ER 385192

1
ER 385-1-92

• Safety Occupational Health Document
  Requirements for HTRW OEW Activities

2
Purpose
To identify the safety and occupational health
documents and procedures required to be developed
and implemented by USACE and its contractors in
executing HTRW OEW activities, including
investigation, design, and construction.
3
Applicability
Applies Corps-wide vertically for all field
activities performing or contracting HTRW OEW
activities including civil works projects.
4
Definitions
HTRW Activities Includes activities for EPA
Superfund, Defense Environmental Restoration
Program (DERP) including FUDS and IRP sites at
active DoD installations and any HTRW activities
at civil works projects.
5
Other Definitions Include

• Safety Health Program
• Qualified Industrial Hygiene Personnel
• Site Safety Health Plan
• (Will satisfy Accident Prevention Plan
  Requirement of EM 385-1-1 if incorporates
  required activity hazard analysis)

6
Design District Responsibilities

• Develop all SH design documents including SSHPs,
  Health Safety Design Analysis (HSDAs) and SH
  specifications
• Conduct detailed technical review of all required
  investigation, pre-design and design related SH
  documents
• Coordinate HTRW design document development and
  review with CX SOH office as required and
  appropriate.

7
SH Documents
Safety and Health Program as Defined by OSHA
8
SH Documents

• Site Safety Health Plan
• For investigations, design, construction, OM
  by USACE or USACE contractors
• Describes site specific SH procedures, practices
  equipment
• Protects affected workers from hazards of the
  site specific tasks to be performed
• Addresses OSHA and Appendix B topics

9
SH Documents

• Health Safety Design Analysis
• All HTRW project design analyses must include a
  chapter on SH
• Provide SH considerations for project by project
  task
• Justifies the SH requirements which are to be
  specified in the contract
• Addresses topics of Appendix B

10
SH Documents

• Safety, Health Emergency Response
  Specifications
• All HTRW contract specifications must contain SH
  section describing the SH requirements developed
  in the HSDA
• SH section shall incorporate applicable
  Appendix B topics
• Must use CEGS 1351 Safety, Health Emergency
  Response

11
ER 385-1-92APPENDIX B
Safety Health Elements for HTRW OEW Documents
12
Appendix B Key Ideas

• 1. Site Description Contamination
  Characteristics
• Past uses of site
• Contaminants to expect concentration ranges
  found

13
Appendix B Key Ideas

• 2. Hazard/Risk Analysis
• Tasks to be performed safety, chemical,
  physical, radiological biological hazard
  analysis by task
• Establish action levels methods to eliminate
  hazards identified

14
Appendix B Key Ideas

• 3. Staff Organization, Qualifications
  Responsibilities
• CIH responsible for development,
  implementation, oversight of contractors SH
  program SSHP (CSP for USTs)
• Two people qualified in first aid
• Occupational physician board certified or board
  eligible

15
Appendix B Key Ideas

• 4. Training
• Need 40 hours training plus 3 days supervised
  field experience to enter contaminated zones
• Supervisors need 8 hour supervisor training
• Site-specific hazard training

16
Appendix B Key Ideas

• 5. Personal Protective Equipment
• Explain PPE components for each site specific
  task to be performed based on the task specific
  hazard analysis

17
Appendix B Key Ideas

• 6. Medical Surveillance
• ALL on-site personnel exposed to hazards due to
  HTRW work - typically includes everyone going
  beyond support zone.
• Medical approval certificate must be appended to
  SSHP
• Records must comply with OSHA

18
Appendix B Key Ideas

• 7. Radiation Dosimetry
• Minimum dosimetry requirements when working
  within radioactive restricted area

19
Appendix B Key Ideas

• 8. Exposure Monitoring/Air Sampling Program
• Use of appropriate monitoring equipment including
  both real-time time-integrated equipment when
  potential for exposure has been determined
• Defines sampling techniques, calibration
  analysis to be used

20
Appendix B Key Ideas

• 9. Heat/Cold Stress Monitoring
• Physiological monitoring protocols work rest
  schedule required
• Monitoring to commence at 70?F above
• WBGT-index TLVs NOT specified

21
Appendix B Key Ideas

• 10. Standard Operating Safety Procedures,
• Engineering Controls Work Practices
• Includes site rules, work practices, controls
  work required permits

22
Appendix B Key Ideas

• 11. Site Control Measures
• Requires the establishment of work
  zones/restricted work areas based on site
  contamination characterization data task
  specific hazard analyses

23
Appendix B Key Ideas

• 12. Personal Hygiene Decontamination
• Addresses decontamination SOPs supplies
• 13. Equipment Decontamination
• Facilities, equipment SOPs

24
Appendix B Key Ideas

• 14. Emergency Equipment First Aid
• Requirements
• 15. Emergency Response Contingency
• Procedures
• Key requirement to pre-notify local emergency
  response people about planned site activities.
  Need response agreement

25
Appendix B Key Ideas

• 16. Accident Prevention
• Daily safety health inspection
• Notification of CO completion of accident
  report
• 17. Logs, Reports Recordkeeping