HAZWOPER AND HAZWOPER RCRA

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1 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 1 f 9 Purpse This requirement cvers emergency and pst-emergency respnse peratins standards, t include training fr persnnel respnding t releases r substantial threats f releases chemical r petrleum prducts withut regard t the lcatin f the hazard. Even thugh there is a specific sectin devted t hazardus materials and emergency respnse (29 CFR ), this sectin des nt encmpass all wrk prcedures arund emergency respnse and 29 CFR 1910 and 29 CFR 1926 cntinue t apply in every respect during emergency respnse peratins. If there is an apparent cnflict r verlap, the prvisin that is mre prtective f emplyee health and safety shall apply. Emergency respnse effrts n land r water t releases f chemicals r petrleum prducts riginating frm RELIANT HOLDINGS LTD AND ITS AFFILIATES facilities r in the curse f transprtatin will cmply with the requirements f 29 CFR (q). The primary cncern in emergency respnse is the safety and security f respnding persnnel. Scpe This sectin applies t all emplyees and independent cntractrs emplyed by and/r cntracted t RELIANT HOLDINGS LTD AND ITS AFFILIATES when respnding t chemical releases. Definitins Emergency respnse: A respnse effrt by emplyees frm utside the immediate release area r by ther designated respnders (e.g., mutual-aid grups, lcal fire departments, etc.) t an ccurrence which results, r is likely t result, in an uncntrlled release f crude il r petrleum prducts. Pst emergency respnse: That prtin f an emergency respnse perfrmed after the immediate threat f a release has been stabilized r eliminated and clean-up f the site has begun. Health hazard: Chemicals which are carcingens, txic agents, reprductive txins, irritants, crrsives, sensitizers, heptatxins, nephrtxins, neurtxins, agents which act n the hematpietic system, and agents which damage the lungs, skin, eyes, r mucus membranes. It als includes stress due t temperature extremes Requirements Written Safety and Health Prgram and Emergency Respnse Plan RELIANT HOLDINGS LTD AND ITS AFFILIATES and any cntractrs r subcntractrs shall develp and implement a written pre-incident safety and health prgram t handle anticipated emergencies prir t the cmmencement f emergency respnse peratins fr their emplyees wh are expected t be invlved in any prduct spill emergency and pst emergency respnse peratins. The prgram shall be designed t identify, evaluate and cntrl safety and health hazards and t prvide fr safe respnse effrts t prduct spill emergency and pst emergency respnse Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

2 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 2 f 9 peratins. These prgrams shall be described in cntrlled manuals identified as cntingency plans r hazardus materials handling prcedures. The plan shall be in writing and available fr inspectin by emplyees, their representatives and OSHA representatives. The fllwing elements must be included in either a specific site safety plan r a cmbinatin f plans addressing the respnse activity: Pre-emergency planning and crdinatin with utside parties Persnnel rles, lines f authrity, training and cmmunicatin Emergency recgnitin and preventin Safe distances and places f refuge Site security and cntrl Evacuatin rutes and prcedures A decntaminatin prcedure shall be develped by the RELIANT HOLDINGS LTD AND ITS AFFILIATES safety ffice, cmmunicated t emplyees thrugh training and implemented thrugh drills befre any emplyees r equipment may enter areas n site where ptential fr expsure t hazardus substances exists. Emergency alerting and respnse prcedures Critique methd t evaluate the respnse and assure fllw-up Persnal prtective equipment and spill cntrl, cntainment, and recvery equipment Site and wrker mnitring t ensure prtective actins are cmmensurate with the cnditins at the site. Engineering cntrls, wrk practices and PPE shall be used t reduce and maintain expsure limits. Feasible engineering cntrls include the use f pressurized cabs r cntrl bths n equipment and/r the use f remtely perated material handling equipment. Prcedure Use f the fllwing safety and cntrl prcedures will be used by thse in charge at the scene t ensure the safety and health f persnnel at spill lcatins. Persn Discvering the Spill Survey and Secure the Area. Evaluate the seriusness f the situatin in regard t prtecting persnnel and the public. D nt apprach the spill if yu can smell hydrcarbns r ptential chemical surces. Ntify yur supervisr as sn as pssible. Remember, any device yu use t call in spill ntice may nt be intrinsically safe. Place yur call frm a safe distance. If the situatin requires, stay at the scene and cntrl access at a safe distance frm the spill until the initial respnse team arrives. The spill area will becme subject t regulatry cntrls with restricted access Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

3 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 3 f 9 Initial Spill Cntrl Actins Initial spill cntrl actins designed t halt the spread f a spill, direct its mvements, r minimize the area affected by the spill shall nt be initiated in the immediate spill area until all f the fllwing ccur: A cmplete site safety analysis Air mnitring shall be used t identify and qualify airbrne levels f hazardus substances. The mnitring will address initial entry, peridic mnitring, pssible IDLH cnditins and wherever expsure may be a pssibility. Gas detectr readings are 10% r less f the lwer explsive limit (LEL). If the readings are abve 10% f the LEL, spill cntrl actins shall be terminated in the immediate area and mved t an area where LEL cnditins are less than 10%. Initial Apprach and Gas Testing Gas testing persnnel shall be trained t cmpetently perate their equipment and ther site specific requirements. Cmbustible gas detectrs (LEL meters) must have current calibratins and be functin tested prir t an apprach t a spill site. At a minimum, the xygen, LEL and permissible expsure level (PEL) must be evaluated thrughut the regulated area at as many pints arund the spill perimeter as pssible. These levels shall be mnitred peridically thrughut the wrk shift t detect changes in airbrne hazards that may result frm wrk activities, changing weather cnditins, etc. Apprach t the incident site. Perfrm a functin test and check the zer reading n the gas detectr. Dn the respiratr. Observe the readings n the gas detectrs as yu apprach the spill site. Cntinue until ne f the fllwing cnditins ccurs. Yu can see all that yu need t bserve, r The gas detectr reads 10% r mre f the LEL, r Liquid il r gas cndensates are encuntered. CAUTION Care must be taken t keep the gas detectrs warm and prevent rugh handling. NOTE If any f these cnditins are exceeded, d nt prceed any clser t the spill perimeter. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

4 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 4 f 9 NOTE Decntaminatin units, first aid kits, and eye flushing supplies shall be functinal and nsite prir t attempting cntact with liquid il r gas cndensates. After the initial bservatins are perfrmed, the site cnditins shall be reprted t the Incident Cmmander. Mark r flag an exclusin area (ht zne) arund the spill site t further cntrl access. Safety Prcedures fr Exclusin Areas Persnnel shall be given a safety briefing n the specific hazards and hazard cntrl prcedures prir t entering the spill site. Decntaminatin units, first aid kits, and eye flushing supplies shall be functinal and n-site prir t attempting cntact with spill materials. T minimize persnnel expsure and reduce ptential ignitin surces, where pssible, all initial appraches t the suspected spill site will be frm the upwind directin. Persnnel shall nt apprach the site r attempt gas testing withut wearing apprpriate respiratry prtectin. Persnal Prtective Equipment (PPE) and Chemical Prtective Clthing Respiratry Prtectin - During spill respnse peratins when gas detectrs read 10% r mre f the LEL, trained gas testing persnnel shall measure PEL levels t determine apprpriate respiratry prtectin levels. Skin Prtectin - The fllwing PPE is recmmended t minimize dermal expsure t chemicals: Hands: neprene, nitrile r butyl rubber glves Feet: neprene, nitrile r butyl rubber bts Bdy: cated tyvek r PVC rain suits (as necessary) Eye Prtectin - At a minimum, safety glasses must be wrn. If a splash hazard t the eyes is present, chemical gggles r a face shield with chemical gggles shall be used. Eye prtectin is nt required if a full-face respiratr is wrn. NOTE: Either ne-piece r tw-piece chemical (magnum 445) suits can be used. Glves and bts can be taped t the arms and legs f the suits as needed. The flaps f a tw-piece suit can be taped as well. Heavy duty duct tape is recmmended Other Cnsideratins The purpse f persnal prtective clthing and equipment is t shield r islate individuals frm the chemical, physical, and bilgical hazards assciated with handling crude il. N single cmbinatin f prtective equipment and clthing is capable f prtecting against all hazards. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

5 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 5 f 9 Cnsider the fllwing: The use f PPE can itself create significant wrker hazards, such as heat stress, physical and psychlgical stress, and impaired visin, mbility, and cmmunicatin. Equipment and clthing that prvide an adequate level f prtectin shall be used. Overprtectin, as well as under prtectin, shuld be avided where pssible. Pst-Emergency Respnse Cleanup r Decntaminatin Prcedures All emplyees leaving a cntaminated area shall be apprpriately decntaminated and all cntaminated clthing and equipment leaving a cntaminated area shall be apprpriately dispsed f r decntaminated. Engineering cntrls, wrk practices and PPE shall be used t reduce and maintain expsure limits. RELIANT HOLDINGS LTD AND ITS AFFILIATES des nt prvide remval f cntaminated substances such as sil r ther elements f the natural envirnment. Decntaminatin prcedures shall be mnitred by the RELIANT HOLDINGS LTD AND ITS AFFILIATES safety department t determine their effectiveness. When such prcedures are fund t be ineffective, apprpriate steps shall be taken t crrect any deficiencies Where the decntaminatin prcedure indicates a need fr regular shwers and change rms utside f a cntaminated area, they shall be prvided and meet the requirements f 29 CFR Decntaminatin shall be perfrmed in gegraphical areas that will minimize the expsure f uncntaminated emplyees r equipment t cntaminated emplyees r equipment. Take int cnsideratin grund water, wind directin, cnstructin material, barriers and fencing, signage and training. PPE and equipment shall be decntaminated, cleaned, laundered, maintained r replaced as needed t maintain their effectiveness. Emplyees whse nn-impermeable clthing becmes wetted with hazardus substances shall immediately remve the clthing. Unauthrized emplyees shall nt remve prtective clthing r equipment frm change rms. General Safety/Physical Hazards During training drills, spill respnses, and remediatin peratins, the physical wrking envirnment f persnnel shall be cntinually evaluated. Expsure t either ht r cld weather cnditins alng with lng wrking hurs, culd adversely affect bth the psychlgical and physilgical cnditin f thse invlved. Cntinued expsure may result in physical discmfrt, lss f efficiency, and a higher susceptibility t accidents and injuries. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

6 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 6 f 9 Persnnel must be cnstantly alert t signs f distress and eliminate r prtect against accident causes. There is a need t cnstantly review methds and prcedures fr rutine wrk and emergency respnse situatins s that all persnnel may functin as safely and effectively as pssible. Supervisin shall keep the fllwing prcedures and safety precautins in mind when wrking with petrleum and petrleum prducts and as decisins are made in hw the wrk is t be cnducted: A jb shall be planned and all persnnel briefed as t the prcedures t be fllwed and the respnsibilities f each persn. Supervisin shall remain n the jb at all times r designate a qualified persn t take their place if called away. When respnding t hydrcarbn spills r gas leaks, the hazardus area shall be defined. N persnnel r equipment shall be permitted in the area f a spill until the hazards assciated with the cntaminated area have been clearly defined by a qualified persn. Befre mving t the jb site, supervisin shuld check tls and safety equipment (including persnal prtective equipment), t ensure everything is safe, usable, and all required tls and safety equipment are available Vehicles, heavy equipment, hand tls, and pwer equipment shall nt be mved int a spill area until adequate precautins have been taken. When pwer equipment is mved int a spill area t expedite repairs, it shuld be remved frm the area as sn as wrk with it is cmpleted. Persnnel wh are nt required shuld be kept ut f the wrk area. Use f matches, lighters, and smking materials shall be in a place designated as safe by supervisin. Upn cmpletin f equipment repairs, necessary perating checks shuld be made befre placing the unit in service. The senir fficial at an emergency respnse site is the mst senir fficial n the site wh has the respnsibility fr cntrlling peratins at the site. Medical Surveillance Any emergency respnse persn wh exhibits signs r symptms which may have resulted frm expsure t hazardus substances during the curse f an emergency shall be prvided with medical cnsultatin at n cst t them. This shall include all emplyees wh are r may be expsed t hazardus substances r health hazards at r abve the established permissible expsure limit, abve the published expsure levels fr these substances, withut regard t the use f respiratrs, fr 30 days r mre a year. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

7 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 7 f 9 Training The RELIANT HOLDINGS LTD AND ITS AFFILIATES new hire rientatin prgram trains all new RELIANT HOLDINGS LTD AND ITS AFFILIATES emplyees and independent cntractrs s they will knw what t d in case they witness r discver a chemical release. They are instructed t leave the area and take n further actin beynd ntifying the RELIANT HOLDINGS LTD AND ITS AFFILIATES facility peratins persnnel f the release. Training fr emplyees expected t participate in an emergency r pst-emergency respnse shall be cmpleted befre they take part in respnse peratins. RELIANT HOLDINGS LTD AND ITS AFFILIATES and cntractr persnnel shall receive initial and refresher training. The level f training received will be cmmensurate with their assigned duties and functins and take place in the area they are wrking in. Initial Emergency Respnse Training Wh Needs Emergency Respnse Training? Supprt Persnnel: This designatin applies t RELIANT HOLDINGS LTD AND ITS AFFILIATES r cntractr persnnel wh are supprting in the peratin f equipment r material (such as general labrers, equipment peratrs, mechanized earth mving peratrs r crane and histing equipment peratrs), and wh are needed temprarily t perfrm immediate emergency supprt wrk that cannt reasnably be dne in a timely manner by RELIANT HOLDINGS LTD AND ITS AFFILIATES emplyee respnders. Supprt persnnel wh will be r may be expsed t the hazards at an emergency respnse scene shall be trained n the use f persnal prtective equipment and als will cver wrk practices which minimize hazardus risks and safe use f engineering cntrls & equipment. First Respnder Awareness Level: RELIANT HOLDINGS LTD AND ITS AFFILIATES persnnel wh are likely t witness r discver a hazardus substance release and have been trained t initiate an emergency respnse sequence by ntifying RELIANT HOLDINGS LTD AND ITS AFFILIATES facility peratins persnnel f the release. Persnnel at this level must receive initial training r have had enugh experience t bjectively demnstrate cmpetency. Annual refresher training r demnstratin f cmpetency is als required. First Respnder Awareness Level emplyees shall have sufficient training r experience t bjectively demnstrate cmpetency in the fllwing areas: An understanding f what hazardus substances are, and the risks assciated with them in an incident. An understanding f the ptential utcmes assciated with an emergency created when hazardus substances are present. The ability t recgnize the presence f hazardus substances in an emergency. The ability t identify the hazardus substances if pssible. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

8 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 8 f 9 An understanding f the rle f the first respnder awareness individual in the client s emergency respnse plan including site security and cntrl and the U.S. Department f Transprtatin s Emergency Respnse Guidebk. The ability t realize the need fr additinal resurces, and t make apprpriate ntificatins. First Respnder Operatins Level: RELIANT HOLDINGS LTD AND ITS AFFILIATES persnnel wh are identified in cntingency plans as respnders t releases r ptential releases f hazardus materials -- as part f the initial respnse t the site fr the purpse f prtecting nearby persns, prperty, r the envirnment frm the effects f the release -- shall be trained t this level. Their functin is t cntain the release frm a safe distance and help it frm spreading. All persnnel at this level must receive 8 hurs f initial training r have had sufficient experience t bjectively demnstrate cmpetency. Annual refresher training r demnstratin f cmpetency is als required. Certificatin is required. Hazardus Materials Technicians: RELIANT HOLDINGS LTD AND ITS AFFILIATES persnnel, wh are identified in cntingency plans as respnders t releases r ptential releases f hazardus materials fr the purpse f stpping the release, shall be trained t this level. Technicians have the knwledge f hw t implement emergency respnse plans, knw the classificatin, identificatin and verificatin f knwn r unknwn substances, functins with an assigned rle in the incident cmmand system, hw t select and use prper PPE, perfrm advanced cntainment and understands decntaminatin and txiclgy. All persnnel at this level must receive at least 24 hurs f training equal t first respnder peratins level. Annual refresher training r demnstratin f cmpetency is required. Certificatin is required. Hazardus Materials Specialists: All RELIANT HOLDINGS LTD AND ITS AFFILIATES and persnnel wrking as field Safety Specialist shall be trained t this level. Material Specialists receive at least 24 hurs f training the technical level and have the ability t develp a site and safety cntrl plan. Annual refresher training r demnstratin f cmpetency is als required. Certificatin is required. On-Scene Incident Cmmander: The Incident Cmmander must have at least 24 hurs f training equal t the first respnder peratins level and knw hw t implement the prgram and system, PPE requirements, hazard and risk assessment, state and federal regulatins and all elements f decntaminatin. Certificatin is required. Pst-Emergency Respnse Training Fr chemical spills, a minimum f fur hurs f training fr pst-emergency respnse wrkers wh have jb duties and respnsibilities with a lw magnitude f risk shall ccur. Refresher Training Emplyees trained fr Initial Emergency Respnse Training must receive annual refresher training f sufficient cntent and duratin t maintain their cmpetencies r shall demnstrate cmpetencies in thse Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

9 Reliant Hldings Ltd and Its Affiliants Dc N: SOP-31 Revisin Date: Initial Versin Revisin N. 0 Next Revisin Date: Preparatin: Safety Mgr Authrity: President Issuing Dept: Safety Page: Page 9 f 9 areas at least annually. RELIANT HOLDINGS LTD AND ITS AFFILIATES must keep recrds f all emplyee training r cmpetency demnstratins. Participatin in drills, cmpletin f apprved respnse training mdules, and n-the-jb training based n the duties and functins each emplyee is expected t perfrm during an emergency respnse may be substituted fr, r used in cnjunctin with, frmal classrm training t demnstrate cmpetency. If demnstrated cmpetency is used in lieu f r in cnjunctin with classrm training, then RELIANT HOLDINGS LTD AND ITS AFFILIATES must keep a recrd f the methdlgy used t demnstrate cmpetency. Trainers and Training Material The Safety Manager shall designate wh has the respnsibility t apprve trainers and training materials used in RELIANT HOLDINGS LTD AND ITS AFFILIATES prvided training fr emplyees wh are identified in cntingency plans as respnders t hazardus material spills, emergency and pst-emergency respnse peratins. All instructrs shall have the training and r academic credentials and instructinal experience t demnstrate cmpetency. Uncntrlled cpy if printed. Valid n day f printing nly. Printed n: 24 January :54 AM COMPANY 2010

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