Model Health & Safety Plan (HASP) for Clean-up of Facilities Contaminated with Anthrax Spores

I. Introduction
This HASP template was prepared by OSHA and funded by EPA. It provides model language that is acceptable to OSHA in meeting the requirements of OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, 29 CFR 1910.120 or 29 CFR 1926.65, paragraph (b)(4). That paragraph requires a site-specific safety and health plan for clean-up operations conducted under HAZWOPER. Qualified health and safety professionals can use the accompanying files to create a site-specific health and safety plan for cleanup of facilities recently contaminated with anthrax spores through bio-terrorism. If these files are completed accurately and thoroughly, and the resulting HASP is fully implemented at the anthrax-decontamination project site, the employer is likely to have a site health and safety program that effectively protects employee health and safety. The files are available as compressed (zipped) Word 6.0/95 document files. They can be opened by most modern word-processing software.

There are 13 HASP chapters included here, one for each of the required elements listed in paragraph (b)(4) of HAZWOPER. Eleven of these are full-text chapters (1-11 below), and two are place-holder chapters where you will insert information from other sources (12 & 13). The chapters include:

  1. Organizational Structure
  2. Site Characterization and Job Hazard Analysis
  3. Site Control
  4. Training
  5. Medical Surveillance
  6. PPE
  7. Exposure Monitoring
  8. Heat Stress
  9. Spill Containment
  10. Decontamination]
  11. Emergency Response
  12. Standard Operating Procedures (SOPs): placeholder chapter for SOPs not included in other chapters
  13. Confined Spaces: placeholder chapter for written confined space entry procedures. If you need assistance preparing such procedures, see OSHA's e-tools webpage.

A brief safety data sheet for anthrax is also included. To date, there is no established exposure limit for anthrax spores. Therefore, exposure should be kept to a minimum.

These files are also available in an ALL-In-One.

II. Specific Instructions for Completing the HASP

These chapters are word processing documents that can be completed by filling in site-specific information. Technical health and safety decisions are required to complete this HASP, just as the preparation of any HASP would require. For this reason, OSHA recommends that only qualified health and safety professionals be used as HASP preparers.

Instructions are included in each chapter to guide the HASP preparer in completing site-specific text. These instructions are in the form of optional text, help text, pick lists, "insert" instructions, and "add/delete/edit" instructions. Each of these is described more fully below.

  • Optional Text: Optional text provides different versions of chapter language depending on specific site circumstances. For example, chapter text for a site that relies on its own employees for emergency response will be different than a site that relies on an outside organization such as a local fire department. The instructions for optional text appear as bold text.
  • Help Text: Help text is included to help the HASP preparer make key decisions. For example, help text provides the definition of a permit-required confined space to assist the preparer in determining whether permit spaces exist at the site. Help text appears as italicized text in brackets.
  • Pick Lists: Pick lists provide a selection of items to help complete a table. For example, a pick list of exposure monitoring instruments will provide the preparer a list of possible instruments to choose from. Pick lists are only suggestions; the preparer must complete each table accurately based on equipment and procedures actually used at the site. In chapter text, a note signifies that there is a pick list associated with the applicable paragraph. The pick lists appear at the end of chapters.
  • "Insert" Instructions: Insert instructions tell the preparer to insert a required figure or map. For example, the preparer must insert a map showing the site zone boundaries. Insert instructions typically appear at the top of a blank page where a map or figure needs to be inserted.
  • "Add/Delete/Edit" Instructions: Add/delete/edit instructions generally appear before chapter SOPs in bold text and instruct the preparer to add, delete, or edit SOPs as appropriate for the site.

To get the maximum benefit from this HASP, OSHA recommends the following:

  • Complete the chapters in order, or at a minimum, complete Chapter 2 before completing Chapters 3-15. This is important since the site characterization/job hazard analyses in Chapter 2 are the basis for the protective measures selected in the remaining chapters.
  • Do not edit or delete text except where indicated in order to retain the HAZWOPER provisions intentionally included in these files.
  • Provide the information requested. The chapter text is designed to prompt you for information that needs to be planned and determined before site activities begin.
  • Insert personnel names wherever indicated in order to assign responsibility for the specific task discussed.
  • Implement the written program that results from your site-specific input.
  • If you have questions about how to choose effective control measures for your anthrax facility decontamination project and/or how to comply with the provisions included in this HASP, seek OSHA's assistance. We recognize that there are no established methods for clean-up of facilities contaminated with weapons-grade anthrax spores. For help in planning and implementing effective clean-up operations, please contact your OSHA Area Office.

III. Attachments to the HASP

You may need additional written programs, plans, or procedures to meet the requirements of other applicable OSHA standards. For example, employees will likely use respiratory protection during facility decontamination/clean-up so you will need to have a written Respiratory Protection Program consistent with 29 CFR 1910.134.

It is also likely that you will need to address the control of hazardous energy, consistent with OSHA's lockout/tagout standard, 29 CFR 1910.147. OSHA's e-tools webpage mentioned above, also offers software to help employers prepare written lockout-tagout procedures.

Examples of written programs, plans, or procedures that may be necessary as a result of health or safety hazards associated with facility decontamination/clean-up operations include but are not limited to:

  • Hearing Conservation Program
  • Respiratory Protection Program (noted above)
  • Exposure Control Plan (Bloodborne Pathogens)
  • Lockout/Tagout Procedures (noted above)
  • Hazard Communication Program
  • Substance-Specific Compliance Program (for expanded health standards in 1910.1001-1910.1096)