I need a corrective action plan

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# K. 1910.120(I) and 1926.65(1): Emergency Response (cont.) ## I. Purpose of Requirements (cont.) <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>. Is the Plan in writing? Employers with 10 or fewer employees do not need a written plan. They may communicate the plan orally. Does it cover the appropriate actions the employer and employees take to protect employees during a hazardous substance emergency?</td><td>1910.38(b), 1926.35(a), 1910.38(c)(3), 1926.35(b)(2)</td><td></td><td></td><td></td></tr><tr><td>. Is the written plan at the workplace and made available for employee review?</td><td>1910.38(b), 1926.35(e)(3)</td><td></td><td></td><td></td></tr><tr><td>. Are emergency escape procedures and emergency escape routes assigned?</td><td>1910.38(c)(2), 1926.35(b)(1)</td><td></td><td></td><td></td></tr><tr><td>Has the employer designated and trained a sufficient number of persons to assist in the safe and orderly evacuation of employees (generally necessary when over 20 employees are on-site)?</td><td>1910.38(e), 1926.35(e)(1)</td><td></td><td></td><td></td></tr><tr><td>. Are procedures established to account for all employees after the emergency evacuation has been completed?</td><td>1910.38(c)(4), 1926.35(b)(3)</td><td></td><td></td><td></td></tr><tr><td>• Does the employer have procedures for notifying both inside and outside parties of incidents so that employees are not at risk? (Examples of at-risk employees may include employees who are required to remain in a temporarily safe area to shut down sites where the employer does not have specific procedures to notify the local fire department other outside responders and has not verified that key responders are capable of a timely response).</td><td>1910.38(c)(1)</td><td></td><td></td><td></td></tr><tr><td>• Is there an employee alarm system that complies with 29 CFR 1910.165?</td><td>1910.38(d), 1926.35(c)(1)</td…

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# How to Plan for Workplace Emergencies and Evacuations (cont.) ## What is an emergency action plan? An emergency action plan covers designated actions employers and employees must take to ensure employee safety from fire and other emergencies. Not all employers are required to establish an emergency action plan. See the flowchart on page 17 to determine if you are. Even if you are not specifically required to do so, compiling an emergency action plan is a good way to protect yourself, your employees, and your business during an emergency. Putting together a comprehensive emergency action plan that deals with all types of issues specific to your worksite is not difficult. You may find it beneficial to include your management team and employees in the process. Explain your goal of protecting lives and property in the event of an emergency, and ask for their help in establishing and implementing your emergency action plan. Their commitment and support are critical to the plan's success. ## What should your emergency action plan include? When developing your emergency action plan, it's a good idea to look at a wide variety of potential emergencies that could occur in your workplace. It should be tailored to your worksite and include information about all potential sources of emergencies. Developing an emergency action plan means you should do a hazard assessment to determine what, if any, physical or chemical hazards in your workplaces could cause an emergency. If you have more than one worksite, each site should have an emergency action plan. At a minimum, your emergency action plan must include the following: - A preferred method for reporting fires and other emergencies; • An evacuation policy and procedure; - Emergency escape procedures and route assignments, such as floor plans, workplace maps, and safe or refuge areas; 5

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# K. 1910.120(I) and 1926.65(1): Emergency Response (cont.) ## I. Purpose of Requirements (cont.) <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>6. Does the SSAHP provide for regular rehearsal of emergency response procedures as part of the overall training for emergency response? NOTES:</td><td>HAZWOPER (1)(3)(iv)</td><td></td><td></td><td></td></tr><tr><td>7. Is the emergency response plan periodically reviewed and regularly updated? NOTES:</td><td>HAZWOPER (1)(3)(v)</td><td></td><td></td><td></td></tr><tr><td>8. Is the emergency response plan coordinated with the response plans of all other site employers? NOTES:</td><td>HAZWOPER (1)(2)(i)-(ii)</td><td></td><td></td><td></td></tr><tr><td>9. Does the SSAHP describe an emergency alarm system? If so:</td><td>HAZWOPER (I)(3)(vi)</td><td></td><td></td><td></td></tr><tr><td>. Is other than voice communication used as a means of sounding the alarm (Note: voice communication is permitted on sites with 10 or fewer employees);</td><td>1910.165 (b)(5)</td><td></td><td></td><td></td></tr><tr><td>. Are spare alarm devices and components that are subject to wear available for prompt restoration of the system;</td><td>1910.165 (c)(2)</td><td></td><td></td><td></td></tr><tr><td>. Are back-up means of alarm, such as employee runners or telephone, provided when the system is out of service; and</td><td>1910.165 (d)(3)</td><td></td><td></td><td></td></tr><tr><td>. Does the alarm system provide positive notification whenever a deficiency exists in the system?</td><td>1910.165 (d)(4)</td><td></td><td></td><td></td></tr><tr><td colspan="5">What to look for: The alarm system should be checked for compliance with 29 CFR 1910.165 and evaluated as to applicability for the particular site. You should ensure that a common alarm signal system serves all site employees, regardless of whether they are employed by the prime contractor or a su…

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# N. 1910.120(o) and 1926.65(o): New Technology Programs ## I. Purpose of Requirements OSHA's requirements for new technology programs are intended to encourage employers to seek improved methods for controlling hazards. To ensure ongoing employee protection, employers are required to develop and implement procedures for new technology review and introduction. The site safety and health plan must include these procedures. <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>1. Does the site safety and health plan contain procedures for evaluating and introducing new technology and equipment for improved hazard control and employee protection?</td><td>HAZWOPER (0)(1)</td><td></td><td></td><td></td></tr><tr><td>Have product developments in areas such as chemical protective clothing, monitoring and chemical detection instrumentation, and decon been reviewed and evaluated for site-specific use?</td><td>(o)(2)</td><td></td><td></td><td></td></tr><tr><td colspan="5">What to look for: Methods and equipment that improve the quality of safety and health in the workplace are always being developed. HAZWOPER requires employer to keep abreast of the new technology emerging in hazardous waste operations regarding safety and health and to develop procedures to introduce it into the workplace. In evaluating compliance, you should verify that: (1) The employer's new technology program is incorporated into the written safety and health plan. (2) The employer reviews areas of new technologies such as innovations in chemical protective clothing, monitoring and chemical detection instrumentation, biological monitoring, and decontamination supplies. Sources of information that may be used by the employer include product catalogs and vendor exhibits at conferences. (3) The employer has a procedure for evaluating the effectiveness and implementation of useful new technologies. Safety and hea…

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# XIII. INSPECTION CHECKLISTS ## A. 1910.120(b) and 1926.65(b): Safety and Health Program ## I. Purpose of Requirements Employers must develop a comprehensive written safety and health program, as required by HAZWOPER paragraph (b). The written program must include three components: an organizational structure, a comprehensive work plan, and a site specific safety and health plan (SSAHP). The work plan must define work tasks and objectives, and must establish personnel requirements. The SSAHP must analyze job specific hazards and address safety and health hazards present at the site. Note: Use this section of the guidelines to verify that the employer has a written safety and health program. Other specific elements of the employer's SSAHP can be found in other compliance checklists in this directive. <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>1. Does the employer have an up-to-date written safety and health program? NOTES:</td><td>HAZWOPER (b)(1)(i)</td><td></td><td></td><td></td></tr><tr><td>2. Does the written safety and health program contain each of the following elements?</td><td></td><td></td><td></td><td></td></tr><tr><td>• An organizational structure;</td><td>HAZWOPER (b)(1)(ii)(A)</td><td></td><td></td><td></td></tr><tr><td>. A site-specific safety and health plan (SSAHP) that includes the employer's standard operating procedures (SOPs) for safety and health; and</td><td>(b)(1)(ii)(C), (b)(1)(ii)(F)</td><td></td><td></td><td></td></tr><tr><td>• A comprehensive work plan NOTES:</td><td>(b)(1)(ii)(B)</td><td></td><td></td><td></td></tr><tr><td>3. Does the employer's written safety and health program include a means of informing subcontractors of site emergency procedures and health and safety hazards present on-site?</td><td>HAZWOPER (b)(1)(iv)</td><td></td><td></td><td></td></tr></table> 16

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# XIII. INSPECTION CHECKLISTS (cont.) ## I. Purpose of Requirements (cont.) <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td colspan="5">What to look for: A written Site Safety and Health Plan (SSAHP) is required by (b)(1)(ii)(C) on all sites within the scope of the standard. The standard requires the development and implementation of a SSAHP as a guide to worker protection for the site and as documentation of the safety and health procedures being used to protect workers. The SSAHP must be site-specific and reflect the actual conditions of the work site and work activities. This plan must be updated through an ongoing evaluation of the hazards and potential for exposure as conditions or activities change. The lack of a plan or its implementation is considered to be a hazard in itself to the employees and is not contingent on documentation of an employee's overexposure. NOTES:</td></tr><tr><td>8. Do the job-specific safety and health risk analyses contain specific information on the nature of safety and health hazards associated with each job performed on-site, and do they provide specific instructions to employees for avoiding the hazards?</td><td>HAZWOPER (b)(4)(i) (b)(4)(ii)(A)</td><td></td><td></td><td></td></tr><tr><td>Does the SSAHP describe the principal chemical contaminants, affected media, anticipated or measured concentrations, potential routes of exposure, and health effects associated with exposure to the contaminants?</td><td></td><td></td><td></td><td></td></tr><tr><td>Does the SSAHP identify the appropriate level of PPE for each site task and operation? NOTES:</td><td>(b)(4)(ii)(C)</td><td></td><td></td><td></td></tr><tr><td>9. Is there evidence that the site safety and health officer or other knowledgeable individual regularly conducts inspections to determine the effectiveness of the SSAHP? Does the employer correct deficiencies in the SSAHP?</td…

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# K. 1910.120(I) and 1926.65(1): Emergency Response (cont.) ## I. Purpose of Requirements (cont.) <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>Does a mutual agreement exist between the employer, the local fire department, and other outside responders regarding each responder's role in an emergency response?</td><td>HAZWOPER (1)(3)(iii)</td><td></td><td></td><td></td></tr><tr><td>Have local emergency responders been provided and have readily available a copy of the site's emergency response plan?</td><td>HAZWOPER (1)(3)(iii)</td><td></td><td></td><td></td></tr><tr><td>Do local emergency responders have procedures for rescuing and/or treating personnel who are potentially contaminated?</td><td>HAZWOPER (1)(3)(iii)</td><td></td><td></td><td></td></tr><tr><td>Have local emergency responders been provided with information on the nature of hazardous substances present at the site and the potential hazards associated with exposure to those substances?</td><td>HAZWOPER (I)(3)(iii)</td><td></td><td></td><td></td></tr><tr><td>Have local emergency responders participated in rehearsals or drills of emergency situations?</td><td>HAZWOPER (1)(3)(iii)</td><td></td><td></td><td></td></tr><tr><td colspan="5">What to look for: Many hazardous waste sites rely on outside services to provide emergency response. Some sites handle certain types of emergencies with their own HAZMAT team, and intend to use outside services for large-scale incidents, or for emergency medical services. Very few sites handle emergency response with no reliance upon outside services. OSHA requires that the hazardous waste site employer reach a mutual agreement with local emergency response organizations about the site's emergency response needs. To verify that this mutual agreement exists, you are required to contact the local fire department at a minimum to confirm the fire department's knowledge of the ag…

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# K. 1910.120(I) and 1926.65(1): Emergency Response ## I. Purpose of Requirements The purpose of HAZWOPER's paragraph (1) is for employers to develop and train employees in site- specific emergency response procedures. According to its requirements, employers must prepare and implement a written Emergency Response Plan (ERP). The ERP must include the following elements: 1) pre-emergency planning, including coordination with local emergency response organizations; 2) a means of alerting and, if necessary, safely evacuating employees; 3) the conduct of emergency response drills; 4) means for obtaining prompt medical and firefighting assistance; and 5) procedures for notifying community, State, and Federal officials of an emergency occurrence. <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>1. Does the employer have a written emergency response plan (ERP)?</td><td>HAZWOPER (b)(4)(ii)(H), (I)(1)(i)</td><td></td><td></td><td></td></tr><tr><td colspan="5">What to look for: If the employer has an Integrated Contingency Plan (ICP), OSHA recognizes this type of document as demonstrating compliance with the emergency response plan requirements of 1910.120(1), (p)(8), and (q); 1910.38; 1926.35; and 1910.119(n). An ICP or One-Plan allows employers to prepare an integrated ERP that meets the requirements of multiple federal agency regulations with a single plan. It does not, however, change the employer's duty to comply with OSHA regulations. The ICP must meet the applicable OSHA requirements and should be reviewed carefully. A copy of the National Response Team's One-Plan guidance is available on the OSHA website. NOTES:</td></tr><tr><td>2. If the employer does not have an ERP but expresses an intent to evacuate all employees and not allow any personnel to respond, does the employer have an emergency action (EAP) plan in accordance with 29 CFR 1910.38(b) or 1926.35?</td><td>H…

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# P. 1910.252(a) and 1926.352: Hot Work Fire Prevention and Protection ## I. Summary The requirements of 1910.252(a) and 1926.352 ensure that employees are adequately protected from hazards associated with welding operations. Where standards are different, their requirements are separated below. You must determine whether the welding operations fall with 1910 or 1926 and evaluate the operations accordingly. If the elements of an effective hot work program are not covered by the appropriate hot work standard, then HAZWOPER requirements should be cited. <table><tr><th>II. Compliance Checklist</th><th>OSHA Reference</th><th>Records Review</th><th>On-Site Conditions</th><th>Interviews</th></tr><tr><td>1a. Does the site safety and health plan contain procedures for cutting and welding in other than specifically designated areas, based on the fire potential of site conditions?</td><td>1910.252 (a)(2)(xiii)(A)</td><td></td><td></td><td></td></tr><tr><td>1b. Does the site safety and health plan contain an effective fire protection and prevention program applicable throughout all phases of construction, repair, alteration, or demolition work? NOTES:</td><td>1926.24</td><td></td><td></td><td></td></tr><tr><td>2a. Does the site safety and health plan designate an individual responsible for authorizing cutting and welding operations in areas not specifically designated for such processes?</td><td>1910.252 (a)(2)(xiii)(B)</td><td></td><td></td><td></td></tr><tr><td>2b. Does the site safety and health plan provide for frequent and regular inspections of hot work areas, materials, and equipment by a competent person designated by the employer? NOTES:</td><td>1926.20(b)(2)</td><td></td><td></td><td></td></tr><tr><td>3. Does the site safety and health plan provide for the individual responsible for authorizing cutting and welding operations to issue written permits granting such authorization? NOTES:</td><td>1910.252 (a)(2)(iv)</td><td></td><td></td><td></td></tr><tr><td>4. Do p…

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# TABLE OF CONTENTS (cont.) E. What written programs should I review during an inspection? Section XIII, Detailed Inspection Guidance, contains specific information on this issue [See Detailed Inspection Guidance in Checklist A. 1910.120(b) and 1926.65(b): Safety and Health Program]. Written programs for hazardous waste clean-up operations that you should review include the following: 1. Safety and health program, as per 29 CFR 1910.120(b)(1) and/or 1926.65(b)(1). The safety and health program requires other written programs such as an organizational structure, a work plan, and a site- specific safety and health plan. See Section XIII for more information on the relationships between the written safety and health program, the site- specific safety and health plan, and the requirements of the HAZWOPER standard; 2. Site-specific safety and health plan, as per HAZWOPER paragraph (b)(1)(ii)(C). This may be part of the safety and health program listed above, and need not duplicate the employers standard operating procedures; 3. Documentation of site characterization and analysis, as per 29 CFR 1910.120(c)(4) and/or 1926.65(c)(4); 4. Spill containment program, as per 29 CFR 1910.120(j)(1)(viii) and/or 1926.65(j)(1)(viii); 5. Emergency response plan, as per 29 CFR 1910.120(1)(1) and/or 1926.65(1)(1); 6. New technology program, as per 29 CFR 1910.120(0) and/or 1926.65(0), which may be part of the safety and health program; and 7. Other programs that may be needed because of special site conditions or special site procedures. Examples include programs for benzene, lead, asbestos, heat stress, process safety management (PSM), permit- required confined space, and lockout/tagout. F. What other agencies have regulations that are related to 29 CFR 1910.120 and 29 CFR 1926.65? What do those regulations address? 1. Environmental Protection Agency, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The NCP is a set of regulations that sets…