Site Specific Assessment
- Review of current emergency/evacuation plans
- Discussion of onsite chemicals and potential for spills or releases
- Establish team requirements
- Determine officer responsibilities
1910.120 covers the following operations, unless the employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards:
- Clean-up operations required by a governmental body, whether federal, state, local, or other, involving hazardous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the EPA's National Priority Site List (NPL), state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are conducted before the presence or absence of hazardous substances has been ascertained);
- Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq);
- Voluntary clean-up operations at sites recognized by federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;
- Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and
- Emergency response operations for releases of, or substantial threats of releases of hazardous substances without regard to the location of the hazard.
Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances must be identified. According to OSHA, risks to consider include, but are not limited to:
[a] Exposures exceeding the permissible exposure limits and published exposure levels.
[b] IDLH concentrations.
[c] Potential skin absorption and irritation sources.
[d] Potential eye irritation sources.
[e] Explosion sensitivity and flammability ranges.
[f] Oxygen deficiency.
It is up to the facility to determine potential onsite hazards and develop response capabilities to mitigate potential emergencies. STEP can help you do that!