Elements of a Site Health and Safety Plan for Contaminant-Related Activities

242 FW 6
Exhibit 2, FWM 171, 02/22/95
Originating Office
Safety Operations
The Project Leader is responsible for ensuring that the appropriate staff member prepares a site health and safety plan specific to contaminant-related activities on Service lands. Following are the minimum elements required:
I. Background - A listing and discussion of contaminants and their associated safety and health implications.

II. Site Characterization

A. Identify list of contaminants and their concentrations. Site staff will work with Engineering, who will contract for a site characterization.

B. Identify modes of exposure to contaminants (i.e., inhalation, ingestion, dermal, etc.).

III. Site Control

A. Identify and mark perimeter on site map.

B. Identify existing geographic features, public utilities, and site improvements on site map.

C. Identify security measures to preclude unauthorized site access (e.g., fence, signs, site personnel patrols, etc.). Site control should be included in contractors’ contracts and must follow Federal regulations. Any necessary permits required by Federal or State governments must be obtained prior to beginning work.

D. Clearly define means of egress on the site map.

E. Clearly define emergency contact information:

(1) Identify primary and backup hospitals, routes to those hospitals, hospital phone numbers.

(2) Identify location of the nearest fire department and all medical services with associated phone numbers.

IV. Communications

A. Identify types and locations of on-site communications that are compatible with protective equipment used (e.g., 2-way radios, cell phones, hand signals, etc.).

B. Communication instructions to contact potential responders.

V. Site Work Zones

A. Exclusion Zone (contaminated).

(1) Area A.

     (i) Where atmospheres may be Immediately Dangerous to Life or Health (IDLH).

     (ii) Known atmospheres containing concentrations capable of being absorbed through the skin or eyes in toxic quantities.

(2) Area B.

     (i) Where atmospheric concentration of contaminant(s) is known and the concentration of contaminant(s) is greater than the protection factor for air-purifying respirators.

     (ii) Oxygen deficient (<19.5%) or oxygen enriched (>23.5%) atmospheres.

     (iii) Skin-absorbed contaminants are not present.

     (iv) Safeguards preclude splashing of individuals.

(3) Area C.

     (i) Air contaminant levels do not exceed the protection factors of air-purifying respirators.

     (ii) The contaminant is not known to be absorbed through the skin.

     (iii) A reliable history of prior entry exists without acute or chronic effects on personnel.

(4) Area D.

     (i) No known airborne health hazards present.

     (ii) This is the minimum protection area inside the exclusion zone.

B. Contamination Reduction Zone - Provides area to prevent transfer of contaminant(s) from the Exclusion Zone to the Clean Zone.

C. Support/Clean Zone - The outer area, considered to be clear of contamination.

D. Location of support facilities, criteria for selection.

(1) Compatibility with existing prevalent wind directions and associated factors.

(2) Ability to remove decontaminated material.

(3) Ability to limit the spread of contamination.

E. Methods and procedures for preventing the spread of contamination.

F. Access to existing roadways and any associated problems with access and egress to the site.

VI. Contaminant Monitoring (airborne) - Personnel and general area monitoring (identify contractor performing monitoring).

VII. Personnel Protection

A. Determine necessary personal protective equipment (PPE) for each contaminated zone.

B. An Occupational Health Professional’s (OSH) evaluation of employees' ability to wear PPE.

C. Provide a written PPE document that includes the following:

(1) Training specific to each piece of PPE.

(2) Instructions on proper cleaning, repair, and storage of equipment.

(3) Procedures for equipment decontamination.

(4) Proper fitting and limitations.

VIII. Medical Surveillance

A. Identify medical provider (must be a licensed physician).

B. Identify those tasks requiring medical monitoring and refer to 242 FW 4, Medical Programs.

C. Maintain medical documentation in accordance with 29 CFR 1910.120(f)(8) and 1910.1020.

IX. Decontamination

A. Identify personal decontamination procedures.

B. Identify equipment decontamination procedures (to include PPE).

C. Scrap decontamination procedures (scrap means expendable materials used in the mitigation or evaluation process, such as disposable containers, clothing, and plastic sheeting).

X. Emergency Procedures

A.  Identify location of first aid kits, fire extinguishers, telephone contact list, and eye wash units.

B. Chemical exposure.

C. Biologic exposure (ticks, mosquitos, snakes, etc.).

D. Radiation.

E. Personal injury.

F. Potential or actual fire or explosion.

G. Environmental accident.

XI. Training

A. Clearly identify training plan, including refresher training.

B. Training requirements for contractor personnel.