Preparedness

For emergency response employers and workers, preparing for a potential radiation emergency plays a vital role in ensuring that they have the necessary equipment, know where to go, and know how to stay safe and healthy when responding to an actual radiation emergency. This page provides information on how to prepare and train emergency response employers and workers for radiation emergencies.

This page provides information specifically for emergency response workers and employers. Workers and employers without emergency response and recovery or related support functions should consult the General Businesses page for information on preparing for radiation emergencies.

On this page… for emergency response workers and employers:

• Plan
  • Planning for Emergency Response Workers
  • Applicable OSHA Standards and Required Plans
  • Incident Command System
• Equip
  • PPE for Emergency Response Workers
  • PPE Requirements in OSHA Standards
• Train
• Exercise

Plan

Planning for Emergency Response Workers

It is crucial that employers whose workers conduct emergency response actions in the early phase of a radiation emergency thoroughly plan in advance to ensure that those workers are adequately prepared if such an incident occurs. Planning should include:

• Evaluating anticipated radiation exposures during radiation emergencies, such as nuclear power plant releases; improvised nuclear device (IND), radiological dispersal device (RDD), or radiation exposure device (RED) events; or other radiation incidents.
• Developing procedures for reducing and maintaining emergency responder exposures to levels As Low as Reasonably Achievable (ALARA) and according to recommended occupational dose limits.
• Obtaining appropriate personal protective equipment (PPE), including respirators and other protective equipment and clothing, for emergency response workers who enter contaminated areas.
• Developing appropriate decision-making criteria for responding to catastrophic incidents that may involve high radiation exposure levels, such as describing what actions (i.e., lifesaving, protecting critical infrastructure) may warrant exceeding established occupational dose limits.
• Informing and educating emergency response workers about emergency response procedures and controls, the voluntary nature of taking on high-risk missions, and the short- and long-term risks of exposure, particularly at higher dose levels.

Effective advanced planning will help ensure that appropriate guidelines are correctly applied and that emergency response workers are not exposed to unnecessary radiation during emergency response operations. In addition, as part of advanced planning, employers should develop a process for assessing hazards and determining appropriate actions in incidents that may involve radiation exposures exceeding occupational dose limits.

Several federal interagency resources offer guidance to employers and other decision-makers on advanced planning for response activities:

• Planning Guidance for Response to a Nuclear Detonation. Interagency document.
• Protective Action Guides (PAG) and Planning Guidance for Radiological Incidents (2017 PAG Manual). U.S. Environmental Protection Agency (EPA).
• Health and Safety Planning Guide for Planners, Safety Officers and Supervisors for Protecting Responders Following a Nuclear Detonation. Interagency document.
• Planning Guidance for Protection and Recovery Following RDD and IND Incidents. U.S. Department of Homeland Security (DHS), Federal Emergency Management Agency (FEMA).

OSHA also provides specific guidance to protect emergency medical services workers from hazardous substance releases during treatment and transport and for hospital-based first receivers of victims from mass casualty incidents involving the release of hazardous substances. The guidance discusses planning for PPE and training needs, decontamination, and other topics.

Decisions regarding emergency response actions for incidents involving radiation exposures in excess of OSHA occupational dose limits require careful consideration. Where OSHA has jurisdiction, the agency always retains its enforcement authority and OSHA standards always apply. Nevertheless, employers should establish plans for weighing the benefits of a rescue or response action (e.g., the significance of the outcome to individuals, large populations, general welfare, or critical infrastructure necessary for public welfare) against the potential health impacts of radiation exposure and other hazards on emergency workers. In an actual emergency response, an employer should apply these plans while working with the Incident Commander, Unified Command staff, and other health and safety personnel to limit worker exposures to all hazards. Employers should mitigate health and safety hazards through a combination of engineering, work practice, and administrative controls (e.g., establishing turn-back doses indicating when workers should leave an area where they are exposed to certain levels of radiation, or setting dose limits for radiation) and appropriate PPE.

Applicable OSHA Standards and Required Plans

This section highlights OSHA standards and directives (instructions for compliance officers) that may be applicable in the event of a radiation emergency. While this page discusses standards across many of the sectors for which OSHA has worker safety and health requirements, OSHA anticipates that most types of emergency response operations fall outside the scope of requirements for the maritime (i.e., shipyard employment, marine terminal, and longshoring) and construction sectors. In these cases, emergency response operations fall under OSHA's general industry standards. Construction standards may be most relevant as response operations transition to recovery, clean-up, and rebuilding after catastrophic radiation emergencies.

OSHA's Ionizing Radiation standards protect workers in:

• General industry (29 CFR 1910.1096), including most covered emergency responders.
• Construction (29 CFR 1926.53).
• Shipyard employment (29 CFR 1915.57 and, to the extent it applies, 29 CFR 1910.1096).
• Marine terminals (29 CFR 1910.1096, to the extent it applies).
• Longshoring (29 CFR 1910.1096, to the extent it applies).

The construction standard for ionizing radiation (29 CFR 1926.53) incorporates by reference the provisions of the general industry standard (29 CFR 1910.1096), in addition to requiring a competent person to perform activities involving the use of radioactive materials or x-rays (see 29 CFR 1926.53(b)). While some shipyard employment operations are covered by OSHA's Uses of Fissionable Material in Ship Repairing and Shipbuilding standard (29 CFR 1915.57), the general industry standard for ionizing radiation (29 CFR 1910.1096) also applies across the maritime sector to activities on vessels and on shore, including in shipyard employment, marine terminals (see 29 CFR 1917.1(a)(2)(vii)), and longshoring (see 29 CFR 1918.1(b)(5)).

OSHA's Ionizing Radiation standards set, including by incorporating by reference, ionizing radiation dose limits for workers. The Ionizing Radiation standards generally:

• Ensure workers are protected from over-exposure.
• Apply to all general industry, construction, and maritime (i.e., shipyard, marine terminal, and longshoring) workers and employers under OSHA jurisdiction, including those involved in emergency response operations.
• Permit whole-body exposure up to 1.25 rem (0.0125 Sv) per calendar quarter, which is often applied in practice as 5 rem (0.05 Sv) per year. In circumstances where exposure above this level would not cause a worker’s accumulated occupational dose to the whole body to exceed 5(n-18) rem ((5(n-18))/100 Sv), where n equals the individual's age in years at his/her last birthday, employers may permit workers to receive a 3-rem (0.03-Sv) dose in a single quarter. Allowing workers to receive doses above the 1.25-rem (0.0125-Sv) quarterly limit is also contingent upon compliance with certain recordkeeping and other requirements of the standards (see, for example, 29 CFR 1910.1096(b)(2) for more information). Note that dose limits may vary under the Uses of Fissionable Material in Ship Repairing and Shipbuilding standard (29 CFR 1915.57) for shipyard employment, as it incorporates by reference provisions of Nuclear Regulatory Commission (NRC) radiation protection standards (10 CFR Part 20). However, most emergency operations involving response to radiation emergencies in shipyards, where 29 CFR 1915.57 applies to activities involving the use of and exposure to sources of ionizing radiation, would fall under the general industry standard (29 CFR 1910.1096).
• Provide airborne exposure limits for radionuclides, which may be more restrictive. The limits given in Appendix B, Table 1 are for exposure to the concentrations specified for 40 hours in any workweek of 7 consecutive days. See 29 CFR 1910.1096(c)(1) for further information.
• Require dose monitoring when a worker receives or is likely to receive a dose in any calendar quarter in excess of 25 percent of the applicable dose limit.
• In construction and shipyard employment, require competent persons specially trained in the proper and safe operation of equipment used in activities involving radioactive materials or X-rays.

The Dose Limits for Emergency Response section of the Response page provides more information about OSHA's worker dose limits, considerations for response operations in which worker doses cannot be maintained below the OSHA limits, and dose limits for other groups (i.e., those of other regulatory agencies that apply to pregnant workers, workers in U.S. Department of Energy or U.S. Nuclear Regulatory Commission-licensed facilities, and members of the public). The Response page also discusses response worker dose monitoring; emergency response employers and workers should be prepared—including by having appropriate equipment and the training to use it—to monitor doses during radiation emergencies.

Employers whose workers will be involved in emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard must comply with OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120 in general industry and, to the extent it applies, in shipyard employment; and 29 CFR 1926.65 in construction). This may include emergency response following a radiation incident. Instruction CPL 02-02-073 describes OSHA enforcement procedures under the relevant provisions of the HAZWOPER standards.

The U.S. Environmental Protection Agency (EPA) has promulgated a standard applying OSHA's HAZWOPER standard to state and local government workers in states where there is no OSHA-approved State Plan. See 40 CFR Part 311.

OSHA standards also require PPE to protect workers, including where engineering and administrative controls are not sufficient to prevent or reduce worker exposures to allowable levels for a variety of hazards. These standards help protect workers in:

• General industry (29 CFR 1910 Subpart I), including most covered emergency responders.
• Construction (29 CFR 1926 Subpart E).
• Shipyard employment (29 CFR 1915 Subpart I).
• Marine terminals (29 CFR 1917 Subpart E).
• Longshoring (29 CFR 918 Subpart J).

Note that OSHA's requirements in the maritime sector incorporate by reference the provisions of specific PPE standards for general industry, including the Respiratory Protection standard (29 CFR 1910.134); see 29 CFR 1915.154 in shipyard employment, 29 CFR 1917.1(a)(2)(x) in marine terminals, and 29 CFR 1918.1(b)(8) in longshoring.

Employers should also be familiar with other OSHA requirements that may apply to their workers, including the General Duty Clause of the Occupational Safety and Health (OSH) Act of 1970, which requires employers to keep their workplace free of serious recognized hazards. The OSHA Standards section of the OSHA Resources page provides a list of additional standards that may apply during a radiation emergency.

Incident Command System

During radiation emergencies, response organizations—including employers involved in response and recovery operations—should be prepared to implement the Incident Command System (ICS). The ICS is part of the National Incident Management System (NIMS) established by the U.S. Department of Homeland Security (DHS)/Federal Emergency Management Agency (FEMA). ICS provides a standardized, on-scene, all-hazards incident management approach that:

• Allows for the integration of facilities, equipment, personnel, procedures, and communications within a common organizational structure.
• Enables a coordinated response among various jurisdictions and organizations, both public and private.
• Establishes common processes for planning and managing resources.

The DHS/FEMA ICS Resource Center provides guidance on implementing the ICS during an actual emergency response. These resources explain the roles and responsibilities of the participants in the ICS, the role of safety and health personnel in the ICS and the role of a Unified Command (UC) structure in coordinating an effective response. This guidance may be useful for employers, response workers, and others affected by emergency situations.

Homeland Security Presidential Directive (HSPD)-5 – Management of Domestic Incidents provides additional background about the creation of NIMS.

Equip

PPE for Emergency Response Workers

Employers of emergency response workers are responsible for ensuring that their workers have and properly use PPE when necessary. PPE can include respiratory protection, protective clothing, and protective barriers used to protect workers from exposure to chemical (including oil), biological, radiological, and nuclear (CBRN) materials and other hazards. The selection of PPE is based on anticipated hazards, and PPE selection may need to be modified as a result of monitoring and assessing actual working conditions. In planning for PPE needs for emergency response workers, employers should consider the full range of a particular hazard that a worker may experience. For example, employers should consider respirator cartridges suitable for both chemical and particulate exposures even if workers may only need protection from particulates most of the time.

Different types and levels of PPE may be needed depending on the specific hazard(s) present. In a radiation emergency, the goal of PPE is to prevent contamination of the worker with radioactive material. PPE also may be needed to protect workers from other hazards, such as electric shock hazards or exposures to hazardous substances that may be encountered during emergency response operations.

The following are some of the important steps employers with emergency response workers need to take with respect to PPE:

• Conduct a hazard assessment to determine what safety and health hazards workers may encounter.
• Follow the hierarchy of controls—including elimination/substitution and engineering, work practice, and administrative controls—before relying on PPE to protect workers.
• Determine what PPE workers need.
• Provide the proper PPE to workers.
• Train workers in the proper use of PPE, including how to put it on and take it off correctly, and how to clean, maintain, and dispose of it after or between uses.
• Ensure that PPE is used properly and whenever necessary.
• Provide medical exams and/or fit testing, as required by OSHA standards, prior to using certain types of PPE (e.g., respirators).
• Regularly review and update the PPE program as hazards change.

If their workers will be involved in emergency response operations during or after a radiation emergency, it is crucial that employers plan in advance of an emergency for the PPE needs of their workers. During and immediately after an emergency, there may be limited supplies of PPE available for purchase, so it is important to have the necessary PPE on hand in advance. In an emergency situation, employers may have little or no time to train or fit workers (e.g., perform fit testing for respirators) for certain types of equipment, so it can be critical to have those tasks complete before an emergency occurs.

OSHA's Getting Started – PPE for Emergency Response and Recovery Workers and HAZWOPER Safety and Health Topics pages provide information on PPE selection and use during emergency response operations.

OSHA and the National Institute for Occupational Safety and Health (NIOSH) have developed guidance on CBRN PPE selection. The guidance includes PPE recommendations for emergency responders who may be exposed to CBRN materials and related emergencies.

The primary consideration in selecting appropriate PPE is the level of contamination that workers may face in the area where they are performing response operations. PPE does not protect workers against direct radiation exposure; but it can help protect them from radiation contamination or intake (i.e., inhalation, ingestion, etc.).

• In the case of a RED, PPE is unlikely to protect emergency response workers from radiation. Contamination is usually not associated with a RED; only direct radiation exposure.
• In the case of a RDD or other small release, radiation and radioactive contamination may be isolated in a small area, perhaps up to several city blocks. PPE can help protect workers from direct contamination, but they may still be exposed to radiation from radioactive contamination of the environment.
• With larger events, such as a nuclear facility disaster or a nuclear detonation (e.g., IND or other nuclear weapon), elevated and dangerous radiation hazards may span a significantly larger geographical area, including a dangerous fallout zone downwind from a nuclear event and other areas many miles outside of the fallout zone where radiation levels are elevated. PPE can help protect workers from direct contamination, but they are still likely to be exposed to radiation from radioactive fallout, environmental contamination resulting from fallout, and any prompt radiation (i.e., radiation resulting directly) from the detonation.

The following interagency guidance documents provide additional information on these delineations:

• Planning Guidance for Response to a Nuclear Detonation. Interagency document.
• Health and Safety Planning Guide for Planners, Safety Officers and Supervisors for Protecting Responders Following a Nuclear Detonation. Interagency document.

In the dangerous fallout zone up to 10–20 miles from the site of a nuclear detonation, radiation levels may be immediately dangerous to life and health. In areas with such high radiation levels, PPE may offer little to no protection to emergency response workers against most types of radiation. Response activities should be delayed until entry into these areas is not immediately dangerous. Once radiation levels are not immediately dangerous to workers, PPE selection for any emergency response operations should be based on a hazard assessment. The assessment may need to consider exposures to more than just radiological hazards.

It is possible that elevated radiation levels may occur many miles from the site of a nuclear detonation and pose the risk of radiation exposure from environmental, victims (including fatalities and survivors), and equipment contamination. Whether PPE is required when working such distances from the detonation site, and what type of PPE should be used depends on surface and airborne contamination levels.

During a radiation emergency, the Incident Commander or Unified Command staff should establish and communicate boundaries, with a goal of keeping areas beyond such boundaries from becoming contaminated. Nevertheless, low levels of contamination may occur due to response workers and equipment moving between zones, contaminated victims self-evacuating from the contaminated area or fallout zones, and atmospheric conditions (e.g. wind speed and direction, rain) changing over time.

Response workers outside of the contaminated areas or fallout zones, but who are anticipated to have contact with contaminated victims, should use PPE consistent with the hazard assessment. This may include emergency medical service (EMS) workers and other responders, as well as healthcare workers receiving and treating patients from the site of a radiation emergency, contaminated surrounding areas, or fallout zones. OSHA's Best Practices for Protecting EMS Responders during Treatment and Transport of Victims of Hazardous Substance Releases and Best Practices for Hospital-Based First Receivers of Victims from Mass Casualty Incidents Involving the Release of Hazardous Substances publications provide more information for these types of workers.

Though the OSHA/NIOSH CBRN PPE Selection Matrix for Emergency Responders recommends using Self-Contained Breathing Apparatus (SCBAs), responders may be adequately protected by at least a full-face, air-purifying respirator with a P-100 or high-efficiency particulate arrestance (HEPA) filter approved by NIOSH for CBRN materials, as determined by the hazard assessment. Use respiratory protection specifically approved by NIOSH to meet minimum requirements for effectiveness during entry into CBRN atmospheres not immediately dangerous to life or health (IDLH). It should be noted that these recommendations for respiratory protection are designed only for protection against inhalation of radioactive particles and do not consider protection that may be necessary for other contaminants, such as chemical or biological agents. Effective respiratory protection relies upon good fit testing, medical exams, and training for workers and selection of appropriate cartridges for air-purifying respirators (e.g., purple/magenta for radioactive air contaminants).

Surgical masks are not designed or approved for protection against particles, including radioactive air contaminants, or chemical vapors.
OSHA's Respiratory Protection eTool provides more information about various types of air-purifying respirators and other respiratory protection equipment.

Other agency guidance on respiratory protection from internal radiation doses due to inhalation or ingestion of radioactive particles include:

• NIOSH's Guidance on Emergency Responder Personal Protective Equipment (PPE) for Response to CBRN Terrorism Incidents.
• NIOSH's Chemical, Biological, Radiological, and Nuclear (CBRN) Respiratory Protection Handbook.
• Department of Energy's Federal Radiological Monitoring and Assessment Center Health and Safety Manual.
• International Atomic Energy Agency's (IAEA's) Practical Radiation Technical Manual on Personal Protective Equipment.

PPE Requirements in OSHA Standards

Emergency responses to hazardous substance releases, including radiation, are covered under OSHA's HAZWOPER standards. The HAZWOPER standards include requirements for PPE selection and use, based on employer assessment of hazards.

The PPE recommended in the OSHA/NIOSH PPE Selection Matrix for Emergency Responders was generally selected to meet the requirements of the HAZWOPER and PPE standards. The OSHA PPE standards include specific requirements addressing eye, face, hand, foot, and respiratory protection, as well as fall protection. In order to use the guidance effectively, an employer must assess the exposure risk associated with a hazardous substance release to the emergency response workers and base PPE selection on that risk. Construction employers preparing for response operations should also keep in mind additional requirements of the Personal Protective and Life Saving Equipment standards (29 CFR 1926 Subpart E) for their industry, which may require safety belts, lifelines, lanyards, safety nets, and personal flotation devices.

When selecting respirators, always follow the requirements of OSHA's Respiratory Protection standards (29 CFR 1910.134 in general industry, shipyard employment, marine terminals, and longshoring; and 29 CFR 1926.103 in construction). Note, however, that OSHA does not allow for consideration of the assigned protection factor (APF) when comparing to the maximum permissible concentration of airborne radioactive contaminants (i.e., employers may not use APF values to estimate a reduction in airborne radioactive material provided by a respirator). In general, the APF of a respirator selected to protect workers against airborne radioactive contaminants should be as high as practical to minimize internal dose and health effects of receiving the dose. This is an important consideration when selecting respirators to maintain worker doses below occupational exposure limits, including OSHA's dose limits. As mentioned on the Introduction page and discussed in the Dose Limits for Emergency Response Situations section of the Response page, OSHA's Ionizing Radiation standard has not been revised from its original 1971 version; the U.S. Department of Energy and the U.S. Nuclear Regulatory Commission both have updated standards based on more recent radiation protection guidance, such as that of the International Commission on Radiological Protection. Employers may follow the updated dose limits in the NRC regulations at 10 CFR Part 20 when they are more protective than the older limits in the OSHA standards. Additionally, the NRC regulations allow consideration of the APF when computing potential worker dose based on derived air concentration (DAC) from sampling data and planned exposure time. OSHA considers it a de minimis condition when an employer has implemented a measure different from one specified in an OSHA standard, but that difference has no direct or immediate relationship to safety and health.

Train

Training for Emergency Response Workers

In accordance with OSHA's HAZWOPER standards (29 CFR 1910.120 in general industry and 29 CFR 1926.65 in construction), all responders who enter a hazardous area, including an area where radiological material is present, must receive certain training. Although  federal OSHA does not cover state and local government workers, emergency responders employed by state or local governments are covered either by OSHA-approved State Plans (which must have standards that are at least as effective as the federal OSHA standards) or by the EPA's HAZWOPER standard, 40 CFR Part 311. (The EPA standard adopts OSHA's HAZWOPER standard by reference.)

OSHA's HAZWOPER Safety and Health Topics page explains requirements of the OSHA HAZWOPER standard, including required worker training.

For personnel responding to incidents involving hazardous materials and weapons of mass destruction (WMDs), DHS adopted National Fire Protection Association (NFPA) standards. NFPA 472, Standard for Competence of Responders to Hazardous Materials/Weapons of Mass Destruction Incidents, describes competency levels for personnel responding to such incidents, and NFPA 473, Standard for Competencies for EMS Personnel Responding to Hazardous Materials/Weapons of Mass Destruction Incidents, addresses basic life support and advanced life support personnel in the pre-hospital setting. Workers need proper training to be able to demonstrate these competencies.

For hospital and triage medical personnel, OSHA's Best Practices for Hospital-Based First Receivers of Victims from Mass Casualty Incidents Involving the Release of Hazardous Substances discusses PPE, training, and other healthcare worker needs.

Exercise

Exercising preparedness and response plans

Whether you are a worker or an employer with an emergency response function, or if you own, manage or work in any other type of business or jobsite, conducting activities to practice your emergency plans is an important step in ensuring that everyone involved knows what to do in the event of an actual emergency. Exercising (i.e. testing) your emergency plans can help save lives and prevent injuries and illnesses in the event of a radiation emergency. You can exercise emergency preparedness plans in several ways:

• Orientations introduce new workers and supervisors to an organization's emergency response plans. Depending on a worker's job function, orientation may entail a simple overview of shelter-in-place and evacuation plans. If a worker's job duties involve emergency response, orientation could include extensive training on preparedness, response, and recovery aspects of a particular job. Orientations allow workers to ask questions about their roles and responsibilities during an emergency.
• Drills are a coordinated, supervised activity normally used to exercise a single specific operation or function in a single workplace. They are also used to provide training with new equipment, to develop new policies or procedures, or to practice and maintain current skills. Examples include conducting a shelter-in-place or evacuation drill in a workplace.

Employers and workers with emergency response functions, and some employers and workers who support such operations, should consider further steps for exercising preparedness and response plans¹:

• Tabletop exercises simulate an emergency situation in an informal, stress-free environment. They are designed to elicit constructive discussion as participants examine and resolve problems based on existing plans.
• Functional exercises are fully simulated and interactive. They validate the capability of an agency or organization to respond to a simulated emergency testing one or more functions of the plans. They focus on policies, procedures, roles, and responsibilities of single or multiple emergency functions before, during, or after any emergency event.
• Full-scale exercises simulate actual emergency conditions. They are designed to evaluate operational capabilities of emergency plans in a real-life environment. Mobilizing an organization's emergency personnel, equipment, and resources can help accomplish intended realism in a full-scale exercise.