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U.S. Department of Labor | |
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Directives
CPL 02-00-035 - CPL 2.35 CH-14 - Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVES). |
Directives - Table of Contents |
| • Record Type: | Instruction |
| • Directive Number: | CPL 02-00-035 |
| • Old Directive Number: | CPL 2.35 CH-14 |
| • Title: | Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVES). |
| • Information Date: | 12/03/1990 |
| • Standard Number: | 1910.120 |
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U.S. Department of Labor Occupational Safety and Health Administration
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance Subject: Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVEs) Manual A. Purpose. This instruction transmits revised and new pages to the Regulatory and General Industry SAVEs Manual for "Hazardous Waste Operations and Emergency Response" and "Control of Hazardous Energy Source (Lockout/Tagout)." B. Scope. This instruction Applies OSHA-wide. C. Action. Regional Administrators and Area Directors shall ensure that all compliance personnel:
D. Background. Final rule and regulations for 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response, were published in the Federal Register, Vol. 54, No. 42, on March 6, 1989. Corrections to the regulations were published in the Federal Register, Vol. 55, No. 72, on April 13, 1990. The final rule for Control of Hazardous Energy Source (Lockout/Tagout) was published in the Federal Register, Vol. 54, No. 169, on September 1, 1989. Corrections and Technical Amendments to the final rule were published in the Federal Register, Vol. 55, No. 183, on September 20, 1990. OSHA Instruction CPL 2.34 CH-14 DEC 03, 1990 Office of General Industry Compliance Assistance E. State Plan States. Regional Administrators shall advise State designees of the action required by this instruction and encourage their participation in the SAVEs program. Patricia K. Clark, Director Directorate of Compliance Programs DISTRIBUTION: National, Regional, and Area Offices Compliance Officers State Designees Area Office Clericals 11(c)/405 Programs NIOSH Regional Program Directors
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
1 29 CFR 1910.120(b)(1)(i): The employer did not develop and/or implement a written safety and health program for its employees involved in hazardous waste operations:
OPTION 2 2 29 CFR 1910.120(b)(1)(i): The employer did not develop and/or implement a written safety and health program that was designed to identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-7 1 29 CFR 1910.120(b)(1)(ii) * : The written safety and health program did not incorporate: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(G)):
NOTE: These SAVEs may be grouped with 29 CFR 1910.120(b)(3)
as appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(b)(1)(iii): The employer did not shore or slope site excavations created during initial site preparation or during hazardous waste operations as appropriate to prevent accidental collapse in accordance with Subpart P of 29 CFR Part 1926:
2 29 CFR 1910.120(b)(1)(iv): Contractor(s), subcontractor(s), or their representative(s) retained by the employer to work in hazardous waste operations were not informed of the site emergency response procedures and/or any potential fire, explosion, health, safety, or other hazards of the hazardous waste operation that had been identified by the employer, including those identified in the employer's information program:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-5 1 29 CFR 1910.120(b)(1)(v): The written safety and health program was not made available to: ENTER THE APPROPRIATE OPTION:
OPTION 1 2 29 CFR 1910.120(b)(2)(i): The organizational structure part of the safety and health program did not establish the specific chain of command and specify the overall responsibilities of supervisors and employees:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 2-5 1 29 CFR 1910.120(b)(2)(i) * : The organizational structure part of the safety and health program did not include: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-D)):
2 29 CFR 1910.120(b)(2)(ii): The employer did not review and/or update the organizational structure part of the safety and health program as necessary to reflect the current status of waste site operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(b)(3): The comprehensive workplan part of the site safety and health program did not address the tasks and objectives of the site operations and the logistics and resources required to reach those tasks and objectives:
OPTIONS 2-6 2 29 CFR 1910.120(b)(3) * : The comprehensive workplan part of the site safety and health program did not: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(vi)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1991 Office of General Industry Compliance Assistance
OPTION 1 1 29 CFR 1910.120(b)(4)(i): The site-specific safety and health plan part of the program required under 29 CFR 1910.120(b)(1)(i) was not available on site:
OPTION 2 2 29 CFR 1910.120(b)(4)(i): The site-specific safety and health plan part of the program required under 29 CFR 1910.120(b)(1)(i) did not address the safety and health hazards of each phase of site operation and/or did not include the requirements and procedures for employee protection:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-10 1 29 CFR 1910.120(b)(4)(ii) * : The site safety and health plan, at a minimum, did not address: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(J)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120(d)(1)
through 29 CFR 1910.120(d)(3) Options 1 to 6 as
appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(b)(4)(iii): The site-specific safety and health plan did not provide for pre-entry briefings to be held prior to initiating any site activity:
OPTION 2 2 29 CFR 1910.120(b)(4)(iii): The site-specific safety and health plan did not provide for pre-entry briefings at such other times as necessary to ensure that employees were apprised of the site safety and health plan and that this plan was being followed:
OPTION 3 3 29 CFR 1910.120(b)(4)(iii): The information and data obtained from site characterization and analysis work required in 29 CFR 1910.120(c) were not used to prepare and update the site safety and health plan:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(b)(4)(iv): Inspections were not conducted by the site safety and health supervisor or, in the absence of that individual, another individual who was knowledgeable in occupational safety and health, acting on behalf of the employer as necessary to determine the effectiveness of the site safety and health plan:
OPTION 2 2 29 CFR 1910.120(b)(4)(iv): Deficiencies in the effectiveness of the site safety and health plan were not corrected by the employer:
3 29 CFR 1910.120(c)(1): Hazardous waste sites were not evaluated in accordance with the requirements of 29 CFR 1910.120(c) to identify specific site hazards and/or to determine the appropriate safety and health control procedures needed to protect employees from the identified hazards:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(c)(2): A preliminary evaluation of the site's characteristics was not performed prior to site entry by a qualified person to aid in the selection of appropriate employee protection methods prior to entry:
OPTION 2 2 29 CFR 1910.120(c)(2): A more detailed evaluation of the site's specific characteristics was not performed by a qualified person immediately after site entry to further identify existing site hazards and/or to further aid in the selection of the appropriate engineering controls and/or personal protective equipment for the tasks to be performed:
3 29 CFR 1910.120(c)(3): All suspected conditions that may pose inhalation or skin absorption hazards that were immediately dangerous to life or health (IDLH) or other conditions that may cause death or serious harm, were not identified during the preliminary survey and evaluated during the detailed survey:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-8 1 29 CFR 1910.120(c)(4) * : Prior to allowing employees to enter a site, the employer did not obtain to the extent available: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(viii)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(c)(5)(i): An ensemble of personal protective equipment (PPE) was not selected, based upon the results of the preliminary site evaluation, and used during initial site entry which would provide protection to a level of exposure below permissible exposure limits and/or published exposure levels for known or suspected hazardous substances and health hazards:
OPTION 2 2 29 CFR 1910.120(c)(5)(i): An ensemble of personal protective equipment (PPE) was not selected and used during initial site entry which would provide protection against other known and suspected hazards identified during the preliminary site evaluation:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(c)(5)(ii): An escape-type self-contained breathing apparatus of at least five minutes' duration was not carried by employees during initial site entry when positive- pressure self-contained breathing apparatus was not used as part of the entry ensemble and/or when respiratory protection was warranted by the potential hazards identified during the preliminary site evaluation:
OPTION 1 2 29 CFR 1910.120(c)(5)(iii): An ensemble providing protection equivalent to Level B PPE was not provided as minimum protection when the preliminary site evaluation did not produce sufficient information to identify the hazards or suspected hazards of the site:
OPTION 2 3 29 CFR 1910.120(c)(5)(iii): Direct reading instruments were not used as appropriate to identify IDLH conditions when the preliminary site evaluation did not produce sufficient information to identify hazards or suspected hazards of the site:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(c)(5)(iv): The appropriate PPE was not selected and used in accordance with 29 CFR 1910.120(g) once the hazards of the site had been identified:
OPTION 1-4 2 29 CFR 1910.120(c)(6) * : During initial site entry when the site evaluation produce information that showed the potential for ionizing radiation or IDLH conditions, or the site information was not reasonably sufficient to eliminate these conditions: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iii)):
OSHA Instruction CPl 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(c)(7): After the presence and concentrations of specific hazardous substances and health hazards had been established, the risks associated with these substances were not identified:
OPTION 2 2 29 CFR 1910.120(c)(7): Employees who would be working on the site were not informed of any risks that had been identified:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(c)(8): Information concerning the chemical, physical, and toxicological properties of each substance known or expected to be present on site that was available to the employer and relevant to the duties employees were expected to perform was not made available to the affected employees prior to the commencement of their work activities:
2 29 CFR 1910.120(d)(1): Appropriate site control procedures to control employee exposure to hazardous substances were not implemented before clean-up work began:
3 29 CFR 1910.120(d)(2): A site control program for protecting employees, which was a part of the employer's site safety and health program required in 29 CFR 1910.120(b), was not developed during the planning stages of the hazardous waste clean-up operation and was not modified as necessary as new information became available:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-6 1 29 CFR 1910.120(d)(3): The site control program did not, as a minimum, include: ENTER THE APPROPRIATE OPTION:
OPTION 1 2 29 CFR 1910.120(e)(1)(i): Employees working on site who were exposed to hazardous substances, health hazards, or safety hazards and/or their supervisors and management responsible for the site did not receive training meeting the requirements of this paragraph before they were permitted to engage in hazardous waste operations that could expose them to hazardous substances, safety, or health hazards:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(e)(1)(i): Employees working on site who were exposed to hazardous substances, health hazards, or safety hazards and/or their supervisors and management responsible for the site did not receive review training as specified in this paragraph:
2 29 CFR 1910.120(e)(1)(ii): Employees were permitted to participate in or to supervise field activities before they were trained to a level required by their job function and responsibility:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-7 1 29 CFR 1910.120(e)(2) * : Employee training did not cover the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)- (vii)):
NOTE: These SAVEs listed Options 1-7 below as well as SAVE
29 CFR 1910.120(b)(4)(ii)(B) may be grouped as appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(e)(3)(i): General site workers engaged in hazardous substance removal or other activities which exposed or potentially exposed workers to hazardous substances and health hazards have not received a minimum of 40 hours of instruction off the site and/or received a minimum of three days actual field experience under the direct supervision of a trained, experienced supervisor:
2 29 CFR 1910.120(e)(3)(ii): Workers on site only occasionally for a specific limited task and who were unlikely to be exposed over permissible exposure limits and/or published exposure limits have not received a minimum of 24 hours of instruction off the site and/or received the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(e)(3)(iii): Workers regularly on site who worked in areas which had been monitored and fully characterized indicating exposures were under permissible exposure limits and/or published exposure limits where respirators were not necessary, and there were no health hazards or the possibility of an emergency developing, and/or received a minimum of 24 hours of instruction off the site have not received the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor:
2 29 CFR 1910.120(e)(3)(iv): Workers with 24 hours of training who were covered by 29 CFR 1910.120(e)(3)(ii) and (e)(3)(iii), and who became general site workers or who were required to wear respirators, did not have the additional 16 hours and/or two days of training necessary to total the training specified in 29 CFR 1910.120(e)(3)(i):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(e)(4): On-site management and supervisors directly responsible for, or who supervise employees engaged in hazardous waste operations did not receive 40 hours of initial training and three days of supervised field experience, and/or at least eight additional hours of specialized training at the time of job assignment on topic(s) such as, but not limited to: ENTER THE APPROPRIATE OPTION:
OPTION 1 The employer's safety and health program and the
associated employee training program:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 5-8 1 29 CFR 1910.120(e)(4): On-site management and supervisors who supervise only employees covered by 29 CFR 1910.120(e)(3)(ii) and (e)(3)(iii) did not receive 24 hours of initial training and one day of supervised field experience and/or at least eight additional hours of specialized training at the time of job assignment on topic(s) such as, but not limited to: ENTER THE APPROPRIATE OPTION:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(e)(5): Trainers were not qualified to instruct employees about the subject matter that was presented in training and/or had not satisfactorily completed a training program for teaching the subjects they were expected to teach, or they did not have the academic credentials and instructional experience necessary for teaching the subjects:
OPTION 2 2 29 CFR 1910.120(e)(5): Instructors did not demonstrate competent instructional skills and/or knowledge of the applicable subject matter:
OPTION 1 3 29 CFR 1910.120(e)(6): Employees and supervisors that had received and successfully completed the training and field experience specified in 29 CFR 1910.120(e)(1) through (e)(4) were not certified by their instructor or the head instructor and/or trained supervisor as having successfully completed the necessary training:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(e)(6): A written certificate was not given to each person certified as having successfully completed the training and/or field experience specified in 29 CFR 1910.120(e)(1) through (e)(4):
OPTION 3 2 29 CFR 1910.120(e)(6): All persons who had not been certified as successfully completing the training and field experience specified in 29 CFR 1910.120(e)(1) through (e)(4) were not prohibited from engaging in hazardous waste operations:
3 29 CFR 1910.120(e)(7): Employees engaged in responding to hazardous emergency situations at hazardous waste clean-up sites that could expose them to hazardous substances were not trained in how to respond to such expected emergencies:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OPTION 2 2 29 CFR 1910.120(e)(8): Employees specified in 1910.120(e)(1), and managers and supervisors specified in 29 CFR 1910.120(e)(4), did not receive eight hours of refresher training annually or any critique of incidents that had occurred in the past year that could serve as training examples of related work:
3 29 CFR 1910.120(e)(9): Certified employees or employees with equivalent training new to a site did not receive appropriate site-specific training before site entry and/or did not have appropriate supervised field experience at the new site:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(f)(2) * : A medical surveillance program was not instituted by the employer for: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iv)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-5 1 29 CFR 1910.120(f)(3) * : Medical examinations and consultations were not made available by the employer to each employee covered under 29 CFR 1910.120(f)(2)(i), (ii), and (iv): ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(E)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-2 1 29 CFR 1910.120(f)(3)(ii) * : Medical examinations and consultations were not made available by the employer to employees covered under 29 CFR 1910.120(f)(2)(iii) including those covered by 29 CFR 1910.120(a)(1)(v) who could have been injured, received a health impairment, developed signs or symptoms which could have resulted from exposure to hazardous substances resulting from an emergency incident, or could have been exposed during an emergency incident to hazardous substances at concentrations above the permissible exposure limits or published exposure levels without the use of necessary personal protective equipment: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A) or (B)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-2 1 29 CFR 1910.120(f)(4)(i): Medical examinations required by 29 CFR 1910.120(f)(3) did not include: ENTER THE APPROPRIATE OPTION:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(f)(4)(ii): The content of medical examinations or consultations made available to employees was not determined by the attending physician:
OPTION 1 2 29 CFR 1910.120(f)(5): Medical examinations and procedures were not performed by or under the supervision of a licensed physician knowledgeable in occupational medicine:
OPTION 2 3 29 CFR 1910.120(f)(5): Medical examinations and procedures were not provided without cost to the employee, without loss of pay, and at a reasonable time and place:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-5 1 29 CFR 1910.120(f)(6) * : The employer did not provide a copy of 29 CFR 1910.120 and its appendices to the attending physician, and, for each employee: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(v)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(f)(7)(i) * : The employer did not obtain and furnish the employee with a copy of the written opinion from the attending physician that contained: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(f)(7)(ii): The written opinion obtained by the employer revealed specific findings or diagnoses unrelated to occupational exposures:
OPTION 1 2 29 CFR 1910.120(f)(8)(i): An accurate record of the medical surveillance required by 29 CFR 1910.120(f) was not retained:
OPTION 2 3 29 CFR 1910.120(f)(8)(i): An accurate record of the medical surveillance required by 29 CFR 1910.120(f) was not retained for the period specified, and/or did not meet the criteria of 29 CFR 1910.20:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(f)(8)(ii) * : The accurate record of the medical surveillance required in 29 CFR 1910.120(f)(8)(i) did not include at least: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):
2 29 CFR 1910.120(g)(1)(i): Engineering controls and work practices were not instituted to reduce and maintain employee exposures to or below the permissible exposure limits for substances regulated by 29 CFR 1910, Subpart Z:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(g)(1)(ii): Whenever engineering controls and work practices are not feasible or not required, any reasonable combination of engineering controls, work practices and PPE were not instituted by the employer:
2 29 CFR 1910.120(g)(1)(iii): The employer implemented a schedule of employee rotation to achieve compliance with permissible exposure limits or dose limits:
3 29 CFR 1910.120(g)(1)(iv): The employer did not comply with the provisions of 29 CFR 1910, Subpart G:
4 29 CFR 1910.120(g)(2): An appropriate combination of engineering controls, work practices, and personal protective equipment was not used to reduce and maintain employee exposures to or below published exposure levels for hazardous substances and health hazards not regulated by 29 CFR 1910, Subparts G and Z:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(g)(3)(i): Personal protective equipment (PPE) was not selected and/or used which would protect employees from the hazards and potential hazards they were likely to encounter as identified during the site characterization and analysis:
OPTIONS 1-3 2 29 CFR 1910.120(g)(3)(ii): Personal protective equipment was not selected based on an evaluation of the performance characteristics of the PPE relative to: ENTER THE APPROPRIATE OPTION:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-3 1 29 CFR 1910.120(g)(3)(iii): Positive pressure self-contained breathing apparatus or positive pressure air-line respirators equipped with an escape air supply were not used when the chemical exposure levels present created a substantial possibility of: ENTER THE APPROPRIATE OPTION:
OPTIONS 1-3 2 29 CFR 1910.120(g)(3)(iv): Totally encapsulating chemical protective suits (equivalent to Level A protection as recommended in Appendix B) were not used in conditions where skin absorption of a hazardous substance could result in a substantial possibility of: ENTER THE APPROPRIATE OPTION:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(g)(3)(v): The level of protection provided by PPE was not increased when additional information on site conditions indicated that increased protection was necessary to reduce employee exposures below permissible exposure limits and/or published exposure levels for hazardous substances and health hazards:
2 29 CFR 1910.120(g)(3)(vi): Personal protective equipment was not selected and/or used to meet the requirements of 29 CFR 1910, Subpart I, and additional requirements specified in this section:
3 29 CFR 1910.120(g)(4)(i): Totally encapsulating protective suits did not protect employees from the particular hazards which were identified during site characterization and analysis:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(g)(4)(ii): Totally encapsulating suits were not capable of maintaining positive air pressure:
2 29 CFR 1910.120(g)(4)(iii): Totally encapsulating suits were not capable of preventing inward test gas leakage of more than 0.5 percent:
OPTION 1 3 29 CFR 1910.120(g)(5): A written personal protective equipment program, which was part of the employer's safety and health program required in 29 CFR 1910.120(b) or required in 29 CFR 1910.120(p)(1) and which was also a part of the site-specific safety and health plan was not established:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 2-11 1 29 CFR 1910.120(g)(5) * : The PPE program did not address the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(x)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(h)(1)(i): Monitoring was not performed in accordance with this paragraph where there could have been a question of employee exposure to hazardous concentrations of hazardous substances in order to assure proper selection of engineering controls, work practices, and personal protective equipment so that employees were not exposed to levels which exceeded permissible exposure limits, or published exposure levels if there are no permissible exposure limits, for hazardous substances:
2 29 CFR 1910.120(h)(1)(ii): Air monitoring was not used to identify and quantify airborne levels of hazardous substances and safety and health hazards in order to determine the appropriate level of employee protection needed on site:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(h)(2): Representative air monitoring was not conducted upon initial entry to identify: ENTER THE APPROPRIATE OPTION:
OPTION 1 2 29 CFR 1910.120(h)(3): Periodic monitoring was not conducted when the possibility of an IDLH condition had developed:
OPTION 2 3 29 CFR 1910.120(h)(3): Periodic monitoring was not conducted when the possibility of a flammable atmosphere had developed:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 3-6 1 29 CFR 1910.120(h)(3) * : Periodic monitoring was not conducted when there was an indication that exposures could have risen over permissible exposure limits or published exposure levels since prior monitoring: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iv)):
OPTION 1 2 29 CFR 1910.120(h)(4): After the actual clean-up phase of the hazardous waste operation commenced, the employer did not monitor those employees likely to have the highest exposures to hazardous substances and health hazards likely to be present above permissible exposure limits or published exposure levels by using personal sampling frequently enough to characterize their exposures:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(h)(4): When the employees likely to have the highest exposure were over permissible exposure limits or published exposure limits, monitoring was not continued to determine all employees likely to be above those limits:
2 29 CFR 1910.120(i): The employer did not develop and implement a program, which is part of the employer's safety and health program required in 29 CFR 1910.120(b), to inform employees, contractors, and subcontractors (or their representatives) actually engaged in hazardous waste operations of the nature, level and degree of exposure likely to result from participation in such hazardous waste operations:
3 29 CFR 1910.120(j)(1)(i): The employer did not handle, transport, label, and dispose of hazardous substances and contaminated soils, liquids, and other residues in accordance with 29 CFR 1910.120(j)(1)(ii)-(xii):
4 29 CFR 1910.120(j)(1)(ii): Drums and containers meeting the appropriate DOT, OSHA, and EPA regulations for the wastes they contain were not used during the clean-up:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(j)(1)(iii): When practical, drums and containers were not inspected and/or their integrity was not assured prior to being moved:
OPTION 2 2 29 CFR 1910.120(j)(1)(iii): Drums or containers that could not be inspected before being moved because of storage conditions were not moved to an accessible location and/or inspected prior to further handling:
3 29 CFR 1910.120(j)(1)(iv): Unlabeled drums and containers were not labeled as if they contain hazardous substances:
4 29 CFR 1910.120(j)(1)(v): Site operations were not organized to minimize the amount of drum or container movement:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(1)(vi): Prior to movement of drums or containers, all employees exposed during the transfer operation were not warned of the potential hazards associated with the contents of the drums or containers:
OPTION 1 2 29 CFR 1910.120(j)(1)(vii): U.S. Department-of-Transportation-
OPTION 2 3 29 CFR 1910.120(j)(1)(vii): Suitable quantities of proper absorbent were not kept available and/or used in areas where spills, leaks, or ruptures may occur:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(1)(viii): Where major spills may occur, a spill containment program, which is part of the employer's safety and health program required in 29 CFR 1910.120(b), was not implemented to contain and isolate the entire volume of the hazardous substance being transferred:
2 29 CFR 1910.120(j)(1)(ix): Drums and containers that could not be moved without rupture, leakage, or spillage of the contents were not emptied into a sound container using a device classified for the material being transferred:
3 29 CFR 1910.120(j)(1)(x): A ground-penetrating system or other type of detection system or device was not used to estimate the location and depth of buried drums or containers:
4 29 CFR 1910.120(j)(1)(xi): Soil or covering material was not removed with caution to prevent drum or container rupture:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(1)(xii): Fire extinguishing equipment meeting the requirements of 29 CFR 1910, Subpart L, was not on hand and ready for use to control incipient fires:
OPTIONS 1-7 2 29 CFR 1910.120(j)(2) * : In areas where drums or containers were being opened, the following procedures were not followed:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
1 29 CFR 1910.120(j)(3): Material-handling equipment used to transfer drums and containers was not selected, positioned, and/or operated to minimize sources of ignition related to the equipment from igniting vapors released from ruptured drums or containers:
2 29 CFR 1910.120(j)(4): Drums and containers containing radioactive wastes were handled before such time as their hazard to employees was properly assessed:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(5)(i): All non-essential employees were not evacuated from the area where drums and containers containing or suspected of containing shock-sensitive waste were being handled:
2 29 CFR 1910.120(j)(5)(ii): Material-handling equipment was not provided with explosive containment devices or protective shields to protect equipment operators from exploding containers in areas where drums or containers containing or suspected of containing shock-sensitive wastes were being handled:
3 29 CFR 1910.120(j)(5)(iii): An employee alarm system capable of being perceived above surrounding light and noise conditions was not used to signal the commencement and completion of explosive waste-handling activities in areas where drums or containers containing or suspected of containing shock-sensitive wastes were being handled:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(j)(5)(iv): Continuous communications were not maintained between the employee-in-charge of the immediate handling area and/or both the site safety and health supervisor and the command post until such time as the handling operation in areas where drums or containers containing or suspected of containing shock-sensitive wastes was being conducted:
OPTION 2 2 29 CFR 1910.120(j)(5)(iv): Communication equipment or methods that could cause shock sensitive materials to explode were used in areas where drums or containers containing or suspected of containing shock-sensitive wastes were handled:
OPTION 1 3 29 CFR 1910.120(j)(5)(v): Drums and/or containers under pressure, as evidenced by bulging or swelling, were moved before such time as the cause of the excess pressure was determined:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(j)(5)(v): Drums and/or containers under pressure, as evidenced by bulging or swelling, were moved before such time as appropriate containment procedures had been implemented to protect employees from explosive relief of the drums or containers:
2 29 CFR 1910.120(j)(6)(i): Lab packs were not opened only when necessary and then not by an individual knowledgeable in the inspection, classification, and segregation of the containers within the pack according to the hazards of the wastes:
3 29 CFR 1910.120(j)(6)(ii): When crystalline material was noted on a container, the contents was not handled as a shock- sensitive waste:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(7): Containers and drums were not sampled in accordance with a sampling procedure which was part of the site safety and health plan developed for and available to employees and others at the specific worksite:
2 29 CFR 1910.120(j)(8)(i): Drums and containers were not identified and classified prior to packaging for shipment:
3 29 CFR 1910.120(j)(8)(ii): Drum or container staging areas were not kept to the minimum number necessary to identify and classify materials safely and prepare them for transport:
4 29 CFR 1910.120(j)(8)(iii): Staging areas were not provided with adequate access and egress routes:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(j)(8)(iv): Bulking of hazardous wastes was permitted before a thorough characterization of the materials had been completed:
2 29 CFR 1910.120(j)(9)(i): Tanks and vaults containing hazardous substances were not handled in a manner similar to that for drums and containers, taking into consideration the size of the tank or vault:
3 29 CFR 1910.120(j)(9)(ii): Appropriate tank or vault entry procedures as described in the site safety and health plan were not followed whenever employees must enter a tank or vault:
4 29 CFR 1910.120(k)(2)(i): A decontamination procedure was not developed, communicated to employees, or implemented before any equipment or employee entered areas on site where potential for exposure to hazardous materials exists:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(k)(2)(ii): Standard operating procedures were not developed to minimize employee contact with hazardous substances or with equipment that had contacted hazardous materials:
OPTION 1 2 29 CFR 1910.120(k)(2)(iii): All employees leaving a contaminated area were not appropriately decontaminated:
OPTION 2 3 29 CFR 1910.120(k)(2)(iii): All contaminated clothing and/or equipment leaving a contaminated area was not appropriately disposed of or decontaminated:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(k)(2)(iv): Decontamination procedures were not monitored by the site safety and health supervisor to determine their effectiveness:
OPTION 2 2 29 CFR 1910.120(k)(2)(iv): Appropriate steps were not taken to correct deficiencies in decontamination procedures when they were found to be ineffective:
3 29 CFR 1910.120(k)(3): Decontamination was not performed in geographical areas that would minimize the exposure of uncontaminated employees or equipment to contaminated employees or equipment:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(k)(4): All equipment and/or solvents used for decontamination were not decontaminated or disposed of properly:
2 29 CFR 1910.120(k)(5)(i): Protective clothing and equipment were not decontaminated, cleaned, laundered, maintained, or replaced as needed to maintain their effectiveness:
OPTION 1 3 29 CFR 1910.120(k)(5)(ii): Employees whose non-impermeable clothing became wetted with hazardous substances did not immediately remove that clothing and/or proceed to shower:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(k)(5)(ii): The employer did not ensure that non-impermeable clothing that became wetted with hazardous substances was disposed of or decontaminated before it was removed from the work zone:
2 29 CFR 1910.120(k)(6): Unauthorized employees removed protective clothing or equipment from change rooms:
3 29 CFR 1910.120(k)(7): Commercial laundries or cleaning establishments that decontaminate protective clothing or equipment were not informed of the potentially harmful effects of exposures to hazardous substances:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(k)(8): Showers and/or change rooms meeting the requirements of 29 CFR 1910.141 were not provided where the decontamination procedure indicated a need for regular showers and change rooms outside of a contaminated area:
OPTION 2 2 29 CFR 1910.120(k)(8): Other effective means for cleansing were not provided and/or used when temperature conditions prevented the effective use of water:
OPTION 1 3 29 CFR 1910.120(l)(1)(i): An emergency response plan was not developed and/or implemented by all employers within the scope of 29 CFR 1910.120(a)(1)(i)-(ii) prior to the commencement of hazardous waste operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(l)(1)(i): The emergency response plan was not in writing and/or available for inspection and copying by employees, employee representatives, OSHA personnel, or other government agencies with relevant responsibilities:
OPTIONS 1-11 1 29 CFR 1910.120(l)(2) * : The employer did not develop an emergency response plan that addressed: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(xi)):
NOTE: These SAVEs listed under Options 1-11 may be grouped with
29 CFR 1910.120(b)(4)(ii)(H) as appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OPTIONS 1-2 1 29 CFR 1910.120(l)(3)(i) * : The employer did not include in the emergency response plan the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A) or (B)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(l)(3)(ii): The emergency response plan was not maintained as a separate section of the Site Safety and Health Plan:
2 29 CFR 1910.120(l)(3)(iii): The emergency response plan was not compatible and integrated with the disaster, fire, and/or emergency response plans of local, State, and/or Federal agencies:
3 29 CFR 1910.120(l)(3)(iv): The emergency response plan was not rehearsed regularly as part of the overall training program for site operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(l)(3)(v): The emergency response plan was not reviewed periodically or amended as necessary to keep it current with new or changing site conditions:
OPTIONS 1-3 2 29 CFR 1910.120(l)(3)(vi): An employee alarm system was not installed in accordance with 29 CFR 1910.165 to notify employees of an emergency situation: ENTER THE APPROPRIATE OPTION:
NOTE: These SAVEs listed under Options 1-3 may be grouped with
29 CFR 1910.120(b)(4)(ii)(H) as appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(l)(3)(vii): Based upon the information available at the time of the emergency, the employer did not evaluate the incident and the site response capabilities and/or proceed with the appropriate steps to implement the site emergency response plan:
2 29 CFR 1910.120(m): While work was in progress, areas accessible to employees were not lighted to not less than the minimum illumination intensities listed in Table H-120.1:
3 29 CFR 1910.120(n)(1)(i): An adequate supply of potable water was not provided on the site:
OPTION 1 4 29 CFR 1910.120(n)(1)(ii): Portable containers used to dispense drinking water were not capable of being tightly closed and/or were not equipped with a tap:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(n)(1)(ii): Water was dipped from containers:
OPTION 1 2 29 CFR 1910.120(n)(1)(iii): A container used to distribute drinking water was not clearly marked as to the nature of its contents:
OPTION 2 3 29 CFR 1910.120(n)(1)(iii): A container used to distribute drinking water was used for another purpose:
4 29 CFR 1910.120(n)(1)(iv): Where single service cups were supplied, a sanitary container for the unused cups and/or a receptacle for disposing of the used cups were not provided:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(n)(2)(i): The employer did not identify outlets for nonpotable water to indicate clearly that the water was unsafe and was not to be used for drinking, washing, or cooking purposes:
2 29 CFR 1910.120(n)(2)(ii): There was an open, or potential, cross-connection between a system furnishing potable water and a system furnishing nonpotable water:
3 29 CFR 1910.120(n)(3)(i): Toilets were not provided for employees in accordance with the requirements contained in Table H-120.2:
4 29 CFR 1910.120(n)(3)(ii): Under temporary field conditions, provisions were not made to assure that at least one toilet facility was available:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-4 1 29 CFR 1910.120(n)(3)(iii) * : The hazardous waste site, which was not provided with a sanitary sewer, although not prohibited by local codes, was not provided with: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):
2 29 CFR 1910.120(n)(3)(v): Doors entering toilet facilities were not provided with entrance locks controlled from inside the facilities:
3 29 CFR 1910.120(n)(4): Food service facilities and operations for employees did not meet applicable laws, ordinances, and regulations of the jurisdictions in which they were located:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(n)(5): When temporary sleeping quarters were provided, they were not heated, ventilated, and lighted:
OPTION 1 2 29 CFR 1910.120(n)(6): Adequate washing facilities were not provided for employees engaged in operations where hazardous substances may be harmful to employees:
OPTION 2 3 29 CFR 1910.120(n)(6): Washing facilities were not in near proximity to the worksite; in areas where exposures were below permissible exposure limits and published exposure levels and which were under the control of the employer; and were not so equipped as to enable employees to remove hazardous substances from themselves:
4 29 CFR 1910.120(n)(7): When hazardous waste clean-up or removal operations had commenced on a site and the duration of the work required six months or longer to complete, showers and change rooms were not provided for all employees exposed to hazardous substances and health hazards involved in hazardous waste clean- up or removal operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(n)(7)(i): Showers meeting the requirements of 29 CFR 1910.141(d)(3) were not provided:
OPTION 1 2 29 CFR 1910.120(n)(7)(ii): Change rooms meeting the requirements of 29 CFR 1910.141(e) were not provided:
OPTION 2 3 29 CFR 1910.120(n)(7)(ii): Change rooms did not consist of two separate change areas separated by the shower area required in 29 CFR 1910.120(n)(7)(i):
OPTION 3 4 29 CFR 1910.120(n)(7)(ii): One change area, with an exit leading off the worksite, did not provide employees with a clean area where they could remove, store, and put on street clothing:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 4 1 29 CFR 1910.120(n)(7)(ii): The second change area, with an exit to the worksite, did not provide employees with an area where they could put on, remove, and store work clothing and personal protective equipment:
OPTION 1 2 29 CFR 1910.120(n)(7)(iii): Showers and change rooms were not located in areas where exposures were below the permissible exposure limits and published exposure levels:
OPTION 2 3 29 CFR 1910.120(n)(7)(iii): Where showers and change rooms were not feasible, a ventilation system was not provided that would supply air that was below the permissible exposure limits and published exposure levels:
4 29 CFR 1910.120(n)(7)(iv): The employer did not ensure that employees showered at the end of their work shift and when leaving the hazardous waste site:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(o)(1): Procedures were not developed for the introduction of effective new technologies and equipment for the improved protection of employees working with hazardous waste operations and were not implemented as part of the site safety and health program to assure that employee protection was being maintained:
OPTION 1 2 29 CFR 1910.120(o)(2): New technologies, equipment, or control measures available to the industry to suppress the level of air contaminants while excavating the site or for spill control were not evaluated by employers or their representatives:
OPTION 2 3 29 CFR 1910.120(o)(2): An evaluation to determine the effectiveness of the new methods, materials, or equipment was not done before they were used on a large scale for enhancing employee protection:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(p)(1): Employers conducting operations at treatment, storage, and disposal (TSD) facilities specified in 29 CFR 1910.120(a)(1)(iv) and who are not exempted by 29 CFR 1910.120(a)(2)(iii) did not provide and/or implement a written safety and health program for employees involved in hazardous waste operations that was available for inspection by employees and their representatives:
OPTION 2 2 29 CFR 1910.120(p)(1): The program was not designed to identify, evaluate and control safety and health hazards in their facilities for the purpose of employee protection, to provide for emergency responses meeting the requirements of 29 CFR 1910.120(p)(8), and to address as appropriate site analysis, engineering controls, maximum exposure limits, hazardous waste handling procedures, and uses of new technologies:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(p)(2): A hazard communication program meeting the requirements of 29 CFR 1910.1200, was not implemented as part of the employer's safety and health program:
2 29 CFR 1910.120(p)(3): A medical surveillance program meeting the requirements of 29 CFR 1910.120(f) was not developed and implemented:
3 29 CFR 1910.120(p)(4): A decontamination procedure meeting the requirements of 29 CFR 1910.120(k) was not developed and implemented:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(p)(5): Procedures meeting the requirements of 29 CFR 1910.120(o) for introducing new and innovative equipment into the workplace were not developed and implemented:
2 29 CFR 1910.120(p)(6): Where employees will be handling drums or containers, procedures meeting the requirements of 29 CFR 1910.120(j)(1)(ii) through (j)(1)(viii) and (xi), as well as (j)(3) and (j)(8), were not developed and implemented prior to such work:
OPTION 1 3 29 CFR 1910.120(p)(7)(i): A training program for employees exposed to health hazards or hazardous substances at TSD operations was not developed and implemented to enable employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(p)(7)(i): Initial training for 24 hours and/or refresher training for 8 hours annually was not provided for employees exposed to health hazards or hazardous substances at TSD operations:
OPTION 3 2 29 CFR 1910.120(p)(7)(i): Employees who had received the initial training required were not given a written certificate attesting that they had successfully completed such training:
3 29 CFR 1910.120(p)(7)(ii): Current employees did not receive 8 hours of refresher training annually:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(p)(7)(iii): Trainers who taught initial training had not satisfactorily completed a training course for teaching the subjects they were expected to teach:
OPTION 2 2 29 CFR 1910.120(p)(7)(iii): Trainers who taught initial training did not have the academic credentials and instruction experience necessary to demonstrate a good command of the subject matter of the courses and competent instructional skills:
OPTION 1 3 29 CFR 1910.120(p)(8)(i): The employer did not develop and implement an emergency response plan:
OPTION 2 4 29 CFR 1910.120(p)(8)(i): The emergency response plan was not a part of the safety and health program developed by the employer as required in 29 CFR 1910.120(p)(1):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 3 1 29 CFR 1910.120(p)(8)(i): An emergency action plan in accordance with 29 CFR 1910.38(a) was not provided by the employer who will evacuate their employees from the danger area when an emergency occurs and who do not permit any of their employees to assist in handling the emergency:
OPTIONS 1-11 2 29 CFR 1910.120(p)(8)(ii) * : An emergency response plan for emergencies that addressed, to the extent not addressed in any specific program required in this paragraph, the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(K)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OPTION 1 1 29 CFR 1910.120(p)(8)(iii)(A): Training for emergency response employees was not completed before they were called upon to perform in real emergencies:
OPTION 2 2 29 CFR 1910.120(p)(8)(iii)(A): Training given to emergency response employees did not include the elements of the emergency response plan, standard operating procedures the employer had established for the job, personal protection equipment to be worn, and procedures for handling emergency incidents:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(p)(8)(iii)(B): Employee members of TSD facility emergency response organizations were not trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees:
OPTION 1 2 29 CFR 1910.120(p)(8)(iii)(C): The employer did not certify that each covered employee had attended and successfully completed the training required in 29 CFR 1910.120(p)(8)(iii):
OPTION 2 3 29 CFR 1910.120(p)(8)(iii)(C): The employer did not certify the employee's competence at least yearly:
OPTION 3 4 29 CFR 1910.120(p)(8)(iii)(C): The method used to demonstrate competency for certification of training was not recorded and maintained by the employer:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-2 1 29 CFR 1910.120(p)(8)(iv)(A) * : The emergency response plan did not include the following elements to the extent that they did not repeat any information already contained in the emergency response plan: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((1) or (2)):
2 29 CFR 1910.120(p)(8)(iv)(B): The emergency response plan was not compatible and integrated with the disaster, fire, and/or emergency response plans of local, State, and/or Federal agencies:
3 29 CFR 1910.120(p)(8)(iv)(C): The emergency response plan was not rehearsed regularly as part of the overall training program for site operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(p)(8)(iv)(D): The site emergency response plan was not reviewed periodically and amended, as necessary, to keep it current with new or changing site conditions or information:
2 29 CFR 1910.120(p)(8)(iv)(E): An employee alarm system was not installed in accordance with 29 CFR 1910.165 to notify employees of an emergency situation; to stop work activities if necessary; to lower background noise to speed communication; and to begin emergency procedures:
3 29 CFR 1910.120(p)(8)(iv)(F): Based upon information available at the time of the emergency, the employer did not evaluate the incident and the site response capabilities and proceed with the appropriate steps to implement the site emergency response plan:
OPTION 1 4 29 CFR 1910.120(q)(1): Employers whose employees were engaged in emergency response no matter where it occurs except for employees engaged in operations specified in 29 CFR 1910.120(a)(1)(i) through (a)(1)(iv), did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(q)(1): The emergency response plan was not in writing and was not available for inspection and copying by employees and their representatives:
OPTIONS 1-11 2 29 CFR 1910.120(q)(2) * : The emergency response plan did not address, to the extent not addressed elsewhere, the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(xi)):
NOTE: Options 9 through 11 are continued top of next page.
146.85
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OPTION 1 1 29 CFR 1910.120(q)(3)(i): The senior emergency response official responding to an emergency did not become the individual in charge of a site-specific Incident Command System (ICS):
OPTION 2 2 29 CFR 1910.120(q)(3)(i): All emergency responders and their communications were not coordinated and controlled through the individual in charge of the ICS, assisted by the senior official present for each employer:
3 29 CFR 1910.120(q)(3)(ii): The individual in charge of the ICS did not identify, to the extent possible, all hazardous substances or conditions present and did not address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies: (a) (LOCATION) (I ENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(q)(3)(iii): Based on the hazardous substances and/or conditions present, the individual in charge of the ICS did not implement appropriate emergency operations and did not assure that the personal protective equipment worn was appropriate for the hazards to be encountered:
OPTION 2 2 29 CFR 1910.120(q)(3)(iii): Personal protective equipment did not meet the criteria contained in 29 CFR 1910.156(e) when worn while performing firefighting operations beyond the incipient stage for any incident:
3 29 CFR 1910.120(q)(3)(iv): Positive-pressure self-contained breathing apparatus was not worn by employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard, until such time that the individual in charge of the ICS determined through the use of air monitoring that a decreased level of respiratory protection would not result in hazardous exposures to employees:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.120(q)(3)(v): The individual in charge of the ICS did not limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who were actively performing emergency operations:
OPTION 2 2 29 CFR 1910.120(q)(3)(v): All operations performed by groups of two or more in hazardous areas were not performed using the buddy system:
OPTION 1 3 29 CFR 1910.120(q)(3)(vi): Back-up personnel did not stand by with equipment ready to provide assistance or rescue:
OPTION 2 4 29 CFR 1910.120(q)(3)(vi): Advanced first aid support personnel did not stand by with medical equipment and transportation capability:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(q)(3)(vii): The individual in charge of the ICS did not designate a safety officer, who was knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and provide direction with respect to the safety of operations for the emergency at hand:
OPTION 1 2 29 CFR 1910.120(q)(3)(viii): When the safety official judged activities to be an IDLH condition and/or to involve an imminent danger condition, the safety official did not have the authority to alter, suspend, or terminate those activities:
OPTION 2 3 29 CFR 1910.120(q)(3)(viii): The safety official did not immediately inform the individual in charge of the ICS of any actions that needed to be taken to correct the hazards at the emergency scene:
4 29 CFR 1910.120(q)(3)(ix): The individual in charge of the ICS did not implement appropriate decontamination procedures after emergency operations had terminated:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(q)(3)(x): Compressed air cylinders used with self-contained breathing apparatus did not meet U.S. Department of Transportation and the National Institute for Occupational Safety and Health criteria:
OPTION 1 2 29 CFR 1910.120(q)(4): Skilled support personnel, such as those operating earth moving or digging equipment or cranes and hoisting equipment who would or could be exposed to the hazards at an emergency response scene, were not given an initial briefing at the site prior to their participation in any emergency response:
OPTION 2 3 29 CFR 1910.120(q)(4): The initial briefing did not include instruction in the wearing of appropriate personal protective equipment, what chemical hazards were involved, and what duties were to be performed:
OPTION 3 4 29 CFR 1910.120(q)(4): All other appropriate safety and health precautions provided to the employer's own personnel were not used to assure the safety and health of those skilled support personnel:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(q)(5): Employees who, in the course of their regular job duties, worked with and were trained in the hazards of specific hazardous substances and who were called upon to provide technical advice or assistance to the individual in charge at a hazardous substance release incident did not receive training or demonstrate competency in the area of their specialization annually:
OPTION 1 2 29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization:
OPTION 2 3 29 CFR 1910.120(q)(6): The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, were not conveyed to them through training before they were permitted to take part in actual emergency operations on an incident:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(i) * : Employees who participated, or were expected to participate, in emergency response as first responders at the awareness level did not have sufficient training or sufficient experience to objectively demonstrate competency in: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(ii) * : Employees who participated, or were expected to participate, in emergency response as first responders at the operational level had not received at least 8 hours of training and/or had not been certified as having such training and/or did not have sufficient experience to demonstrate competency, in addition to the areas listed for the awareness levels, in: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-9 1 29 CFR 1910.120(q)(6)(iii) * : Employees who participated, or were expected to participate, as hazardous material technicians had not received at least 24 hours of training equal to the first responder operations level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(I)):
NOTE: These SAVEs listed under Options 1-9 below may be grouped
with 29 CFR 1910.120(q)(6) as appropriate.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OPTIONS 1-9 1 29 CFR 1910.120(q)(6)(iv) * : Employees who participated, or were expected to participate, as hazardous material specialists had not received 24 hours of training equal to the hazardous materials technician level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(I)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(v) * : Employees who participated, or were expected to participate, as an on-scene incident commander had not received 24 hours of training equal to the first responder operations level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(q)(7): Trainers who taught the training subjects specified in 29 CFR 1910.120(q)(6) had not satisfactorily completed a training course for teaching the subjects they were expected to teach and/or did not have academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they were to teach:
2 29 CFR 1910.120(q)(8)(i): Employees who were trained in accordance with 29 CFR 1910.120(q)(6) did not receive annual refresher training of sufficient content and duration to maintain their competencies or did not demonstrate competency in those areas at least yearly:
OPTION 1 3 29 CFR 1910.120(q)(8)(ii): A statement of the training or competency of each employee was not made:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.120(q)(8)(ii): The employer did not keep a record of the methodology used to demonstrate competency when a statement of competency was made:
2 29 CFR 1910.120(q)(9)(i): Members of an organized and designated HAZMAT team and hazardous materials specialists did not receive a baseline physical examination and were not provided with medical surveillance as required in 29 CFR 1910.120(f):
3 29 CFR 1910.120(q)(9)(ii): Emergency response employees who exhibited signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident, either immediately or subsequently, were not provided with medical consultation as required in 29 CFR 1910.120(f)(3)(ii):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(q)(10): Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, did not meet the requirements of 29 CFR 1910.120(g)(3) through (5):
2 29 CFR 1910.120(q)(11)(i): When it had been determined, upon completion of the emergency response, that it was necessary to remove hazardous substances, health hazards, and materials contaminated with them from the site of the incident, the employer conducting the clean-up did not comply with all of the requirements of 29 CFR 1910.120(b) through (o):
OPTION 1 3 29 CFR 1910.120(q)(11)(ii): Where the clean-up was done on plant property using plant or workplace employees, such employees had not completed the training requirements of 29 CFR 1910.38(a); 1910.134; 1910.1200; and other appropriate safety and health training made necessary by the tasks that they were expected to perform:
OSHA Instruction CPl 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 4 29 CFR 1910.120(q)(11)(ii): Equipment to be used in the performance of clean-up work was not in serviceable condition and had not been inspected prior to use:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OSHA Instruction CPL 2.35 CH-11 JUNE 25, 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.145(c)(3):Safety instruction sign(s) were not used where there was a need for general instructions and suggestions relative to safety measure(s):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(c)(1): The employer did not establish a program consisting of an energy control procedure and employee training to ensure that before any employee performed any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment would be isolated, and rendered inoperative in accordance with 29 CFR 1910.147(c)(4):
2 29 CFR 1910.147(c)(2)(i): Where an energy isolating device was not capable of being locked out, the employer's energy control program under 29 CFR 1910.147(c)(1) did not utilize a tagout system:
3 29 CFR 1910.147(c)(2)(ii): The employer's tagout energy control program procedures did not successfully comply with 29 CFR 1910.147(c)(3) and no lockout was provided for employee protection:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT)
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.147(c)(2)(iii): Where major replacement, repair, renovation or modification of machine or equipment was performed after January 2, 1990, the employer did not provide an energy isolating device designed to accept a lockout device:
OPTION 2 2 29 CFR 1910.147(c)(2)(iii): New machines and equipment that were installed after January 2, 1990, were not provided with energy isolating devices designed to accept lockout devices:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT AND DATE
INSTALLATION)
3 29 CFR 1910.147(c)(3)(i): The tagout device used on an energy isolating device, which was capable of being locked out, was not attached at the same location that the lockout device would have been attached:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT)
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT) (THIS
INCLUDES ENFORCEMENT OF PROCEDURES)
OPTION 1 2 29 CFR 1910.147(c)(4)(ii): The energy control procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, including, but not limited to Items A-D of this section:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.147(c)(4)(ii): Energy control procedures did not provide a means to enforce compliance:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)
2 29 CFR 1910.147(c)(5)(i): Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware were not provided by the employer for isolating, securing, or blocking of machines or equipment from energy sources:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)
OPTION 1 3 29 CFR 1910.147(c)(5)(ii): Lockout devices and tagout devices were not singularly identified:
OPTION 2 4 29 CFR 1910.147(c)(5)(ii): Device other than lockout devices and tagout devices were used for controlling energy:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 3 1 29 CFR 1910.147(c)(5)(ii): Lockout devices and tagout devices were utilized for other purposes than controlling energy:
2 29 CFR 1910.147(c)(5)(ii)(A)(1): Lockout and tagout devices were not durable; they were not capable of withstanding the environment to which they were exposed for the maximum period of time that exposure was expected:
OPTION 1 3 29 CFR 1910.147(c)(5)(ii)(A)(2): Tagout devices were not constructed so that exposure to wet and damp locations would not cause the tag to deteriorate:
OPTION 2 4 29 CFR 1910.147(c)(5)(ii)(A)(2): Tagout devices were not printed so that exposure to wet and damp locations would not cause the message on the tag to become illegible:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(c)(5)(ii)(A)(3): Tags in use were not durable to prevent their deterioration in corrosive environments such as areas where acid and alkali chemicals were handled and stored:
OPTION 1 2 29 CFR 1910.147(c)(5)(ii)(B): Lockout and tagout devices were not standardized within the facility in at least one criteria: Color; shape; or size:
OPTION 2 3 29 CFR 1910.147(c)(5)(ii)(B): Print and format utilized for tagout devices were not standardized within the facility:
4 29 CFR 1910.147(c)(5)(ii)(C)(1): Lockout devices were not substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.147(c)(5)(ii)(C)(2): Tagout devices and their means of attachment were not substantial enough to prevent inadvertent or accidental removal:
OPTION 2 2 29 CFR 1910.147(c)(5)(ii)(C)(2): Means of attachment of tagout devices utilized by the employer were not of a non- reusable type, attachable by hand, self-locking, and non- releasable with a minimum unlocking strength of no less than 50 pounds:
3 29 CFR 1910.147(c)(5)(ii)(D): Lockout devices and tagout devices did not indicate the identity of the employee applying the device(s):
4 29 CFR 1910.147(c)(5)(iii): Tagout devices utilized did not warn against hazardous conditions if the machine or equipment was energized:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(c)(6)(i): The employer did not conduct an annual or more frequent inspection of the energy control procedure to ensure that the procedure and requirements of this standard were followed:
2 29 CFR 1910.147(c)(6)(i)(A): The periodic inspection of the energy control procedure was not performed by an authorized employee other than the one utilizing the energy control procedure being inspected:
3 29 CFR 1910.147(c)(6)(i)(B): The periodic inspection of the energy control procedure was not conducted to correct any deviations or inadequacies identified during the inspection:
4 29 CFR 1910.147(c)(6)(i)(C): Where lockout was used for energy control, the periodic inspection did not include a review, between the inspector and each authorized employee, of that employee's responsibilities under the energy control procedure being inspected:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.147(c)(6)(i)(D): Where tagout was used for energy control, the periodic inspection did not include a review, between the inspector and each authorized and affected employee:
OPTION 2 2 29 CFR 1910.147(c)(6)(i)(D): Where tagout was used for energy control, the periodic inspection did not include a review, between the inspector and of the employee's responsibilities under the energy control procedure being inspected:
OPTION 3 3 29 CFR 1910.147(c)(6)(i)(D): Where tagout was used for energy control, the periodic inspection did not include the elements set forth in 29 CFR 1910.147(c)(7)(ii):
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)
OPTION 1 4 29 CFR 1910.147(c)(6)(ii): The employer had not certified that periodic inspections of the energy control procedures had been performed:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.147(c)(6)(ii): The periodic inspection certification of energy control procedures did not contain the required documentation as to identification of the machine or equipment, inspection date, employees included, and the person performing the inspection:
OPTION 1 2 29 CFR 1910.147(c)(7)(i): The employer did not provide adequate training to ensure that the purpose and function of the energy control program was understood by employees:
OPTION 2 3 29 CFR 1910.147(c)(7)(i): The employer did not provide adequate training to ensure that employees required the knowledge and skills required for the safe application, usage and removal of energy control devices:
OPTION 3 4 29 CFR 1910.147(c)(7)(i): The training program of the employer did not include all the training elements listed under Items A-C of this section:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(c)(7)(ii): The employer used a tagout system and did not provide training to the employees which included the limitations of tags as listed under A-F of this section:
2 29 CFR 1910.147(c)(7)(iii)(A): Retraining was not provided for authorized and affected employees when there was a change in their job assignments, a change in machines, equipment or processes that presented a new hazard, or when there was a change in the energy control procedures:
3 29 CFR 1910.147(c)(7)(iii)(B): Additional retraining was not provided whenever a periodic inspection under 29 CFR 1910.147(c)(6) revealed that there were deviations from or inadequacies in the employee's knowledge or use of the energy control procedures:
OPTION 1 4 29 CFR 1910.147(c)(7)(iii)(C): Retraining of employees for proficiency did not the introduce new or revised control methods and procedures as necessary:
OPTION 2 5 29 CFR 1910.147(c)(7)(iii)(C): Retraining did not reestablish employee proficiency about the prohibition relating to attempts to restart or reenergize machines or equipment which are locked or tagged out:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.147(c)(7)(iv): The employer had not certified that employee training had been accomplished and kept up to date:
OPTION 2 2 29 CFR 1910.147(c)(7)(iv): The certification of employee training by the employer did not contain each employee name and date of training:
3 29 CFR 1910.147(c)(8): Lockout or tagout was not performed only by the authorized employees who are performing the servicing or maintenance:
OPTION 1 4 29 CFR 1910.147(c)(9): The employer or authorized employee did not notify affected employees of the application and removal of lockout or tagout devices from the machine or equipment:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.147(c)(9): The employer or authorized employee did not notify affected employees before the lockout or tagout devices were applied to the machine or equipment:
OPTION 3 2 29 CFR 1910.147(c)(9): The employer or authorized employee did not notify affected employees after the lockout or tagout devices were removed from the machine or equipment:
3 29 CFR 1910.147(d): The established procedure for the application of energy control (the lockout or tagout procedures) did not cover the following elements, actions and done in sequence as required by 29 CFR 1910.147 (d)(1)- (d)(6):
4 29 CFR 1910.147(d)(1): The authorized employee did not have knowledge of the type and magnitude of the energy, the hazards of the energy to be controlled, and the method or means to control the energy before the authorized or affected employee turned off the machine or equipment in preparation for the shutdown:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 1 1 29 CFR 1910.147(d)(2): The machine or equipment was not turned off or shut down using the procedures established the machine or equipment:
OPTION 2 2 29 CFR 1910.147(d)(2): An orderly shutdown of machine or equipment was not utilized to avoid any additional or increased hazards to employees as a result of equipment stoppage:
3 29 CFR 1910.147(d)(3): All energy isolating devices that were needed to control the energy to the machine or equipment was not physically located and operated in such a manner as to isolate the machine or equipment from the energy source.
4 29 CFR 1910.147(d)(4)(i): Lockout or tagout devices were not affixed to each energy isolating device by authorized employees:
(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(d)(4)(ii): Lockout devices utilized were not affixed in a manner that held the energy isolating device in a "safe" or "off" position:
2 29 CFR 1910.147(d)(4)(iii): Tagout devices utilized were not affixed in such a manner as to clearly indicate that the operation or movement of the energy isolating devices from the "safe" or "off" position was prohibited:
3 29 CFR 1910.147(d)(4)(iii)(A): Where tagout devices were used with energy isolating devices designed with the capability of being locked, the tag attachment was not fastened at the same point at which the lock would have been attached:
4 29 CFR 1910.147(d)(4)(iii)(B): Where a tag could not be affixed directly to the energy isolating device, the tag was not located as close as safely possible to the device, in a position that would have been immediately obvious to anyone attempting to operate the device:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(d)(5)(i): All potentially hazardous stored or residual energy was not relieved, disconnected, restrained or otherwise rendered safe after the application of lockout or tagout devices to energy isolating devices:
2 29 CFR 1910.147(d)(5)(ii): Where there was a possibility of reaccumulation of stored energy to a hazardous level, verification of isolation was not continued until the servicing or maintenance was completed, or until the possibility of such accumulation no longer existed:
3 29 CFR 1910.147(d)(6): Prior to starting work on machines or equipment that had been locked out or tagged out, the authorized employee did not verify that isolation and deenergization of the machine or equipment had been accomplished:
4 29 CFR 1910.147(e)(1): Before lockout or tagout devices were removed and energy was restored to the machine or equipment, authorized employees did not inspect the work area to ensure that nonessential items had been removed and that machine or equipment components were operationally intact.
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(e)(2)(i): Before lockout or tagout devices were removed and energy was restored to the machine or equipment, authorized employees did not ensure that all employees had been safely positioned or removed from the work area:
2 29 CFR 1910.147(e)(2)(ii): After lockout or tagout devices were removed and before machines or equipment is started, affected employees were not notified that the lockout or tagout device(s) have been removed:
3 29 CFR 1910.147(e)(3): Each lockout or tagout device was not removed from each energy isolating device by the employee who had applied the device:
4 29 CFR 1910.147(f)(1): When lockout or tagout devices temporarily were removed from the energy isolating device and the machine or equipment was energized to test or position the machine, equipment or component thereof, the sequence of actions were not followed in accordance with 29 CFR 1910.147(f)(1)(i)-(v):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.147(f)(2)(i): When outside servicing personnel were engaged in activities in a facility, the on-site employer and the outside employer did not inform each other of their respective lockout or tagout procedures:
2 29 CFR 1910.147(f)(2)(ii): The on-site employer did not ensure that his or her personnel understood and complied with restrictions and prohibitions of the outside employer's energy control procedures:
3 29 CFR 1910.147(f)(3)(i): A procedure was not utilized to afford the employees a level of protection equivalent to that provided by the implementation of a personal lockout or tagout device when servicing and/or maintenance was performed by a crew, craft, department, or other group:
OPTION 1 4 29 CFR 1910.147(f)(3)(ii): Group lockout or tagout devices were not used in accordance with procedures required by 29 CFR 1910.147(c)(4):
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance OPTION 2 1 29 CFR 1910.147(f)(3)(ii): Group lockout or tagout devices were not used in accordance with specific requirements listed in paragraphs A-D of this section:
2 29 CFR 1910.147(f)(4): During shift or personnel changes, specific procedures were not utilized to ensure the continuity of lockout or tagout protection, including provision for the orderly transfer of lockout or tagout devices between off-going and oncoming employees, to minimize exposure to hazards from the unexpected energization, or start-up of the machine or equipment, or the release of stored energy:
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance
OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.151(a): Medical personnel were not readily available for advice and consultation on matters of plant health:
OPTION 1 2 29 CFR 1910.151(b): There was neither an infirmary, clinic, or hospital used for the treatment of all injured employees in near proximity to the workplace nor a person or persons adequately trained to render first aid:
OPTION 2 3 29 CFR 1910.151(b): First aid supplies approved by a consulting physician were not readily available:
4 29 CFR 1910.151(c): Where employees were exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body were not provided within the work area for immediate emergency use:
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