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Model Health & Safety Plan (HASP) for Clean-up of
Facilities Contaminated with Anthrax Spores
I. Introduction
This HASP template was prepared by OSHA and funded by EPA. It
provides model language that is acceptable to OSHA in meeting the
requirements of OSHA's Hazardous Waste Operations and Emergency
Response (HAZWOPER) Standard, 29 CFR 1910.120 or 29 CFR 1926.65,
paragraph (b)(4). That paragraph requires a site-specific safety
and health plan for clean-up operations conducted under HAZWOPER.
Qualified health and safety professionals can use the
accompanying files to create a site-specific health and safety
plan for cleanup of facilities recently contaminated with anthrax
spores through bio-terrorism. If these files are completed
accurately and thoroughly, and the resulting HASP is fully
implemented at the anthrax-decontamination project site, the
employer is likely to have a site health and safety program that
effectively protects employee health and safety. The files are
available as compressed (zipped) Word 6.0/95 document files. They
can be opened by most modern word-processing software.
There are 13 HASP chapters included here, one for each of the
required elements listed in paragraph (b)(4) of HAZWOPER. Eleven
of these are full-text chapters (1-11 below), and two are
place-holder chapters where you will insert information from
other sources (12 & 13). The chapters include:
- Organizational
Structure [ZIP 7KB]
- Site Characterization and Job Hazard
Analysis [ZIP 7KB]
- Site Control [ZIP 8KB]
- Training [ZIP 7KB]
- Medical Surveillance [ZIP 9KB]
- PPE [ZIP 13 KB]
- Exposure Monitoring [ZIP 10KB]
- Heat Stress [ZIP 11KB]
- Spill Containment [ZIP 6KB]
- Decontamination [ZIP 8KB]
- Emergency Response [ZIP 12KB]
- Standard Operating Procedures (SOPs) [ZIP 3KB]:
placeholder chapter for SOPs not included in other chapters
- Confined Spaces [ZIP 3KB]:
placeholder chapter for written confined space entry procedures.
If you need assistance preparing such procedures, see
OSHA's e-tools webpage.
A brief safety data sheet for anthrax [ZIP 5KB] is also
included. To date, there is no established exposure limit for
anthrax spores. Therefore, exposure should be kept to a
minimum.
These files are also available in an ALL-In-One [ZIP 100KB].
II. Specific Instructions for Completing the HASP
These chapters are word processing documents that can be
completed by filling in site-specific information. Technical
health and safety decisions are required to complete this HASP,
just as the preparation of any HASP would require. For this
reason, OSHA recommends that only qualified health and safety
professionals be used as HASP preparers.
Instructions are included in each chapter to guide the HASP
preparer in completing site-specific text. These instructions are
in the form of optional text, help text, pick lists, "insert"
instructions, and "add/delete/edit" instructions. Each of these
is described more fully below.
- Optional Text: Optional text provides different
versions of chapter language depending on specific site
circumstances. For example, chapter text for a site that relies
on its own employees for emergency response will be different
than a site that relies on an outside organization such as a
local fire department. The instructions for optional text appear
as bold text.
- Help Text: Help text is included to help the HASP
preparer make key decisions. For example, help text provides the
definition of a permit-required confined space to assist the
preparer in determining whether permit spaces exist at the site.
Help text appears as italicized text in brackets.
- Pick Lists: Pick lists provide a selection of items to
help complete a table. For example, a pick list of exposure
monitoring instruments will provide the preparer a list of
possible instruments to choose from. Pick lists are only
suggestions; the preparer must complete each table accurately
based on equipment and procedures actually used at the site. In
chapter text, a note signifies that there is a pick list
associated with the applicable paragraph. The pick lists appear
at the end of chapters.
- "Insert" Instructions: Insert instructions tell the
preparer to insert a required figure or map. For example, the
preparer must insert a map showing the site zone boundaries.
Insert instructions typically appear at the top of a blank page
where a map or figure needs to be inserted.
- "Add/Delete/Edit" Instructions: Add/delete/edit
instructions generally appear before chapter SOPs in bold text
and instruct the preparer to add, delete, or edit SOPs as
appropriate for the site.
To get the maximum benefit from this HASP, OSHA
recommends the following:
- Complete the chapters in order, or at a minimum, complete
Chapter 2 before completing Chapters 3-15. This is important
since the site characterization/job hazard analyses in Chapter 2
are the basis for the protective measures selected in the
remaining chapters.
- Do not edit or delete text except where indicated in order to
retain the HAZWOPER provisions intentionally included in these
files.
- Provide the information requested. The chapter text is
designed to prompt you for information that needs to be planned
and determined before site activities begin.
- Insert personnel names wherever indicated in order to assign
responsibility for the specific task discussed.
- Implement the written program that results from your
site-specific input.
- If you have questions about how to choose effective control
measures for your anthrax facility decontamination project and/or
how to comply with the provisions included in this HASP, seek
OSHA's assistance. We recognize that there are no established
methods for clean-up of facilities contaminated with
weapons-grade anthrax spores. For help in planning and
implementing effective clean-up operations, please contact your
OSHA Area Office.
III. Attachments to the HASP
You may need additional written programs, plans, or procedures
to meet the requirements of other applicable OSHA standards. For
example, employees will likely use respiratory protection during
facility decontamination/clean-up so you will need to have a
written Respiratory Protection Program consistent with 29 CFR
1910.134.
It is also likely that you will need to address the control of
hazardous energy, consistent with OSHA's lockout/tagout standard,
29 CFR 1910.147.
OSHA's e-tools webpage mentioned above, also offers software
to help employers prepare written lockout-tagout procedures.
Examples of written programs, plans, or procedures that may be
necessary as a result of health or safety hazards associated with
facility decontamination/clean-up operations include but are not
limited to:
- Hearing Conservation Program
- Respiratory Protection Program (noted above)
- Exposure Control Plan (Bloodborne Pathogens)
- Lockout/Tagout Procedures (noted above)
- Hazard Communication Program
- Substance-Specific Compliance Program (for expanded health
standards in 1910.1001-1910.1096)
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