Site H&S Plan Review Checklist

(29 CFR 1910.120)

Date:

Site Name/Location:

Brief Site Description:

Site OSC/Phone #:

Site Specific Hazards Identified:

v     Health and Safety Plan (HASP) Review

● Is there a HASP available on-site?

♦ Has the OSC reviewed and signed off/approved the HASP?

♦ Have all workers on site read and signed off on the plan?

● Has there been a health and safety audit conducted on site?

If so by whom/what affiliation & when?

♦ Have all identified deficiencies been corrected?

29 CFR 1910.120 (b)(1)(ii)(A): An organizational structure;

29 CFR 1910.120 (2)(i)(A…D): The organizational structure part of the program shall establish the specific chain of command and specify the overall responsibilities of supervisors and employees. It shall include, at a
minimum, the following elements:
♦ A general supervisor who has the responsibility and authority to direct all hazardous waste operations;
♦ A general supervisor who has the responsibility and authority to direct all hazardous waste operations;
♦ A site safety and health supervisor who has the responsibility and authority to develop and implement the site safety and health plan and verify compliance;
♦ All other personnel needed for hazardous waste site operations and emergency response and their general functions and responsibilities;

♦ The lines of authority, responsibility, and communication.

 ● Does the HASP include an organizational structure showing chain of command with function and responsibilities of [(b)(1)(ii)
(A) and (b)(2)(i)(A…D)]:?
♦ Organizational Structure showing chain of command, function & responsibilities:

♦ Supervisor? [(A)]:

♦ Safety Officer? [(B)]:

♦ All other personnel? [(C)]:

♦ Lines of authority, responsibility and communication? [D]:

29 CFR 1910.120 (b)(1)(ii)(B): A comprehensive workplan;

29 CFR 1910.120 (b)(3)(…): Comprehensive workplan part of the site program. The comprehensive workplan part of the program shall address the tasks and

objectives of the site operations and the logistics and resources required to reach those tasks and objectives.
(i): The comprehensive workplan
procedures available elsewhere.
(ii): The comprehensive workplan shall define work tasks & objectives & identify the methods for accomplishing those tasks and objectives.

(iii): The comprehensive workplan shall establish personnel requirements for implementing the plan.
(iv): The comprehensive workplan shall provide the implementation of the tng required in para (e) of this section (1910.120(e) Initial Training).

(v): The comprehensive workplan shall provide for the implementation of the required informational programs required in paragraph (i) of this section
(1910.120(i) Handling Drums and Containers).
(vi): The comprehensive workplan shall provide for the implementation of the medical surveillance program described in paragraph (f) of this section

(1910.120(f) Medical surveillance).

● Is there a comprehensive work plan with details of [(b)(1)(ii)(B) and (b) (3)(…)]:

♦ Cleanup activities and standard operating procedures [i]:

● Defines work tasks and objectives and methods for accomplishing them [ii]?

● Personnel requirements (i.e., personnel needed) for implementing [iii]?

● Provides for implementation of HAZWOPER training requirements [iv]?

● Provides informational program implementation of nature, level, & degree of exposure likely from site work [v]?

● Provides for implementation of medical surveillance program [vi]?

 ● Site Specific Safety Plan on Site [(b)(1)(ii)(C) and (4)(…)]:
29 CFR 1910.120 (b)(1)(ii)(C): A site-specific H&S plan which need not repeat the employer's SOPs required in paragraph (b)(1)(ii)(F) of this section;
29 CFR 1910.120 (4)(…): Site-specific safety and health plan part of the program.
(i): General. The site H&S plan, which must be kept on site, shall address the H&S hazards of each phase of site operation and include the
requirements & procedures for employee protection.
(ii)(…): Elements. The site safety and health plan, as a minimum, shall address the following:
(A): A safety and health risk or hazard analysis for each site task and operation found in the workplan.

(B): Employee training assignments to assure compliance with paragraph (e) of this section.
(C): Personal protective equipment to be used by employees for each of the site tasks and operations being conducted as

required by the personal protective equipment program in paragraph (g)(5) of this section.
(D): Medical surveillance requirements in accordance with the program in paragraph (f) of this section.
(E): 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.
(F): Site control measures in accordance with the site control program required in paragraph (d) of this section.

(G): Decontamination procedures in accordance with paragraph (k) of this section.

(H): An emergency response plan meeting the requirements of paragraph (l) of this section for safe and effective
responses to emergencies, including the necessary PPE and other equipment.

(I): Confined space entry procedures.

(J): A spill containment program meeting the requirements of paragraph (j) of this section.

(iii): Pre-entry briefing. The site specific safety and health plan shall provide for pre-entry briefings to be held prior to initiating any site activity, and at such
other times as necessary to ensure that employees are apprised of the site safety and health plan and that this plan is being followed. The information and
data obtained from site characterization and analysis work required in para © of this section shall be used to prepare and update the site H&S plan.

(iv): Effectiveness of site H&S plan. Inspections shall be conducted by the site H&S supervisor or, in the absence of that individual,
another individual who is knowledgeable in occupational safety and health, acting on behalf of the employer as necessary to determine

the effectiveness of the site safety and health plan. Any deficiencies in the effectiveness of the site safety and health plan shall be
corrected by the employer.
 Ø      Has a risk/hazard analysis been completed for each site task and operation [(ii)(A)]?

● Have all employees received 40 hour HAZWOPER training (4)(ii)(B)]?

● Is documentation available on site?

● Are all employees current on their 8-hour refresher training?

● Have supervisors or on-site management received an additional 8 hours of specialized training at the time of job assignment?

Ø      Does Plan address PPE for each task and operation and is consistent with PPE Program [(ii)(C) reference (g)(5)]?

● Are employees trained in use of PPE?

● PPE selection based upon site hazards?

● PPE use and limitations of the equipment?

● Work mission duration?

● PPE maintenance and storage?

● PPE decontamination and disposal?

● PPE training and proper fitting?

● PPE donning and doffing procedures?

● PPE inspection procedures prior to, during, and after use?

● Evaluation of the effectiveness of the PPE program?

● Limitations during temperature extremes, heat stress, and other appropriate medical considerations?
 Ø      Does Plan address Medical Surveillance requirements (i.e., a statement to that effect) [(ii)(D), see also (f)]?

Ø      Does the Plan address air monitoring, personnel monitoring, and environmental sampling techniques and instruments to be used,
including calibration of such instruments [(ii)(E) see also section (h)]?

Ø      Does the Plan address site control measures [(ii)(F) references (d)(3)]?
● Is there a map in the Site-Specific Safety and Health Plan [(d)(3)]?
● Have work zones been defined [(d)(3)]?
● Is there a buddy system in place [(d)(3)]?

● Have site communications been established [(d)(3)]?

● Has a route to the nearest hospital been defined and explained to the crew [(d)(3)]?
● Has the route to the nearest hospital been posted?
● Has the route to the nearest hospital been posted in each vehicle?

Ø      Are there written Decon procedures [(ii)(G) references (k)]?

§         Has it been communicated to employees and is it being implemented [(k)(2)(i)]?

§         Has an SOP been established to minimize contact with hazardous substances & contaminated
equipment [(k)(2)(ii)]?

§         Is a procedure in place for deconing personnel and equipment [(k)(2)(iii)]?

§         Is Safety Officer monitoring decontamination procedure for effectiveness [(k)(2)(iv)]?

§         Is decon location protective to uncontaminated personnel and equipment [(k)(3)]?

§         Is equipment used for decontaminating properly decontaminated itself or properly disposed of along with any
decon solutions [(k)(4)]?
 §         Is PPE properly decontaminated or disposed of [(k)(5)]?

§         Does SOP require when PPE clothing becomes wetted with hazardous substance to immediately decon &
shower [(k)(5)]?

§         Does SOP require only authorized personnel remove PPE clothing & equipment from change room [(k)(6)]?

§         If commercial establishments are deconing PPE clothing & equipment, have they been informed of potential
harmful effects due to exposure to hazardous substances [(k)(7)]?

§         Are showers & change rooms required by the decon procedures & meet the requirements of [(k)(8)]?
Ø      Is there an emergency response plan [(ii)(H) references (l)]?

Does it discuss:
§         Pre-emergency planning [(2)(i)]?

§         Personnel role, lines of authority, and communication [(2)(ii)]?

Ø      Emergency recognition and prevention [(2)(iii)]?

§         Safe distances and places of refuge [(2)(iv)]?

§         Site security and control [(2)(v)]?

§         Evacuation routes and procedures [(2)(vi)]?

§         Decontamination procedures which are not already covered (ii)(G) [(2)(vii)]?

§         Emergency medical treatment and first aid [(2)(viii)]?

·        Who on site has first aid/CPR?

§         Emergency alerting and response procedures [(2)(ix)]?

§         Critique of response and follow-up [(2)(x)]?

§         PPE and emergency equipment [(2)(xi)]?

 §         Site topography, layout, and prevailing weather conditions [(3)(i)(A)]?

§         Procedures for reporting to local, state, and federal agencies [(3)(i)(B)]?

Ø      Is the emergency response plan consistent with the following requirements?:

§         It is a separate section of the Site Safety and Health Plan [(3)(ii)?
§         It is compatible & integrated with the disaster, fire and/or emergency response plans of local, state, & federal
agencies [(3)(iii)]

§         It has been rehearsed regularly as part of the overall training program for site operations [(3)(iv)]
§         It has been reviewed periodically and, as necessary, amended to keep it current with new or changing site
conditions or information [(3)(v)]

§         An employee alarm system has been installed in accordance with 29 CFR 1910.165 to notify employees of an
emergency situation; to stop work activities if necessary; to lower background noise in order to speed
communication; and to begin emergency procedures [(3)(vi)]

§         It allows, based upon the information available at time of the emergency, the employer to evaluate the
incident and the site response capabilities and proceed with the appropriate steps to implement the site
emergency response plan [(3)(vii)]?

Ø      Are there confined space entry procedures [ii)(i)]?

§         Have any confined entry situations been identified?

Ø      Is there a spill containment program [(ii)(j) references (J)]?

v     Other issues to watch for:

Ø      Is sanitation addressed [e.g., hand washing and toilets]?

Ø      Has the local fire department been informed of site operations [Do this if dealing with a situation which might
warrant calling fire department, e.g., explosive or flammable material]?

Ø      Has the local hospital been contacted [Do this if dealing with a unique substance that would require further
 preparation by hospital, e.g., nerve agent, HF, cyanide, etc.]?

Ø      Are there compressed gas cylinders on site and are procedures for handling addressed appropriately?

Ø      Is there a welding/torch cutting operation on site and are procedures for welding/cutting operations addressed?

Ø      Is any type of air sampling equipment on site and are procedures addressed appropriately to include operation, maint, & calibration?

Ø      Is there an XRF on site and are procedures addressed appropriately to include operation, maint, and security?

Ø      Is heat or cold stress addressed in Plan?

v     Other Comments:

Other reference sources:

OSHA Technical Enforcement and Assistance Guidelines for Hazardous Waste Site and RCRA Corrective Action Cleanup Operations, November 2003
http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-02-071.pdf

EPA/540/G-89/010, "Health and Safety Audit Guidelines," SARA Title I, Section 126, Office of Emergency and Remedial Response, USEPA, 1989.
http://www.epa.gov/cgi-bin/claritgw?op-Display&document=clserv:OSWER:1423;&rank=4&template=epa

OSHA Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120 and 1926.65, Paragraph (q):
Emergency Response to Hazardous Substance Releases.
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1572

EPA/LABOR SUPERFUND HEALTH & SAFETY TASK FORCE: OSHA AUDITS OF SUPERFUND SITES FROM 1993 TO 1993
http://www.osha.gov/SLTC/hazardouswaste/sftaskrpt.html

Seven Steps to Successful Safety and Health Programs at Superfund Sites: A Compendium of Lessons Learned by Mary Ann Garrahan This report was
published in OSHA's Job Safety and Health Quarterly, Volume 5 Number 2, Winter 1995.
http://www.osha.gov/SLTC/hazardouswaste/7steps.html

HAZWOPER requires a written H&S program. This program will be documented in the H&S Plan (HASP). The HASP will contain
the site-specific H&S plan per 1910.120(b)(4) as well as the other elements.
 OSC Site Field Review Checklist
(29 CFR 1910.120)
EPA Region 2, RAB/RAB

Date:

Site Name/Location:
Site OSC/Phone #:
Field Audit:

Site (General)
PPE
Head Protection - 29 CFR 1910.135
Eye & Face Protection - 29 CFR 1910.133
Foot Protection - 29 CFR 1910.133
Hearing Protection - 29 CFR 1926.101
Respiratory Protection - 29 CFR 1910.136
Hand Protection - 29 CFR 1910.138
Electrical Protection Device - 29 CFR 1910.137
Sanitation - 29 CFR 1910.141
Housekeeping - 29 CFR 1910.141(a)(3)
Waste Disposal - 29 CFR 1910.141(a)(4)
Vermin Control - 29 CFR 1910.141(a)(5)
Potable Water - 29 CFR 1910.141(b)(1)
Non-Potable Water Sources - 29 CFR 1910.141(b)(2)
Toilet Facilities - 29 CFR 1910.141(c)
Hand Washing Facilities - 29 CFR 1910.141(d)(1)-(2)
Change Room Facilities - 29 CFR 1910.141(e)
Eating/Drinking Facilities - 29 CFR 1910.141(g)(2)

Crew Rest/Break Area

Housekeeping
Designated Smoking Area
Eating/Drinking Area
Adequate Space
Other

Decon/PPE Change Out Area

Emergency Showers ANSI Z358.1
Adequate Water Supply (20 gal/min for 15 min)
Temperature (65-90 degrees F)
Housekeeping
Decon Line
Other
Heavy Equipment
Backup Alarms
Used Properly
Certified Operators
Other

Fall Protection
Being Used
Areas Identified/Marked
Other

Rigging/Slinging
Daily Inspection
Qualified Person
Tag Lines
Hardware

Flammable Liquid Storage

Storage Area Marked?
Fueling Area Defined/Marked
Portable Tanks Secondarily Contained
Fire Extinguishers

Security
Site Fenced
Site Security Guards Employed
Site Security Guard Checks Route Identified
Emergency Notification Procedures Posted
Other

Electrical
Lock out - Tag Out
Extension Cords
Overloaded Circuits
Overhead Power Lines
Other

Office
Housekeeping
Designated Smoking Area
Eating/Drinking Area
 Adequate Space
Other

Permit Confined Space - 29 CFR 1910.146

Areas Idendified & Posted
Hazards Identified
Supervisor
Entry Attendant
Entrants Identified
Rescue
Rescue Equipment
Lighting
Air Monitoring
Communications
Internal
External
Other

Site Traffic
Traffic Flow
Parking
Truck Loadout
Speed Limits
Other

Demolition 1926 Subpart T

Perparatory Operations 1926.850
Stairs, Passageways, & Ladders 1926.851
Chutes 1926.852
Removal of Materials through Floor Openings 1926.853
Walls, Masonry Sections & Chimney Removal 1926.854
Manual Removal of Floors 1926.855
Walls, Floors & Material w/Equip Removal 1926.856
Storage 1926.857
Removal of Steel Construction 1926.858
Mechanical Demolition 1926.859
Selective Demolition by Explosives 1926.860