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Critical Safety Procedures and Hazard Controls ==============================================

This document outlines the critical safety procedures, hazard controls, and emergency response protocols necessary for today's planned activities. It also details the required Personal Protective Equipment (PPE) to ensure worker safety and regulatory compliance.

Hazard Identification and Risk Assessment

A comprehensive site evaluation must be performed to identify potential hazards and determine appropriate safety and health control procedures. This evaluation should be conducted by a qualified person before site entry to select suitable employee protection methods. A more detailed evaluation should follow immediately after initial site entry to assess specific site characteristics. [3]

The preliminary and detailed surveys should identify conditions that may pose inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH), or other conditions that may cause death or serious harm. Examples include confined space entry, explosive or flammable situations, vapor clouds, or areas with biological indicators. [2]

Risk identification involves determining the risks associated with identified hazardous substances and informing employees of these risks. Considerations include exposures exceeding permissible limits, IDLH concentrations, potential skin and eye irritation sources, explosion sensitivity, flammability ranges, and oxygen deficiency. [8] [8]

Hazard Controls

Hierarchy of Controls

The hierarchy of controls should be followed to minimize or eliminate hazards. This includes:

  • Elimination: Removing the hazard completely.
  • Substitution: Replacing a hazardous substance or process with a less hazardous one.
  • Engineering Controls: Using enclosures, machine guards, or worker booths to prevent contact with the hazard.
  • Administrative Controls: Modifying work procedures, providing training, and implementing safety policies.
  • Personal Protective Equipment (PPE): Providing and ensuring the correct use of PPE as a last line of defense.

Site Control Program

A site control program must be implemented to control employee exposure to hazardous substances before cleanup work begins. This program should be developed during the planning stages and modified as necessary. Key elements include: [9] [9]

  • A site map indicating the location of hazards and control measures.
  • Clearly defined site work zones to segregate contaminated and clean areas.
  • Implementation of a buddy system to ensure continuous communication and support between workers.
  • Effective site communication methods, including alerting means for emergencies.
  • Standard operating procedures (SOPs) or safe work practices for all tasks.
  • Identification of the nearest medical assistance facilities and emergency contact information.

Good Housekeeping

Good housekeeping practices are essential to prevent the accumulation of hazardous materials and conditions. This includes regular cleaning, proper material storage, and waste disposal. [7]

Personal Hygiene

Personal hygiene practices are crucial for minimizing exposure to hazardous materials. These practices include: [1]

  • Washing hands thoroughly after handling materials and before eating, drinking, or smoking.
  • Avoiding touching the lips, nose, and eyes with contaminated hands.
  • Prohibiting smoking, drinking, chewing gum, or eating in work areas; these activities should only be permitted in designated clean areas.
  • Ensuring hazardous products are not stored in the same refrigerator as food items.

Emergency Response Procedures

Emergency Preparedness

Being prepared for emergencies involves ensuring that necessary equipment and supplies are readily available and that employees know what to do during unplanned events such as releases, spills, fires, or injuries. Emergency response procedures should be written, and employees should regularly practice their emergency response skills. [1]

Emergency Response Plan Elements

The emergency response plan should address the following elements:

  • Pre-emergency planning to anticipate potential incidents.
  • Clearly defined personnel roles, lines of authority, and communication protocols.
  • Emergency recognition and prevention measures.
  • Safe distances and places of refuge.
  • Site security and control procedures.
  • Evacuation routes and procedures.
  • Decontamination procedures.
  • Emergency medical treatment and first aid protocols.
  • Emergency alerting and response procedures.
  • Procedures for handling emergency incidents.
  • Critique of the response and follow-up actions.
  • PPE and emergency equipment requirements.

Incident Command System (ICS)

An Incident Command System (ICS) should be implemented to effectively control and manage operations during an emergency. The senior official responding to the incident is in charge of the ICS. The ICS helps to reduce confusion, improve safety, organize and coordinate actions, and facilitate effective management of the incident. [4] [4]

Emergency Equipment and Supplies

A current inventory list of all emergency equipment and supplies should be maintained, including maintenance and decontamination procedures. Equipment should be tested as specified by the manufacturer, and equipment and supply needs should be reviewed when changes occur. Contact lists for suppliers of emergency equipment and supplies should be maintained, updated, and readily available. [6]

Personal Protective Equipment (PPE)

PPE Program

A comprehensive PPE program should be in place, including hazard identification, medical monitoring, environmental surveillance, selection, use, maintenance, and decontamination of PPE, and associated training. The written PPE program should include policy statements, procedures, and guidelines, with copies available to all employees and a reference copy at the worksite. Technical data, maintenance manuals, and relevant regulations should also be maintained. [4] [4]

PPE Selection

The selection of appropriate PPE must be based on the specific hazards present at the workplace. Examples of PPE include: [5]

  • Respiratory protection
  • Head protection
  • Skin protection (e.g., coveralls, aprons, full body suits)
  • Gloves
  • Eye protection (e.g., face shields, goggles)
  • Foot protection
  • Hearing protective devices (e.g., earplugs, earmuffs)

PPE Usage

PPE should be used in conjunction with other protective methods, and its effectiveness should be evaluated periodically. Over-protection, as well as under-protection, can be hazardous and should be avoided where possible. [4] [4]

Training and Education

Employee education and training are critical for ensuring work is conducted safely. Training must cover how to do the job safely, the hazards and risks of the job, and the controls in place to protect them. Workers must also be provided with information on how to protect themselves and co-workers. [7]

Training Program Elements

The training program should include:

  • Names of personnel responsible for site safety and health.
  • Safety, health, and other hazards present on the site.
  • Proper use of personal protective equipment.
  • Work practices to minimize risks from hazards.
  • Safe use of engineering controls and equipment on the site.
  • Medical surveillance requirements, including recognition of symptoms and signs of overexposure.
  • Contents of the site safety and health plan.

Review and Evaluation of Controls

It is important to determine the effectiveness of implemented control methods and adjust as required. Controls must not create new hazards. The hazard and the control method should be monitored to ensure the control is working effectively and that exposure to the hazard is reduced or eliminated. [5] [5]

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9 source record(s)

Sources used for this answer

[1] General Industry Safety and Health Standards (MIOSHA)

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# 1910.120 - HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (cont.) ## 1910.120(b)(2) Organizational structure part of the site program. (cont.) - 1910.120(b)(2)(i)(C) All other personnel needed for hazardous waste site operations and emergency response and their general functions and responsibilities. - 1910.120(b)(2)(i)(D) The lines of authority, responsibility, and communication. 1910.120(b)(2)(ii) The organizational structure shall be reviewed and updated as necessary to reflect the current status of waste site operations. - 1910.120(b)(3) Comprehensive workplan part of the site program. Comprehensive workplan part of the site program. The comprehensive workplan part of the program shall address the tasks and objectives of the site operations and the logistics and resources required to reach those tasks and objectives. 1910.120(b)(3)(i) The comprehensive workplan shall address anticipated clean-up activities as well as normal operating procedures which need not repeat the employer's procedures available elsewhere. 1910.120(b)(3)(ii) The comprehensive workplan shall define work tasks and objectives and identify the methods for accomplishing those tasks and objectives. - 1910.120(b)(3)(iii) The comprehensive workplan shall establish personnel requirements for implementing the plan. 1910.120(b)(3)(iv) The comprehensive workplan shall provide for the implementation of the training required in paragraph (e) of this section. - 1910.120(b)(3)(v) The comprehensive workplan shall provide for the implementation of the required informational programs required in paragraph (i) of this section. - 1910.120(b)(3)(vi) The comprehensive workplan shall provide for the implementation of the medical surveillance program described in paragraph (f) if this section. ## 1910.120(b)(4) Site-specific safety and health plan part of the program. 1910.120(b)(4)(i) General. The site safety and health plan, which must be kept on site, shall address the safety and health hazards of…

[2] Emergency Management Checklist

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# Emergency Management Checklist (cont.) ## What is an example of an emergency management checklist? (cont.) <table><tr><th>from hazards</th><th></th><th></th><th></th><th></th><th></th></tr><tr><td>- The command post is adequately equipped</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Provisions have been made for emergency power, light, utilities, etc.</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td colspan="5">Plan provides for emergency response training and covers the following:</td><td></td></tr><tr><td>- Emergency response training is based on specific hazards and response duties</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Testing of knowledge and skills is conducted</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Plan specifies type and frequency of training for each response function</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Adequate training records are kept</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Minimum training levels are defined</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Training of first aid responders complies with legislation, at minimum</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>A current inventory list of all equipment and supplies exists:</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Maintenance and decontamination procedures are included</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Equipment is tested as specified by the manufacturer</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Equipment and supply needs are reviewed when changes occur</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Contact lists for suppliers of emergency equipment and supplies maintained, updated and readily available</td><td></td><td></td><td></td><td></td><td></td></tr><tr><td>- Respiratory equipment selection, use and maintenance comply with current …

[3] Hazard and Risk - Hierarchy of Controls

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# Enclosure and Isolation (cont.) ## Good Housekeeping (cont.) Being prepared for emergencies means making sure that the necessary equipment and supplies are readily available and that employees know what to do when something unplanned happens such as a release, spill, fire, or injury. These procedures should be written and employees should have the opportunity to practice their emergency response skills regularly. Please see the OSH Answers document on emergency_planning for more information. ## Personal Hygiene Practices and Facilities Personal hygiene practices are another effective way to reduce the amount of a hazardous material absorbed, ingested, or inhaled by a worker. Examples of personal hygiene practices include: - Washing hands after handling material and before eating, drinking or smoking. - Avoiding touching lips, nose, and eyes with contaminated hands. - No smoking, drinking, chewing gum or eating in the work areas - these activities should be permitted only in a "clean" area. - Not storing hazardous products in the same refrigerator as food items. Please see the OSH Answers documents on Workplace Housekeeping, Hand Washing: Reducing the Risk of Common Infections and Good Hygiene Practices - Reducing the Spread of Infections and Viruses for more information. ## What should I know about personal protective equipment (PPE) as a hazard control method? Personal protective equipment (PPE) refers to anything workers wear to help protect them from workplace hazards. The use of PPE as the main method to control exposures should be limited to situations where elimination, substitution, engineering, or administrative controls are not practicable, or when: - Additional protection is required because other control methods are not sufficient to reduce the hazard - The hazard is a result of a temporary or emergency condition PPE limits exposure to the harmful effects of a hazard but only if the PPE is worn and used correctly. Examples of PPE inclu…

[4] Construction Safety and Health Standards (MIOSHA)

Page 9

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Source excerpt

# 1910.120 - HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (cont.) ## 1910.120(b)(4) Site-specific safety and health plan part of the program. (cont.) 1910.120(c)(7) Risk identification. Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be informed of any risks that have been identified. In situations covered by the Hazard Communication Standard, 29 CFR 1910.1200, training required by that standard need not be duplicated. NOTE TO PARAGRAPH (c)(7). - Risks to consider include, but are not limited to: [a] Exposures exceeding the permissible exposure limits and published exposure levels. [b] IDLH Concentrations. [c] Potential Skin Absorption and Irritation Sources. [d] Potential Eye Irritation Sources. [e] Explosion Sensitivity and Flammability Ranges. [f] Oxygen deficiency. 1910.120(c)(8) Employee notification. Any information concerning the chemical, physical, and toxicologic properties of each substance known or expected to be present on site that is available to the employer and relevant to the duties an employee is expected to perform shall be made available to the affected employees prior to the commencement of their work activities. The employer may utilize information developed for the hazard communication standard for this purpose. ## 1910.120(d) Site control. 1910.120(d)(1) General. Appropriate site control procedures shall be implemented to control employee exposure to hazardous substances before clean-up work begins. 1910.120(d)(2) Site control program. A site control program for protecting employees which is part of the employer's site safety and health program required in paragraph (b) of this section shall be developed during the planning stages of a hazardous waste clean-up operation and modified as necessary as new information becomes available. 1910.120(d)(3) Elem…

[5] General Industry Safety and Health Standards (MIOSHA)

Page 9

Open source document

Source excerpt

# 1910.120 - HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (cont.) ## 1910.120(b)(4) Site-specific safety and health plan part of the program. (cont.) 1910.120(c)(7) Risk identification. Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be informed of any risks that have been identified. In situations covered by the Hazard Communication Standard, 29 CFR 1910.1200, training required by that standard need not be duplicated. NOTE TO PARAGRAPH (c)(7). - Risks to consider include, but are not limited to: [a] Exposures exceeding the permissible exposure limits and published exposure levels. [b] IDLH Concentrations. [c] Potential Skin Absorption and Irritation Sources. [d] Potential Eye Irritation Sources. [e] Explosion Sensitivity and Flammability Ranges. [f] Oxygen deficiency. 1910.120(c)(8) Employee notification. Any information concerning the chemical, physical, and toxicologic properties of each substance known or expected to be present on site that is available to the employer and relevant to the duties an employee is expected to perform shall be made available to the affected employees prior to the commencement of their work activities. The employer may utilize information developed for the hazard communication standard for this purpose. ## 1910.120(d) Site control. 1910.120(d)(1) General. Appropriate site control procedures shall be implemented to control employee exposure to hazardous substances before clean-up work begins. 1910.120(d)(2) Site control program. A site control program for protecting employees which is part of the employer's site safety and health program required in paragraph (b) of this section shall be developed during the planning stages of a hazardous waste clean-up operation and modified as necessary as new information becomes available. 1910.120(d)(3) Elem…

[6] Hazard and Risk - Hierarchy of Controls

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# Enclosure and Isolation (cont.) ## What should I know about personal protective equipment (PPE) as a hazard control method? (cont.) - Skin protection (e.g., coveralls, aprons, full body suits) - Gloves - Eye protection (e.g., face shield, goggles) - Foot protection - Hearing protective devices (e.g., ear plugs, ear muffs) The choice of what type of PPE is required must be based on the specific hazard found at the workplace. No matter which type of PPE is used, it is essential to have a complete PPE program in place. For more information about PPE programs, please see the following document Designing an Effective PPE Program. ## Can more than one control method be used or followed? Yes. Sometimes a hazard cannot be controlled using a single type of control method. If a hazard cannot be eliminated, a combination of controls may be required. For example: - Using a scissor lift instead of a ladder (substitution). Workers should be trained on the safe use of the equipment and follow safe work procedures (administrative controls). When working at heights, workers should also use PPE, including a full body harness and lanyard attached to an anchor point, there is a risk of injury from falling. - Driving in the winter for work. Controls may include not driving during extreme winter weather (elimination), determining if there are any other options for driving, such as public transit (substation), use of winter tires (engineering), and driver training (administrative). ## Should the adequacy of controls be reviewed or evaluated? Yes. It is important to determine the effectiveness of the control methods implemented and adjust as required. Controls must not create new hazards. For example, if wearing PPE contributes to other hazards (e.g., heat stress), then it is important to review if other control methods are possible or if additional precautions are needed. Monitor both the hazard and the control method to make sure that the control is working effectively…

[7] Construction Safety and Health Standards (MIOSHA)

Page 8

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Source excerpt

# 1910.120 - HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE (cont.) ## 1910.120(b)(4) Site-specific safety and health plan part of the program. (cont.) performed by a qualified person in order to further identify existing site hazards and to further aid in the selection of the appropriate engineering controls and personal protective equipment for the tasks to be performed. 1910.120(c)(3) Hazard identification. All suspected conditions that may pose inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH) or other conditions that may cause death or serious harm shall be identified during the preliminary survey and evaluated during the detailed survey. Examples of such hazards include, but are not limited to, confined space entry, potentially explosive or flammable situations, visible vapor clouds, or areas where biological indicators such as dead animals or vegetation are located. - 1910.120(c)(4) Required information. The following information to the extent available shall be obtained by the employer prior to allowing employees to enter a site: - 1910.120(c)(4)(i) Location and approximate size of the site. - 1910.120(c)(4)(ii) Description of the response activity and/or the job task to be performed. - 1910.120(c)(4)(iii) Duration of the planned employee activity. - 1910.120(c)(4)(iv) Site topography and accessibility by air and roads. - 1910.120(c)(4)(v) Safety and health hazards expected at the site. - 1910.120(c)(4)(vi) Pathways for hazardous substance dispersion. - 1910.120(c)(4)(vii) Present status and capabilities of emergency response teams that would provide assistance to on-site employees at the time of an emergency. - 1910.120(c)(4)(viii) Hazardous substances and health hazards involved or expected at the site and their chemical and physical properties. 1910.120(c)(5) Personal protective equipment. Personal protective equipment (PPE) shall be provided and used during initial site entry in accordance with …

[8] Hazard and Risk - Hierarchy of Controls

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# Enclosure and Isolation (cont.) ## Work Practices (cont.) - Keeping equipment well maintained. - Preparing and training for emergency response for incidents such as spills, fire, or employee injury. ## Education and Training Employee education and training on how to conduct their work safely is a critical element of any complete workplace health and safety program. Training must cover not only how to do the job safely but it must also ensure that workers understand the hazards and risks of their job, and the controls in place to protect them. It must also provide them with information on how to protect themselves and co-workers. ## Good Housekeeping Good housekeeping is essential to prevent the accumulation of hazardous or toxic materials (e.g., build-up of dust or contaminant on ledges, or beams), or hazardous conditions (e.g., poor stockpiling). For more information about workplace housekeeping, please see the OSH Answers document Workplace Housekeeping - Basic Guide. For more information about combustible dust, please see the OSH Answers document Combustible Dusts. Figure 4 Emergency Preparedness Hazard and Risk - Hierarchy of Controls CCOHS

[9] Construction Safety and Health Standards (MIOSHA)

Page 34

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# 1926.65 - APPENDIX C COMPLIANCE GUIDELINES (cont.) As discussed in appendix B, no single combination of protective equipment and clothing is capable of protecting against all hazards. Thus PPE should be used in conjunction with other protective methods and its effectiveness evaluated periodically. The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress, and impaired vision, mobility, and communication. For any given situation, equipment and clothing should be selected that provide an adequate level of protection. However, over-protection, as well as under-protection, can be hazardous and should be avoided where possible. Two basic objectives of any PPE program should be to protect the wearer from safety and health hazards, and to prevent injury to the wearer from incorrect use and/or malfunction of the PPE. To accomplish these goals, a comprehensive PPE program should include hazard identification, medical monitoring, environmental surveillance, selection, use, maintenance, and decontamination of PPE and its associated training. The written PPE program should include policy statements, procedures, and guidelines. Copies should be made available to all employees, and a reference copy should be made available at the worksite. Technical data on equipment, maintenance manuals, relevant regulations, and other essential information should also be collected and maintained. 6. Incident command system (ICS). "Incident command system (ICS)." Paragraph 1926.65(q)(3)(ii) requires the implementation of an ICS. The ICS is an organized approach to effectively control and manage operations at an emergency incident. The individual in charge of the ICS is the senior official responding to the incident. The ICS is not much different than the "command post" approach used for many years by the fire service. During large complex fires involving several companies and many pieces of apparatus, a command post would be establi…

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