Coordinating Agency:
Department of Labor/Occupational Safety and Health Administration
Cooperating Agencies:
Department of Defense
Department of Energy
Department of Health and Human Services Department of Homeland Security
Environmental Protection Agency
Introduction
Purpose
The Worker Safety and Health Support Annex provides guidelines for implementing
worker safety and health support functions during potential or actual Incidents
of National Significance. This annex describes the actions needed to ensure that
threats to responder safety and health are anticipated, recognized, evaluated,
and controlled consistently so that responders are properly protected during
incident management operations.
Scope
- This annex addresses those functions critical to supporting and facilitating
the protection of worker safety and health for all emergency responders and
response organizations during potential and actual Incidents of National
Significance. While this annex addresses coordination and provision of technical
assistance for incident safety management activities, it does not address public
health and safety.
- Coordination mechanisms and processes used to provide technical assistance for
carrying out incident safety management activities include identification and
characterization of incident hazards, assessments and analyses of health risks
and exposures to responders, medical monitoring, and incident risk management.
Policies
- Emergency Support Function (ESF) #5 -- Emergency Management activates the
Department of Labor/Occupational Safety and Health Administration (DOL/OSHA) as
the coordinator for worker safety and health technical support. DOL/OSHA then
implements the activities described in this annex.
- DOL/OSHA assistance and coordination, as described in this annex, also may be
requested during the course of an incident if specific needs are identified by
other ESFs or individual agencies.
- Private-sector and Federal employers are responsible for the safety and health
of their own employees.
- State and local governments are responsible for worker health and safety
pursuant to State and local statutes, and in some cases 40 CFR 311, Worker
Protection. This responsibility includes allocating sufficient resources for
safety and health programs, training staff, purchasing protective clothing and
equipment as needed, and correcting unsafe or unsanitary conditions.
- This annex does not replace the primary responsibilities of the government and
employers; rather, it ensures that in fulfilling these responsibilities,
response organizations plan and prepare in a consistent manner and that
interoperability is a primary consideration for worker safety and health.
- Several Federal and State agencies, including DOL/OSHA and the Environmental
Protection Agency (EPA), have oversight authority for responders and response
operations. While these agencies retain their authorities, they are expected to work
cooperatively and proactively with Federal, State, local, and private-sector responders prior
to and during response operations to ensure the adequate protection of all
workers.
- Worker safety and health representatives work with the Joint Information
Center (JIC) regarding the release of general occupational safety and health
information.
Concept of Operations
General
DOL/OSHA coordinates Federal safety and health assets to provide proactive
consideration of all potential hazards; ensures availability and management of
all safety resources needed by responders; shares responder safety-related
information; and coordinates among Federal agencies, State, local, and tribal
governments, and private-sector organizations involved in incident response.
Organization
Headquarters Level
- DOL/OSHA coordinates the activities of the Federal agencies that provide the
core architecture for worker safety and health technical support during an
Incident of National Significance or when otherwise directed.
- DOL/OSHA and cooperating agencies provide staff to support the Joint Field
Office (JFO) Safety Coordinator/Incident Command Post
(ICP) Safety Officer. DOL/OSHA and cooperating agencies also may serve as
technical specialists in other JFO elements as required.
Regional and Field Level
Representatives from Federal, State, local, and tribal governments and the
private sector involved in incident characterization, stabilization, and cleanup
meet at least daily to identify and resolve conflicts, share information, and
provide the JFO Safety Coordinator/ICP Safety Officer with the information
necessary to manage responder safety and health risks.
Pre-Incident Coordination
Coordination Through Existing Organizations and Committees
- DOL/OSHA supports and is a member of the National Response Team under the
National Oil and Hazardous Substance Pollution Contingency Plan (NCP).
- Pre-incident coordination also involves other existing interagency committees
that focus attention on responder health and safety.
NRP Worker Safety and Health Support
Coordination Committee
This standing committee provides the proactive integration of worker safety and
health assets needed for preparedness at all levels of government.
- DOL/OSHA coordinates this group through regular meetings and interagency
exercises.
- DOL/OSHA and the cooperating agencies report to the Emergency Support Function
Leaders Group at least twice yearly on the status of worker safety and health
asset readiness.
Pre-Incident Planning Guidance Development and Distribution
- DOL/OSHA works with organizations such as the National Institute of
Environmental Health Sciences (NIEHS) Worker Education and Training Program (WETP)
National Clearinghouse for Worker Safety and Health Training to consolidate
responder safety- and health-related guidance documents, regulations, and
resources in one location. This information is provided to other agencies,
responders, and
response organizations, including State and local public health departments and
emergency management agencies.
- DOL/OSHA's Hazardous Waste Operations and Emergency Response Standard (HAZWOPER)
requires training for responders based on the anticipated roles they will play
during response to a hazardous substance release (see 29 CFR
1910.120(q)).
- DOL/OSHA works with other organizations that develop and fund responder
training to ensure their curricula are consistent in content and message for
each level of responder (skilled support, operations level, etc.) and that they
support the preparedness objectives listed in the National Incident Management
System (NIMS). These organizations include the Department of Homeland
Security/Office of State and Local Government Coordination and Preparedness (DHS/OSLGCP), the EPA (HAZWOPER/ Emergency Response Training Program), NIEHS,
organizations that develop related consensus standards, and other State and
local government programs.
Proactive Coordination of Technical Assets and Reach-back Capabilities: DOL/OSHA
and cooperating agencies develop and disseminate an inventory of expertise and
resources available for response to Incidents of National Significance, and
coordinate development of a strategy for their deployment.
Prevention Guidance Development and Distribution: DOL/OSHA coordinates with
cooperating agencies to develop and disseminate information on the likely
hazards associated with potential incidents and the preventive actions that can
be taken to reduce or eliminate illnesses and injuries that may result from
hazardous exposure.
Actions
The worker safety and health assets of DOL/OSHA and cooperating agencies support
the following actions at the headquarters, regional, and field levels by:
- Providing occupational safety and health technical advice and support to the JFO Safety Officer and Coordination Group, to the ICP Safety Officer(s) involved
in incident management, and, if appropriate, at all incident sites;
- Undertaking site-specific occupational safety and health plan development and
implementation, and ensuring that plans are coordinated and consistent among
multiple sites, as appropriate;
- Identifying and assessing health and safety hazards and characterizing the
incident environment, to include continued monitoring of incident safety on a
24/7 basis;
- Carrying out responder personal exposure monitoring, on a 24/7 basis,
including task- specific exposure monitoring for:
- Chemical and biological contaminants; and
- Physical stressors (e.g., noise, heat/cold, ionizing radiation);
- Providing responder medical surveillance and medical monitoring and, in
conjunction with HHS, evaluating the need for longer term epidemiological
medical monitoring and surveillance of responders;
- Assessing responder safety and health resource needs and identifying sources
for those assets;
- Developing, implementing, and monitoring an incident personal protective
equipment (PPE) program, including the selection, use, and decontamination of
PPE; implementation of a respiratory protection fit-test program; and
distribution of PPE;
- Collecting and managing data (exposure data, accident/injury documentation,
etc.) to facilitate consistent data-formatting and data-sharing among response
organizations;
- Communicating with labor unions, contractors, and other organizations
regarding responder safety and health issues;
- Coordinating and providing incident-specific responder training;
- Providing psychological first aid during and after incident response and
recovery activities; and
- Identifying, in coordination with HHS, appropriate immunization and
prophylaxis for responders and recovery workers.
As the coordinator for the Worker Safety and Health
Support Annex, DOL/OSHA facilitates resolution of
any technical or other disputes among cooperating agencies regarding the actions
described above. In the case of a dispute that cannot be resolved, DOL/OSHA
summarizes the disputed areas for presentation to the JFO Safety Coordinator/ICP
Safety Officer and, if necessary, the JFO Coordination Group for resolution.
After Action
DOL/OSHA facilitates a critique of operations to compile "lessons learned"
related to responder safety and health issues.
Responsibilities
Coordinating Agency: DOL/OSHA
- DOL/OSHA, as annex coordinator and worker health and safety coordinator,
assists the JFO Safety Coordinator/ICP Safety Officer by providing and
coordinating technical support for responder safety and health.
- DOL/OSHA resolves technical, procedural, and risk assessment conflicts, if
necessary through formal recourse to the JFO Safety Coordinator/ICP Safety
Officer or JFO Coordination Group, before they adversely
affect the consistency and accuracy of the advice and information provided to
responders, response organizations, and the JFO Coordination Group.
- DOL/OSHA is responsible for carrying out the policies identified in this
annex.
- DOL/OSHA implements a system to capture and manage incident exposure data in a
centralized location to enable data-sharing among agencies with a responder
health and safety focus.
Cooperating Agencies
Agency |
Responsibilities |
|
|
Department of Defense/U.S. Army Corps of Engineers
(DOD/USACE) |
- When USACE is mission assigned to provide ice, water, emergency power, debris
removal, temporary housing, temporary roofing, or structural safety assessment,
it deploys Safety and Occupational Health (SOH) professionals to the incident
location to provide technical assistance to USACE assets.
- USACE SOH professionals coordinate with DOL/OSHA and other annex cooperating
agencies to ensure the implementation of coordinated, effective worker safety
and health activities in support of the Incident Command System as established
in the NIMS.
- USACE provides emergency location SOH support through utilization of its
worldwide SOH Functional Planning and Response Teams.
|
Department of Energy
(DOE) |
Functions pertaining to DOE are identified in ESF #12 --Energy and other
applicable NRP annexes.
|
Department of Health and
Human Services |
National Institute for Occupational Safety and Health (NIOSH)
HHS/NIOSH provides
technical support and expertise in the characterization of complex, unknown, and
multiple-contaminant worker exposures.
HHS/NIOSH and DOL/OSHA collaborate in all areas and ensure that their collective
safety and industrial hygiene assets are aligned to produce consistent, vetted
advice to the incident command structure.
Agency for Toxic Substances and Disease Registry (ATSDR)
Under the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), section 104(i) [42 U.S.C. 9604(i)], HHS/ATSDR is required to cooperate
with HHS/NIOSH and DOL/OSHA to provide information and technical support on: the
toxic effects of chemicals based on peer-reviewed studies; emergency medical
management information specific to potential exposures; worker protective
measures, including selection of appropriate respiratory protection and chemical
protective clothing; action levels to upgrade the protective ensemble; and
appropriate means of monitoring hazards during response actions as defined in
CERCLA.
National Institute of Environmental Health Sciences
The Superfund Amendments and Reauthorization Act of 1986 (Title 42 U.S.C.
section 9660a) established, under section 126(g), the WETP as an assistance
program for the training and education of workers engaged in activities related
to hazardous waste removal, containment, and emergency response. The program is
managed by HHS/NIEHS and provides:
- Training technical assistance such as instructional staff, curriculum-
development experts, subject-matter experts, and professional staff.
- Safety training to worker target populations with respect to the nature and
location of the incident and the particular hazards.
- Assistance and support in the development and delivery of site-specific health
and safety training through appropriately qualified WETP awardee instructional
staff.
- Assistance such as respirator fit-testing and distribution of PPE.
|
Department of Homeland
Security |
U.S. Coast Guard (USCG)
Functions performed by DHS/USCG are identified in ESF #10 -- Oil and
Hazardous Materials Response and other applicable annexes.
Emergency Preparedness and Response/Federal Emergency Management
Agency (EPR/FEMA)
Functions pertaining to DHS/EPR/FEMA are identified in ESF #5 -- Emergency
Management and other applicable annexes. |
Environmental Protection
Agency |
Functions performed by EPA are identified in the ESF #10
-- Oil and Hazardous
Materials Response Annex, the Nuclear/Radiological Incident Annex, other
applicable NRP annexes, and the NCP. |
Other Responding
Organizations
|
Other Federal, State, local, and tribal government agencies, as well as private-
sector organizations with responders at the incident location, provide technical
support and expertise in accordance with their agency's mission and
responsibilities, in coordination with DOL/OSHA and annex cooperating agencies.
Organizations lacking safety and occupational health technical expertise are
expected to provide liaisons to the JFO Coordination Group safety staff, attend
appropriate safety briefings, identify issues regarding potential hazards, and
communicate those issues to their responder personnel and to the JFO Safety
Coordinator/ICP Safety Officer. |
|