Seven Steps to Successful Safety and Health
Programs at Superfund Sites:
A Compendium of Lessons Learned
by Mary Ann Garrahan. This report was published in OSHA's Job Safety and Health Quarterly, Volume 5 Number 2, Winter 1995.
In 1992, OSHA joined forces with the Environmental Protection Agency's (EPA) Office of Emergency and Remedial Response to review health and safety programs and practices at Superfund1 sites where thermal treatment technology is used. At a thermal treatment site, a controlled heat system drives off or thermally destroys hazardous waste. Thermal treatment systems can be high-temperature (incinerators) or low-temperature systems (organic volatilization facilities). They are widely used to treat soil or sludge contaminated with organic materials or pesticides.
Through an interagency agreement, the EPA-Labor Superfund Safety and Health Task Force has sponsored teams of OSHA professionals to audit or inspect more than 10 sites across the country. As senior industrial hygienist in the Office of Health Compliance Assistance, I am OSHA's representative on the task force and put together the audit teams. Earl Cook of the OSHA Health Response Team in Salt Lake City serves as team leader. The team is generally made up of OSHA safety and health professionals from the OSHA Salt Lake City Technical Center and the region in which the site is located, with support from OSHA's Office of Engineering and Construction and an OSHA contractor, Meridian Research, Inc.
The audit team focuses on the implementation of and compliance with OSHA's standard on Hazardous Waste Operations and Emergency Response (29 CFR 1910.120) or HAZWOPER. The team also examines each facility's overall safety and health program and the standard operating procedures associated with thermal treatment.
Now, more than 2 years into the project, patterns of safety and health program deficiencies have emerged.
Although there is widespread awareness of OSHA's HAZWOPER standard and most contractors and subcontractors prepare written safety and health plans, essential site-specific details frequently are not addressed and implementation and evaluation of written plans often is lacking.
The following list of safety and health concerns is a summary of the program management problems most frequently noted during audit team inspections. These are the things that employers and employees should look for to develop safety and health programs that will provide more effective worker protection at Superfund sites.
The contract must allow effective, site-specific management of safety and health
At several sites visited by the audit team, contract specifications bound contractors to safety and health procedures that were later found by OSHA and the contract-issuing agency (usually the EPA or the Army Corps of Engineers, managing the project for EPA) to be unsuited to site hazards.
For instance, at one site, contract requirements limited sampling to contaminants specified in the contract even though evidence of the presence of other hazardous substances was found during site operations.
At another site, the contract required the use of full-face air-purifying respirators despite the fact that sampling results collected during site operations did not reveal airborne levels of site contaminants.
New exposures or unanticipated levels of exposure-- either high or low-- may necessitate procedural changes in sampling, personal protective equipment (PPE), or medical monitoring for effective hazard control. In such cases, the latitude to change PPE requirements or otherwise reduce control measures can be as important to worker protection and program effectiveness as the authority to increase control levels. Contracts must provide the contractor's safety and health personnel the flexibility to establish and modify site safety and health procedures throughout site operations based on existing and anticipated hazards.
Contracts must provide the contractor's safety and health personnel the flexibility to establish and modify site safety and health procedures throughout the site operations based on the existing and anticipated hazards.
The contractor must designate a safety and health supervisor who has the authority to manage site safety and health procedures and is qualified to do so
Conditions can change rapidly or unexpectedly at hazardous waste sites; modifications to safety and health procedures may be necessary to ensure employee protection. Site safety and health supervisors must be sufficiently knowledgeable to interpret and use site data to make safety and health decisions. These personnel also must have the authority to make such decisions and this authority must be clearly established in the safety and health plan.
At several audited sites, the contractor's original written plan called for inappropriately stringent PPE requirements and safety and health supervisors enforced them even though subsequent sampling results showed that lower levels of PPE could be used. In some cases, this was due to a lack of delegated authority, but at other sites, safety and health supervisors appeared to lack the experience and professional judgement necessary to make indicated changes. At one site, the safety and health supervisor was unavailable to oversee site procedures, having been allowed to go on vacation without a qualified replacement.
If site safety and health matters are to be well-managed, site safety and health supervisors must be qualified, available, and authorized to implement effective safety and health procedures.
Although boiler-plate documents may be a useful starting point for site-specific plans and may ensure that each HAZWOPER paragraph is addressed, it is important that the final plan identify the actual hazards present on the site as well as the specific workplace controls and procedures needed to protect against those hazards.
Written safety and health plans must be site-specific
In any job, identifying associated hazards is the first step in safe and healthful operations. Each job presents its own unique set of hazards based on the physical conditions present and the tasks to be accomplished.
Despite these site-specific variations in hazards, many of the safety and health plans reviewed by the audit team appeared to be boiler-plate documents. Rather than dealing with the specific hazards, tasks, and safety and health procedures applicable to the site, the plans often contained generic guidance on safety and health topics. Sections on decontamination, spill containment, confined space, medical surveillance, and heat stress commonly reflected this approach. Detail also was lacking in job hazard analyses; the plans overlooked many site tasks and their associated hazards, such as equipment maintenance activities.
Although boiler-plate documents may be a useful starting point for site specific plans and may ensure that each HAZWOPER paragraph is addressed, it is important that the final plan identify the actual hazards present on the site as well as the specific workplace controls and procedures needed to protect against those hazards.
OSHA's work zone requirements are intended to contain and reduce hazardous exposures. When establishing and maintaining work zones, there should be procedures to take into account changing site operations or weather conditions.
Site work zones must isolate hazards
The audit team frequently found that work zones were configured more for ease of operations than for hazard isolation. For example, at one site, trailers were designated as clean areas to accommodate the project's administrative needs despite the fact the trailers were adjacent to a contaminated area and sample results indicated contamination had spread from the contaminated area into the trailers. On the same site, all roads were designated as clean areas, allowing unimpeded movement of site equipment, even though much of that equipment moved into and between exclusion zones without undergoing decontamination.
On most audited sites, the use of a contamination reduction zone (CRZ), providing a buffer between contaminated and clean zones, was rare except for personnel decontamination areas.
OSHA's work zone requirements are intended to contain and reduce hazardous exposures. When establishing and maintaining work zones, there should be procedures to take into account changing site operations or weather conditions. Where chemical hazards can be carried from one part of the site to another via dust particles, clothing, equipment, or water run-off, and where heavy equipment must move between zones and onsite roads, the use of a CRZ is essential to decontaminate equipment and personnel and prevent the transfer of contamination to clean areas. The size of the CRZ is determined by the area needed to decontaminate workers and equipment and the distance necessary to prevent physical transfer of hazardous substances from the contaminated areas to clean areas.
Within all work zones, hazard levels should be measured and documented on an ongoing basis to ensure the effective establishment of boundaries.
The effectiveness of site safety and health procedures must be evaluated and documented
After writing and implementing the site safety and health plan, its effectiveness must be monitored throughout the duration of the project. Required elements of the plan must include provisions to evaluate the effectiveness of program elements such as PPE, decontamination, and housekeeping; to correct identified deficiencies; and to update workplace procedures.
Many sites fall short on these requirements. For example, some audited sites documented safety and health deficiencies, but failed to document corrective action or to update the site safety and health plan. At one site, the daily safety log contained several references to heat stress difficulties and to subcontractor non-compliance with PPE requirements, but no other documentation was available to indicate whether these issues had been addressed. It is important to evaluate existing programs and operations to identify deficiencies or required changes; however, these efforts are fruitless unless the appropriate corrective actions or program revisions are effected.
Written maintenance and repair procedures and records are essential where thermal technology is used
Thermal treatment is a versatile and cost-effective technology that presents potentially serious hazards including fire, explosion, and high-voltage electricity. For this reason, thermal unit design, maintenance, and repair can have a significant impact on the safety and health of site workers.
Despite this significance, thermal unit operation at several sites visited was often managed through trouble-shooting rather than planned maintenance, and documentation for process changes and repairs was usually lacking. Knowledge of unit operations at these sites and familiarity with emergency shutdown procedures rested with only one or two individuals.
In evaluating thermal unit operating procedures, the audit team found that the principles of OSHA's process safety management (PSM) standard (29 CFR 1910.119) provided an effective tool for developing safety and health procedures, including preparing and implementing an equipment maintenance program.
Consistent with the PSM standard, the team believed that an effective equipment maintenance program should include required procedures and schedules, documentation of operating procedures including shutdown procedures, operator training, the availability of accurate process diagrams and manuals, documentation of repairs, and development of emergency shutdown procedures, including emergency shutdown authorities and responsibilities.
Thermal treatment is a versatile and cost-objective technology that presents potentially serious hazards including fire, explosion, and high-voltage electricity.
Emergency response must be coordinated with local responders and rehearsed onsite
Although site emergency response often requires the assistance of local fire, ambulance, and medical personnel, it is not uncommon to find local responders unfamiliar with site hazards or with their respective roles in emergencies.
At one rural site that lacked 911 service and relied on volunteer dispatch, fire, and ambulance services, the fire chief had not been contacted about the site's 30,000 gallon LPG (liquefied petroleum gas) tank and expressed concern about his crew's ability to respond to a site fire or explosion that might involve it.
At another site, the local hospital had not been provided a copy of the site's emergency response plan as required by the local emergency planning committee and had no knowledge of site activities. The volunteer ambulance service for that same site also was unfamiliar with site hazards and with the contamination likely to be encountered when transporting or providing aid to potential victims. In addition, workers at several sites expressed skepticism that the emergency alarm system could be heard above operating equipment, or that evacuation routes would be accessible in the event of an actual emergency.
To ensure that emergency response activities occur as planned, emergency evacuation drills are necessary even on projects of short duration, and local responders must be included in response planning and drills.
In sum, effective safety and health programs at Superfund sites are possible through a thorough and ongoing investigation of site hazards and the implementation of necessary and appropriate controls. The site safety and health plan and appropriate operating procedures must incorporate identified hazards and controls. Established plans and procedures must be evaluated and updated throughout the life of the project to reflect changing site conditions and tasks. Finally, the plan and appropriate contract mechanisms must provide the flexibility to allow safety and health supervisors to exercise professional judgement in managing site safety and health matters.
The OSHA documents, Protocol for Safety and Health Inspections at Superfund Incinerator Sites and Summary Report on OSHA Inspections Conducted at Superfund Incinerator Sites, provide additional information concerning OSHA audit team inspections. These documents can be obtained by contacting the OSHA Office of Publications at (202) 219-4667.
To ensure that emergency response activities occur as planned, emergency evacuation drills are necessary even on projects of short duration, and local responders must be included in response planning drills.
MaryAnn Garrahan is an Industrial Hygienist in OSHA's Office of Health Compliance Assistance. Contributions to this article by Earl Cook, OSHA's Health Response Team, William Perry, OSHA's Directorate of Health Standards Programs, and Nina Baird, now at ATL International, Inc.
1Superfund, the common name for the Comprehensive Environmental Response, Liability, and Compensation Act (CERLCA), passed by Congress in 1980 and amended in 1986, gives EPA authority to identify parties responsible for inactive or abandoned waste sites and to force clean-up actions, or to clean up those sites itself and find (or sue) responsible parties later. Superfund also established a process for identifying and prioritizing sites for clean-up action. The Superfund Amendments and Reauthorization Act of 1986 (SARA) directed OSHA to issue a standard for the health and safety of workers engaged in hazardous waste and emergency response operations.