technologies for the suppression of toxic vapors or for spill control must be evaluated by the Such evaluations must be made employer or a representative prior to being introduced to the site. available, upon request. to OSHA.

(p) Certain Operations Conducted Under BCRA: TSD facilities must comply with this paragraph. Compliance shall include:

8.

Decontamination program:

New technology program;

Material handling program; and

Training program.

New Employees - a minimum of 24 hours of instruction off-site and 8 hours of annual
refresher training.

Documentation showing equivalent training to that specified for a new

employee is acceptable.

Emergency response program - a full emergency response program, including a written emergency response plan plus appropriate training is required. The written plan can incorporate by reference any written documentation included in TSDF permits. The Emergency Response Plan shall include the following elements:

A. Planning & Coordination

B. Lines of Authority, Roles, & Communications

C. Emergency Recognition & Prevention

D. Safe Distances & Places of Refuge

E. Site Security & Control

F. Evacuation Routes and Procedures

G. Decontamination Procedures

H. Emergency Medical Treatment & First-aid

I. Emergency Alerting & Response

J. Critique & Follow-up

K. PPE & Equipment

Training - Employees need to be trained prior to being required to respond to a real emergency. The training must be to a level of competence to perform safely and effectively. The training to a level of competency must be repeated annually, and the emergency response plan must be rehearsed regularly as part of the overall training program of the site.

(q) Emergency Response to Hazardous Substance Releases :

This includes municipal first

This paragraph covers emergency responders not elsewhere covered. responders. HAZMAT teams, company response teams who respond to hazardous material emergencies, and anyone else not specifically provided for in other parts of the regulation. Generators and other affected Companies, must comply with this paragraph. Compliance shall include:

Personal roles, lines of authority, training and communication
Emergency recognition and prevention

(ii)

(iii)

(iv)

Safe distances and places of refuge

(xiii) Plans to use outside (including local) Emergency Responders

(3)

(4)

Skilled or Specialist Employees can be used as needed, provided their safety is protected.
All personnel must be trained based on their duties and functions.

(1)

(ii)

(iii)

First Responder Awareness Level those who may discover or report the spill
First Responders

those who perform the initial steps to secure. control, and contain the spill. (from a safe distance).

Hazardous Materials Technicians - individuals who respond to spills for the purpose

PREFACE

(5)

(10)

of clean-up. They shall be more highly trained and experienced than First Response
Operations Level personnel. These people will clean-up most industrial spills.
Incident Commander the person(s) who organize and control the complete spill

response.

·

Employees must receive sufficient annual training to maintain the level of competency gained
during their initial training.

(6) Baseline and periodic medical surveillance must be provided.

(7)

(8)

All chemical protective equipment must meet OSHA requirements contained in 1910.120(g).

Post-Emergency response procedures specifying actions which may be necessary after the
emergency is mitigated.

(Appendix B)

General Description and Discussion of Levels of Protection and Protection Gear.
(Appendix C) Compliance Guidelines

INTERPRETATION

Employers at CERCLA or Equivalent Sites

Employers at any site that looks like a CERCLA "clean-up"
site, whether Federally ordered, State ordered, or

voluntary, must comply with all parts of this regulation
(b) through (0). The specific items which must be

addressed in the compliance program are:

A. Develop a written Safety and Health Plan which addresses each element mandated in
paragraphs (b) - (o).

Employers at a RCRA Treatment, Storage, or Disposal (or
Recycling) Facility must comply with all elements contained
in paragraph (p). The specific items which must be
addressed in the compliance program include:

A.

B.

Develop a written safety and health plan which addresses each element in paragraphs
(p) (1) - (p) (8).

Develop a written Emergency Response Plan.

COPYRIGHT INFORMATION

HAZARDOUS CHEMICAL SAFETY is provided

hazardous

Inc.

as a

materials

service to the
industry. Copyright C 1987 by CHEMICAL
SAFETY ASSOCIATES,
all rights
reserved. Printed in the United States
of America. No part of this manual may
be reproduced, stored in a retrieval
system, or transmitted in any form or by any
means, electronic, mechanical, photocopying,
recording, or otherwise, except for the
use of U.S. ARMY DUGWAY PROVING GROUND and
individuals who obtain written permission
directly from CHEMICAL SAFETY ASSOCIATES,
Inc.

ASSOCIATES,

CHEMICAL SAFETY
Inc.
acknowledges the use of materials provided
by the Justrite Manufacturing Company, the
Matheson Gas Company, and the US
Occupational Safety
Health
Administration (US-OSHA)

The

and

staff of CHEMICAL SAFETY ASSOCIATES,
Inc. is prepared to assist you to develop
and implement your chemical safety program.
Ask your instructor or contact our office
for more information.

San Diego, CA 1987

INTRODUCTION

Prior to 1970, few chemical regulations existed. Some

states,

notably New Jersey and California imposed regulations on a limited number of chemicals. Some Federal agencies, such as the Interstate Commerce Commission and the Food and Drug Administration imposed regulations on chemicals in-transit and on some consumer goods. The general public was unaware of chemicals in the workplace or in the environment. The situation today is completely

changed.

Chemicals, companies which use chemicals, companies which produce chemicals, and companies which dispose of chemicals are all tightly and rigorously regulated. What happened in the past two decades to cause

this dramatic change?

Love Canal leaked. The water in Santa Clara valley (California) became contaminated. Falcon eggs lost their

viability. Chemical manufacturing plants in Bophal, India,

Servasco, Italy, and Henderson, Nevada exploded.

people became scared.

this fear is referred to as

Today, this

And

"Chemophobia".

Local, State, and Federal legislators, in response to the problems, publicity, and pressure from their constituents produced the laws and regulations with which we now must

now comply.

INTRODUCTION to CHEMICAL REGULATIONS