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Hazardous Waste - Control and Prevention |
Printing Instructions
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Summary Report on OSHA Inspections
Conducted at Superfund Incineration Sites
Directorate of Compliance Programs
Occupational Safety and Health Administration
200 Constitution Avenue, NW
Washington, DC 20210
September 16, 1993
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TABLE OF CONTENTS
- INTRODUCTION
- GENERAL OVERVIEW ON INCINERATION TECHNOLOGY AND ASSOCIATED OCCUPATIONAL HAZARDS
- DESCRIPTION OF SUPERFUND TDF SITES
- INSPECTION RESULTS
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Safety and health supervisors at the site must be given the
authority to exercise their judgment in matters of employee safety and
health. Management decisions related to safety and health must reflect the
judgment of such individuals
-
The site specific safety and health plan (SAHP) must include
procedures for the implementation and enforcement of safety and health rules
for all persons on site, including employers, employees, outside contractors,
and visitors
-
The safety and health program must be effective in ensuring
the ongoing task-specific hazard analyses were conducted so that the
selection of appropriate personal protective equipment (PPE) could be made
and modified as conditions warrant
-
Task-specific hazard analyses must lead to the development of
written standard operating procedures (SOPs) that specified the controls
necessary to safely perform each task
-
Emergency response elements of the safety and health program
must be fully implemented as described in the program
-
All site control elements of the safety and health program
must be fully implemented as described in the program
-
The safety and health program must include procedures for
monitoring the effectiveness of PPE, decontamination procedures, or
housekeeping programs
-
Self-audit site inspection and abatement tracking programs
must be formalized and effectively implemented
-
Process safety management procedures for the incinerator
facility need to be improved
-
Procedures to monitor for and reduce heat stress need to be
effective
- SUMMARY
SUMMARY REPORT ON OSHA INSPECTIONS
CONDUCTED AT SUPERFUND INCINERATOR SITES
I. INTRODUCTION
The Occupational Safety and Health Administration (OSHA) and the
Environmental Protection Agency's (EPA's) Office of Emergency and Remedial
Response (OERR) recently entered into an interagency agreement to participate
jointly in activities that will ensure vigorous occupational safety and
health oversight of Superfund Thermal Destruction Facilities (TDFs). These
efforts are being coordinated by a joint EPA-Labor Superfund Safety and
Health Task Force. As part of this initiative, OSHA is conducting a number
of in-depth safety and health evaluations of Superfund incinerator
facilities; this report summarizes the findings of five such inspections
conducted between 1992 and 1993.
Although a major objective of these inspections was to assess compliance
with OSHA's Hazardous Waste Operations and Emergency Response Standard (29
CFR 1910.120), the investigations were also designed to evaluate the overall
adequacy of each facility's safety and health program, as implemented by the
contractors operating at each site, and to identify any factors that were
contributing to reduced program effectiveness. Emphasis was placed on
evaluating each employer's safety and health standard operating procedures
(SOP's) and the adequacy of task- and operation-specific hazard analyses and
emergency response programs. However, because of the focus on safety and
health program design and implementation, the investigations went beyond the
assessment of compliance with these specific OSHA requirements and included
such areas as the effectiveness of strategies to mitigate heat stress,
confined space programs and the use of process safety management approaches
in the operation of the TDF.
Inspections were conducted over a three- or four-day period by teams of from
four to six OSHA personnel. Activities undertaken by the inspection team
included the conduct of interviews with employees, safety and health
personnel, union representatives, and site management personnel to evaluate
the effectiveness of safety and health program implementation; a number of
walkthrough inspections to observe and document site conditions, operations,
and safety and health program deficiencies; the collection of wipe samples of
work surfaces in clean areas and employees' skin; and a detailed review of
each site's written safety and health plan (SAHP), emergency response plan,
operation-specific hazard analyses, and other relevant written safety and
health programs and records.
The remainder of this report is presented in four sections. The overview of
incineration technology and associated occupational hazards is presented in
Section II. Section III provides a general description of Superfund TDF
sites of the type inspected, as well as brief descriptions of the five sites
visited. Findings from each of the inspections are presented in Section IV.
Section V presents an overall summary of our findings.
II. GENERAL OVERVIEW ON INCINERATION TECHNOLOGY AND ASSOCIATED
OCCUPATIONAL HAZARDS
Incineration of hazardous waste involves the use of controlled flame
combustion to thermally destroy hazardous wastes; this method is one of the
most frequently selected technologies for treating hazardous contaminants at
Superfund sites. Incineration has been found to be suitable for the
destruction of most organic materials (volatile and non-volatile),
pesticides, and cyanides found in sludges, soils, and liquids having a high
organic content. An on-site incineration system is comprised of several
subsystems, including:
- Waste pretreatment (solids sizing, mixing, grinding);
- Waste feed (conveyors, augers, hoppers, chutes, pumps,
ram feeders);
- Primary and secondary combustion units;
- Air pollution control equipment (secondary burners,
scrubbers, precipitators, quench systems, filters, spray towers);
and
- Residue handling and disposal (solidification,
stabilization of ash, use of ash as backfill material, filtration,
clarification, and neutralization of waste liquids).
Figure 1 is a diagram of these subsystems that shows the flow of waste feed,
ash, and waste gases through the system. Residues that are generated in the
operation of the incinerator include fly ash, bottom ash, and scrubbing and
quenching liquids. (Refer to paper copy for Figure 1)
Exposure to hazardous contaminants present on an incinerator site can occur
both within the area being remediated and near the waste pretreatment and
incinerator feed area. Potential exposure to site contaminants or to their
incomplete combustion products can occur in the vicinity of the incinerator
if it is not operating according to design parameters. Deficient operating
conditions may include:
- Short residence time;
- Low oxygen to fuel- or waste-ratio;
- Low-temperature operation;
- Soil/ash fallout creating steam pressure buildup in
the combustion chamber;
- Incinerator slag buildup;
- Waste surges;
- Poor gas mixing in the combustion chamber due to low
turbulence within the chamber; and
- High halogen content of the waste feed.
In addition, poorly designed or malfunctioning air pollution control
equipment will increase particulate emissions, which often carry incomplete
combustion products adsorbed onto the particle's surface.
Other occupational hazards commonly found on Superfund incinerator sites
include those associated with thermal stress, the use of heavy construction
equipment, work in confined spaces, excavation and trenching operations,
storage and handling of flammable materials such as motor fuels, walking and
working surfaces, noise, hot or cold environments, or marine operations.
III. DESCRIPTION OF SUPERFUND TDF SITES
All of the sites inspected utilized a transportable rotary kiln incinerator
to destroy hazardous materials at the site of contamination. In addition,
contractors at each of the sites also engaged in excavation activities
designed to move contaminated soils and lagoon sediments to the waste
pretreatment area. All excavation, waste pretreatment, and waste feed
operations were conducted within a demarcated exclusion zone, entry into
which required the use of Level C or Level B personal protective equipment
(PPE). With one exception, the incinerator unit itself and associated
pollution control equipment were located outside the exclusion zone. Figure
2 shows the general layout common to each site visited. (Refer to paper
copy for Figure 2)
In instances where EPA is unable to identify the responsible party, or where
EPA cannot reach an agreement with the responsible party, EPA conducts any
necessary remedial design and remedial action (RD/RA). When EPA takes the
lead to conduct RD/RA, the Agency can choose between two contracting
mechanisms; EPA may provide direct oversight of a RD/RA contractor under the
Alternative Remedial Contracting Strategy, or EPA may request that RD/RA be
administered and implemented by the U.S. Army Corps of Engineers (USACE) or
Bureau of Reclamation (BUREC) under Interagency Agreements (IAG) with EPA.
In some instances, a State agency will assume responsibility for RD/RA, in
which case it will use any of its own contracting mechanisms. In any event,
the Agency that issues the competitively bid contract provides oversight of
the clean-up activities being conducted under the contract. The prime
contractor is responsible for implementing cleanup procedures in accordance
with the terms of the contract and is responsible for developing and
implementing a safety and health program for the site. The prime contractor
may procure the services of a number of subcontractors that specialize in
various aspects of the cleanup activity; frequently, a subcontractor is hired
to operate the TDF.
Table 1 identifies the locations of the sites investigated, the prime
contractor, the subcontractor responsible for incinerator operation, and the
state or Federal government agency responsible for remediation oversight.
All sites were inspected between May of 1992 and April of 1993. For the
remainder of this report, the identities of the sites are masked and are
referred to by a randomly assigned letter designation (Sites A through E).
TABLE 1. DESCRIPTION OF SUPERFUND INCINERATOR SITES INSPECTED BY OSHA (1992-1993) |
NAME OF SITE |
LOCATION |
GOVERNMENT OVERSIGHT AGENCY |
PRIME CONTRACTOR |
SUBCONTRACTOR FOR INCINERATOR OPERATION |
TONNAGE TO BE INCINERATED |
Bridgeport Rental and Oil Services (BROS) |
Bridgeport, NJ |
EPA/U.S. Army Corps. Of Engineers |
EBASCO |
ENSCO |
100,000 |
Old Midland Products |
Ola, Arkansas |
Arkansas Dept. of Pollution Control and Ecology |
Chemical Waste Management |
None |
Less than 25,000 |
Rose Township Demode Road |
Oakland County, MI |
EPA Region V/ARCS |
Perland Environmental Technologies, Inc. |
OHM Remediation Services Corp. |
Less than 25,000 |
Sikes Disposal Pits |
Crosby, TX |
Texas State Water Commission |
IT-DAVY (Joint Venture) |
None |
300,000 |
Big D Campground |
Kingsville, OH |
Ohio EPA/ARCS |
Flour Daniel Inc. |
Containment treatment |
30,093 (As of 4/93) |
IV. INSPECTION RESULTS
OSHA found several deficiencies in the design, management, and
implementation of safety and health plans at each site. These deficiencies
fell into 10 functional areas, listed in Table 2. With few exceptions,
deficiencies in these 10 functional areas were common to all 5 sites;
discussion of the findings specific to each functional area follows.
TABLE 2. SUMMARY OF FUNCTIONAL AREAS IN WHICH SAFETY AND HEALTH PROGRAM DEFICIENCIES WERE FOUND AT SUPERFUND INCINERATOR SITES |
- Safety and health supervisors at the site must be given the authority to exercise their judgement in matters of employee safety and health. Management decisions related to safety and health must reflect the judgement of such individuals.
- The site specific safety and health plan (SAHP) must include procedures for the implementation and enforcement of safety and health rules for all persons on site, including employers, employees, outside contractors, and visitors.
- The safety and health program must be effective in ensuring that ongoing task-specific hazard analyses were conducted so that the selection of appropriate personal protective equipment (PPE) could be made and modified as conditions warrant.
- Task-specific hazard analyses must lead to the development of written standard operating procedures (SOPs) that specified the controls necessary to safely perform each task.
- Emergency response elements of the safety and health program must be fully implemented as described in the program.
- All site control elements of the safety and health program must be fully implemented as described in the program.
- The safety and health program must include procedures for monitoring the effectiveness of PPE, decontamination procedures, or housekeeping programs.
- Self-audit site inspection and abatement tracking programs must be formalized and effectively implemented.
- Process safety management procedures for the incinerator facility need to be improved.
- Procedures to monitor for and reduce heat stress need to be effective.
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A. SAFETY AND HEALTH SUPERVISORS AT THE SITE MUST BE GIVEN THE
AUTHORITY TO EXERCISE THEIR JUDGMENT IN MATTERS OF EMPLOYEE SAFETY AND
HEALTH. MANAGEMENT DECISIONS RELATED TO SAFETY AND HEALTH MUST REFLECT THE
JUDGMENT OF SUCH INDIVIDUALS.
Perhaps the most essential component of the safety and health program at a
hazardous waste site is the development, management, and implementation of
the program by a competent site safety and health supervisor who has the
authority to make decisions that affect employee safety and health. Because
worksite conditions that affect employee safety and health can change
rapidly, the safety and health supervisor needs to have sufficient authority
to make decisions in a timely manner to respond to dynamic conditions. In
addition, for an effective program, the safety and health supervisor must
have the flexibility to conduct any investigation deemed necessary to fully
characterize the hazardous exposures of employees and to ensure that the
various elements of the safety and health program are effective in mitigating
these hazards. The need to grant appropriate authority to the site safety
and health supervisor is addressed in paragraph (b)(2)(i)(B) of 29 CFR
1910.120 (HAZWOPER).
At Site B, interviews with safety and health management personnel indicated
that some decisions regarding employee safety and health were made without
input from safety and health professionals. In addition, industrial hygiene
personnel from the oversight agency were not readily available to evaluate
the recommendations made by the contractor's safety and health personnel.
Furthermore, the contractor was bound by contract provisions that dictated
specific procedures for employee exposure monitoring and the selection of
PPE, regardless of conditions occurring on site. For example, although the
contractor was free to upgrade the level of PPE when site conditions so
warranted, downgrading the level of PPE required the submission of a written
justification to the Contracting Officer and the receipt of written approval
before a downgrade could be implemented. The time required to obtain
permission to downgrade PPE may place employees at unnecessary risk of heat
stress and other hazards associated with the use of PPE, such as restricted
vision, impaired communication, and increased fatigue. Contractor safety and
health personnel concurred with this conclusion, and cited an example where
employees engaged in installing a new pug mill were required to wear Level C
PPE, despite a low potential for exposure to contaminants on the site.
Therefore, OSHA concludes that the on-site presence of a competent safety
and health professional from the oversight agency, coupled with the use of
more flexible contractual safety and health provisions, would lead to better
and more responsive safety and health decision making in the face of changing
site conditions.
At the remaining four sites inspected, contractor safety and health
personnel appeared to have more latitude to make and implement changes to
their respective SAHPs to respond to changes in site conditions. However, a
deficiency in this area was noted at Site D, where no site safety and health
supervisor had been designated for a period of about five months; as a
result, some aspects of the SAHP, in particular the monitoring program, had
not been fully implemented at this site.
B. THE SITE-SPECIFIC SAHP MUST INCLUDE PROCEDURES FOR THE
IMPLEMENTATION AND ENFORCEMENT OF SAFETY AND HEALTH RULES FOR ALL PERSONS
ON-SITE, INCLUDING EMPLOYERS, EMPLOYEES, OUTSIDE CONTRACTORS, AND
VISITORS.
This functional area is closely related to the first deficiency described
above, because it also involves the authority of the site's safety and health
supervisor. To maintain adequate site control, the site safety and health
supervisor must have the authority to enforce the SAHP's rules on any
individual present at the site, whether employee or outside contractor. At
Site B, the safety and health supervisor felt that, because of the
contractor/client relationship between the contractor and the oversight
agency, he had little authority over the safety and health activities of
oversight agency personnel. However, when shown the deficiencies identified
by OSHA, personnel form the oversight agency emphasized that they expected
the site safety and health supervisor to exercise authority over any person
present on site, including their own personnel, if necessary.
The authority of the safety and health supervisor was most at issue at Site
A. At this site, two of the contractors issued their own SAHPs, each with
distinct safety and health requirements. Interviews with safety and health
personnel at these sites indicated that no single site safety and health
supervisor who had overall responsibility for the enforcement of safety and
health requirements for all personnel on site had been designated. Although
it may be appropriate for each contractor to develop its own SAHP, OSHA
considered it essential that both plans be integrated and enforced
consistently to ensure uniformity and clear understanding of expectations by
on-site personnel, and particularly to ensure clear lines of authority and an
understanding of response actions during an emergency situation. At this
site, the emergency alerting schemes of the prime and subcontractor varied
considerably, a situation that could easily lead to confusion in crisis (See
Section E below). Another result of having two safety and health supervisors
enforcing separate plans for their own employees was that PPE requirements
frequently varied for prime and subcontractor employees. For example, some
employees of one contractor expressed concern and were confused about a
requirement that they wear Level C protection in an area where employees of
the other contractor were permitted to wear Level D PPE. Allowing a
situation of this type to continue clearly undermines any effort to convey to
employees the need to take appropriate protective measures to guard against
exposure to hazardous conditions.
C. THE SAFETY AND HEALTH PROGRAM MUST BE EFFECTIVE IN ENSURING THAT
ONGOING TASK-SPECIFIC HAZARD ANALYSES WERE CONDUCTED SO THAT THE SELECTION OF
APPROPRIATE PPE COULD BE MADE AND MODIFIED AS CONDITIONS WARRANT.
The OSHA standard (29 CFR 1910.120) mandates that site safety and health
programs require task- and operation-specific hazard analyses to be conducted
at the site; these analyses are intended to ensure a comprehensive and
systematic approach to hazard anticipation, recognition, and evaluation at
hazardous waste sites. Because work operations and site conditions change as
the remediation process progresses, hazard analyses must be conducted on an
ongoing basis; that is, the potential hazards associated with each operation
must be reevaluated periodically as conditions change to ensure that
employees are being afforded appropriate protection. For example, as work
progresses, all information and data on employee exposures obtained to date
should be incorporated into the analysis to enhance and refine the
evaluation; the results of air monitoring are an important source of
site-specific information used for hazard analysis. The requirement to
conduct task- and operation-specific hazard analyses and to incorporate the
results of such analyses into the site-specific SAHP is contained in
paragraph (b)(4)(ii)(A) of the HAZWOPER standard. Paragraph (h) of the
standard also requires that the exposures of employees be monitored to ensure
adequate characterization of their exposures; the results of all exposure
monitoring should feed back into the hazard analysis process to ensure
continuing improvement in site planning and procedures.
Program deficiencies were identified in two related areas: the development
of operation-specific hazard analyses and conduct of monitoring programs
designed to characterize employee exposures to hazardous materials. These
deficiencies are discussed in more detail below.
Written Operation-Specific Hazard Analyses: Three of the five sites
inspected lacked written hazard analyses for some tasks and operations that
were being conducted on site. In addition, some of the written analyses
examined failed to include an appropriate level of detail in describing the
nature of the hazards or the protective measures to be taken in performing
the task or operation.
At Site B, for example, written hazard analyses were not available for two
tasks: cleaning the filter presses and charging chemicals into the aqueous
waste treatment system. Operation of the filter press cleaning operation,
which involves spraying filter presses with a stream of water, revealed that
the employee engaged in the operation was exposed to splashes of contaminated
liquids on the back of his head and neck because the protective clothing he
was using was inadequate. OSHA believes that a hazard analysis of this
operation would have indicated the need for protective clothing of a
different design. Also at this site, it was noted that substantial overspray
from an equipment decontamination operation was carried into areas where
Level D PPE was permitted, thus potentially exposing unprotected personnel to
contaminated aerosols. The written hazard analysis for this operation did
not identify this potential hazard, which was readily apparent to OSHA
inspectors on direct visual observation.
Site E lacked written hazard analyses for tasks and operations frequently
performed by employees; examples of these operations include working on or
near moving equipment such as conveyors, operating heavy equipment,
relighting the pilot of the secondary combustion chamber, and conducting air
monitoring and surveying in the excavation area. For example, although
safety and health management personnel believed that industrial hygiene
technicians were among the most highly exposed individuals on the site
because they spent so much time in the exclusion zone, no formal analysis of
the hazards associated with air monitoring in the exclusion zone had been
conducted.
At Site A, written hazard analyses were not available for several
operations, including:
- Cleaning filter presses;
- Changing mix tanks with caustic and acid from
55-gallon drums;
- Changing and cleaning sand filters, which may be
contaminated with lead and other heavy metals;
- Procedures for incinerator operation/shutdown in
emergency situations, especially with respect to the use of emergency
respiratory protection; and
- Decontamination of heavy equipment, especially with
respect to containing overspray to prevent contamination of the personnel
decontamination trailer.
In contrast, hazard analyses were available for all tasks and operations at
Site D. The site's approach to hazard analysis was unique in that it asked
the employees who performed each operation to conduct the analysis. The
employee performing each task or operation completed a standard form, and the
information was reviewed and supplemented where necessary by the safety and
health supervisor. This approach minimized the potential for operations to
be overlooked during the hazard analysis and ensured that all important
hazards would be identified.
Employee Exposure Monitoring: As discussed above, the results
obtained from a site's exposure monitoring program should be used to
continually improve and refine the ongoing process of operation-specific
hazard analysis, which is designed, in turn, to identify the appropriate kind
and level of employee protection needed. Each of the sites inspected relied
primarily on the results of real-time monitoring for organic vapor and dusts
to characterize employee exposures. Selection of the appropriate level of
PPE on these sites is generally based on action level concentrations
determined from real-time air sampling; for example, Level C PPE is indicated
when dust concentrations exceed 1 mg/m(3) or organic vapor concentrations
exceed 1 ppm. This approach which is commonly used on hazardous waste sites,
was recommended by EPA's Standard Operating Guides (1984). Relying on
real-time sampling results to guide PPE selection is certainly appropriate
during the initial site entry and characterization phases, where the nature
and the extent of the hazards on the site are largely unknown; however, by
the time the sites are engaged in active remediation, a considerable amount
of data has been compiled that enables fuller and more accurate
characterization of employee exposures and therefore provides a sounder basis
for the selection of PPE. Four of the five sites inspected collected personal
air samples for various contaminants known to be present on site; the
contaminants selected for monitoring represented the principal contaminants
identified in the preliminary Remedial Investigation/Feasibility Studies
(RI/FS) conducted before work began at the sites. However, no site actually
used these monitoring data to make decisions about the PPE to be worn by
employees or to determine whether employees were being exposed to other air
contaminants. As a result, OSHA concluded that employee exposures were not
being characterized sufficiently to permit the selection of the most
appropriate level of protection.
Specifically, at Site A, no personal sampling for air contaminants had been
conducted, despite potential employee exposures to PCBs, arsenic, lead,
organic solvents, diesel exhaust, and carbon monoxide. The level of PPE
assigned to employees was based primarily on the location of the operation
rather than on the concentration of the contaminants to which employees were
exposed. The safety and health supervisor at this site used a miniram
real-time dust analyzer to determine exposures to lead and PCBs but did not
appear to factor the results of this monitoring into the PPE selection
process. In addition, the monitoring equipment being used was not always
properly calibrated to manufacturer's specifications.
Similarly, the monitoring program implemented at Site C did not adequately
characterize the health risks associated with each site task or operation. No
personal monitoring had been performed to determine employee
time-weighted-average exposures for any work tasks conducted on this site.
Specifically, the site did not have a program in place to identify, evaluate,
or monitor employee exposure to specific air contaminants that were
identified in the original site investigation such as lead, vinyl chloride,
or specific organic solvents. The only environmental monitoring conducted
had been area sampling using a photoionization detector for total organic
chemical vapors, a direct reading meter for toluene diisocyanate (TDI), and a
combustible gas meter.
Consequently, the PPE usage at Site C appeared to be more related to
corporate policy rather than on a site-specific evaluation of site hazards.
The use of unnecessarily high levels of PPE in itself may create a hazard due
to restricted vision and mobility, and increased potential for heat stress.
Although Level B protection would always be necessary during excavation and
drum characterization operations, OSHA believes that certain areas of the
site in which Level B was being used, such as the feed hopper, can be
sufficiently characterized so as to permit the use of half-mask or no
respirators most of the time. To this end, direct reading instrumentation
can be used on an on-going basis to determine the appropriate level of
respiratory protection after employee exposure has been adequately
characterized through the use of personal samples.
At Site E, personal air samples were routinely taken for benzene and vinyl
chloride, as mandated by the contract with the oversight agency; however, no
program was in place at this site to identify and quantify airborne levels of
other hazardous substances present. This deficiency was particularly
important at this site because a number of employees reported experiencing
signs of respirator cartridge breakthrough or facepiece leakage, despite
personal sampling results indicating that exposures to benzene and vinyl
chloride were low. In other words, these employees were being exposed to
concentrations of unknown contaminants while working in the exclusion zone.
In addition, management at Site E paid inadequate attention to the monitoring
program, as evidenced by the late submission of samples for laboratory
analysis.
The SAHP for Site D contained provisions for real-time sampling for organic
vapors and dusts, personal air sampling for pentachlorophenol and polynuclear
aromatic hydrocarbons, and detector tube measurements for benzene, toluene,
xylenes, and vinyl chloride; however, only the real time organic vapor
measurements were used to select the appropriate level of PPE. Furthermore,
the sampling program specified in the SAHP was inconsistently implemented by
safety and health personnel; direct-reading measurements were not taken in
accordance with the schedule outlined in the SAHP, and no personal air
samples for pentachlorophenol had been taken in a period of more than two
months. Most of these difficulties were attributable to the absence of a
designated site safety and health officer until just prior to the inspection.
The exposure monitoring program at Site B was the most complex of the
programs at all sites inspected. This program called for frequent real-time
measurements of organic vapor and dust levels and personal air sampling for
several indicator substances, including PCBs, toluene, naphthalene, phenols,
and trichloroethylene. Several personal air samples for these materials were
taken daily; however, not all were subject to analysis. According to the
contract between the oversight agency and the contractor, air samples were
selected for analysis only if real-time measurements indicated the potential
for relatively high exposure or the samples were selected for analysis by the
oversight agency's contracting officer. These sample selection procedures
were not described in the SAHP, nor were employees routinely notified that
air samples were not submitted for analysis, according to discussions with
Laborer's representative. Instead, employees were interpreting the fact that
they were not being notified of the results of the sampling to mean that they
were not being significantly exposed, when in fact employees were not being
notified because the samples had never been analyzed.
OSHA performed a detailed analysis of the sampling results obtained by Site
B personnel for a 1-month period prior to the inspection. During this month,
industrial hygiene personnel collected 79 air samples; of these, 30 were
submitted for analysis. About half of these were designated as area, rather
than personal samples. The vast majority of samples taken and analyzed
represented exposures in two areas, the pug mill and an area in which the
lagoon was being dredged. Only 4 of the 30 samples analyzed were taken on
employees working in the feed preparation area or in the vicinity of the
incinerator, and none were taken in the ash handling area. Thus, despite the
dedication of considerable time and resources to sampling, OSHA concludes
that employee exposures were not being adequately characterized on an ongoing
basis.
The situation at Site B reflects the fact that the site safety and health
supervisor had not been given adequate authority to design a sampling
strategy that reflected changing work or site conditions. For example, the
company was concerned about potential lead exposures to personnel operating
at newly installed pug mill and ordered that personal samples be taken;
however, because lead had not been specifically identified during the RI/FS
stage, no requirements for such sampling had been incorporated into the SAHP.
As a consequence, these samples were taken at the contractor's expense,
which means that a disincentive had been built into the system to discourage
the contractor from exercising its judgment as on-site conditions changed.
Another example concerns the maintenance operation conducted about once per
week at the site that requires employees to enter the secondary kiln to chip
away slag that accumulates on the inner walls. Employees are provided with
air-purifying respiratory protection to conduct this operation. Despite the
potential for exposure to silica, personal samples for this substance have
not been taken and are not required by contract, and thus there is no
confirmation that air-purifying respirators are appropriate.
D. TASK-SPECIFIC HAZARD ANALYSES MUST LEAD TO THE DEVELOPMENT OF
WRITTEN STANDARD OPERATING PROCEDURES (SOPs) THAT SPECIFIED THE CONTROLS
NECESSARY TO SAFELY PERFORM EACH TASK.
Detailed hazard analyses conducted for each site task and operation provide
the basis for developing standard operating procedures to protect employees
from safety and health hazards. Written safety and health SOPs provide a
mechanism for keeping employees aware of procedures that ensure their safety
and for management to ensure that hazard control procedures are enforced.
Requirements for written safety and health SOPs are included in paragraphs
(b)(4)(i) of the HAZWOPER standard. In general, the inspection team found
that written SOPs either lacks sufficient detail to be useful to employees
and safety and health personnel, or were not available for several important
operations.
For example, the SAHP developed for Site B did not include written safety
and health procedures and protective measures to be used for the emergency
shutdown of the incinerator. Safety and health hazards may be present during
automatic waste feed shutoff (AWFSO), which can occur from a variety of
causes, such as elevated stack temperature, low furnace vacuum, low oxygen
levels, failure of the furnace pilot light, failure of the brick lining, low
water pressure to the scrubber, or inappropriate flow of waste feed.
Although the site maintained written procedures for incinerator operation
during AWFSO events, these procedures did not include the safety and health
measures required to address the hazards associated with each type of
shutdown.
Many of the SOPs at Site B contained only broad and general statements such
as "use appropriate protective clothing". Thus, the SOPs did not convey
specific information on protective measures to be taken to address the types
of hazards associated with each operation or task. In addition, the
inspection team felt that the site's SAHP and SOPs had not been made readily
available to employees; employee interviews indicated that some employees
were unaware of the existence and availability of these documents. To be
maximally useful, both documents should be available in the control zone
where employees can refer to them as needed.
The SOPs in Site B's SAHP did not always address the specific PPE
requirements of each task or operation, as required by paragraph
1910.120(b)(4)(ii)(C). For example, the site implemented a PPE program that
separately identified the level of respiratory and dermal protection required
for each area of the site, although this requirement was not described in the
written SAHP. Despite the fact that this requirement reflected an
improvement in the site's PPE program, it was not included in the most recent
versions of the SAHP or in other written safety and health procedures. The
root cause of this deficiency derives from contractual provisions requiring
that any change to the SAHP be accompanied by the issuance of a new edition
of the SAHP; since issuance of a new edition is a major undertaking, there is
considerable reluctance to modify the SAHP as events on the site unfold. As
a consequence, changes in safety and health procedures are not being
incorporated into the SAHP. This practice has since changed at the site, and
SAHP revisions may now be issued in the form of change notices; although
these notices still require approval by the oversight agency's contracting
officer, they are more quickly effected than was the case formerly.
Deficiencies noted in the SAHP for Site C included the absence of addressing
the safety and health risk or hazard analysis for potentially hazardous
operations, such as incinerator operation, feeding waste to the incinerator,
or cleaning of labels on excavated barrels.
The SAHP developed for Site D did not include written site-specific safety
and health SOPs for the following operations: line breaking, hot work,
confined space work, repairing the primary valve on the caustic tank, and
evaluating the thermal status of employees working in the exclusion zone.
The SAHP did incorporate, by reference, a series of corporate SOPs covering
certain of these topics, such as hot work and confined space entry work,
although these SOPs had not been revised as necessary to address
site-specific factors, despite a requirement in the corporate SOPs to do so.
For example, the SOP for confined space entry work did not identify the
specific locations of confined spaces on site.
The SAHP used at this site also did not reflect the site's practice of
permitting employees to wear Level C protection when performing tasks of
short duration (i.e., less than 15 minutes) in the closed waste feed
preparation area (an area that normally requires Level B PPE). This
exception to the normal requirement to wear Level B PPE should be discussed
in the SAHP, along with the supporting reasons that justify relaxing the PPE
requirement for short-duration tasks conducted in this area.
At Site A, the written SOPs for confined space entry lack detail. For
example, the SOP did not identify the specific locations of the confined
spaces at the site. In addition, the SOP did not explicitly require that the
air quality be tested in confined spaces when air-supplied respirators were
being used, nor did it require the use of forced ventilation during the
conduct of hot work in confined spaces. In both cases, however, the safety
and health supervisor at the site expected both of these practices to be
carried out.
Safety and health SOPs in the SAHP at Site A did not address the selection
of PPE for employees working in the excavation area. In addition, the site's
SOPs did not specify the procedures to be used by employees to decontaminate
or dispose of PPE. Furthermore, the SAHP contained no SOPs for the conduct of
regular inspections/audits of the safety and health program at the site or
for delegating the authority to do so.
E. EMERGENCY RESPONSE ELEMENTS OF THE SAFETY AND HEALTH PROGRAM MUST
BE FULLY IMPLEMENTED AS DESCRIBED IN THE PROGRAM.
The emergency response plan for a hazardous waste site is one of the key
components of a site's SAHP. Major elements of the emergency response plan
include coordination with local organizations that provide emergency response
services (i.e., fire department, health care facility, and local emergency
response center), training employees in emergency response alerting and
evacuation procedures, and conducting drills to determine the effectiveness
of the emergency response plan. Requirements for developing and implementing
emergency response plans are contained in paragraph (l) of the HAZWOPER
standard.
All SAHPs of the incinerator sites that were inspected were deficient in the
emergency response training provided to employees. In addition the SAHPs of
these same sites had incomplete or outdated written emergency plans.
Inspection of Site B revealed a number of areas in which emergency planning
needed to be improved. In particular, the employees responsible for
implementing the emergency procedures associated with shutdown of the
incinerator did not have direct access to or training in the use of the PPE
that might be necessary during shutdown, nor was emergency SCBA or other
respiratory protection available to employees in the incinerator control
room. In addition, the safety and health officer for the subcontractor
charged with operating the incinerator at Site B had difficulty locating the
written emergency shutdown procedures when OSHA requested them to do so.
At the time of the inspection, OSHA understood from employee and management
interviews that only one evacuation drill had been conducted at Site B, and
that this drill had not been very successful. In their response to OSHA's
findings, however, the prime contractor reported that three drills had been
concluded prior to the inspection and that two of these had been deemed to be
successful; the third was not considered adequate due to missed communication
among the parties regarding the execution of the drill. In no case have the
emergency drills at Site B involved other than on-site employees; according
to management personnel at Site B, this was due to difficulties encountered
when attempting to coordinate arrangements with community organizations
through the oversight agency.
An OSHA inspector contacted several of the local emergency response
organizations in the area of Site B, and neither the county Emergency
Response Center nor the local hospital were able to locate copies of the
site's written emergency response plan. A hospital representative did report
that procedures had been developed for tracking potentially contaminated
patients, however.
Site B's Spill Control and Response Plan was not current, as evidenced by
the organization chart, which identified as responsible individuals, persons
who were no longer employed at the site. In addition, the written Spill
Response Plan contained procedures for conducting monthly meetings, drills,
and periodic spill containment inspections; none of these procedures were
being implemented at the site. OSHA recommended that the program be
reevaluated to ensure that it addressed specific hazards at the site,
including those locations around the aqueous waste treatment area where
hazardous materials were being stored.
Interviews with employees at Site B indicated that some were not familiar
with the meaning of the emergency signals identified in the SAHP, indicating
the need to provide more frequent training and practice drills. The site
relied heavily on the use of small air horns located strategically throughout
the site to provide notification of emergency situations; however, access to
some of these horns was blocked by drums and equipment. In addition, the
main siren located at the site had not been tested periodically because of
concerns about alarming the surrounding community.
As was the case with Site B, employees at Site D were not familiar with all
emergency signals and procedures specified in the SAHP. In addition, the
SAHP did not specifically address procedures to be followed in the event of
fire; it was the company's policy that employees not fight fires beyond the
incipient stage.
At Site A, OSHA found that the emergency alerting procedures of the two
on-site contractors were inconsistent and were not clearly understood by site
employees. The SAHP for each contractor specified the use of air horns for
emergency alerting, but personnel from the subcontractor at the site
indicated that they would actually rely on radio communication in an
emergency. Additionally, the two contractors had different alarm signals; for
example, one contractor planned to signal site evacuation using one long
blast followed by one short blast, while the other contractor's plan mandated
the use of continuous 30-second blast. Both contractors also used different
radio frequencies, which creates the potential for miscommunication during an
emergency.
Other deficiencies in the emergency plan at Site A included the following:
- There was no emergency SCBA in the incinerator control
room, despite the potential for emergency conditions that may dictate the use
of such equipment;
- The emergency response plan did not identify
specifically where employees were to assemble during an emergency evacuation.
In addition, maps were not readily available that showed the evacuation
routes to pre-designated assembly areas;
- The emergency response plan was not rehearsed
regularly, according to interviews with employees; and
- Emergency air horns and spares were not kept in the
decontamination trailer, as required by the SAHP.
The SAHP developed for Site E did not address all anticipated emergencies,
including procedures to be followed in the event of natural gas line rupture
or fires. In addition, alternate evacuation routes should have been
established for employees working in the exclusion zone; only one evacuation
route was indicated in the SAHP. During the inspection, the site had an
evacuation drill that made it apparent that site personnel were aware of
evacuation routes; however, the emergency alarm siren could not be heard
inside the control zone trailer where inspection team members were reviewing
records, and personnel in this trailer had to be verbally instructed to
evacuate. Thus, the emergency alerting procedures did not conform to the
requirements of 1910.120(l)(3)(vi) or 1910.165 regarding the use of emergency
alarms.
The emergency response plan for Site C did not accurately describe the
training requirements for members of the on-site emergency response team.
Additionally, the deficiencies included team member names not being
identified, as well as the level of involvement the team is expected to have
in an emergency response. Further, the SAHP for this site failed to address
the emergency response plan for chemicals brought onto the site such as fuel
or wastewater treatment plant chemicals, although the emergency response plan
did address spills of the identified landfill contaminants.
F. ALL SITE CONTROL ELEMENTS OF THE SAFETY AND HEALTH PROGRAM MUST BE
FULLY IMPLEMENTED AS DESCRIBED IN THE PROGRAM.
Inspection team members found that certain elements of each facility's site
control program were not being rigorously implemented. In particular, this
included the use of the buddy system, which is required by paragraph (d)(3)
of HAZWOPER. The purpose of these requirements is to ensure that only
properly trained and authorized individuals enter those areas of the site
where potential hazards are present, and that, in the event of an emergency,
rapid assistance can be rendered to employees working in the exclusion zone.
At four of the sites inspected, use of the buddy system for employees
entering the exclusion zone was required in the SAHP, but the systems were
generally informal and, as a result, were inconsistently implemented. For
example, it was not evident from Site C's SAHP that the buddy system would be
in place during all activities conducted in areas requiring Level B PPE
(these activities included trailer placement, surface soil sampling,
groundwater well installation, groundwater sampling, and surface water
sampling).
In general, employees at these sites were instructed to watch for each other
in the exclusion zone, but no formal assignment of partners was made prior to
entry into the exclusion zone. Evidence of this deficiency could be seen in
the exclusion zone entry/exit logs, which contained numerous entries by
single individuals who were not paired with a buddy. Furthermore, employees
wearing respiratory protection equipment were observed to be working without
the benefit of direct observation by a designated buddy.
Therefore, the health personnel on these sites need to reevaluate their
criteria for determining where the buddy system is necessary, and to
formalize the use of the buddy system in those areas so that employees have a
clear understanding of the importance of adhering to the buddy requirement.
Demarcation of different work zones on hazardous waste sites is another
crucial feature of the site control program. In general, the various work
zones were clearly identified and demarcated at Sites A, C, D, and E. Entry
and egress of personnel and equipment through the exclusion zone were
accomplished on these sites via well-established decontamination facilities.
However, at Site B, demarcation of the various work areas was less clear, due
in large part to the movement of barricades by equipment.
G. THE SAFETY AND HEALTH PROGRAMS MUST INCLUDE PROCEDURES FOR
MONITORING THE EFFECTIVENESS OF PPE, DECONTAMINATION PROCEDURES, OR
HOUSEKEEPING PROGRAMS.
Safety and health supervisors at hazardous waste sites need to evaluate the
effectiveness of their safety and health programs on an ongoing basis to
ensure that SOPs are warranted. Monitoring the effectiveness of the program
is required under paragraph (b)(4)(iv) of the HAZWOPER standard. In general,
inspections uncovered the fact that safety and health personnel have not
established objective procedures for monitoring the effectiveness of certain
elements of their programs, in particular the use of PPE, decontamination
procedures, and housekeeping procedures. The effectiveness of these program
elements can be assessed in a variety of ways, such as by taking wipe samples
on decontaminated equipment and surfaces in clean areas, analyzing the final
decontamination rinse water for the presence of contaminants, or visual
inspection of PPE for signs of leakage or failure. During these inspections,
wipe samples of work surfaces in clean areas, as well as skin wipes and hand
washes, were collected to examine the effectiveness of PPE and procedures for
preventing contamination of clean areas. None of the sites inspected
employed methods such as these to evaluate the effectiveness of their
programs.
At Site B, PCB surface contamination was found in the incinerator control
room and in a portable laboratory located in a Level D PPE area near the
incinerator kiln. Also at this site, inspection team members observed that
overspray from the equipment decontamination area presented a potential
exposure hazard to personnel in an adjacent Level D PPE area; thus, although
the procedures used to decontaminate equipment at this site may have been
effective, the methods employed created another potential exposure hazard
that was readily apparent even on direct visual observation. Other sites
avoided this problem by using curtains to contain any overspray.
During the inspection at Site D, team members observed a number of employees
doffing potentially contaminated PPE in a manner inconsistent with the site's
SOPs; for example, some employees were observed removing their inner gloves
before removing their potentially contaminated outer clothing. In addition,
it was observed that cotton coveralls worn under Tyvek protective clothing
showed visible signs of contamination after employees had finished using a
high-pressure water wash to decontaminate large excavated items; this
suggests that a more impervious type of protective clothing (such as
double-seamed Tyvek) should be used during this operation. Thus, the
ineffectiveness of the protective clothing worn during this operation was
readily apparent, again by direct visual observation.
At Site C, workers in the materials preparation building and feed hopper
areas were required to wear Saranex coated Tyvek and level B respiratory
protection. However, the rationale for this level of protection was not
stated in the SAHP. Because these workers handled contaminated soil, it
appeared unlikely that there was a potential for serious skin exposure to
liquid chemicals. Uncoated Tyvek clothing would have most likely provided
adequate skin protection for these workers. The use of the Saranex coated
Tyvek greatly increased the potential for heat stress among these workers.
H. SELF-AUDIT SITE INSPECTION AND ABATEMENT TRACKING PROGRAMS MUST BE
FORMALIZED AND EFFECTIVELY IMPLEMENTED.
The overall effectiveness of the safety and health program must be
evaluated, in part, by conducting regular inspections and audits to ensure
that the program is being properly implemented. In addition, there should be
a mechanism to follow-up on corrective actions recommended by the site safety
and health officer during safety inspections. All hazard abatement action
identified by the site safety and health officer should be tracked to ensure
that the corrective actions have been implemented and the hazard(s) have been
eliminated. The program should designate individuals to periodically inspect
work areas and ensure that hazard abatement has been accomplished. Paragraph
(b)(4)(iv) of the HAZWOPER standard contains the requirement that the site
safety and health supervisor, or a knowledgeable designee, perform periodic
inspections to evaluate the effectiveness of the program.
Some of the program deficiencies discussed above point to the need for more
rigorous and formalized inspection and abatement tracking procedures on the
sites inspected. Examples demonstrating this include the instance at Site D
where improper PPE doffing procedures were being used, the inaccessibility of
some of the emergency air horns at Site B, and the lack of a system at Site C
for ensuring that safety and health problems are corrected in a timely
manner. Documented instances in which safety and health standards were not
being complied with point to the need to strengthen self-inspection and
abatement tracking at these sites. These findings are summarized in Table 3.
TABLE 3. SUMMARY OF SAFETY AND HEALTH VIOLATIONS IDENTIFIED ON HAZARDOUS WASTE INCINERATOR SITES |
Name of Site |
Description of Violation |
Citation |
Site A |
Natural gas line was not protected from impact. |
1910.120(g) |
Certification of lockout/tagout inspections not provided. |
[1910.147(c)(6)(ii)] |
Alloy chain slings were not properly identified
by label. |
1910.184(e)(1) |
Wire rope sling with broken wires was not removed from service. |
1910.184(f)(5)(i) |
Bench grinder did not meet specifications for clearance and guarding. |
1910.215(a),(b) |
Barrier guards were not provided to protect employees from rotating machine parts. |
1910.219(c)(2)(i) |
Belts and pulleys on compressor were unguarded. |
1910.219(d),(e) |
Chain and sprocket wheels were not enclosed. |
1910.219(f) |
Open-sided floor platforms were unguarded. |
1910.23(c)(i) |
Employees were not protected from incidental welding rays. |
1910.252(b)(2) |
Flexible cords were used in lieu of permanent
wiring. |
1910.252(g)(i) |
High-voltage boxes were not properly secured or
labeled. |
1910.305(b),(g) |
Moving equipment had non-operating backup
alarm. |
[1926.602(a)(ii)] |
Employee was within swing radius of
backhoe. |
[1926.651(e)] |
Site B |
Signs designating work zones have been moved by
equipment and not replaced on a timely basis. |
1910.120(d)(3) |
Employees were not provided with separate clean
and dirty change areas. |
[1910.120(n)(7)(ii)] |
Building had unguarded platform on three
sides. |
1910.23(c) |
Workers were on elevated platform without
benefit of guardrail or safety belt. |
1910.23(c) |
Unguarded floor opening was located more than 6
feet from ground. |
1910.23(a)(8) |
There was no means of safe egress from a second
level platform. |
1910.36(b)(1) |
Caution signs were not provided near
high-voltage electrical sources. |
1910.304(d)(2) |
Acid and caustic charging areas were not
provided with emergency eyewash or shower. |
1910.151(c) |
Feed conveyor was unguarded, exposing employees
to nip-point hazard. |
1910.212(a) |
Ground plug was missing from electrical power
tools. |
1926.300(a) |
Front-end loader had cracked front and side
windshields. |
1926.601(b)(5) |
Flexible electrical wire was used in lieu of
fixed wiring. |
1910.305(g)(1)(iii) |
Site C |
MSDSs were not routinely checked for
completeness and accuracy. |
1910.1200(g)(8) |
Labels on several containers including the
caustic and acid tanks in the water treatment plant had no hazard
warnings; other containers, such as fuel cans, had no labels at
all. |
1910.1200(f)(5)(ii) |
There were no methods to deal with the hazards
of non-routine tasks and no method for informing employees of
contents of unlabeled pipes. |
1910.1200(e)(1)(ii) |
There were no methods of informing employees of
the hazards associated with foreseeable emergencies. |
1910.1200(e)(2)(ii) |
The water treatment building had improperly
guarded platforms on two 13-foot storage tanks. |
1910.23(c) |
The elevated platform on a hopper near the
baghouse had a broken guardrail on the west side. The guardrail
on the truck into which the baghouse fines are loaded had broken
guardrails on all sides. |
1910.23(c) |
An unguarded floor opening was located about 4
feet from the ground on the platform near the baghouse. |
1910.23(a)(8)
|
The step-up inspection platform on the drum
crusher was not adequately guarded. |
1910.212(a)(3), (4) |
A live electrical box on the east end of the
lunch room trailer was not properly guarded from vehicle
traffic. |
1910.303(g)(2)(ii) |
The battery charging area located in the
compressor shed was not provided with an acceptable emergency
eyewash. |
1910.151(c) |
The handle for the main natural gas shut-off was
removed from the valve stem. |
[1910.120(l)(2)(iii)] |
Site D |
Electrical extension cord lacked ground
plug. |
1926.300(a) |
Drums used to transfer flammable liquids were
not grounded or bonded. |
1910.106 |
No fire watch was present during a welding
operation. |
1910.252(d)(2)(ii) |
HAZCOM program was deficient in that MSDS's
were missing and no hazard warning labels were used on caustic
tanks. |
1910.1200 |
Issuance, enforcement, and review of hot work
and confined space entry permits were not effectively performed
during welding operation. |
1910.146(c)(1&2),(f) |
Site E |
Standard operating procedures for
decontamination and PPE were not being adhered to. |
1910.120(c)(5),(k) |
Confined space entry permit did not address
possible hazards. |
1910.146(c)(5), (C) |
Record of fire extinguisher inspection was not
available. |
1910.157(e) |
I. PROCESS SAFETY MANAGEMENT PROCEDURES FOR THE INCINERATOR FACILITY
NEED TO BE IMPROVED.
Hazardous waste incineration is a complex process in which a number of upset
conditions can result in potential hazards to employees; these hazards are
typically presented when the upset condition causes a sudden increase in
system pressure or a bypass of the pollution control equipment.
Transportable incinerators are equipped with several safety interlock systems
that trigger automatic equipment shutdown or interruption of waste feed when
operating parameters fall outside the normal range. However, safe operation
of incinerator equipment still relies heavily on the attention of the
operator and the implementation of proper maintenance and repair procedures
that optimize the safety and reliability of the incinerator and its
associated equipment. Although the incinerator sites inspected in this study
do not generally fall within the scope of OSHA's process safety management
standard (29 CFR 1910.119), the inspection team applied many of the
principles that formed the basis of that standard to evaluate each site's
management procedures for ensuring the safe operation of the incinerator.
Some of these principles include maintaining accurate Piping and
Instrumentation Diagrams (P&IDs), developing and implementing written
programs for regularly scheduled equipment maintenance, ensuring that safety
equipment such as pressure relief devices are properly installed and
operating, and keeping accurate records of repairs and modifications made to
the system.
At three of the sites, production operations had been initiated only a few
weeks prior to the inspection; few repairs or process modifications had been
undertaken. Each of these sites had procedures in place to maintain accurate
records of such activities. The inspection team believed that, should there
be any change in the supervisory personnel responsible for incinerator
operation, adequate information regarding system design and operation would
be available for their use. At Site B, however, only daily visual inspection
and maintenance logs were kept. No routine procedures were in place to
ensure that records of process modifications were maintained or that P&IDs
were updated. Responsibility for incinerator maintenance was delegated to a
single person (the lead engineer), who was familiar with process maintenance
and modifications that had been conducted up to that time, but maintained no
accurate historical record of these changes. Thus, the inspection team
believed that there was a need at this site to implement formal and
systematic recordkeeping procedures to ensure safe operation of the
incinerator in the event of a personnel change.
At four of the sites inspected, the inspection team noted a lack of any
capability to manually separate or disconnect the natural gas feed line from
the incinerator in the event of an emergency. Each site possessed the
capability of stopping gas flow to the incinerator through the use of
electrically operated relays; however, it would not be possible to isolate
the natural gas supply from the TDF at the source. At Site A, the main
shutoff valve of the natural gas line was located just outside the main gate
of the plant; this valve lacked either a computer-controlled interlock or
manually operated valve. The guard was instructed to manually close the main
gas valve in the event of an emergency, but no wrench or other device was
readily available to enable him to do so. At Sites B and C the main gas
valve lacked a handle that would enable an employee to isolate the TDF from
the gas supply. The main gas valve at Site D was located 300 feet from the
site entrance and also lacked a handle.
J. PROCEDURES TO MONITOR FOR AND REDUCE HEAT STRESS NEED TO BE
EFFECTIVE
Perhaps the greatest health hazard facing hazardous waste site workers is
that of heat stress, which is exacerbated by the use of impermeable chemical
protective clothing. Ideally, a comprehensive heat stress program will
include several elements, including environmental and medical monitoring
(i.e., measurements of pulse rate, oral temperature, and/or weight loss),
issuance of heat alerts, implementation of work-rest regimens when site
conditions warrant, provision for fluid intake and shaded rest areas in the
exclusion zone, and regular training of employees in recognizing the signs
and symptoms of heat stress in themselves and others. The inspection team
found that heat stress programs varied considerably among the sites
inspected, and in no instance were all elements of a comprehensive heat
stress program present.
Safety and health personnel at Site B conducted periodic environmental
monitoring to measure wet-bulb-globe-temperature (WBGT) conditions; these
were used to trigger work-rest regiments in accordance with the site's SAHP.
In addition, pre- and post-shift body weights were taken on employees
assigned to work in the exclusion zone. No other medical monitoring was
routinely conducted, but the contractor was experimenting with the use of
remote pulse sensors at the time of the inspection. During the inspection,
two workers entered the decontamination trailer with signs of heat
exhaustion; two health and safety technicians were present at the time, but
did not know what actions to take. Employees interviewed during the
inspection stated that they had complained of lack of shaded rest areas in
the exclusion zone, but none had been provided.
Safety and health personnel at Site D issued verbal warnings of potential
heat stress hazards when temperatures exceeded 70 degrees F. Workers were
trained to recognize signs and symptoms on site, but there was no provision
for medical or environmental monitoring of heat stress condition. Employees
stated during interviews that they believed their training adequately
protected them from heat stress.
Site E was the only one inspected that implemented routine medical
monitoring for heat stress. Pulse rates were determined after workers exited
the exclusion zone, and these rates were required to fall to predetermined
levels before the workers were allowed to re-enter. No heat stress program
was described in the SAHP for Site A; the written program included only an
appendix containing information publications. Similarly, the SAHP for the
Site C did not provide for taking environmental measurements or otherwise
characterizing the potential for heat stress to determine when engineering
controls, work practices, or other control measures are to be instituted.
V. SUMMARY
The primary findings of this project to date point the need for a change in
culture at these sites. Despite the fact that these safety and health
programs were generally comprehensive in scope and were oriented toward
compliance with HAZWOPER and other applicable standards, our inspections
revealed consistent deficiencies attributable to the failure to apply
professional judgment appropriately and to pay attention to meaningful
details. These problems were evidenced in several ways:
- Hazard analyses failed to consider all of the
available data describing the safety and health conditions at each
site;
- Objective measures to evaluate the effectiveness of
the site's safety and health program, particularly for PPE use,
decontamination procedures, and heat stress programs were lacking;
and
- Exposure monitoring programs were targeted toward
compliance rather than toward the characterization of employee
exposures.
In addition, these inspections identified several disincentives and
obstacles that would interfere with efforts to alter the safety and health
culture at these sites. For example, contractors are often not free to
exercise independent judgment because contractual provisions lock them into
predetermined activities that do not permit them to respond to changes in
site conditions or to new information. Another obstacle that operates
against improved hazard recognition and evaluation skills is the training
currently provided to safety and health personnel. At present, most of the
technicians at these sites are inadequately trained to do more than follow
"cookbook" instructions. In summary, OSHA believes that nothing short of
rigorous program of on-going self-assessment, improved training in hazard
recognition and evaluation, enhanced management commitment, and sustained
employee involvement in the program will achieve the change in culture needed
to move these sites toward excellence in occupational safety and health.
[Corrected 5/19/03]
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