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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. 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

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  1. Emergency Response What Is Expected by OSHA Before and During an ER? David Ippolito USDOL/OSHA Director Office of Science and Technology Assessment

  2. World Trade Center Early October 2001 David Ippolito 202-693-2334

  3. View from the southwest November 01 David Ippolito 202-693-2334

  4. One of thousand of samples taken by OSHA David Ippolito 202-693-2334

  5. Antenna from the north tower David Ippolito 202-693-2334

  6. 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

  7. 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

  8. 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

  9. 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

  10. 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

  11. 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

  12. 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

  13. 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

  14. 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

  15. 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

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  17. 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

  18. 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

  19. 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

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  21. 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

  22. .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

  23. Typical decontamination station David Ippolito 202-693-2334

  24. 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

  25. 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

  26. 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

  27. 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

  28. 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

  29. 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

  30. David Ippolito 202-693-2334

  31. Questions THANK YOU David Ippolito 202-693-2334

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