References Developing Training Programs Safety and Health Issues
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Safety and Health Issues for Brownfields Job Training When you are conducting brownfields job training you need to enforce safety and health standards, both in the classroom and at brownfields sites. Also, several of the environmental, health and safety courses commonly offered in brownfields job training programs require that students have a medical waiver or physical examination. This is especially true if SCBAs will be used during the training. A sample waiver of liability is provided at the end of this chapter.
Safety and Health in the Classroom and at the Work Site
Whether your own organization is conducting training or you hire an outside training provider, you need to be sure that appropriate safety and health procedures are being followed in the classroom and at the work site. For example, Honolulu Community College provides a list of safety and health rules to students enrolled in its Emergency Response to Hazardous Materials course. The students are asked to sign and date this document, which states they agree to follow all safety and health rules.
NIOSH Safety Checklist Program for Schools (http://www.cdc.gov/niosh/docs/2004-101/default.html) provides information needed by schools to maintain safe classrooms, shops, and labs for teachers and students in career-technical education. This information can also be used by colleges and universities with occupational safety and health programs.
Safety & Health Hazards Associated with Brownfields Sites
A document published by the Occupational Safety and Health Administration (OSHA), Brownfields Health & Safety for Sites Evaluated and Remediated Under Federal Brownfields Initiatives or State Voluntary Cleanup Programs (http://www.osha.gov/SLTC/brownfields/brnfld_qna.html), provides the following information on potential safety and health hazards associated with brownfields site assessment activities and clean-up activities.
Safety & Health Hazards Associated with Brownfields Site Assessment Activities and OSHA Standards that Apply
"Brownfield site assessment tasks are performed on- and off-site. They can range from reviewing historical information (e.g., aerial photographs) to collecting subsurface soil samples and evaluating environmental contamination within site structures. Historic site records will often allow you to identify specific site contaminants, their likely concentrations and locations.
The best way to determine which occupational hazards exist is to conduct a job hazard analysis for each assessment task. A job hazard analysis combines employee exposure information with equipment and procedural information and results in a list of chemical and physical hazards associated with each task.
Sample collection is likely to be the most intrusive activity conducted during this phase. Familiarity with environmental sampling equipment (i.e., hand augers, mechanical soil drills, and drill rigs) and procedures will allow you to determine the physical hazards associated with collecting samples. When you have determined the hazards that may be present and tasks that could result in employee exposure, you can identify the applicable OSHA standard(s) to protect your employees.
See the table below for a list of hazards that might be associated with your site assessment activities and the Federal OSHA standards that address those hazards. This list is not intended to be comprehensive. Rather, it suggests hazards that you should consider.
Potential Hazards and OSHA Standards for Consideration during Site Assessment Activities (Not Comprehensive)
* This table does not include all of the applicable OSHA standards since each situation is unique. Standards enforced in states with OSHA-approved state plans may be different. The Federal General Industry and Construction citations are provided above. If you are under State OSHA jurisdiction, some of the standards may be different. The tasks that employees conduct determine which standards will apply. OSHA defines "construction work" in 29 CFR 1926.32 (g) and 1910.12 as "construction, alteration, and/or repair, including painting and decorating." Employers engaged in these activities are considered to be doing construction work and must comply with the Construction Safety and Health standards in 29 CFR 1926.
Safety and Health Hazards Associated with Brownfields Clean-Up Activities and OSHA Standards that Apply
Site clean-up activities involve a greater variety of hazards and higher levels of exposure than site assessment activities. Depending on how and where hazardous substances are dispersed, an intrusive collection method (pumping, stripping, removing, or excavating) to consolidate environmentally contaminated material for treatment or disposal may be required. These types of operations usually result in the highest chemical exposure to employees, and require the most physical activity, equipment, and planning.
The time and equipment required to do a task may add to its hazards. For example, the use of heavy equipment and on-site treatment technologies may require hearing protection, adequate and appropriate storage of flammable and corrosive materials, other personal protective equipment (PPE), and emergency response resources. Since clean-up activities usually occur over a longer duration than site assessment activities, employers may need to provide more on-site facilities for personal hygiene needs.
See the table below for a list of hazards that might be associated with Brownfields clean-up operations and the OSHA standards that address those hazards. This list is not intended to be comprehensive. Rather, it suggests hazards that should be considered.
Potential Hazards and OSHA Standards for Consideration during Cleanup Activities (Not Comprehensive)
* This table does not include all of the applicable OSHA standards since each situation is unique. Standards enforced in states with OSHA-approved state plans may be different.
The Federal General Industry and Construction citations are provided above. If you are under state OSHA jurisdiction, some of the standards may be different. The tasks that employees conduct determine which standards will apply. OSHA defines "construction work" in 29 CFR 1926.32 (g) and 1910.12 as "construction, alteration, and/or repair, including painting and decorating." Employers engaged in these activities are considered to be doing construction work and must comply with the Construction Safety and Health Regulations in 29 CFR 1926.
Additional Resources
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