hazardous waste hanbook

12 Monitoring Well Safety at Hazardous Sites 13113 Hazardous Waste Transportation Safety 135 Appendix F: Medical Occupational History 161 Appendix G: Hazardous Substance Data Sheet 165 A

Hazardous Waste Handbook

for Health and Safety

Hazardous Waste Handbook

for Health and Safety

Third Edition

William F Martin John M Lippitt Paul J Webb

Boston Oxford Auckland Johannesburg Melbourne New Delhi

Copyright © 2000 by Butterworth–Heinemann

A member of the Reed Elsevier group

All rights reserved

No part of this publication may be reproduced, stored in a retrieval system, or transmitted

in any form or by any means, electronic, mechanical, photocopying, recording, or otherwise,without the prior written permission of the publisher

Recognizing the importance of preserving what has been written, Butterworth–Heinemannprints its books on acid-free paper whenever possible

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Library of Congress Cataloging-in-Publication Data

Martin, William F

Hazardous waste handbook for health and safety / William F Martin, John M Lippitt,Paul Webb.—3rd ed

p cm

Includes bibliographical references and index

ISBN 0-7506-7135-1 (alk paper)

1 Hazardous waste sites—Safety measures—Handbooks, manuals, etc 2 Hazardouswaste sites—Health aspects—Handbooks, manuals, etc 3 Environmental health—Handbooks, manuals, etc I Lippitt, John M II Webb, Paul III Title

TD1052 M38 2000

628.4¢2¢0289—dc21

00-023588

British Library Cataloguing-in-Publication Data

A catalogue record for this book is available from the British Library

The publisher offers special discounts on bulk orders of this book

For information, please contact:

Manager of Special Sales

12 Monitoring Well Safety at Hazardous Sites 131

13 Hazardous Waste Transportation Safety 135

Appendix F: Medical Occupational History 161 Appendix G: Hazardous Substance Data Sheet 165 Appendix H: Chemical Protective Clothing

Appendix I: Decontamination Procedures for

Three Typical Levels of Protection 175 Appendix J: Health and Safety Checklist 179 Appendix K: Chemical Hazard Data—NIOSH

Contents

v

William F Martin, P.E., holds a civil engineering degree

from the University of Kentucky and a master’s degree

in environmental health engineering from the

Univer-sity of Texas He served twenty-two years as a

commis-sioned officer in the U.S Public Health Service He

held positions with the Indian Health Service, U.S

Coast Guard, Federal Water Pollution Control

Admin-istration, and National Institute for Occupational

Safety and Health A registered professional engineer

in Texas and Kentucky, he has presented and published

numerous technical papers, both foreign and domestic

He served on the Superfund steering committee made

up of EPA, OSHA, NIOSH, and the U.S Coast Guard

He served as the NIOSH Hazardous Waste Program

Director with primary responsibility for coordinating

all Institute Superfund activities, including research

projects and the production of comprehensive health

and safety guidelines, worker bulletins, and training

materials Mr Martin has consulted on environmental

engineering and hazardous waste health and safety

with Valentec International Corporation,

Environ-mental Systems & Services, Inc., and Greenglobe

Engineering, Inc

John M Lippitt, M.En., is a Registered Sanitarian

with the Ohio State Board of Sanitation Registration

He is currently employed as a Project Scientist for SCS

Engineers, a consulting engineering firm specializing

in hazardous and solid waste management Mr Lippittprovides expertise in health and safety management for SCS projects and has prepared several documentsconcerning methods of worker protection and costs ofworker safety and health for NIOSH and the USEPA.His professional experience prior to joining SCSinvolved five years as a public health sanitarian, a yearconducting carcinogen-testing research and develop-ment with the USEPA Health Effects Research Labo-ratory, and nine months as an on-site coordinator for the Ohio EPA to monitor the activities of a licensedhazardous waste landfill

Paul J Webb, C.I.H., has experience including

industrial hygiene positions with the North CarolinaDepartment of Labor, Division of Occupational Safetyand Health, and within the pharmaceutical industry He

is currently president of Occu-Health Consultants, Inc.,

a Raleigh-based firm specializing in occupational healthand safety Over the past several years, his firm hasworked with clients in private industry and municipalgovernment in the development and implementation ofemergency response programs and personnel training

Mr Webb received his B.S in biology and his M.P.H

in industrial hygiene from the University of South Carolina He is certified in the comprehensive practice

of industrial hygiene by the American Board of trial Hygiene

Indus-Authors

vi

Professionals in environmental health, occupational

health, environmental management, and engineering

have often noted the need for a well-referenced health

and safety training manual to prepare new workers for

hazardous materials and hazardous waste cleanup

activ-ities This need is addressed in this third edition of

Hazardous Waste Handbook for Health and Safety.

These authors average over fifteen years each in

pro-fessional experience in teaching, regulating, consulting,

and handling of hazardous materials Additional field

experience and new regulations have prompted this

third edition The third edition has expanded and

updated material in every chapter References have

been revised to reflect current sources The main

objec-tive of this textbook continues to be its use as a resource

book for training professionals in the practice of

occu-pational safety and health in hazardous materials and

waste activities The authors feel strongly that anyone

teaching or training hazardous waste workers should

have thoroughly covered at least the content of this

edition in an academic setting and have had

consider-able field experience under experienced supervision

This edition is considered a minimum of academic

exposure for the hazardous waste health and safety

course commonly referred to as the Occupational Safetyand Health Administration (OSHA) forty-hour or Hazardous Waste Operation and Emergency Response(HAZWOPER) training The Environmental Protec-tion Agency (EPA), Department of Defense (DoD),Department of Energy (DoE), U.S Coast Guard(USCG), and OSHA regulations and contracts usuallyrequire this level of health and safety training for all on-site personnel This training manual is a companion to

the textbook Protecting Personnel at Hazardous Waste Sites, Third Edition (Butterworth-Heinemann, 1999).

Hazardous waste management is a challengingendeavor in our national effort to protect the quality ofour environment The authors of this book feel that thischallenge can be met without sacrificing the health ofthose individuals and companies called on to accom-plish the task

This manual is an expanded version of the previousedition, with many updates of the NIOSH/OSHA/USCG/EPA publication “Occupational Safety andHealth for Hazardous Waste Site Activities” (1985)

# 85-115, which the authors of this book helped todevelop in 1983–1985

Preface

vii

Recognition is given to the U.S Public Health Service,

especially the National Institute for Occupational

Safety and Health (NIOSH), the Center for Disease

Control and Prevention (CDCP), the Occupational

Safety and Health Administration (OSHA), the U.S

Environmental Protection Agency (EPA), the

Depart-ment of Energy (DoE), the DepartDepart-ment of Defense

(DoD), and the U.S Coast Guard (USCG), for their

efforts under the Resource Conservation and Recovery

Act (RCRA) and Superfund to gather, develop, and

make publicly available health and safety guidelines,

publications, and contractor reports

This practical hazardous waste health and safety

handbook and training manual would not be possible

without the previous work of many individuals,

compa-nies, and government agencies During the past fifteen

years, the authors have worked with a host of highly

qualified professionals in the nation’s efforts to contain

hazardous waste spills, clean up abandoned landfills,

control hazardous chemical threats to the environment

and public health, and adequately dispose of solid and

hazardous waste

Outside reviewers contributed substantially to the

quality and focus of this edition.A special thanks to

Pro-fessor Joe Ledbetter, Ph.D., University of Texas, for his

specific review comments, which improved the quality

of this edition The South Carolina Department of

Health and Environmental Control, through the

reviews of Shannon Berry, Ron Kinney, and Harold

Seabrook, was very helpful in keeping this edition

prac-tical and current An extensive review by William

Keffer, senior engineering advisor, was very helpful for

the second edition, and also provided some excellent

options for this edition The NIOSH staff, especially

Stephen P Berardinelli, Ph.D., Aaron W Schoppee,Ph.D., Jim Spahr, and Dr Belard in the Division ofSafety Research, Morgantown, West Virginia, recom-mended a number of changes in the second editionrelating to personal protective equipment that wereincorporated into the present edition The authors alsorecognize the following for their review comments onthe first two editions, which have been incorporated into the present edition: James P Kirk, William R.Goutdie III, Steven J Sherman, Vicki Santoro, Joseph

A Gispanski, and James B Walters

The contributing authors of the third edition of

Protecting Personnel at Hazardous Waste Sites provided

the key items for updating this training manual: EdwardBishop, Ph.D., C.I.H.; Joanna Burger, Ph.D.; Leslie W.Cole, M.S.; David L Dahlstrom, C.I.H.; David Dyjack,Dr.P.H., C.I.H.; Michael Gochfeld, M.D., Ph.D.; DennisGoldman, Ph.D.; Ralph F Goldman, Ph.D.; Larry L.Janssen, C.I.H.; Paul W Jonmaire, Ph.D.; John M.Lippitt, M.En.; William F Martin, P.E.; James M.Melius, M.D.; Richard C Montgomery, Ph.D.; James P.Pastorick, B.A.; Lamar E Priester, Jr., Ph.D.; L E

“Chip” Priester III; Timothy G Pothero, B.A.; Charles

F Redinger, C.I.H., Ph.D.; Charles J Sawyer, C.I.H.,P.E.; Arthur D Schwope, M.A.; H Randy Sweet;Lynn P Wallace, Ph.D., P.E., D.E.E.; and Paul J Webb,C.I.H

The authors wish to thank Laurie Goodale ofPriester & Associates for her desktop publishing skills

in the production of this third edition Thanks to Ann T.Kiefert, M.S., for her technical editing of the final draft

Ms Kiefert’s experience with Florida’s environmentalregulations and her graduate studies at Florida StateUniversity contributed to her expert input

Acknowledgements

viii

INTRODUCTION: LAWS AND REGULATIONS

Department of Energy (DoE) lands and facilities Occupational risk assessment and toxicology have been expanded because classroom experi- ence at educational centers all across the United States indicated that many professional people were being trained for hazardous waste occupa- tions with very limited backgrounds in applied occupational health.

This manual is intended for individuals who have direct responsibility to carry out hazardous waste site cleanup and hazardous waste emergencies It can be used as:

• a training manual

• a planning tool

• a management reference

• an educational textbook

• a technical reference document

It also serves as an applied industrial hygiene handbook for hazardous waste activities and is a valuable sourcebook on hazardous waste occu- pational safety and health It should be used as a preliminary basis for developing a specific health and safety program Consult other sources and experienced individuals as necessary for the details needed to design and implement occupa- tional safety and health plans at specific haz- ardous waste sites.

Although this manual cites federal lations, it is not a definitive legal document and should not be taken as such Individuals who are responsible for the health and safety of workers

regu-at hazardous waste sites should obtain and comply with the most recent federal, state, and local regulations

Several of the key hazardous waste, health and safety–related regulations are briefly summa- rized in this chapter.

1

I n the past two decades, industry,

govern-ment, and the general public have become

increasingly aware of the need to respond

to the hazardous waste problem, which has

grown steadily over the past 100 years In 1980,

Congress passed the Comprehensive

Environ-mental Response, Compensation, and Liability

Act (CERCLA)—the Superfund law—to provide

for liability, compensation, cleanup, and

emer-gency response for hazardous substances

released into the environment and the cleanup

of abandoned and uncontrolled hazardous waste

disposal sites The Superfund Amendments and

Reauthorization Act (SARA) of 1986 extended

CERCLA and added new authorities under Title

III of SARA that included Emergency Planning,

Community Right-to-Know, and Toxic Chemical

Release Reporting The Resource Conservation

and Recovery Act (RCRA) of 1976 sets the

stan-dards for waste handling, storage, and disposal.

The 1975 Hazardous Materials Transportation Act

provides regulation of hazardous materials

label-ing, packaglabel-ing, placardlabel-ing, manifestlabel-ing, and

transporting.

This handbook is a training manual and

guid-ance document for employees and supervisors

responsible for occupational safety and health

programs at hazardous waste sites It was

devel-oped to give site supervisors specific

instruc-tions and guidelines on how to protect the

safety and health of workers A second goal of

this handbook is to improve hazardous waste

operations efficiency through knowledge and

training of the work force A third goal is to

reduce the cost of hazardous waste cleanups

through reduced lawsuits and liability losses of

employers and individuals.

Additional field experience and new

regu-lations have prompted this third edition Updated

information has been added to address the

1990’s effort to clean up and convert to civilian

use major Department of Defense (DoD) and

The Codes of Federal Regulations (CFRs) provide the

complete text of current regulations Some of the CFRs

of direct application to hazardous waste operations are

as follows: 40 CFR 300, 29 CFR 1910, 40 CFR 260265, 30

CFR 11, and 49 CFR 100199 These federal publicationscan be located at major public libraries, university libraries, and most major federal and state offices Manydatabases will provide access to these regulations Two

2 HAZARDOUS WASTE HANDBOOK

of these are the Computer-Aided Environmental

Legislative Data System (CELDS) and LEXIS CELDS

contains abstracts of environmental regulations and is

designed for use in environmental impact analysis and

environmental quality management The abstracts are

written in an informative narrative style, with excessive

verbiage removed Characteristics of this system are as

follows:

1 Legislative information is indexed to a hierarchical

keyword thesaurus, in addition to being indexed to a

set of environmental keywords

2 Information can be obtained for federal and state

environmental regulations, as well as regulatory

requirements related to the keywords

3 Appropriate reference documents, such as enactment/

effective date, legislative reference, administrative

agency, and bibliographical reference, are provided

The system is structured to satisfy the user agency’s

(U.S Department of Defense) specific needs for

envi-ronmental regulations; consequently, the needs of

other agencies may not be completely satisfied by

this system.Augmentations to the system include

regula-tions of concern to the U.S Environmental Protection

Agency (EPA)

LEXIS is a full-text system from Mead Data

Central It is a database with a family of files that

contain the full text of the following:

1 United States Code—a codification by major title of

the body of U.S statutes

2 Code of Federal Regulations—a codification by

major title of current effective administrative agency

regulations

3 Federal Register—July 1980 to present

4 Supreme Court decisions since 1960

5 State court decisions—courts of last resort,

inter-mediary courts, lower courts

FEDERAL REGULATIONS

SUPERFUND AMENDMENTS AND

REAUTHORIZATION ACT (SARA)

(42 U.S.C 11001 ET SEQ.)

Basic Objective This act revises and extends

CERCLA (Superfund authorization) CERCLA is

extended by the addition of new authorities known

as the Emergency Planning and Community

Right-to-Know Act of 1986 (also known as Title III of SARA)

Title III of SARA provides for “emergency planning

and preparedness, community right-to-know reporting,

and toxic chemical release reporting.”

Key Provisions There are key provisions which

apply when a hazardous substance is handled and when

an actual release has occurred Even before any gency has arisen, certain information must be madeavailable to state and local authorities, and to thegeneral public upon request Facility owners and oper-ators are obligated to provide information pertaining

emer-to any regulated substance present on the facility emer-to theappropriate state or local authorities (Subtitle A) Threetypes of information are to be reported to the appro-priate state and local authorities (Subtitle B):

1 Material Safety Data Sheets (MSDSs), which are

prepared by the chemical manufacturer of any ardous chemical and are retained by the facilityowner or operator (or if confidentiality is a concern,

haz-a list of hhaz-azhaz-ardous chemichaz-als for which MSDSs are retained can be made available) These sheetscontain general information on a hazardous chemi-cal and provide an initial notice to the state and localauthorities

2 Emergency and Hazardous Chemical Inventory

Forms, which are submitted annually to the state and local authorities Tier 1 information includes themaximum amount of a hazardous chemical that may

be present at any time during the reporting year, andthe average daily amount present during the yearprior to the reporting year Also included is the

“general location of hazardous chemicals in each egory.” This information is available to the generalpublic upon request Tier II information is reportedonly if requested by an emergency entity or firedepartment This information provides a moredetailed description of the chemicals, the averageamounts handled, the precise location, storage pro-cedures, and whether the information is to be madeavailable to the general public (allowing for the pro-tection of confidential information)

cat-3 Toxic chemical release reporting, which releases

general information about effluents and emissions ofany “toxic chemicals.”

In the event a release of a hazardous substance does occur, a facility owner or operator must notify the authorities This notification must identify the hazardous chemical involved; amounts released;time, duration, environmental fate; and suggestedaction

A multilayer emergency planning and responsenetwork on the state and local government levels is to

be established (also providing a notification scheme forthe event of a release)

Enforcement Responsibilities: Federal–State tionship Local emergency planning committees or anemergency response commission appointed by the gov-ernor of the state are responsible for the responsescheme The primary drafters of the local response plans

Rela-INTRODUCTION: LAWS AND REGULATIONS 3

are local committees, which are also responsible for

ini-tiating the response procedure in the event of an

emer-gency Each state commission will supervise the local

activities

Accomplishments and Impacts SARA

legisla-tion, promoting emergency planning and providing

citizen information at the local level, was a response to

the Bhopal, India, disaster A major intent is to reassure

U.S citizens that a similar tragedy will not occur in this

country The standardization of reporting and record

keeping should produce long-term benefits and

well-designed response plans Whether a high-quality

emergency response involvement can be maintained

indefinitely at the local level remains a question

COMPREHENSIVE ENVIRONMENTAL RESPONSE,

COMPENSATION, AND LIABILITY ACT

(42 U.S.C 9601 ET SEQ.)

Basic Objective The act, known as CERCLA or

“Superfund,” has four objectives These are:

1 To provide the enforcement agency the authority to

respond to releases of hazardous wastes (as defined

in the Clean Water Act, Clean Air Act, Toxic

Sub-stances Control Act, Solid Waste Disposal Act, and

by the administrator of the enforcement agency)

from “inactive” hazardous waste sites that endanger

public health and the environment

2 To establish a Hazardous Substance Superfund

3 To establish regulations controlling inactive

haz-ardous waste sites

4 To provide liability for releases of hazardous wastes

from such inactive sites

The act amends the Solid Waste Disposal Act It

provides for an inventory of inactive hazardous waste

sites and for the appropriate action to protect the public

from the dangers possible from such sites It is a

response to the concern for the dangers of negligent

hazardous waste disposal practices

Key Provisions Key provisions of this act are:

1 The establishment of a Hazardous Substance

Super-fund based on fees from industry and federal

appro-priations to finance response actions

2 The establishment of liability to recover costs of

response from liable parties, and to induce the

cleanup of sites by responsible persons

3 The determination of the number of inactive

hazardous waste sites by conducting a national

inventory This inventory shall include coordination

by the Agency for Toxic Substances and Disease

Registry within the Public Health Service for the

purpose of implementing the health-related

authori-ties in the act

4 The provision of the authority for the EPA to act

when there is a release or threat of release of a lutant from a site that may endanger public health.Such action may include “removal, remedy andremedial action.”

pol-5 The revision of the National Contingency Plan for

the Removal of Oil and Hazardous Substances (40CFR, Part 300) This plan must include a section toestablish procedures and standards for responding toreleases of hazardous substances, pollutants, and con-taminants as well as abatement actions necessary tooffset imminent dangers

Enforcement Responsibilities: Federal–State lationship The EPA has responsibility for enforce-ment of the act as it pertains to the inventory, liability,and response provisions The EPA is also responsible forclaims against the Hazardous Substance Superfund,which is administered by the President of the UnitedStates The EPA is responsible for promulgating regula-tions to designate hazardous substances, reportablequantities, and procedures for response The NationalResponse Center, established by the Clean Water Act,

Re-is responsible for notifying appropriate governmentagencies of any release

The following Department of Transportation cies also have responsibilities under the act:

agen-1 U.S Coast Guard—responses to releases from

vessels

2 Federal Aviation Administration—responses to

re-leases from aircraft

3 Federal Highway Administration—responses to

re-leases from motor carriers

4 Federal Railway Administration—responses to

re-leases from rolling stock

States are encouraged by the act to participate in sponse actions The act authorizes the EPA to enter intocontracts or cooperative agreements with states to takeresponse actions The fund can be used to defray costs tothe states The EPA must first approve an agreement with the state, based on the commitment by the state toprovide funding for remedial implementation Beforeundertaking any remedial action as part of a response,the EPA must consult with the affected state(s)

re-Accomplishments and Impacts On July 16, 1982,the EPA published the final regulations pursuant toSection 105 of the act, revising the National Contin-gency Plan for Oil and Hazardous Substances under the Clean Water Act, reflecting new responsibilities andpowers created by CERCLA The plan establishes aneffective response program Because the act requires anational inventory of inactive hazardous waste sites, theintent is to identify potential danger areas and effect a

4 HAZARDOUS WASTE HANDBOOK

cleanup or remedial actions to avoid or mitigate public

health and environmental dangers In studying a

sam-pling of these sites, the House Committee on Interstate

and Foreign Commerce (House Report No 961016)

found four dangerous characteristics common to all the

sites These characteristics are:

1 Large quantities of hazardous wastes

2 Unsafe design of the sites and unsafe disposal

practices

3 Substantial environmental danger from the wastes

4 The potential for major health problems to people

living and working in the area of the sites

The intent of the act is to eliminate the above

prob-lems by dealing with the vast quantities of hazardous

and toxic wastes in unsafe disposal sites in the country

The immediate impact of the act has been the

identifi-cation of the worst sites where the environmental and

health dangers are imminent This priority list will be

used to spend the money available in the Hazardous

Waste Response Fund in the most effective way to

elim-inate the imminent dangers.The long-term impact of the

act will be to eliminate and clean up all the identified

inactive sites and develop practices and procedures to

prevent future hazards in such sites, whether active or

inactive Another accomplishment of the act is to

estab-lish liability for the cost of cleanup to discourage unsafe

design and disposal practices The act has armed the

EPA with the authority to pursue an active program of

cost recovery for cleanup from responsible parties

RESOURCE CONSERVATION AND RECOVERY

ACT (RCRA) (42 U.S.C 6901 ET SEQ.)

Basic Objective RCRA, as it exists now, is the

culmination of a long series of pieces of legislation,

dating back to the passage of the Solid Waste Disposal

Act of 1965, which address the problem of waste

dis-posal It began with the attempt to control solid waste

disposal and eventually evolved into an expression of

the national concern with the safe and proper disposal

of hazardous waste Establishing alternatives to existing

methods of land disposal and the conversion of solid

wastes into energy are two important needs noted by

the act

The RCRA of 1976 gives the EPA broad authority

to regulate the disposal of hazardous wastes; encourages

the development of solid waste management plans and

nonhazardous waste regulatory programs by states;

pro-hibits open dumping of wastes; regulates underground

storage tanks; and provides for a national research,

development, and demonstration program for improved

solid waste management and resource conservation

techniques

The control of hazardous wastes will be undertaken

by identifying and tracking hazardous wastes as they are

generated, ensuring that hazardous wastes are properlycontained and transported, and regulating the storage,disposal, or treatment of hazardous wastes

A major objective of the RCRA is to protect theenvironment and conserve resources through the devel-opment and implementation of solid-waste plans by the states The act recognizes the need to develop anddemonstrate waste management practices that are notonly environmentally sound and economical but alsoconserve resources The act requires the EPA to under-take a number of special studies on subjects such asresource recovery from glass and plastic waste and man-aging the disposal of sludge and tires An InteragencyResource Conservation Committee has been estab-lished to report to the president and the Congress onthe economic, social, and environmental consequences

of present and alternative resource conservation andresource recovery techniques

Key Provisions Some of the significant elements

of the Act follow

Hazardous wastes are identified by definition andpublication Four classes or definitions of hazardouswaste have been identified: ignitability, reactivity, cor-rosivity, and toxicity The chemicals that fall into theseclasses are regulated primarily because of the danger-ous situations they can cause when landfilled withtypical municipal refuse Four lists, containing approxi-mately 1000 distinct chemical compounds, have beenpublished (These lists are revised as new chemicalsbecome available.) These lists include waste chemicalsfrom nonspecific sources, by-products of specific indus-trial processes, and pure or off-specification commercialchemical products These classes of chemicals are regu-lated primarily to protect groundwater from contami-nation by toxic products and by-products

The act requires tracking of hazardous wastes fromgeneration, to transportation, to storage, and to disposal

or treatment Generators, transporters, and operators offacilities that dispose of solid wastes must comply with a system of record keeping, labeling, and manu-facturing to ensure that all hazardous waste is desig-nated only for authorized treatment, storage, or disposalfacilities The EPA must issue permits for these facili-ties, and the facilities must comply with standards issued

by the EPA

The states must develop hazardous waste ment plans and have them approved by the EPA Theseplans will regulate hazardous wastes in the states andwill control the issuance of permits If a state does notdevelop such a plan, the EPA will develop one based onthe federal program

manage-Solid waste disposal sites are to be inventoried todetermine compliance with sanitary landfill regulationsissued by the EPA Open dumps are to be closed orupgraded within five years of the inventory As with haz-

INTRODUCTION: LAWS AND REGULATIONS 5

ardous waste management, states must develop

man-agement plans to control the disposal of solid waste and

to regulate disposal sites The EPA has issued guidelines

to assist states in developing their programs

As of 1983, experience and a variety of studies

dating back to the initial passage of the RCRA

legisla-tion found that an estimated 40 million metric tons

of hazardous waste escaped control annually through

loopholes in the legislative and regulatory framework

Subsequently, Congress was forced to reevaluate

RCRA, and in doing so found that RCRA fell short of

its legislative intent by failing to regulate a significant

number of small-quantity generators, regulate waste

oil, ensure the environmentally sound operation of land

disposal facilities, and realize the need to control the

contamination of groundwater caused by leaking

under-ground storage tanks

Major amendments were enacted in 1984 in order

to address the shortcomings of RCRA Key provisions

of the 1984 amendments include:

• Notification of underground tank data and

regula-tions for detection, prevention, and correction of

releases

• Incorporation of small-quantity generators (which

generate between 100 and 1000 kg of hazardous waste

per month) into the regulatory scheme

• Restriction of land disposal of a variety of wastes

unless the EPA determines that land disposal is safe

from human health and environmental points of

views

• Requirement of corrective action by treatment,

storage, and disposal facilities for all releases of

haz-ardous waste regardless of when the waste was placed

in the unit

• Requirement of the EPA to inspect

government-owned facilities (which handle hazardous waste)

annually, and other permitted hazardous waste

facil-ities at least every other year

• Regulation of facilities that burn wastes and oils in

boilers and industrial furnaces

Enforcement Responsibilities: Federal–State

Re-lationship Subtitle C of the Solid Waste Disposal

Act, as amended by the RCRA of 1976, directs the EPA

to promulgate regulations for the management of

hazardous wastes

The hazardous waste regulations initially published

in May 1980 from the RCRA control the treatment,

storage, transport, and disposal of waste chemicals that

may be hazardous if landfilled in the traditional way

These regulations (40 CFR 261265) identify hazardous

chemicals in two ways, by listing and by definition A

chemical substance that appears on any of the lists or

meets any one of the definitions must be handled as ahazardous waste

Like other environmental legislation, RCRAenforcement responsibilities for hazardous waste man-agement will eventually be handled by each state, withfederal approval Each state must submit a program forthe control of hazardous waste These programs must

be approved by the EPA before the state can acceptenforcement responsibilities

The state programs will pass through three phasesbefore final approval will be given The first phase is theinterim phase, during which the federal program will be

in effect The states will begin submitting their programsfor the control of hazardous wastes The second-phaseprograms will address permitting procedures A finalphase will provide federal guidance for design and oper-ation of hazardous waste disposal facilities Many stateshave chosen to allow the federal programs to suffice asthe state program to avoid the expense of designing andenforcing the program

It should also be noted that the Department ofTransportation has enforcement responsibilities for thetransportation of hazardous wastes and for the manifestsystem involved in transporting

Accomplishments and Impacts The 1980 tions for the control of hazardous wastes were aresponse to the national concern over hazardous wastedisposal States have begun to discover their own “LoveCanals,” and the impacts of unregulated disposal of haz-ardous wastes on their communities While the Super-fund legislation provides funds for the cleanup of suchsites, RCRA attempts to avoid future Love Canals.TOXIC SUBSTANCES CONTROL ACT (TSCA) (15 U.S.C 2601 ET SEQ.)

regula-Basic Objective This act sets up the toxic stances program which is administered by the EPA Ifthe EPA finds that a chemical substance may present anunreasonable risk to health or to the environment andthat there is insufficient data to predict the effects of thesubstance, manufacturers may be required to conducttests to evaluate the characteristics of the substance,such as persistence, acute toxicity, or carcinogeniceffects Also, the act establishes a committee to develop

sub-a prioritized list of chemicsub-al substsub-ances to be tested Thecommittee may list up to fifty chemicals that must betested within one year However, the EPA may requiretesting for chemicals not on the priority list

Manufacturers must notify the EPA of the tion to manufacture a new chemical substance The EPAmay then determine if adequate data are available toassess the health and environmental effects of the newchemical If the data are determined to be inadequate,the EPA will require testing Most important, the EPAmay prohibit the manufacture, sale, use, or disposal of a

inten-6 HAZARDOUS WASTE HANDBOOK

new or existing chemical substance if it finds the

chem-ical presents an unreasonable risk to health or the

envi-ronment The EPA can also limit the amount of the

chemical that can be manufactured and the amount and

manner in which the chemical can be used

The act also regulates the labeling and disposal of

polychlorinated biphenyls (PCBs) and prohibits their

production and distribution after July 1979

In 1986, Title II, “Asbestos Hazard Emergency

Response,” was added to address issues of inspection

and removal of asbestos products in public schools and

to study the extent of (and response to) the public

health danger posed by asbestos in public and

com-mercial buildings

Key Provisions Testing is required on chemical

substances meeting certain criteria to develop data with

respect to the health and environmental effects for

which there are insufficient data relevant to the

deter-mination that the chemical substance does or does not

present an unreasonable risk of injury to health or the

environment

Testing shall include identification of the chemical

and standards for test data Testing is required from the

following:

1 Manufacturers of a chemical meeting certain criteria

2 Processors of a chemical meeting certain criteria

3 Distributors or persons involved in disposal of

chem-icals meeting certain criteria

Test data required by the act must be submitted to

the EPA The data must identify the chemical, list the

uses or intended uses, and provide the information

required by the applicable standards for the

develop-ment of test data

The EPA will establish a priority list of chemical

substances for regulation Priority is given to substances

known to cause or contribute to cancer, gene mutations,

or birth defects The list is revised and updated as

needed

A new chemical may not be manufactured without

notifying the EPA at least ninety days before

manufac-turing begins The notification must include test data

showing that the manufacture, processing, use, and

dis-posal of the chemical will not present an unreasonable

risk of injury to health or the environment Chemical

manufacturers must keep records for submission to the

EPA as required The EPA will use these reports to

compile an inventory of chemical substances

manufac-tured or processed in the United States

The act also regulates the disposal and use of and

prohibits the future manufacture of PCBs, and requires

the EPA to engage, through various means, in research,

development, collection, dissemination, and utilization

of data relevant to chemical substances

Enforcement Responsibilities: Federal–State lationship The EPA has enforcement responsibilitiesfor the act, but the act makes provisions for consulta-tions with other federal agencies involved in health andenvironmental issues, such as OSHA and the Depart-ment of Health and Human Services Initially, the statescould receive EPA grants to aid them in establishingprograms at the state level to prevent or eliminateunreasonable risks to health or the environment related

Re-to chemical substances

Accomplishments and Impacts TSCA has vided a framework for ensuring that chemical manu-facturers take responsibility for testing the health andenvironmental effects of chemical substances Although

pro-it requires the manufacturer to establish the safety of achemical, it still gives the EPA the final authority toprohibit or severely restrict chemicals in commerce.Thus, it is an attempt to prevent significant health andenvironmental problems that may surface later on Thefact that when this legislation was initially passed, PCBeffects were such an issue because of their widespreadand uncontrolled use is reflective of public concernsover the number of other possible chemicals commonlyused which could be carcinogenic Public concern was

so visible that an immediate need was perceived to ulate PCBs Thus, PCBs are controlled and specificallyprohibited by TSCA rather than RCRA

reg-NATIONAL ENVIRONMENTAL POLICY ACT(NEPA) (42 U.S.C 4341 ET SEQ.)

Enforcement Responsibilities: Federal–State lationship The President’s Council on EnvironmentalQuality (CEQ) has the main responsibility for oversee-ing federal efforts to comply with NEPA In 1978, CEQissued regulations to comply with the procedural provi-sions of NEPA Other provisions of NEPA apply tomajor federal actions significantly affecting the quality

Re-of the human environment

Accomplishments and Impacts The enactment

of this act has added a new dimension to the planningand decision-making process of federal agencies in theUnited States.This act requires federal agencies to assessthe environmental impact of implementing their majorprograms and actions early in the planning process Forthose projects or actions that are either expected to have

a significant effect on the quality of the human ment or are expected to be controversial on environ-mental grounds, the proponent agency is required to file

environ-a formenviron-al environmentenviron-al impenviron-act stenviron-atement (EIS) Otheraccomplishments and impacts of the act are:

• It has provided a systematic means of dealing withenvironmental concerns and including environmentalcosts in the decision-making process

INTRODUCTION: LAWS AND REGULATIONS 7

• It has opened governmental activities and projects to

public scrutiny and public participation

• Some projects have been delayed because of the time

required to comply with the NEPA requirements

• Many projects have been modified or abandoned to

balance environmental costs with other benefits

• It has served to accomplish the four purposes of the

act as stated in its text

FEDERAL INSECTICIDE, FUNGICIDE, AND

RODENTICIDE ACT (FIFRA) (7 U.S.C 136 ET SEQ.)

Basic Objective FIFRA is designed to regulate

the use and safety of pesticide products within the

United States The 1972 amendments are intended to

ensure that the environmental harm resulting from the

use of pesticides does not outweigh the benefits

Key Provisions Key provisions of FIFRA include:

• The evaluation of risks posed by pesticides

(requir-ing registration with the EPA)

• The classification and certification of pesticides by

specific use (as a way to control exposure)

• The restriction, suspension, or cancellation of the use

of pesticides that are harmful to the environment

• The enforcement of the above requirements through

inspections, labeling, notices, and state regulation

Enforcement Responsibilities: Federal–State

Re-lationship The EPA is allowed to establish

regula-tions concerning registration, inspecregula-tions, fines, and

criminal penalties, and to stop the sale of pesticides

Primary enforcement responsibility, however, has been

assumed by almost every state Federal law specifies

only that each state must have adequate laws and

enforcement procedures to assume primary authority

As in the case for almost any federal law, FIFRA

preempts state law to the extent that it addresses the

pesticide problem Thus, a state cannot adopt a law or

regulation that counters a provision of FIFRA, but it

can adopt laws which are more stringent

Accomplishments and Impacts Although the

volume of pesticides and related information is

enor-mous, FIFRA has enabled the EPA to acquire additional

information for analysis of risk and environmental

degradation resulting from the use of pesticides This

information has been, and will continue to be, generally

invaluable in such analyses However, Congress

contin-ues to struggle with the balancing of benefits and

detri-ments of the use of pesticides in its attempt to deal

with the economic, scientific, and environmental issues

involved in the regulation of pesticides

FEDERAL AND STATE REGULATORY AGENCIES

The following federal agencies and their parallel stateagencies can be contacted for the latest regulations,training materials, and technical updates:

National Institute for Occupational Safety and Health(NIOSH)—Centers for Disease Control and Prevention

4676 Columbia ParkwayCincinnati, OH 45226Occupational Safety and Health Administration(OSHA)

200 Constitution Avenue, NWWashington, DC 20210Environmental Protection Agency (EPA)

401 M Street, SWWashington, DC 20460Federal Emergency Management Administration(FEMA)

500 C Street, SWWashington, DC 20472U.S Coast Guard (USCG)—Department of Trans-portation

2100 Second Street, SWWashington, DC 20593Agency for Toxic Substances and Disease Registry

1600 Clifton Road, NEAtlanta, GA 30333Although this handbook was designed to assistsupervisors at abandoned or uncontrolled hazardouswaste sites, the information can be used in planning forand responding to emergencies involving hazardousmaterials

A short bibliography is provided at the end of each chapter to provide additional sources of technicalinformation

BIBLIOGRAPHY

“Accreditation of Training Programs for HazardousWaste Operations: Notice of Public Hearings.”

Federal Register 55 (210): 45616–8, 1990.

American Conference of Governmental Industrial

Hygienists (ACGIH) Threshold Limit Values for Chemical Substances and Physical Agents and Biological Exposure Indices Cincinnati, Ohio:

8 HAZARDOUS WASTE HANDBOOK

Blackman, W.C Jr Basic Hazardous Waste

Manage-ment 2nd ed New York: Louis Publishers, 1996.

Bretherick, L Handbook of Reactive Chemical

Hazards 3rd ed Boston: Butterworth-Heinemann,

1985

Cheremisinoff, P.N Hazardous Materials: Emergency

Response Pocket Handbook Lancaster, PA:

Tech-nomic, 1988

Corbitt, R.A Standard Handbook of Environmental

Engineering New York: McGraw-Hill, 1989.

Dyjack, D.T., S.P Levine, et al “Comparison of AIHA

ISO 9001 ” AIHA Journal 59:419–29, June,

1989

EPA Standard Operating Guides U.S EPA (OERR),

OSWER Directive 9285.1–02, Washington, DC,

1988

—— (1989) Worker Protection Standards for

Haz-ardous Waste Operations and Emergency Response:

Final Rule 40 CFR 311 54(120):26653–8 (July 23).

Government Institutes, Inc Hazardous Material Spills

—Conference Proceedings Rockville, MD:

Gov-ernment Institutes, Inc., yearly

—— Management of Uncontrolled Hazardous Waste

Sites—Conference Proceedings Rockville, MD:

Government Institutes, Inc., annually

Inhaber, H Slaying the NIMBY Dragon New

Brunswick, NJ: Transaction Publishers, 1998

Lave, L.B., and A.C Upton Toxic Chemicals, Health and

the Environment Baltimore, MD: Johns Hopkins

Press, 1987

Lindgren, G.F Guide to Managing Industrial Hazardous

Waste Boston: Butterworth-Heinemann, 1983.

Martin, W.F., and M Gochfeld Introduction and Federal

Programs Chapter 1 of Protecting Personnel

at Hazardous Waste Sites. 3rd ed Boston:

Butterworth-Heineman, 2000

National Institute for Occupational Safety and Health

(NIOSH) Occupational Safety and Health ance Manual for Hazardous Waste Site Activities.

Guid-U.S Department of Health and Human ServicesPublication No 85115 Washington, DC: GPO,October, 1985

—— Pocket Guide to Chemical Hazards Washington,

DC: National Institute for Occupational Safety andHealth, 1997

—— Registry of Toxic Effects of Chemical Substances.

Cincinnati: NIOSH, 1990

—— /OSHA/USGG/EPA Occupational Safety & Health Guidance Manual for Hazardous Waste Site Activities Document DHHS (NIOSH) 85–115,

1985

Occupational Safety and Health Administration(OSHA) 29 CFR 1910.120, Vol 54 (42), March 6,1989

Scannell, G.F Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120 U.S.

DOL (OSHA) Directorate of Compliance grams CPL 2–2.51, 1990

Pro-Sullivan, T.F.P Directory of Environmental Information Sources 3rd ed Rockville, MD: Government Insti-

Waxman, M.F Hazardous Waste Site Operations New

York: John Wiley and Sons, 1996

HAZARDS

• cold exposure

• noise Interaction among the substances may produce additional compounds not originally deposited at the site Workers are subject to dangers posed by the disorderly physical envi- ronment of uncontrolled sites The stress of working in protective clothing adds its own risk Selection of protective equipment often is overly conservative due to many unknowns (see Chapter 6, Personal Protective Equipment).

In approaching a site, it is prudent to sume that all these hazards are present until site characterization has shown otherwise A site health and safety plan must provide protection against the potential hazards and specific protec- tion against individual known hazards The safety plan must be continuously updated with new information and changing site conditions.

as-9

H azardous waste sites pose a

multi-tude of health and safety risks, any

one of which could result in serious

injury or death (see Table 2.1) These

hazards are due to the physical and chemical

nature of the site as well as the work being

per-formed They include the following:

• chemical exposure

• fire and explosion

• oxygen deficiency

• ionizing radiation

• biologic (etiologic) hazards

• physical safety hazards

• electrical hazards

• heat stress

CHEMICAL EXPOSURE

Preventing exposure to toxic chemicals is a primary

concern at hazardous waste sites Most sites contain

a variety of chemical substances in gaseous, liquid, or

solid form These substances can enter the unprotected

body by inhalation, direct skin contact, ingestion, or

through a puncture wound (injection) A contaminant

can cause damage at the point of contact or act

sys-temically by causing a toxic effect at other points in

the body

Workers on hazardous waste sites can be exposed

to chemicals in a variety of ways, including:

• Direct contact with wastes during sampling, loading

and over-packing of containers, and handling of bulk

wastes and waste containers

• Cross-contamination of food, tobacco products,

ma-terials, and equipment caused by inappropriate

prac-tices (smoking or eating in contaminated areas)

and/or inadequate decontamination of personnel and

equipment upon exit from contamination areas

• Entry into low-lying areas and confined spaces where

air contaminants accumulate from waste containers

and areas and piles containing bulk wastes

• Contact with groundwater and surface waters thathave been contaminated by direct contact withwastes and/or contaminated media

• Contact with chemical contaminants released, oftenunder pressure, from unplanned chemical reactionscaused by mixing incompatible chemical in the wastesand contaminated media being cleaned up

• Contact with previously unknown wastes when containers are opened or ruptured during handlingand/or uncovered during excavation and movement

of bulk wastes and soils

• Contact with wastes released or media contaminated

by spills, failure of containment, fires, explosions andother emergency situations

Preventing worker exposures is the primary objective

of site controls, safe work practices, and use of sonal protection equipment and clothing (see Chapter

per-7, Site Controls, and Chapter 6, Personal ProtectiveEquipment)

Chemical exposures are generally divided into twocategories: acute and chronic Symptoms resulting from

acute exposures usually occur during or shortly after

exposure to a sufficiently high concentration of a

TABLE 2.1 Overview of Typical Hazards Encountered at Hazardous Waste Sites

Hazard Exposure Route Symptom or Measurement or Personal Additional Type or Cause Effect Measuring Device Prevention Protection Comments

Chemical Inhalation, eye/skin Headaches, nausea, TLV, PEL, IDLH, LD 50 , Follow SOP and Protective clothing Remove person exposure contact, ingestion, rashes, burning, etc Devices: OVA, safety procedures; Respiratory immediately and

puncture coughing, cancer, HNU, air sampling, use extra caution protection decontaminate if

liver damage, detection tubes, when working in hot exposed to a kidney damage personal monitoring, zones Use remote chemical.

convulsions, coma, field GC control devices

Ionizing Molecular degradation Radiation burns, Radiation detection Do radiation survey Protective clothing Consult health radiation releases gamma, beta, mutagenicity, meters, Geiger-Müller early investigation and dust masks physicist if

and alpha radiation: death detector, gamma Gamma is detectable will protect against measurements are gamma is most scintillation meter through thin metal alpha and help above 10 mR/hr At

chemical wastes available.

Fire and Unstable chemicals; Burns, concussion, Flash point: Ventilate to prevent Nomex Always test

explosion incompatible shock, dismem- <100°F—flammable vapor buildup; use Fire proximity chemicals before

reactions; shock- berment, death material 100°F–200°F only nonsparking suits Blasts suits mixing; in enclosed sensitive chemicals; —fire hazard tools; use explosion- SCBAs areas, use a nitrogen

enclosed spaces or >25% LEL—Withdraw safe instruments of toxic vapors and

or static electricity accurately in

oxygen-deficient environment.

>10% LEL—Stop all spark-producing operation.

Oxygen In enclosed spaces Inattention, impaired 21% O 2 is normal Monitor enclosed SCBAs supply air When O 2 is below deficiency (e.g., buildings, tanks, judgment, reduced <19.5% O 2 is of and low areas before Safety lines 19.5% at HW site,

manholes) or low coordination, concern at HW sites entry; use mechanical assume O 2 has been areas (e.g., trenches), altered breathing <16% O 2 is dangerous ventilation replaced by toxic

other gases; generally nausea, brain When O 2 is displaced Toxic gases will they are dangerous damage, uncon- in air, N 2 is displaced likely require

Therefore, if O 2 is reduced from 21% to 19.5%, a total of 1.5%

O 2 was displaced.

Since N 2 is a 4 : 1 ratio with O 2 , 6.0% of N 2

was displaced, for a total of 7.5% air; this is equal to 75,000 ppm, a potentially deadly concentration for many chemicals to which one could be exposed.

Physical Sharp objects, Slip, trip, or fall Visual inspection and Identify physical Lighter protective

safety slippery surfaces, resulting in cuts, monitoring hazards Correct clothing,

better-hazards steep grades, uneven broken bones, those that can be fitting clothing,

terrain, fogged bruises, concus- corrected and rope hard-hats, boots

Rubber or other nonconducting gloves, handgrips, etc.

Electrical Exposed skin Electrical shock Electricity, Ohmmeter, Lock out and tag Rubber and other Particular care is

inspection switches, and gloves, handgrips, using large

controls ladders, etc equipment where

overhead electrical wires are present Also need to check underground utilities

if excavation is involved.

Heat Caused by difficult Inattention, impaired Temperature, both Frequent rest breaks, Cool packs or Beware of cryogenic stress work done in clothing judgment, tiredness, ambient and body monitor body vests in hot chemicals.

designed to protect exhaustion, fatigue, temperature and conditions; warm Fogging of face against chemicals but stroke, death condition, drink clothing under piece is a common

conditions supplied air suits fluids should be

are used replaced in heat

stress conditions.

(continued)

designed to protect coordination, temperature and conditions.

against chemicals but hypothermia, death condition, drink

conditions.

Biologic Waste from hospitals Fever, disease, Swab, swipe, and Decontaminate with Disposable gloves Biohazard label (etiologic) and research facilities death grab high-volume air disinfectant and use should result in

impingement media hygiene Immunize if etiologic agents Requires laboratory agent is known present until

bandages, surgical tubing) should be considered suspect Noise Compressors, Temporary or Sound-level meter and Shielding or Earplugs Use of earphones

machinery, large permanent hearing octave-band analyzer enclosure of source with communication

contaminated.

See Appendix K for additional information on a selection of chemicals and their hazards, IDLH, PEL, symptoms, and personal protective equipment TLV = threshold limit value; PEL = permissible exposure limit; IDLH = immediately dangerous to life or health; LD 50 = lethal dose, 50%; OVA = organic vapor analyzer; GC = gas chromatography; LEL = lower exposure limit; SCBA = self-contained breathing apparatus.

HAZARDS 13

contaminant The concentration required to produce

such effects varies widely from chemical to chemical

The term chronic exposure generally refers to exposures

to low concentrations of a contaminant over a long

period of time The concentrations required to produce

symptoms of chronic exposure depend on the chemical,

the duration of each exposure, and the number of

expo-sures For a given contaminant, the symptoms of an

acute exposure may be completely different from those

resulting from chronic exposure

For either chronic or acute exposure, the toxic

effect may be temporary and reversible or permanent

(disability or death) Some chemicals may cause obvious

symptoms such as burning, coughing, nausea, tearing

eyes, or rashes Other chemicals may cause health

damage without any such warning signs Health effects

such as cancer or respiratory disease may not become

manifest for several years or decades after exposure In

addition, some toxic chemicals may be colorless and/

or odorless, may dull the sense of smell, or may not

produce any immediate discomfort that could act as a

warning that toxic chemicals are present Thus, the

ability of a worker to notice an exposure by his or her

senses or feelings of discomfort cannot be relied upon

to determine whether a worker is at risk of toxic

expo-sure to these chemicals

The effects of exposure are not just dependent

on the chemical, its concentration, the route of entry,

and the duration of exposure A given response to a

toxic chemical also may be influenced by a number

of personal factors, such as the individual’s smoking

habits

A primary exposure route of concern on a

haz-ardous waste site is inhalation The lungs are extremely

vulnerable to chemical agents Even substances that do

not directly affect the lungs may pass through lung

tissue into the bloodstream Chemicals also can enter

the respiratory tract through a punctured eardrum

Direct contact of the skin and eyes by gaseous,

liquid, or solid substances is another important route of

exposure Some chemicals directly injure the skin Some

pass through the skin into the bloodstream, where they

are transported to vulnerable organs Skin absorption is

enhanced by abrasions, cuts, heat, and moisture The eye

is particularly vulnerable because airborne chemicals

can dissolve into its moist surface and be carried to the

rest of the body through the bloodstream (capillaries

are very close to the surface of the eye) Do not wear

contact lenses when wearing protective equipment,

because they can trap chemicals against the eye surface

Keeping hands away from the face, minimizing contact

with liquid and solid chemicals, and using protective

clothing and eyewear will protect against skin and eye

exposure to hazardous substances

Although ingestion should be the least significant

route of exposure at a site, it is important to be aware

of ways in which this type of exposure can occur erate ingestion of chemicals is unlikely, but personalhabits such as chewing gum or tobacco, drinking, eating,

Delib-or smoking cigarettes on-site may provide a route ofentry for chemicals

Chemical exposure by injection must be prevented.Chemicals can be introduced into the body throughpuncture wounds by stepping or tripping and fallingonto contaminated sharp objects Safety shoes with steelshanks are an important protective measure againstinjection

FIRE AND EXPLOSION

There are many potential causes of fires and explosions

at hazardous waste sites:

• chemical reactions that produce explosion, fire,

or heat

• ignition of explosive or flammable chemicals

• ignition of materials due to oxygen enrichment

• irritation of shock- or friction-sensitive compounds

• sudden release of materials under pressure

Explosions and fires may arise spontaneously.More commonly, however, they result from site activi-ties such as moving drums, accidentally mixing incom-patible chemicals, or introducing an ignition source,such as a spark from equipment At hazardous wastesites, explosions and fires not only pose the obvioushazards of intense heat, open flame, smoke inhalation,and flying objects, but they also may cause the release

of toxic chemicals into the environment Such releasescan threaten both personnel on-site and members of thegeneral public living or working nearby To protectagainst the hazard, monitor for explosive atmospheresand flammable vapors, keep all potential ignitionsources away from a fire or explosive area, use non-sparking explosion-proof equipment, and follow thework practice instructions when performing any haz-ardous task such as bulking or mixing chemicals

con-14 HAZARDOUS WASTE HANDBOOK

Oxygen deficiency may result from the

displace-ment of oxygen by another gas or the consumption of

oxygen by a chemical reaction Confined spaces or

low-lying areas are particularly vulnerable to oxygen

defi-ciency Field personnel must monitor oxygen levels and

should use supplied air respiratory equipment when

oxygen concentrations drop below 19.5% by volume

Any decrease in the oxygen level of the breathing zone

should be considered a potential immediately

danger-ous to life or health (IDLH) atmosphere

IONIZING RADIATION

Radioactive materials emit one or more of three types

of harmful radiation: alpha, beta, and gamma Alpha

radiation has limited penetration ability and is usually

stopped by clothing and the outer layers of the skin

Alpha radiation poses little threat outside the body but

can be hazardous if materials that emit alpha radiation

are inhaled or ingested Beta radiation can cause

harmful beta burns to the skin and damage the

subsur-face blood system Beta radiation also can be hazardous

if materials that emit beta radiation are inhaled or

ingested Use of protective clothing, coupled with good

personal hygiene and decontamination, affords

protec-tion against alpha and beta radiaprotec-tion

Gamma radiation easily passes through clothing

and human tissue and can cause serious and

perma-nent damage to the body Chemical protective clothing

(CPC) affords no protection against gamma

radia-tion, but use of respiratory and protective equipment

can help keep radiation-emitting materials from

entering the body by inhalation, injection, or skin

contact

If you discover levels of gamma radiation slightly

above natural background, consult a health physicist

At high levels of any type of radiation, cease activities

until the site has been examined and assessed by

health physicists

BIOLOGIC (ETIOLOGIC) HAZARDS

Wastes from hospitals and research facilities may

contain disease-causing bacteria and viruses that could

infect site personnel Like chemical hazards, etiologic

agents may be dispersed in the environment via water

and wind Other biologic hazards that may be present

at a hazardous waste site include poisonous plants,

insects, animals, and indigenous pathogens Protective

clothing and respiratory equipment can help reduce

the chances of exposure Thoroughly wash any exposed

body parts and equipment to help protect against

infection

PHYSICAL SAFETY HAZARDS

Hazardous waste sites may contain numerous physical

hazards such as the following:

an accident

Accidents involving physical hazards can result indirect injury to workers Accidents also can create addi-tional hazards, for example, increased chemical expo-sure can result from damaged protective equipment, or

a danger of explosion may be caused by the mixing ofchemicals Site personnel should be constantly on thelookout for potential safety hazards and should imme-diately inform their superiors of any new hazards so thatmitigative action can be taken

ELECTRICAL HAZARDS

Overhead power lines, downed electrical wires, andburied cables all pose a danger of shock or electrocu-tion if workers contact or sever them during site oper-ations Electrical equipment used on-site also may pose a hazard to workers Use low-voltage equipmentwith groundfault interrupters and watertight, corrosion-resistant connecting cables to help minimize this hazard

In addition, lightning is a hazard during outdoor ations, particularly for workers handling metal con-tainers or equipment Monitor weather conditions andsuspend work during electrical storms to eliminate thishazard

oper-HEAT STRESS

Heat stress can be a major hazard, especially forworkers wearing protective clothing (see Table 2.2) Thesame protective materials that shield the body fromchemical exposure limit the dissipation of body heat andmoisture Protective clothing can, therefore, create ahazardous condition Depending on the ambient tem-perature and the work being performed, heat stress canoccur very rapidly—within as little as fifteen minutes Itcan pose as great a danger to worker health as chemi-cal exposure In its early stages, heat stress can causerashes, cramps, discomfort, and drowsiness, resulting in

TABLE 2.2 Classification, Medical Aspects, and Prevention of Heat Illness

Underlying Physiologic Category and Clinical Features Predisposing Factors Disturbance Treatment Prevention

1 Temperature regulation heatstroke

Heatstroke: (1) Hot, dry skin usually red, (1) Sustained exertion in Failure of the central Immediate and rapid Medical screening of mottled or cyanotic; (2) t re , 40.5°C heat by unacclimatized drive for sweating cooling by immersion workers, selection based (104°F) and over; (3) confusion, loss of workers; (2) Lack of (cause unknown), in chilled water with on health and physical consciousness, convulsions, t re physical fitness and leading to loss of massage or by wrap- fitness; acclimatization continues to rise; fatal if treatment obesity; (3) Recent evaporative cooling and ping in wet sheet with for 5 to 7 days by

delayed alcohol intake; an uncontrolled accel- vigorous fanning with graded work and heat

(4) Dehydration; (5) erating rise in t re ; there cool, dry air; avoid exposure; monitoring Individual susceptibility; may be partial rather overcooling, treat shock workers during sus- (6) Chronic cardiovas- than complete failure if present tained work in severe

2 Circulatory hypostasis heat syncope

Fainting while standing erect and Lack of acclimatization Pooling of blood in Move to cooler area; rest Acclimatization;

immobile in heat dilated vessels of skin in recumbent position; intermittent activity to

and lower parts of body recovery prompt and assist venous return to

3 Water and/or salt depletion

(a) Heat exhaustion: (1) Fatigue, (1) Sustained exertion (1) Dehydration from Move to cooler area; Acclimatize workers nausea, headache, giddiness; (2) Skin in heat; (2) Lack of deficiency of water; (2) rest in recumbent using a breaking-in

clammy and moist, complexion pale, acclimatization; Lack of acclimatization; position; administer schedule for 5 to 7 days; muddy, or hectic flush; (3) May faint on (3) Failure to replace (3) Circulatory strain for fluids by mouth; keep at supplement dietary salt standing with rapid, thready pulse and water loss in sweat competing demands for rest until urine volume only during acclimati- low blood pressure; (4) Oral temperature blood flow to skin and to indicates that water zation; ample drinking normal or low but rectal temperature active muscles balances have been water to be available at

than 3 g/L.

(b) Heat cramps: Painful spasms of (1) Heavy sweating Loss of body salt in Salted liquids by mouth Adequate salt intake muscles used during work (arms, legs, during hot work; (2) sweat; water intake or more prompt relief by with meals; in

or abdominal); onset during or after Drinking large amounts dilutes electrolytes; IV infusion unacclimatized workers

(continued)

TABLE 2.2 (Continued)

Underlying Physiologic Category and Clinical Features Predisposing Factors Disturbance Treatment Prevention

4 Skin eruptions

(a) Heat rash (miliaria rubra; “prickly Unrelieved exposure to Plugging of sweat gland Mild drying lotions, skin Cool sleeping quarters heat”): Profuse tiny raised vesicles humid heat with skin ducts with retention of cleanliness to prevent to allow skin to dry (blisterlike) on affected areas, prickling continuously wet with sweat and inflammatory infection between heat exposure sensations during heat exposure unevaporated sweat reaction.

(b) Anhydrotic heat exhaustion (miliaria Weeks or months of Skin trauma (heat rash, No effective treatment Treat heat rash and profunda): Extensive areas of skin do constant exposure to sunburn) causes sweat available for anhydrotic avoid further skin

not sweat on heat exposure but present climatic heat with retention deep in skin; areas of skin; recovery trauma by sunburn; gooseflesh appearance, which subsides previous history of reduced evaporative of sweating occurs periodic relief from with cool environments; associated with extensive heat rash cooling causes heat gradually on return to sustained heat.

incapacitation in heat and sunburn intolerance cooler climate.

5 Behavioral disorders

(a) Heat fatigue-transient: Impaired Performance decrement Discomfort and Not indicated unless Acclimatization and performance of skilled sensorimotor, in unacclimatized and physiologic strain accompanied by other training for work in the mental or vigilance tasks in heat unskilled worker heat illness heat.

(b) Heat fatigue-chronic: Reduced Workers at risk come Psychosocial stresses Medical treatment for Orientation on life in hot performance capacity, lowering of self- from temperate climates probably as important as serious cases; speedy regions (customs, climate, imposed standards of social behavior for long residence in heat stress; may involve relief of symptoms on living conditions, etc.) (e.g., alcoholic overindulgence), inability tropical latitudes hormonal imbalance, but returning home.

HAZARDS 17

impaired functional ability that threatens the safety of

both the individual and her coworkers Continued heat

stress can lead to heatstroke and death Avoid

overpro-tection, carefully train and monitor personnel wearing

protective clothing, judiciously schedule work and rest

periods, and replace fluids frequently to protect against

this hazard For further information on heat stress,

see Chapter 6, Personal Protective Equipment, and that

chapter’s section on heat stress and other physiological

factors

HEATSTROKE

The classical description of heatstroke includes (1) a

major disruption of central nervous function

(uncon-sciousness or convulsions); (2) a lack of sweating; and

(3) a rectal temperature in excess of 41°C (105.8°F)

The 41°C rectal temperature is an arbitrary value for

hyperpyrexia because the disorder has not been

pro-duced experimentally in humans, so observations are

made only after the admission of patients to hospitals,

which may vary in time from about thirty minutes

to several hours after the event In some heatstroke

cases, sweating may be present The local

circum-stances of metabolic and environmental heat loads that

give rise to the disorder are highly variable and are

often difficult or impossible to reconstruct with

accu-racy The period between the occurrence of the event

and admission to a hospital may result in a quite

dif-ferent medical outcome from one patient to another,

depending on the knowledge, understanding, skill,

and facilities available to those who render first aid in

the intervening period Recently, the sequence of

bio-logic events in some fatal heatstroke cases has been

described

Heatstroke is a medical emergency, and any

proce-dure from the moment of onset that will cool the patient

improves the prognosis Placing the patient in a shady

area, removing outer clothing and wetting the skin,

and increasing air movement to enhance evaporative

cooling are all urgently needed until professional

methods of cooling and assessment of the degree of the

disorder are available Frequently, by the time a patient

is admitted to a hospital, the disorder has progressed to

a multisystem lesion affecting virtually all tissues and

organs In the typical clinical presentation, the central

nervous system is disorganized, and there is commonly

evidence of fragility of small blood vessels, possibly

coupled with the loss of integrity of cellular membranes

in many tissues The blood-clotting mechanism is often

severely disturbed, as are liver and kidney functions It

is not clear, however, whether these events are present

at the onset of the disorder or whether their

develop-ment requires a combination of a given degree of

ele-vated body temperature and a certain period of time for

tissue or cellular damage to occur Postmortem

evalua-tion indicates there are few tissues that escape logical involvement Early recognition of the disorder

patho-or its impending onset, associated with appropriatetreatment, considerably reduces the death rate and theextent of organ and tissue involvement An ill workershould not be sent home or left unattended without aphysician’s specific order

HEAT EXHAUSTIONHeat exhaustion is a mild form of heat disorder thatreadily yields to prompt treatment This disorder hasbeen encountered frequently in experimental assess-ment of heat tolerance Characteristically, it is some-times but not always accompanied by a small increase

in body temperature (38°C to 39°C or 100.4°F to102.2°F) The symptoms of headache, nausea, vertigo,weakness, thirst, and giddiness are common to both heatexhaustion and the early stages of heatstroke There is

a wide inter-individual variation in the ability to ate an increased body temperature; some individualscannot tolerate rectal temperatures of 38°C to 39°C, andothers continue to perform well at even higher rectaltemperatures

toler-There are, of course, many variants in the opment of heat disorders Failure to replace water may predispose the individual to one or more of theheat disorders and may complicate an already complexsituation Therefore, cases of hyperpyrexia can be pre-cipitated by hypohydration It is unlikely that there isonly one cause of hyperpyrexia without some influencefrom another Recent data suggest that cases of heatexhaustion can be expected to occur some ten timesmore frequently than cases of heatstroke

devel-HEAT CRAMPSHeat cramps are common in individuals who work hard

in the heat They are attributable to a continued loss ofsalt in the sweat, accompanied by a copious intake ofwater without appropriate replacement of salt Otherelectrolytes such as Mg++, Ca++, and K+ also may beinvolved Cramps often occur in the muscles principallyused during work and can be readily alleviated by rest,the ingestion of water, and the correction of any bodyfluid electrolyte imbalance

HEAT RASHESThe most common heat rash is prickly heat (miliariarubra), which appears as red papules, usually in areaswhere the clothing is restrictive, and gives rise to a prick-ling sensation, particularly as sweating increases Itoccurs in skin that is persistently wetted by unevapo-rated sweat, apparently because the keratinous layers ofthe skin absorb water, swell, and mechanically obstructthe sweat ducts The papules may become infectedunless they are treated

18 HAZARDOUS WASTE HANDBOOK

Another skin disorder, miliaria crystallina, appears

with the onset of sweating in skin previously injured at

the surface, such as areas damaged by sunburn The

damaged skin forms watery vesicles which prevent

the escape of sweat The watery vesicles rapidly subside

once sweating stops and the problem ceases to exist

once the damaged skin is sloughed

Miliaria profunda occurs when sweat ducts below

the skin surface are blocked This rash also occurs

following sunburn injury but has been reported to occur

without clear evidence of previous skin injury Discrete

and pale elevations of the skin resembling gooseflesh

are present In most cases, the rashes disappear when

the individuals are returned to cool environments

It seems likely that the rashes’ occurrence can be

reduced or eliminated when a substantial part of the day

is spent in cool and/or dry areas so that the skin surface

can dry

Although these heat rashes are not dangerous in

themselves, each of them carries the possibility of

result-ing in patchy areas that are anhydrotic, adversely

af-fecting evaporative heat loss and thermoregulation In

experimentally induced miliaria rubra, sweating

capac-ity recovers within three to four weeks Wet and/or

damaged skin could absorb toxic chemicals more

readily than dry, unbroken skin

COLD EXPOSURE

Cold injury (hypothermia and frostbite) is a danger at

low temperatures and at extreme wind-chill factors To

guard against them, wear appropriate clothing, have

warm shelter readily available, carefully schedule work

and rest periods, and monitor workers’ physical

condi-tions Learn to recognize warning symptoms, such as

reduced coordination, drowsiness, impaired judgment,

fatigue, and numbing of toes and fingers

HYPOTHERMIA

Hypothermia is the result of the body losing heat faster

than it can produce it

Get the victim out of the cold

Remove wet clothes and dry the victim’s skin

Rewarm the victim by active or passive means

FROSTBITEFrostbite is caused by the freezing of tissues

Risk FactorsvasoconstrictorTypes

frost nipsuperficial frostbitedeep frostbiteTreatmentGet the victim out of the cold

Remove the victim’s clothing

Soak the victim in warm water (102°F to 106°F)

NOISE

Working around large equipment often exposesworkers to excessive noise The effects of noise caninclude the following:

• psychological effects from workers being startled,annoyed, or distracted

• physiological effects, including physical damage, pain,temporary and/or permanent hearing loss, or reducedmuscular control (when exposure is severe)

• communication interference that may increase tial hazards due to the inability to warn of danger or

poten-to communicate safety precautions

Permissible noise exposures are listed in OSHAregulations 29 CFR 1910.95 Earmuffs, earplugs, orother noise attenuators can be used for hearing protection

ed Boston: Butterworth–Heinemann, 2000

Employee Health Risks at Toxic Waste Sites Publication

No 919SSP Serial No 10183 Washington, DC:GPO, September, 1990

Encyclopedia of Occupational Health and Safety 4th ed.

Luigi Parmeggiani, ed Geneva: InternationalLabor Office, 1998

Hallenbeck, W.H., and M Gochfeld “Toxicology and

Risk Assessment.” Chapter 4 in Protecting nel at Hazardous Waste Sites, W.F Martin and

Person-M Gochfeld, eds 3rd ed Boston: Butterworth–Heinemann, 2000

HAZARDS 19

Hill, V.H “Control of Noise.” In The Industrial

Envi-ronment: Its Evaluation and Control Cincinnati:

National Institute for Occupational Safety and

Health, 1973

Lewis, R.J., Sr Hazardous Chemicals Desk Reference.

4th ed New York: Van Nostrand Reinhold, 1997

National Fire Protection Association Fire Protection

Guide on Hazardous Materials 7th ed Quincy,

MA: National Fire Protection Association, 1978

National Institute for Occupational Safety and Health

(NIOSH) Hot Environments U.S Department of

Health and Human Services Publication No 80132

Cincinnati: NIOSH, 1980

—— Occupational Exposure to Hot Environments.

U.S Department of Health and Human Services

Publication No 86113 Cincinnati: NIOSH, April,

1986

NIOSH Pocket Guide to Chemical Hazards U.S.

Department of Health and Human Services, Public

Health Service, Centers for Disease Control,

NIOSH, 97–140, June, 1997

North American Emergency Response Guidebook U.S.

Department of Transportation, 1996 This book can

be ordered through safety supply companies

Noyes Data Corporation Hazardous Chemicals Data

Book. 2nd ed Parkridge, NJ: Noyes Data

Corporation, 1986

Occupational Safety and Health Administration

(OSHA) Control of Hazardous Energy

(Lockout-Tagout) U.S Department of Labor Publication No.

Pohanish, R.P., and S.A Greene, eds Hazardous Substances Resource Guide Detroit, MI: Gale

Sax, N.I Dangerous Properties of Industrial Materials.

7th ed New York: Van Nostrand Reinhold, 1988

—— and R.J Lewis, Sr Three-volume set Sax’s

Dangerous Properties of Industrial Materials.

9th ed New York: Van Nostrand Reinhold, 1996

Standard Operating Safety Guides U.S EPA, Office

of Emergency and Remedial Response, June,1992

TLVs and BEIs: Threshold Limit Values for Chemical Substances and Physical Agents; Biological Expo- sure Indices Cincinnati, OH: American Conference

of Governmental Industrial Hygienists (ACGIH),1997

Waxman, M.F Hazardous Waste Site Operation: A ing Manual for Site Professionals New York: John

Train-Wiley & Sons, 1996

PLANNING AND ORGANIZATION

concerns for each phase of the operation and describe the procedures for worker and public protection.

Coordinating with the existing response organizations is required and will provide access

to a wide range of experienced individuals gress established a national response organiza- tion under the National Contingency Plan to coordinate response actions to releases of haz- ardous substances National Contingency Plan response teams are composed of representa- tives of federal, state, and local agencies The EPA has designated individuals responsible for coordinating federal activities related to site cleanup.

Con-Planning should be viewed as an ongoing process The cleanup activities and health and safety plans must be continuously revised to adapt to new site conditions and account for new information.

21

P lanning is the first step in hazardous

waste site response activities By

anticipating and taking steps to

pre-vent potential health and safety

hazards, work at a waste site can proceed with

minimum risk to workers and the public.

Planning can be organized into three phases:

developing an organizational structure for site

operations, establishing a work plan that

consid-ers each specific phase of the operation, and

developing and implementing a health and safety

plan.

The organizational structure should identify

the personnel needed for the operation,

estab-lish the chain of command, and specify the

res-ponsibilities of each employee The work plan

should establish the objectives of site operations

and the logistics and resources required to

achieve the goals The health and safety plan

should determine the health and safety

PERSONNEL AND RESPONSIBILITIES

An organizational structure and personnel

require-ments should be developed in the first phase of

planning This structure should do the following:

• Identify a leader who has the authority to direct all

response activities

• Periodically inspect protective equipment

• Ensure that protective clothing and equipment are

properly stored and maintained

• Control entry and exit at the access control points

• Coordinate safety program activities with the

scien-tific advisers

• Confirm each team member’s suitability for work

based on a physician’s recommendation

• Monitor the work parties for signs of stress, such as

cold exposure, heat stress, and fatigue

• Monitor on-site hazards and conditions

• Conduct periodic inspections to determine whether

the health and safety plan is being followed

• Enforce the buddy system

• Know emergency procedures, evacuation routes,

and the telephone numbers of the ambulance, local

hospital, poison control center, fire department, andpolice department

• Notify, when necessary, local public emergency officers

• Coordinate emergency medical care

• Manage field operations

• Execute the work plan and schedule

• Enforce safety procedures

• Enforce site control

• Document field activities and sample collection

• Notify emergency response personnel by telephone

or radio in the event of an emergency

• Assist the site safety officer (SSO) in a rescue operation

• Maintain a log of communication and site activities

• Assist other field team members in the clean areas, asneeded

• Maintain line-of-sight and communication contactwith the work parties via walkie-talkies, air horns, orother means

22 HAZARDOUS WASTE HANDBOOK

• Set up decontamination lines and the

decontamina-tion soludecontamina-tions appropriate for the types of chemical

contaminations on-site

• Identify the other personnel needed for the project

and assign their general functions and

responsibili-ties

• Show lines of authority, responsibility, and

communi-cation

• Identify the contact points and relationships with

other response agencies

The organizational structure and responsibilities

may require adjustments as new information is gained

and site conditions change Any changes to the

organi-zational structure should be recorded in the work or

safety plans and communicated to all parties involved

The following list of responsibilities must be assigned to

designated individuals:

• Provide the necessary facilities, equipment, and

money

• Provide adequate personnel and time resources to

conduct activities safely

• Support the efforts of on-site management

• Provide appropriate disciplinary actions when unsafe

acts or practices occur

• Provide advice on the design of the work plan and the

health and safety plan

• Become familiar with the types of materials on-site

and the potential for worker exposure; recommend

the medical program for the site

• Provide emergency treatment and decontamination

procedures for the specific types of exposures that

may occur at the site Obtain special drugs,

equip-ment, or supplies necessary to treat such exposures

• Provide emergency treatment procedures

appropri-ate to the hazards on-site

• Prepare and organize the background review of the

situation, the work plan, and the field team

• Obtain permission for site access and coordinate

activities with appropriate officials

• Ensure that the work plan is completed on schedule

• Brief the field teams on their specific assignments

• Prepare the final report and support files on response

activities

• Serve as the liaison with public officials

• Choose protective clothing and equipment

• Control the decontamination of all equipment,

per-sonnel, and samples from the contaminated area

• Assist in the disposal of contaminated clothing and

materials

• Ensure that all required equipment is available

• Advise medical personnel of potential exposures andconsequences

• Stand by, with protective gear partially on, near ardous waste areas

haz-• Rescue any workers whose health or safety is endangered

• Notify the SSO or supervisor of unsafe conditions

• Plan and mobilize the facilities, materials, and personnel required for the response

• Photograph site conditions

• Archive photographs

• Provide financial and contractual support

• Release information to the news media and thepublic concerning site activities

• Manage site security

• Maintain the official records of site activities

• Advise on the properties of the materials on-site

• Advise on contaminant control methods

• Advise on the dangers of chemical mixtures that mayresult from site activities

• Provide immediate advice to those at the scene of achemical-related emergency

• Provide communication to the public in the event of

an emergency

• Predict the movement of released hazardous als through the atmospheric, geologic, and hydrologicenvironment

materi-• Assess the effect of this movement on air, water, and surface water quality

ground-• Predict the exposure of people and the ecosystem tothe materials

• Help plan for public evacuation

• Mobilize transit equipment

• Assist in public evacuation

• Respond to fires that occur on-site

• Provide meteorological information

• Control access to the site

• Advise on methods of handling explosive materials

• Assist in safely detonating or disposing of explosivematerials

• Conduct health hazard assessments

• Advise on adequate health protection

• Conduct monitoring tests to determine worker sures to hazardous substances

expo-PLANNING AND ORGANIZATION 23

• Advise on toxicological properties and health effects

of substances on-site

• Provide recommendations on the protection of

worker health

This list is intended to illustrate the scope of

responsibilities and functions that must be covered One

individual may perform one or several of the functions

described, depending on the size of the operation and

the training and experience of the individual Use

Appendix J, Health and Safety Checklist, as a tool for

ensuring that all the tasks are being done and the

responsibilities are adequately assigned

Regardless of the size of the effort, all response

teams should include an individual responsible for

implementing health and safety requirements The

designated safety person should have access to other

occupational health and safety professionals Once

an organizational system has been developed, all

individuals should be identified and their respective

authorities clearly explained to all members of the

response team

One of the critical elements in worker safety is

the attitude of all levels of project management This

attitude sets the tone for the entire operation The SSO

and the supervisor or team leader must have the clear

support of senior management for establishing,

implementing, and enforcing safety programs The

importance of management’s attitude toward safety

throughout the project cannot be overemphasized since

site personnel are more likely to cooperate with these

programs if they sense a genuine concern on the part of

management

The following organizational factors are indicators

of successful worker safety programs:

• strong management commitment to safety

• close contact and interaction among workers,

super-visors, and management, enabling open

communica-tion on safety as well as other job-related matters

• a work force subject to less turnover, including a

core of workers with significant lengths of service in

their jobs

• a high level of housekeeping, orderly workplace

conditions, and effective environmental quality

control

• well-developed selection, job placement, and

ad-vancement procedures

• training practices emphasizing early indoctrination

and follow-up instruction in job safety procedures

The most effective industrial safety programs are

often identified by their success in dealing with people

Open communication among workers, supervisors, and

management concerning work site safety is essential

The effective management of response actions

at hazardous waste sites requires a commitment to thehealth and safety of the general public as well as to theon-site personnel Prevention and containment of con-taminant release into the surrounding community should

be addressed in the planning stages of a project Not onlymust the public be protected, but they also must be madeaware of the health and safety program and have confi-dence in it To accomplish these goals, the project teamleader or public information officer, under the supervi-sion of the project team leader, should establish commu-nity liaison well before any response action is begun and

be in continuous contact with community leaders

WORK PLAN

A work plan describing anticipated cleanup activitiesmust be developed before beginning on-site responseactions The work plan should be periodically reexam-ined and updated as new information about site condi-tions is obtained

The following steps should be taken in formulating

a work plan:

• Review available information:

site recordswaste inventoriesgenerator and transporter manifestsprevious sampling and monitoring datasite photos

state and local environmental and health agencyrecords

• Define work objectives

• Determine methods of accomplishing the objectives(e.g., sampling plan, inventory, disposal techniques)

• Determine personnel requirements

• Determine the need for additional training of personnel Evaluate their current knowledge/skilllevel against the tasks they will perform and the situations they may encounter (see Chapter 11,Training)

• Determine equipment requirements Evaluate theneed for special equipment or services, such as thesubcontracting of drilling equipment or heavy equip-ment and operators

Preparation of the work plan often requires a tidisciplinary approach Input from all levels of man-agement and outside consultants may improve the planand prevent oversights

mul-HEALTH AND SAFETY PLAN

The health and safety plan must provide measures tominimize accidents and injuries that may occur during

24 HAZARDOUS WASTE HANDBOOK

normal daily activities or adverse conditions such as

hot or cold weather This section describes the

plan-ning process for health and safety during normal site

operations—that is, nonemergency situations Chapter

9, Spills and Site Emergencies, describes planning and

response to emergencies

Development of a written health and safety plan

helps ensure that all safety aspects of site operations are

thoroughly examined prior to commencing fieldwork

The health and safety plan may need updating as site

cleanup progresses

Planning requires information, thus, planning and

site characterization should be coordinated An initial

health and safety plan should be developed so that the

preliminary site assessment can proceed in a safe

manner The information from this assessment can then

be used to refine the health and safety plan so that

further site activities can proceed safely At a minimum,

the plan should do the following:

• Name key personnel and alternates responsible for

site safety

• Describe the safety and health risks or hazards

as-sociated with each site operation conducted (see

Chapter 4, Site Characterization)

• Confirm that personnel are adequately trained to

perform their job responsibilities and to handle the

specific hazardous situations they may encounter (see

Chapter 11, Training)

• Describe the protective clothing and equipment to be

worn by personnel during various site operations (see

Chapter 6, Personal Protective Equipment)

• Describe the program for periodic air monitoring,

personnel monitoring, and environmental sampling

(see Chapter 4, Site Characterization, and Chapter 7,

Site Control and Work Practices)

• Describe the actions to be taken to mitigate existing

hazards

• Define site control measures and include a site map

(see Chapter 7, Site Control and Work Practices)

• Establish decontamination procedures for personnel

and equipment (see Chapter 8, Decontamination)

• Set forth the site’s standard operating

proce-dures (SOPs)

• Ensure that all employees have completed all

medical monitoring requirements

• Set forth a contingency plan for safe and effective

responses to emergencies

• Establish confined-space entry procedures

• Establish a spill-containment program

Appendix E provides a sample site safety plan for

a fairly complex hazardous waste site cleanup

opera-tion The sample plan can be used as a guide, not a dard, for designing a safety plan

stan-SAFETY MEETINGS AND INSPECTIONS

To ensure that the health and safety plan is being followed, the safety officer should conduct a safetymeeting prior to initiating any site activity and beforeeach workday These safety meetings serve the follow-ing purposes:

• describe the assigned tasks and their potentialhazards

• review the SOPs for the planned assignments

• coordinate activities

• identify methods and precautions to prevent injuries

• plan for emergencies

• describe any changes in the safety plan

• get worker feedback on safety conditions

• get worker feedback on how well the safety plan isworking

The SSO should also conduct frequent inspections

of site conditions, facilities, equipment, and activities

to determine whether the health and safety plan is adequate and being followed

At a hazardous waste site, risks to workers canchange quickly and dramatically when there arechanges in the following:

• the actions of other people

• the state of degradation of containers and ment structures

contain-• the state of equipment maintenance

• weather conditions

• the work being done

• the workers assigned to the site

The following safety inspection guidelines should beobserved:

• Develop a checklist for each site, listing the items thatshould be inspected See Appendix J

• Review the results of these inspections with sors and workers

supervi-• Reinspect any identified problems to ensure that theyhave been corrected

• Document all inspections and subsequent follow-upactions Retain these records until site activities arecompleted and as long as required by regulatoryagencies

PLANNING AND ORGANIZATION 25

The frequency at which inspections should occur varies

with the characteristics of the site and the equipment

used onsite The frequency of inspections will depend on

the following:

• the severity of risk on-site

• regulatory requirements

• operation and maintenance requirements

• the expected lifetime of clothing, equipment, vehicles,

and other items

• recommendations based on professional judgment,

laboratory test results, and field experience

BIBLIOGRAPHY

Dahlstrom, D., and P Jonmaire “Occupational Health

& Safety Programs for Hazardous Waste.” Chapter

3 in Protecting Personnel at Hazardous Waste Sites.

3rd ed W.F Martin and M Gochfeld eds Boston:

Butterworth–Heinemann, 2000

Dinardi, S.R “The Occupational Environment: Its

Eval-uation and Control.” Fairfax, VA: AIHA, 1997

Gere Engineers, Inc Hazardous Waste Site Remediation:

The Engineer’s Perspective New York: Van

Nos-trand Reinhold, 1988

Kilbourne, A.L., and K Canning “Environmental

Soft-ware Guide Delivering More Bang for the Byte.”

Pollution Engineering January, 1999, 40–53.

National Institute for Occupational Safety and Health

(NIOSH) Safety Program Practices in Holding Plants U.S Department of Health,

Record-Education, and Welfare Publication No 79136.Cincinnati: NIOSH, 1979

National Oil and Hazardous Substances Pollution tingency Plan 40 CFR Part 300.

Sawyer, C.J., and W.F Martin “Health, Safety and

Con-tingency Plans.” Chapter 13 in Protecting Personnel

at Hazardous Waste Sites 3rd ed W.F Martin

and M Gochfeld, eds Boston: Butterworth–Heinemann, 2000

Superfund Innovative Cleanup Technologies

Publica-tion No 86199P Washington, DC: GPO, 1986.U.S Environmental Protection Agency (EPA) Office

of Emergency and Remedial Response Hazard

Response Support Division Standard Operating Safety Guides Washington, DC: EPA, November,

1986

Webb, P.J “Information Gathering, Databases and Site

Characterization.” Chapter 2 in Protecting nel at Hazardous Waste Sites 3rd ed W.F Martin

Person-and M Gochfeld, eds Boston: Butterworth–Heinemann, 2000

World Health Organization “Planning.” In Hazardous Waste Management: Health Aspects of Chemical Safety Interim Document 7 Copenhagen: World

Health Organization, 1982

It is important to recognize that site terization is a continuous process In addition to the formal information gathering that takes place during the phases of site characterization

charac-described here, all site personnel should be stantly alert for new information about site conditions.

con-This chapter details the three phases of site characterization and provides a general guide that should be adapted to meet the specific situ- ation Within each phase of information gather- ing, determine the most appropriate sequence of steps, particularly if time or budget considera- tions limit the scope of the investigation Wher- ever possible, pursue all information sources.

27

S ite characterization is directly related to

worker protection The more accurate,

detailed, and comprehensive the

infor-mation about a site, the more the

pro-tective measures can be tailored to the hazards

workers may encounter.

At each phase of site characterization, first

obtain information and then evaluate it to define

the hazards the site may pose to field personnel.

Then use this assessment to develop work and

safety plans that define the scope and limits of

the next phase of investigation.

The personnel with primary responsibility for

site characterization and assessment are the site

safety officer and the project team leader In

addition, outside experts, such as chemists,

health physicists, industrial hygienists, and

toxi-cologists, may be needed to interpret all the

available information on site conditions.

Site characterization generally proceeds in

three phases:

1 Conduct off-site surveys to gather all

information prior to site entry.

OFF-SITE CHARACTERIZATION

Obtain as much information as possible before site

entry so that the hazards can be evaluated and

prelim-inary controls instituted to protect initial entry

person-nel Focus initial information-gathering missions on

identifying all potential or suspected IDLH conditions

Some indicators of potential IDLH conditions are listed

in Table 4.1

Information can be obtained off-site in two ways:

remote resources and off-site reconnaissance

REMOTE RESOURCES

Collect as much data as possible before any personnel

go on-site Obtain the following information where

possible:

• exact location of the site

• detailed description of the activity that occurred at

the site

• duration of the activity

• meteorological data—current weather and forecast,prevailing wind direction, precipitation levels, tem-perature profiles

• terrain—historical and current site maps, site tographs, aerial photographs, U.S Geological Surveytopographic quadrangle maps, land use maps, landcover maps

pho-• utility company records

• geologic and hydrologic data

• habitation—population centers, population at risk

• accessibility by air and roads

• paths of dispersion

• present status of response and who has responded

• hazardous substances involved and their chemicaland physical properties; some sources of this infor-mation follow:

company records, receipts, logbooks, and ledgersrecords from state and federal pollution-controlregulatory/enforcement agencies, state attorney

28 HAZARDOUS WASTE HANDBOOK

general’s office, state occupational safety and

health agencies, and state fire marshall’s office

waste storage inventories and manifests or shipping

papers

interviews with personnel and their families (verify

all information from interviews)

records of generators and transporters

water department and sewage district records

interviews with neighbors (note possible

site-related medical problems and verify all

informa-tion from interviews)

local fire and police department records

court records

utility company records

media reports (verify all information from the

media)

interviews with nearby residents (verify all

infor-mation from interviews)

previous surveying (including soil,

ground-penetrating radar, and magnetometer surveys),

sampling, and monitoring data

OFF-SITE RECONNAISSANCE

At a site in which the hazards are largely unknown or

there is no need to go on-site immediately, make visual

observations, monitor atmospheric concentrations of

airborne pollutants at the site perimeter (see Chapter 5,

Air Monitoring), and collect samples near the site

Samples taken off-site are not definite indications of

on-site conditions but do assist in the preliminary

eval-uation Off-site reconnaissance should involve the

following actions:

• Develop a preliminary site map, with the locations of

buildings, containers, impoundments, pits, ponds, and

tanks

• Review historical and current aerial photographs

Note the following:

disappearance of natural depressions, quarries, orpits

variation in revegetation of disturbed areasmounding or uplift in disturbed areas or paved surfaces

modifications in gradechanges in vegetation around buildings and storageareas

changes in traffic patterns at site

• Note any labels, markings, or placards on containers

discol-• Monitor the ambient air at the site perimeter for thefollowing materials:

toxic substancescombustible gasesinorganic gases, particulates, and vaporsorganic gases, particulates, and vaporsoxygen deficiency

ionizing radiationspecific materials, if known

• Note any unusual odors

• Collect and analyze off-site samples, including the following:

soildrinking watergroundwatersite runoffsurface water

PROTECTION OF ENTRY PERSONNEL

The selection of protective equipment for the initial sitesurvey should be based on (1) the information fromremote resources and off-site reconnaissance and (2)the proposed work to be accomplished For example, ifthe purpose of the survey is to inspect on-site condi-tions, count containers, measure the ambient air for hotspots (areas with high concentrations of toxic chemi-cals), and generally get acquainted with the site, thelevel of protection will be less stringent than if contain-ers are to be opened and samples taken (Chapter 6,Personal Protective Equipment, provides more detail

on the selection of protective items.)The ensemble of clothing and equipment referred

to as Level B protection is generally the minimum levelrecommended by the EPA for an initial entry until thesite hazards have been identified and the most appro-

TABLE 4.1 Indicators of Potential

IDLH Conditions

Large containers or tanks that must be entered

Enclosed spaces (such as buildings or trenches) that

must be entered

Potentially explosive or flammable situations (indicated

by bulging drums, effervescence, gas generation, or

instrument readings)

Extremely toxic materials (such as cyanide or

phosgene)

Presence of uncontained wastes (such as standing

pools of liquids or severely discolored soil)

Areas where biological indicators (such as dead

animals or vegetation) are located

SITE CHARACTERIZATION 29

priate protective clothing and equipment chosen Level

B is preferred over Level A whenever there is no reason

to believe in the presence of skin-penetrating toxins,

such as cyanide gases or rocket fuels, because of the

physical risks posed by the lack of visibility, dexterity,

and heat stress from the full encapsulating suit in Level

A protection Those physical risks must be carefully

weighted against the chemical risks of the site Level B

equipment is described in Chapter 6

ON-SITE INFORMATION GATHERING

SITE SURVEY

The purpose of an on-site survey is to verify and

supplement information from the off-site

characteriza-tion Prior to going on-site, use the off-site

characteri-zation to develop a safety plan for site entry, addressing

the work to be accomplished and prescribing the

pro-cedures to protect the health and safety of the entry

team Establish priorities for monitoring and

investi-gating after carefully evaluating probable conditions

Because team members are entering an unknown

envi-ronment, caution and conservative actions are

appro-priate The composition of the entry team depends on

the site characteristics but should consist of four

persons—two who will enter the site and two outside

support people outfitted with personal protective

equip-ment (PPE) and prepared to enter the site in case of

emergency

During the site survey, the following should be

completed:

• Monitor the air for IDLH conditions (combustible or

explosive atmospheres, oxygen deficiency, toxic

substances)

• Monitor for ionizing radiation Survey for gamma and

beta radiation with a Geiger-Müller (GM) detection

tube or a gamma scintillation tube If alpha radiation

is expected, use a proportional counter

• Visually observe for signs of IDLH or potential

IDLH conditions, including the presence of the

Exercise extreme caution in continuing the site

survey when IDLH hazards are indicated Tables 4.1

and 4.2 provide some guidelines for decision making

If IDLH conditions are not present, or if proper

pre-cautions can be taken, continue the survey

• Conduct further air monitoring as necessary

• Note the types of containers, impoundments, or other

storage systems:

paper or wood packagesmetal or plastic barrels or drumsunderground tanks

aboveground tankscompressed-gas tankscompressed-gas cylinderspits, ponds, or lagoons

• Note the condition of waste containers and storagesystems:

sound (undamaged)visibly rusted or corrodedleaking

bulgingtypes and quantities of material in containerslabels on containers indicating corrosive, explosive,flammable, or toxic materials

• Note the physical condition of the materials:

gas, liquid, or solidcolor and turbiditybehavior—corroding, foaming, or vaporizingconditions conducive to splash or contact

• Identify natural wind barriers:

buildingshillstankstrees

• Determine the potential paths of dispersion:

airbiological routes, such as food chains and animalsgroundwater

land surfacesurface water

• Note any indicators of potential chemical exposure:dead fish, animals, or vegetation

dust or spray in the airfissures or cracks in solid surfaces that expose deepwaste layers

pools of liquidfoam or oil on liquid surfacesgas generation or effervescencedeteriorating containerscleared land areas or possible landfill areas

• Note any physical hazards:

conditions of site structuresobstacles to entry and exittrenches, pits, or abandoned wellssoil stability, slopes, mud, and duststability of stacked materialelectrical wires (overhead or underground)noise sources

• Identify any reactive, incompatible, or highly sive wastes

corro-• Note land features

30 HAZARDOUS WASTE HANDBOOK

• Note the presence of any natural dermatitis agents:

• Take samples of the following items:

air (see Chapter 5, Air Monitoring)

drainage ditches (water and sediment)

soil (surface and subsurface)surface water

storage containersstreams and ponds (water and sediment)groundwater (upgradient, beneath site, down-gradient)

• Sample for or identify the following:

biological or pathological hazardsdisease-carrying animals or insects

TABLE 4.2 Atmospheric Hazard Guidelines

Monitoring

caution as higher levels are encountered.

in atmospheres with less than 19.5% oxygen Determine what gases are displacing oxygen.

level may be due to oxygen displacement SCBA may not be needed based on oxygen content only; look at other

indicators.

department or other fire specialist.

monitoring Consult with a health physicist.

Continue monitoring only upon advice of a health physicist.

gases and

vapors

GC mode

2 Operated in survey mode LEL = lower explosive limit; SCBA = self-contained breathing apparatus; PEL = permissible exposure limit; GC = gas chromatography; TLV = threshold limit value.

SITE CHARACTERIZATION 31

• If necessary, use one or more of the following remote

sensing or subsurface investigative methods to locate

buried wastes or contaminant plumes:

Accurate, current, and readily accessible information

about site conditions and activities is essential for

assessing hazards, reviewing plans, and making

de-cisions in an emergency situation However, action

may be required before all the highly desirable

infor-mation is available Thus, any plan for action should

provide for the continuous input of information

Documentation may become crucial in the event

of any litigation If litigation is likely, develop a

document-tracking plan with the assistance of qualified

attorneys

Record all information pertinent to field activities,

sample analysis, and site conditions in one of several

These documents must be controlled to ensure that

they are all accounted for when the project is

com-pleted Assign the task of document control to one

indi-vidual on the project team and specify the following

responsibilities:

• Number each document (including sample labels)

with a serial number

• List each document in a document inventory

• Record the whereabouts of each document in a

separate document register so that it can be readily

located In particular, record the name and location

of site personnel who have documents in their

• File all documents in a central file at the completion

of the site response

Field personnel should record all activities andobservations while on-site in a field logbook, a boundbook with consecutively numbered pages Entriesshould be made during or just after completing a task

to ensure thoroughness and accuracy The followingshould be recorded during sampling:

• date and time of entry

• type of material (e.g., sludge or wastewater)

• description of material container

• description of sample

• chemical components and concentrations, if known

• number and size of samples taken

• description and location of sampling point

• date and time of sample collection

• difficulties experienced in obtaining sample

• visual references such as maps or photographs ofsampling site

• field observations (including weather and site conditions)

• field measurements of the materials (e.g., ness, flammability, and pH)

explosive-• whether chain-of-custody forms have been filled outfor the samples

• whether chain-of-custody seals have been used

Sometimes, because of the team structure, number

of individuals involved, or need for a specific type ofpaper, notes might be made on separate sheets Whenthat is necessary, the field notes, data records, graphs,and other records must be initialed, listed in thelogbook, and stapled into it

Photographs can be an accurate, objective addition

to a fieldworkers’s written observations For each tograph taken, record the following in the field logbook:

pho-• date, time, and name of site

• name and signature of photographer

• location of subject within the site

• general compass direction of the photograph’s orientation

• general description of subject

• sequential number of the photograph and film rollnumber

• camera and lens type used

32 HAZARDOUS WASTE HANDBOOK

Assign serially numbered sample labels or tags to

sampling team personnel and record them in the field

logbook Note lost, voided, or damaged labels in the

logbook Firmly affix the labels to the sample

contain-ers using either gummed labels or tags attached by

string or wire Record on the tag, in waterproof ink,

information such as the following:

• sample log number

• date and time sample collected

• preservative used

• analysis required

• name of collector

• pertinent field data

In addition to supporting litigation, written records

of sample collection, transfer, storage, analysis, anddestruction help ensure the proper interpretation ofanalytical test results Record information describingthe chain of custody on a form that accompanies thesample from collection to destruction See Figure 4.1 for

a sample chain-of-custody record

HAZARD ASSESSMENT

Once the presence and concentration of a specific ical or class of chemicals have been established, thehealth hazards associated with that chemical or classmust be determined This is done by referring to stan-dard data reference sources and, sometimes, originaltoxicological studies For many of the more commonly

chem-Hazardous Materials Laboratory Collector’s Sample No

CHAIN-OF-CUSTODY RECORDHazardous Materials

Location of Sampling: Producer Hauler Disposal Site

Other:

Address

signature

Type of Process Producing Waste

Field Information

Sample Allocation:

1

name of organization2

name of organization3

name of organizationChain of Possession

Figure 4.1 Example of chain-of-custody record