Chapter 6: Special Health and Safety Considerations for Remediation Projects

All construction managers and workers are familiar with Occupational Safety and Health Administration (OSHA) requirements for protecting the health and safety of everyone on the job. Those of us in the horizontal drilling business know about protecting ourselves from electrical strikes, confined-space entry and work in excavations. In environmental drilling, however, we have additional risks we must prepare for, including many that are not easily seen. Because the risks are invisible, we must develop safe work practices that allow us to efficiently perform our jobs and still protect us from the chemical and other hazards that may be present.

This section of the handbook is designed to provide drillers with an overview of requirements that are not necessarily covered in Hazardous Waste Site Operations and Emergency Response (HAZWOPER) training (40 hours health and safety training). The following provides guidance for personal protective equipment and respiratory protection, two of the more critical areas of worker safety on hazardous waste sites. This section is not a comprehensive guide and should only be used for planning purposes. Consult a safety professional for a more complete health and safety program for your company.

Basic Health And Safety Requirements

The primary regulation that applies to drillers are the requirements of the Occupational Safety and Health Act of 1970. This act was designed to " . .. provide for the general welfare and to assure so far as possible every working man and woman in the Nation safe and healthful working conditions and preserve our human resources." Furthermore, section 5 (a) of the Act requires that each employer should furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees. Basically, what these two statements mean is that you have to protect your employees from harm in the work place. Specific regulations have been developed to help you do so.

29 CFR 1910.120 Hazardous Waste Site Operations and Emergency Response requirements apply to all personnel engaged in the following work:

  • hazardous substance response operations under Comprehensive Environmental Response,Compensation, and Liability Act (CERCLA)
  • initial investigations at CERCLA sites before the presence or absence of hazardous substances have been determined
  • major corrective actions taken in cleanup operations under Resource Conservation and Recovery Act (RCRA)
  • operations involving hazardous waste treatment, storage or disposal facilities regulated under RCRA
  • operations at hazardous waste sites designated for cleanup by state or local authorities
  • emergency and post emergency response operations for releases of hazardous substances

The requirements of the Occupational Safety and Health Standards, 29 CFR 1910, include a wide range of activities, many of which are not specifically applicable to horizontal environmental drilling. Table 1, the Table of Contents of 29 CFR 1910, at the end of this chapter shows the various activities that are covered. Subpart H. Hazardous Materials, is of particular concern for horizontal environmental wells.

The following is a brief discussion of the requirements for HAZWOPER. Please refer to the complete text of 29 CFR 1910.120 for additional detail. A complete listing of all Occupational Safety and Health Standards can be found on the Internet If you do not have access to the Internet, you can find this information at your local library.

Health And Safety Program

Every contractor working on projects covered by 29 CFR 1910.120 must have an established health and safety program that describes procedures for good health and safety practices in keeping with state and federal occupational health and safety standards and that represents the minimum standard of safe work practices to be observed. This program should be endorsed at the highest levels of your company and have full management backing for implementation. A good health and safety program will cover most of the requirements of 29 CFR 1910.120 and help your company organize to meet the requirements.

At a minimum, the health and safety program should include:

1. An organizational structure

2. A comprehensive work plan

3. A site-specific safety and health plan

4. A safety and health training program

5. A medical surveillance program

6. The employers standard operating procedures for safety and health, and

7. The interface between general program and site-specific activities.

Table 2, at the end of this chapter, is an example of the table of contents for a health and safety program. The program you develop for your company must be tailored to fit your business and practices. Prospective clients may require a COW of your health and safety program as a prequalification to bid a project.

Personal Protective Equipment (PPE)

Scope and Purpose

Given the types of projects which your company will be involved in, it is not feasible to characterize site-specific hazards and specify the exact equipment to be issued to each employee in a comprehensive program plan. Appropriate PPE should be selected and distributed on a case-by-case basis, based on the results of individual workplace hazard assessments and certifications. For the purposes of this handbook, we will only discuss PPE and clothing and respiratory protection, as they pertain to environmental drilling. Other references for electrical safety, welding, etc., should be consulted before undertaking these activities.

In every case, however, the use of PPE as the primary method of controlling employees' exposure to hazardous substances within established acceptable exposure limits is permitted only in accordance with the minimum requirements and standard operating procedures established by your company.

This section of the handbook is designed to supplement the information in your 40-hour HAZWOPER training.

Program Administration and Implementation

Your Company Health and Safety Of officer (CHSO) typically has overall responsibility and authority for establishing and implementing an effective PPE program at the administrative level. The Health and Safety Of Officer should be a certified industrial hygienist, certified safety professional, health physicist, or similarly qualified professional in the field of occupational health and safety or should have access to the services of such an individual on a contractual basis.

Your CHSO is typically responsible for evaluating the likelihood of the need for respiratory protection and/or other PPE at the initial planning stage of every project. On any project where the need for the use of PPE may be reasonably anticipated, your company should designate a Site Health and Safety Of Officer The Site Health and Safety Of ficer will be responsible for ensuring that the applicable standard operating procedures are implemented in the field.

Hazard Recognition and Evaluation

Your CHSO or a designee should assess the "workplace," including both in-house and field operations, and determine if hazards are present or likely to be present which necessitate the use of PPE. The CHSO should certify in writing that the workplace hazard assessment has been performed. At a minimum the written certification should:

  • Identify the document as certification of the hazard assessment.
  • Identify the workplace evaluated.
  • Identify the person certifying that the evaluation has been performed and the date(s) of the certification(s).

In the case of "hazardous waste field operations," the equivalent of the workplace hazard assessment and certification should be incorporated into the site/hazard characterization and site-specific health and safety plan, respectively.

Whenever the presence of chemical or radiological contamination may be reasonably anticipated in the soil or groundwater, your CHSO should investigate the site history and, to the extent possible, identify the most likely contaminants and relative concentrations (very low, high, extremely high, etc.).

Under no circumstances should the Site Health and Safety Officer allow the use of airpurifying respirators or any other PPE to be the primary method of protecting employees from potential exposure to hazardous chemical or radioactive substances on any project, unless such use is in accordance with the provisions of the written company health and safety program. The site history should be determined to the fullest extent possible, and a preliminary site characterization should be developed for every site where the use of PPE, even as a contingency, may be reasonably anticipated.

PPE --Selection And Use

The purpose of PPE is to shield or isolate individuals from exposure to chemical, physical, biological and radiological hazards via skin contact and potential dermal or ingestion.

When properly selected and used, PPE can effectively reduce and/or eliminate such hazards. Improper use of PPE can give workers a false sense of security; it can contribute to the spread of contamination and can actually create greater hazards than it prevents.

Similarly, there is no PPE substitute for good personal hygiene and work habits. Eating and smoking with contaminated hands is likely to be the single, most significant route of exposure encountered by personnel. Eating, drinking, smoking or using other tobacco products, taking medications and chewing gum are prohibited within any designated exclusion zone or decontamination zone. Workers who have been in an exclusion or decon zone or have handled any potentially contaminated materials or items anywhere on a "contaminated" site must make a habit of washing their hands prior to any of the above activities.

If necessary, portable wash stations should be set up on site. Workers should limit the above activities (with the possible exception of drinking liquids to avoid heat stress) to designated breaks and lunch periods.

It is not necessary for every worker to become familiar with all of the various PPE materials and/or their applications. It is, however, imperative that every employee and subcontractor be familiar with the general requirements and limitations discussed below and all site-specific PPE requirements and procedures designated in a Site Specific Health and Safety Plan.


Every employee required to use PPE should receive training so that he or she is knowledgeable in the recognition of hazards, characteristics and limitations of various types of PPE and is proficient in the use of the applicable equipment. At a minimum, the training should address/include:

  • Discussion of hazards which necessitate the use of PPE. When PPE is necessary. What PPE is necessary.
  • Characteristics and limitations of PPE. Selection of PPE.
  • Requirements for medical evaluation of certain users.
  • Inspection of PPE prior to use. Proper donning/adjustment/use procedures. Decontamination/doffing, disposal procedures.
  • Maintenance, cleaning, and storage of PPE.
  • Hands-on exercises.

Each affected employee must demonstrate an understanding of the training topics and the ability to use PPE properly before he or she is allowed to perform work requiring the use of PPE.

Your CHSO or a designee should certify in writing that each affected employee has received the required training and demonstrated his or her understanding of the training. The certification should include the name of each employee trained, the date(s) of training, and the specific subject of certification. A written exam is not required.

Retraining/refresher training should be provided under the following circumstances:

  • The employee cannot adequately demonstrate his or her ability to properly use PPE.
  • Changes in the workplace, employees' job duties, or types of PPE render previous training obsolete.
  • Inadequacies in an employee's knowledge or use of PPE indicate that the employee has not retained the requisite understanding of a skill.
  • At least annually for all employees engaged in operations falling under state and/or federal standard foremployees engaged in so-called "hazardous waste" operations.

Written records of training will be retained in the employee's personnel files for the duration of employment plus 30 years, or the life of your company, whichever is longer.

PPE Selection

Protective clothing, including boots, gloves, and protective coveralls/suits are available from a number of manufacturers in a wide variety of different styles, sizes and materials. The most important consideration in the selection of protective clothing is the nature of the hazardous substance(s) which will challenge the material. A material which offers a high level of protection against one class of hazardous substances may offer very little protection or even completely degrade in the presence of another. For example, polyvinyl chloride (PVC) is extremely effective against most water-soluble inorganic compounds, acids and bases, and amines, but dissolves rapidly in the presence of low concentrations of benzene and alkylated aromatics. Consequently, a preliminary site characterization is the first and perhaps most important step in the selection process.

There is no single material that is effective against all hazardous substances nor any material that is 100% effective against any single, hazardous substances given a long enough period of exposure. Permeation is a process by which a substance dissolves into and/or moves through a material on a molecular level. Almost any chemical will eventually permeate through almost any protective material.

Multiple layers of different materials could offer 100% effective protection indefinitely, but the enhanced likelihood of loose-fitting PPE becoming caught in moving machinery and the mobility, communication, and heat stress hazards created by excessive levels of PPE frequently exceed the site hazards they are intended to mitigate.

The objective is to select a material that will not degrade in the presence of the anticipated site contaminants and will resist permeation through the material (breakthrough) for the duration of its intended use and fashion a PPE ensemble which eliminates more hazards than it creates.

A fairly limited suite of boots, gloves, and coveralls can be used in various combinations or ensembles to provide an adequate level of protection for virtually any exposure scenario anticipated on any project. For example, commonly available glove materials such as neoprene and nitryl butyl rubber (NBR) are not as resistant to pure halogenated solvents (TCE, PCE and TCA) or aromatics (benzene, ethylbenzene, toluene and xylene) as certain other glove materials such as Viton (which costs over $40 per pair) or polyvinyl alcoholPVA (which dissolves in water). Under the exposure conditions most likely to be encountered by your company employees (namely intermittent handling of contaminated soil or groundwater and subsequent decontamination) neoprene and NBR gloves are perfectly acceptable, if not optimum choices for the given applications.

Unless otherwise specified in a site-specific health and safety plan, bata polyblend boots, or the equivalent boots by Ranger or Tingley, either alone or in combination with disposable boot covers (booties) will be used on all hazardous waste related projects.

Cotton coveralls or disposable Tyvek or Polytyvek coveralls should be worn on all hazardous waste-related projects. In certain (rare) cases, a second suit of "Saranex," "Chemrel," or PVC may also be indicated.

The Health and Safety Officer will select specific items typically from among those listed above, and designate a task-specific "ensemble" of PPE as discussed below.

PPE Ensembles

The following scheme should be used to designate the required level(s) of personal protective equipment and respiratory protection:


Level A refers to the use of a fully encapsulating, chemical-protective suit and either a pressure-demand, self-contained breathing apparatus or a pressure-demand, supplied-air respirator (air line) with escape provisions. Level A should be used only when the highest level of skin, respiratory, and eye protection is required. Level A is appropriate when substances with a high degree of hazard to the skin are known or suspected to be present in concentrations which could pose a dermal hazard and skin contact is possible, particularly when there is a possibility of exposure to gases or vapors which may be toxic via the dermal exposure route.


Level B refers solely to the use of a pressure-demand, self-contained breathing apparatus or a pressure-demand, supplied-air respirator with escape provisions. Level B should be used when the highest level of respiratory protection is required, but a level of skin protection less than Level A is needed.

Level B is required in atmospheres containing less than 19.5% oxygen, in atmospheres which are potentially IDLH (immediately dangerous to life or health), in atmospheres containing known concentrations of substances which warrant the use of the highest level of respiratory protection and in atmospheres known to contain incompletely identified gases or vapors as indicated by a direct-reading instrument.


Level C should refer solely to the use of full-or half-face air-purifying respirators. Level C protection may be used when the types of air contaminants have been identified, concentrations are measured and all criteria for the use of air-purifying respirators are met. Full-face respirators should be used when a high level of eye and face protection is required or when the primary hazard is an airborne particulate and a higher respirator-fit/protection factor is required such as in the case of airborne radionuclides.


Level D refers to work without respiratory protection and is permissible only when the atmosphere contains no known or suspected hazards.

The appropriate ensembles of chemical or radiological protective clothing used in conjunction with Level B. C, and D respiratory protection may vary tremendously. Consequently the numerical designations "1," "2," and "3" described below, should be used to specify the level of protective clothing that is to be utilized in conjunction with the specified level of respiratory protection. The level of PPE can thereby be completely defined by the designation "C-2," "B-1," etc.

Level 3 protective clothing consists of two, more or less separate layers of taped protective coveralls, boots, and gloves and represents the highest level of dermal protection below the Level A fully encapsulating suit. Level 3 protective clothing should be reserved for those situations where liquid or particulate contaminants are known or suspected to be present in concentrations which could result in significant exposure via the dermal exposure route, and skin contact is a plausible consideration.


  • Long pants.
  • Shirt (T-shirt acceptable).
  • Safety glasses or safety goggles.
  • Face shield, if splash hazard exists.
  • Note: 3 and 4 are not required if using full-face respirator.
  • Inner, one-piece Tyvek suit.
  • Hooded, one-piece, waterproof outer suit (Saranex, Chemrel, or PVC).
  • Inner gloves of PVC, NBR, or latex rubber taped to inner suit.
  • NBR or neoprene rubber, outer gloves taped to outer suit. Viton rubber when warranted by chemical contamination.
  • Solvent-resistant, steel-toed, rubber boots taped to inner suit.
  • Disposable, outer boot covers (booties) taped to outer suit.

The heat stress-related hazards posed by Level 3 protective clothing contradicts its use "strictly as a precautionary measure." Appropriate applications of Level 3 protective clothing include situations where whole body exposure to corrosive liquids or nearly pure phase organic hydrocarbons andlor solvents is likely, where high levels of PCB contamination exist in soil and where high concentrations of pesticides or other substances which may be acutely toxic via the dermal exposure route are present.

Level 2 should be worn whenever contamination of clothing could pose a significant exposure route or contribute to the spread of contamination "off site." Reusable, cotton coveralls or a single Tyvek suit are acceptable where the primary hazards are due to the presence of low concentrations of particulates such as soil contaminated with chromium, cadmium, PCBs, etc. or groundwater contaminated with low concentrations (one or two orders of magnitude above drinking water standards) of metals, organics, or radionuclides.

A single layer of polyethylene-coated Tyvek (Poly-tyvek), PVC, Saranex or Chemrel is appropriate where the primary hazard is contaminated surface or groundwater and contamination levels are such that any exposure via skin contact poses a potential hazard.


  • Long pants.
  • Long-sleeved shirt with collar.
  • Steel-toed, rubber boots or steel-toed, leather boots and outer boot covers (booties).
  • Outer, disposable booties (required if working in radioactively contaminated area).
  • Safety glasses or safety goggles.
  • Face shield, if splash hazard exists. Note: 5 and 6 not required if using full-face respirator.
  • Lightweight, cotton coveralls, one-piece Tyvek or water-resistant, Poly-tyvek suit.
  • Inner PVC, NBR, or latex rubber gloves.
  • NBR or neoprene rubber, outer gloves.

A minimum of Level 1 protective clothing, as specified below, must be worn by personnel while engaged in any on-site activities in the field. In the majority of situations likely to be encountered, exposure via splashing in the eyes and hand to mouth contamination are the most viable exposure routes. In such cases, appropriate eye/face protection gloves, and personal decontamination (washing hands before eating or smoking) offer a substantial level of protection.


  • Long pants.
  • Long-sleeved shirt with collar.
  • Steel-toed, leather boots or steel-toed, rubber boots where wet decontamination may be required.
  • Safety glasses or safety goggles, and where appropriate, face shield.
  • Hard hat (where overhead hazards exist).
  • Lightweight, cloth overalls when performing any sampling or any invasive procedure.
  • NBR, PVC or latex rubber, surgical gloves when sampling or handling any potentially contaminated surface or item. Where the type of glove is not specified disposable NBR rubber gloves such as Best N-Dex are convenient and offer protection against a wider variety of substances than either PVC or latex gloves.

The D-1 ensemble will be the most common classification of protective clothing worn on horizontal environmental drilling sites. Your company and workers must be prepared to upgrade to more protective ensembles as required.

Heat Stress Using PPE

Heat stress is a physiological condition which can be the result of a number of interacting factors including environmental conditions such as ambient temperature, humidity, and radiant (solar) heat load and task-related conditions such as workload, protective clothing, and the physical state of the individual worker. Working in a hot environment can have farreaching effects on workers, especially those who are unacclimated to the heat, ranging from transient heat fatigue to heat exhaustion and heat stroke. Heat stroke is a serious, immediately life-threatening situation.

Employees engaged in hazardous waste operations must bear in mind that working in protective clothing can greatly increase the likelihood and severity of heat stress, at temperatures and under working conditions which would otherwise be of little or no concern.

All employees must be aware of the possibility of and be alert to the symptoms of heat stress. Should any employee experience extreme fatigue, cramps, dizziness, headache, nausea, profuse sweating, pale clammy skin, or erratic behavior, the employee is to immediately leave the work area, undergo decontamination and remove protective clothing, rest in a shaded area, cool off, and drink plenty of cool water. If symptoms do not subside after a reasonable rest period (15 minutes to one-half hour), the employee should notify the Site Health and Safety Officer and seek medical assistance.

Under normal working conditions, the so-called wet bulb globe temperature (WBGT) serves as a fairly reliable indicator of potential heat stress. Consequently, it offers an acceptable approach to controlling the heat stress hazard by adjusting the work-rest period, based on the WBGT, and workload, as provided on p. 82 of the 1993-1994 American Conference of Governmental Hygienists Threshold Values.

When working in protective clothing however, the body's cooling mechanism is severely impaired, if not entirely defeated, and the recommendations of the above referenc,e based on the environmental WBGT, are no longer applicable. The relative humidity on the inside of an impermeable, chemical protective suit is typically "100%," and the wet bulb temperature is essentially equal to the dry bulb temperature.

In all cases, when working in level C-2, B-2, C-3 or B-3 PPE in ambient temperatures greater than 72 F. employees should use the "buddy system" to monitor each other's pulse rate at the start of each rest period. If the pulse rate exceeds 110 beats per minute, the employee should take his or her oral temperature with a clean, disposable, colormetric oral thermometer. If the oral temperature exceeds 99.6 F. the next work period should be shortened by one third. The pulse rate and oral temperature should be monitored again at the beginning of the next rest period; if the oral temperature exceeds 99.6 F. the work period should again be shortened by one third etc., until the oral temperature remains below 99.6 F. Under no circumstances should any employee be permitted to return to work in the contaminated zone if his or her temperature exceeds 100.6 F.

Ice vests should be considered whenever employees are required to work in Level C-3 or B-3 PPE in temperatures exceeding 80 F.

Employees should be encouraged to drink small amounts of water frequently. Drinking within a chemically or radioactively contaminated "exclusion zone" is prohibited unless otherwise specified in the site-specific health and safety plan. Drinking water in a "controlled area" (e.g., within the decontamination zone at the support zone decontarnination zone border is permissible and recommended, provided that the water is stored in a clean, closed container such as a plastic water cooler with a spigot and is used with single-use paper cups that are stored in a clean, enclosed dispenser and are available to drink from.

Alcohol inhibits a diuretic hormone in the kidneys and greatly increases a person's susceptibility to dehydration and heat stroke. Alcoholic beverages should be avoided completely for the duration of any project where heat stress is a factor.

Cold Stress Using PPE

The primary hazards associated with working in the cold are hypothermia (decrease in body temperature) and frostbite. Hypothermia is the most frequent cause of accidental death among individuals lost, stranded, or otherwise unprepared for extended periods of exposure but is rarely a serious occupational hazard. Nevertheless, workers should be aware of the symptoms of hypothermia:

An involuntary increase in muscle tension (goose bumps) and mild shivering occurs in response to a lowered body temperature and results in a metabolic heat production 1.5 to 2 times resting levels. If the core temperature drops to 35 C (95 F), violent whole body shivering will occur resulting in greatly increased heat production. This may temporarily render the individual totally helpless. At this point, under controlled working conditions and out of necessity, most individuals seek shelter and warmth. Further cooling to a core temperature below 32.2 C (90 F) will result in loss of muscle coordination, irrational behavior, unconsciousness and eventually death (core temperature below 80 F).

The American Conference of Governmental Industrial Hygienists has established threshold limit values (TLVs) in the form of work/warm-up schedules for employees working in temperatures below -26.1 C (-15 F).

Employees who must work under cold conditions should:

  • Eat a proper diet and never consume alcoholic beverages to "keep warm."
  • Always wear a hat, cover the neck and use a layered system of clothing. Ideally, the innermost layer should be polypropylene or a similar material which will "wick" moisture away from the skin.
  • Wear proper boots (rubber boots which trap moisture are not recommended unless absolutely necessary) and an appropriate number of pairs of socks (too many can be as bad as too few).
  • Steel-toed boots can aggravate the problem. Where steel-toed boots are required under conditions of extreme cold, workers should wear steeltoed packs or steel "toe caps" on the outside of regular packs.
  • Wear a windproof, outer layer of clothing.
  • Workers who must travel during periods of extreme cold should have appropriate clothing and equipment to deal with the environment in the event of a breakdown or other emergency.

When wearing multiple layers of PPE while working, overheating and sweating inside of the suit(s) and the resultant hypothermia due to wet clothing are likely to become the most serious problems. When working in multilayered or impermeable layers of PPE, employees should initially wear less, warm clothing than they would normally wear without the PPE and should remain alert to the symptoms of hypothermia.

Frostbite is a much more likely hazard than hypothermia. As the body attempts to keep vital, internal organs warm, it increases blood flow to the core at the expense of the extremities (hands and feet), which are also likely to be the most exposed parts of the body.

Frostbite does not become a factor for a properly clothed individual until temperatures drop below 15 F or the wind-chill index drops below -20 F. In calm winds, at -20 F the windchill is also -20 F. That same -20 F, however, in a 25 mile per hour wind results in a wind-chill factor of 74 degrees below zero and represents a serious frostbite hazard.

Frostbite is most likely to occur in extremities, especially the fingers, toes, cheeks and ears. In very early stages of frostbite, the affected body part may feel numb and appear white.

As frostbite progresses, the individual may experience pain and a loss of flexibility in the affected body part and the affected skin may appear waxy or translucent. Mild frostbite can be treated by immersing the affected part in warn water. Frostbitten tissue should not be rubbed. Deep frostbite is a very serious condition which requires immediate medical eatment.

Preventative measures for frostbite:

  • Wear proper boots and socks. Be aware of the fact that steel-toed boots may aggravate the situation.
  • Wear mittens rather than gloves, if possible.
  • Avoid the use of tobacco, as it constricts blood flow.
  • Always wear a hat andlor a hood which covers the ears.
  • In extreme conditions, wear a mask or skin cap which covers the entire face except for the nose and mouth.
  • Be aware of the conditions which are likely to cause frostbite [i.e., wind-chill index below -28 C (-20 F)], be aware of the symptoms, and be prepared.

Issuance d PPE

No employee should be issued PPE aside from hard hats and safety glasses/face shields or assigned to any project requiring the use of PPE until the employee has received the required training and a baseline physical examination. In the field, the Site Health and Safety Of fleer should verify that each employee is provided with the proper size of the appropriate PPE specified in the Site-Specific Health and Safety Plan.

PPE Inspection

Employees must inspect all PPE prior to use. Outer (rubber) gloves should be inflated and rolled up to identify holes. Rubber boots should be examined for any evidence of degradation or leaks. Site personnel can use the "buddy system" to visually inspect the integrity of disposable coveralls on the individual, prior to entering the contaminated area. Any PPE found to be defective or compromised in any way should be immediately replaced.

PPE Decontamination and Disposal

All PPE used on potentially contaminated sites must be properly decontaminated and/or disposed of in proper containers. Appropriate decontamination and disposal procedures should be specified in the Site-Specific Health and Safety Plan.

In general, decontamination of PPE will be limited to washing and rinsing respirator face pieces, boots, and occasionally outer gloves and boot covers. Disposable coveralls will typically be removed and discarded after one use. Boot covers and outer gloves may be decontaminated and reused but will typically be discarded at the end of each shift. Respirator cartridges should be removed and discarded as necessary but no less than once a day at the end of each shift.

Every effort should be made to minimize the amount of decontamination liquids (wash water) generated. Arrangements must be made in advance to leave all decontamination liquids and discarded PPE with the client, for subsequent disposal by the client.

Physical Qualifications of Personnel

No employee should be assigned to a task requiring the use of a respirator or chemical protective clothing until he or she has been approved for the use of such equipment by a licensed physician. At a minimum, employee evaluations should meet the requirements of American National Standards Institute (ANSI) Z88.6-1984 "American National Standard for Respiratory Protection --Physical Qualifications for Personnel." A copy of the physician's written evaluation should be retained in the employee's confidential personnel file, with a copy kept in the field file in the event that an OHSA inspector wants verification of medical monitoring.

Follow-Up Medical Surveillance

All employees who are or may be exposed to hazardous substances at a level in excess of an established PEL (permissible exposure limit), TLV (threshold limit value), or REL (NIOSH recommended exposure limit) for 30 days or more per year; all employees who wear a respirator for 30 days or more per year; and any employees who may have been exposed to hazardous substances at concentrations above the applicable PEL's or TLV's in an emergency situation should receive follow-up medical examinations at least once a year. Physical examinations or biological monitoring for specific contaminants (or the appropriate metabolites) may be conducted more frequently as necessary to evaluate the effectiveness of the PPE program.

A physician should determine the requirements of each follow-up examination with the complete cooperation of your CHSO. At a minimum, your CHSO and the employee should provide the physician with a description of the employee's duties as they relate to the employee's exposure, the employee's exposure levels or anticipated exposure levels and a description of any actual or anticipated use of personal protective equipment. Further, any information from previous medical examinations of the employee which is not readily available to the examining physician should be made available by your company, the employee, or the employee's personal physician.

All employee medical records and available exposure records should be retained in a confidential personnel file for at least the duration of employment plus 30 years, or the life of your company, whichever is longer. An employee's medical and/or exposure records should be provided to the employee or a designated representative within 15 days of a verbal or written request.

Program Evaluation

The effectiveness of the PPE program should be evaluated at least annually in order to identify and correct deficiencies. The evaluation should include consulting the users/wearers to determine wearer acceptance and address any suggestions, complaints, etc. In addition, the operation of the program should be periodically audited to ensure that appropriate PPE is consistently issued, properly used, and maintained in good operating condition.

Finally, the evaluations should include an appraisal of the level of protection afforded. Results of the periodic physical examination should be evaluated and if, necessary, specific bioassay surveillance of respirator/PPE wearers should be conducted to determine if wearers are being provided with adequate protection.

Respiratory Protection

Occasionally, field operations may involve working in the presence of potentially harmful airborne contaminants. Such contaminants could conceivably include toxic gases and vapors, dusts, mists, and sprays, smoke and/or fumes, and oxygen-deficient atmospheres associated with certain work practices, intrusive activities in contaminated soil or groundwater, confined-space entry, or other unrelated pre-existing site conditions.

Given the transitory and often unpredictable nature of field operations, engineering methods to control such hazards are rarely feasible. In those instances, the employee must rely on the use of personal respiratory protective devices such as air-purifying or air supplying respirators to protect his or her health.

Use of Approved Respirators

Only gas masks approved by the Bureau of Mines under BM Schedule 14F or respirators approved by Mine Safety and Health Administration (MSHA) and NIOSH (National Institute for Occupational Safety and Health) under provision of 30 CFR 11 should be used. Any modifications of an approved respirator or use of any component that is not specifically approved for use with an approved respirator by the authorizing agencies voids the approval.

Facial Hair and Corrective Lenses

Under no circumstances should any employee use any negative-pressure respirator, any self-contained breathing apparatus (SCBA), or any respirator in an atmosphere immediately dangerous to life or health (IDLH), if facial hair comes between the sealing periphery of the face piece and the face or if facial hair may interfere with valve function. This requirement effectively prohibits the use of respirators by persons wearing beards (even if only several days' growth), large sideburns, and large mustaches.

Eyeglasses with temple bars should not be worn with any respirators having a full face piece. ANSI procedures and OSHA regulations disallow the use of respiratory protection by persons wearing contact lenses. The original basis of this dictum, however, has never been clearly established. Industry experiences over the past 23 years since OSHA adopted ANSI Z88.2-1969 in the respiratory protection regulations have likewise failed to provide any justification.

As a general policy, employees should avoid wearing contact lenses with respiratory protection. Employees with uncorrected vision poorer than 20/40 with both eyes should not wear a full-face respirator without vision correction. When such vision correction is required on a regular or long-term basis, your company should provide corrective lenses which fit inside of the full-face respirator face piece. In those instances where an employee would otherwise be unable to perform his or her job duties or in an emergency situation, the use of contact lenses with respiratory protection is permissible.

Employees should not wear contact lenses while using respiratory protection in any IDLH atmosphere under any circumstances other than emergency escape.

Fit Testing

No employee should wear any respirator other than a pressure-demand supplied-air respirator in any atmosphere exceeding any permissible exposure limit (PEL) or threshold limit value (TLV), unless he or she has been qualitatively fit tested using isoamyl acetate (banana oil) and stannic oxychloride (irritant smoke) according to the procedures set forth in Appendix C of the 29CRF1910.1001 asbestos regulations.

The employee should be allowed to use only the specific make(s), model(s), and size of respirator(s) for which he or she obtains a satisfactory fit as determined by the above referenced procedure. Fit testing should be repeated at least every six months or whenever an employee loses or gains in excess of fifteen pounds or has major cosmetic or dental surgery which may effect the respirator fit.

A record of respirator fit test results should be retained in the employee's health and safety file for the duration of employment plus 30 years, or the life of your company, whichever is longer. An additional wallet-sized record should be provided to the employee and maintained on his or her person. These records should include the following information:

  • Name of person tested. Date of test. Type of fit test procedure used. Specific make, model and size of respirator tested. Name of test operator.
  • Results of fit test including success or failure to obtain a satisfactory seal.


Every employee required to wear a respirator should receive training such that he or she is knowledgeable in the characteristics and recognition of respiratory hazards and proficient in the use of the applicable respirator(s). At a minimum, the training should address:

  • Classification of respiratory hazards according to their biological effect.
  • Respirator selection.
  • Limitations of respirators and restrictions on use.
  • Respirator inspection.
  • Medical evaluation of users.
  • IDLH and oxygen-deficient atmospheres and confined spaces.
  • Maintenance, cleaning, and storage of respirators.
  • Fit testing.
  • A long familiarizing period of wear in normal air.

Refresher training should be provided at least annually, or quarterly if respirators are intended primarily for emergency use or for use in potentially IDLH atmospheres. All initial training and all refresher training of Site Health and Safety Officers should be administered by or under the direction of your CHSO. A written outline of the training program should be maintained and periodically updated (at least annually).

Written records of training will be retained in the employee's personnel files for the duration of employment, plus 30 years or the life of your company, whichever is longer.

Respirator Selection Criteria

The following factors must be considered in the selection of appropriate respiratory protection:

  • Are the airborne contaminants known?
  • If so, what toxic substances are present and in what (relative) concentrations?
  • Is the atmosphere expected to be oxygen-deficient (<19.5 percent 02) or IDLH (immediately dangerous to life or health)?
  • What are the peak versus average concentration?
  • Do the contaminants exhibit good warning properties (e.g., odor or irritation), or are the contaminants readily detectable on a direct-reading air-monitoring instrument?
  • What are the chemical and physical properties of the contaminants?
  • What are the potential health effects if an improper respirator is selected or if an appropriate respirator is used improperly?
  • Is the respirator intended for emergency response or rescue operations?

The overall working environment and nature of the task(s) must also be considered. For example:

  • How far must an employee go to reach safety (clean air)?
  • What will be the expected temperature and humidity? High temperatures and humidity greatly decrease the efficiency and useful life of air-purifying respirators. Extreme temperatures compromise elastomeric parts, cause fogging of face masks, and freeze valves and regulator parts.
  • Does the task require the use of respirator protection continuously or only occasionally? How often and for how long?
  • What is the required level of physical exertion?
  • Must the employee be able to move about freely or is the task restricted to a relatively limited area?

The following restrictions apply to the use of half-face or full-face air-purifying respirators. Air-purifying respirators may be used only when all four of the following conditions are met:

  • The atmosphere is not IDLH.
  • The atmosphere is not oxygen-deficient (i.e., less than 19.5 percent oxygen).
  • The airborne contaminants exhibit good warning properties or the atmosphere is monitored on a real-time basis.
  • It can be demonstrated that the concentration of airborne contaminants is below the product of the PEL, TLV, or REL (as appropriate) times the respirator protection factor (PF) or the maximum approved capability of the cartridge, whichever is lower.

Maximum concentration = TLV x PF

The PF is defined as the ratio of the concentration of a contaminant in the ambient air, to the concentration inside the respirator mask. The PF can be determined exactly by performing a "quantitative fit test," (i.e., simultaneously measuring the concentrations of a test substance on the inside and outside of the mask).

As an alternative to determining protection factors by the quantitative fit testing procedure, the ANSI Z88.2-1980 Standard Practices for Respiratory Protection assign the following protection factors for various types of respirators when a satisfactory fit is demonstrated by the qualitative fit-testing procedure:

Type of Respirator

Protection Factor

Half-face air-purifying


Full-face air-purifying

100 50(OSHA)

Powered air-purifying


Demand air-supplied

100 50(OSHA)

Pressure-Demand air-supplied


Your CHSO has the responsibility to ensure that all of the above criteria for the use of airpurifying respirators, particularly bullet No. 4, are met. In those instances where a determination is made that air-purifying respirators offer an adequate level of protection, the employee should be allowed to pick the most comfortable respirator from a selection including respirators of varying sizes from different manufacturers. In addition, the Site Health and Safety Officer should ensure that each employee is provided with approved fresh cartridges appropriate for the (presumably) known respiratory hazard(s).

Air purifying respirators equipped with organic vapor/acid gas cartridges are quite effective in removing certain highly toxic gases such as H2S and HCN but are not approved for such use due to the acutely toxic nature of these substances and the potential for the sudden development of IDLH conditions. In such cases, the use of cartridge-type air-purifying respirators at concentrations in excess of the eight-hour TLV, short-term exposure limit (STEL) or TLV ceiling value (C) is permitted only for emergency escape.

Continuous exposure to HIS, HCN or other acutely toxic substances at concentrations in excess of the respective TLV's require the use of pressure-demand air-supplying respirators. Pressure-demand self-contained breathing apparatus (SCBA) or pressure demand air line respirator with escape bottle must be used in the following situations:

  • IDLH atmosphere.
  • Oxygen-deficient atmosphere.
  • Unknown, airborne contaminants and/or unknown concentrations of contaminants with poor warning properties.
  • Confined-space entry regardless of contaminant unless a lower level of protection can be justified and is specified in the task-specific confined-space entry permit.
  • Emergency rescue in contaminated or oxygen deficient atmosphere.

In all other instances, an appropriate respirator may be based on the physical requirements and logistics of the specific task at hand. Specific procedures will be established in the project-specific health and safety plan prepared by either your client or your CHSO and implemented by the Site Health and Safety Officer.

In those instances where existing data or a detailed site history indicate that chemical concentrations are very low or there are only a few possible contaminants, your CHSO may be able to establish an appropriate respiratory protection strategy based on the relative toxicity of contaminants, comparison of odor thresholds to PEL's or TLV's, etc.

When contamination is known or expected to exist in significant (but below IDLH) concentrations and the contaminants are unknown or there are many possible contaminants, the selection criteria discussed above allows only two possible respiratory protection alternatives until the respiratory hazard is positively identified and characterized:

  • The use of pressure-demand supplied-air respiratory protection.
  • The use of appropriate air-purifying respirators, while continuously monitoring workers' breathing zones with an appropriate direct reading instrument such as a Photovac "Microtlp," a Thermoenvironmental "OVM," or a Foxboro organic vapor analyzer (OVA) for organics, an MSA 361 for HIS (hydrogen sulfide) and detector tubes for specific compounds such as HCN (hydrogen cyanide), with predetermined conservative action levels (as indicated by the direct-reading nstruments) established to serve as the basis for either ceasing operations or upgrading to pressure-demand supplied-air.

Additional factors such as the presence or absence of waste lagoons, abandoned or unlabeled drums, visible contamination, stressed vegetation, dead animals, or perceptible odors will weigh heavily in determining an appropriate level of respiratory protection.

For example, where the history of a site and nature of contaminants are ill-defined but the site is known to include a long history of industrial use and is obviously grossly contaminated, pressure-demand SCBAs might be a logical level of respiratory protection for an initial entry. On the other hand, given that there is no longer any observable evidence of chemical contamination nor any perceptible odors in the area, a lower level of respiratory protection might be entirely appropriate provided that one observes the following precautionary measures:

  • to the extent possible, always approach a potentially contaminated area from upwind.
  • monitor the air continuously using an appropriate, direct-reading instrument (typically a photoionization or flame ionization organic vapor detector).
  • establish "action levels" for either leaving the area or upgrading to a pre-determined level of protection.

According to the USEPA's "Rationale for Relating Total Atmospheric Vapor/Gas Concentrations to the Selection of the Level of Protection," any consistent reading on an OVM or OVA in the worker's breathing zone above the upwind background level is the recommended action level for the use of an air-purifying respirator. Readings in excess of five ppm above background require pressure-demand air-supplied air. These action levels are believed to be conservative in most situations but must, nevertheless, be adjusted appropriately depending on available information regarding site history, previous use, known site conditions, existing data, and field observations as discussed above.

When contaminants are known or have been positively identified by an appropriate sampling strategy and air-purifying respirators have been selected to reduce employee exposure levels, the Health and Safety Of ficer or the Site Health and Safety Officer must select appropriate air-monitoring instrumentation and implement an air-monitoring regimen commensurate with the perceived degree of respiratory hazard.

The action level for the use of respiratory protection should be determined as follows:

  • Identify the "critical" contaminants(s). This will depend on a number of factors including relative concentration, relative toxicity, vapor pressure, odor threshold, etc.
  • Identify an appropriate monitoring instrument and the instrument response (in percent relative to the calibration gas used) to the critical contaminant(s).
  • Multiply the instrument response times the TLV or PEL of the critical contaminant (whichever is lower). If the site falls under the OSHA 1910.120 standards for hazardous waste operations or a state equivalent, use the lowest of the TLV, PEL, or NIOSH REL.

For example, assuming that trichlorethylene (TCE) is identified as the critical contaminant (PEL-100 ppm, TLV-50 ppm, REL-25 ppm) and the OVA response to TCE is 70 percent, the action level for the use of respiratory protection will be 0.7 x 25 ppm = 17.5 ppm as measured on an OVA. Good industrial hygiene practice, however, requires that a reasonable safety factor (such as "2") be applied to allow for instrument variations or any possible additive effects of mixtures of contaminants. In the above case, breathing-zone concentrations consistently in excess of 10 ppm as measured on the Foxboro OVA would represent a reasonable action level for donning organic vapor air-purifying respirators.

The maximum allowable concentration for the use of a particular type of respirator should be the lower of the action level determined according to the procedures specified above times the assigned protection factor for the particular respirator or the maximum use concentration as stated on the cartridge. Using the example above, the maximum allowable concentration for a half-face respirator as determined on an OVA will be:

10 ppm x 10 (PF) = 100 ppm

Note that this is only applicable in those instances where the contaminants are known.

Air-monitoring equipment should be available on all sites falling under the requirements of 29CRF1910.120 (RCRA cleanups, CERCLA remedial actions, hazardous materials spills, etc.) and on all sites where there is known contamination or where high levels of contamination may be reasonably anticipated (abandoned municipal landfills, etc.).

Issuance of Respirators

No employee should be issued a respirator or assigned to a project requiring the use of respiratory protection until the employee has received a baseline physical examination and been fit tested as specified in Section 7 above for the specific make, model, and size of respirator issued. Your CHSO should be the only one having the authority to select and assign respirators. In the field, the Site Health and Safety Officer should verify that each employee is provided with an appropriate respirator and the proper cartridges and/or filters as necessary.

Respirator Inspection, Maintenance and Storage

Each employee assigned to a task which may require the use of an air purifying respirator should be trained in proper inspection, maintenance decontamination and storage procedures for his or her respirator.

The respirator should be inspected by the wearer prior to each use to ensure that it is in proper working condition. This will include inspection of the inhalation and exhalation valves for creases, tears, poor seating, foreign material, etc., examination of all rubber or elastomeric parts for signs of deterioration, verification that the respirator is equipped with appropriate cartridges, and evaluation of the overall condition of the respirator.

Each employee should be responsible for the proper decontamination, cleaning, routine maintenance and storage of his or her air-purifying respirator. It should be the employee's responsibility to inspect his or her respirator for missing, worn or deteriorated parts or any other defects and return the respirator to the Site Health and Safety Officer for repair or replacement. All respirators must be inspected before and after each use and during cleaning.

Individual employees must perform the specified check-out procedures prior to the initial "donning" and at least once prior to each day of use thereafter, and they must use the equipment in accordance with the training received.

Respirators should be stored in a manner that will protect them against dust, sunlight, heat, extreme cold, excessive moisture or damaging chemicals. Respirators should be stored to prevent distortion of rubber or other elastomeric parts. Respirators should not be stored in such places as lockers and tool boxes unless they are protected from contamination, distortion and damage. Emergency and rescue-use respirators that are placed in work areas should be quickly accessible at all times, and the storage cabinet or container in which they are stored should be clearly marked. Each respirator stored for emergency or rescue use should be inspected by the designated Site Health and Safety Officer at least once a month. The date and results of the inspection should be recorded and maintained with the respirator.

Repairs to air-supplying respirators, other than routine maintenance, should be performed only by certified technicians.

Emergency Use

Occasionally, air-purifying respirators may be necessary to bring employee exposures within allowable TLV's or PEL's on a continuous basis. In other instances, respiratory protection will not be routinely required, and the use of a half-face respirator will in itself represent the "contingency plan."

On those sites where the possibility of chemical contamination has been recognized, a preliminary site characterization must be prepared, and the potential risks associated with the known or suspected contaminants must be identified. If the potential exists for exposures in excess of any established standard, an appropriate initial level of protection must be designated, appropriate air-monitoring procedures and "action levels" must be established, and the appropriate "action" to be taken in the event of the exceedance of a designated action level must be specified in advance.

Should air contamination levels exceed the maximum allowable concentrations of the available respiratory protection or should a situation arise which is obviously beyond the scope of the specified respiratory protection strategy (such as sudden release), workers should don their respirators if they have not done so already and immediately leave the area.