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See attached **files (2)** – ## UnitVDB2304.docx – ## UnitV.pdf **## UnitVDB2304.docx** Unit V DB 2304 An initial post of at least 200 words addressing the discussion board topic. A response post of a minimum of 75 meaningful words. Looking the Unit Reading Assignments, and again OSHA's Safety and H…
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**files (2)**
– ## UnitVDB2304.docx
– ## UnitV.pdf
**## UnitVDB2304.docx**
Unit V DB 2304
An initial post of at least 200 words addressing the discussion board topic.
A response post of a minimum of 75 meaningful words.
Looking the Unit Reading Assignments, and again OSHA's Safety and Health Management Program Guidelines, how does your organization communicate your Safety and Health Programs to the workers?
What do you think a "Safety Culture" looks like? Who determines what your Company's Safety Culture is, and why?
What would you include in your programs that would foster a "safety culture" in your organization? What have you found to be the most effective?
Reference:
Goetsch, D. L. (2017).
_Construction Safety and the OSHA Standards_ (2nd ed.). Pearson Education (US).
[https://online.vitalsource.com/books/9780134472904](https://online.vitalsource.com/books/9780134472904)
.
**Response to: Clayton Laurent**
Top of Form
One aspect of OSHA's Safety and Health Management Program Guidelines that I believe is critical to a successful safety program is management commitment. Many organizations have written safety policies, procedures, and training programs, but the effectiveness of those programs depends heavily on the actions of leadership. Employees quickly recognize whether management truly values safety or simply views it as a compliance requirement.
In my experience, a strong safety culture begins when management demonstrates that safety is a core organizational value. This includes providing adequate resources, supporting employee training, correcting hazards promptly, and holding all employees accountable for following established safety procedures. When supervisors and managers consistently follow the same rules they expect employees to follow, it builds trust and credibility throughout the organization.
One of the greatest challenges organizations face is balancing production demands with safety expectations. Employees may feel pressure to complete work quickly, which can lead to shortcuts and increased risk-taking behaviors. A strong safety culture exists when employees understand that safety takes priority over production schedules and when management reinforces that message through its actions and decisions.
To strengthen safety culture, I would implement programs that encourage employee participation, near-miss reporting, hazard recognition, and open communication between workers and management. I have found that employees are much more likely to engage in safety programs when they believe their concerns are heard and acted upon. Ultimately, a positive safety culture is created when management commitment, employee involvement, and accountability work together to make safety part of everyday operations rather than simply another workplace requirement.
Bottom of Form
**## UnitV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Discuss contractor safety from a safety management systems perspective.
5.1 Identify ways the safety culture of a construction company can be established or improved.
Required Unit Resources
Chapter 3: Pro-Active Safety Strategies in Construction: Safety Culture, Total Safety Management, and Other
Strategies
Chapter 7: Construction Safety and Health: Programs, Plans, and Policies
In order to access the following resource, click the link below.
Read pages 1–8 in the following document listed below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health in
construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Unit Lesson
Imagine that you are a theater producer and you are preparing for your next project. So far, you have a broad
idea of what you want the show to be about. Are you ready to begin the show? Certainly not! You need to
have a script. Once the script is written, you need to hire the cast. But you still cannot begin until the cast
learns their parts and rehearses the scenes. You need a set, props, costumes, lights, and a stage crew. Many
elements must come together in order for the production to be successful.
What does this have to do with construction safety? Simply put, planning is essential for the success of any
endeavor. You would not send actors onstage without preparing them and providing the necessary tools. You
start with a written script and work from there. In the world of accident prevention, a written safety plan is the
equivalent of the script. It is the document everyone follows to reach the goal. In a stage production, the goal
is a successful performance. In safety, the goal is to reduce the chance of injury or illness.
There are many examples of safety plans and safety management systems in the literature, but there are
elements common to all. The consensus seems to be that effective safety management includes:
1. Management leadership: All levels of management must demonstrate commitment to the safety
efforts. Without this element, the program will not succeed.
2. Worker participation: Workers who are actively involved and empowered are more likely to take
ownership and responsibility.
3. Hazard identification and assessment: A structured process is used to identify hazards and determine
the level of risk
4. Hazard prevention and control: Actions are taken to eliminate hazards or reduce the risks
5. Education and training: Workers are provided the information needed to protect themselves from
workplace hazards.
6. Program evaluation: Effectiveness of injury/illness prevention efforts are measured, and actions are
taken to improve performance when needed (Goetsch, 2018; Martin & Corcoran, 2018; OSHA,
2016a).
UNIT V STUDY GUIDE
Safety Management
Programs and Culture
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
Effective safety management systems are “top down” systems—that is, the highest levels of management
must fully support and become engaged in the entire effort. Management engagement is more than just
issuing a safety policy statement and written plan. All levels of management must demonstrate their
commitment through their actions by taking part in all the other aspects of the safety management system.
Many safety management systems follow a continuous improvement process, sometimes called a plan-do-
check-act or PDCA cycle. The plan and do elements are important, but some organizations put little effort into
the check and act elements. Going back to the theater analogy for a moment, we plan the production by
writing the script, selecting actors, scenery, sets and props, and rehearsing. Only then can we do the
production. How do we know if the show will work as planned? We could wait until opening night and read
what the critics have to say, or we could conduct a dress rehearsal, evaluate the show ourselves and then
make changes as needed, thus improving the odds of a positive review. A safety management system also
needs to be evaluated once it is in place. We could wait to see if any accidents happen and then make
needed adjustments, but similar to having a dress rehearsal, it is more effective to examine (check) the
process before any accidents happen. The difficulty in accident prevention is knowing what to look for and
how to act to make effective changes.
Most organizations use accident rates to measure program
effectiveness. We can certainly learn from accidents by
investigating them thoroughly and determining causal factors.
But accident rates are lagging indicators, that is, a measurement
based on failure. Effective accident prevention also requires
leading indicators that allow us to take action before the failure.
While the Occupational Safety and Health Administration (OSHA)
requires organizations to calculate accident rates, it also
recognizes the importance of leading indicators as a proactive
approach to accident prevention (OSHA, 2016b). Leading
indicators must be tailored to the organization’s operations, but
they typically include measurements of safety training completed,
job hazard analyses completed, hazards identified and corrected,
and workplace observations of safe and unsafe behaviors
(OSHA, 2016b).
The effectiveness of any safety management system is
dependent on the safety culture of the organization. Sometimes
referred to as “the way we do things around here,” an
organization’s culture is its system of expected performance
(Manuela, 2014). Safety culture, then, is the system of expected
performance for the safety management plan. Organizational
safety culture starts with top management. As we noted earlier,
management’s actions influence how everyone else acts. Let’s
say that an organization has a policy that states “safety is our first
priority.” What does that mean? It seems to indicate that safety
will be considered before anything else. However, priorities can, and do, change. It is not uncommon for some
safety procedures to be set aside in order to meet an urgent production deadline. Despite what might be
written and published, if management acts differently, that becomes the reality for employees (Manuela,
2014).
A true safety culture establishes safety as a core value in everything that is done. This means that everyone
in the organization is committed to reducing risks to an acceptable level, are empowered to take actions that
reflect that core value, and demonstrate this value in their actions.
It is also important to note that while a safety culture defines expected safe behaviors, workers should not be
expected to demonstrate the desired behaviors unless they have been fully trained (Goetsch, 2018). Workers
must be monitored for the desired behaviors and corrections made. Allowing unsafe behaviors, even when it
might seem expedient, will quickly undermine any efforts to establish or maintain a safety culture.
(Adapted from Goetsch, 2018)
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
Safety professionals are in a unique position to influence the safety culture. Manuela (2014) lists a number of
ways safety professionals can exert this influence:
• data gathering and analysis to identify process shortcomings,
• applying best practices for hazard identification and analysis,
• giving advice on prioritizing risks, and
• recommending management system actions needed for improvement.
Remember that the safety culture is controlled by management, not the safety professional. By providing
advice and guidance to management, safety professionals become agents of change (Manuela, 2014).
What does an effective safety culture look like? Goetsch (2018) provides some things to look for:
• fewer accidents than similar companies,
• positive safety attitude of decision makers,
• safety and health considerations addressed in the decision-making process,
• employees empowered to speak up and take action,
• peer pressure encouraging safe behaviors,
• recognition and reward for safety program participation,
• management personnel as role models for safe behaviors,
• ongoing comprehensive safety training. and
• working safely addressed in position descriptions and performance appraisals.
The ever-changing nature of construction sites presents some unique challenges for the safety professional.
Hazards can be identified and controlled one day, only to find new hazards appearing the next day as the job
progresses. A well-designed safety management plan executed within a positive safety culture will enable
organizations to identify and control emerging hazards quickly and efficiently.
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Wiley.
Martin, L., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council.
Occupational Safety and Health Administration. (2016a, October). Recommended practices for safety and
health in construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Occupational Safety and Health Administration. (2016b). The use of metrics in process safety management
(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). United States Department of Labor.
https://www.osha.gov/Publications/OSHA3896.pdf
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.
Conduct internet research to identify a construction company that prides itself on maintaining a safe and
healthy workplace. Determine which of the strategies discussed in this unit the company uses to maintain a
safe and healthy work environment.
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– References
– Learning Activities (Nongraded)
**## UnitV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Discuss contractor safety from a safety management systems perspective.
5.1 Identify ways the safety culture of a construction company can be established or improved.
Required Unit Resources
Chapter 3: Pro-Active Safety Strategies in Construction: Safety Culture, Total Safety Management, and Other
Strategies
Chapter 7: Construction Safety and Health: Programs, Plans, and Policies
In order to access the following resource, click the link below.
Read pages 1–8 in the following document listed below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health in
construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Unit Lesson
Imagine that you are a theater producer and you are preparing for your next project. So far, you have a broad
idea of what you want the show to be about. Are you ready to begin the show? Certainly not! You need to
have a script. Once the script is written, you need to hire the cast. But you still cannot begin until the cast
learns their parts and rehearses the scenes. You need a set, props, costumes, lights, and a stage crew. Many
elements must come together in order for the production to be successful.
What does this have to do with construction safety? Simply put, planning is essential for the success of any
endeavor. You would not send actors onstage without preparing them and providing the necessary tools. You
start with a written script and work from there. In the world of accident prevention, a written safety plan is the
equivalent of the script. It is the document everyone follows to reach the goal. In a stage production, the goal
is a successful performance. In safety, the goal is to reduce the chance of injury or illness.
There are many examples of safety plans and safety management systems in the literature, but there are
elements common to all. The consensus seems to be that effective safety management includes:
1. Management leadership: All levels of management must demonstrate commitment to the safety
efforts. Without this element, the program will not succeed.
2. Worker participation: Workers who are actively involved and empowered are more likely to take
ownership and responsibility.
3. Hazard identification and assessment: A structured process is used to identify hazards and determine
the level of risk
4. Hazard prevention and control: Actions are taken to eliminate hazards or reduce the risks
5. Education and training: Workers are provided the information needed to protect themselves from
workplace hazards.
6. Program evaluation: Effectiveness of injury/illness prevention efforts are measured, and actions are
taken to improve performance when needed (Goetsch, 2018; Martin & Corcoran, 2018; OSHA,
2016a).
UNIT V STUDY GUIDE
Safety Management
Programs and Culture
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
Effective safety management systems are “top down” systems—that is, the highest levels of management
must fully support and become engaged in the entire effort. Management engagement is more than just
issuing a safety policy statement and written plan. All levels of management must demonstrate their
commitment through their actions by taking part in all the other aspects of the safety management system.
Many safety management systems follow a continuous improvement process, sometimes called a plan-do-
check-act or PDCA cycle. The plan and do elements are important, but some organizations put little effort into
the check and act elements. Going back to the theater analogy for a moment, we plan the production by
writing the script, selecting actors, scenery, sets and props, and rehearsing. Only then can we do the
production. How do we know if the show will work as planned? We could wait until opening night and read
what the critics have to say, or we could conduct a dress rehearsal, evaluate the show ourselves and then
make changes as needed, thus improving the odds of a positive review. A safety management system also
needs to be evaluated once it is in place. We could wait to see if any accidents happen and then make
needed adjustments, but similar to having a dress rehearsal, it is more effective to examine (check) the
process before any accidents happen. The difficulty in accident prevention is knowing what to look for and
how to act to make effective changes.
Most organizations use accident rates to measure program
effectiveness. We can certainly learn from accidents by
investigating them thoroughly and determining causal factors.
But accident rates are lagging indicators, that is, a measurement
based on failure. Effective accident prevention also requires
leading indicators that allow us to take action before the failure.
While the Occupational Safety and Health Administration (OSHA)
requires organizations to calculate accident rates, it also
recognizes the importance of leading indicators as a proactive
approach to accident prevention (OSHA, 2016b). Leading
indicators must be tailored to the organization’s operations, but
they typically include measurements of safety training completed,
job hazard analyses completed, hazards identified and corrected,
and workplace observations of safe and unsafe behaviors
(OSHA, 2016b).
The effectiveness of any safety management system is
dependent on the safety culture of the organization. Sometimes
referred to as “the way we do things around here,” an
organization’s culture is its system of expected performance
(Manuela, 2014). Safety culture, then, is the system of expected
performance for the safety management plan. Organizational
safety culture starts with top management. As we noted earlier,
management’s actions influence how everyone else acts. Let’s
say that an organization has a policy that states “safety is our first
priority.” What does that mean? It seems to indicate that safety
will be considered before anything else. However, priorities can, and do, change. It is not uncommon for some
safety procedures to be set aside in order to meet an urgent production deadline. Despite what might be
written and published, if management acts differently, that becomes the reality for employees (Manuela,
2014).
A true safety culture establishes safety as a core value in everything that is done. This means that everyone
in the organization is committed to reducing risks to an acceptable level, are empowered to take actions that
reflect that core value, and demonstrate this value in their actions.
It is also important to note that while a safety culture defines expected safe behaviors, workers should not be
expected to demonstrate the desired behaviors unless they have been fully trained (Goetsch, 2018). Workers
must be monitored for the desired behaviors and corrections made. Allowing unsafe behaviors, even when it
might seem expedient, will quickly undermine any efforts to establish or maintain a safety culture.
(Adapted from Goetsch, 2018)
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
Safety professionals are in a unique position to influence the safety culture. Manuela (2014) lists a number of
ways safety professionals can exert this influence:
• data gathering and analysis to identify process shortcomings,
• applying best practices for hazard identification and analysis,
• giving advice on prioritizing risks, and
• recommending management system actions needed for improvement.
Remember that the safety culture is controlled by management, not the safety professional. By providing
advice and guidance to management, safety professionals become agents of change (Manuela, 2014).
What does an effective safety culture look like? Goetsch (2018) provides some things to look for:
• fewer accidents than similar companies,
• positive safety attitude of decision makers,
• safety and health considerations addressed in the decision-making process,
• employees empowered to speak up and take action,
• peer pressure encouraging safe behaviors,
• recognition and reward for safety program participation,
• management personnel as role models for safe behaviors,
• ongoing comprehensive safety training. and
• working safely addressed in position descriptions and performance appraisals.
The ever-changing nature of construction sites presents some unique challenges for the safety professional.
Hazards can be identified and controlled one day, only to find new hazards appearing the next day as the job
progresses. A well-designed safety management plan executed within a positive safety culture will enable
organizations to identify and control emerging hazards quickly and efficiently.
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Wiley.
Martin, L., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council.
Occupational Safety and Health Administration. (2016a, October). Recommended practices for safety and
health in construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Occupational Safety and Health Administration. (2016b). The use of metrics in process safety management
(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). United States Department of Labor.
https://www.osha.gov/Publications/OSHA3896.pdf
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.
Conduct internet research to identify a construction company that prides itself on maintaining a safe and
healthy workplace. Determine which of the strategies discussed in this unit the company uses to maintain a
safe and healthy work environment.
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– References
– Learning Activities (Nongraded)
**## UnitVDB2304.docx**
Unit V DB 2304
An initial post of at least 200 words addressing the discussion board topic.
A response post of a minimum of 75 meaningful words.
Looking the Unit Reading Assignments, and again OSHA's Safety and Health Management Program Guidelines, how does your organization communicate your Safety and Health Programs to the workers?
What do you think a "Safety Culture" looks like? Who determines what your Company's Safety Culture is, and why?
What would you include in your programs that would foster a "safety culture" in your organization? What have you found to be the most effective?
Reference:
Goetsch, D. L. (2017).
_Construction Safety and the OSHA Standards_ (2nd ed.). Pearson Education (US).
[https://online.vitalsource.com/books/9780134472904](https://online.vitalsource.com/books/9780134472904)
.
**Response to: Clayton Laurent**
Top of Form
One aspect of OSHA's Safety and Health Management Program Guidelines that I believe is critical to a successful safety program is management commitment. Many organizations have written safety policies, procedures, and training programs, but the effectiveness of those programs depends heavily on the actions of leadership. Employees quickly recognize whether management truly values safety or simply views it as a compliance requirement.
In my experience, a strong safety culture begins when management demonstrates that safety is a core organizational value. This includes providing adequate resources, supporting employee training, correcting hazards promptly, and holding all employees accountable for following established safety procedures. When supervisors and managers consistently follow the same rules they expect employees to follow, it builds trust and credibility throughout the organization.
One of the greatest challenges organizations face is balancing production demands with safety expectations. Employees may feel pressure to complete work quickly, which can lead to shortcuts and increased risk-taking behaviors. A strong safety culture exists when employees understand that safety takes priority over production schedules and when management reinforces that message through its actions and decisions.
To strengthen safety culture, I would implement programs that encourage employee participation, near-miss reporting, hazard recognition, and open communication between workers and management. I have found that employees are much more likely to engage in safety programs when they believe their concerns are heard and acted upon. Ultimately, a positive safety culture is created when management commitment, employee involvement, and accountability work together to make safety part of everyday operations rather than simply another workplace requirement.
Bottom of Form
**## UnitV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Discuss contractor safety from a safety management systems perspective.
5.1 Identify ways the safety culture of a construction company can be established or improved.
Required Unit Resources
Chapter 3: Pro-Active Safety Strategies in Construction: Safety Culture, Total Safety Management, and Other
Strategies
Chapter 7: Construction Safety and Health: Programs, Plans, and Policies
In order to access the following resource, click the link below.
Read pages 1–8 in the following document listed below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health in
construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Unit Lesson
Imagine that you are a theater producer and you are preparing for your next project. So far, you have a broad
idea of what you want the show to be about. Are you ready to begin the show? Certainly not! You need to
have a script. Once the script is written, you need to hire the cast. But you still cannot begin until the cast
learns their parts and rehearses the scenes. You need a set, props, costumes, lights, and a stage crew. Many
elements must come together in order for the production to be successful.
What does this have to do with construction safety? Simply put, planning is essential for the success of any
endeavor. You would not send actors onstage without preparing them and providing the necessary tools. You
start with a written script and work from there. In the world of accident prevention, a written safety plan is the
equivalent of the script. It is the document everyone follows to reach the goal. In a stage production, the goal
is a successful performance. In safety, the goal is to reduce the chance of injury or illness.
There are many examples of safety plans and safety management systems in the literature, but there are
elements common to all. The consensus seems to be that effective safety management includes:
1. Management leadership: All levels of management must demonstrate commitment to the safety
efforts. Without this element, the program will not succeed.
2. Worker participation: Workers who are actively involved and empowered are more likely to take
ownership and responsibility.
3. Hazard identification and assessment: A structured process is used to identify hazards and determine
the level of risk
4. Hazard prevention and control: Actions are taken to eliminate hazards or reduce the risks
5. Education and training: Workers are provided the information needed to protect themselves from
workplace hazards.
6. Program evaluation: Effectiveness of injury/illness prevention efforts are measured, and actions are
taken to improve performance when needed (Goetsch, 2018; Martin & Corcoran, 2018; OSHA,
2016a).
UNIT V STUDY GUIDE
Safety Management
Programs and Culture
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
Effective safety management systems are “top down” systems—that is, the highest levels of management
must fully support and become engaged in the entire effort. Management engagement is more than just
issuing a safety policy statement and written plan. All levels of management must demonstrate their
commitment through their actions by taking part in all the other aspects of the safety management system.
Many safety management systems follow a continuous improvement process, sometimes called a plan-do-
check-act or PDCA cycle. The plan and do elements are important, but some organizations put little effort into
the check and act elements. Going back to the theater analogy for a moment, we plan the production by
writing the script, selecting actors, scenery, sets and props, and rehearsing. Only then can we do the
production. How do we know if the show will work as planned? We could wait until opening night and read
what the critics have to say, or we could conduct a dress rehearsal, evaluate the show ourselves and then
make changes as needed, thus improving the odds of a positive review. A safety management system also
needs to be evaluated once it is in place. We could wait to see if any accidents happen and then make
needed adjustments, but similar to having a dress rehearsal, it is more effective to examine (check) the
process before any accidents happen. The difficulty in accident prevention is knowing what to look for and
how to act to make effective changes.
Most organizations use accident rates to measure program
effectiveness. We can certainly learn from accidents by
investigating them thoroughly and determining causal factors.
But accident rates are lagging indicators, that is, a measurement
based on failure. Effective accident prevention also requires
leading indicators that allow us to take action before the failure.
While the Occupational Safety and Health Administration (OSHA)
requires organizations to calculate accident rates, it also
recognizes the importance of leading indicators as a proactive
approach to accident prevention (OSHA, 2016b). Leading
indicators must be tailored to the organization’s operations, but
they typically include measurements of safety training completed,
job hazard analyses completed, hazards identified and corrected,
and workplace observations of safe and unsafe behaviors
(OSHA, 2016b).
The effectiveness of any safety management system is
dependent on the safety culture of the organization. Sometimes
referred to as “the way we do things around here,” an
organization’s culture is its system of expected performance
(Manuela, 2014). Safety culture, then, is the system of expected
performance for the safety management plan. Organizational
safety culture starts with top management. As we noted earlier,
management’s actions influence how everyone else acts. Let’s
say that an organization has a policy that states “safety is our first
priority.” What does that mean? It seems to indicate that safety
will be considered before anything else. However, priorities can, and do, change. It is not uncommon for some
safety procedures to be set aside in order to meet an urgent production deadline. Despite what might be
written and published, if management acts differently, that becomes the reality for employees (Manuela,
2014).
A true safety culture establishes safety as a core value in everything that is done. This means that everyone
in the organization is committed to reducing risks to an acceptable level, are empowered to take actions that
reflect that core value, and demonstrate this value in their actions.
It is also important to note that while a safety culture defines expected safe behaviors, workers should not be
expected to demonstrate the desired behaviors unless they have been fully trained (Goetsch, 2018). Workers
must be monitored for the desired behaviors and corrections made. Allowing unsafe behaviors, even when it
might seem expedient, will quickly undermine any efforts to establish or maintain a safety culture.
(Adapted from Goetsch, 2018)
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
Safety professionals are in a unique position to influence the safety culture. Manuela (2014) lists a number of
ways safety professionals can exert this influence:
• data gathering and analysis to identify process shortcomings,
• applying best practices for hazard identification and analysis,
• giving advice on prioritizing risks, and
• recommending management system actions needed for improvement.
Remember that the safety culture is controlled by management, not the safety professional. By providing
advice and guidance to management, safety professionals become agents of change (Manuela, 2014).
What does an effective safety culture look like? Goetsch (2018) provides some things to look for:
• fewer accidents than similar companies,
• positive safety attitude of decision makers,
• safety and health considerations addressed in the decision-making process,
• employees empowered to speak up and take action,
• peer pressure encouraging safe behaviors,
• recognition and reward for safety program participation,
• management personnel as role models for safe behaviors,
• ongoing comprehensive safety training. and
• working safely addressed in position descriptions and performance appraisals.
The ever-changing nature of construction sites presents some unique challenges for the safety professional.
Hazards can be identified and controlled one day, only to find new hazards appearing the next day as the job
progresses. A well-designed safety management plan executed within a positive safety culture will enable
organizations to identify and control emerging hazards quickly and efficiently.
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Wiley.
Martin, L., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council.
Occupational Safety and Health Administration. (2016a, October). Recommended practices for safety and
health in construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Occupational Safety and Health Administration. (2016b). The use of metrics in process safety management
(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). United States Department of Labor.
https://www.osha.gov/Publications/OSHA3896.pdf
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.
Conduct internet research to identify a construction company that prides itself on maintaining a safe and
healthy workplace. Determine which of the strategies discussed in this unit the company uses to maintain a
safe and healthy work environment.
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– References
– Learning Activities (Nongraded)
**## UnitVDB2304.docx**
Unit V DB 2304
An initial post of at least 200 words addressing the discussion board topic.
A response post of a minimum of 75 meaningful words.
Looking the Unit Reading Assignments, and again OSHA's Safety and Health Management Program Guidelines, how does your organization communicate your Safety and Health Programs to the workers?
What do you think a "Safety Culture" looks like? Who determines what your Company's Safety Culture is, and why?
What would you include in your programs that would foster a "safety culture" in your organization? What have you found to be the most effective?
Reference:
Goetsch, D. L. (2017).
_Construction Safety and the OSHA Standards_ (2nd ed.). Pearson Education (US).
[https://online.vitalsource.com/books/9780134472904](https://online.vitalsource.com/books/9780134472904)
.
**Response to: Clayton Laurent**
Top of Form
One aspect of OSHA's Safety and Health Management Program Guidelines that I believe is critical to a successful safety program is management commitment. Many organizations have written safety policies, procedures, and training programs, but the effectiveness of those programs depends heavily on the actions of leadership. Employees quickly recognize whether management truly values safety or simply views it as a compliance requirement.
In my experience, a strong safety culture begins when management demonstrates that safety is a core organizational value. This includes providing adequate resources, supporting employee training, correcting hazards promptly, and holding all employees accountable for following established safety procedures. When supervisors and managers consistently follow the same rules they expect employees to follow, it builds trust and credibility throughout the organization.
One of the greatest challenges organizations face is balancing production demands with safety expectations. Employees may feel pressure to complete work quickly, which can lead to shortcuts and increased risk-taking behaviors. A strong safety culture exists when employees understand that safety takes priority over production schedules and when management reinforces that message through its actions and decisions.
To strengthen safety culture, I would implement programs that encourage employee participation, near-miss reporting, hazard recognition, and open communication between workers and management. I have found that employees are much more likely to engage in safety programs when they believe their concerns are heard and acted upon. Ultimately, a positive safety culture is created when management commitment, employee involvement, and accountability work together to make safety part of everyday operations rather than simply another workplace requirement.
Bottom of Form
**## UnitV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit V
Upon completion of this unit, students should be able to:
5. Discuss contractor safety from a safety management systems perspective.
5.1 Identify ways the safety culture of a construction company can be established or improved.
Required Unit Resources
Chapter 3: Pro-Active Safety Strategies in Construction: Safety Culture, Total Safety Management, and Other
Strategies
Chapter 7: Construction Safety and Health: Programs, Plans, and Policies
In order to access the following resource, click the link below.
Read pages 1–8 in the following document listed below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health in
construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Unit Lesson
Imagine that you are a theater producer and you are preparing for your next project. So far, you have a broad
idea of what you want the show to be about. Are you ready to begin the show? Certainly not! You need to
have a script. Once the script is written, you need to hire the cast. But you still cannot begin until the cast
learns their parts and rehearses the scenes. You need a set, props, costumes, lights, and a stage crew. Many
elements must come together in order for the production to be successful.
What does this have to do with construction safety? Simply put, planning is essential for the success of any
endeavor. You would not send actors onstage without preparing them and providing the necessary tools. You
start with a written script and work from there. In the world of accident prevention, a written safety plan is the
equivalent of the script. It is the document everyone follows to reach the goal. In a stage production, the goal
is a successful performance. In safety, the goal is to reduce the chance of injury or illness.
There are many examples of safety plans and safety management systems in the literature, but there are
elements common to all. The consensus seems to be that effective safety management includes:
1. Management leadership: All levels of management must demonstrate commitment to the safety
efforts. Without this element, the program will not succeed.
2. Worker participation: Workers who are actively involved and empowered are more likely to take
ownership and responsibility.
3. Hazard identification and assessment: A structured process is used to identify hazards and determine
the level of risk
4. Hazard prevention and control: Actions are taken to eliminate hazards or reduce the risks
5. Education and training: Workers are provided the information needed to protect themselves from
workplace hazards.
6. Program evaluation: Effectiveness of injury/illness prevention efforts are measured, and actions are
taken to improve performance when needed (Goetsch, 2018; Martin & Corcoran, 2018; OSHA,
2016a).
UNIT V STUDY GUIDE
Safety Management
Programs and Culture
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
[https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf](https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
Effective safety management systems are “top down” systems—that is, the highest levels of management
must fully support and become engaged in the entire effort. Management engagement is more than just
issuing a safety policy statement and written plan. All levels of management must demonstrate their
commitment through their actions by taking part in all the other aspects of the safety management system.
Many safety management systems follow a continuous improvement process, sometimes called a plan-do-
check-act or PDCA cycle. The plan and do elements are important, but some organizations put little effort into
the check and act elements. Going back to the theater analogy for a moment, we plan the production by
writing the script, selecting actors, scenery, sets and props, and rehearsing. Only then can we do the
production. How do we know if the show will work as planned? We could wait until opening night and read
what the critics have to say, or we could conduct a dress rehearsal, evaluate the show ourselves and then
make changes as needed, thus improving the odds of a positive review. A safety management system also
needs to be evaluated once it is in place. We could wait to see if any accidents happen and then make
needed adjustments, but similar to having a dress rehearsal, it is more effective to examine (check) the
process before any accidents happen. The difficulty in accident prevention is knowing what to look for and
how to act to make effective changes.
Most organizations use accident rates to measure program
effectiveness. We can certainly learn from accidents by
investigating them thoroughly and determining causal factors.
But accident rates are lagging indicators, that is, a measurement
based on failure. Effective accident prevention also requires
leading indicators that allow us to take action before the failure.
While the Occupational Safety and Health Administration (OSHA)
requires organizations to calculate accident rates, it also
recognizes the importance of leading indicators as a proactive
approach to accident prevention (OSHA, 2016b). Leading
indicators must be tailored to the organization’s operations, but
they typically include measurements of safety training completed,
job hazard analyses completed, hazards identified and corrected,
and workplace observations of safe and unsafe behaviors
(OSHA, 2016b).
The effectiveness of any safety management system is
dependent on the safety culture of the organization. Sometimes
referred to as “the way we do things around here,” an
organization’s culture is its system of expected performance
(Manuela, 2014). Safety culture, then, is the system of expected
performance for the safety management plan. Organizational
safety culture starts with top management. As we noted earlier,
management’s actions influence how everyone else acts. Let’s
say that an organization has a policy that states “safety is our first
priority.” What does that mean? It seems to indicate that safety
will be considered before anything else. However, priorities can, and do, change. It is not uncommon for some
safety procedures to be set aside in order to meet an urgent production deadline. Despite what might be
written and published, if management acts differently, that becomes the reality for employees (Manuela,
2014).
A true safety culture establishes safety as a core value in everything that is done. This means that everyone
in the organization is committed to reducing risks to an acceptable level, are empowered to take actions that
reflect that core value, and demonstrate this value in their actions.
It is also important to note that while a safety culture defines expected safe behaviors, workers should not be
expected to demonstrate the desired behaviors unless they have been fully trained (Goetsch, 2018). Workers
must be monitored for the desired behaviors and corrections made. Allowing unsafe behaviors, even when it
might seem expedient, will quickly undermine any efforts to establish or maintain a safety culture.
(Adapted from Goetsch, 2018)
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
Safety professionals are in a unique position to influence the safety culture. Manuela (2014) lists a number of
ways safety professionals can exert this influence:
• data gathering and analysis to identify process shortcomings,
• applying best practices for hazard identification and analysis,
• giving advice on prioritizing risks, and
• recommending management system actions needed for improvement.
Remember that the safety culture is controlled by management, not the safety professional. By providing
advice and guidance to management, safety professionals become agents of change (Manuela, 2014).
What does an effective safety culture look like? Goetsch (2018) provides some things to look for:
• fewer accidents than similar companies,
• positive safety attitude of decision makers,
• safety and health considerations addressed in the decision-making process,
• employees empowered to speak up and take action,
• peer pressure encouraging safe behaviors,
• recognition and reward for safety program participation,
• management personnel as role models for safe behaviors,
• ongoing comprehensive safety training. and
• working safely addressed in position descriptions and performance appraisals.
The ever-changing nature of construction sites presents some unique challenges for the safety professional.
Hazards can be identified and controlled one day, only to find new hazards appearing the next day as the job
progresses. A well-designed safety management plan executed within a positive safety culture will enable
organizations to identify and control emerging hazards quickly and efficiently.
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
Manuele, F. A. (2014). Advanced safety management: Focusing on Z10 and serious injury prevention (2nd
ed.). Wiley.
Martin, L., & Corcoran, D. (2018). Supervisors’ safety manual (11th ed.). National Safety Council.
Occupational Safety and Health Administration. (2016a, October). Recommended practices for safety and
health in construction (OSHA Document No. 3886). United States Department of Labor.
https://www.osha.gov/shpguidelines/docs/8524_OSHA_Construction_Guidelines_R4.pdf
Occupational Safety and Health Administration. (2016b). The use of metrics in process safety management
(PSM) facilities (OSHA Fact Sheet No. DOC FS-3896). United States Department of Labor.
https://www.osha.gov/Publications/OSHA3896.pdf
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.
Conduct internet research to identify a construction company that prides itself on maintaining a safe and
healthy workplace. Determine which of the strategies discussed in this unit the company uses to maintain a
safe and healthy work environment.
– Course Learning Outcomes for Unit V
– Required Unit Resources
– Unit Lesson
– References
– Learning Activities (Nongraded)
See attached **files (2)** – ## UnitIVJournal2304.docx – ## UnitIV.pdf **## UnitIVJournal2304.docx** Unit IV Journal 2304 In the Unit Reading Assignment, we learn about OSHA's Safety and Health Management Guidelines and the "Core Elements" for Communication and Coordination for Host Employers, Contr…
Immediate access to the full model answer, formatted citations, and rubric breakdown.
Have this question answered from scratch according to your specific instructions and deadline.
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**files (2)**
– ## UnitIVJournal2304.docx
– ## UnitIV.pdf
**## UnitIVJournal2304.docx**
Unit IV Journal 2304
In the Unit Reading Assignment, we learn about OSHA's Safety and Health Management Guidelines and the "Core Elements" for Communication and Coordination for Host Employers, Contractors, and Staffing Agencies.
Think about the contractors your company uses. Do you prequalify them? If so, what criteria do you use? If not, do you think it is a good idea to prequalify contractors? Why, or why not?
Considering that many independent contractors and temporary workers are not direct, full-time employees, and may come from many different industries, backgrounds and cultures, how would you ensure everyone understands the safety message?
Who is responsible for overseeing their safety?
Who is responsible for insurance coverages and OSHA Log reporting? Does it make a difference who is supervising and directing their work? Why or why not?
Understanding that multiple trades may be working together, how would you manage the program so that they do not create hazards for each other?
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitIV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
4. Summarize methods for ensuring contractor accountability.
4.1 Identify relationships between host employer and contractor liability.
4.2 Compare and contrast insurance requirements.
4.3 Develop best practices for contractor prequalifications.
Required Unit Resources
Chapter 5: Workers’ Compensation and Other Kinds of Construction Insurance
In order to access the following resources, click the link below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs: Communication and coordination for host employers, contractors, and staffing agencies.
United States Department of Labor. https://www.osha.gov/shpguidelines/communication.html
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
Wilbanks, D. W. (2019, July). Contractor safety prequalification: The significant limitations of loss rates.
Professional Safety, 64(7), 22–26.
https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-
journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337
Unit Lesson
Who’s on First?
We touched briefly in Units II and III on the relationships between the controlling (host) contractor, and the
contractor or subcontractor roles. Let’s look a little more deeply into the way this actually works.
In the unit reading assignment, we look at what Occupational Safety and Health Administration (OSHA) has to
recommend regarding contractors, subcontractors, independent contractors, and temporary help from staffing
agencies. The key issue here is communication. Why is this so important? Would you want to accept a job not
knowing anything about the hazards? Letting everyone know what hazards may be present, how to avoid
them, and how to report accidental contact with them is part of the host employer’s responsibility. Think of it
this way. If you invite someone to your home, and you know that your front step is damaged and someone
could fall through it, would you fix the step, route a path around it, tell them to avoid that step, or take the
chance that they will see it for themselves? Of course, fixing the step is the best choice, but in the event that
is not possible and there is no avoiding it, you would want to make them aware of it so they can avoid contact
themselves.
Communication really is where it all starts. As the contract manager, construction manager, or general
contractor, your company is considered to be the host employer. You control the entire site. As the employer
in control of the entire site, it is your responsibility to recognize and identify potential hazards and work to
eliminate them. Communication is a two-way street. It is also the host employer’s responsibility to listen to the
UNIT IV STUDY GUIDE
Contractor Prequalification
and Insurance
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf](https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf)
[https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337](https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
contractors and to ask what hazards their work will bring to the site. As the host employer, you are
responsible to find out what those hazards are.
Working with the contractors, you must understand what their operations entail, how they interact with other
operations, and the hazards that may be added to the site as a whole. Each phase of a project will bring its
own unique hazards, and it is up to you to ensure communication about these is transmitted to everyone. How
are you going to accomplish this?
Coordination between all is critical. Holding weekly coordination meetings to discuss not only the ongoing
work, but the hazards involved is crucial in ensuring everyone is made aware of them. There may be multiple
activities going on in the same area and without coordination, if so, nobody is going to know what the other is
doing, and that can cause chaos. Consider this example from building construction—your electricians need to
work in the same area as your plumbers, at the same time. Ladders everywhere! And materials all over the
place. Let’s add in some HVAC work, because the ductwork also has to be installed. So now we have scissor
lifts running around and pallet jacks trying to make their way through the mess. All of these activities go hand
in hand, and all have to be installed in coordination with each other. If you start installing the ductwork before
the plumbing or fire sprinkler pipes go in, how do you reach above the ductwork to get where you need to be?
(I have seen workers try to climb on the ductwork to get to the plumbing lines!).
Compare and Contrast Insurance Requirements
Preparing for the worst. Insurance can be defined as a contract between the insurer (i.e., an insurance
company) and the insured (person or company who purchase the policy) to reimburse for losses under
predetermined circumstances in exchange for a fee (the premium). What does this mean to you in plain
language? The English commonly use the term assurance, which has the same meaning as insurance in the
United States (International Risk Management Institute, n.d.).
For this course, we are only going to look at workers’ compensation. This is the type of insurance we, as
safety professionals, deal with most regularly. When a worker is injured as a part of doing their job, in most
cases, measures are in place to ensure they are taken care of. They do not have to pay for their own medical
treatment or therapy, and if they lose time from work, they will receive a portion of their average wages (after
a waiting period, in most states). This serves two purposes: 1) to get the worker healthy and whole and back
to work; and 2) to eliminate the threat of lawsuits against the employer. This is the case in most industries, but
not all, and workers’ compensation will vary from state to state, as it is regulated at the state level (Goetsch,
2018).
This insurance only covers employees. In the required unit resource readings, we look at different levels of
who is considered an employee, and who is not. Now, here is where this gets a little complicated in terms of
contractors. Let’s look at the different levels of contractors.
Your company may hire a contractor to do some work in your facility that your own work force would not
normally do, such as repairs, modifications, additions, or other work. Again, some of you might call these
turnarounds or shutdowns. Any work that your own company does not self-perform will likely be contracted
out. Now, this work may require a whole company to do the work, or just a person or two. Maybe you just
need to have landscaping maintenance. Or hire a single consultant.
So Who Covers These Workers?
In most cases, the contractor/subcontractor for larger work will have their own workers’ compensation
insurance that covers their own employees. But let’s look at this: in the consultant’s case, they should have
what is called professional liability insurance, which should be part of the contract you have with them,
protecting your company from unforeseen events.
In other cases where you might hire an independent contractor, such as a lawn care firm, how do you handle
this? Do you check to see if they have insurance, and are bonded and licensed? Going back to the
contractor/subcontractor that your company brings in to do major work, are you checking to see if they have
the right coverage in place? What happens if they have all temporary workers performing the tasks? How are
they covered?
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
In the required unit resources reading, we learn that there are many different definitions of employee. How do
we make sure all workers on our sites are covered under workers’ compensation? How do we ensure that
those uncovered workers cam not turn around and make claims against our companies? If your company
uses a staffing agency to provide temporary workers, it would be a good idea to review the insurance
coverage the staffing agency provides. In many cases, they will provide workers’ compensation, however the
deductible will be large. OSHA (2014) holds that, in most cases, the host employer and the staffing agency
will be joint employers.
What does this mean? In your required unit resources reading, we learn that OSHA considers the host
employer, in many cases, to be the one responsible for recording the injury or illness on their OSHA log. The
key factor here is supervision and direction. If the host contractor is providing the day-to-day supervision, the
temporary worker becomes an employee of the host employer. This can, and has, resulted in the temporary
worker being covered under the host employer’s workers compensation policy.
In a case several years ago, several temporary workers were hired at a project to do general labor. One of
them fell and sustained a head injury which eventually led to his death. The staffing agency claimed that
because the host employer provided the direct supervision, the employee belonged to the host employer. The
staffing agency did have workers’ compensation insurance; however they also had a million dollar deductible,
meaning that everything up to that million dollars came out of the staffing agency’s pocket.
If you have used a staffing agency, you may have noticed that the workers will bring their “tickets” to be
signed by the host employer’s supervisor at the end of each day. Does your company read the back of those
tickets? They are essentially a contract you are agreeing to abide by. Many host employers now use a
contract with the staffing agency and insist that they provide their own supervision, much like any other
contracted or subcontracted firm. This can provide protections for the host employer. Now, as we read above,
while the worker cannot sue the employer under workers’ compensation, contracted employees are able, in
most cases, to sue the host employer under their general liability policy. But that is another story for another
day.
This rolls us right into prequalifying our contractors. We should be looking at several factors when hiring
contractors. We should be using staffing agencies and making sure they have their own supervision—
workers’ compensation and other insurance is one of those areas.
Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
There are some great methods to ensure the safety of all, even before beginning work. One of the best ways
is to do your homework! Prequalification of contractors is a great way to ascertain whether or not they have a
history of injuries, fatalities, or violations. Check their past performance. Review their safety program. Some
companies perform their own prequalification; some use a third-party to review a contractor’s performance
history. Either way you go, it is a best practice to know who you are working with.
Convincing your company to perform prequalifications before hiring contractors is one of the best ways to
gauge the safety knowledge of those you will be working with. Of course, many small firms may not have
strong safety programs. The independent contractor will rely on the host employer to provide the rules for the
project. The staffing agency should work with the host employer to ensure that their employees are in tune
with your policies and programs.
It is a good practice to require that the contractor provide a site safety representative with a site specific safety
plan developed for the work they will be performing on the particular project. A generic corporate safety
manual is not a site specific safety plan (SSSP). Contractors should know and understand the work they are
to perform and the environment in which they will be performing it. Once you have your own SSSP
developed, you can share it with your contractors so they can understand what is expected of them before
they come on site, and formulate their own SSSP for their specific work. By submitting an SSSP, it
demonstrates that they have knowledge of the hazards they may encounter. Remember to require that they
submit an example of their Pre-task Analysis (PTA) or Job Safety Analysis (JSA).
OSH 2304, Introduction to Contractor Safety 4
UNIT x STUDY GUIDE
Title
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
International Risk Management Institute. (n.d.). Insurance. https://www.irmi.com/term/insurance-
definitions/insurance
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– Who’s on First?
– Compare and Contrast Insurance Requirements
– So Who Covers These Workers?
– Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
– References
**## UnitIV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
4. Summarize methods for ensuring contractor accountability.
4.1 Identify relationships between host employer and contractor liability.
4.2 Compare and contrast insurance requirements.
4.3 Develop best practices for contractor prequalifications.
Required Unit Resources
Chapter 5: Workers’ Compensation and Other Kinds of Construction Insurance
In order to access the following resources, click the link below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs: Communication and coordination for host employers, contractors, and staffing agencies.
United States Department of Labor. https://www.osha.gov/shpguidelines/communication.html
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
Wilbanks, D. W. (2019, July). Contractor safety prequalification: The significant limitations of loss rates.
Professional Safety, 64(7), 22–26.
https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-
journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337
Unit Lesson
Who’s on First?
We touched briefly in Units II and III on the relationships between the controlling (host) contractor, and the
contractor or subcontractor roles. Let’s look a little more deeply into the way this actually works.
In the unit reading assignment, we look at what Occupational Safety and Health Administration (OSHA) has to
recommend regarding contractors, subcontractors, independent contractors, and temporary help from staffing
agencies. The key issue here is communication. Why is this so important? Would you want to accept a job not
knowing anything about the hazards? Letting everyone know what hazards may be present, how to avoid
them, and how to report accidental contact with them is part of the host employer’s responsibility. Think of it
this way. If you invite someone to your home, and you know that your front step is damaged and someone
could fall through it, would you fix the step, route a path around it, tell them to avoid that step, or take the
chance that they will see it for themselves? Of course, fixing the step is the best choice, but in the event that
is not possible and there is no avoiding it, you would want to make them aware of it so they can avoid contact
themselves.
Communication really is where it all starts. As the contract manager, construction manager, or general
contractor, your company is considered to be the host employer. You control the entire site. As the employer
in control of the entire site, it is your responsibility to recognize and identify potential hazards and work to
eliminate them. Communication is a two-way street. It is also the host employer’s responsibility to listen to the
UNIT IV STUDY GUIDE
Contractor Prequalification
and Insurance
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf](https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf)
[https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337](https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
contractors and to ask what hazards their work will bring to the site. As the host employer, you are
responsible to find out what those hazards are.
Working with the contractors, you must understand what their operations entail, how they interact with other
operations, and the hazards that may be added to the site as a whole. Each phase of a project will bring its
own unique hazards, and it is up to you to ensure communication about these is transmitted to everyone. How
are you going to accomplish this?
Coordination between all is critical. Holding weekly coordination meetings to discuss not only the ongoing
work, but the hazards involved is crucial in ensuring everyone is made aware of them. There may be multiple
activities going on in the same area and without coordination, if so, nobody is going to know what the other is
doing, and that can cause chaos. Consider this example from building construction—your electricians need to
work in the same area as your plumbers, at the same time. Ladders everywhere! And materials all over the
place. Let’s add in some HVAC work, because the ductwork also has to be installed. So now we have scissor
lifts running around and pallet jacks trying to make their way through the mess. All of these activities go hand
in hand, and all have to be installed in coordination with each other. If you start installing the ductwork before
the plumbing or fire sprinkler pipes go in, how do you reach above the ductwork to get where you need to be?
(I have seen workers try to climb on the ductwork to get to the plumbing lines!).
Compare and Contrast Insurance Requirements
Preparing for the worst. Insurance can be defined as a contract between the insurer (i.e., an insurance
company) and the insured (person or company who purchase the policy) to reimburse for losses under
predetermined circumstances in exchange for a fee (the premium). What does this mean to you in plain
language? The English commonly use the term assurance, which has the same meaning as insurance in the
United States (International Risk Management Institute, n.d.).
For this course, we are only going to look at workers’ compensation. This is the type of insurance we, as
safety professionals, deal with most regularly. When a worker is injured as a part of doing their job, in most
cases, measures are in place to ensure they are taken care of. They do not have to pay for their own medical
treatment or therapy, and if they lose time from work, they will receive a portion of their average wages (after
a waiting period, in most states). This serves two purposes: 1) to get the worker healthy and whole and back
to work; and 2) to eliminate the threat of lawsuits against the employer. This is the case in most industries, but
not all, and workers’ compensation will vary from state to state, as it is regulated at the state level (Goetsch,
2018).
This insurance only covers employees. In the required unit resource readings, we look at different levels of
who is considered an employee, and who is not. Now, here is where this gets a little complicated in terms of
contractors. Let’s look at the different levels of contractors.
Your company may hire a contractor to do some work in your facility that your own work force would not
normally do, such as repairs, modifications, additions, or other work. Again, some of you might call these
turnarounds or shutdowns. Any work that your own company does not self-perform will likely be contracted
out. Now, this work may require a whole company to do the work, or just a person or two. Maybe you just
need to have landscaping maintenance. Or hire a single consultant.
So Who Covers These Workers?
In most cases, the contractor/subcontractor for larger work will have their own workers’ compensation
insurance that covers their own employees. But let’s look at this: in the consultant’s case, they should have
what is called professional liability insurance, which should be part of the contract you have with them,
protecting your company from unforeseen events.
In other cases where you might hire an independent contractor, such as a lawn care firm, how do you handle
this? Do you check to see if they have insurance, and are bonded and licensed? Going back to the
contractor/subcontractor that your company brings in to do major work, are you checking to see if they have
the right coverage in place? What happens if they have all temporary workers performing the tasks? How are
they covered?
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
In the required unit resources reading, we learn that there are many different definitions of employee. How do
we make sure all workers on our sites are covered under workers’ compensation? How do we ensure that
those uncovered workers cam not turn around and make claims against our companies? If your company
uses a staffing agency to provide temporary workers, it would be a good idea to review the insurance
coverage the staffing agency provides. In many cases, they will provide workers’ compensation, however the
deductible will be large. OSHA (2014) holds that, in most cases, the host employer and the staffing agency
will be joint employers.
What does this mean? In your required unit resources reading, we learn that OSHA considers the host
employer, in many cases, to be the one responsible for recording the injury or illness on their OSHA log. The
key factor here is supervision and direction. If the host contractor is providing the day-to-day supervision, the
temporary worker becomes an employee of the host employer. This can, and has, resulted in the temporary
worker being covered under the host employer’s workers compensation policy.
In a case several years ago, several temporary workers were hired at a project to do general labor. One of
them fell and sustained a head injury which eventually led to his death. The staffing agency claimed that
because the host employer provided the direct supervision, the employee belonged to the host employer. The
staffing agency did have workers’ compensation insurance; however they also had a million dollar deductible,
meaning that everything up to that million dollars came out of the staffing agency’s pocket.
If you have used a staffing agency, you may have noticed that the workers will bring their “tickets” to be
signed by the host employer’s supervisor at the end of each day. Does your company read the back of those
tickets? They are essentially a contract you are agreeing to abide by. Many host employers now use a
contract with the staffing agency and insist that they provide their own supervision, much like any other
contracted or subcontracted firm. This can provide protections for the host employer. Now, as we read above,
while the worker cannot sue the employer under workers’ compensation, contracted employees are able, in
most cases, to sue the host employer under their general liability policy. But that is another story for another
day.
This rolls us right into prequalifying our contractors. We should be looking at several factors when hiring
contractors. We should be using staffing agencies and making sure they have their own supervision—
workers’ compensation and other insurance is one of those areas.
Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
There are some great methods to ensure the safety of all, even before beginning work. One of the best ways
is to do your homework! Prequalification of contractors is a great way to ascertain whether or not they have a
history of injuries, fatalities, or violations. Check their past performance. Review their safety program. Some
companies perform their own prequalification; some use a third-party to review a contractor’s performance
history. Either way you go, it is a best practice to know who you are working with.
Convincing your company to perform prequalifications before hiring contractors is one of the best ways to
gauge the safety knowledge of those you will be working with. Of course, many small firms may not have
strong safety programs. The independent contractor will rely on the host employer to provide the rules for the
project. The staffing agency should work with the host employer to ensure that their employees are in tune
with your policies and programs.
It is a good practice to require that the contractor provide a site safety representative with a site specific safety
plan developed for the work they will be performing on the particular project. A generic corporate safety
manual is not a site specific safety plan (SSSP). Contractors should know and understand the work they are
to perform and the environment in which they will be performing it. Once you have your own SSSP
developed, you can share it with your contractors so they can understand what is expected of them before
they come on site, and formulate their own SSSP for their specific work. By submitting an SSSP, it
demonstrates that they have knowledge of the hazards they may encounter. Remember to require that they
submit an example of their Pre-task Analysis (PTA) or Job Safety Analysis (JSA).
OSH 2304, Introduction to Contractor Safety 4
UNIT x STUDY GUIDE
Title
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
International Risk Management Institute. (n.d.). Insurance. https://www.irmi.com/term/insurance-
definitions/insurance
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– Who’s on First?
– Compare and Contrast Insurance Requirements
– So Who Covers These Workers?
– Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
– References
**## UnitIVJournal2304.docx**
Unit IV Journal 2304
In the Unit Reading Assignment, we learn about OSHA's Safety and Health Management Guidelines and the "Core Elements" for Communication and Coordination for Host Employers, Contractors, and Staffing Agencies.
Think about the contractors your company uses. Do you prequalify them? If so, what criteria do you use? If not, do you think it is a good idea to prequalify contractors? Why, or why not?
Considering that many independent contractors and temporary workers are not direct, full-time employees, and may come from many different industries, backgrounds and cultures, how would you ensure everyone understands the safety message?
Who is responsible for overseeing their safety?
Who is responsible for insurance coverages and OSHA Log reporting? Does it make a difference who is supervising and directing their work? Why or why not?
Understanding that multiple trades may be working together, how would you manage the program so that they do not create hazards for each other?
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitIV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
4. Summarize methods for ensuring contractor accountability.
4.1 Identify relationships between host employer and contractor liability.
4.2 Compare and contrast insurance requirements.
4.3 Develop best practices for contractor prequalifications.
Required Unit Resources
Chapter 5: Workers’ Compensation and Other Kinds of Construction Insurance
In order to access the following resources, click the link below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs: Communication and coordination for host employers, contractors, and staffing agencies.
United States Department of Labor. https://www.osha.gov/shpguidelines/communication.html
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
Wilbanks, D. W. (2019, July). Contractor safety prequalification: The significant limitations of loss rates.
Professional Safety, 64(7), 22–26.
https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-
journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337
Unit Lesson
Who’s on First?
We touched briefly in Units II and III on the relationships between the controlling (host) contractor, and the
contractor or subcontractor roles. Let’s look a little more deeply into the way this actually works.
In the unit reading assignment, we look at what Occupational Safety and Health Administration (OSHA) has to
recommend regarding contractors, subcontractors, independent contractors, and temporary help from staffing
agencies. The key issue here is communication. Why is this so important? Would you want to accept a job not
knowing anything about the hazards? Letting everyone know what hazards may be present, how to avoid
them, and how to report accidental contact with them is part of the host employer’s responsibility. Think of it
this way. If you invite someone to your home, and you know that your front step is damaged and someone
could fall through it, would you fix the step, route a path around it, tell them to avoid that step, or take the
chance that they will see it for themselves? Of course, fixing the step is the best choice, but in the event that
is not possible and there is no avoiding it, you would want to make them aware of it so they can avoid contact
themselves.
Communication really is where it all starts. As the contract manager, construction manager, or general
contractor, your company is considered to be the host employer. You control the entire site. As the employer
in control of the entire site, it is your responsibility to recognize and identify potential hazards and work to
eliminate them. Communication is a two-way street. It is also the host employer’s responsibility to listen to the
UNIT IV STUDY GUIDE
Contractor Prequalification
and Insurance
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf](https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf)
[https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337](https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
contractors and to ask what hazards their work will bring to the site. As the host employer, you are
responsible to find out what those hazards are.
Working with the contractors, you must understand what their operations entail, how they interact with other
operations, and the hazards that may be added to the site as a whole. Each phase of a project will bring its
own unique hazards, and it is up to you to ensure communication about these is transmitted to everyone. How
are you going to accomplish this?
Coordination between all is critical. Holding weekly coordination meetings to discuss not only the ongoing
work, but the hazards involved is crucial in ensuring everyone is made aware of them. There may be multiple
activities going on in the same area and without coordination, if so, nobody is going to know what the other is
doing, and that can cause chaos. Consider this example from building construction—your electricians need to
work in the same area as your plumbers, at the same time. Ladders everywhere! And materials all over the
place. Let’s add in some HVAC work, because the ductwork also has to be installed. So now we have scissor
lifts running around and pallet jacks trying to make their way through the mess. All of these activities go hand
in hand, and all have to be installed in coordination with each other. If you start installing the ductwork before
the plumbing or fire sprinkler pipes go in, how do you reach above the ductwork to get where you need to be?
(I have seen workers try to climb on the ductwork to get to the plumbing lines!).
Compare and Contrast Insurance Requirements
Preparing for the worst. Insurance can be defined as a contract between the insurer (i.e., an insurance
company) and the insured (person or company who purchase the policy) to reimburse for losses under
predetermined circumstances in exchange for a fee (the premium). What does this mean to you in plain
language? The English commonly use the term assurance, which has the same meaning as insurance in the
United States (International Risk Management Institute, n.d.).
For this course, we are only going to look at workers’ compensation. This is the type of insurance we, as
safety professionals, deal with most regularly. When a worker is injured as a part of doing their job, in most
cases, measures are in place to ensure they are taken care of. They do not have to pay for their own medical
treatment or therapy, and if they lose time from work, they will receive a portion of their average wages (after
a waiting period, in most states). This serves two purposes: 1) to get the worker healthy and whole and back
to work; and 2) to eliminate the threat of lawsuits against the employer. This is the case in most industries, but
not all, and workers’ compensation will vary from state to state, as it is regulated at the state level (Goetsch,
2018).
This insurance only covers employees. In the required unit resource readings, we look at different levels of
who is considered an employee, and who is not. Now, here is where this gets a little complicated in terms of
contractors. Let’s look at the different levels of contractors.
Your company may hire a contractor to do some work in your facility that your own work force would not
normally do, such as repairs, modifications, additions, or other work. Again, some of you might call these
turnarounds or shutdowns. Any work that your own company does not self-perform will likely be contracted
out. Now, this work may require a whole company to do the work, or just a person or two. Maybe you just
need to have landscaping maintenance. Or hire a single consultant.
So Who Covers These Workers?
In most cases, the contractor/subcontractor for larger work will have their own workers’ compensation
insurance that covers their own employees. But let’s look at this: in the consultant’s case, they should have
what is called professional liability insurance, which should be part of the contract you have with them,
protecting your company from unforeseen events.
In other cases where you might hire an independent contractor, such as a lawn care firm, how do you handle
this? Do you check to see if they have insurance, and are bonded and licensed? Going back to the
contractor/subcontractor that your company brings in to do major work, are you checking to see if they have
the right coverage in place? What happens if they have all temporary workers performing the tasks? How are
they covered?
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
In the required unit resources reading, we learn that there are many different definitions of employee. How do
we make sure all workers on our sites are covered under workers’ compensation? How do we ensure that
those uncovered workers cam not turn around and make claims against our companies? If your company
uses a staffing agency to provide temporary workers, it would be a good idea to review the insurance
coverage the staffing agency provides. In many cases, they will provide workers’ compensation, however the
deductible will be large. OSHA (2014) holds that, in most cases, the host employer and the staffing agency
will be joint employers.
What does this mean? In your required unit resources reading, we learn that OSHA considers the host
employer, in many cases, to be the one responsible for recording the injury or illness on their OSHA log. The
key factor here is supervision and direction. If the host contractor is providing the day-to-day supervision, the
temporary worker becomes an employee of the host employer. This can, and has, resulted in the temporary
worker being covered under the host employer’s workers compensation policy.
In a case several years ago, several temporary workers were hired at a project to do general labor. One of
them fell and sustained a head injury which eventually led to his death. The staffing agency claimed that
because the host employer provided the direct supervision, the employee belonged to the host employer. The
staffing agency did have workers’ compensation insurance; however they also had a million dollar deductible,
meaning that everything up to that million dollars came out of the staffing agency’s pocket.
If you have used a staffing agency, you may have noticed that the workers will bring their “tickets” to be
signed by the host employer’s supervisor at the end of each day. Does your company read the back of those
tickets? They are essentially a contract you are agreeing to abide by. Many host employers now use a
contract with the staffing agency and insist that they provide their own supervision, much like any other
contracted or subcontracted firm. This can provide protections for the host employer. Now, as we read above,
while the worker cannot sue the employer under workers’ compensation, contracted employees are able, in
most cases, to sue the host employer under their general liability policy. But that is another story for another
day.
This rolls us right into prequalifying our contractors. We should be looking at several factors when hiring
contractors. We should be using staffing agencies and making sure they have their own supervision—
workers’ compensation and other insurance is one of those areas.
Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
There are some great methods to ensure the safety of all, even before beginning work. One of the best ways
is to do your homework! Prequalification of contractors is a great way to ascertain whether or not they have a
history of injuries, fatalities, or violations. Check their past performance. Review their safety program. Some
companies perform their own prequalification; some use a third-party to review a contractor’s performance
history. Either way you go, it is a best practice to know who you are working with.
Convincing your company to perform prequalifications before hiring contractors is one of the best ways to
gauge the safety knowledge of those you will be working with. Of course, many small firms may not have
strong safety programs. The independent contractor will rely on the host employer to provide the rules for the
project. The staffing agency should work with the host employer to ensure that their employees are in tune
with your policies and programs.
It is a good practice to require that the contractor provide a site safety representative with a site specific safety
plan developed for the work they will be performing on the particular project. A generic corporate safety
manual is not a site specific safety plan (SSSP). Contractors should know and understand the work they are
to perform and the environment in which they will be performing it. Once you have your own SSSP
developed, you can share it with your contractors so they can understand what is expected of them before
they come on site, and formulate their own SSSP for their specific work. By submitting an SSSP, it
demonstrates that they have knowledge of the hazards they may encounter. Remember to require that they
submit an example of their Pre-task Analysis (PTA) or Job Safety Analysis (JSA).
OSH 2304, Introduction to Contractor Safety 4
UNIT x STUDY GUIDE
Title
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
International Risk Management Institute. (n.d.). Insurance. https://www.irmi.com/term/insurance-
definitions/insurance
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– Who’s on First?
– Compare and Contrast Insurance Requirements
– So Who Covers These Workers?
– Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
– References
**## UnitIVJournal2304.docx**
Unit IV Journal 2304
In the Unit Reading Assignment, we learn about OSHA's Safety and Health Management Guidelines and the "Core Elements" for Communication and Coordination for Host Employers, Contractors, and Staffing Agencies.
Think about the contractors your company uses. Do you prequalify them? If so, what criteria do you use? If not, do you think it is a good idea to prequalify contractors? Why, or why not?
Considering that many independent contractors and temporary workers are not direct, full-time employees, and may come from many different industries, backgrounds and cultures, how would you ensure everyone understands the safety message?
Who is responsible for overseeing their safety?
Who is responsible for insurance coverages and OSHA Log reporting? Does it make a difference who is supervising and directing their work? Why or why not?
Understanding that multiple trades may be working together, how would you manage the program so that they do not create hazards for each other?
Your journal entry must be at least 200 words in length. No references or citations are necessary.
**## UnitIV.pdf**
OSH 2304, Introduction to Contractor Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
4. Summarize methods for ensuring contractor accountability.
4.1 Identify relationships between host employer and contractor liability.
4.2 Compare and contrast insurance requirements.
4.3 Develop best practices for contractor prequalifications.
Required Unit Resources
Chapter 5: Workers’ Compensation and Other Kinds of Construction Insurance
In order to access the following resources, click the link below.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs: Communication and coordination for host employers, contractors, and staffing agencies.
United States Department of Labor. https://www.osha.gov/shpguidelines/communication.html
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
Wilbanks, D. W. (2019, July). Contractor safety prequalification: The significant limitations of loss rates.
Professional Safety, 64(7), 22–26.
https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-
journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337
Unit Lesson
Who’s on First?
We touched briefly in Units II and III on the relationships between the controlling (host) contractor, and the
contractor or subcontractor roles. Let’s look a little more deeply into the way this actually works.
In the unit reading assignment, we look at what Occupational Safety and Health Administration (OSHA) has to
recommend regarding contractors, subcontractors, independent contractors, and temporary help from staffing
agencies. The key issue here is communication. Why is this so important? Would you want to accept a job not
knowing anything about the hazards? Letting everyone know what hazards may be present, how to avoid
them, and how to report accidental contact with them is part of the host employer’s responsibility. Think of it
this way. If you invite someone to your home, and you know that your front step is damaged and someone
could fall through it, would you fix the step, route a path around it, tell them to avoid that step, or take the
chance that they will see it for themselves? Of course, fixing the step is the best choice, but in the event that
is not possible and there is no avoiding it, you would want to make them aware of it so they can avoid contact
themselves.
Communication really is where it all starts. As the contract manager, construction manager, or general
contractor, your company is considered to be the host employer. You control the entire site. As the employer
in control of the entire site, it is your responsibility to recognize and identify potential hazards and work to
eliminate them. Communication is a two-way street. It is also the host employer’s responsibility to listen to the
UNIT IV STUDY GUIDE
Contractor Prequalification
and Insurance
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/shpguidelines/communication.html](https://www.osha.gov/shpguidelines/communication.html)
[https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf](https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf)
[https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337](https://libraryresources.columbiasouthern.edu/login?url=https://www.proquest.com/scholarly-journals/contractor-safety-prequalification-significant/docview/2251995068/se-2?accountid=33337)
OSH 2304, Introduction to Contractor Safety 2
UNIT x STUDY GUIDE
Title
contractors and to ask what hazards their work will bring to the site. As the host employer, you are
responsible to find out what those hazards are.
Working with the contractors, you must understand what their operations entail, how they interact with other
operations, and the hazards that may be added to the site as a whole. Each phase of a project will bring its
own unique hazards, and it is up to you to ensure communication about these is transmitted to everyone. How
are you going to accomplish this?
Coordination between all is critical. Holding weekly coordination meetings to discuss not only the ongoing
work, but the hazards involved is crucial in ensuring everyone is made aware of them. There may be multiple
activities going on in the same area and without coordination, if so, nobody is going to know what the other is
doing, and that can cause chaos. Consider this example from building construction—your electricians need to
work in the same area as your plumbers, at the same time. Ladders everywhere! And materials all over the
place. Let’s add in some HVAC work, because the ductwork also has to be installed. So now we have scissor
lifts running around and pallet jacks trying to make their way through the mess. All of these activities go hand
in hand, and all have to be installed in coordination with each other. If you start installing the ductwork before
the plumbing or fire sprinkler pipes go in, how do you reach above the ductwork to get where you need to be?
(I have seen workers try to climb on the ductwork to get to the plumbing lines!).
Compare and Contrast Insurance Requirements
Preparing for the worst. Insurance can be defined as a contract between the insurer (i.e., an insurance
company) and the insured (person or company who purchase the policy) to reimburse for losses under
predetermined circumstances in exchange for a fee (the premium). What does this mean to you in plain
language? The English commonly use the term assurance, which has the same meaning as insurance in the
United States (International Risk Management Institute, n.d.).
For this course, we are only going to look at workers’ compensation. This is the type of insurance we, as
safety professionals, deal with most regularly. When a worker is injured as a part of doing their job, in most
cases, measures are in place to ensure they are taken care of. They do not have to pay for their own medical
treatment or therapy, and if they lose time from work, they will receive a portion of their average wages (after
a waiting period, in most states). This serves two purposes: 1) to get the worker healthy and whole and back
to work; and 2) to eliminate the threat of lawsuits against the employer. This is the case in most industries, but
not all, and workers’ compensation will vary from state to state, as it is regulated at the state level (Goetsch,
2018).
This insurance only covers employees. In the required unit resource readings, we look at different levels of
who is considered an employee, and who is not. Now, here is where this gets a little complicated in terms of
contractors. Let’s look at the different levels of contractors.
Your company may hire a contractor to do some work in your facility that your own work force would not
normally do, such as repairs, modifications, additions, or other work. Again, some of you might call these
turnarounds or shutdowns. Any work that your own company does not self-perform will likely be contracted
out. Now, this work may require a whole company to do the work, or just a person or two. Maybe you just
need to have landscaping maintenance. Or hire a single consultant.
So Who Covers These Workers?
In most cases, the contractor/subcontractor for larger work will have their own workers’ compensation
insurance that covers their own employees. But let’s look at this: in the consultant’s case, they should have
what is called professional liability insurance, which should be part of the contract you have with them,
protecting your company from unforeseen events.
In other cases where you might hire an independent contractor, such as a lawn care firm, how do you handle
this? Do you check to see if they have insurance, and are bonded and licensed? Going back to the
contractor/subcontractor that your company brings in to do major work, are you checking to see if they have
the right coverage in place? What happens if they have all temporary workers performing the tasks? How are
they covered?
OSH 2304, Introduction to Contractor Safety 3
UNIT x STUDY GUIDE
Title
In the required unit resources reading, we learn that there are many different definitions of employee. How do
we make sure all workers on our sites are covered under workers’ compensation? How do we ensure that
those uncovered workers cam not turn around and make claims against our companies? If your company
uses a staffing agency to provide temporary workers, it would be a good idea to review the insurance
coverage the staffing agency provides. In many cases, they will provide workers’ compensation, however the
deductible will be large. OSHA (2014) holds that, in most cases, the host employer and the staffing agency
will be joint employers.
What does this mean? In your required unit resources reading, we learn that OSHA considers the host
employer, in many cases, to be the one responsible for recording the injury or illness on their OSHA log. The
key factor here is supervision and direction. If the host contractor is providing the day-to-day supervision, the
temporary worker becomes an employee of the host employer. This can, and has, resulted in the temporary
worker being covered under the host employer’s workers compensation policy.
In a case several years ago, several temporary workers were hired at a project to do general labor. One of
them fell and sustained a head injury which eventually led to his death. The staffing agency claimed that
because the host employer provided the direct supervision, the employee belonged to the host employer. The
staffing agency did have workers’ compensation insurance; however they also had a million dollar deductible,
meaning that everything up to that million dollars came out of the staffing agency’s pocket.
If you have used a staffing agency, you may have noticed that the workers will bring their “tickets” to be
signed by the host employer’s supervisor at the end of each day. Does your company read the back of those
tickets? They are essentially a contract you are agreeing to abide by. Many host employers now use a
contract with the staffing agency and insist that they provide their own supervision, much like any other
contracted or subcontracted firm. This can provide protections for the host employer. Now, as we read above,
while the worker cannot sue the employer under workers’ compensation, contracted employees are able, in
most cases, to sue the host employer under their general liability policy. But that is another story for another
day.
This rolls us right into prequalifying our contractors. We should be looking at several factors when hiring
contractors. We should be using staffing agencies and making sure they have their own supervision—
workers’ compensation and other insurance is one of those areas.
Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
There are some great methods to ensure the safety of all, even before beginning work. One of the best ways
is to do your homework! Prequalification of contractors is a great way to ascertain whether or not they have a
history of injuries, fatalities, or violations. Check their past performance. Review their safety program. Some
companies perform their own prequalification; some use a third-party to review a contractor’s performance
history. Either way you go, it is a best practice to know who you are working with.
Convincing your company to perform prequalifications before hiring contractors is one of the best ways to
gauge the safety knowledge of those you will be working with. Of course, many small firms may not have
strong safety programs. The independent contractor will rely on the host employer to provide the rules for the
project. The staffing agency should work with the host employer to ensure that their employees are in tune
with your policies and programs.
It is a good practice to require that the contractor provide a site safety representative with a site specific safety
plan developed for the work they will be performing on the particular project. A generic corporate safety
manual is not a site specific safety plan (SSSP). Contractors should know and understand the work they are
to perform and the environment in which they will be performing it. Once you have your own SSSP
developed, you can share it with your contractors so they can understand what is expected of them before
they come on site, and formulate their own SSSP for their specific work. By submitting an SSSP, it
demonstrates that they have knowledge of the hazards they may encounter. Remember to require that they
submit an example of their Pre-task Analysis (PTA) or Job Safety Analysis (JSA).
OSH 2304, Introduction to Contractor Safety 4
UNIT x STUDY GUIDE
Title
References
Goetsch, D. L. (2018). Construction safety and the OSHA standards (2nd ed.). Pearson.
International Risk Management Institute. (n.d.). Insurance. https://www.irmi.com/term/insurance-
definitions/insurance
Occupational Safety and Health Administration. (2014). Injury and illness recordkeeping requirements
(Temporary Worker Initiative Bulletin No. 1). United States Department of Labor.
https://www.osha.gov/temp_workers/OSHA_TWI_Bulletin.pdf
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– Who’s on First?
– Compare and Contrast Insurance Requirements
– So Who Covers These Workers?
– Develop Best Practices for Contractor Pre-Qualifications: Choosing the Best
– References
See attached **files (2)** – ## OSHA2303UnitIIIPowerPointPresentation.docx – ## UnitIII.pdf **## OSHA2303UnitIIIPowerPointPresentation.docx** OSHA 2303 Unit III PowerPoint Presentation Assignment Instructions: Before you begin this assignment, review the Occupational Safety and Health Administration…
Immediate access to the full model answer, formatted citations, and rubric breakdown.
Have this question answered from scratch according to your specific instructions and deadline.
Order on TutorsGallery →See attached
**files (2)**
– ## OSHA2303UnitIIIPowerPointPresentation.docx
– ## UnitIII.pdf
**## OSHA2303UnitIIIPowerPointPresentation.docx**
OSHA 2303 Unit III PowerPoint Presentation
Assignment Instructions:
Before you begin this assignment, review the Occupational Safety and Health Administration's (OSHA)
[Hazard Communication Standard, 29 CFR §1910.1200.](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
After you have reviewed the webpages above, imagine that you have been asked to present to the senior leadership team at a chemical manufacturing company. The goal of the presentation is to inform senior leadership about OSHA Hazard Communication regulations and hazardous materials control technologies, so they can develop a hazardous communications program for their company.
In a PowerPoint presentation, address the areas below.
· Classify hazardous waste using Environmental Protection Agency (EPA) regulations.
· Explain the purpose of OSHA and its importance to management practices.
· Explain OSHA’s hierarchy of controls for hazards and provide an example of a control method for each level of the hierarchy (four total).
· Explain why laws, regulations, and standards need to be considered when drafting a communications program.
· Summarize the requirements of the OSHA Hazardous Communication program that regulates the control of hazardous materials in the workplace.
· Provide the steps that leadership should take to develop their hazardous communications program at their company.
· Describe common hazardous materials control technologies.
Your PowerPoint presentation must be at least 12 slides in length, not counting the title slide and references slides. Support your presentation with at least two references. Use APA Style for in-text citations and references. Your references can include but are not limited to the textbook or any OSHA websites. Support your presentation with at least two images or graphics. Speaker notes are not required for this assignment.
Reference:
Haight, J. M., Butler, T. S., Caccavale, S., Campbell, S. L., Fender, D. L., & Hamid (2013).
_Hazardous Material Management and Hazard Communication_. American Society of Safety Professionals (ASSP).
[https://online.vitalsource.com/books/9781885581822](https://online.vitalsource.com/books/9781885581822)
**## UnitIII.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit III
Upon completion of this unit, students should be able to:
2. Recognize common hazardous materials control technologies.
2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)
Hazardous Communication program that regulate the control of hazardous materials in the
workplace.
2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a
workplace.
Required Unit Resources
Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100
In order to access the following resources, click the links below.
Review these recommended practices for safety and health programs from the U.S. Department of Labor on
pp. 20–23 of the following publication.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs (OSHA Publication No. 3885).
https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
Learn more about the hierarchy controls by reviewing the following website.
National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease
Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/
Review the following webpage to learn about chemical hazards and toxic substances.
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Details of the Hazard Communication Standard are listed below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and
hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS
Unit Lesson
Hazardous Materials in the Workplace
Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and
Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk
assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be
implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making
UNIT III STUDY GUIDE
Common Methods Used for Control of
Hazardous Materials in the Workplace
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.cdc.gov/niosh/topics/hierarchy/](https://www.cdc.gov/niosh/topics/hierarchy/)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
sure that workers who have the potential for exposure are well-informed of the risk so they can take
appropriate measures to protect themselves.
The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information
they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard
was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee
representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in
1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially
unchanged until the adoption of the United Nations Globally Harmonized System of Classification and
Labeling of Chemicals (GHS) in March 2012.
Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its
existence. The original standard was performance-based, meaning that many of the provisions stated the
desired result but did not give details on how to get to that point. It allowed for much interpretation among
employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the
years, it is obvious that the two groups often have different interpretations of the standard. Additional
evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI)
that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the
various interpretations.
Two topics of the original standard that were performance-based and have been the source of much
confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which
were originally called material safety data sheets (MSDSs). Both have been changed to specification
standards, meaning they leave less room for interpretation.
Hazardous Material Labels
The HazCom Standard has always required chemical manufacturers and importers to label their hazardous
material products. The first step in this process is to classify chemicals in accordance with the guidelines
provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard
determination was left up to the manufacturer, and no specific criteria were provided.
Also, prior to the 2012 revision, the requirements for labels included only the name and address of the
manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA,
1970d). As one might expect, buying the same chemical from two different manufacturers would likely result
in two different labels. Many employers began developing their own in-house labeling systems, or they used
labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation
(DOT). These actions helped with consistency, but whether they met the appropriate requirement was still
open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide
provides examples.
The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all
labels; these specifications have been listed below.
• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the
identifier, but it must match the identifier used on the accompanying SDS.
• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and
"Warning" is used for less serious hazards. Only one signal word may appear on a label.
• Hazard statements: This is a brief description of the nature of the hazards of the chemical.
• Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.
Four types of precautionary statements are identified: prevention, response, storage, and disposal.
• Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only
requires the use of eight of the symbols (the pictogram for an environmental hazard is not required).
• Manufacturer information: Name, address, and telephone number of the chemical manufacturer or
importer must be included (OSHA, 2013a).
[https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT](https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT)
[https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf](https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers
contain the same information in the same format, but OSHA still provides employers with some options. As
noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been
spent on developing these in-house systems, and many of them likely meet the intent of the HazCom
Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the
1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that
developed their own systems and those that sell OSHA-compliant labels; however, this is much like a
performance standard and may be subject to interpretation.
SDSs
Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in
format. They have been readily available in electronic versions and on the internet for more than 10 years.
The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA,
2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is
standardized across all workplaces.
• Section 1: Identification
• Section 2: Hazard(s)
• Section 3: Composition/Information on Ingredients
• Section 4: First Aid Measures
• Section 5: Fire Fighting Measures
• Section 6: Accidental Release Measures
• Section 7: Handling and Storage
• Section 8: Exposure Controls/Personal Protection
• Section 9: Physical and Chemical Properties
• Section 10: Stability and Reactivity
• Section 11: Toxicological Information
Sample HazCom label
(OSHA, 2013a)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
• Section 12: Ecological Information
• Section 13: Disposal Considerations
• Section 14: Transport Information
• Section 15: Regulatory Information
• Section 16: Other Information
OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency
(EPA) and the DOT regulations may require this information. The chemical manufacturer or importer
preparing the SDS is required to make that determination. From a practical standpoint, the information in
these sections would certainly help the employer with EPA and DOT compliance issues.
The standard requires SDSs to be readily
available to all employees on all work shifts.
Over the years, OSHA has interpreted readily
available to mean immediate and without delay
(Haight, 2012). In addition, access to SDS
information must not require assistance (e.g.,
requesting a copy from a supervisor or needing
an intermediary to gain computer access for
electronic versions).
SDSs are required to be in English, but it
makes sense to also make them, or the
information they contain, available in all
languages that are represented in the
organization. Keep in mind that all employees
have a right to know and understand the
hazards of the chemicals with which they work.
Even if only one employee speaks a language
other than English, that one employee not
understanding the hazards can create a
dangerous situation for all employees.
Even when all employees have been informed of the risks associated with the hazardous materials in the
workplace, there may be risks associated with the hazardous materials that are unacceptable. The
assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing
exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit
showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to
implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH)
and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated
with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.
Do these workers know the hazards of the containers
with which they are working? Are the containers
clearly marked? Are they in compliance with the
HazCom Standard?
(Henshall, 2008)
(NIOSH, n.d.-a)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
The controls are arranged with the most effective controls at the top and the least effective controls at the
bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the
hazardous materials from the workplace. Substitution also removes the hazardous materials from the
workplace but substitutes another material that must then be evaluated for risk. Since these two controls
remove the original hazardous materials from the workplace, they are often combined into one category
called elimination/substitution. This control method may be the most effective, but it is also the most difficult to
implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a
chemical process or client specifications and no other hazardous materials will work. In those cases,
elimination/substitution are not viable control methods.
The next most effective control option involves the use of engineering controls. Note that engineering controls
do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for
exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the
worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material.
One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two
most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation
systems. A general dilution ventilation system reduces the concentration of a hazardous material by
introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation
system collects the air near the source and moves the contaminated air somewhere outside the work area
where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation
system and the specifications for that system will vary depending on several variables including air
concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other
examples of some commonly used engineering controls include the use of sound deadening materials around
machines and lead-lined walls around ionizing radiation sources.
Administrative controls are not as effective as engineering controls because they do not take any action to
reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work
in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a
work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot
environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the
risk of developing a heat illness can be reduced.
The control measure that is the least effective is the use of personal protective equipment (PPE). The reason
that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the
workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many
sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE
manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected.
Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used?
OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or
impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using
more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used
to reduce risk during the time period when engineering and administrative controls are being implemented.
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
Henshall, G. (2008). FEMA – 39025 – EPA workers locating hazardous material moved by Ike in Texas
[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_-
_EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg
National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Occupational Safety and Health Administration. (1970a). Occupational safety and health standards: Personal
protective equipment: General requirements (OSHA Standard No. 1910.132). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS
Occupational Safety and Health Administration. (1970b). Occupational safety and health standards: Toxic and
hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppA
Occupational Safety and Health Administration. (1970c). Occupational safety and health standards: Toxic and
hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppB
Occupational Safety and Health Administration. (1970d). Occupational safety and health standards: Toxic and
hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United
States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppC
Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.
United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history
Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and
pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3636.pdf
Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data
sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3514.pdf
Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of
Labor. https://www.osha.gov/SLTC/ventilation/index.html
OSH 2303, Hazardous Materials Safety 7
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.
One important task is identifying hazards in the workplace and performing a risk assessment for those
hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration
(OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the
website below, and use the tool to see if your skills at identifying hazards are up-to-date.
Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States
Department of Labor. https://www.osha.gov/hazfinder/index.html
OSHA has also developed an electronic health and safety program that is accessible on their website. The
program contains some good information about identifying hazards and some control methods. Access the
program below, and review the material.
Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).
United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html
[https://www.osha.gov/hazfinder/index.html](https://www.osha.gov/hazfinder/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 III
– Required Unit Resources
– Unit Lesson
– Hazardous Materials in the Workplace
– Hazardous Material Labels
– SDSs
– References
– Learning Activities (Nongraded)
**## UnitIII.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit III
Upon completion of this unit, students should be able to:
2. Recognize common hazardous materials control technologies.
2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)
Hazardous Communication program that regulate the control of hazardous materials in the
workplace.
2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a
workplace.
Required Unit Resources
Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100
In order to access the following resources, click the links below.
Review these recommended practices for safety and health programs from the U.S. Department of Labor on
pp. 20–23 of the following publication.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs (OSHA Publication No. 3885).
https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
Learn more about the hierarchy controls by reviewing the following website.
National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease
Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/
Review the following webpage to learn about chemical hazards and toxic substances.
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Details of the Hazard Communication Standard are listed below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and
hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS
Unit Lesson
Hazardous Materials in the Workplace
Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and
Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk
assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be
implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making
UNIT III STUDY GUIDE
Common Methods Used for Control of
Hazardous Materials in the Workplace
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.cdc.gov/niosh/topics/hierarchy/](https://www.cdc.gov/niosh/topics/hierarchy/)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
sure that workers who have the potential for exposure are well-informed of the risk so they can take
appropriate measures to protect themselves.
The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information
they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard
was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee
representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in
1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially
unchanged until the adoption of the United Nations Globally Harmonized System of Classification and
Labeling of Chemicals (GHS) in March 2012.
Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its
existence. The original standard was performance-based, meaning that many of the provisions stated the
desired result but did not give details on how to get to that point. It allowed for much interpretation among
employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the
years, it is obvious that the two groups often have different interpretations of the standard. Additional
evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI)
that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the
various interpretations.
Two topics of the original standard that were performance-based and have been the source of much
confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which
were originally called material safety data sheets (MSDSs). Both have been changed to specification
standards, meaning they leave less room for interpretation.
Hazardous Material Labels
The HazCom Standard has always required chemical manufacturers and importers to label their hazardous
material products. The first step in this process is to classify chemicals in accordance with the guidelines
provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard
determination was left up to the manufacturer, and no specific criteria were provided.
Also, prior to the 2012 revision, the requirements for labels included only the name and address of the
manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA,
1970d). As one might expect, buying the same chemical from two different manufacturers would likely result
in two different labels. Many employers began developing their own in-house labeling systems, or they used
labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation
(DOT). These actions helped with consistency, but whether they met the appropriate requirement was still
open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide
provides examples.
The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all
labels; these specifications have been listed below.
• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the
identifier, but it must match the identifier used on the accompanying SDS.
• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and
"Warning" is used for less serious hazards. Only one signal word may appear on a label.
• Hazard statements: This is a brief description of the nature of the hazards of the chemical.
• Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.
Four types of precautionary statements are identified: prevention, response, storage, and disposal.
• Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only
requires the use of eight of the symbols (the pictogram for an environmental hazard is not required).
• Manufacturer information: Name, address, and telephone number of the chemical manufacturer or
importer must be included (OSHA, 2013a).
[https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT](https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT)
[https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf](https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers
contain the same information in the same format, but OSHA still provides employers with some options. As
noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been
spent on developing these in-house systems, and many of them likely meet the intent of the HazCom
Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the
1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that
developed their own systems and those that sell OSHA-compliant labels; however, this is much like a
performance standard and may be subject to interpretation.
SDSs
Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in
format. They have been readily available in electronic versions and on the internet for more than 10 years.
The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA,
2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is
standardized across all workplaces.
• Section 1: Identification
• Section 2: Hazard(s)
• Section 3: Composition/Information on Ingredients
• Section 4: First Aid Measures
• Section 5: Fire Fighting Measures
• Section 6: Accidental Release Measures
• Section 7: Handling and Storage
• Section 8: Exposure Controls/Personal Protection
• Section 9: Physical and Chemical Properties
• Section 10: Stability and Reactivity
• Section 11: Toxicological Information
Sample HazCom label
(OSHA, 2013a)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
• Section 12: Ecological Information
• Section 13: Disposal Considerations
• Section 14: Transport Information
• Section 15: Regulatory Information
• Section 16: Other Information
OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency
(EPA) and the DOT regulations may require this information. The chemical manufacturer or importer
preparing the SDS is required to make that determination. From a practical standpoint, the information in
these sections would certainly help the employer with EPA and DOT compliance issues.
The standard requires SDSs to be readily
available to all employees on all work shifts.
Over the years, OSHA has interpreted readily
available to mean immediate and without delay
(Haight, 2012). In addition, access to SDS
information must not require assistance (e.g.,
requesting a copy from a supervisor or needing
an intermediary to gain computer access for
electronic versions).
SDSs are required to be in English, but it
makes sense to also make them, or the
information they contain, available in all
languages that are represented in the
organization. Keep in mind that all employees
have a right to know and understand the
hazards of the chemicals with which they work.
Even if only one employee speaks a language
other than English, that one employee not
understanding the hazards can create a
dangerous situation for all employees.
Even when all employees have been informed of the risks associated with the hazardous materials in the
workplace, there may be risks associated with the hazardous materials that are unacceptable. The
assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing
exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit
showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to
implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH)
and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated
with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.
Do these workers know the hazards of the containers
with which they are working? Are the containers
clearly marked? Are they in compliance with the
HazCom Standard?
(Henshall, 2008)
(NIOSH, n.d.-a)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
The controls are arranged with the most effective controls at the top and the least effective controls at the
bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the
hazardous materials from the workplace. Substitution also removes the hazardous materials from the
workplace but substitutes another material that must then be evaluated for risk. Since these two controls
remove the original hazardous materials from the workplace, they are often combined into one category
called elimination/substitution. This control method may be the most effective, but it is also the most difficult to
implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a
chemical process or client specifications and no other hazardous materials will work. In those cases,
elimination/substitution are not viable control methods.
The next most effective control option involves the use of engineering controls. Note that engineering controls
do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for
exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the
worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material.
One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two
most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation
systems. A general dilution ventilation system reduces the concentration of a hazardous material by
introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation
system collects the air near the source and moves the contaminated air somewhere outside the work area
where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation
system and the specifications for that system will vary depending on several variables including air
concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other
examples of some commonly used engineering controls include the use of sound deadening materials around
machines and lead-lined walls around ionizing radiation sources.
Administrative controls are not as effective as engineering controls because they do not take any action to
reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work
in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a
work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot
environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the
risk of developing a heat illness can be reduced.
The control measure that is the least effective is the use of personal protective equipment (PPE). The reason
that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the
workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many
sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE
manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected.
Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used?
OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or
impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using
more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used
to reduce risk during the time period when engineering and administrative controls are being implemented.
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
Henshall, G. (2008). FEMA – 39025 – EPA workers locating hazardous material moved by Ike in Texas
[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_-
_EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg
National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Occupational Safety and Health Administration. (1970a). Occupational safety and health standards: Personal
protective equipment: General requirements (OSHA Standard No. 1910.132). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS
Occupational Safety and Health Administration. (1970b). Occupational safety and health standards: Toxic and
hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppA
Occupational Safety and Health Administration. (1970c). Occupational safety and health standards: Toxic and
hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppB
Occupational Safety and Health Administration. (1970d). Occupational safety and health standards: Toxic and
hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United
States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppC
Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.
United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history
Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and
pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3636.pdf
Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data
sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3514.pdf
Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of
Labor. https://www.osha.gov/SLTC/ventilation/index.html
OSH 2303, Hazardous Materials Safety 7
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.
One important task is identifying hazards in the workplace and performing a risk assessment for those
hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration
(OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the
website below, and use the tool to see if your skills at identifying hazards are up-to-date.
Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States
Department of Labor. https://www.osha.gov/hazfinder/index.html
OSHA has also developed an electronic health and safety program that is accessible on their website. The
program contains some good information about identifying hazards and some control methods. Access the
program below, and review the material.
Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).
United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html
[https://www.osha.gov/hazfinder/index.html](https://www.osha.gov/hazfinder/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 III
– Required Unit Resources
– Unit Lesson
– Hazardous Materials in the Workplace
– Hazardous Material Labels
– SDSs
– References
– Learning Activities (Nongraded)
**## OSHA2303UnitIIIPowerPointPresentation.docx**
OSHA 2303 Unit III PowerPoint Presentation
Assignment Instructions:
Before you begin this assignment, review the Occupational Safety and Health Administration's (OSHA)
[Hazard Communication Standard, 29 CFR §1910.1200.](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
After you have reviewed the webpages above, imagine that you have been asked to present to the senior leadership team at a chemical manufacturing company. The goal of the presentation is to inform senior leadership about OSHA Hazard Communication regulations and hazardous materials control technologies, so they can develop a hazardous communications program for their company.
In a PowerPoint presentation, address the areas below.
· Classify hazardous waste using Environmental Protection Agency (EPA) regulations.
· Explain the purpose of OSHA and its importance to management practices.
· Explain OSHA’s hierarchy of controls for hazards and provide an example of a control method for each level of the hierarchy (four total).
· Explain why laws, regulations, and standards need to be considered when drafting a communications program.
· Summarize the requirements of the OSHA Hazardous Communication program that regulates the control of hazardous materials in the workplace.
· Provide the steps that leadership should take to develop their hazardous communications program at their company.
· Describe common hazardous materials control technologies.
Your PowerPoint presentation must be at least 12 slides in length, not counting the title slide and references slides. Support your presentation with at least two references. Use APA Style for in-text citations and references. Your references can include but are not limited to the textbook or any OSHA websites. Support your presentation with at least two images or graphics. Speaker notes are not required for this assignment.
Reference:
Haight, J. M., Butler, T. S., Caccavale, S., Campbell, S. L., Fender, D. L., & Hamid (2013).
_Hazardous Material Management and Hazard Communication_. American Society of Safety Professionals (ASSP).
[https://online.vitalsource.com/books/9781885581822](https://online.vitalsource.com/books/9781885581822)
**## UnitIII.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit III
Upon completion of this unit, students should be able to:
2. Recognize common hazardous materials control technologies.
2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)
Hazardous Communication program that regulate the control of hazardous materials in the
workplace.
2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a
workplace.
Required Unit Resources
Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100
In order to access the following resources, click the links below.
Review these recommended practices for safety and health programs from the U.S. Department of Labor on
pp. 20–23 of the following publication.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs (OSHA Publication No. 3885).
https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
Learn more about the hierarchy controls by reviewing the following website.
National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease
Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/
Review the following webpage to learn about chemical hazards and toxic substances.
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Details of the Hazard Communication Standard are listed below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and
hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS
Unit Lesson
Hazardous Materials in the Workplace
Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and
Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk
assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be
implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making
UNIT III STUDY GUIDE
Common Methods Used for Control of
Hazardous Materials in the Workplace
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.cdc.gov/niosh/topics/hierarchy/](https://www.cdc.gov/niosh/topics/hierarchy/)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
sure that workers who have the potential for exposure are well-informed of the risk so they can take
appropriate measures to protect themselves.
The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information
they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard
was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee
representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in
1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially
unchanged until the adoption of the United Nations Globally Harmonized System of Classification and
Labeling of Chemicals (GHS) in March 2012.
Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its
existence. The original standard was performance-based, meaning that many of the provisions stated the
desired result but did not give details on how to get to that point. It allowed for much interpretation among
employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the
years, it is obvious that the two groups often have different interpretations of the standard. Additional
evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI)
that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the
various interpretations.
Two topics of the original standard that were performance-based and have been the source of much
confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which
were originally called material safety data sheets (MSDSs). Both have been changed to specification
standards, meaning they leave less room for interpretation.
Hazardous Material Labels
The HazCom Standard has always required chemical manufacturers and importers to label their hazardous
material products. The first step in this process is to classify chemicals in accordance with the guidelines
provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard
determination was left up to the manufacturer, and no specific criteria were provided.
Also, prior to the 2012 revision, the requirements for labels included only the name and address of the
manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA,
1970d). As one might expect, buying the same chemical from two different manufacturers would likely result
in two different labels. Many employers began developing their own in-house labeling systems, or they used
labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation
(DOT). These actions helped with consistency, but whether they met the appropriate requirement was still
open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide
provides examples.
The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all
labels; these specifications have been listed below.
• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the
identifier, but it must match the identifier used on the accompanying SDS.
• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and
"Warning" is used for less serious hazards. Only one signal word may appear on a label.
• Hazard statements: This is a brief description of the nature of the hazards of the chemical.
• Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.
Four types of precautionary statements are identified: prevention, response, storage, and disposal.
• Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only
requires the use of eight of the symbols (the pictogram for an environmental hazard is not required).
• Manufacturer information: Name, address, and telephone number of the chemical manufacturer or
importer must be included (OSHA, 2013a).
[https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT](https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT)
[https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf](https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers
contain the same information in the same format, but OSHA still provides employers with some options. As
noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been
spent on developing these in-house systems, and many of them likely meet the intent of the HazCom
Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the
1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that
developed their own systems and those that sell OSHA-compliant labels; however, this is much like a
performance standard and may be subject to interpretation.
SDSs
Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in
format. They have been readily available in electronic versions and on the internet for more than 10 years.
The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA,
2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is
standardized across all workplaces.
• Section 1: Identification
• Section 2: Hazard(s)
• Section 3: Composition/Information on Ingredients
• Section 4: First Aid Measures
• Section 5: Fire Fighting Measures
• Section 6: Accidental Release Measures
• Section 7: Handling and Storage
• Section 8: Exposure Controls/Personal Protection
• Section 9: Physical and Chemical Properties
• Section 10: Stability and Reactivity
• Section 11: Toxicological Information
Sample HazCom label
(OSHA, 2013a)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
• Section 12: Ecological Information
• Section 13: Disposal Considerations
• Section 14: Transport Information
• Section 15: Regulatory Information
• Section 16: Other Information
OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency
(EPA) and the DOT regulations may require this information. The chemical manufacturer or importer
preparing the SDS is required to make that determination. From a practical standpoint, the information in
these sections would certainly help the employer with EPA and DOT compliance issues.
The standard requires SDSs to be readily
available to all employees on all work shifts.
Over the years, OSHA has interpreted readily
available to mean immediate and without delay
(Haight, 2012). In addition, access to SDS
information must not require assistance (e.g.,
requesting a copy from a supervisor or needing
an intermediary to gain computer access for
electronic versions).
SDSs are required to be in English, but it
makes sense to also make them, or the
information they contain, available in all
languages that are represented in the
organization. Keep in mind that all employees
have a right to know and understand the
hazards of the chemicals with which they work.
Even if only one employee speaks a language
other than English, that one employee not
understanding the hazards can create a
dangerous situation for all employees.
Even when all employees have been informed of the risks associated with the hazardous materials in the
workplace, there may be risks associated with the hazardous materials that are unacceptable. The
assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing
exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit
showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to
implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH)
and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated
with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.
Do these workers know the hazards of the containers
with which they are working? Are the containers
clearly marked? Are they in compliance with the
HazCom Standard?
(Henshall, 2008)
(NIOSH, n.d.-a)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
The controls are arranged with the most effective controls at the top and the least effective controls at the
bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the
hazardous materials from the workplace. Substitution also removes the hazardous materials from the
workplace but substitutes another material that must then be evaluated for risk. Since these two controls
remove the original hazardous materials from the workplace, they are often combined into one category
called elimination/substitution. This control method may be the most effective, but it is also the most difficult to
implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a
chemical process or client specifications and no other hazardous materials will work. In those cases,
elimination/substitution are not viable control methods.
The next most effective control option involves the use of engineering controls. Note that engineering controls
do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for
exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the
worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material.
One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two
most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation
systems. A general dilution ventilation system reduces the concentration of a hazardous material by
introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation
system collects the air near the source and moves the contaminated air somewhere outside the work area
where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation
system and the specifications for that system will vary depending on several variables including air
concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other
examples of some commonly used engineering controls include the use of sound deadening materials around
machines and lead-lined walls around ionizing radiation sources.
Administrative controls are not as effective as engineering controls because they do not take any action to
reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work
in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a
work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot
environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the
risk of developing a heat illness can be reduced.
The control measure that is the least effective is the use of personal protective equipment (PPE). The reason
that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the
workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many
sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE
manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected.
Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used?
OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or
impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using
more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used
to reduce risk during the time period when engineering and administrative controls are being implemented.
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
Henshall, G. (2008). FEMA – 39025 – EPA workers locating hazardous material moved by Ike in Texas
[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_-
_EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg
National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Occupational Safety and Health Administration. (1970a). Occupational safety and health standards: Personal
protective equipment: General requirements (OSHA Standard No. 1910.132). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS
Occupational Safety and Health Administration. (1970b). Occupational safety and health standards: Toxic and
hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppA
Occupational Safety and Health Administration. (1970c). Occupational safety and health standards: Toxic and
hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppB
Occupational Safety and Health Administration. (1970d). Occupational safety and health standards: Toxic and
hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United
States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppC
Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.
United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history
Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and
pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3636.pdf
Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data
sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3514.pdf
Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of
Labor. https://www.osha.gov/SLTC/ventilation/index.html
OSH 2303, Hazardous Materials Safety 7
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.
One important task is identifying hazards in the workplace and performing a risk assessment for those
hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration
(OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the
website below, and use the tool to see if your skills at identifying hazards are up-to-date.
Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States
Department of Labor. https://www.osha.gov/hazfinder/index.html
OSHA has also developed an electronic health and safety program that is accessible on their website. The
program contains some good information about identifying hazards and some control methods. Access the
program below, and review the material.
Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).
United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html
[https://www.osha.gov/hazfinder/index.html](https://www.osha.gov/hazfinder/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 III
– Required Unit Resources
– Unit Lesson
– Hazardous Materials in the Workplace
– Hazardous Material Labels
– SDSs
– References
– Learning Activities (Nongraded)
**## OSHA2303UnitIIIPowerPointPresentation.docx**
OSHA 2303 Unit III PowerPoint Presentation
Assignment Instructions:
Before you begin this assignment, review the Occupational Safety and Health Administration's (OSHA)
[Hazard Communication Standard, 29 CFR §1910.1200.](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
After you have reviewed the webpages above, imagine that you have been asked to present to the senior leadership team at a chemical manufacturing company. The goal of the presentation is to inform senior leadership about OSHA Hazard Communication regulations and hazardous materials control technologies, so they can develop a hazardous communications program for their company.
In a PowerPoint presentation, address the areas below.
· Classify hazardous waste using Environmental Protection Agency (EPA) regulations.
· Explain the purpose of OSHA and its importance to management practices.
· Explain OSHA’s hierarchy of controls for hazards and provide an example of a control method for each level of the hierarchy (four total).
· Explain why laws, regulations, and standards need to be considered when drafting a communications program.
· Summarize the requirements of the OSHA Hazardous Communication program that regulates the control of hazardous materials in the workplace.
· Provide the steps that leadership should take to develop their hazardous communications program at their company.
· Describe common hazardous materials control technologies.
Your PowerPoint presentation must be at least 12 slides in length, not counting the title slide and references slides. Support your presentation with at least two references. Use APA Style for in-text citations and references. Your references can include but are not limited to the textbook or any OSHA websites. Support your presentation with at least two images or graphics. Speaker notes are not required for this assignment.
Reference:
Haight, J. M., Butler, T. S., Caccavale, S., Campbell, S. L., Fender, D. L., & Hamid (2013).
_Hazardous Material Management and Hazard Communication_. American Society of Safety Professionals (ASSP).
[https://online.vitalsource.com/books/9781885581822](https://online.vitalsource.com/books/9781885581822)
**## UnitIII.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit III
Upon completion of this unit, students should be able to:
2. Recognize common hazardous materials control technologies.
2.1 Summarize the requirements of the Occupational Safety and Health Administration (OSHA)
Hazardous Communication program that regulate the control of hazardous materials in the
workplace.
2.2 Associate OSHA’s hierarchy of controls to the management of hazardous materials in a
workplace.
Required Unit Resources
Review Chapter 3: Hazard Communication and Right-to-Know Regulations Issues, pp. 86–100
In order to access the following resources, click the links below.
Review these recommended practices for safety and health programs from the U.S. Department of Labor on
pp. 20–23 of the following publication.
Occupational Safety and Health Administration. (2016). Recommended practices for safety and health
programs (OSHA Publication No. 3885).
https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf
Learn more about the hierarchy controls by reviewing the following website.
National Institute for Occupational Safety and Health. (2015). Hierarchy of controls. Centers for Disease
Control and Prevention. https://www.cdc.gov/niosh/topics/hierarchy/
Review the following webpage to learn about chemical hazards and toxic substances.
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Details of the Hazard Communication Standard are listed below.
Occupational Safety and Health Administration. (1970). Occupational safety and health standards: Toxic and
hazardous substances: Hazard communication (OSHA Standard No. 1910.1200). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS
Unit Lesson
Hazardous Materials in the Workplace
Hazardous materials in the workplace present some level of risk to occupants. The Occupational Safety and
Health Administration (OSHA) requires employers to evaluate that level of risk using some type of risk
assessment tool. When the level of risk associated with a chemical hazard is unacceptable, controls must be
implemented to reduce the risk to an acceptable level. One approach to reducing the level of risk is making
UNIT III STUDY GUIDE
Common Methods Used for Control of
Hazardous Materials in the Workplace
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf](https://www.osha.gov/shpguidelines/docs/OSHA_SHP_Recommended_Practices.pdf)
[https://www.cdc.gov/niosh/topics/hierarchy/](https://www.cdc.gov/niosh/topics/hierarchy/)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html](https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10099&p_table=STANDARDS)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
sure that workers who have the potential for exposure are well-informed of the risk so they can take
appropriate measures to protect themselves.
The OSHA Hazard Communication (HazCom) Standard is designed to provide workers with the information
they need to protect themselves from the risks associated with hazardous materials. The HazCom Standard
was originally published in 1984 after 10 years of difficult rulemaking negotiations with industry and employee
representative groups (OSHA, 2004). The original standard applied only to the manufacturing section, and in
1994, OSHA expanded the applicability of the standard to all employers. The standard remained essentially
unchanged until the adoption of the United Nations Globally Harmonized System of Classification and
Labeling of Chemicals (GHS) in March 2012.
Violations of the HazCom Standard have consistently been in the top 10 most-cited standards throughout its
existence. The original standard was performance-based, meaning that many of the provisions stated the
desired result but did not give details on how to get to that point. It allowed for much interpretation among
employers, and OSHA compliance officers. Given the number of noncompliance citations issued over the
years, it is obvious that the two groups often have different interpretations of the standard. Additional
evidence of the disagreements and confusion can be found in the hundreds of letters of interpretation (LOI)
that OSHA has issued about the standard. You can access the Standard Interpretations webpage to see the
various interpretations.
Two topics of the original standard that were performance-based and have been the source of much
confusion and interpretation over the years are the sections on labeling and safety data sheets (SDSs), which
were originally called material safety data sheets (MSDSs). Both have been changed to specification
standards, meaning they leave less room for interpretation.
Hazardous Material Labels
The HazCom Standard has always required chemical manufacturers and importers to label their hazardous
material products. The first step in this process is to classify chemicals in accordance with the guidelines
provided in Appendices A and B of the standard (OSHA, 1970b; OSHA, 1970c). Previously, hazard
determination was left up to the manufacturer, and no specific criteria were provided.
Also, prior to the 2012 revision, the requirements for labels included only the name and address of the
manufacturer or importer, the identification of the chemical, and the appropriate hazard warnings (OSHA,
1970d). As one might expect, buying the same chemical from two different manufacturers would likely result
in two different labels. Many employers began developing their own in-house labeling systems, or they used
labels from the National Fire Protection Association (NFPA) or from the U.S. Department of Transportation
(DOT). These actions helped with consistency, but whether they met the appropriate requirement was still
open for interpretation. The DOT Chart 15: Hazardous Materials Markings, Labeling and Placarding Guide
provides examples.
The 2012 HazCom Standard resolved most of the labeling issues by prescribing specific information for all
labels; these specifications have been listed below.
• Product identifier used on the SDS: The standard allows the chemical manufacturer to determine the
identifier, but it must match the identifier used on the accompanying SDS.
• Signal word: Two signal words are prescribed: "Danger" is used for the most serious hazards, and
"Warning" is used for less serious hazards. Only one signal word may appear on a label.
• Hazard statements: This is a brief description of the nature of the hazards of the chemical.
• Precautionary statements: This is a recommended measure to minimize or prevent adverse effects.
Four types of precautionary statements are identified: prevention, response, storage, and disposal.
• Pictograms: Nine graphic symbols are prescribed to identify specific hazard classes, but OSHA only
requires the use of eight of the symbols (the pictogram for an environmental hazard is not required).
• Manufacturer information: Name, address, and telephone number of the chemical manufacturer or
importer must be included (OSHA, 2013a).
[https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT](https://www.osha.gov/pls/oshaweb/owasrch.search_form?p_doc_type=INTERPRETATIONS&p_toc_level=3&p_keyvalue=1910.1200&p_status=CURRENT)
[https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf](https://www.fmcsa.dot.gov/sites/fmcsa.dot.gov/files/docs/Hazardous_Materials_Markings_Labeling_and_Placarding_Guide.pdf)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
Standardized labeling requirements ensure that the same chemicals purchased from different manufacturers
contain the same information in the same format, but OSHA still provides employers with some options. As
noted earlier, in the 25 years since the first HazCom Standard was issued, much time and effort has been
spent on developing these in-house systems, and many of them likely meet the intent of the HazCom
Standard. OSHA recognizes this by allowing in-house labeling systems that meet the requirements of the
1994 HazCom Standard to remain in effect (OSHA, 2013a). That is good news for organizations that
developed their own systems and those that sell OSHA-compliant labels; however, this is much like a
performance standard and may be subject to interpretation.
SDSs
Much has changed with MSDSs in the last 25 years. MSDSs evolved and became more standardized in
format. They have been readily available in electronic versions and on the internet for more than 10 years.
The OSHA HazCom Standard now prescribes a standard format of 16 sections to align with the GHS (OSHA,
2013b). The information on the SDSs, as they are now called, is essentially the same as the MSDS but is
standardized across all workplaces.
• Section 1: Identification
• Section 2: Hazard(s)
• Section 3: Composition/Information on Ingredients
• Section 4: First Aid Measures
• Section 5: Fire Fighting Measures
• Section 6: Accidental Release Measures
• Section 7: Handling and Storage
• Section 8: Exposure Controls/Personal Protection
• Section 9: Physical and Chemical Properties
• Section 10: Stability and Reactivity
• Section 11: Toxicological Information
Sample HazCom label
(OSHA, 2013a)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
• Section 12: Ecological Information
• Section 13: Disposal Considerations
• Section 14: Transport Information
• Section 15: Regulatory Information
• Section 16: Other Information
OSHA does not require sections 13, 14, and 15 to be completed, but the Environmental Protection Agency
(EPA) and the DOT regulations may require this information. The chemical manufacturer or importer
preparing the SDS is required to make that determination. From a practical standpoint, the information in
these sections would certainly help the employer with EPA and DOT compliance issues.
The standard requires SDSs to be readily
available to all employees on all work shifts.
Over the years, OSHA has interpreted readily
available to mean immediate and without delay
(Haight, 2012). In addition, access to SDS
information must not require assistance (e.g.,
requesting a copy from a supervisor or needing
an intermediary to gain computer access for
electronic versions).
SDSs are required to be in English, but it
makes sense to also make them, or the
information they contain, available in all
languages that are represented in the
organization. Keep in mind that all employees
have a right to know and understand the
hazards of the chemicals with which they work.
Even if only one employee speaks a language
other than English, that one employee not
understanding the hazards can create a
dangerous situation for all employees.
Even when all employees have been informed of the risks associated with the hazardous materials in the
workplace, there may be risks associated with the hazardous materials that are unacceptable. The
assessment of an unacceptable risk may come from workplace industrial hygiene sampling showing
exposures exceeding the applicable OSHA permissible exposure limit (PEL) or from a workplace audit
showing unacceptable risks of fire or explosion. In these cases, OSHA may require the employer to
implement controls to reduce the risk(s). The National Institute for Occupational Safety and Health (NIOSH)
and OSHA recommend the use of the hierarchy of controls when attempting to reduce the risks associated
with hazardous materials (NIOSH, n.d.-b). One rendering of the hierarchy of controls is depicted below.
Do these workers know the hazards of the containers
with which they are working? Are the containers
clearly marked? Are they in compliance with the
HazCom Standard?
(Henshall, 2008)
(NIOSH, n.d.-a)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
The controls are arranged with the most effective controls at the top and the least effective controls at the
bottom of the inverted pyramid. Elimination is the most effective control because it completely removes the
hazardous materials from the workplace. Substitution also removes the hazardous materials from the
workplace but substitutes another material that must then be evaluated for risk. Since these two controls
remove the original hazardous materials from the workplace, they are often combined into one category
called elimination/substitution. This control method may be the most effective, but it is also the most difficult to
implement (NIOSH, n.d.-b). In many cases, a hazardous material is required to be used because of a
chemical process or client specifications and no other hazardous materials will work. In those cases,
elimination/substitution are not viable control methods.
The next most effective control option involves the use of engineering controls. Note that engineering controls
do not remove the hazardous materials from the workplace. Engineering controls reduce the potential for
exposure to workers by reducing the amount (concentration) of the hazardous material that reaches the
worker. Engineering controls can be very effective in reducing the risk associated with a hazardous material.
One of the most important (and commonly used) engineering controls is ventilation (OSHA, 2017). The two
most commonly used types of ventilation are general dilution ventilation and local exhaust ventilation
systems. A general dilution ventilation system reduces the concentration of a hazardous material by
introducing outside air that does not have the contaminant into the workplace air. A local exhaust ventilation
system collects the air near the source and moves the contaminated air somewhere outside the work area
where it may be filtered, treated, or simply released into the air outside the workplace. The type of ventilation
system and the specifications for that system will vary depending on several variables including air
concentrations, toxicity of the hazardous material, and physical characteristics of the workplace. Other
examples of some commonly used engineering controls include the use of sound deadening materials around
machines and lead-lined walls around ionizing radiation sources.
Administrative controls are not as effective as engineering controls because they do not take any action to
reduce the concentration of a hazardous material in the workplace. Instead, they change the way people work
in order to reduce risk (NIOSH, n.d.-b). A good example of an administrative control is implementing a
work/rest regimen to reduce the risks associated with heat extremes. By requiring workers in a hot
environment to take periodic breaks of a specified duration and to take measures to rehydrate and cool, the
risk of developing a heat illness can be reduced.
The control measure that is the least effective is the use of personal protective equipment (PPE). The reason
that PPE is the least effective is that it does not reduce the concentration of a hazardous material in the
workplace. PPE merely blocks the hazardous material before the exposure occurs. Because of the many
sources of leaks and malfunctions associated with PPE, the amount of protection claimed by PPE
manufacturers may not be achieved in the actual workplace, and exposures may be higher than expected.
Unfortunately, PPE is also one of the most commonly used control methods. When should PPE be used?
OSHA (1970a) says PPE should be used when there is a hazard present capable of causing injury or
impairment. However, OSHA requires the employer to attempt to reduce the risk to an acceptable level using
more effective controls prior to using PPE as the primary control method (OSHA, n.d.). PPE can also be used
to reduce risk during the time period when engineering and administrative controls are being implemented.
OSH 2303, Hazardous Materials Safety 6
UNIT x STUDY GUIDE
Title
References
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
Henshall, G. (2008). FEMA – 39025 – EPA workers locating hazardous material moved by Ike in Texas
[Photograph]. Wikimedia Commons. http://commons.wikimedia.org/wiki/File:FEMA_-_39025_-
_EPA_workers_locating_hazardous_material_moved_by_Ike_in_Texas.jpg
National Institute for Occupational Safety and Health. (n.d.-a). Hierarchy of controls [Image]. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
National Institute for Occupational Safety and Health. (n.d.-b). Hierarchy of controls: Overview. Centers for
Disease Control and Prevention.
https://www.cdc.gov/niosh/topics/hierarchy/images/HierarchyControls.jpg
Occupational Safety and Health Administration. (n.d.). Chemical hazards and toxic substances: Controlling
exposure. United States Department of Labor.
https://www.osha.gov/SLTC/hazardoustoxicsubstances/control.html
Occupational Safety and Health Administration. (1970a). Occupational safety and health standards: Personal
protective equipment: General requirements (OSHA Standard No. 1910.132). United States
Department of Labor.
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=9777&p_table=STANDARDS
Occupational Safety and Health Administration. (1970b). Occupational safety and health standards: Toxic and
hazardous substances: Health hazard criteria (OSHA Standard No. 1910.1200 App A). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppA
Occupational Safety and Health Administration. (1970c). Occupational safety and health standards: Toxic and
hazardous substances: Physical criteria (OSHA Standard No. 1910.1200 App B). United States
Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppB
Occupational Safety and Health Administration. (1970d). Occupational safety and health standards: Toxic and
hazardous substances: Allocation of label elements (OSHA Standard No. 1910.1200 App C). United
States Department of Labor. https://www.osha.gov/laws-
regs/regulations/standardnumber/1910/1910.1200AppC
Occupational Safety and Health Administration. (2004). Hazard communication in the 21st century: History.
United States Department of Labor. https://www.osha.gov/dsg/hazcom/finalmsdsreport.html#history
Occupational Safety and Health Administration. (2013a). Hazard Communication Standard: Labels and
pictograms (OSHA Brief No. DSG BR-3636). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3636.pdf
Occupational Safety and Health Administration. (2013b). Hazard Communication Standard: Safety data
sheets (OSHA Brief No. DSG BR-3514). U.S. Department of Labor.
https://www.osha.gov/Publications/OSHA3514.pdf
Occupational Safety and Health Administration. (2017). Ventilation: Overview. United States Department of
Labor. https://www.osha.gov/SLTC/ventilation/index.html
OSH 2303, Hazardous Materials Safety 7
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.
One important task is identifying hazards in the workplace and performing a risk assessment for those
hazards in order to evaluate the need for controls. The Occupational Safety and Health Administration
(OSHA) has developed a tool to teach workers how to identify hazards in different workplaces. Access the
website below, and use the tool to see if your skills at identifying hazards are up-to-date.
Occupational Safety and Health Administration. (2017). Hazard identification training tool. United States
Department of Labor. https://www.osha.gov/hazfinder/index.html
OSHA has also developed an electronic health and safety program that is accessible on their website. The
program contains some good information about identifying hazards and some control methods. Access the
program below, and review the material.
Occupational Safety and Health Administration. (2006). OSHA e-HASP software – version 2.0 (e-HASP2).
United States Department of Labor. https://www.osha.gov/dep/etools/ehasp/index.html
[https://www.osha.gov/hazfinder/index.html](https://www.osha.gov/hazfinder/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 III
– Required Unit Resources
– Unit Lesson
– Hazardous Materials in the Workplace
– Hazardous Material Labels
– SDSs
– References
– Learning Activities (Nongraded)
See attached **files (2)** – ## OSHA2303UnitIVJournal.docx – ## UnitIVStudyGuide.pdf **## OSHA2303UnitIVJournal.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 yo…
Immediate access to the full model answer, formatted citations, and rubric breakdown.
Have this question answered from scratch according to your specific instructions and deadline.
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**files (2)**
– ## OSHA2303UnitIVJournal.docx
– ## UnitIVStudyGuide.pdf
**## OSHA2303UnitIVJournal.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:
**## UnitIVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Identify the requirements of the primary federal agencies regulating hazardous material spill
response activities.
5.2 Recall the chemical properties that affect how a hazardous substance reacts during a spill
response.
5.3 Identify the reporting requirements related to the release of a hazardous material.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 37–59
In order to access the following resource, click the link below.
The Occupational Safety and Health Administration (OSHA) has published an excellent explanation of
HAZWOPER requirements, which can be found on the webpage below.
Occupational Safety and Health Administration. (n.d.). The application of HAZWOPER to worksite response
and cleanup activities.United States Department of Labor.
https://www.osha.gov/dep/ohe/application_worksiteresponse.html
Unit Lesson
When the Occupational Safety and Health Administration (OSHA) was created in 1970, there was already a
cadre of safety practitioners working in the industry and actively involved in accident prevention efforts. The
American Society of Safety Engineers (ASSE) had been active for many years, as had other safety-related
nongovernment organizations such as the National Fire Protection Association (NFPA), the National Safety
Council (NSC), and the American Conference of Governmental Industrial Hygienists (ACGIH). The OSHA
standards that were created had roots in these private organizations and forced companies to finally pay
attention to worker safety.
The Environmental Protection Agency (EPA) was also created in 1970 with specific air quality, water quality,
and solid waste responsibilities transferred to it from the U.S. Department of the Interior; the U.S. Department
of Agriculture; and the U.S. Department of Health, Education, and Welfare. The goal was to provide the nation
with a focal point for addressing the growing problem of pollution (EPA, 1992).
The EPA was given broad powers to publish and enforce standards, and since an environmental profession
did not yet exist, the industry found itself with very limited in-house expertise to deal with the new federal
and state requirements. Some companies chose to assign environmental responsibilities to safety
departments, but many safety professionals objected, claiming it would force their accident prevention
efforts into the background. Over the past 40 years, a new environmental management profession has
emerged and flourished, but a connection to the safety profession remains, particularly in hazardous material
spills and cleanup.
UNIT IV STUDY GUIDE
Introduction to Hazardous
Spill Response
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
A Cooperative Effort
The EPA, the U.S. Department of
Transportation (DOT), and OSHA are all
directly involved in the regulation of hazardous
material spill response. The EPA has the
broadest coverage with laws and standards
that apply to nearly every situation. Central to
the EPA’s oversight of hazardous substance
spill cleanup and reporting are the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of
1980 and the Superfund Amendments and
Reauthorization Act (SARA) of 1986. They
include requirements to report to local
authorities the inventories of acutely hazardous
substances when specified storage quantities
are exceeded. This allows local emergency
planning committees to develop effective
response plans. Together, the Resource
Conservation and Recovery Act (RCRA),
CERCLA, and SARA complete the cradle-to-
grave cycle of hazardous waste management. RCRA focuses on reducing the amount of hazardous waste
produced and the number of incidents involving hazardous waste while CERCLA and SARA deal with the
effects when there is a breakdown in the waste management practices established by RCRA (EPA, 2014).
The DOT regulations cover transportation incidents (Haight, 2012). Many of the larger spills in recent years
have been the result of land, water, and air transportation incidents. The DOT's requirements for labeling and
manifesting hazardous material shipments are critical to the effectiveness of local emergency response
agencies in dealing with transportation emergencies. Unlike a warehouse where the presence of dangerous
materials must be reported to local authorities under CERCLA and SARA requirements, there is rarely
advance notification of hazardous substances being transported through a community; explosives and
radioactive materials are the exceptions. If hazardous materials are properly identified on containers and
vehicles, emergency response personnel can use the DOT’s hazard classification system markings, labels,
and placards to quickly determine the correct courses of action to protect property and people should an
incident occur. See the 2016 Emergency Response Guidebook for more information on the hazard
classification system.
However, the EPA is not tasked with protecting workers performing hazardous materials spill response
functions. Section 126 of SARA tasked OSHA with developing and implementing standards to protect workers
involved in these emergency response and cleanup operations related to hazardous waste spills and releases
(OSHA, n.d.). The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard is the
result of that EPA mandate.
The HAZWOPER Standard requires employers to develop written safety and health plans for containment
and cleanup of hazardous waste and to provide training to all employees involved in hazardous waste
operations (Haight, 2012). Closely tied to HAZWOPER is OSHA’s Hazard Communication Standard
(HazCom), which you can read for more information.
As we saw in the previous unit, the HazCom Standard requires employers to maintain safety information on
all hazardous substances used in the workplace—not just waste—and to ensure employees who use these
substances understand the dangers and how to protect themselves (Haight, 2012).
Coordinated Help
The EPA, OSHA, and DOT are not alone. The National Response Center (NRC) is a cooperative effort
among 15 federal departments and agencies to coordinate all hazardous materials incident planning and
response across the nation, under the framework of the EPA, DOT, and OSHA regulations and standards
(Haight, 2012). The NRC coordinates with state and local emergency response planning agencies to ensure
EPA, DOT, and OSHA logos
(Department of Labor, n.d.; Department of
Transportation, n.d.; U.S. Government, n.d.)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
consistency in emergency response and protection of the public (National Response Team, 2005). If an
incident crosses local or state jurisdictions or local response teams become overwhelmed by the scope of an
incident, an NRC team will be dispatched to provide assistance. All oil and chemical spills required to be
reported under EPA and DOT regulations must be reported by telephone to the NRC. In addition, persons
discovering a spill or release, even if they are not responsible, should contact the NRC (Haight, 2012). In
recent years, the responsibilities of the NRC have been expanded beyond accidental releases of oil and
hazardous substances to include intentional releases and terrorist activities.
Safe containment and cleanup of hazardous material spills and releases begins with an understanding of the
physical and chemical properties of the materials and their toxicity. Safety practitioners and industrial
hygienists are involved with protecting employees from exposure to these substances in the workplace and
are often the best source of the needed information; it is critical that an organization’s safety and health staff
be involved in all spill and release-related planning and discussions. OSHA’s permissible exposure limits
(PELs) are the regulatory standards for worker exposure that must be followed in all spill cleanup operations
(Haight, 2012). The updating of OSHA’s PEL standards, however, has not kept pace with research that
recommends lower exposure limits. Organizations may want to apply the threshold limit value (TLV)
published by the ACGIH. These guidelines are updated annually and represent best practice solutions to
worker exposures.
The geology, hydrology, and meteorology of the area affected by a spill or release also play a significant role
in the planning process (Haight, 2012). Civil engineers and environmental specialists are often the sources for
the needed information. Only after the necessary information is compiled can a plan be developed on who will
respond, how they will respond, how they should be trained, and what equipment they will need.
Effective planning is important to any response operation, but how do you know if the plans will be effective?
Very simply, the plan must be practiced, and a critical evaluation should be conducted. The NRC is an
excellent source for benchmarks against which plans can be measured (National Response Team, 2001).
Risk Assessment
There is much uncertainty surrounding the effects of hazardous substance spills and releases on people and
the environment. Since the 1980s, the EPA has promoted the use of risk assessment as a method to address
Preparedness components under the National Response System
(National Response Team, 2005, slide 37)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
this uncertainty (EPA, 2013). The risk assessment process evaluates the probability of an adverse event—in
our case, a hazardous substance release—and the severity of the harm it may cause to people, property, and
the environment. While some of the risk assessment process is subjective and may depend on the knowledge
and experience of the persons conducting it, there are also many resources available to increase reliability.
One such resource is the EPA’s Integrated Risk Information System (IRIS), which is a database of hazardous
materials and their known effects on human health and the environment.
Risk assessments help sort out which events would result in the most serious consequences and which
events are most likely to occur. The ones judged to be the higher risk become the priority for action. In some
cases, it may be appropriate to not plan for the events that are highly unlikely to occur. Determination of these
tolerable risks must be made at the highest level of organizational management. A side benefit of a risk
assessment is often the replacement of a hazardous material with one that is less hazardous or
nonhazardous. Workers will no longer be exposed, and the adverse consequences of a spill have been
mitigated.
While most people do not like to discuss cost when assessing risks to human health, it is important to know
that organizations do not have an infinite amount of money to spend. Risk assessment can help determine
the best use of available funds to protect people and the environment and allow the organization to remain
viable.
In the next unit, we will continue the discussion and look deeper into the requirements and best practices for
developing spill response plans.
References
Department of Labor. (n.d.). US-OSHA-logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:US-OSHA-Logo.svg
Department of Transportation. (n.d.). Seal of the United States Department of Transportation [Image].
Wikimedia Commons. http://commons.wikimedia.org/wiki/File:US-DeptOfTransportation-Seal.svg
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Response Team. (2001). Hazardous materials emergency planning guide. Environmental Protection
Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
National Response Team. (2005). The National Response System: Federal, state, and local governments
working together to protect Americans from threats to our land, air, and water [PowerPoint slides].
https://www.nrt.org/sites/2/files/NRT-NRS_Outreach_Presentation_12-16-09v10.ppt
Occupational Safety and Health Administration. (n.d.). Hazardous Waste Operations and Emergency
Response (HAZWOPER): Overview. United States Department of Labor.
https://www.osha.gov/SLTC/emergencypreparedness/hazwoper/
United States Environmental Protection Agency. (1992). The guardian: Origins of the EPA.
https://archive.epa.gov/epa/aboutepa/guardian-origins-epa.html
United States Environmental Protection Agency. (2013). About risk assessment: History of risk at EPA.
https://www.epa.gov/risk/about-risk-assessment
United States Environmental Protection Agency. (2014). RCRA orientation manual 2014 (EPA Document No.
530-F-11-003). https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
U.S. Government. (n.d.). Environmental Protection Agency logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Environmental_Protection_Agency_logo.png
[https://www.epa.gov/iris](https://www.epa.gov/iris)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Suggested Unit Resources
In order to access the following resources, click the links below.
The Environmental Protection Agency (EPA) provides a summary of hazardous substance spill reporting
requirements on the webpage below.
United States Environmental Protection Agency. (2014). When are you required to report an oil spill and
hazardous substance release? https://www.epa.gov/emergency-response/when-are-you-required-
report-oil-spill-and-hazardous-substance-release#oil%20spills
The Emergency Response Guidebook (ERG) is an essential document for any organization that handles
hazardous substances. You can download the 2016 edition of the ERG below. Versions of the ERG for
mobile devices are also available on the U.S. Department of Transportation (DOT) website.
Pipeline and Hazardous Materials Safety Administration. (2016). 2016 Emergency response guidebook. U.S.
Department of Transportation.
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf
Review the National Response Team’s Hazardous Materials Emergency Planning Guide (pp. 1–14) below.
National Response Team. (2001, July). Hazardous materials emergency planning guide. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Read the fact sheet below, which briefs the topic of hazardous waste operations and emergency response.
Occupational Safety and Health Administration. (2004). Hazardous waste operations and emergency
response [Fact sheet]. U.S. Department of Labor.
https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.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/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
[https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– A Cooperative Effort
– Coordinated Help
– Risk Assessment
– References
– Suggested Unit Resources
**## UnitIVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Identify the requirements of the primary federal agencies regulating hazardous material spill
response activities.
5.2 Recall the chemical properties that affect how a hazardous substance reacts during a spill
response.
5.3 Identify the reporting requirements related to the release of a hazardous material.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 37–59
In order to access the following resource, click the link below.
The Occupational Safety and Health Administration (OSHA) has published an excellent explanation of
HAZWOPER requirements, which can be found on the webpage below.
Occupational Safety and Health Administration. (n.d.). The application of HAZWOPER to worksite response
and cleanup activities.United States Department of Labor.
https://www.osha.gov/dep/ohe/application_worksiteresponse.html
Unit Lesson
When the Occupational Safety and Health Administration (OSHA) was created in 1970, there was already a
cadre of safety practitioners working in the industry and actively involved in accident prevention efforts. The
American Society of Safety Engineers (ASSE) had been active for many years, as had other safety-related
nongovernment organizations such as the National Fire Protection Association (NFPA), the National Safety
Council (NSC), and the American Conference of Governmental Industrial Hygienists (ACGIH). The OSHA
standards that were created had roots in these private organizations and forced companies to finally pay
attention to worker safety.
The Environmental Protection Agency (EPA) was also created in 1970 with specific air quality, water quality,
and solid waste responsibilities transferred to it from the U.S. Department of the Interior; the U.S. Department
of Agriculture; and the U.S. Department of Health, Education, and Welfare. The goal was to provide the nation
with a focal point for addressing the growing problem of pollution (EPA, 1992).
The EPA was given broad powers to publish and enforce standards, and since an environmental profession
did not yet exist, the industry found itself with very limited in-house expertise to deal with the new federal
and state requirements. Some companies chose to assign environmental responsibilities to safety
departments, but many safety professionals objected, claiming it would force their accident prevention
efforts into the background. Over the past 40 years, a new environmental management profession has
emerged and flourished, but a connection to the safety profession remains, particularly in hazardous material
spills and cleanup.
UNIT IV STUDY GUIDE
Introduction to Hazardous
Spill Response
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
A Cooperative Effort
The EPA, the U.S. Department of
Transportation (DOT), and OSHA are all
directly involved in the regulation of hazardous
material spill response. The EPA has the
broadest coverage with laws and standards
that apply to nearly every situation. Central to
the EPA’s oversight of hazardous substance
spill cleanup and reporting are the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of
1980 and the Superfund Amendments and
Reauthorization Act (SARA) of 1986. They
include requirements to report to local
authorities the inventories of acutely hazardous
substances when specified storage quantities
are exceeded. This allows local emergency
planning committees to develop effective
response plans. Together, the Resource
Conservation and Recovery Act (RCRA),
CERCLA, and SARA complete the cradle-to-
grave cycle of hazardous waste management. RCRA focuses on reducing the amount of hazardous waste
produced and the number of incidents involving hazardous waste while CERCLA and SARA deal with the
effects when there is a breakdown in the waste management practices established by RCRA (EPA, 2014).
The DOT regulations cover transportation incidents (Haight, 2012). Many of the larger spills in recent years
have been the result of land, water, and air transportation incidents. The DOT's requirements for labeling and
manifesting hazardous material shipments are critical to the effectiveness of local emergency response
agencies in dealing with transportation emergencies. Unlike a warehouse where the presence of dangerous
materials must be reported to local authorities under CERCLA and SARA requirements, there is rarely
advance notification of hazardous substances being transported through a community; explosives and
radioactive materials are the exceptions. If hazardous materials are properly identified on containers and
vehicles, emergency response personnel can use the DOT’s hazard classification system markings, labels,
and placards to quickly determine the correct courses of action to protect property and people should an
incident occur. See the 2016 Emergency Response Guidebook for more information on the hazard
classification system.
However, the EPA is not tasked with protecting workers performing hazardous materials spill response
functions. Section 126 of SARA tasked OSHA with developing and implementing standards to protect workers
involved in these emergency response and cleanup operations related to hazardous waste spills and releases
(OSHA, n.d.). The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard is the
result of that EPA mandate.
The HAZWOPER Standard requires employers to develop written safety and health plans for containment
and cleanup of hazardous waste and to provide training to all employees involved in hazardous waste
operations (Haight, 2012). Closely tied to HAZWOPER is OSHA’s Hazard Communication Standard
(HazCom), which you can read for more information.
As we saw in the previous unit, the HazCom Standard requires employers to maintain safety information on
all hazardous substances used in the workplace—not just waste—and to ensure employees who use these
substances understand the dangers and how to protect themselves (Haight, 2012).
Coordinated Help
The EPA, OSHA, and DOT are not alone. The National Response Center (NRC) is a cooperative effort
among 15 federal departments and agencies to coordinate all hazardous materials incident planning and
response across the nation, under the framework of the EPA, DOT, and OSHA regulations and standards
(Haight, 2012). The NRC coordinates with state and local emergency response planning agencies to ensure
EPA, DOT, and OSHA logos
(Department of Labor, n.d.; Department of
Transportation, n.d.; U.S. Government, n.d.)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
consistency in emergency response and protection of the public (National Response Team, 2005). If an
incident crosses local or state jurisdictions or local response teams become overwhelmed by the scope of an
incident, an NRC team will be dispatched to provide assistance. All oil and chemical spills required to be
reported under EPA and DOT regulations must be reported by telephone to the NRC. In addition, persons
discovering a spill or release, even if they are not responsible, should contact the NRC (Haight, 2012). In
recent years, the responsibilities of the NRC have been expanded beyond accidental releases of oil and
hazardous substances to include intentional releases and terrorist activities.
Safe containment and cleanup of hazardous material spills and releases begins with an understanding of the
physical and chemical properties of the materials and their toxicity. Safety practitioners and industrial
hygienists are involved with protecting employees from exposure to these substances in the workplace and
are often the best source of the needed information; it is critical that an organization’s safety and health staff
be involved in all spill and release-related planning and discussions. OSHA’s permissible exposure limits
(PELs) are the regulatory standards for worker exposure that must be followed in all spill cleanup operations
(Haight, 2012). The updating of OSHA’s PEL standards, however, has not kept pace with research that
recommends lower exposure limits. Organizations may want to apply the threshold limit value (TLV)
published by the ACGIH. These guidelines are updated annually and represent best practice solutions to
worker exposures.
The geology, hydrology, and meteorology of the area affected by a spill or release also play a significant role
in the planning process (Haight, 2012). Civil engineers and environmental specialists are often the sources for
the needed information. Only after the necessary information is compiled can a plan be developed on who will
respond, how they will respond, how they should be trained, and what equipment they will need.
Effective planning is important to any response operation, but how do you know if the plans will be effective?
Very simply, the plan must be practiced, and a critical evaluation should be conducted. The NRC is an
excellent source for benchmarks against which plans can be measured (National Response Team, 2001).
Risk Assessment
There is much uncertainty surrounding the effects of hazardous substance spills and releases on people and
the environment. Since the 1980s, the EPA has promoted the use of risk assessment as a method to address
Preparedness components under the National Response System
(National Response Team, 2005, slide 37)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
this uncertainty (EPA, 2013). The risk assessment process evaluates the probability of an adverse event—in
our case, a hazardous substance release—and the severity of the harm it may cause to people, property, and
the environment. While some of the risk assessment process is subjective and may depend on the knowledge
and experience of the persons conducting it, there are also many resources available to increase reliability.
One such resource is the EPA’s Integrated Risk Information System (IRIS), which is a database of hazardous
materials and their known effects on human health and the environment.
Risk assessments help sort out which events would result in the most serious consequences and which
events are most likely to occur. The ones judged to be the higher risk become the priority for action. In some
cases, it may be appropriate to not plan for the events that are highly unlikely to occur. Determination of these
tolerable risks must be made at the highest level of organizational management. A side benefit of a risk
assessment is often the replacement of a hazardous material with one that is less hazardous or
nonhazardous. Workers will no longer be exposed, and the adverse consequences of a spill have been
mitigated.
While most people do not like to discuss cost when assessing risks to human health, it is important to know
that organizations do not have an infinite amount of money to spend. Risk assessment can help determine
the best use of available funds to protect people and the environment and allow the organization to remain
viable.
In the next unit, we will continue the discussion and look deeper into the requirements and best practices for
developing spill response plans.
References
Department of Labor. (n.d.). US-OSHA-logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:US-OSHA-Logo.svg
Department of Transportation. (n.d.). Seal of the United States Department of Transportation [Image].
Wikimedia Commons. http://commons.wikimedia.org/wiki/File:US-DeptOfTransportation-Seal.svg
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Response Team. (2001). Hazardous materials emergency planning guide. Environmental Protection
Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
National Response Team. (2005). The National Response System: Federal, state, and local governments
working together to protect Americans from threats to our land, air, and water [PowerPoint slides].
https://www.nrt.org/sites/2/files/NRT-NRS_Outreach_Presentation_12-16-09v10.ppt
Occupational Safety and Health Administration. (n.d.). Hazardous Waste Operations and Emergency
Response (HAZWOPER): Overview. United States Department of Labor.
https://www.osha.gov/SLTC/emergencypreparedness/hazwoper/
United States Environmental Protection Agency. (1992). The guardian: Origins of the EPA.
https://archive.epa.gov/epa/aboutepa/guardian-origins-epa.html
United States Environmental Protection Agency. (2013). About risk assessment: History of risk at EPA.
https://www.epa.gov/risk/about-risk-assessment
United States Environmental Protection Agency. (2014). RCRA orientation manual 2014 (EPA Document No.
530-F-11-003). https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
U.S. Government. (n.d.). Environmental Protection Agency logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Environmental_Protection_Agency_logo.png
[https://www.epa.gov/iris](https://www.epa.gov/iris)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Suggested Unit Resources
In order to access the following resources, click the links below.
The Environmental Protection Agency (EPA) provides a summary of hazardous substance spill reporting
requirements on the webpage below.
United States Environmental Protection Agency. (2014). When are you required to report an oil spill and
hazardous substance release? https://www.epa.gov/emergency-response/when-are-you-required-
report-oil-spill-and-hazardous-substance-release#oil%20spills
The Emergency Response Guidebook (ERG) is an essential document for any organization that handles
hazardous substances. You can download the 2016 edition of the ERG below. Versions of the ERG for
mobile devices are also available on the U.S. Department of Transportation (DOT) website.
Pipeline and Hazardous Materials Safety Administration. (2016). 2016 Emergency response guidebook. U.S.
Department of Transportation.
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf
Review the National Response Team’s Hazardous Materials Emergency Planning Guide (pp. 1–14) below.
National Response Team. (2001, July). Hazardous materials emergency planning guide. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Read the fact sheet below, which briefs the topic of hazardous waste operations and emergency response.
Occupational Safety and Health Administration. (2004). Hazardous waste operations and emergency
response [Fact sheet]. U.S. Department of Labor.
https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.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/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
[https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– A Cooperative Effort
– Coordinated Help
– Risk Assessment
– References
– Suggested Unit Resources
**## OSHA2303UnitIVJournal.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:
**## UnitIVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Identify the requirements of the primary federal agencies regulating hazardous material spill
response activities.
5.2 Recall the chemical properties that affect how a hazardous substance reacts during a spill
response.
5.3 Identify the reporting requirements related to the release of a hazardous material.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 37–59
In order to access the following resource, click the link below.
The Occupational Safety and Health Administration (OSHA) has published an excellent explanation of
HAZWOPER requirements, which can be found on the webpage below.
Occupational Safety and Health Administration. (n.d.). The application of HAZWOPER to worksite response
and cleanup activities.United States Department of Labor.
https://www.osha.gov/dep/ohe/application_worksiteresponse.html
Unit Lesson
When the Occupational Safety and Health Administration (OSHA) was created in 1970, there was already a
cadre of safety practitioners working in the industry and actively involved in accident prevention efforts. The
American Society of Safety Engineers (ASSE) had been active for many years, as had other safety-related
nongovernment organizations such as the National Fire Protection Association (NFPA), the National Safety
Council (NSC), and the American Conference of Governmental Industrial Hygienists (ACGIH). The OSHA
standards that were created had roots in these private organizations and forced companies to finally pay
attention to worker safety.
The Environmental Protection Agency (EPA) was also created in 1970 with specific air quality, water quality,
and solid waste responsibilities transferred to it from the U.S. Department of the Interior; the U.S. Department
of Agriculture; and the U.S. Department of Health, Education, and Welfare. The goal was to provide the nation
with a focal point for addressing the growing problem of pollution (EPA, 1992).
The EPA was given broad powers to publish and enforce standards, and since an environmental profession
did not yet exist, the industry found itself with very limited in-house expertise to deal with the new federal
and state requirements. Some companies chose to assign environmental responsibilities to safety
departments, but many safety professionals objected, claiming it would force their accident prevention
efforts into the background. Over the past 40 years, a new environmental management profession has
emerged and flourished, but a connection to the safety profession remains, particularly in hazardous material
spills and cleanup.
UNIT IV STUDY GUIDE
Introduction to Hazardous
Spill Response
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
A Cooperative Effort
The EPA, the U.S. Department of
Transportation (DOT), and OSHA are all
directly involved in the regulation of hazardous
material spill response. The EPA has the
broadest coverage with laws and standards
that apply to nearly every situation. Central to
the EPA’s oversight of hazardous substance
spill cleanup and reporting are the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of
1980 and the Superfund Amendments and
Reauthorization Act (SARA) of 1986. They
include requirements to report to local
authorities the inventories of acutely hazardous
substances when specified storage quantities
are exceeded. This allows local emergency
planning committees to develop effective
response plans. Together, the Resource
Conservation and Recovery Act (RCRA),
CERCLA, and SARA complete the cradle-to-
grave cycle of hazardous waste management. RCRA focuses on reducing the amount of hazardous waste
produced and the number of incidents involving hazardous waste while CERCLA and SARA deal with the
effects when there is a breakdown in the waste management practices established by RCRA (EPA, 2014).
The DOT regulations cover transportation incidents (Haight, 2012). Many of the larger spills in recent years
have been the result of land, water, and air transportation incidents. The DOT's requirements for labeling and
manifesting hazardous material shipments are critical to the effectiveness of local emergency response
agencies in dealing with transportation emergencies. Unlike a warehouse where the presence of dangerous
materials must be reported to local authorities under CERCLA and SARA requirements, there is rarely
advance notification of hazardous substances being transported through a community; explosives and
radioactive materials are the exceptions. If hazardous materials are properly identified on containers and
vehicles, emergency response personnel can use the DOT’s hazard classification system markings, labels,
and placards to quickly determine the correct courses of action to protect property and people should an
incident occur. See the 2016 Emergency Response Guidebook for more information on the hazard
classification system.
However, the EPA is not tasked with protecting workers performing hazardous materials spill response
functions. Section 126 of SARA tasked OSHA with developing and implementing standards to protect workers
involved in these emergency response and cleanup operations related to hazardous waste spills and releases
(OSHA, n.d.). The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard is the
result of that EPA mandate.
The HAZWOPER Standard requires employers to develop written safety and health plans for containment
and cleanup of hazardous waste and to provide training to all employees involved in hazardous waste
operations (Haight, 2012). Closely tied to HAZWOPER is OSHA’s Hazard Communication Standard
(HazCom), which you can read for more information.
As we saw in the previous unit, the HazCom Standard requires employers to maintain safety information on
all hazardous substances used in the workplace—not just waste—and to ensure employees who use these
substances understand the dangers and how to protect themselves (Haight, 2012).
Coordinated Help
The EPA, OSHA, and DOT are not alone. The National Response Center (NRC) is a cooperative effort
among 15 federal departments and agencies to coordinate all hazardous materials incident planning and
response across the nation, under the framework of the EPA, DOT, and OSHA regulations and standards
(Haight, 2012). The NRC coordinates with state and local emergency response planning agencies to ensure
EPA, DOT, and OSHA logos
(Department of Labor, n.d.; Department of
Transportation, n.d.; U.S. Government, n.d.)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
consistency in emergency response and protection of the public (National Response Team, 2005). If an
incident crosses local or state jurisdictions or local response teams become overwhelmed by the scope of an
incident, an NRC team will be dispatched to provide assistance. All oil and chemical spills required to be
reported under EPA and DOT regulations must be reported by telephone to the NRC. In addition, persons
discovering a spill or release, even if they are not responsible, should contact the NRC (Haight, 2012). In
recent years, the responsibilities of the NRC have been expanded beyond accidental releases of oil and
hazardous substances to include intentional releases and terrorist activities.
Safe containment and cleanup of hazardous material spills and releases begins with an understanding of the
physical and chemical properties of the materials and their toxicity. Safety practitioners and industrial
hygienists are involved with protecting employees from exposure to these substances in the workplace and
are often the best source of the needed information; it is critical that an organization’s safety and health staff
be involved in all spill and release-related planning and discussions. OSHA’s permissible exposure limits
(PELs) are the regulatory standards for worker exposure that must be followed in all spill cleanup operations
(Haight, 2012). The updating of OSHA’s PEL standards, however, has not kept pace with research that
recommends lower exposure limits. Organizations may want to apply the threshold limit value (TLV)
published by the ACGIH. These guidelines are updated annually and represent best practice solutions to
worker exposures.
The geology, hydrology, and meteorology of the area affected by a spill or release also play a significant role
in the planning process (Haight, 2012). Civil engineers and environmental specialists are often the sources for
the needed information. Only after the necessary information is compiled can a plan be developed on who will
respond, how they will respond, how they should be trained, and what equipment they will need.
Effective planning is important to any response operation, but how do you know if the plans will be effective?
Very simply, the plan must be practiced, and a critical evaluation should be conducted. The NRC is an
excellent source for benchmarks against which plans can be measured (National Response Team, 2001).
Risk Assessment
There is much uncertainty surrounding the effects of hazardous substance spills and releases on people and
the environment. Since the 1980s, the EPA has promoted the use of risk assessment as a method to address
Preparedness components under the National Response System
(National Response Team, 2005, slide 37)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
this uncertainty (EPA, 2013). The risk assessment process evaluates the probability of an adverse event—in
our case, a hazardous substance release—and the severity of the harm it may cause to people, property, and
the environment. While some of the risk assessment process is subjective and may depend on the knowledge
and experience of the persons conducting it, there are also many resources available to increase reliability.
One such resource is the EPA’s Integrated Risk Information System (IRIS), which is a database of hazardous
materials and their known effects on human health and the environment.
Risk assessments help sort out which events would result in the most serious consequences and which
events are most likely to occur. The ones judged to be the higher risk become the priority for action. In some
cases, it may be appropriate to not plan for the events that are highly unlikely to occur. Determination of these
tolerable risks must be made at the highest level of organizational management. A side benefit of a risk
assessment is often the replacement of a hazardous material with one that is less hazardous or
nonhazardous. Workers will no longer be exposed, and the adverse consequences of a spill have been
mitigated.
While most people do not like to discuss cost when assessing risks to human health, it is important to know
that organizations do not have an infinite amount of money to spend. Risk assessment can help determine
the best use of available funds to protect people and the environment and allow the organization to remain
viable.
In the next unit, we will continue the discussion and look deeper into the requirements and best practices for
developing spill response plans.
References
Department of Labor. (n.d.). US-OSHA-logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:US-OSHA-Logo.svg
Department of Transportation. (n.d.). Seal of the United States Department of Transportation [Image].
Wikimedia Commons. http://commons.wikimedia.org/wiki/File:US-DeptOfTransportation-Seal.svg
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Response Team. (2001). Hazardous materials emergency planning guide. Environmental Protection
Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
National Response Team. (2005). The National Response System: Federal, state, and local governments
working together to protect Americans from threats to our land, air, and water [PowerPoint slides].
https://www.nrt.org/sites/2/files/NRT-NRS_Outreach_Presentation_12-16-09v10.ppt
Occupational Safety and Health Administration. (n.d.). Hazardous Waste Operations and Emergency
Response (HAZWOPER): Overview. United States Department of Labor.
https://www.osha.gov/SLTC/emergencypreparedness/hazwoper/
United States Environmental Protection Agency. (1992). The guardian: Origins of the EPA.
https://archive.epa.gov/epa/aboutepa/guardian-origins-epa.html
United States Environmental Protection Agency. (2013). About risk assessment: History of risk at EPA.
https://www.epa.gov/risk/about-risk-assessment
United States Environmental Protection Agency. (2014). RCRA orientation manual 2014 (EPA Document No.
530-F-11-003). https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
U.S. Government. (n.d.). Environmental Protection Agency logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Environmental_Protection_Agency_logo.png
[https://www.epa.gov/iris](https://www.epa.gov/iris)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Suggested Unit Resources
In order to access the following resources, click the links below.
The Environmental Protection Agency (EPA) provides a summary of hazardous substance spill reporting
requirements on the webpage below.
United States Environmental Protection Agency. (2014). When are you required to report an oil spill and
hazardous substance release? https://www.epa.gov/emergency-response/when-are-you-required-
report-oil-spill-and-hazardous-substance-release#oil%20spills
The Emergency Response Guidebook (ERG) is an essential document for any organization that handles
hazardous substances. You can download the 2016 edition of the ERG below. Versions of the ERG for
mobile devices are also available on the U.S. Department of Transportation (DOT) website.
Pipeline and Hazardous Materials Safety Administration. (2016). 2016 Emergency response guidebook. U.S.
Department of Transportation.
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf
Review the National Response Team’s Hazardous Materials Emergency Planning Guide (pp. 1–14) below.
National Response Team. (2001, July). Hazardous materials emergency planning guide. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Read the fact sheet below, which briefs the topic of hazardous waste operations and emergency response.
Occupational Safety and Health Administration. (2004). Hazardous waste operations and emergency
response [Fact sheet]. U.S. Department of Labor.
https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.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/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
[https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– A Cooperative Effort
– Coordinated Help
– Risk Assessment
– References
– Suggested Unit Resources
**## OSHA2303UnitIVJournal.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:
**## UnitIVStudyGuide.pdf**
OSH 2303, Hazardous Materials Safety 1
Course Learning Outcomes for Unit IV
Upon completion of this unit, students should be able to:
5. Describe the central tenets of a materials spill response plan.
5.1 Identify the requirements of the primary federal agencies regulating hazardous material spill
response activities.
5.2 Recall the chemical properties that affect how a hazardous substance reacts during a spill
response.
5.3 Identify the reporting requirements related to the release of a hazardous material.
Required Unit Resources
Chapter 2: Hazardous Material Spills and Response, pp. 37–59
In order to access the following resource, click the link below.
The Occupational Safety and Health Administration (OSHA) has published an excellent explanation of
HAZWOPER requirements, which can be found on the webpage below.
Occupational Safety and Health Administration. (n.d.). The application of HAZWOPER to worksite response
and cleanup activities.United States Department of Labor.
https://www.osha.gov/dep/ohe/application_worksiteresponse.html
Unit Lesson
When the Occupational Safety and Health Administration (OSHA) was created in 1970, there was already a
cadre of safety practitioners working in the industry and actively involved in accident prevention efforts. The
American Society of Safety Engineers (ASSE) had been active for many years, as had other safety-related
nongovernment organizations such as the National Fire Protection Association (NFPA), the National Safety
Council (NSC), and the American Conference of Governmental Industrial Hygienists (ACGIH). The OSHA
standards that were created had roots in these private organizations and forced companies to finally pay
attention to worker safety.
The Environmental Protection Agency (EPA) was also created in 1970 with specific air quality, water quality,
and solid waste responsibilities transferred to it from the U.S. Department of the Interior; the U.S. Department
of Agriculture; and the U.S. Department of Health, Education, and Welfare. The goal was to provide the nation
with a focal point for addressing the growing problem of pollution (EPA, 1992).
The EPA was given broad powers to publish and enforce standards, and since an environmental profession
did not yet exist, the industry found itself with very limited in-house expertise to deal with the new federal
and state requirements. Some companies chose to assign environmental responsibilities to safety
departments, but many safety professionals objected, claiming it would force their accident prevention
efforts into the background. Over the past 40 years, a new environmental management profession has
emerged and flourished, but a connection to the safety profession remains, particularly in hazardous material
spills and cleanup.
UNIT IV STUDY GUIDE
Introduction to Hazardous
Spill Response
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
[https://www.osha.gov/dep/ohe/application_worksiteresponse.html](https://www.osha.gov/dep/ohe/application_worksiteresponse.html)
OSH 2303, Hazardous Materials Safety 2
UNIT x STUDY GUIDE
Title
A Cooperative Effort
The EPA, the U.S. Department of
Transportation (DOT), and OSHA are all
directly involved in the regulation of hazardous
material spill response. The EPA has the
broadest coverage with laws and standards
that apply to nearly every situation. Central to
the EPA’s oversight of hazardous substance
spill cleanup and reporting are the
Comprehensive Environmental Response,
Compensation, and Liability Act (CERCLA) of
1980 and the Superfund Amendments and
Reauthorization Act (SARA) of 1986. They
include requirements to report to local
authorities the inventories of acutely hazardous
substances when specified storage quantities
are exceeded. This allows local emergency
planning committees to develop effective
response plans. Together, the Resource
Conservation and Recovery Act (RCRA),
CERCLA, and SARA complete the cradle-to-
grave cycle of hazardous waste management. RCRA focuses on reducing the amount of hazardous waste
produced and the number of incidents involving hazardous waste while CERCLA and SARA deal with the
effects when there is a breakdown in the waste management practices established by RCRA (EPA, 2014).
The DOT regulations cover transportation incidents (Haight, 2012). Many of the larger spills in recent years
have been the result of land, water, and air transportation incidents. The DOT's requirements for labeling and
manifesting hazardous material shipments are critical to the effectiveness of local emergency response
agencies in dealing with transportation emergencies. Unlike a warehouse where the presence of dangerous
materials must be reported to local authorities under CERCLA and SARA requirements, there is rarely
advance notification of hazardous substances being transported through a community; explosives and
radioactive materials are the exceptions. If hazardous materials are properly identified on containers and
vehicles, emergency response personnel can use the DOT’s hazard classification system markings, labels,
and placards to quickly determine the correct courses of action to protect property and people should an
incident occur. See the 2016 Emergency Response Guidebook for more information on the hazard
classification system.
However, the EPA is not tasked with protecting workers performing hazardous materials spill response
functions. Section 126 of SARA tasked OSHA with developing and implementing standards to protect workers
involved in these emergency response and cleanup operations related to hazardous waste spills and releases
(OSHA, n.d.). The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard is the
result of that EPA mandate.
The HAZWOPER Standard requires employers to develop written safety and health plans for containment
and cleanup of hazardous waste and to provide training to all employees involved in hazardous waste
operations (Haight, 2012). Closely tied to HAZWOPER is OSHA’s Hazard Communication Standard
(HazCom), which you can read for more information.
As we saw in the previous unit, the HazCom Standard requires employers to maintain safety information on
all hazardous substances used in the workplace—not just waste—and to ensure employees who use these
substances understand the dangers and how to protect themselves (Haight, 2012).
Coordinated Help
The EPA, OSHA, and DOT are not alone. The National Response Center (NRC) is a cooperative effort
among 15 federal departments and agencies to coordinate all hazardous materials incident planning and
response across the nation, under the framework of the EPA, DOT, and OSHA regulations and standards
(Haight, 2012). The NRC coordinates with state and local emergency response planning agencies to ensure
EPA, DOT, and OSHA logos
(Department of Labor, n.d.; Department of
Transportation, n.d.; U.S. Government, n.d.)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
[https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099](https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10099)
OSH 2303, Hazardous Materials Safety 3
UNIT x STUDY GUIDE
Title
consistency in emergency response and protection of the public (National Response Team, 2005). If an
incident crosses local or state jurisdictions or local response teams become overwhelmed by the scope of an
incident, an NRC team will be dispatched to provide assistance. All oil and chemical spills required to be
reported under EPA and DOT regulations must be reported by telephone to the NRC. In addition, persons
discovering a spill or release, even if they are not responsible, should contact the NRC (Haight, 2012). In
recent years, the responsibilities of the NRC have been expanded beyond accidental releases of oil and
hazardous substances to include intentional releases and terrorist activities.
Safe containment and cleanup of hazardous material spills and releases begins with an understanding of the
physical and chemical properties of the materials and their toxicity. Safety practitioners and industrial
hygienists are involved with protecting employees from exposure to these substances in the workplace and
are often the best source of the needed information; it is critical that an organization’s safety and health staff
be involved in all spill and release-related planning and discussions. OSHA’s permissible exposure limits
(PELs) are the regulatory standards for worker exposure that must be followed in all spill cleanup operations
(Haight, 2012). The updating of OSHA’s PEL standards, however, has not kept pace with research that
recommends lower exposure limits. Organizations may want to apply the threshold limit value (TLV)
published by the ACGIH. These guidelines are updated annually and represent best practice solutions to
worker exposures.
The geology, hydrology, and meteorology of the area affected by a spill or release also play a significant role
in the planning process (Haight, 2012). Civil engineers and environmental specialists are often the sources for
the needed information. Only after the necessary information is compiled can a plan be developed on who will
respond, how they will respond, how they should be trained, and what equipment they will need.
Effective planning is important to any response operation, but how do you know if the plans will be effective?
Very simply, the plan must be practiced, and a critical evaluation should be conducted. The NRC is an
excellent source for benchmarks against which plans can be measured (National Response Team, 2001).
Risk Assessment
There is much uncertainty surrounding the effects of hazardous substance spills and releases on people and
the environment. Since the 1980s, the EPA has promoted the use of risk assessment as a method to address
Preparedness components under the National Response System
(National Response Team, 2005, slide 37)
OSH 2303, Hazardous Materials Safety 4
UNIT x STUDY GUIDE
Title
this uncertainty (EPA, 2013). The risk assessment process evaluates the probability of an adverse event—in
our case, a hazardous substance release—and the severity of the harm it may cause to people, property, and
the environment. While some of the risk assessment process is subjective and may depend on the knowledge
and experience of the persons conducting it, there are also many resources available to increase reliability.
One such resource is the EPA’s Integrated Risk Information System (IRIS), which is a database of hazardous
materials and their known effects on human health and the environment.
Risk assessments help sort out which events would result in the most serious consequences and which
events are most likely to occur. The ones judged to be the higher risk become the priority for action. In some
cases, it may be appropriate to not plan for the events that are highly unlikely to occur. Determination of these
tolerable risks must be made at the highest level of organizational management. A side benefit of a risk
assessment is often the replacement of a hazardous material with one that is less hazardous or
nonhazardous. Workers will no longer be exposed, and the adverse consequences of a spill have been
mitigated.
While most people do not like to discuss cost when assessing risks to human health, it is important to know
that organizations do not have an infinite amount of money to spend. Risk assessment can help determine
the best use of available funds to protect people and the environment and allow the organization to remain
viable.
In the next unit, we will continue the discussion and look deeper into the requirements and best practices for
developing spill response plans.
References
Department of Labor. (n.d.). US-OSHA-logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:US-OSHA-Logo.svg
Department of Transportation. (n.d.). Seal of the United States Department of Transportation [Image].
Wikimedia Commons. http://commons.wikimedia.org/wiki/File:US-DeptOfTransportation-Seal.svg
Haight, J. M. (Ed.). (2012). Hazardous material management and hazard communication. American Society of
Safety Engineers.
National Response Team. (2001). Hazardous materials emergency planning guide. Environmental Protection
Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
National Response Team. (2005). The National Response System: Federal, state, and local governments
working together to protect Americans from threats to our land, air, and water [PowerPoint slides].
https://www.nrt.org/sites/2/files/NRT-NRS_Outreach_Presentation_12-16-09v10.ppt
Occupational Safety and Health Administration. (n.d.). Hazardous Waste Operations and Emergency
Response (HAZWOPER): Overview. United States Department of Labor.
https://www.osha.gov/SLTC/emergencypreparedness/hazwoper/
United States Environmental Protection Agency. (1992). The guardian: Origins of the EPA.
https://archive.epa.gov/epa/aboutepa/guardian-origins-epa.html
United States Environmental Protection Agency. (2013). About risk assessment: History of risk at EPA.
https://www.epa.gov/risk/about-risk-assessment
United States Environmental Protection Agency. (2014). RCRA orientation manual 2014 (EPA Document No.
530-F-11-003). https://www.epa.gov/sites/production/files/2015-07/documents/rom.pdf
U.S. Government. (n.d.). Environmental Protection Agency logo [Image]. Wikimedia Commons.
http://commons.wikimedia.org/wiki/File:Environmental_Protection_Agency_logo.png
[https://www.epa.gov/iris](https://www.epa.gov/iris)
OSH 2303, Hazardous Materials Safety 5
UNIT x STUDY GUIDE
Title
Suggested Unit Resources
In order to access the following resources, click the links below.
The Environmental Protection Agency (EPA) provides a summary of hazardous substance spill reporting
requirements on the webpage below.
United States Environmental Protection Agency. (2014). When are you required to report an oil spill and
hazardous substance release? https://www.epa.gov/emergency-response/when-are-you-required-
report-oil-spill-and-hazardous-substance-release#oil%20spills
The Emergency Response Guidebook (ERG) is an essential document for any organization that handles
hazardous substances. You can download the 2016 edition of the ERG below. Versions of the ERG for
mobile devices are also available on the U.S. Department of Transportation (DOT) website.
Pipeline and Hazardous Materials Safety Administration. (2016). 2016 Emergency response guidebook. U.S.
Department of Transportation.
https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf
Review the National Response Team’s Hazardous Materials Emergency Planning Guide (pp. 1–14) below.
National Response Team. (2001, July). Hazardous materials emergency planning guide. Environmental
Protection Agency. https://www.epa.gov/sites/production/files/2014-
09/documents/cleannrt10_12_distiller_complete.pdf
Read the fact sheet below, which briefs the topic of hazardous waste operations and emergency response.
Occupational Safety and Health Administration. (2004). Hazardous waste operations and emergency
response [Fact sheet]. U.S. Department of Labor.
https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills](https://www.epa.gov/emergency-response/when-are-you-required-report-oil-spill-and-hazardous-substance-release#oil%20spills)
[https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.pdf](https://www.phmsa.dot.gov/sites/phmsa.dot.gov/files/docs/ERG2016.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/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
[https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf](https://www.osha.gov/OshDoc/data_General_Facts/factsheet-hazardouswaste.pdf)
– Course Learning Outcomes for Unit IV
– Required Unit Resources
– Unit Lesson
– A Cooperative Effort
– Coordinated Help
– Risk Assessment
– References
– Suggested Unit Resources
See attached **files (6)** – ## OHSA4UnitVIIScholarlyActivity.docx – UVII-1.jpg – UVII-3.jpg – UVII-4.jpg – UVII-2.jpg – UnitVII_Template.docx **## OHSA4UnitVIIScholarlyActivity.docx** OHSA 4 Unit VII Scholarly Activity In your current place of employment, your company has a good safety record. The…
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– ## OHSA4UnitVIIScholarlyActivity.docx
– UVII-1.jpg
– UVII-3.jpg
– UVII-4.jpg
– UVII-2.jpg
– UnitVII_Template.docx
**## OHSA4UnitVIIScholarlyActivity.docx**
OHSA 4 Unit VII Scholarly Activity
In your current place of employment, your company has a good safety record. The daily work activities in the plant fall under OSHA’s general industry (1910) standards.
With the success of the company and increased sales, the company has had to hire more workers and convert existing areas of the plant to enable more production. This means the areas formerly used for other purposes not related to production will be unavailable.
Realizing the need, the owners and senior leadership provided the resources to build a new, state-of-the-art multi-purpose building for events, meetings, and training. When it is finished, it will be an impressive sight when visitors or workers arrive at the site.
The new multi-purpose building is 5 (five) stories high, and will contain meeting rooms, training facilities, and a kitchen/dining area on the first floor. The upper floors will host additional meeting rooms and offices for executives and visiting staff, as well as spaces planned for future use.
CSU Construction, Inc., has been contracted to perform this work. However, your company has a team overseeing the work. They have been onsite for approximately 6 months and have completed a considerable amount of work. However, they are still about a year from completion.
All contractors on site have been through your orientation program and are expected to follow your safety rules, which only cover the general industry (1910) standards.
Due to a worker complaint regarding inadequate access and egress at the construction site, the local OSHA Area Office visited the construction site and found several violations, the most serious being the lack of an Emergency Action Plan that does not take the current construction activities into consideration.
Your current EAP only covers the standards (1910) for the existing facility and does not address the construction activities under 29CFR 1926 or the current conditions of the site.
Under the multi-employer policy, your company, as the "controlling" or "host" employer, received the OSHA citation for not having an Emergency Action Plan (EAP) in place that included contracting firms and addressed the current conditions during construction. Therefore, as your company is overseeing the work, as the controlling contractor, you have also been cited and must respond.
You have been brought in to assist the host company in developing and implementing the program required by OSHA under the construction standards (29CFR 1926), which includes all contractors on site and reflects the actual conditions happening at the time.
The ongoing construction activities include concrete masonry units (CMU) block exterior walls and a sloped standing seam metal roof on the exterior, along with underground utility installation requiring excavations. The masons work from scaffolding, and the roofers are tied off to anchor points. They access the roof area using aerial lifts or the exterior stair tower on the south end.
In the interior of the building, framing and drywall are being installed, the electricians are working to install permanent power, and the plumbers and HVAC trades are working from ladders to install their work. Lighting is temporary string lights. The elevator has not been installed yet. However, there is an exterior material lift that also carries the workers to their respective floors where they are working. The stairs have not been installed on the upper floors, and access is gained by using ladders in floor openings that will eventually be covered.
Prepare a written EAP using the
[template attached here](https://online.columbiasouthern.edu/bbcswebdav/pid-17949820-dt-asiobject-rid-173970891_1/xid-173970891_1). It must contain all the information required by 29 C.F.R. 1926.34 and 1926.35. Your plan must address how you will specifically address the requirement for medical services and first aid, means of egress and accountability, and how to notify workers of an emergency and employee training. Additionally, include a section that addresses how you will reduce the risk of and respond to acts of violence at the worksite.
You must include at least two academic references. Adhere to APA Style when creating citations and references for this assignment.
**UVII-1.jpg**
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**UVII-3.jpg**
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**UnitVII_Template.docx**
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**UnitVII_Template.docx**
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**## OHSA4UnitVIIScholarlyActivity.docx**
OHSA 4 Unit VII Scholarly Activity
In your current place of employment, your company has a good safety record. The daily work activities in the plant fall under OSHA’s general industry (1910) standards.
With the success of the company and increased sales, the company has had to hire more workers and convert existing areas of the plant to enable more production. This means the areas formerly used for other purposes not related to production will be unavailable.
Realizing the need, the owners and senior leadership provided the resources to build a new, state-of-the-art multi-purpose building for events, meetings, and training. When it is finished, it will be an impressive sight when visitors or workers arrive at the site.
The new multi-purpose building is 5 (five) stories high, and will contain meeting rooms, training facilities, and a kitchen/dining area on the first floor. The upper floors will host additional meeting rooms and offices for executives and visiting staff, as well as spaces planned for future use.
CSU Construction, Inc., has been contracted to perform this work. However, your company has a team overseeing the work. They have been onsite for approximately 6 months and have completed a considerable amount of work. However, they are still about a year from completion.
All contractors on site have been through your orientation program and are expected to follow your safety rules, which only cover the general industry (1910) standards.
Due to a worker complaint regarding inadequate access and egress at the construction site, the local OSHA Area Office visited the construction site and found several violations, the most serious being the lack of an Emergency Action Plan that does not take the current construction activities into consideration.
Your current EAP only covers the standards (1910) for the existing facility and does not address the construction activities under 29CFR 1926 or the current conditions of the site.
Under the multi-employer policy, your company, as the "controlling" or "host" employer, received the OSHA citation for not having an Emergency Action Plan (EAP) in place that included contracting firms and addressed the current conditions during construction. Therefore, as your company is overseeing the work, as the controlling contractor, you have also been cited and must respond.
You have been brought in to assist the host company in developing and implementing the program required by OSHA under the construction standards (29CFR 1926), which includes all contractors on site and reflects the actual conditions happening at the time.
The ongoing construction activities include concrete masonry units (CMU) block exterior walls and a sloped standing seam metal roof on the exterior, along with underground utility installation requiring excavations. The masons work from scaffolding, and the roofers are tied off to anchor points. They access the roof area using aerial lifts or the exterior stair tower on the south end.
In the interior of the building, framing and drywall are being installed, the electricians are working to install permanent power, and the plumbers and HVAC trades are working from ladders to install their work. Lighting is temporary string lights. The elevator has not been installed yet. However, there is an exterior material lift that also carries the workers to their respective floors where they are working. The stairs have not been installed on the upper floors, and access is gained by using ladders in floor openings that will eventually be covered.
Prepare a written EAP using the
[template attached here](https://online.columbiasouthern.edu/bbcswebdav/pid-17949820-dt-asiobject-rid-173970891_1/xid-173970891_1). It must contain all the information required by 29 C.F.R. 1926.34 and 1926.35. Your plan must address how you will specifically address the requirement for medical services and first aid, means of egress and accountability, and how to notify workers of an emergency and employee training. Additionally, include a section that addresses how you will reduce the risk of and respond to acts of violence at the worksite.
You must include at least two academic references. Adhere to APA Style when creating citations and references for this assignment.
**UVII-1.jpg**
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**UVII-3.jpg**
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**UVII-4.jpg**
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**UVII-2.jpg**
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**UnitVII_Template.docx**
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**## OHSA4UnitVIIScholarlyActivity.docx**
OHSA 4 Unit VII Scholarly Activity
In your current place of employment, your company has a good safety record. The daily work activities in the plant fall under OSHA’s general industry (1910) standards.
With the success of the company and increased sales, the company has had to hire more workers and convert existing areas of the plant to enable more production. This means the areas formerly used for other purposes not related to production will be unavailable.
Realizing the need, the owners and senior leadership provided the resources to build a new, state-of-the-art multi-purpose building for events, meetings, and training. When it is finished, it will be an impressive sight when visitors or workers arrive at the site.
The new multi-purpose building is 5 (five) stories high, and will contain meeting rooms, training facilities, and a kitchen/dining area on the first floor. The upper floors will host additional meeting rooms and offices for executives and visiting staff, as well as spaces planned for future use.
CSU Construction, Inc., has been contracted to perform this work. However, your company has a team overseeing the work. They have been onsite for approximately 6 months and have completed a considerable amount of work. However, they are still about a year from completion.
All contractors on site have been through your orientation program and are expected to follow your safety rules, which only cover the general industry (1910) standards.
Due to a worker complaint regarding inadequate access and egress at the construction site, the local OSHA Area Office visited the construction site and found several violations, the most serious being the lack of an Emergency Action Plan that does not take the current construction activities into consideration.
Your current EAP only covers the standards (1910) for the existing facility and does not address the construction activities under 29CFR 1926 or the current conditions of the site.
Under the multi-employer policy, your company, as the "controlling" or "host" employer, received the OSHA citation for not having an Emergency Action Plan (EAP) in place that included contracting firms and addressed the current conditions during construction. Therefore, as your company is overseeing the work, as the controlling contractor, you have also been cited and must respond.
You have been brought in to assist the host company in developing and implementing the program required by OSHA under the construction standards (29CFR 1926), which includes all contractors on site and reflects the actual conditions happening at the time.
The ongoing construction activities include concrete masonry units (CMU) block exterior walls and a sloped standing seam metal roof on the exterior, along with underground utility installation requiring excavations. The masons work from scaffolding, and the roofers are tied off to anchor points. They access the roof area using aerial lifts or the exterior stair tower on the south end.
In the interior of the building, framing and drywall are being installed, the electricians are working to install permanent power, and the plumbers and HVAC trades are working from ladders to install their work. Lighting is temporary string lights. The elevator has not been installed yet. However, there is an exterior material lift that also carries the workers to their respective floors where they are working. The stairs have not been installed on the upper floors, and access is gained by using ladders in floor openings that will eventually be covered.
Prepare a written EAP using the
[template attached here](https://online.columbiasouthern.edu/bbcswebdav/pid-17949820-dt-asiobject-rid-173970891_1/xid-173970891_1). It must contain all the information required by 29 C.F.R. 1926.34 and 1926.35. Your plan must address how you will specifically address the requirement for medical services and first aid, means of egress and accountability, and how to notify workers of an emergency and employee training. Additionally, include a section that addresses how you will reduce the risk of and respond to acts of violence at the worksite.
You must include at least two academic references. Adhere to APA Style when creating citations and references for this assignment.
**UVII-1.jpg**
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**UVII-3.jpg**
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**UVII-4.jpg**
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**UVII-2.jpg**
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**UnitVII_Template.docx**
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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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**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)