Plans safety

Non-RCRA-permitted TSDs and waste treatment activities not covered by RCRA (e.g., wastewater treatment facilities permitted under the Clean Water Act) are not covered by HAZWOPER, except for emergency response and some limited waste management operations. Specific HAZWOPER elements are assimilated into the existing health and safety program based on hazard analyses. Worker protection requirements are met through existing health and safety plans [1]. 

Health and safety planning and implementation emphasize jobs and tasks. Many DOE or Army Corps of Engineers sites have an established work control system (WCS) that is focused at the job and task level. Workers are familiar with the WCS and understand its content because each work-task package includes checklists and permits. This is a normal part of daily work. The WCS is a practical vehicle for managing and conducting these activities and supports the HASP by providing a mechanism to accomplish the following ... 

Providing health and safety planning for site-specific projects, at the job and task levels. 

All contractors should interface with each other to encourage mutual understanding and coordinating their respective activities, as well as for reviewing and commenting on documents such as work plans or the safety plan. 

The following are important aspects of a hazard-based health and safety planning process ... 

Developing a Site-Specific Health and Safety Plan... 

Wlien the appropriate researeh has been eompleted, it is time to use the information to develop the site-speeifie safety plan. Keep in mind that this plan will provide the basis for proteetion of workers, visitors, and the publie. The plan defines health and safety hazards, eontrols, and requirements for individual aetivities at a speeifie worksite and provides doeumentation to help identify and eontrol health and safety hazards before fieldwork begins [1],... 

Most requests for proposals and bid speeifieations will inelude statements that all work will eomply with all applieable safety guidelines. You may eome aeross the argument that, Sinee we have already agreed to abide by the law (OSHA standard), why not just submit the latest eopy of 29 CFR or another applieable guidanee and inelude it as an attaehment to our work plan, and save the time and effort of developing a safety plan ... 

We believe (and regulators agree) that attaehing 29 CFR or other doeuments as a substitute for a safety plan is not eompliant, nor is it a... 

A properly written safety plan eontains worker health and safety program information, guidanee, and alternatives. The HASP should quiekly answer the two questions What hazards are present and What provisions have been made to make sure that all tasks will be performed safely [1] Subsequent ehapters will provide a detailed examination of a typieal HASP. The information presented will be generie and should be modified to fit any site-speeifie hazards. 

Although signatures are no guarantee that you will do the job any more safely, not obtaining signatures is not an acceptable alternative. We believe in signatures and feel that they should be a requirement for safety plans as well as many other safety-related documents such as ... 

The introduction is a brief statement regarding the development of the HASP. It should include the applicability and limitations. In this section, a statement is typically made that sets the stage for the safety plan and disallows any changes to the document without an amendment being completed and approved. 

Development of a Site-Specific Health and Safety Plan 77 6.3.4 Project Personnel and Responsibilities... 

JHAs of individual work operations or tasks and their associated hazards should be included in the plan to help develop effective controls. Many times subcontractor activities are added to the safety plan after its original publication. Typically, subcontractor activity is specialized and short lived. It would be advantageous to have all JHAs completed and included as part of the work before the work begins. 

Wliatever type of monitoring instrumentation is employed it should be operated, ealibrated, and maintained in aeeordanee with all reeom-mended manufaeturer speeifieations. A eopy of the operating manual should be maintained in elose proximity to the equipment and should be ineluded as an appendix to the safety plan. Those who are operating the equipment should be trained adequately and understand the limitations of that equipment. The operator should know the eontents of the manufaeturer s manual and be able to answer questions about that equipment. 

An outline of the medieal surveillanee program, as approved by the oeeupational health staff, should be ineorporated in, or appended to, the site-speeifie safety plan. Modifieations to the program should be based on the professional judgment of the oeeupational health physieian, in eonsultation with the health and safety professionals, and on the hazards of the speeifie worksite. 

The following guidelines for establishing an emergeney treatment program should be doeumented or refereneed in the safety plan ... 

After the safety plan has been eompleted and approved by the management team, the most ehallenging part of the job needs to be addressed. It is, very simply, the exeeution proeess. Now that the plan is written we should make sure that all site work is performed in a safe manner. Worksite eontrols established in the plan should eome into play immediately when aetivities begin. It is essential that everyone at the worksite is aware of the eontents of the safety plan. To make sure that everyone is familiar with the safety plan eontents, everyone should be oriented before any work is performed. 

To make sure that safety is a priority at your projeet, the safety plan needs to be adhered to. All workers should beeome familiar with and trained in at least those parts of the safety plan that may aflfeet them. Workers should not be deemed qualified to perform their assigned job funetions until site management is satisfied that they have reeeived not only the required funetional training, but other safety-related site-speeifie instruetions. 

Although inspeeting the worksite is important for enforeement of important requirements, it is also a useful tool to help determine if the site orientation, the safety plan, or the safety program is eflfeetive. If newly oriented workers are out of eomplianee in eertain areas, this may indi-eate that the orientation needs to be reviewed and improved. 

The audit/inspeetion form that you should use ean be developed from the safety plan. A qualified person should examine the safety plan and eome up with a eheeklist that should serve as an audit/inspeetion form. Allowanees should be made to inelude items not speeifieally noted in the safety plan but that may be observed during field walk-throughs. Certain highly pertinent seetions of what OSHA uses when performing a eomplianee inspeetion of hazardous waste sites is ineluded in Appendix D. This inspeetion/audit form eovers many of the basies and ean be used a general guide. 

If your safety plan is eomprehensive, it should speeify defined roles and responsibilities. The safety plan will state what proeedures should be followed when workers eome upon a safety-related situation that they eannot fix themselves. 

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