OSHA and Emergency Response  The Occupational Safety and Health Administration (OSHA) addresses responsibilities for employers with regards to disaster preparedness and response in several OSHA standards.  The following OSHA standards require employers to address emergency preparedness in some way:

OSHA’s Emergency Action Plans  Emergency Action Plans (29 CFR (a))  The OSHA Etool on Emergency Action Plans can be found here.here

(a)  Employer’s requiring some employees to use portable fire extinguishers and others to evacuate  Employers who must supply portable fire extinguishers but require their employees to evacuate only  Employers who require employees to evacuate during certain emergencies e.g. total area flooding or, evacuation during a release of a toxic substance Ref: (q)  Specific health standards –

OSHA’s Emergency Action Plans  Businesses that deal with hazardous substances (such as Ethylene Oxide, Methylenedianiline, or Butadiene ), or that are subject to the provisions of the Process Safety Management of Highly Hazardous Chemicals, Hazardous Waste Operations, or Grain Handling standards may also need to develop an emergency action plan in compliance with 29 CFR (a).

OSHA’s Emergency Action Plans  Emergency action plans and rescue provisions can also be found in the standards covering Permit Required Confined Spaces (29 CFR ), Fire Brigades (29 CFR ), and Hazard Communication (29 CFR ).

OSHA’s Directive CPL  OSHA CPL was issued April 24,  This instruction updates enforcement procedures for compliance officers who need to conduct inspections of emergency response operations.

National Response Plan and OSHA’s Role  New guidance is provided on how the HAZWOPER standard may apply to unique events such as terrorist attacks and addresses OSHA's role under the National Response Plan.  This instruction assists other Federal, State, and local personnel who have responsibilities under incident command systems and will assist in emergency response operations.

OSHA’s Role Under HSPD-5  OSHA's relationship with Homeland Security Presidential Directive (HSPD-5), including discussion addressing the National Response Plan (NRP), the Worker Safety and Health Support Annex, and the National Incident Management System (NIMS).

Some Basic OSHA Expectations  Employee protection is priority # 1  Fully consider the widest range of worst case scenarios when deciding your emergency actions  As the employer expects more from its employees, OSHA expects more of the employer  Plan, communicate and train --- train, communicate and plan

So What Constitutes a Workplace Emergency?  Webster - an unforeseen combination of circumstances or the resulting state that calls for immediate action  An unexpected and uncontrolled event that has seriously harmed or threatens harm to workers  any potential occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment which could result in an uncontrolled release of a hazardous chemical into the workplace

Fundamentals  29 CFR and 37 (emergency egress) Sufficient # for the occupancy Exit ways and access thereto are unobstructed Exit ways and access thereto are clearly marked Exit signs are visible at night Emergency lighting is supplied when needed OSHA is the authority having jurisdiction

Fundamentals  requires the availability of emergency first aid  Requires emergency body and eyes flushing where contact with corrosives can occur  – requires “appropriate first-aid supplies” when employees work with dipping and coating chemicals

Designated First Aid Responders  – addresses protection required against blood borne pathogens - your designated and collateral duty first aiders are covered ECP Training on Universal Precautions and the standard HBV vaccinations and post exposure follow-up  Collateral Duty Exception

Personal Protective Equipment  OSHA Subpart I – Assess your emergency plan to ensure that PPE needs have been anticipated Provide the required PPE Train and re-train employees (as necessary) on its use, maintenance and limitations Verify and then certify that training was completed

Emergency Use Respiratory Protection  Written program  Provide a respirator for the worst case anticipated use  Inspect emergency use respirators monthly Inspections must include certification Date, signature, findings, S/N and any actions taken e.g. “Tank filled”  Train employees on emergency use  Medically evaluate employees

Broad Scope Emergency Standards  Employee emergency response plans: (a) Does your plan include evacuation? Is it required by a specific OSHA standard? If so, you must follow this standard The elements are an excellent starting point for all evacuation plans

BEFORE the Emergency Occurs  Plan safe evacuation for the range of anticipated emergencies  Assign roles to execute the plan  Identify the means to report emergencies  Prepare written plan that describes roles and evacuation procedures  Train employees on the plan and assigned roles  Implement and alarm system per  Coordinate with outside responders as necessary  Document your efforts, meeting minutes, training records, disciplinary actions - employee declinations

During an Emergency  If your planning and preparation is deficient, your response certainly will be…. The larger, more newsworthy the event, the more likely OSHA will be there OSHA will normally inspect the management of both the emergency crisis and its consequence The more reasonably anticipated the emergency, the higher the expectation that the employer will respond appropriately

Broad Scope Standards cont.  Hazardous Waste Operations & Emergency Response: (q) Applies anywhere an emergency chemical release can occur All Haz-Mat responders are covered Performance Oriented

Prior to the Haz-Mat Emergency  (q) requires…  A written plan, available upon request to OSHA that considers….  Pre-planning and coordination w/outside parties  Identified personnel roles, lines of authority, training and communication e.g. the ICS system  Training on emergency recognition and prevention  Safe Distances and Refuge

.120(q) continued  Site security and control  Evacuation Routes and Procedures  Decontamination  Emergency Medical Treatment + First Aid  Critique of Response and Follow-Up  PPE and Emergency Equipment

During a Haz-Mat Emergency  Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards encountered……  IC can appoint a safety officer to oversee personnel safety

Emergency Haz-Mat Roles During an Emergency  The roles that you decide for your employees determine their level of involvement and the amount of training First responder Awareness – Determines if ER needed and notify First responder Operations – Protect – Contain - Exclusion Zone Hazardous Materials Tech. – Control at source + Remediation Hazardous Materials Specialist –could be the “Safety Officer” – liaison with outside responders Incident Commander Level – has Operations Level Training with authoritative and unilateral decision making ability

Emergencies at Plants Covered by  Focuses on preventing accidental releases.  The employer must establish and implement an emergency action plan for the entire plant in accordance with the provisions of 29 CFR (a).  The emergency action plan shall include procedures for handling small releases.  Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR (a), (p) and (q). .119 requires the training of on-site contractors.

Site Security  Assess your liabilities and risks  Identify your soft underbelly and firm it up  The greater the consequence, the greater the need for security  Develop a security culture – employees and contractors  Develop a strong working relationship with local police and first responders

Miscellaneous Emergency Related Issues  Confined Spaces – Emergency Rescue  Significant Spills must be reported to the NRC  Must report a fatality or hospitalization of 3 or more employees to OSHA within 8hrs.

Protecting Emergency Responders, Volume 1: Lessons Learned from Terrorist Attacks  Protecting Emergency Responders: Lessons Learned from Terrorist Attacks, sponsored by the National Institute for Occupational Safety and Health (NIOSH), summarizes the results of a conference held in New York City on Dec. 9-11, 2001, and organized by the RAND Science and Technology Policy Institute. Participants were emergency workers from around the country who responded to the bombing of the Alfred E. Murrah Building in Oklahoma City, the September 11th attacks on the World Trade Center and the Pentagon, and the anthrax incidents that occurred during autumn 2001.

Protecting Emergency Responders, Volume 2: Community Views of Safety and Health Risks and Personal Protection Needs  Firefighters, law enforcement officers, and emergency medical service responders play a critical role in protecting people and property in the event of fires, natural and man-made disasters, medical emergencies, terrorist and other criminal acts, and numerous other types of emergencies.  The authors examine the hazards that emergency responders face and the personal protective technology needed to contend with those hazards.

Protecting Emergency Responders, Volume 3: Safety Management in Disaster and Terrorism Response  This study provides recommendations for preparing for response to such disasters and other large-scale incidents.  It uses literature review, study interviews with members of the response community, and information gathered at the RAND Corporation- National Institute for Occupational Safety and Health workshop Protecting Emergency Responders: Safety Management in Major Disaster and Terrorism Response in Arlington, Va., on February 27, 2003.

Protecting Emergency Responders, Volume 4: Personal Protective Equipment Guidelines for Structural Collapse Events  This monograph serves as a technical source for National Institute for Occupational Safety and Health (NIOSH) incident commander guidelines for emergency response immediately following large structural collapse events.  It characterizes response activities and expected hazards, and develops guidelines for selecting appropriate personal protective equipment (PPE).