Chapter 6: Health & Safety Program

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Health & Safety Program

Objectives: By the end of this section, participants will be able to assess compliance of the health and safety program and develop a site-specific health and safety plan.

Why this section is important: The Health and Safety Program is the blueprint for a safe workplace, not to mention that is required by OSHA and noncompliance can result in potential liability (in the forms of OSHA fines, lawsuits, worker compensation insurance rate hikes, criminal charges, etc.).

Written Health & Safety Program Requirements

The program must be maintained by the employer and made available to:

Any employee or employee representative,

Any contractor, subcontractor or other representative working for the employer who may be potentially exposed to hazardous substances,

OSHA personnel,

Personnel of federal, state, and local agencies with regulatory authority over the site.

General Components of the Written Health & Safety Program

Organizational Structure: Identifies the specific chain of command in the employer’s organization, and specifies the overall responsibilities of supervisors and employees in carrying out the health and safety program. The structure should also identify the lines of authority, communicating, and coordination among personnel and managers in the organization.

Comprehensive Work Plan: Identifies anticipated cleanup activities as well as normal operating procedures. It should establish implementation strategies for carrying out the training, informational, and medical surveillance programs of the general health and safety program.

Site-Specific Health and Safety Plan (HASP): Must be developed and implemented for each site where workers are potentially exposed to hazardous substances.

Health & Safety Training Program: Must address the hazards present on-site, use of personal protective equipment, work practices to minimize risks, safe use of engineering controls and equipment, and medical surveillance requirements.

Medical Surveillance Program: A detailed plan for ensuring and monitoring the general health of workers engaged in hazardous waste operations.

Standard Operating Procedures: Required for all work practices.

Coordination Procedures: To coordinate comprehensive and site-specific health and safety activities.

Health and Safety Program Comprehensive and Site-Specific Components
Comprehensive Health and Safety Program	Site-Specific Health and Safety Plan (HASP)
Site-specific health and safety plans (HASP)	Key personnel
	Health and safety risk analysis
	Site control measures
	Training assignments
	Medical surveillance requirements
	Personal protective equipment
	Air and employee monitoring
	Spill containment program
	Confined space procedures
	Decontamination procedures
	Emergency response plan
Organizational Structure
Health and safety training program
Medical surveillance program
Standard operating procedures
Coordination procedures

Health & Safety Plan Development & Site Characterization

A site-specific HASP must be developed for each site where workers are engaged in hazardous waste operations.

Development of the site-specific HASP is a process that incorporates the information collected during the site characterization phase of hazardous waste operations.

Site Characterization

Site characterization generally is divided into three phases:

Prior to site entry, the preliminary evaluation is conducted off-site to gather information about the site and to conduct reconnaissance from the site perimeter.

During the second stage, initial site entry is made and preliminary air monitoring is performed. During this phase, site entry is restricted to properly trained and protected reconnaissance personnel.

Once the hazards have been identified to the greatest extent possible, other activities may commence at the site. Monitoring is continued to provide a continuous source of information about site conditions.

Sources of Site-Specific Information

Company records, receipts, worker compensation claims, logbooks, or ledger.

Records and permits from federal and state pollution control regulatory and enforcement agencies, state Attorney General’s office, state Occupational Safety and Health Agencies, state Fire Marshal’s office.

Interviews with personnel and their families (all interview information should be verified).

Generator and transporter records.

Water department and sewage records.

Interviews with nearby residents (note possible site-related medical problems and verify all information from interview).

Local fire and police department records.

Court and utility company records.

Verified media reports.

Previous surveying (including soil, ground-penetrating radar, and magnetometer surveys), sampling, and monitoring data.