HAZWOPER and Clandestine Labs

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HAZWOPER and Clandestine Labs

• Dave Appel IDEM Health Safety Director

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HAZWOPER

• Hazardous waste operations and emergency response
  standards (29 CFR 1910.120) apply to the
  following situations
• Clean-up operations required by a governmental
  body at uncontrolled hazardous waste sites
• Voluntary clean-up operations at uncontrolled
  hazardous waste sites
• Operations involving hazardous waste that are
  conducted at treatment, storage, disposal (TSD)
  facilities
• Emergency response operations

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HAZWOPER Clan Labs

• How does this apply?
• Uncontrolled hazardous waste site means an area
  identified as an uncontrolled hazardous waste
  site by a governmental body where an accumulation
  of hazardous substances creates a threat to the
  health and safety of individuals or the
  environment or both.

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HAZWOPER

• What is required?
• Site Specific Health Safety Plan
• Site Characterization
• Training
• Medical Surveillance
• Engineering controls, work practices and personal
  protective equipment
• Air Monitoring
• Drums and container handling
• Decontamination

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HAZWOPER

• 29 CFR 1910.120(e) Training Required
• All employees working on site (such as but not
  limited to equipment operators, general laborers
  and others) exposed to hazardous substances,
  health hazards, or safety hazards and their
  supervisors and management responsible for the
  site shall receive training before they are
  permitted to engage in hazardous waste operations
  that could expose them to hazardous substances,
  safety, or health hazards.
• Employees shall not be permitted to participate
  in or supervise field activities until they have
  been trained to a level required by their job
  function and responsibility

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Hazwoper Training

• Elements to be covered
• Names of personnel and alternates responsible for
  site safety and health
• Safety, health and other hazards present
• Use of PPE
• Work practices by which the employee can minimize
  risks from hazards
• Safe use of engineering controls and equipment
• Medical surveillance requirements including
  recognition of symptoms and signs which might
  indicate over exposure to hazards

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• Initial training
• General site workers (such as equipment
  operators, general laborers and supervisory
  personnel) engaged in hazardous substance removal
  or other activities which expose or potentially
  expose workers to hazardous substances and health
  hazards shall receive a minimum of 40 hours of
  instruction off the site, and a minimum of three
  days actual field experience under the direct
  supervision of a trained experienced supervisor

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HAZWOPER Training

• Workers on site only occasionally for a specific
  limited task (such as, but not limited to, ground
  water monitoring, land surveying, or geophysical
  surveying) and who are unlikely to be exposed
  over permissible exposure limits and published
  exposure limits shall receive a minimum of 24
  hours of instruction off the site, and the
  minimum of one day actual field experience under
  the direct supervision of a trained, experienced
  supervisor.
• Workers with 24 hours of training who become
  general site workers or who are required to wear
  respirators, shall have the additional 16 hours
  and two days of training necessary to total the
  40 hours of training.

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Management and supervisor training

• On-site management and supervisors directly
  responsible for or who supervise employees
  engaged in hazardous waste operations
• 40 hours initial and three days of supervised
  field experience (the training may be reduced to
  24 hours and one day if the only area of their
  responsibility is employees requiring only 24
  hours of training) and at least eight additional
  hours of specialized training at the time of job
  assignment
• Such topics may be, the employer's safety and
  health program, personal protective equipment
  program, spill containment program, and health
  hazard monitoring procedure and techniques.

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Refresher Training

• Employees, managers and supervisors that have
  completed the 40 hour or 24 hour training shall
  receive eight hours of refresher training
  annually
• Any critique of incidents that have occurred in
  the past year that can serve as training examples
  of related work, and other relevant topics.

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(No Transcript)
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Site Specific Health and Safety Plan (HASP)

• Addresses hazards associated with any site work
  to be conducted
• Identifies work practices, equipment, PPE,
  emergency procedures, etc.
• Requires site research
• Must be adjusted based upon site conditions-not a
  static document
• May be generated from a template but with site
  specific information

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Site Characterization

• A preliminary evaluation of a site's
  characteristics shall be performed prior to site
  entry by a qualified person in order to aid in
  the selection of appropriate employee protection
  methods prior to site entry.
• Immediately after initial site entry, a more
  detailed evaluation of the site's specific
  characteristics shall be performed in order to
  further identify existing site hazards and to
  further aid in the selection of the appropriate
  engineering controls and personal protective
  equipment for the tasks to be performed.
• Assessment will be based upon the work to be
  performed or anticipated

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Medical Surveillance

• All employees who are or may be exposed to
  hazardous substances or health hazards at or
  above the established permissible exposure limit,
  above the published exposure levels for these
  substances, without regard to the use of
  respirators, for 30 days or more a year
• All employees required to wear a respirator gt30
  days per year
• Any employee that develops signs or symptoms of
  an exposure

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Personal Protective Equipment

• PPE must selected based upon the types of hazards
  suspected or encountered
• PPE must be designated for each task
• Employees must be trained on all aspects of the
  PPE

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• Chemical PPE Selection Guidebook

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Respiratory Protection

• Written program is required
• Respirator and cartridge selection must be based
  on the hazards known or anticipated
• All employees must be medically approved prior to
  use
• All employees must be fit tested on the exact
  make, model, and size of respirator that they
  will be using
• All employees must be trained

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Respiratory Protection
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Respiratory Protection
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Respiratory Protection

• Voluntary use of respirators
• Sometimes, workers may wear respirators to avoid
  exposures to hazards, even if the amount of
  hazardous substance does not exceed the limits
  set by OSHA standards.
• No medical surveillance or fit testing is
  required
• NIOSH Approved respirators should be used

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Air Monitoring

• Air monitoring is essential for initial site
  characterization
• No one instrument can do it all

• Photionization Detector (PID)
• Measures volatile organic compounds
• Ultraviolet light use for ionization source
• Not chemical specific
• Ionization potential critical for instrument use
• Good suitability for Clan Lab investigations

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Air Monitoring

• Flame Ionization Detector (FID)
• Uses a hydrogen flame as ionization source
• Ionization potential irrelevant
• Cannot be used in temperatures lt40 degree F
• Expensive and difficult to use
• Good suitability for Clan Lab investigations

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Air Monitoring

• Direct reading tubes
• Measure concentration of specific contaminants
  instantaneously
• Chemical specific
• Requires hand operated pump
• Clan Lab kits available

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Air Monitoring

• PID/Multimeter Combination
• Combination PID and CGI

• Small and lightweight
• Capable of reading VOCs, CO, H2S, LEL, O2
• SO2, NO, NO2, Cl2, HCN, NH3, PH3 sensors
  available

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Hazard Communication

• Requires employers to inform employees of all the
  hazards associated with materials used in the
  workplace
• MSDS Requirements
• Employee Right to Know
• Utilization of on-line resources is beneficial in
  determining hazardous chemical involved in meth
  production

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Hazard Communication
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Confined Spaces
Categorizing a Work Space
Space large enough to enter Limited or
Restricted entry or exit Not designed for
continuous worker occupancy.
NO
Not a confined Space
YES
Confined Space
Permit- Required Confined Space
Non Permit Required Space
Hazardous Atmosphere
Or
Engulfment Hazard
YES
NO
Or
Configuration Hazard
Or
Any other recognized serious hazard
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Confined Spaces
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Confined Spaces

• If exit is blocked or cannot remain open it could
  result in becoming a confined space

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Permit Required Confined Space

• A confined space that has one or more of the
  following characteristics becomes a Permit
  Required Confined Space
• Contains or has a potential to contain a
  hazardous atmosphere.
• Contains a material that has the potential for
  engulfing an entrant.
• Has an internal configuration such that an
  entrant could be trapped or asphyxiated by
  inwardly converging walls or by a floor which
  slopes downward and tapers to a small
  cross-section.
• Contains any other recognized serious safety or
  health hazard.

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Bloodborne Pathogens

• Limits occupational exposure to blood and other
  potentially infectious materials since any
  exposure could result in transmission of
  bloodborne pathogens which could lead to disease
  or death.
• Covers all employees who could be "reasonably
  anticipated" as the result of performing their
  job duties to face contact with blood and other
  potentially infectious materials.

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Bloodborne Pathogens

• Blood and other potentially infectious body
  fluids include
• Semen
• Vaginal secretions
• Cerebrospinal fluid
• Synovial fluid
• Pleural fluid
• Peritoneal fluid
• Amniotic fluid
• Saliva (in dental procedures), and
• Any body fluid that is visibly contaminated with
  blood.

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Bloodborne Pathogens

• Hepatitis B
• Standard requires the employer to offer HBV
  vaccinations to employees affected.
• Hepatitis C
• HIV
• HBV and HIV are most commonly transmitted
  through
• Sexual Contact
• Sharing of hypodermic needles
• From mothers to their babies at/before birth
• Accidental puncture from contaminated needles,
  broken glass, or other sharps
• Contact between broken or damaged skin and
  infected body fluids
• Contact between mucous membranes and infected
  body fluids
• Accidental puncture from contaminated needles and
  other sharps can result in transmission of
  bloodborne pathogens.

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Bloodborne Pathogens

• BBP Standard addresses
• PPE, Work Practices Engineering Controls
• Hygiene Practices
• Decontamination and Sterilization
• Signs, Labels Color Coding
• Emergency Procedures (for exposures)

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Conclusion

• General Duty Clause 5a(1)
• The OSHA Catch-All
• Each employer --Shall furnish to each of his
  employees employment and a place of employment
  which are free from recognized hazards that are
  causing or are likely to cause death or serious
  physical harm to his employeesShall comply
  with occupational safety and health standards
  promulgated under this Act.Each employee shall
  comply with occupational safety and health
  standards and all rules, regulations, and orders
  issued pursuant to this Act which are applicable
  to his own actions and conduct

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Conclusion

• HAZWOPER has a direct application to Clan Lab
  operations and clean up
• Each company should develop a Health Safety
  Plan to deal with issues associated with Clan
  Labs
• Hazard recognition, evaluation, and training is
  key
• Preplanning and preparation facilitate site work
• Dont forget other applicable OSHA standards
• Utilize the resources provided
• No job is worth jeopardizing worker safety