514 EM 385-1-1 Chapters 30-37

36-7. Minimum Plan Requirements.

Site Safety and Health Plan (SSHP) Development

The SSHP must be developed for all environmental cleanup and investigation projects, addressing SOH hazards, employee protection requirements, and procedures for each phase of site operation.
It must include site description, contamination characterization, staff organization, qualifications, responsibilities, training types and frequency, hazard evaluation, occupational exposure controls, risk analysis, exposure sampling and monitoring, medical surveillance, thermal stress management, SOPs, site control measures, personal hygiene and decontamination procedures, and emergency response and contingency procedures.
Changes to the SSHP require written modifications with SHM concurrence and USACE supervisor approval or KO or COR acceptance.

Comprehensive Work Plan

A Comprehensive Work Plan is necessary for all environmental cleanup and investigation projects, to be developed as per 29 CFR 1910.120(b)(3) or 29 CFR 1926.65(b)(3).

Emergency Response Plan

Required for facilities or projects using, storing, or handling hazardous substances, to be developed in line with 29 CFR 1910.120(q) or 29 CFR 1926.65(q).
Must include operations identification, pre-emergency planning with local emergency responders, personnel roles, lines of authority, training, communication, emergency recognition and prevention, safe distances, places of refuge, site security and control, evacuation routes and procedures, decontamination, emergency medical treatment and first aid, emergency alerting and response procedures, PPE and emergency equipment, designation of an Emergency Response Team, and critique of response and follow-up.
Projects that will evacuate their employees from the danger area when an emergency occurs, and do not permit any of their employees to assist in handling the emergency or providing spill mitigation steps must instead of an Emergency Response Plan, provide an Emergency Action Plan.

Knowledge Check Choose the best answer for the question.

36-5. What plan is required if an employer does not intend to evacuate employees in response to an emergency?

Fire Prevention Plan

Hazard Communication Plan

Emergency Action Plan

Emergency Response Plan

You forgot to answer the question!

EM 385-1-1 Paragraph 36-7.

36-7. Minimum Plan Requirements.

a.  Site Safety and Health Plan (SSHP).  A SSHP must be developed for all environmental cleanup and investigation projects.  The SSHP must address the SOH hazards of each phase of site operation and include the requirements and procedures for employee protection.  The SSHP must specifically address the requirements to protect workers from the health hazards associated with site contamination and the specific processes that may disturb, release, and/or transport these contaminants during the planned investigation or remedial action activities.  See chapter 6 of this manual for radiation safety requirements to be included in the SSHP for cleanup of
radioactive isotopes. Changes and modification to the SSHP are permitted and must be made in writing with the concurrence of the SHM and approved by the USACE supervisor or accepted by the KO or COR.  The SSHP must be developed according to
29 CFR 1910.120(b)(4)/ 29 CFR 1926.65(b)(4) and as described below.  The SSHP
must include the following:  (36-7.a)

(1)  Site Description and Contamination Characterization.  A description of the site, location and approximate size, description of activities to be performed, duration of the planned activity, site topography and accessibility (air and road), pathways of hazardous
    substance dispersion. A description of the contamination based on the information or data obtained from site characterization and analysis activities performed according to
    29 CFR 1910.120(c)/ 29 CFR 1926.65(c).

(2)  Staff organization, qualifications, and responsibilities (see para 36-4).

(3)  Type and frequency of required training, both general and project specific
    (see para 36-3).

(4)  Hazard Evaluation.  Detailed evaluation of the hazards related to the contamination expected to be encountered, OEL, exposure route, exposure symptoms, health effects, odor and if available odor threshold, and target organs.  Provide the determination of the potential exposure levels and routes based on sampling data and/or the composition of the substance, work process, exposure controls, type of media, and routes of exposure.

(5)  Occupational Exposure Controls.  Detail the controls that will be implemented to protect workers from exposure to contamination.  Detail any hazard elimination/substitution steps, engineering and administrative controls, and PPE that will be utilized, see chapter 5 for PPE requirements.  Identify the frequency of inspections
    for controls and the personnel responsible for conducting inspections and sampling/monitoring.

(6)  Risk Analysis.  The risk analysis must evaluate the overall risk for the planned environmental cleanup or investigation project and how planned exposure controls, and the work process will eliminate or reduce the likelihood for exposure to contaminates during each site task and activity.

(7)  Occupational Exposure Sampling and Monitoring Procedures.  Detail the occupational exposure sampling and monitoring to be implemented to ensure measures to protect workers from overexposure to site contaminates are adequate and effective. This must include frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instrumentation to be used, including methods of maintenance and calibration of monitoring and sampling equipment to be used. Include project specific action levels and exposure mitigation measures to be taken if action levels are exceeded.  Detail how these records will be maintained and managed.

(8)  Medical Surveillance.  Summarize the medical surveillance provided to employees on this project and how these records will be maintained and managed (see para 36-3.b).

Note.  Do not include medical clearance certificates or medical documents containing PII, PHI or other protected information in the SSHP.  Provide a summary of personnel with date of last medical clearance and the applicable standard.

(9)  Thermal Stress Management Plan.  Detail the procedures and practices that will be implemented to protect and monitor workers from heat and cold stress during the performance of the environmental cleanup and investigation project.  See chapter 6 for Thermal Stress Management Plan requirements.

(10)  SOPs, engineering controls, and work practices to include the following:

(a)  Site rules/prohibitions (for example, buddy system, eating/drinking/ smoking restrictions.).

(b)  Work permit requirements (for example, radioactive work, excavation, hot work, confined space).

(d)  Drum/container/tank handling (for example, opening, sampling, overpacking, draining, pumping, purging, inerting, cleaning, excavating and removal, disassembly and disposal, spill contingency).

(11) Site Control Measures.  Describe how the site will be set up so that access into and out of the EZ through the CRZ will be controlled.  Define how work activities inside the EZ will be conducted to prevent spread contamination to uncontaminated areas of the project.

(12) Personal Hygiene and Decontamination Procedures.  Describe equipment to be used and step-by-step procedures to be followed that will assure personnel and equipment are decontaminated properly when exiting the EZ through the CRZ and into the support zone.

(13) Emergency Response and Contingency Procedures.  Document a plan for responding to emergencies at the project the meets the requirements in 29 CFR
    1910.120(l) or 29 CFR 1926.65(l).  Emergency response and contingency procedures must address the following:

(a)  Describes the agreement that will be established between the contractor (or USACE for in-house activities), local emergency responders, and the servicing emergency medical facility.  Identify the Emergency Response Team that would dispatch to the cleanup and investigation site at the time of an emergency, their contact information and capabilities.  Specify the responsibilities of onsite personnel, the site configuration, specific details about site activities with emergency response personnel and the emergency medical facility in the event of an on-site emergency.

(b)  Personnel and lines of authority for emergency situations.

(c)  Criteria and procedures for emergency recognition and site evacuation (for example, emergency alarm systems, evacuation routes and reporting locations, site security).

(d)  Decontamination and medical treatment procedures of injured personnel.

(e)  A route map to emergency medical facilities and phone numbers for emergency responders.

(f)  Criteria for alerting the local community responders.

(14) Confined Spaces.  If confined spaces must be entered to perform cleanup work, then detail the site-specific confined space entry procedures according to chapter 34.

(15)  Spill Containment.  Describe equipment to be used and procedures to be followed to store contaminated media and investigative derived waste generated by cleanup activities.  Identify drum and container handling procedures when applicable to the work. Include spill containment procedures to contain spills of contaminated media stored onsite.

b.  Comprehensive Work Plan.  A Comprehensive Work Plan is required for all environmental cleanup and investigation projects.  The plan must be developed according to 29 CFR 1910.120(b)(3) or 29 CFR 19126.65(b)(3).  (36-7.b)

c.  Emergency Response Plan.  An Emergency Response Plan is required for facilities or construction projects using, storing, or handling hazardous substances where a hazardous substance release may result in exposure causing adverse effects to the health or safety of employees.  The plan must be developed according to 29 CFR 1910.120(q) or 29 CFR 1926.65(q).  The Emergency Response Plan for hazardous spill Response must include the following:  (36-7.c)

Note. Projects that will evacuate their employees from the danger area when an emergency occurs, and do not permit any of their employees to assist in handling the emergency or providing spill mitigation steps must instead of an Emergency Response Plan, provide an Emergency Action Plan according to 29 CFR 1910.38 or
29 CFR 1926.35.

(1)  Operations. Identify operations requiring use of hazardous substances. (2)  Pre-Emergency Planning with Local Emergency Responders.  Describe
    emergency response agreements, including roles and responsibilities, made with local emergency responders for hazardous material response, fire, rescue, emergency medical care, and security and law enforcement.

(3)  Personnel Roles, Lines of Authority, Training, and Communication.  Describe key personnel roles, command structure/lines of authority, and communications requirements for responding to site-specific hazardous substance releases.

(4)  Emergency Recognition and Prevention.  Identify the likely emergency scenarios for the project and how employees can expect to identify and recognize emergency scenarios.

(5)  Safe Distances and Places of Refuge.  Select safe places of refuge to be used in emergency situations, identify these locations in the Emergency Response Plan, and require employees to report to selected places of refuge during emergencies.

(6)  Site Security and Control.  Describe how the facility will be secured and describe access to the site controlled during emergencies.

(7)  Evacuation Routes and Procedures.  Describe and map out evacuation routes to safe places of refuge and any special safety and health procedures employees must follow while evacuating the facility.

(8)  Decontamination.  Describe site procedures for decontaminating personnel and equipment that may have come into contact with hazardous substances.

(9)  Emergency Medical Treatment and First Aid. Explain how emergency medical treatment and first aid will be provided in the event of a hazardous substance spill.

(10) Emergency Alerting and Response Procedures.  Describe how personnel will be alerted in the event of a hazardous substance spill, and how facility personnel must respond after emergency alerting procedures are initiated.

(11) PPE and Emergency equipment.  Describe the PPE and emergency response equipment that will be available for use by response personnel at the facility.

(12) Emergency Response Team.  Designate a facility-specific Emergency Response Team. Describe the team’s emergency responsibilities for interacting with local emergency response providers (that is, where the facility team’s responsibilities end, and the local response providers begin).

(13) Critique of Response and Follow-up.  Describe how lessons learned from emergency response will be documented and used to improve future emergency response actions.