need for PPE in any particular job. Where such controls will not effectively minimize the exposures, then PPE will be necessary. Appropriate selection of PPE begins with answering two questions:
- What are the hazards faced by a worker or volunteer in a particular job?
- What is the anticipated level of hazard exposure for a worker or volunteer in doing that job?
Crude oil and its constituents, as well as oil dispersants, can cause skin irritation and inflammation. OSHA recommends avoiding all unprotected skin and eye contact to crude oil, dispersants, and other chemicals used during oil spill emergencies. PPE to prevent skin contact must be selected carefully for use in a hot, wet environment. Skin damage due to chaffing from increased sweating, coupled with the mechanical stress of ill-fitting PPE, can compromise the skin’s natural barrier against bacteria. In addition, the use of sunscreen, shaded safety glasses, and wide-brimmed hats are recommended in a hot, wet environment.
For many response tasks, gloves, protective clothing, and protective footwear will be necessary. Several types of materials are capable of protecting against crude oil, including those made from neoprene, nitrile and butyl rubber, as well as other commercially available products. PPE should be evaluated before purchase and use by contacting the manufacturer to be sure it has barrier performance against the expected exposures. For eye/face protection, safety glasses, safety goggles, or face shields may be required depending on the specific work activity.
Information is available in the American Petroleum Institute (API) Recommended Practice 98, Personal Protective Equipment Selection for Oil Spill Responders, First Edition, August 2013.2
The expandable boxes below provide additional information about:
- Guidance on Selection of Protective Clothing
- Reuse of Personal Protective Equipment
- Use of Respiratory Protection.
- Voluntary Use of Respirators.
- Guidance on Selection of Protective Clothing
The selection of adequate chemical and flame resistant protective garments includes determining whether the fabric, seams, and design are appropriate and sufficiently protective. The selection must be based on expected exposure and verified by field audits and changed if the selected PPE does not perform adequately. The potential for contribution to heat stress or cold stress must also be considered in the selection of protective clothing, in addition to the potential exposure to fire, water, oil and tar, and other chemicals.
In general, overprotection from chemical and fire exposure generally creates a greater potential for heat stress. Partial body garments such as aprons and sleeves may be used to help reduce the risk of increased heat stress where the potential for heavy exposures to certain parts of the body is limited and hygiene facilities to handle incidental exposures exist. Evaluate the job to determine where it is feasible to use lower levels of PPE to reduce potential heat stress.
Selection of Fabric
When exposures may require repulsion of droplets of oil, repellant-treated fabrics should be used. Some treated fabrics will become oil soaked when subjected to higher quantities of liquid oil under pressure. Coated fabrics generally offer a higher level of barrier to liquid oil and are divided into two categories—impermeable and selectively permeable barrier materials or fabrics. Both types will provide a physical barrier to liquid and solidified oil. These fabrics come in a range of weights and durability.
Full body garments made from impervious film fabrics have higher potential for heat stress. Microporous film fabrics often use thin films to achieve high moisture transport. These products may be easily abraded and damaged, thus compromising the barrier protection of the fabric. Uncoated or permeable fabrics, spun-bonded polypropylene and polypropylene SMS (spunbond/meltblown/spunbond), will, in general, absorb or allow penetration of oil but typically result in lower heat stress for the wearer.
Garments made with permeable fabrics should be considered in situations where little or no liquid oil contact is expected, such as removing tar balls from the beach. Partial body garments, such as sleeves and aprons worn over these garments, can provide added barrier protection in areas of the body where greater exposure is expected or observed. Partial body garments can be made from the same impermeable fabrics or from impervious film fabrics. Flame resistant clothing should be selected in accordance with 29 CFR 1910.132, the General Industry Standard for PPE.
Selection of Seams
Taped and welded seams are appropriate when the seams will come into contact with liquid chemicals under pressure or when there is sufficient liquid to form pools, puddles, or run-off on the garment. Garments made from impervious film fabrics should have welded or taped seams to prevent liquids from entering through the seams when significant contact with liquids is expected. Sewn, serged, or bound seams without sealing tape should be considered only in situations that involve minimum liquid volumes and minimum contact pressure. Sewn, serged, or bound seams are normally found on most garments made from uncoated fabrics, microporous film fabrics, and some garments made with lightweight impervious film fabrics.
Selection of Design
The most common form of chemical and flame resistant clothing is the coverall. However, full body protection can also be obtained with the combination of jacket and bib overalls, or a shirt and pants combination. The protection provided by the garment closure and interface areas between garments should be considered when selecting PPE. Closures and interface areas (i.e., glove to jacket) provide a potential point of entry for hazards. If significant liquid contact is expected, the closure and interface areas should be minimized and provide the same level of protection as the rest of the garment. If less than full body protection is acceptable, partial body garments present a significantly lower heat stress impact than full body coveralls. Many job activities are associated with oil spill responses where the worker will have localized exposure to contaminated materials or fire. Partial body garments, such as sleeves, aprons, pants, and shirts, can help protect those parts of the body that will be potentially exposed, such as forearms, front of the body, or legs.
Note: Workers should remove gloves, and any other PPE that could contaminate food or drink, and thoroughly wash their hands with soap and water before eating. Workers should also remove all PPE before leaving the contaminated area at the end of the shift to reduce take-home exposure.
- Reuse of Personal Protective Equipment
Consult the manufacturer’s instructions on whether PPE should be disposed of or cleaned after use. If it can be cleaned, consider whether any special procedures are required for disposal of the decontaminated waste. Tears, rips, pinholes, and other damage can result in penetration of the crude oil or other contaminants through the PPE. When damage is present, the PPE should generally be replaced because repair is often impractical.
Protective Clothing and Gloves
All chemicals including crude oil can be expected to permeate through protective barriers eventually over time. Permeation can take place without visible evidence in the protective materials. Many manufacturers of PPE, in particular, manufacturers of gloves, will provide information on breakthrough times from various chemicals (time it takes for the chemical to pass through the protective material). The PPE will need to be removed and discarded prior to the breakthrough time. Users should consult with the specific manufacturer to confirm the performance of their product.
In oil spill emergencies under warm and humid conditions, disposable filtering facepiece respirators will likely need to be discarded after several hours of use, in part because they will become moist with perspiration. These respirators should be discarded and replaced if they are soaked, contaminated, damaged, or hard to breathe through. For intermittent use of disposable filtering facepiece respirators, they may be stored in a clean, breathable container, such as a paper bag between uses. Disposable filtering facepiece respirators must be used only by a single wearer. Elastomeric respirators can be cleaned, disinfected, and reused. Specific information on cleaning re-usable respirators can be found in the OSHA Respiratory Protection Standard, Appendix B-2 to 29 CFR 1910.134: Respirator Cleaning Procedures (Mandatory).
- Use of Respiratory Protection
A decision to use respiratory protection should be based on the best available qualitative information using the expert opinion method and on the best available comprehensive quantitative information about the type and level of exposure to toxic chemical and physical agents via inhalation. The use of effective engineering and administrative controls, and other PPE should be implemented before considering the use of respirators for worker protection.
When respiratory protection is required, a complete respiratory protection program must comply with OSHA’s Respiratory Protection Standard (29 CFR 1910.134). See OSHA’s Respiratory Protection Safety and Health Topics page for more information. Elements of a respiratory protection program include training, fit testing, medical clearance, change-out schedule, and respirator cleaning, maintenance, and inspection procedures.
- For authoritative information from a trusted source to verify which respirators are approved by NIOSH, how to get them and how to use them, see the NIOSH Respirator Trusted-Source Web page at http://www.cdc.gov/niosh/npptl/topics/respirators/disp_part/RespSource.html#sect1.
- For additional information on NIOSH-approved respirators, see http://www.cdc.gov/niosh/topics/respirators/.
- For information on chemical hazards, see the NIOSH Pocket Guide to Chemical Hazards, which can be found at http://www.cdc.gov/niosh/npg/.
The subsections below are provided as examples only. See the Additional Resources page for more information about respiratory protection for oil spill emergencies.
Source Control Activities
The source control vessels conduct activities closest to the area where crude oil appears on the surface, including drilling relief wells, conducting underwater operations at the source including dispersant application, and providing support and supplies. If surface application of dispersant is deemed necessary, it should be applied at a safe distance from vessels operating in the area. Variable concentrations of hydrocarbons are likely present in the air in and around these vessels. Engineering and administrative controls should be used to control hydrocarbon vapor levels during source control activities, but exposures to crude oil-derived VOCs and other constituents may not be eliminated entirely. Significant spikes in concentrations may occur unexpectedly, and would necessitate donning a respirator especially when engineering and administrative controls cannot provide protection.
For workers involved in source control activities, respirators should be used in those situations where potentially excessive exposure is reasonably anticipated or where indicated by exposure assessment or where symptoms/health effects are being reported. Where eye protection is not needed against irritating gases/vapors, OSHA recommends using a half facepiece respirator. If eye protection is needed, OSHA recommends a full facepiece elastomeric respirator with an organic vapor/P100 cartridge. A full facepiece respirator provides eye protection against irritating gases/vapors and a relatively high level of respiratory protection when exposures are variable and potentially higher. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination organic vapor/P100 cartridge provides comprehensive protection against both particulates and gases and vapors, and the P100 filter provides some protection against water mist for the organic vapor filter component.
Off-Shore Activities: Vessels Involved in Burning Crude Oil
Vessels involved in crude oil burning are exposed to crude oil/dispersant that is less aged and may emit more VOCs than crude/dispersant closer to shore that may have undergone more weathering. The primary hazards from in-situ burns are likely to be heat, exposure to products of combustion and, rarely, flash fire. Some vessels engaged in burning may be working in close proximity to source control activities.
Products of combustion will include a complex mixture of particulate matter, smoke and soot; VOCs such as partially oxidized alcohols, aldehydes, and ketones; metals such as vanadium, chromium, and nickel; and gases such as carbon dioxide and carbon monoxide. The chemical composition of these emissions will vary based on the oil composition, weather conditions during each burn, and the completeness of the combustion process. When in-situ (i.e., on-site) burns are conducted, they should be conducted remotely with all vessels positioned upwind at an adequate distance away from the resultant smoke plume. Every effort should be made to keep workers from the area of the smoke plume, and to evacuate them as quickly as possible when changing conditions may put them in the area of the contaminants of the burn.
Under ideal conditions, vessels will be located a sufficient distance upwind from burns, and respiratory protection may not be necessary. The employer should assess the specific job tasks before the burning activity to evaluate potential worker exposures and then select respiratory protection and other PPE according to the results of their evaluation. Respiratory protection will be needed, however, when the wind direction changes, causing exposure to the combustion products in the plume. Under such circumstances, or where symptoms/health effects are being reported, inhalational exposure may occur; therefore, OSHA recommends respiratory and eye protection.
In conjunction with an immediate evacuation protocol, NIOSH-approved escape respirators may be used in response to unanticipated exposure events. The rated duration of the escape respirator provided to each occupant should be no less than the employer's determination of the reasonable time for egress to refuge quarters or to maneuver the vessel to clean air. The NIOSH-approved protections for the escape respirators must include organic vapors (OV) and particles (P100 or HE). Escape respirators should be cached to provide workers with immediate access to the units. Once the escape respirator is donned, all production tasks in progress should be discontinued, and workers should be evacuated to designated refuge locations, and the vessels should be maneuvered to avoid further exposure. Work should not resume until the cause of the event has been investigated and the caches of escape respirators restocked.
If protection is required during continuing operations, a full facepiece elastomeric respirator or a powered air purifying respirator (PAPR) with a loose-fitting hood can be used. The units should be equipped with cartridges for OV and particles (P100 or HE). A full facepiece respirator or a PAPR with a loose fitting hood are preferred because they provide both eye protection against irritating smoke and an appropriate level of respiratory protection. Cartridges including P100 particulate filters (oil resistant) are recommended over N95 filters (not resistant to oil aerosols). The combination OV/P100 cartridge provides comprehensive protection against soot, gases and vapors. Another means of protection is non-vented safety goggles to prevent eye irritation and a half-mask respirator with an organic vapor/P100 cartridge.
Note: Flame resistant clothing will help protect workers, for instance, such as those workers in the igniter boat during in-situ burning. The clothing should be cleaned, maintained, and regularly inspected in accordance with the manufacturer’s instructions. Some flame resistant clothing may lose its protective qualities after repeated or improper cleanings. Wearing any flammable clothing over flame resistant clothing will negate the flame resistant protection. Flame resistant clothing should be selected in accordance with 29 CFR Subpart I (Personal Protective Equipment), Section 1910.132, General Requirements.
Off-Shore Activities: Vessels Not Involved in Source Control or Burning
Some vessels operating off-shore engage in deployment of containment and sorbent booms, skimming operations to remove oil from the water, and dispersant application. These vessels are not involved in burning nor are they located in close proximity to in-situ burning. Generally, these vessels have contact with oil that has weathered, and, as such, does not emit significant amounts of VOCs. Respiratory protection generally will not be necessary as symptoms/health effects are not expected to occur in this setting. Dermal protection is needed.
Other vessels not involved in burning may operate at a farther distance from shore and possibly encounter more volatile crude. In this case, administrative controls (e.g., worker rotation and decrease in work hours) and respiratory protection (e.g., half-mask elastomeric respirator with an organic vapor cartridge) should be implemented where symptoms/health effects are being reported.
Note: Representative and routine air and personal breathing zone monitoring should be conducted to verify that unsafe exposures are not occurring, especially when these vessels operate in areas where partially weathered crude oil exist.
Shoreline Clean-up Activities
The types of activities associated with shoreline cleaning include manual removal of “tarballs” or “tarpatties,” shovel removal of oiled-contaminated sand, low pressure flushing, manual sorbent application, and manual cutting of vegetation. The more “aged” or “weathered” crude oil is, the lower the concentrations of VOCs. However, if symptoms/health effects occur, the affected worker(s) should be removed and evaluated medically, and the worksite should be assessed for potential exposure to heat and VOCs for the remaining workers. Weathered crude oil contains harmful chemicals that can cause skin irritation and other irritant reactions. Thus, gloves and protective clothing, and appropriate hand hygiene facilities are recommended.
If high pressure washing is conducted, aerosolization of oil mist into respirable droplets could occur and respiratory protection is recommended with use of at least the level of a disposable P100 filtering facepiece respirator. The use of highly concentrated detergents, degreasers, and solvents, and the use of heated water during pressure washing, may volatilize hydrocarbons and result in the need for respiratory protection. Respiratory protection, if deemed necessary by professional judgment and/or air monitoring results, should include the use of a combination organic vapor/P100 cartridge half-mask respirator. Eye and skin protection during such activities also will be necessary.
- Voluntary Use of Respirators
Even when comprehensive and routine air monitoring indicates that no inhalational hazard exists, an employer may permit respiratory protection to be worn voluntarily by employees provided it will not in itself create a hazard. See the OSHA Respiratory Protection Standard (29 CFR 1910.134). Employers or volunteer organizations who supply respirators for voluntary use must provide oil spill response, recovery, or cleanup workers with the information in the OSHA Respiratory Protection Standard, Appendix D to 29 CFR 1910.134 (Mandatory) Information for Employees Using Respirators When Not Required Under Standard.
More information for workers on an employer's responsibilities under OSHA's respiratory protection voluntary use requirements is available at: Transcript for the OSHA Training Video and https://www.osha.gov/video/respiratory-protection/voluntary-use.
The Use of Respiratory Protection section above provides information about those exposure situations where OSHA recommends the use of respiratory protection during oil spill response, recovery, and cleanup.
Workers Bothered by Odors
During the Deepwater Horizon response in 2010, NIOSH and OSHA developed interim guidance that included one situation where voluntary use of respirators may be helpful is when an individual is bothered by non-hazardous levels of hydrocarbon odor and cannot be relocated to another work area. In that case, a carbon-impregnated odor-reduction filtering facepiece respirator may provide some odor reduction potential—and can be worn voluntarily without the employer having to implement a respiratory protection program. These types of respirators do not provide health protective effects; they only provide odor reduction. In addition, all respirators have adverse effects on breathing, vision, and communication, result in some discomfort, and are associated with additional physiological stress.
The employer’s site-specific Health and Safety Plan (HASP) should include decontamination activities that are part of response, recovery, and cleanup operations. See the HASP section of the Preparedness page for more information about HASPs.
PPE and Other Equipment
Vessels, PPE, and other equipment may become contaminated with weathered oil. Respiratory protection is generally not necessary for decontamination activities, although other PPE, including dermal, eye, face protection, and protective footwear is necessary.
If a high pressure washing mechanical sprayer is used to decontaminate PPE and other equipment, aerosolization of oil mist into respirable droplets could occur. When there is potential exposure to oil mist, particulate respiratory protection of at least the level of a P100 disposable filtering facepiece respirator is recommended in addition to skin, eye, face protection, and protection footwear, particularly if highly concentrated detergents, solvents, or degreasers are used.
Cleaning and caring for birds, turtles, and other wildlife may generate aerosols of water, crude oil, soap, ammonia, and other chemicals. Eye and face protection, in addition to skin protection, is recommended. When irritating concentrations of ammonia are experienced, dilutional ventilation, for example, by means of fans and other means to increase air exchange, is recommended.
Recommended PPE includes eye protection (i.e., safety glasses, goggles, face shields). Birds will peck under stress and may aim for the eyes. Eye protection is also necessary to protect against large droplet sprays from struggling birds. Oil-resistant outer protective clothing is recommended. An oil-resistant gown may provide sufficient upper body protection, avoiding the need for coveralls. Gloves that are oil resistant and provide protection against pecking, biting, and sharp talons are recommended. Non-skid footwear or boots that are oil-resistant and waterproof are also recommended. Respiratory protection is not generally recommended, unless wildlife is heavily coated with fresh crude oil. In such cases, a half-mask respirator with an organic vapor cartridge is recommended.
Employers (plan holders and OSROs) involved in oil spill response and recovery must implement medical evaluations for workers under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR 1910.120(f). For more information, see OSHA's HAZWOPER Safety and Health Topics page.
OSHA's HAZWOPER standard (29 CFR 1910.120(f)) requires that employers make medical exams available to covered workers at a reasonable time and place prior to employment, periodically (at least once every 12 months), and at the termination of employment or reassignment to a non-covered position. Workers covered by this provision include:
- Workers who are or may be exposed to hazardous substances or health hazards at or above the established PEL, or if there is no PEL, above published OELs for these substances, without regard to the use of respirators, for 30 days or more a year;
- All workers who wear a respirator for 30 days or more a year or as required by 29 CFR 1910.134;
- All workers who are injured, become ill or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards from an emergency response or hazardous waste operation; and
- Members of HAZMAT teams.
Table 6 summarizes specific HAZWOPER medical surveillance provisions. In some cases, employers may also be required to comply with medical surveillance provisions of other OSHA standards. Employers and workers may refer to the OSHA Resources page for links to additional relevant standards, standard interpretations, and enforcement directives.
- Emergency Responder Health Monitoring and Surveillance System (ERHMS)
NIOSH along with the NRT and other interagency collaborators at the state and local levels developed the Emergency Responder Health Monitoring and Surveillance System (ERHMS). The ERHMS was developed based on lessons learned from health monitoring and surveillance for emergency response workers (including police, fire, and emergency medical personnel, as well as public health personnel and cleanup/repair/restoration/recovery workers) during the Deepwater Horizon Oil Spill and Hurricane Katrina responses.
The three phases in ERHMS are:
Pre-Deployment Phase: Rostering and credentialing of emergency response and recovery workers maintains accountability and supports four functions designed to co-operate with one another. These activities include: recording basic and credential information on the worker (registration); assigning a credential level based on responder certification and education (emergency credentialing); regularly confirming responder information (re-verification; assigning an identification badge in accordance with credential level (emergency badging).
Deployment Phase: This phase consists of worker identification, accountability, and tracking. When the level of response is greater than the capabilities of the first tier of local responders, keep a roster to track everyone who reports to the disaster site and is involved in response or remediation work. The Logistics function of the Incident Command System (ICS) is responsible for collecting this information into a comprehensive rostering system. Site-specific training is required and must occur before responders enter a designated disaster control zone (see OSHA HAZWOPER standard (29 CFR 1910.120). Site-specific training and training materials should be able to meet expected and unexpected biological health and safety hazards onsite.
Post-Deployment Phase: An out-processing assessment is the minimum post-deployment evaluation that should be conducted for responders. Out-processing assessments are conducted to determine if responders have been adversely affected by their deployment duties and to what extent.
For more information on ERHMS, see:
Workers are urged to report any symptoms they associate with their oil spill response, recovery, or cleanup work to their employer, their physician, poison control center, state or local health department or a local health facility. Symptoms reported from excessive exposure to crude oil or dispersants commonly include eye, nose and throat irritation; headache; dizziness; upset stomach; and cough or shortness of breath.
Workers are urged to seek medical attention for any symptoms they associate with response recovery, or cleanup work. Workers should also have immediate access to medical care provided by licensed healthcare professionals with appropriate expertise. All medical conditions should be assessed for work-relatedness of the illness or injury.
A comprehensive worker safety and health program should have a system for reporting symptoms, near-misses, injuries, and illnesses, and workers should be encouraged to report these occurrences. Symptoms, near-miss, illness, and injury data should be analyzed to assess real-time trends so that preventive actions can be taken to prevent similar occurrences. This information is also useful in evaluating the potential for long-term health effects. Symptoms, near-miss, illness and injury data should be readily available to all partners and stakeholders involved in the oil spill, including state and local health officials, as well as the general public.
NIOSH Medical Pre-Placement Evaluation for Workers Engaged in Deepwater Horizon Response
For the Deepwater Horizon response, NIOSH developed recommendations for pre-placement medical evaluations for workers or volunteers, which are available at: http://www.cdc.gov/niosh/topics/oilspillresponse/preplacement.html. Those NIOSH recommendations were not intended to replace existing medical evaluation programs required under HAZWOPER. The NIOSH recommendations were designed to:
- Provide healthcare professionals with guidance on the important elements of a pre-placement evaluation;
- Assist healthcare professionals in identifying (a) workers with health concerns that need to be addressed, (b) workers that may have specific susceptibilities for whom activities may need to be restricted or modified, and (c) workers with medication, immunization, or training needs; and
- Provide valuable information to the worker on his/her health status and the potential demands of the oil spill work they are undertaking.
1 Interagency Agency for Research on Cancer, Crude Oil, IARC Summary and Evaluation, Volume 45, 1989 http://www.inchem.org/documents/iarc/vol45/45-02.html.
2 Available online from www.api.org/pubs.