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See attached **files (2)** – ## OSHA2303UnitVDB.docx – ## UnitVStudyGuide.pdf **## OSHA2303UnitVDB.docx** OSHA 2303 Unit V DB Assignment Instructions: Imagine that you are involved with a hazardous material spill response or cleanup operation. Describe a cleanup or response plan that you might put i…
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See attached
**files (2)**
– ## OSHA2303UnitVDB.docx
– ## UnitVStudyGuide.pdf
**## OSHA2303UnitVDB.docx**
OSHA 2303 Unit V DB
Assignment Instructions:
Imagine that you are involved with a hazardous material spill response or cleanup operation. Describe a cleanup or response plan that you might put into place and describe what you believe would be your role in it.
Reply 1:
**Amy Costello**
Top of Form
The hazardous-materials response scenario most closely related to my work would be responding to a chemical spill in a K–12 science laboratory. As part of my role supporting school districts, I help develop and maintain Chemical Hygiene Plans and Hazard Communication Programs and provide training on hazard recognition, risk assessment, emergency preparedness, and chemical spill response.
If a chemical spill occurred in a science classroom, my response plan would begin with ensuring the safety of students and staff. The first step would be to stop the activity, isolate the area, and assess the spill to determine whether it is a minor spill that trained staff can safely manage or a major spill requiring evacuation and emergency response. Factors such as the type and quantity of the chemical, potential exposure hazards, fire risk, and whether anyone was injured or exposed would be considered. Safety Data Sheets (SDS) would be reviewed to identify chemical hazards, required PPE, and appropriate spill response procedures.
My role would likely be that of a safety advisor and Chemical Hygiene Plan resource rather than the person performing the cleanup. I would assist school staff in evaluating hazards, determining appropriate response actions, coordinating communication with administration and emergency responders as needed, and ensuring proper procedures are followed. I would also help confirm that the necessary PPE, spill kits, and emergency equipment are available and used correctly.
After the incident, I would support the district in documenting the event, reviewing root causes, evaluating whether existing controls were effective, and identifying opportunities to prevent a similar incident in the future. This could include updating procedures, improving employee training, modifying chemical storage practices, or substituting less hazardous chemicals when possible.
Bottom of Form
**## UnitVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Compare risk assessments of two hazardous materials at a workplace.
5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a
spill response program.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 59–79
In order to access the following resources, click the links below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Read pages 30–36 in the resource below.
Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency
response (OSHA Document No. 3114-07R). U.S. Department of Labor.
https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf
The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an
excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations.
National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Emergency service personnel can face many unique and dangerous situations, many of which may be
unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations
and best practices for protecting these workers.
Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders
during treatment and transport of victims of hazardous substance releases (OSHA Document No.
3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS-
respondersSM.pdf
Unit Lesson
Occupational Safety and Health Administration’s
Hazardous Waste Operations and Emergency Response Regulation
The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency
Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites;
certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous
material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency
UNIT V STUDY GUIDE
Establishing and Maintaining a
Hazardous Spill Response Program
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf](https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
responses to hazardous materials, which are covered in section (q) of the standard. The first step in
compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by
OSHA to be included in the EAP:
• pre-emergency planning and coordination with outside parties;
• personnel roles, lines of authority, training, and communication;
• emergency recognition and prevention;
• safe distances and places of refuge;
• site security and control;
• evacuation routes and procedures;
• decontamination;
• emergency medical treatment procedures;
• emergency alerting and response procedures;
• critiques of response and follow-up; and
• PPE and emergency equipment (OSHA, 1970).
Hazard Assessment
As you can see, developing a written EAP is quite
detailed and takes time. One project that must be
performed prior to developing the EAP is determining
what hazardous materials may be present that would
require an emergency spill response. The first step is
typically conducting a hazard assessment. This process
is used to identify the hazardous materials you have
present at a site as well as the hazardous materials that
are generated by the processes in your workplace.
Remember that hazardous wastes are simply hazardous
materials that are discarded. The presumption here is
that you understand the various definitions of hazardous
material. If not, the Environmental Protection Agency
(EPA), OSHA, and the U.S. Department of
Transportation (DOT) require the publishing of definitions
and lists of substances that are considered hazardous.
Perhaps the best source of information about any
chemical is its safety data sheet (SDS).
The term that is generally applied to the process of
identifying hazards in a workplace is a job hazard
analysis (JHA). The process is important enough that
OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to
use a specific method to identify hazards in the workplace. While there are many commercially available
programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a
Two airmen inventory hazardous materials.
(Wright, 2009)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
checklist to detail steps required for processes performed at a workplace, and then determine which hazards
are associated with each step. An example of a JHA worksheet from the booklet is shown below.
Once you know what hazards are present in the workplace, you can determine what would happen if any of
these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be
adverse effects on people, property, or the environment? You then need to decide the probability of that spill
or release happening. This process is commonly called a risk assessment. The risk assessment process can
be used to rate the risks associated with hazardous materials at a workplace. This information can be
valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to
require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to
be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix.
There are many risk assessment matrices available. The matrix below was created just for this lesson.
Probability Very
Likely
Likely Possible Unlikely Very
Unlikely
Severity
Rating
Health
Outcome
5 4 3 2 1
5 Death or
Permanent
Total
Disability
25 20 15 10 5
4 Permanent
or Partial
Disability
20 16 12 8 4
3 Injury or
Illness
With Lost
Workdays
15 12 9 6 3
2 Injury or
Illness
With No
Lost
Workdays
10 8 6 4 2
1 First Aid
Only or No
Treatment
5 4 3 2 1
(OSHA, 2002)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of
hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space.
The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25,
while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two
releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks
associated with the release of compounds that are more similar in toxicity.
Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This
model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and
needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will
help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill
and the probability of such an event happening). The model uses the following seven events:
1. stressing event occurs (thermal, chemical, mechanical, human);
2. container breach occurs (detonating, rapid release, leak);
3. hazardous materials or energy escapes;
4. hazardous material engulfs danger zone (dispersion, path, pattern, distance);
5. hazardous material or energy impinges on receptors (transient, lingering, permanent);
6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);
and
7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).
Much of the information required for any risk assessment can be obtained from the SDS for that material or
the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could
result in a release. The model can also point to preventative measures.
Another extremely important part of the EAP is to determine which personnel need to be trained on their
responsibilities under the plan and how much training is required. Personnel who are expected to respond to
a spill must have training, but do
not forget that there may be
employees whose job in an
emergency is to simply evacuate
safely. Do they know when, how,
and where to evacuate? This
training also needs to be
conducted.
For the first responders, those
responsible for cleanup, and
those directing the response and
cleanup operations, various
levels of training are prescribed
in OSHA’s HAZWOPER
Standard 29 Code of Federal
Regulations (CFR)
§1910.120(q). Be sure to check
with state and local agencies for
additional requirements. The
different levels of response and
the duration of the initial training
for each level are summarized below.
Response Level Initial Training Duration
First Responder Awareness Not Specified (Sufficient Training)
First Responder Operations 8 Hours
Hazardous Materials Technician 24 Hours
Hazardous Materials Specialist 24 + Specialty Training
On-Scene Incident Commander 24 Hours + ICS Training
(OSHA, 1970)
Emergency response exercise held in Nevada
(National Nuclear Security Administration, n.d.)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Each of the training classes is required to cover specific rubrics designed to allow the responders to perform
their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The
regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of
the training. Workers in each of the categories must also have annual refresher training or demonstrate
competency in each rubric area again. The regulation does not specify the length of the annual refresher
training but says the training must provide enough content and last long enough so the workers can maintain
their competency. Annual refresher training has traditionally been 8 hours in length.
Another important step is to make sure that the correct equipment (including PPE) is present at the site. A
spill response plan will not be effective if the PPE and other equipment available to responders is inadequate.
The type and levels of equipment and PPE will vary depending on the hazardous materials that are present
and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials
(e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of
meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of
protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements
and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully
encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause
serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the
Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection
requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29
CFR §1910.134.
The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs
and then everyone frantically tries to remember who is supposed to do what, although this is often the case.
Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and
simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the
most effective response. When determining the best frequency for undertaking these exercises, consider that
personnel and situations change often. Sports teams practice between games, right? Considering the
dangers inherent in spill response, your team deserves no less.
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).
U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf
Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
In a previous unit, you were introduced to the software program that the Occupational Safety and Health
Administration (OSHA) published to assist employers with developing a health and safety program. The
software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0
webpage.
If you did not already, download the software, and review the chapters on the emergency response plan and
decontamination. Compare the guidelines in the software to the company where you currently work or a
location with which you are familiar. How does the response plan at the company compare with the guidelines
in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write
your thoughts down in a personal journal.
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation
– Hazard Assessment
– References
– Learning Activities (Nongraded)
**## UnitVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Compare risk assessments of two hazardous materials at a workplace.
5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a
spill response program.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 59–79
In order to access the following resources, click the links below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Read pages 30–36 in the resource below.
Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency
response (OSHA Document No. 3114-07R). U.S. Department of Labor.
https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf
The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an
excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations.
National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Emergency service personnel can face many unique and dangerous situations, many of which may be
unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations
and best practices for protecting these workers.
Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders
during treatment and transport of victims of hazardous substance releases (OSHA Document No.
3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS-
respondersSM.pdf
Unit Lesson
Occupational Safety and Health Administration’s
Hazardous Waste Operations and Emergency Response Regulation
The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency
Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites;
certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous
material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency
UNIT V STUDY GUIDE
Establishing and Maintaining a
Hazardous Spill Response Program
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf](https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
responses to hazardous materials, which are covered in section (q) of the standard. The first step in
compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by
OSHA to be included in the EAP:
• pre-emergency planning and coordination with outside parties;
• personnel roles, lines of authority, training, and communication;
• emergency recognition and prevention;
• safe distances and places of refuge;
• site security and control;
• evacuation routes and procedures;
• decontamination;
• emergency medical treatment procedures;
• emergency alerting and response procedures;
• critiques of response and follow-up; and
• PPE and emergency equipment (OSHA, 1970).
Hazard Assessment
As you can see, developing a written EAP is quite
detailed and takes time. One project that must be
performed prior to developing the EAP is determining
what hazardous materials may be present that would
require an emergency spill response. The first step is
typically conducting a hazard assessment. This process
is used to identify the hazardous materials you have
present at a site as well as the hazardous materials that
are generated by the processes in your workplace.
Remember that hazardous wastes are simply hazardous
materials that are discarded. The presumption here is
that you understand the various definitions of hazardous
material. If not, the Environmental Protection Agency
(EPA), OSHA, and the U.S. Department of
Transportation (DOT) require the publishing of definitions
and lists of substances that are considered hazardous.
Perhaps the best source of information about any
chemical is its safety data sheet (SDS).
The term that is generally applied to the process of
identifying hazards in a workplace is a job hazard
analysis (JHA). The process is important enough that
OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to
use a specific method to identify hazards in the workplace. While there are many commercially available
programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a
Two airmen inventory hazardous materials.
(Wright, 2009)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
checklist to detail steps required for processes performed at a workplace, and then determine which hazards
are associated with each step. An example of a JHA worksheet from the booklet is shown below.
Once you know what hazards are present in the workplace, you can determine what would happen if any of
these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be
adverse effects on people, property, or the environment? You then need to decide the probability of that spill
or release happening. This process is commonly called a risk assessment. The risk assessment process can
be used to rate the risks associated with hazardous materials at a workplace. This information can be
valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to
require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to
be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix.
There are many risk assessment matrices available. The matrix below was created just for this lesson.
Probability Very
Likely
Likely Possible Unlikely Very
Unlikely
Severity
Rating
Health
Outcome
5 4 3 2 1
5 Death or
Permanent
Total
Disability
25 20 15 10 5
4 Permanent
or Partial
Disability
20 16 12 8 4
3 Injury or
Illness
With Lost
Workdays
15 12 9 6 3
2 Injury or
Illness
With No
Lost
Workdays
10 8 6 4 2
1 First Aid
Only or No
Treatment
5 4 3 2 1
(OSHA, 2002)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of
hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space.
The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25,
while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two
releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks
associated with the release of compounds that are more similar in toxicity.
Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This
model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and
needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will
help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill
and the probability of such an event happening). The model uses the following seven events:
1. stressing event occurs (thermal, chemical, mechanical, human);
2. container breach occurs (detonating, rapid release, leak);
3. hazardous materials or energy escapes;
4. hazardous material engulfs danger zone (dispersion, path, pattern, distance);
5. hazardous material or energy impinges on receptors (transient, lingering, permanent);
6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);
and
7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).
Much of the information required for any risk assessment can be obtained from the SDS for that material or
the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could
result in a release. The model can also point to preventative measures.
Another extremely important part of the EAP is to determine which personnel need to be trained on their
responsibilities under the plan and how much training is required. Personnel who are expected to respond to
a spill must have training, but do
not forget that there may be
employees whose job in an
emergency is to simply evacuate
safely. Do they know when, how,
and where to evacuate? This
training also needs to be
conducted.
For the first responders, those
responsible for cleanup, and
those directing the response and
cleanup operations, various
levels of training are prescribed
in OSHA’s HAZWOPER
Standard 29 Code of Federal
Regulations (CFR)
§1910.120(q). Be sure to check
with state and local agencies for
additional requirements. The
different levels of response and
the duration of the initial training
for each level are summarized below.
Response Level Initial Training Duration
First Responder Awareness Not Specified (Sufficient Training)
First Responder Operations 8 Hours
Hazardous Materials Technician 24 Hours
Hazardous Materials Specialist 24 + Specialty Training
On-Scene Incident Commander 24 Hours + ICS Training
(OSHA, 1970)
Emergency response exercise held in Nevada
(National Nuclear Security Administration, n.d.)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Each of the training classes is required to cover specific rubrics designed to allow the responders to perform
their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The
regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of
the training. Workers in each of the categories must also have annual refresher training or demonstrate
competency in each rubric area again. The regulation does not specify the length of the annual refresher
training but says the training must provide enough content and last long enough so the workers can maintain
their competency. Annual refresher training has traditionally been 8 hours in length.
Another important step is to make sure that the correct equipment (including PPE) is present at the site. A
spill response plan will not be effective if the PPE and other equipment available to responders is inadequate.
The type and levels of equipment and PPE will vary depending on the hazardous materials that are present
and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials
(e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of
meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of
protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements
and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully
encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause
serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the
Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection
requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29
CFR §1910.134.
The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs
and then everyone frantically tries to remember who is supposed to do what, although this is often the case.
Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and
simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the
most effective response. When determining the best frequency for undertaking these exercises, consider that
personnel and situations change often. Sports teams practice between games, right? Considering the
dangers inherent in spill response, your team deserves no less.
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).
U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf
Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
In a previous unit, you were introduced to the software program that the Occupational Safety and Health
Administration (OSHA) published to assist employers with developing a health and safety program. The
software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0
webpage.
If you did not already, download the software, and review the chapters on the emergency response plan and
decontamination. Compare the guidelines in the software to the company where you currently work or a
location with which you are familiar. How does the response plan at the company compare with the guidelines
in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write
your thoughts down in a personal journal.
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation
– Hazard Assessment
– References
– Learning Activities (Nongraded)
**## OSHA2303UnitVDB.docx**
OSHA 2303 Unit V DB
Assignment Instructions:
Imagine that you are involved with a hazardous material spill response or cleanup operation. Describe a cleanup or response plan that you might put into place and describe what you believe would be your role in it.
Reply 1:
**Amy Costello**
Top of Form
The hazardous-materials response scenario most closely related to my work would be responding to a chemical spill in a K–12 science laboratory. As part of my role supporting school districts, I help develop and maintain Chemical Hygiene Plans and Hazard Communication Programs and provide training on hazard recognition, risk assessment, emergency preparedness, and chemical spill response.
If a chemical spill occurred in a science classroom, my response plan would begin with ensuring the safety of students and staff. The first step would be to stop the activity, isolate the area, and assess the spill to determine whether it is a minor spill that trained staff can safely manage or a major spill requiring evacuation and emergency response. Factors such as the type and quantity of the chemical, potential exposure hazards, fire risk, and whether anyone was injured or exposed would be considered. Safety Data Sheets (SDS) would be reviewed to identify chemical hazards, required PPE, and appropriate spill response procedures.
My role would likely be that of a safety advisor and Chemical Hygiene Plan resource rather than the person performing the cleanup. I would assist school staff in evaluating hazards, determining appropriate response actions, coordinating communication with administration and emergency responders as needed, and ensuring proper procedures are followed. I would also help confirm that the necessary PPE, spill kits, and emergency equipment are available and used correctly.
After the incident, I would support the district in documenting the event, reviewing root causes, evaluating whether existing controls were effective, and identifying opportunities to prevent a similar incident in the future. This could include updating procedures, improving employee training, modifying chemical storage practices, or substituting less hazardous chemicals when possible.
Bottom of Form
**## UnitVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Compare risk assessments of two hazardous materials at a workplace.
5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a
spill response program.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 59–79
In order to access the following resources, click the links below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Read pages 30–36 in the resource below.
Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency
response (OSHA Document No. 3114-07R). U.S. Department of Labor.
https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf
The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an
excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations.
National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Emergency service personnel can face many unique and dangerous situations, many of which may be
unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations
and best practices for protecting these workers.
Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders
during treatment and transport of victims of hazardous substance releases (OSHA Document No.
3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS-
respondersSM.pdf
Unit Lesson
Occupational Safety and Health Administration’s
Hazardous Waste Operations and Emergency Response Regulation
The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency
Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites;
certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous
material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency
UNIT V STUDY GUIDE
Establishing and Maintaining a
Hazardous Spill Response Program
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf](https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
responses to hazardous materials, which are covered in section (q) of the standard. The first step in
compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by
OSHA to be included in the EAP:
• pre-emergency planning and coordination with outside parties;
• personnel roles, lines of authority, training, and communication;
• emergency recognition and prevention;
• safe distances and places of refuge;
• site security and control;
• evacuation routes and procedures;
• decontamination;
• emergency medical treatment procedures;
• emergency alerting and response procedures;
• critiques of response and follow-up; and
• PPE and emergency equipment (OSHA, 1970).
Hazard Assessment
As you can see, developing a written EAP is quite
detailed and takes time. One project that must be
performed prior to developing the EAP is determining
what hazardous materials may be present that would
require an emergency spill response. The first step is
typically conducting a hazard assessment. This process
is used to identify the hazardous materials you have
present at a site as well as the hazardous materials that
are generated by the processes in your workplace.
Remember that hazardous wastes are simply hazardous
materials that are discarded. The presumption here is
that you understand the various definitions of hazardous
material. If not, the Environmental Protection Agency
(EPA), OSHA, and the U.S. Department of
Transportation (DOT) require the publishing of definitions
and lists of substances that are considered hazardous.
Perhaps the best source of information about any
chemical is its safety data sheet (SDS).
The term that is generally applied to the process of
identifying hazards in a workplace is a job hazard
analysis (JHA). The process is important enough that
OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to
use a specific method to identify hazards in the workplace. While there are many commercially available
programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a
Two airmen inventory hazardous materials.
(Wright, 2009)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
checklist to detail steps required for processes performed at a workplace, and then determine which hazards
are associated with each step. An example of a JHA worksheet from the booklet is shown below.
Once you know what hazards are present in the workplace, you can determine what would happen if any of
these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be
adverse effects on people, property, or the environment? You then need to decide the probability of that spill
or release happening. This process is commonly called a risk assessment. The risk assessment process can
be used to rate the risks associated with hazardous materials at a workplace. This information can be
valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to
require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to
be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix.
There are many risk assessment matrices available. The matrix below was created just for this lesson.
Probability Very
Likely
Likely Possible Unlikely Very
Unlikely
Severity
Rating
Health
Outcome
5 4 3 2 1
5 Death or
Permanent
Total
Disability
25 20 15 10 5
4 Permanent
or Partial
Disability
20 16 12 8 4
3 Injury or
Illness
With Lost
Workdays
15 12 9 6 3
2 Injury or
Illness
With No
Lost
Workdays
10 8 6 4 2
1 First Aid
Only or No
Treatment
5 4 3 2 1
(OSHA, 2002)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of
hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space.
The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25,
while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two
releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks
associated with the release of compounds that are more similar in toxicity.
Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This
model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and
needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will
help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill
and the probability of such an event happening). The model uses the following seven events:
1. stressing event occurs (thermal, chemical, mechanical, human);
2. container breach occurs (detonating, rapid release, leak);
3. hazardous materials or energy escapes;
4. hazardous material engulfs danger zone (dispersion, path, pattern, distance);
5. hazardous material or energy impinges on receptors (transient, lingering, permanent);
6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);
and
7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).
Much of the information required for any risk assessment can be obtained from the SDS for that material or
the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could
result in a release. The model can also point to preventative measures.
Another extremely important part of the EAP is to determine which personnel need to be trained on their
responsibilities under the plan and how much training is required. Personnel who are expected to respond to
a spill must have training, but do
not forget that there may be
employees whose job in an
emergency is to simply evacuate
safely. Do they know when, how,
and where to evacuate? This
training also needs to be
conducted.
For the first responders, those
responsible for cleanup, and
those directing the response and
cleanup operations, various
levels of training are prescribed
in OSHA’s HAZWOPER
Standard 29 Code of Federal
Regulations (CFR)
§1910.120(q). Be sure to check
with state and local agencies for
additional requirements. The
different levels of response and
the duration of the initial training
for each level are summarized below.
Response Level Initial Training Duration
First Responder Awareness Not Specified (Sufficient Training)
First Responder Operations 8 Hours
Hazardous Materials Technician 24 Hours
Hazardous Materials Specialist 24 + Specialty Training
On-Scene Incident Commander 24 Hours + ICS Training
(OSHA, 1970)
Emergency response exercise held in Nevada
(National Nuclear Security Administration, n.d.)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Each of the training classes is required to cover specific rubrics designed to allow the responders to perform
their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The
regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of
the training. Workers in each of the categories must also have annual refresher training or demonstrate
competency in each rubric area again. The regulation does not specify the length of the annual refresher
training but says the training must provide enough content and last long enough so the workers can maintain
their competency. Annual refresher training has traditionally been 8 hours in length.
Another important step is to make sure that the correct equipment (including PPE) is present at the site. A
spill response plan will not be effective if the PPE and other equipment available to responders is inadequate.
The type and levels of equipment and PPE will vary depending on the hazardous materials that are present
and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials
(e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of
meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of
protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements
and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully
encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause
serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the
Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection
requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29
CFR §1910.134.
The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs
and then everyone frantically tries to remember who is supposed to do what, although this is often the case.
Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and
simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the
most effective response. When determining the best frequency for undertaking these exercises, consider that
personnel and situations change often. Sports teams practice between games, right? Considering the
dangers inherent in spill response, your team deserves no less.
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).
U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf
Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
In a previous unit, you were introduced to the software program that the Occupational Safety and Health
Administration (OSHA) published to assist employers with developing a health and safety program. The
software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0
webpage.
If you did not already, download the software, and review the chapters on the emergency response plan and
decontamination. Compare the guidelines in the software to the company where you currently work or a
location with which you are familiar. How does the response plan at the company compare with the guidelines
in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write
your thoughts down in a personal journal.
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation
– Hazard Assessment
– References
– Learning Activities (Nongraded)
**## OSHA2303UnitVDB.docx**
OSHA 2303 Unit V DB
Assignment Instructions:
Imagine that you are involved with a hazardous material spill response or cleanup operation. Describe a cleanup or response plan that you might put into place and describe what you believe would be your role in it.
Reply 1:
**Amy Costello**
Top of Form
The hazardous-materials response scenario most closely related to my work would be responding to a chemical spill in a K–12 science laboratory. As part of my role supporting school districts, I help develop and maintain Chemical Hygiene Plans and Hazard Communication Programs and provide training on hazard recognition, risk assessment, emergency preparedness, and chemical spill response.
If a chemical spill occurred in a science classroom, my response plan would begin with ensuring the safety of students and staff. The first step would be to stop the activity, isolate the area, and assess the spill to determine whether it is a minor spill that trained staff can safely manage or a major spill requiring evacuation and emergency response. Factors such as the type and quantity of the chemical, potential exposure hazards, fire risk, and whether anyone was injured or exposed would be considered. Safety Data Sheets (SDS) would be reviewed to identify chemical hazards, required PPE, and appropriate spill response procedures.
My role would likely be that of a safety advisor and Chemical Hygiene Plan resource rather than the person performing the cleanup. I would assist school staff in evaluating hazards, determining appropriate response actions, coordinating communication with administration and emergency responders as needed, and ensuring proper procedures are followed. I would also help confirm that the necessary PPE, spill kits, and emergency equipment are available and used correctly.
After the incident, I would support the district in documenting the event, reviewing root causes, evaluating whether existing controls were effective, and identifying opportunities to prevent a similar incident in the future. This could include updating procedures, improving employee training, modifying chemical storage practices, or substituting less hazardous chemicals when possible.
Bottom of Form
**## UnitVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Compare risk assessments of two hazardous materials at a workplace.
5.2 Select the appropriate equipment and personal protective equipment (PPE) for establishing a
spill response program.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 59–79
In order to access the following resources, click the links below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Read pages 30–36 in the resource below.
Occupational Safety and Health Administration. (2008). Hazardous waste operations and emergency
response (OSHA Document No. 3114-07R). U.S. Department of Labor.
https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf
The National Response Team’s publication Hazardous Materials Emergency Response Planning Guide is an
excellent resource for helping ensure that your plans and procedures comply with the myriad of regulations.
National Response Team. (2001, July). Hazardous materials emergency planning guide. U.S. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Emergency service personnel can face many unique and dangerous situations, many of which may be
unanticipated. The Occupational Safety and Health Administration (OSHA) has summarized the regulations
and best practices for protecting these workers.
Occupational Safety and Health Administration. (2009). Best practices for protecting emergency responders
during treatment and transport of victims of hazardous substance releases (OSHA Document No.
3370-11). U.S. Department of Labor. https://www.osha.gov/Publications/OSHA3370-protecting-EMS-
respondersSM.pdf
Unit Lesson
Occupational Safety and Health Administration’s
Hazardous Waste Operations and Emergency Response Regulation
The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency
Response (HAZWOPER) regulation covers three basic operations: operations at hazardous waste sites;
certain operations at treatment, storage, and disposition facilities; and emergency responses to hazardous
material releases no matter where they occur (OSHA, 1970). For this lesson, we will focus on emergency
UNIT V STUDY GUIDE
Establishing and Maintaining a
Hazardous Spill Response Program
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB](https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200AppB)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf](https://www.osha.gov/sites/default/files/publications/OSHA-3114-hazwoper.pdf)
[https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf](https://www.epa.gov/sites/production/files/2014-09/documents/cleannrt10_12_distiller_complete.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
[https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf](https://www.osha.gov/Publications/OSHA3370-protecting-EMS-respondersSM.pdf)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
responses to hazardous materials, which are covered in section (q) of the standard. The first step in
compliance is to develop a written emergency action plan (EAP). The elements listed below are specified by
OSHA to be included in the EAP:
• pre-emergency planning and coordination with outside parties;
• personnel roles, lines of authority, training, and communication;
• emergency recognition and prevention;
• safe distances and places of refuge;
• site security and control;
• evacuation routes and procedures;
• decontamination;
• emergency medical treatment procedures;
• emergency alerting and response procedures;
• critiques of response and follow-up; and
• PPE and emergency equipment (OSHA, 1970).
Hazard Assessment
As you can see, developing a written EAP is quite
detailed and takes time. One project that must be
performed prior to developing the EAP is determining
what hazardous materials may be present that would
require an emergency spill response. The first step is
typically conducting a hazard assessment. This process
is used to identify the hazardous materials you have
present at a site as well as the hazardous materials that
are generated by the processes in your workplace.
Remember that hazardous wastes are simply hazardous
materials that are discarded. The presumption here is
that you understand the various definitions of hazardous
material. If not, the Environmental Protection Agency
(EPA), OSHA, and the U.S. Department of
Transportation (DOT) require the publishing of definitions
and lists of substances that are considered hazardous.
Perhaps the best source of information about any
chemical is its safety data sheet (SDS).
The term that is generally applied to the process of
identifying hazards in a workplace is a job hazard
analysis (JHA). The process is important enough that
OSHA published a booklet specifically outlining the process (OSHA, 2002). OSHA does not require you to
use a specific method to identify hazards in the workplace. While there are many commercially available
programs that can be used to perform a JHA, the OSHA booklet uses one of the simplest methods: Use a
Two airmen inventory hazardous materials.
(Wright, 2009)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
checklist to detail steps required for processes performed at a workplace, and then determine which hazards
are associated with each step. An example of a JHA worksheet from the booklet is shown below.
Once you know what hazards are present in the workplace, you can determine what would happen if any of
these materials were spilled or released into the environment (i.e., the air, water, or soil). Would there be
adverse effects on people, property, or the environment? You then need to decide the probability of that spill
or release happening. This process is commonly called a risk assessment. The risk assessment process can
be used to rate the risks associated with hazardous materials at a workplace. This information can be
valuable when developing a written EAP. Hazardous materials with higher risks would be more likely to
require full spill responses with enhanced PPE. As with the JHA, OSHA does not specify a method that has to
be used to perform a risk assessment. Many safety practitioners use a risk assessment matrix.
There are many risk assessment matrices available. The matrix below was created just for this lesson.
Probability Very
Likely
Likely Possible Unlikely Very
Unlikely
Severity
Rating
Health
Outcome
5 4 3 2 1
5 Death or
Permanent
Total
Disability
25 20 15 10 5
4 Permanent
or Partial
Disability
20 16 12 8 4
3 Injury or
Illness
With Lost
Workdays
15 12 9 6 3
2 Injury or
Illness
With No
Lost
Workdays
10 8 6 4 2
1 First Aid
Only or No
Treatment
5 4 3 2 1
(OSHA, 2002)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
An example of how you might use the matrix would be comparing the risk of the release of 1,000 gallons of
hydrogen cyanide gas into a space and the release of 1,000 gallons of 10W30 motor oil into the same space.
The risk assessment score for the hydrogen cyanide release would be at the top of the scale, probably 25,
while the release of the motor oil would be at the low end of the scale, probably 1 or 2. While these two
releases have very easily identified differences in risk, the same procedure can be used to evaluate the risks
associated with the release of compounds that are more similar in toxicity.
Another good tool to use, which is mentioned in the textbook, is the General Behavior Model (GEBMO). This
model facilitates the creation of hypothetical situations that can then be examined for possible outcomes and
needed response actions (Haight, 2012). Following the GEBMO sequence for each hazardous material will
help complete the hazard assessment by leading you to the risk (the severity of the consequences of a spill
and the probability of such an event happening). The model uses the following seven events:
1. stressing event occurs (thermal, chemical, mechanical, human);
2. container breach occurs (detonating, rapid release, leak);
3. hazardous materials or energy escapes;
4. hazardous material engulfs danger zone (dispersion, path, pattern, distance);
5. hazardous material or energy impinges on receptors (transient, lingering, permanent);
6. hazardous material or energy harms receptors (thermal, chemical, radiation, etiologic, mechanical);
and
7. remedial efforts are attempted (first aid, firefighting, chemical decontamination).
Much of the information required for any risk assessment can be obtained from the SDS for that material or
the DOT Emergency Response Guidebook. The process is repeated for every probable scenario that could
result in a release. The model can also point to preventative measures.
Another extremely important part of the EAP is to determine which personnel need to be trained on their
responsibilities under the plan and how much training is required. Personnel who are expected to respond to
a spill must have training, but do
not forget that there may be
employees whose job in an
emergency is to simply evacuate
safely. Do they know when, how,
and where to evacuate? This
training also needs to be
conducted.
For the first responders, those
responsible for cleanup, and
those directing the response and
cleanup operations, various
levels of training are prescribed
in OSHA’s HAZWOPER
Standard 29 Code of Federal
Regulations (CFR)
§1910.120(q). Be sure to check
with state and local agencies for
additional requirements. The
different levels of response and
the duration of the initial training
for each level are summarized below.
Response Level Initial Training Duration
First Responder Awareness Not Specified (Sufficient Training)
First Responder Operations 8 Hours
Hazardous Materials Technician 24 Hours
Hazardous Materials Specialist 24 + Specialty Training
On-Scene Incident Commander 24 Hours + ICS Training
(OSHA, 1970)
Emergency response exercise held in Nevada
(National Nuclear Security Administration, n.d.)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Each of the training classes is required to cover specific rubrics designed to allow the responders to perform
their required duties. The list of rubrics for each level can be reviewed in section (q) of the regulation. The
regulation allows workers who have enough experience to demonstrate competency in all the rubrics in lieu of
the training. Workers in each of the categories must also have annual refresher training or demonstrate
competency in each rubric area again. The regulation does not specify the length of the annual refresher
training but says the training must provide enough content and last long enough so the workers can maintain
their competency. Annual refresher training has traditionally been 8 hours in length.
Another important step is to make sure that the correct equipment (including PPE) is present at the site. A
spill response plan will not be effective if the PPE and other equipment available to responders is inadequate.
The type and levels of equipment and PPE will vary depending on the hazardous materials that are present
and their quantities. Common equipment that is present at worksites with EAPs include absorbent materials
(e.g., booms, pillows), neutralization kits, overpack drums, hazardous waste bags, and different types of
meters. The most commonly used PPE for spill response teams is the Level A suit. There are four levels of
protective ensembles designated as Level A, Level B, Level C, and Level D. You can review the requirements
and uses for each level in Appendix B to the HAZWOPER Standard (OSHA, 1970). The Level A suit is a fully
encapsulating suit with a self-contained breathing apparatus (SCBA). If the hazardous material cannot cause
serious harm when contacting the skin, a Level B suit can be used instead. The main difference between the
Level A and Level B suit is that the Level B suit is not fully encapsulating. The use of respiratory protection
requires the implementation of a respiratory protection program in accordance with the OSHA regulation 29
CFR §1910.134.
The final step is to execute the plan. This does not mean that the plan sits on a shelf until an incident occurs
and then everyone frantically tries to remember who is supposed to do what, although this is often the case.
Periodic refresher training is not enough either. Plans must be tested through tabletop exercises and
simulated response actions. This is the only effective way to identify and correct weaknesses and ensure the
most effective response. When determining the best frequency for undertaking these exercises, consider that
personnel and situations change often. Sports teams practice between games, right? Considering the
dangers inherent in spill response, your team deserves no less.
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Nuclear Security Administration. (n.d.). NNSA-NSO-1184 [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:NNSA-NSO-1184.jpg
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Hazardous
materials: Hazardous waste operations and emergency response (OSHA Standard No. 1910.120).
United States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.120
Occupational Safety and Health Administration. (2002). Job hazard analysis (OSHA Publication No. 3071).
U.S. Department of Labor. https://www.osha.gov/Publications/osha3071.pdf
Wright, B. A. (2009). Inventory of hazardous products, Guantanamo [Photograph]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Inventory_of_hazardous_ products,_Guantanamo.jpg
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
Learning Activities (Nongraded)
Nongraded Learning Activities are provided to aid students in their course of study. You do not have to submit
them. If you have questions, contact your instructor for further guidance and information.
In a previous unit, you were introduced to the software program that the Occupational Safety and Health
Administration (OSHA) published to assist employers with developing a health and safety program. The
software is called e-HASP and can be downloaded for free at the OSHA e-HASP Software – Version 2.0
webpage.
If you did not already, download the software, and review the chapters on the emergency response plan and
decontamination. Compare the guidelines in the software to the company where you currently work or a
location with which you are familiar. How does the response plan at the company compare with the guidelines
in the e-HASP? What could you recommend to improve the company’s decontamination procedures? Write
your thoughts down in a personal journal.
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
[https://www.osha.gov/dep/etools/ehasp/index.html](https://www.osha.gov/dep/etools/ehasp/index.html)
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– Occupational Safety and Health Administration’s Hazardous Waste Operations and Emergency Response Regulation
– Hazard Assessment
– References
– Learning Activities (Nongraded)
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