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Training Marine Oil Spill Response Workers under OSHA’s Hazardous Waste Operations and Emergency Response Standard

U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3172

About this Booklet

This informational booklet is intended to provide a generic, non-exhaustive overview of a particular standards-related topic. This publication does not itself alter or determine compliance responsibilities, which are set forth in OSHA standards themselves and the Occupational Safety and Health Act. Moreover, because interpretations and enforcement policy may change over time, for additional guidance on OSHA compliance requirements, the reader should consult current and administrative interpretations and decisions by the Occupational Safety and Health Review Commission and the Courts.

Material contained in this publication is in the public domain and may be reproduced, fully or partially, without permission of the Federal Government. Source credit is requested but not required.

This information will be made available to sensory impaired individuals upon request. Voice phone: (202) 693-1999 Teletypewriter: (TTY) 1-877-889-5627 See also OSHA’s Website at http://www.osha.gov
Contents

Introduction
How Marine Oil Spill Responses Are Organized and Managed
Applying the HAZWOPER Standard to Marine Oil Spills
Hazards to Marine Oil Spill Responders
Training Requirements
Oil Spill Scenario
Other Sources of OSHA Assistance
Appendix A: Related OSHA Standards and Directives
Appendix B: Related OSHA Publications
Appendix C. OSHA Offices
Footnote Figures and Tables
Figure 1. Training Decisions Flowchart for Emergency Response Workers
Figure 2. Training Decisions Flowchart for Post-Emergency Response Cleanup Workers
Figure 3. Sample Certifications
Figure 4. Illustration of Incident
Table 1. Hazardous Chemicals and Their Effects
Table 2. Training for Workers Who Perform Emergency Response
Table 3. Training for Workers Who Perform Only Post-Emergency Response
Table 4. Training Topics and Competency Areas

Introduction

This booklet, written for marine oil spill response employers,* describes the training your employees need under HAZWOPER, the Hazardous Waste Operations and Emergency Response standard, Title 29 of Code of Federal Regulations (CFR) 1910.120. The Occupational Safety and Health Administration (OSHA) published HAZWOPER to protect workers involved in hazardous substance emergency response and cleanup operations.

Not every spill response worker needs the same amount of training. The type of training you give your workers depends on how close they will be to a spill and what role they will have in stopping, containing, or recovering the spilled material from the release. For example, if you have workers who control an oil spill early in an incident, they need more training than workers who simply warn others about a spill. This booklet explains how HAZWOPER training requirements apply to the range of workers who participate in marine oil spill response. To use this guidance effectively, you need to know the duties you expect your workers to perform and the exposure conditions under which you would allow them to work. You must train your workers to the highest level of skill, responsibility, and exposure that you will assign them.

This booklet was prepared by Office of Health Enforcement in conjunction with the U.S. Coast Guard Office of Response.

*Oil spill response accounts for the majority of marine spill response operations and is the focus of this pamphlet. HAZWOPER training, however, is required for all marine spill response operations conducted under the National Contingency Plan. The training you provide must cover the range of hazardous substance spills you expect your marine response employees to handle.

How Marine Oil Spill Responses Are Organized and Managed

Marine oil spill response is organized and managed according to the regulations found in 40 CFR 300, the National Oil and Hazardous Substance Pollution Contingency Plan (NCP). These regulations describe procedures for responding to hazardous substance releases and oil discharges. Appendix E of the regulation specifically addresses oil spill response. The U.S. Coast Guard (USCG) and the Environmental Protection Agency (EPA) jointly led the development of the NCP.

Marine oil spill response involves a network of government agencies, community organizations, industry groups, and contractors. Federal and/or state agencies usually monitor the responsible party (generally the owner or operator of the vessel, facility, port, or pipeline involved in the spill). The Federal Government can direct cleanup operations if the responsible party does not respond adequately, is not capable of taking action, or is unknown.

An On-Scene Coordinator (OSC) acts as the leader for response activities. In the coastal areas of the United States, USCG serves as the OSC for oil spill responses. In inland areas, including rivers and other inland waters, EPA generally takes the lead.

HAZWOPER requires that a senior official who is present at the response site, an Incident Commander, lead an emergency response operation. For marine oil spills, the ranking Coast Guard officer or EPA official at the spill scene usually functions as the On-Scene Incident Commander. The emergency response remains in effect until the Incident Commander declares it completed.

OSHA is responsible for assuring safe and healthful working conditions for working men and women. During marine oil spill response, OSHA provides advice and consultation at the request of other government agencies. If necessary, OSHA uses enforcement action to assure that workers are properly protected.

Emergency Response vs. Post-Emergency Response

The HAZWOPER standard identifies two basic phases of a response action: emergency response and post-emergency response. Depending on the size of the spill, these phases may be managed differently. In addition, workers who participate ONLY in post-emergency response require different training than emergency response workers receive.

Emergency response is “a response effort…to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance” (29 CFR 1910.120(a)(3)). For marine oil spills, an uncontrolled release is a situation in which the oil and its associated airborne and surface contamination hazards are releasing into the environment or are in danger of releasing into the environment and posing a worker exposure hazard. Oil in grounded ships, which is in danger of being released into the environment, represents an emergency response situation. Onwater containment, skimming operations, and underwater oil recovery operations also are considered to be emergency response activities because the oil is still in danger of being released into the environment. Shoreline cleanup is normally considered to be a post-emergency response unless the oil is below the high-tide mark or storm surge boundary (active or forecasted) and can reasonably be expected to be re-released into the marine environment.

Post-emergency response is performed “after the immediate threat of a release has been stabilized or eliminated and cleanup of the site has begun” (29 CFR 1910.120(a)(3)). Oil spilled into a marine environment is considered to be stabilized when it is in a stable container with no compromised structural integrity, to limit the potential for worker exposure to associated hazards. This includes floating bladders, barges, drums, and roll-off containers on shore. Oil also is considered to be stabilized when it is stranded on shore and not reasonably expected to rerelease into the environment through wave or storm effects. Floating oil is not considered to be stabilized, even if contained within a boom.

During response to a large release such as a marine oil spill, emergency response and postemergency response cleanup activities may occur at the same time. In these cases, the boundaries between the emergency response area and the post-emergency response area must be well defined and explained to responders and cleanup workers.

Applying the HAZWOPER Standard to Marine Oil Spills

HAZWOPER Requirements that Apply to Marine Oil Spills

The NCP defines oil as any kind of oil in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes but not dredged spoil (dirt or rock).

Response actions conducted under the NCP must comply with the provisions of HAZWOPER. You’ll find this requirement in 40 CFR 300.150. Therefore, if your workers are participating in a response action under the NCP, you must have an occupational safety and health program consistent with HAZWOPER and you must train your workers according to HAZWOPER’s training requirements. This applies whether the responsible party or a government agency is directing the cleanup.

For marine oil spill emergency response, the HAZWOPER provisions that most directly apply include:
Emergency response operations in HAZWOPER paragraph (q), and
Post-emergency response cleanup operations in paragraph (q)(11).
See also emergency response training provisions in paragraph (q)(6), and post-emergency response training requirements in paragraph (q)(11).

When HAZWOPER Does Not Apply

The NCP defines oil as any kind of oil in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes but not dredged spoil (dirt or rock.)

HAZWOPER does not apply to incidental releases that are limited in quantity and pose no safety and health threat to employees working in the immediate vicinity of the spill. These oil spills can be absorbed or controlled at the time of the release by employees in the immediate vicinity. The difference between emergency spills and incidental releases is described in the definition of emergency response in HAZWOPER paragraph (a)(3). An incidental release does not have the potential to become an emergency within a short time. If an incidental release occurs, employers do not need to implement HAZWOPER.

HAZWOPER Coverage for Volunteers

Volunteers frequently participate in marine oil spill response, but Federal OSHA standards do not cover uncompensated workers. In states approved to manage their own occupational health and safety program (called OSHA state plan states), volunteers are often covered under state plan HAZWOPER requirements. In states administered by Federal OSHA, volunteers are covered by the EPA HAZWOPER standard (40 CFR 311). EPA’s HAZWOPER standard has identical requirements, but the coverage is different from Federal OSHA standard coverage. The EPA standard covers local and state government employees, both compensated and volunteers.

Hazards to Marine Oil Spill Responders

Marine oil spill responders face a variety of health and safety hazards, including fire and explosion, oxygen deficiency, exposure to carcinogens and other chemical hazards, heat and cold stress, and safety hazards associated with working around heavy equipment in a marine environment. A full discussion of these hazards is beyond the scope of this training booklet, but a brief list of hazards and their known health consequences is shown in Table 1. Your workers should be trained to anticipate and control exposure to the hazards associated with their assigned duties.

To determine acceptable levels of exposure and train your workers about them, consult OSHA’s exposure limits in Subparts G and Z. If OSHA does not regulate an exposure of concern, consult the National Institute for Occupational Safety and Health (NIOSH) Recommended Exposure Limits (RELs) and Immediately Dangerous to Life and Health (IDLH) levels. If neither OSHA nor NIOSH has established a limit, consult the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) and Biological Exposure Indices (BEIs) for chemical, physical, and biological agents. You may use a more protective limit than OSHA’s if one has been established and plan your controls accordingly. Material Safety Data Sheets from the product manufacturer may provide useful information for worker training.

Additional Hazards Marine oil spill responders need training to work safely around these and other potential hazards. You should decide which hazards apply to your operations.
Biological (e.g., plants, animals, insects, remediation materials)
Drowning
Noise
Electricity
Slips and Trips
Biohazardous debris (e.g., syringes on shoreline)
Ergonomic Stresses (e.g., repetitive strain, low back pain)
Sunburn
Confined Spaces
Underwater Diving
Falls
Unguarded Equipment
Cranes
Fatigue
Vehicles (e.g., aircraft, boats, cars, trucks)
Cutting and Welding
Fire and Explosion
Degreasers
Heat or Cold Stress
Dispersants
In-Situ Burning Particles
Other OSHA standards apply to marine oil spill response and cleanup operations. See Appendix A, Related OSHA Standards.

Table 1. Hazardous Chemicals and Their Effects

Hazardous Chemicals – Adverse Health Effects

Benzene (crude oils high in BTEX, benzene, toluene, ethylbenzene, and xylene) – Irritation to eyes, skin, and respiratory system; dizziness; rapid heart rate; headaches; tremors; confusion; unconsciousness; anemia; cancer

Benzo(a)pyrene (a polycyclic aromatic hydrocarbon reproductive [see below], formed when oil or gasoline burns) – Irritation to eyes and skin, cancer, possible effects

Carbon dioxide (inerting atmosphere, byproduct of combustion) – Dizziness, headaches, elevated blood pressure, rapid heart rate, loss of consciousness asphyxiation, coma

Carbon monoxide (byproduct of combustion) – Irritation to eyes, skin, and respiratory Dizziness, confusion, headaches, nausea, weakness, loss of consciousness, asphyxiation, coma

Ethyl benzene (high in gasoline) – Irritation to eyes, skin, and respiratory system; loss of consciousness; asphyxiation; nervous system effects

Hydrogen sulfide (oils high in sulfur, decaying plants and animals) – Irritation to eyes, skin, and respiratory system; dizziness; drowsiness; cough; headaches; nervous system effects

Methyl tert-butyl ether (MTBE) (octane booster and clean air additive for gasoline, or pure MTBE) – Irritation to eyes, skin, and respiratory system; headaches; nausea; dizziness; confusion; fatigue; weakness; nervous system, liver, and kidney

Polycyclic aromatic hydrocarbons (PAHs) (occur in crude oil, and formed during burning of oil) – Irritation to eyes and skin, cancer, possible reproductive effects, immune system effects

Sulfuric acid (byproduct of combustion of sour petroleum product) – Irritation to eyes, skin, teeth, and upper respiratory system; severe tissue burns; cancer

Toluene (high BTEX crude oils) – Irritation to eyes, skin, respiratory system; fatigue; confusion; dizziness; headaches; memory loss; nausea; nervous system, liver, and kidney effects

Xylenes (high BTEX crude oils) – Irritation to eyes, skin, respiratory system; dizziness; confusion; change in sense of balance; nervous system gastrointestinal system, liver, kidney, and blood effects

Training Requirements

HAZWOPER training requirements that apply to marine oil spill emergency response are located in 29 CFR 1910.120(q)(6). Requirements and training guidance for post-emergency response are in HAZWOPER paragraph (q)(11) and in OSHA Instruction CPL 02-02-051, Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120. The HAZWOPER training requirements are based on your workers’ assigned duties during an oil spill. For example, if you have deck hands who are assigned to equipment decontamination during and after an oil spill, you need to provide the level of HAZWOPER training required for the duties and hazards of the decontamination tasks.

Figures 1 and 2 comprise a training decision flowchart. Begin at the top of the chart (Figure 1) if your workers participate in emergency response. Begin at Figure 2 (indicated by the arrow) if your workers perform cleanup only after the release is stabilized (post-emergency). Emergency response workers may perform cleanup activities without further HAZWOPER training if you can certify that they have the skills and knowledge to do so safely.

After you determine the type(s) of training your workers need, turn to Table 2 or 3, as indicated on Figure 1. These tables show each type or category of training described in the flowchart. Table 2 contains the emergency response training requirements. For each type of emergency response training shown in the flowchart, Table 2 lists the specific HAZWOPER training requirements and examples of corresponding oil spill job functions.

Table 3 shows post-emergency response training. In the left-hand column, you’ll find the hazard characteristics that distinguish each type of training because this is how the HAZWOPER standard itself separates cleanup training categories. Verify that the hazards your workers might face fit within the training category you’ve chosen. Table 3 also lists the HAZWOPER training requirements and examples of job functions that might require that training.

Training Content

Because workers need to be trained before they respond, you should train your emergency response workers to the highest level of responsibility they might need to assume. You should train your cleanup workers to the highest exposure conditions they may encounter. You must never expect or allow your workers to perform an emergency response or cleanup operation without proper training and certification.

Table 4 lists training topics and competencies for categories of training described in Tables 2 and 3. The listed topics paraphrase the HAZWOPER required competencies listed in paragraphs (q) and (e) of the standard. As an example, if your workers perform defensive actions for all emergency response operations, they need 8 hours of training in areas 31-36 and competency in areas 25-30 on Table 4. This is equivalent to HAZWOPER requirements for the first-responder operations level in (q)(6)(ii) of the standard.

Certifying and Updating Training

Workers who receive HAZWOPER training must receive a written certificate when they successfully complete the training. This is a requirement of paragraphs (e)(6) and (q)(6). Figure 2, Sample Certifications, illustrates examples of training certification cards given to workers completing various levels of HAZWOPER training. You do not need to repeat the initial training if the worker goes to work at a new site. The worker must have additional training or site briefings, however, that are needed to work safely at the new spill incident or cleanup site. Every year, your emergency responders and cleanup workers must receive refresher training to maintain and demonstrate competency.

Note that Tables 2, 3, and 4 clarify HAZWOPER training requirements. You cannot use these tables as a substitute for the language of the regulation. Also, training required by other OSHA standards that may also apply to your employees is not discussed in this booklet.

For information about the acceptability of various technology-based training formats, see OSHA letters of interpretation on OSHA’s website at: http://www.osha.gov.

Oil Spill Scenario

This scenario is not intended to represent a typical marine oil spill. It illustrates levels of training needed for several job functions and hazardous exposure levels. Information in parentheses refers to the training levels in the Figure 1 flowchart.

Incident

A tugboat is pushing a barge loaded with a sour crude that contains sulfur, benzene, toluene, and xylene to an anchorage for lightering (See Figure 4). The anchorage is within sight of the local Coast Guard Marine Safety Office. Contractor resources also are located in the port within view of the anchorage. The tug pushing the barge miscalculates the turning radius, causing the barge to collide with the stern of a tank vessel. The vessels lock together. As a result, two of the barge’s port cargo tanks are breached, releasing several thousand gallons of crude oil into the water. Prevailing winds and currents carry the oil away from the vessels. Some oil is trapped between the barge and the tank vessel.

It is midday on a sunny summer day. The wind is 5 knots. The water temperature is around 70 degrees Fahrenheit. Air temperature is around 84 degrees Fahrenheit.

Discovery

Members of the tug crew immediately notify the Coast Guard of the incident (Figure 1: First Responder Awareness Level).

The tug and tank vessel crews remain with their vessels to ensure control of their ships. Vapors from the fresh oil begin to irritate the eyes of the captains and the crews. Both captains order crew members to remain upwind of the oil and avoid the area between the vessels where the oil is trapped.

Initial Emergency Response

The owner of the barge is located across the country. According to the company’s emergency response plan, the owner calls an Oil Spill Removal Organization (OSRO) to clean up the spill. The tug captain is designated by the owner to be the company’s representative. Because the owner is not on-scene and does not participate in spill response activities, he is not required to have HAZWOPER training. The tug captain is on-scene making decisions in the response. Therefore, the tug captain must have Incident Commander training for emergency response (Figure 1: Incident Commander).

The Coast Guard radios the tug captain to confirm the oil type, the same type listed on the cargo manifest faxed by the owner. The owner also faxes the cargo manifest to the OSRO. The Coast Guard uses references and advice from federal health professionals to estimate a safe distance from the spill.

After consultation with references, mathematical computer models, and federal health and safety professionals, the Coast Guard creates a safety zone around the spill and uses its boats to enforce it (Figure 1: First-Responder Operations Level).

The safety zone is conservatively large to maximize public safety. Support staff, news media, and other workers who will have no exposure to hazardous substances (Figure 1: Workers unlikely to be exposed over limits) will use the safety zone.

Initial Assessment

An hour after the initial oil release, two OSRO boats approach the spill from downwind to characterize the plume and determine the release zone boundaries. Their crews will monitor exposure levels using air-monitoring equipment (Figure 1: Hazardous Materials Technician or Specialist). Because exposure to hydrogen sulfide and benzene is expected, these responders must wear self-contained breathing apparatus (SCBA) while confirming estimated exposures. They may be able to switch to airpurifying respirators after the assessment.

They continue monitoring as the OSRO boats approach the spill until reaching permissible exposure limits. The boats work around the spill area to identify the limits of the High Exposure zone caused by vapors escaping the oil. Colorimetric tubes confirm air concentrations of 0.5 ppm of benzene and 4 ppm hydrogen sulfide at 200 feet (61 meters) downwind of the slick and 100 feet (30 meters) across the widest part of the plume.

The responders complete site characterization in areas where oil could be trapped between vessels, beneath piers, and in dock corners and other bounded spaces.

Outside the high exposure zone (the hot zone), workers prepare deflection and exclusion booms to divert the oil to a recovery site (Figure 1: First-Responder Operations Level).

The response team sets up a command center to coordinate response and cleanup activities. This area supports the Incident Commander, (Figure 1: Incident Commander), supervisors of the clean-up crews (Figure 1: Managers/Supervisors) with hourly requirements dependent on exposure, and other personnel (training depends on duties and exposures).

Mechanical Recovery

Four hours have passed. Air measurements of hydrogen sulfide, benzene, toluene, and xylene, taken with colorimetric tubes, register well below permissible exposure limits near the leading edge of the slick. An industrial hygienist and a marine chemist conduct a more detailed site characterization using advanced air-monitoring equipment such as a portable infrared analyzer and portable gas chromatograph (Figure 1a: Hazardous Materials Technician/Specialist, or Specialist Employee, depending on job duties). They confirm that the air exposures from the oil slick are below permissible limits. Air concentrations are above permissible limits, however, near oil trapped between the vessels and oil remaining in the damaged tanks.

Oil recovery skimmers arrive to skim free-floating oil. Containment boom and skimmer operators work from a boat. These operators wear goggles and protective clothing because the oil could irritate their skin and eyes. Because air concentrations are below permissible limits, operators are not required to wear respirators (Figure 1: First-Responder Operations Level).

The ships’ support crews remain upwind of the spill (Figure 1: Skilled Support Personnel or Figure 1: Workers unlikely to be exposed over limits).

Shoreline Cleanup

Six hours have passed. Oil reaches the shoreline. Skimmers near the shore remove oil that was deflected into recovery areas (Figure 1: First-Responder Operations Level, if these workers also participate in emergency response; or Figure 1: Workers unlikely to be exposed over limits, if these workers perform cleanup only).

The oil continues to irritate skin and eyes, so workers cleaning the shoreline wear chemical protective clothing, gloves, booties, and goggles. Because of the increased clothing requirements, site safety officer assistants begin monitoring for heat stress (Figure 1: Skilled Support Personnel or Figure 2: Workers unlikely to be exposed over limits, depending on the assistants’ job duties).

Responders form decontamination lines at each shoreline cleanup area. Each worker decontaminates before a break period and at the end of the shift. Workers dispose of outer booties, wash or remove oiled clothing, dispose of outer gloves, wash goggles and remove inner gloves. To minimize the spread of contamination, workers conduct their own decontamination while a worker stands by to assist. The decontamination assistants take responsibility for maintaining and dismantling the decontamination line (Figure 2: Workers unlikely to be exposed over limits, if these workers perform cleanup operations only).

Vessel

A skimming team recovers oil trapped between the vessels. Vessel personnel in SCBAs measure chemical and oxygen concentrations and the percentage of the lower explosive limit (LEL) for the space between the vessels (Figure 1: Hazardous Materials Technician/Specialist, or Specialist Employee, depending on job duties). Results of the monitoring indicate that workers conducting skimming operations must also be in SCBA. The workers decide to wait until exposure levels register below permissible limits before removing the oil.

Aboard the barge, a pumping team prepares to pump oil from the damaged cargo tanks into the tank vessel (Figure 1: Hazardous Materials Technician or Specialist). Explosion is a risk during pumping operations, so responders measure the LEL percentage and oxygen concentration throughout the operation. Before starting the pumping operations, workers in SCBAs put vapor recovery systems in place. Once the vapor recovery systems are in place, measured chemical concentration levels drop below permissible exposure limits and workers begin pumping.

Final Stages

Two days later, no free-floating oil remains. Pumping operations are completed. No hazardous chemicals are detected by air-monitoring equipment. The oil is weathered and is no longer an irritant; however, slip and trip hazards persist. Shoreline cleanup operations continue.

No repair facility is located within a reasonably safe distance for transport, so workers conduct initial, temporary repairs for safe sailing. They clean the damaged tanks inside and out before patching and welding them. There is a risk of explosion, oxygen deficiency, and overexposures to chemicals (Figure 1: General Spill Site Worker, if the workers perform cleanup only). Forced ventilation makes the holds safe, and a competent person tests them before the cleaning begins. A marine chemist tests and certifies the areas Safe for Hot Work before cutting and/or welding operations begin.

The company’s site safety and health plan does not cover the disposal of waste containers. Because of this oversight, oiled debris and waste decay in the containers, releasing hydrogen sulfide. A hazardous materials response team removes the contaminated waste from the containers (Figure 1: General Spill Site Worker). A week has passed. To speed removal of remaining debris on shore, training is offered to a team of local volunteers (Figure 2: Workers unlikely to be exposed above limits, and associated footnote). Trained supervisors (Figure 2: Managers/Supervisors of workers unlikely to be exposed above limits, with training level dependent on anticipated exposures) oversee the volunteers. As shoreline cleanup progresses, shoreline clean-up assessment teams begin to verify that shorelines are clean (Figure 2: Workers unlikely to be exposed above limits).

Other Sources of OSHA Assistance

Safety and Health Program Management Guidelines

Effective management of worker safety and health protection is a decisive factor in reducing the extent and severity of work-related injuries and illnesses and their related costs. To assist employers and employees in developing effective safety and health programs, OSHA published recommended Safety and Health Program Management Guidelines (Federal Register 54(16): 3904-3916, January 26, 1989). These voluntary guidelines apply to all places of employment covered by OSHA.

The guidelines identify four general elements that are critical to the development of a successful safety and health management program:
Management leadership and employee involvement,
Worksite analysis,
Hazard prevention and control, and
Safety and health training.

The guidelines recommend specific actions, under each of these general elements, to achieve an effective safety and health program. The Federal Register notice containing the guidelines is available online at http://www.osha.gov.

State Programs

The Occupational Safety and Health Act of 1970 (OSH Act) encourages states to develop and operate their own job safety and health plans. OSHA approves and monitors these plans. There are currently 26 state plan states; 23 of these states administer plans covering both private and public (state and local government) employment; the other 3 states—Connecticut, New Jersey, and New York—cover the public sector only.

The 25 states and territories with their own OSHA-approved occupational safety and health plans must adopt standards identical to, or at least as effective as, the federal standards. Until a state standard is promulgated, OSHA will provide interim enforcement assistance, as appropriate, in these states. A listing of states with approved plans appears at the end of this booklet.

Consultation Services

Consultation assistance is available on request to employers who want help in establishing and maintaining a safe and healthful workplace. Largely funded by OSHA, the service is provided at no cost to the employer. Primarily developed for smaller employers with more hazardous operations, the consultation service is delivered by state governments employing professional safety and health consultants. Comprehensive assistance includes an appraisal of all mechanical systems, physical work practices, and occupational safety and health hazards of the workplace and all aspects of the employer’s present job safety and health program. In addition, the service offers assistance to employers in developing and implementing an effective safety and health program. No penalties are proposed or citations issued for hazards identified by the consultant.

For more information concerning consultation assistance, see the list of consultation projects listed at the end of this publication, or visit OSHA’s website at http://www.osha.gov.

Voluntary Protection Programs (VPPs)

Voluntary Protection Programs and onsite consultation services, when coupled with an effective enforcement program, expand worker protection to help meet the goals of the OSH Act. The three VPPs—Star, Merit, and Demonstration—are designed to recognize outstanding achievements by companies that have successfully incorporated comprehensive safety and health programs into their total management system. The VPPs motivate others to achieve excellent safety and health results in the same outstanding way as they establish a cooperative relationship between employers, employees, and OSHA.

For additional information on VPPs and how to apply, contact the OSHA regional offices listed at the end of this publication.

Training and Education

OSHA’s area offices offer a variety of information services, such as publications, audiovisual aids, technical advice, and speakers for special engagements. OSHA’s Training Institute in Des Plaines, IL, provides basic and advanced courses in safety and health for federal and state compliance officers, state consultants, federal agency personnel, and private sector employers, employees, and their representatives.

The OSHA Training Institute also has established OSHA Training Institute Education Centers to address the increased demand for its courses from the private sector and from other federal agencies. These centers are nonprofit colleges, universities, and other organizations that have been selected after a competition for participation in the program. They are located in various parts of the U.S.

OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training and education in subjects where OSHA believes there is a lack of workplace training. Grants are awarded annually. Grant recipients are expected to contribute 20 percent of the total grant cost.

For more information on grants, training, and education, contact the OSHA Training Institute, Office of Training and Education, 1555 Times Drive, Des Plaines, IL 60018, (847) 297-4810. For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this publication.

Electronic Information

Internet—OSHA standards, interpretations, directives, and additional information are now on the World Wide Web at http://www.osha.gov.

CD-ROM—A wide variety of OSHA materials, including standards, interpretations, directives, and more, can be purchased on CD-ROM from the U.S. Government Printing Office. To order, write to the Superintendent of Documents, P.O. Box 371954, Pittsburgh, PA 15250-7954 or phone (202) 512-1800. Specify OSHA Regulations, Documents and Technical Information on CD-ROM (ORDT), GPO Order No. S/N 729-013-00000-5. The price is $46 per year ($57.50 foreign); $17 per single copy ($21.25 foreign).

Emergencies

For life-threatening situations, call (800) 321-OSHA. The teletypewriter (TTY) number is (877) 889-5627. Complaints will go immediately to the nearest OSHA area or state office for help. For further information on any OSHA program, contact your nearest OSHA area or regional office listed at the end of this publication.

Appendix A: Related OSHA Standards and Directives

OSHA standards, interpretations, and directives are available online at http://www.osha.gov

To review the complete report click on the link below.


Training Marine Oil Spill Response Workers under OSHA’s Hazardous Waste Operations and Emergency Response Standard

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Benzo[a]pyrene – Living Downstream by Sandra Steingraber

Benzo[a]pyrene causes cancer in a simple, direct way. Nearly all living things have in common a group of cellular enzymes responsible for detoxifying and metabolizing possibly harmful chemical invaders. When this enzyme group encounters benzo[a]pyrene, it inserts oxygen into the foreign molecule, the first step toward breaking it down. However, in a strange twist of fate, this addition activates benzo[a]pyrene rather than detoxifies it. The altered molecule now has the ability to bond tightly to a strand of DNA — that is, to one of the cell’s chromosomes along which lie the organism’s genes. A chemical invader so attached is called a DNA adduct, and it has the power to alter the structure of the DNA strand and cause a genetic mutation. If uncorrected, this type of damage can become a crucial step leading to the formation of cancer. Page 136

Benzo(a)pyrene (a polycyclic aromatic hydrocarbon reproductive [see below], formed when oil or gasoline burns) – Irritation to eyes and skin, cancer, possible effects.

– Taken from the Training Marine Oil Spill Response Workers under OSHA’s Hazardous Waste Operations and Emergency Response Standard

Coal tar itself is classified as a known carcinogen, but because humans are almost always exposed to its constituent ingredients in mixtures, the data from human studies are inadequate to so classify benzo[a]pyrene individually.


Chemical Profile for Coal Tar from Scorecard

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