Occupational Health and Safety Program for Hazardous Waste Sites

(See endnotes 95, 106)

Note: The program described below may be specific for hazardous waste sites but all of its elements constitute basically what an occupational health and safety program should include. Therefore, these elements and program are usable in virtually all of the other chapters in this book as the material relates to occupational health and safety and employee welfare.

Planning and Operation

Planning is not only the first of the elements of a good program but also the most critical one when dealing with any type of activity involving people and/or the natural environment. This is especially true of hazardous waste sites with their many unique problems and opportunities for people, air, land, and water to be exposed to innumerable dangerous substances. Planning consists of: establishing an organizational structure for all working operations; developing a comprehensive work plan including every single facet of the operation, and its potential dangers and means of prevention and mitigation if necessary; developing and implementing a comprehensive health and safety plan which includes all aspects of occupational prevention, treatment, and healthcare, starting with preemployment physical examinations, necessary immediate treatment, and long-term care as needed; risk analysis of all aspects of the work environment; and risk communications to all individuals concerning what might happen and how to deal with it.

The plan also has a special section on the contamination of air, land, and water and how to prevent, mitigate, and control the various hazardous substances which may degrade these environmental media and the incorporated ecosystems. From its inception, the plan proposal should include the thoughts, knowledge, and experience of all interested parties and partners. A local and state contingency plan identifying all appropriate personnel, policies, procedures, communications systems, and other equipment should be established, and this response team should carry out all necessary functions when accidental releases or disasters occur.

The organizational structure should include a high-level administrator with direct authority to carry out all necessary actions in the implementation of the plan and to order industrial and other operations shut down and emergency actions taken. This authority should come directly from the chief administrative officer and the board of trustees. It should cross all departmental lines. Other personnel needed to carry out program elements should be identified, and specific detailed criteria should be established for hiring them as well as providing the job specifications for the position. Lines of authority, responsibility, and communications should be established clearly. An individual should be identified who will interface with the community and the media. There should be a scientific advisor to the project to clarify all problems where contamination may be released into the environment or individuals may become affected by the hazardous substances. A comprehensive work plan should include the input of all levels of supervision and management and the individuals actually carrying out the various tasks. Appropriate training and retraining should be established.

A written site safety plan based on well-thought-out policies and procedures based on industry experience and best available technologies to protect personnel and the public must be put into action before any work occurs at the site. The site safety plan should list the key personnel, methods of contact, and responsibilities; describe the risks from each portion of the disposal system and how to deal with them; describe the various types of personal protective clothing and equipment to be used; describe any specific medical surveillance needed; list the types of monitoring including air, water, land, and personnel; describe means of mitigating potential and existing hazards; list decontamination procedures for personnel, equipment, and the environment; establish emergency response to spills, fires, explosions, worker injuries, and catastrophic events; and establish all standard operating procedures.

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