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Emergency Response. What Is Expected by OSHA Before and During an ER?. David Ippolito USDOL/OSHA Director Office of Science and Technology Assessment. World Trade Center Early October 2001. View from the southwest November 01. One of thousand of samples taken by OSHA.

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emergency response

Emergency Response

What Is Expected by OSHA

Before and During an ER?

David Ippolito

USDOL/OSHA

Director

Office of Science and Technology Assessment

slide2

World Trade Center Early October 2001

David Ippolito 202-693-2334

slide3
View from the southwest November 01

David Ippolito 202-693-2334

slide4
One of thousand of samples taken by OSHA

David Ippolito 202-693-2334

slide5
Antenna from the north tower

David Ippolito 202-693-2334

presentation objectives
Presentation Objectives
  • Discuss the most common OSHA standards involving emergencies in general industry
  • Provide OSHA’s insight into common emergency response situations in general industry
  • Answer your questions on what is acceptable to OSHA

David Ippolito 202-693-2334

some basic osha expectations
Some Basic OSHA Expectations
  • Employee protection is priority # 1
  • Fully consider the widest range of worst case scenarios when deciding your emergency actions
  • As the employer expects more from its employees, OSHA expects more of the employer
  • Plan, communicate and train --- train, communicate and plan

David Ippolito 202-693-2334

so what constitutes a workplace emergency
So What Constitutes a Workplace Emergency?
  • Webster - an unforeseen combination of circumstances or the resulting state that calls for immediate action
  • An unexpected and uncontrolled event that has seriously harmed or threatens harm to workers
  • 1910.1200 - any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace

David Ippolito 202-693-2334

fundamentals
Fundamentals
  • 29 CFR 1910.36 and 37 (emergency egress)
    • Sufficient # for the occupancy
    • Exit ways and access thereto are unobstructed
    • Exit ways and access thereto are clearly marked
    • Exit signs are visible at night
    • Emergency lighting is supplied when needed
    • OSHA is the authority having jurisdiction

David Ippolito 202-693-2334

fundamentals10
Fundamentals
  • 1910.151 requires the availability of emergency first aid
  • Requires emergency body and eyes flushing where contact with corrosives can occur
  • 1910.124 – requires “appropriate first-aid supplies” when employees work with dipping and coating chemicals

David Ippolito 202-693-2334

designated first aid responders
Designated First Aid Responders
  • 1910.1030 – addresses protection required against blood borne pathogens - your designatedand collateral duty first aiders are covered
    • ECP
    • Training on Universal Precautions and the standard
    • HBV vaccinations and post exposure follow-up
  • Collateral Duty Exception

David Ippolito 202-693-2334

personal protective equipment
Personal Protective Equipment
  • OSHA Subpart I – 1910.132-138
    • Assess your emergency plan to ensure that PPE needs have been anticipated
    • Provide the required PPE
    • Train and re-train employees (as necessary) on its use, maintenance and limitations
    • Verify and then certify that training was completed

David Ippolito 202-693-2334

emergency use respiratory protection
Emergency Use Respiratory Protection
  • Written program
  • Provide a respirator for the worst case anticipated use
  • Inspect emergency use respirators monthly
    • Inspections must include certification
    • Date, signature, findings, S/N and any actions taken e.g. “Tank filled”
  • Train employees on emergency use
  • Medically evaluate employees

David Ippolito 202-693-2334

broad scope emergency standards
Broad Scope Emergency Standards
  • Employee emergency response plans: 1910.38(a)
    • Does your plan include evacuation?
    • Is it required by a specific OSHA standard?
    • If so, you must follow this standard
    • The elements are an excellent starting point for all evacuation plans

David Ippolito 202-693-2334

who must comply with 1910 38 a
Who Must Comply with 1910.38 (a)
  • Employer’s requiring some employees to use portable fire extinguishers and others to evacuate
  • Employers who must supply portable fire extinguishers but require their employees to evacuate only
  • Employers who require employees to evacuate during certain emergencies e.g. total area flooding or, evacuation during a release of a toxic substance Ref: 1910.120(q)
  • Specific health standards – 1910.1047

David Ippolito 202-693-2334

before the emergency occurs
BEFORE the Emergency Occurs
  • Plan safe evacuation for the range of anticipated emergencies
  • Assign roles to execute the plan
  • Identify the means to report emergencies
  • Prepare written plan that describes roles and evacuation procedures
  • Train employees on the plan and assigned roles
  • Implement and alarm system per 1910.165
  • Coordinate with outside responders as necessary
  • Document your efforts, meeting minutes, training records, disciplinary actions - employee declinations

David Ippolito 202-693-2334

during an emergency
During an Emergency
  • If your planning and preparation is deficient, your response certainly will be….
    • The larger, more newsworthy the event, the more likely OSHA will be there
    • OSHA will normally inspect the management of both the emergency crisis and its consequence
    • The more reasonably anticipated the emergency, the higher the expectation that the employer will respond appropriately

David Ippolito 202-693-2334

broad scope standards cont
Broad Scope Standards cont.
  • Hazardous Waste Operations & Emergency Response: 1910.120 (q)
    • Applies anywhere an emergency chemical release can occur
    • All Haz-Mat responders are covered
    • Performance Oriented

David Ippolito 202-693-2334

prior to the haz mat emergency
Prior to the Haz-Mat Emergency
  • 1910.120(q) requires…
  • A written plan, available upon request to OSHA that considers….
  • Pre-planning and coordination w/outside parties
  • Identified personnel roles, lines of authority, training and communication e.g. the ICS system
  • Training on emergency recognition and prevention
  • Safe Distances and Refuge

David Ippolito 202-693-2334

120 q continued
.120(q) continued
  • Site security and control
  • Evacuation Routes and Procedures
  • Decontamination
  • Emergency Medical Treatment + First Aid
  • Critique of Response and Follow-Up
  • PPE and Emergency Equipment

David Ippolito 202-693-2334

slide23
Typical decontamination station

David Ippolito 202-693-2334

during a haz mat emergency
During a Haz-Mat Emergency
  • Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards encountered……
  • IC can appoint a safety officer to oversee personnel safety

David Ippolito 202-693-2334

emergency haz mat roles during an emergency
Emergency Haz-Mat Roles During an Emergency
  • The roles that you decide for your employees determine their level of involvement and the amount of training
    • First responder Awareness – Determines if ER needed and notify
    • First responder Operations – Protect – Contain - Exclusion Zone
    • Hazardous Materials Tech. – Control at source + Remediation
    • Hazardous Materials Specialist –could be the “Safety Officer” – liaison with outside responders
    • Incident Commander Level – has Operations Level Training with authoritative and unilateral decision making ability

David Ippolito 202-693-2334

emergencies at plants covered by 1910 119
Emergencies at Plants Covered by 1910.119
  • Focuses on preventing accidental releases.
  • The employer must establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR 1910.38(a).
  • The emergency action plan shallinclude procedures for handling small releases.
  • Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p) and (q).
  • .119 requires the training of on-site contractors.

David Ippolito 202-693-2334

site security
Site Security
  • Assess your liabilities and risks
  • Identify your soft underbelly and firm it up
  • The greater the consequence, the greater the need for security
  • Develop a security culture – employees and contractors
  • Develop a strong working relationship with local police and first responders
  • Http://www.ncjrs.Org/pdffiles1/nij/195171.pdf

David Ippolito 202-693-2334

miscellaneous emergency related issues
Miscellaneous Emergency Related Issues
  • Confined Spaces – Emergency Rescue
  • Significant Spills must be reported to the NRC
    • 800-424-8802
  • Must report a fatality or hospitalization of 3 or more employees to OSHA within 8hrs.

David Ippolito 202-693-2334

summary
Summary
  • Assess your reasonably anticipated worst case emergency potentials
  • Decide on how involved you want your employees in emergency response
  • Ensure that employees are adequately trained, provided with the right equipment or otherwise fully prepared for the worst case response based on their level of involvement

David Ippolito 202-693-2334

questions
Questions

THANK YOU

David Ippolito 202-693-2334