______________________________
SECRETARY of LABOR, UNITED, )
STATES DEPARTMENT OF LABOR, )
)
Complainant, ) Docket Nos. 90-1553
) 90-2587
)
v. )
)
UNITED PARCEL SERVICE, INC., )
)
Respondent. ) February 26, 1992
______________________________)
PARTIAL STIPULATION AND SETTLEMENT AGREEMENT
Complainant and Respondent have reached a partial settlement of the above-captioned matter presently pending before the Occupational Safety and Health Review Commission. The parties hereby agree as follows:
A. The Occupational Safety and Health review Commission (hereafter the "Commission") has jurisdiction over this matter pursuant to Section 10(c) of the Occupational Safety and Health Act of 1970 (84 Stat. 1590; 29 U.S.C. et seq., hereinafter the "Act").
B. Respondent, United Parcel Service, Inc., is a corporation with its principal place of business located at 643 West 43rd Street, New York, New York. At all times material to this proceeding Respondent has been engaged in the business of package delivery. During the course of its business, its employees perform various tasks in the nature of package delivery. During the course of its business, Respondent uses materials and equipment which it receives from places located outside the state of New York. Respondent, as a result of these aforesaid activities, is an employer engaged in a business affecting commerce as defined in Sections 3(3) and 3(5) of the Act, and has employees as defined by Section 3(6) of the Act, and is subject to the requirements of the Act.
C. As a result of inspections (Nos. 018236414 and 101538866) conducted by OSHA of Respondent's facilities located in Uniondale, New York and Watertown, Connecticut, citations alleging, inter alia, violations of the recordkeeping standards at 29 CFR 1904.2(a), 29 CFR 1904.2(b)(2), and 29 CFR 1904.8 were issued to Respondent on August 17, 1990 and Notifications of proposed civil penalties in connection with these alleged violations were also issued to Respondent on the previously mentioned dates.
D. Respondent disagreed with the citations and notifications of proposed penalties and filed timely notices of contest with the Secretary of Labor, which were transmitted to the Commission pursuant to Section 10(c) of the Act.
A. This Stipulation and Settlement Agreement (hereinafter the "Agreement") is intended to settle all outstanding OSHA citations issued under 29 CFR 1904 to Respondent at these two facilities as a result of the aforementioned inspections. The Agreement also provides for action by Respondent concerning its OSHA recordkeeping practices at all UPS facilities, including those noted above.
B. The parties to this Agreement recognize that certain of the covered facilities are located in states which have assumed authority for the enforcement of OSHA standards pursuant to Section 18 of the Act. Those states are encouraged to honor or to agree to the terms of this Agreement.
A. Respondent agrees to withdraw its Notice of Contest to the citations and notification of proposed penalties as such may have been amended by this Agreement and to pay the U.S. Department of Labor the amount of $465,900.00 in full settlement of the penalties proposed in the two notifications of proposed penalty. Respondent agrees to provide payment of this amount to OSHA within thirty days after this Agreement becomes a final order of the Commission. The Settlement amount shall be paid in two checks as follows:
* $450,000 to cover alleged violations of 29 CFR 1904.2(a) except Item No. 122 in the Watertown, Connecticut citation;
* $15,900 to cover alleged violations of 29 CFR 1904.2(a) (Item No. 122 of the Watertown, Connecticut citation); 29 CFR 1904.2(b)(2) and 29 CFR 1904.8.
B. Complainant agrees that this payment from Respondent satisfies the proposed penalties for the citations issued under 29 CFR 1904 to Respondent issued as a result of these inspections and this Agreement amends the notifications of proposed penalties to reduce the total penalty for the recordkeeping citations to $465,900.
A. Within 60 days after execution of this Agreement, Respondent agrees that it will have fully implemented its redesign of its injury and illness recordkeeping system as follows:
The company will implement a new computer recordkeeping system which will permit records to be identified on an establishment-by-establishment basis. In addition, the new computer system will insure that appropriate definitions for recordkeeping purposes, of restricted duty and lost work days cases are utilized.
B. Six months after the execution of this Agreement by all parties hereto, Respondent will have implemented at all its facilities a program to examine relevant records in its possession of all employees to ensure that the required records are in compliance with the regulations at 29 CFR Part 1904, the instructions on OSHA Form 200 Log, and the Revised Recordkeeping Guidelines issued by the United States Department of Labor, Bureau of Labor Statistics in april 1986 (the "1986 Guidelines"). this review shall include: (1) entry on the 200 log of the injuries and illnesses cited by OSHA at the cited facilities; and (2) entry of all other instances that were properly recordable from January 1, 1989 to the date of execution of this Agreement.
C. OSHA agrees that additions and modifications made to Respondent's records pursuant to section B above shall hereafter not be subject to citation by OSHA.
D. Respondent agrees to hereafter maintain at its facilities its occupational injury and illness records in accordance with the regulations of 29 CFR Part 1904, the OSHA 200 log and its instructions and the 1986 BLS Guidelines, as the same may be amended from time to time.
E. Six months after the execution of this Agreement by all parties hereto, Respondent shall have conducted training in OSHA injury and illness recordkeeping requirements for those of its employees having responsibility for recordkeeping at its facilities. The training program will be conducted by individuals knowledgeable in the recordkeeping requirements. The training program will cover the regulations of 29 CFR Part 1904, the instruction on OSHA Form 200 Log and OSHA 101 or their acceptable equivalents, the 1986 BLS Guidelines, as they may from time to time be amended, as well as the provisions of this Agreement. Thereafter, newly appointed recordkeepers shall be given similar training.
F. Respondent will implement the following procedures at its facilities. Pending an investigation and final determination, if a case otherwise meets the requirements for recording, Respondent shall record injuries and illnesses which (1) involve filed workers' compensation claims, (2) involve sickness or accident claims for which occupational causation is claimed, or (3) involve medical restrictions or job transfers. In addition, before concluding that a case will not be recorded, Respondent shall ask the employee whether the condition was caused or aggravated by work. If the employee answers in the affirmative and the case otherwise meets the recording criteria, the case will be entered on the log pending an investigations and final determination of causation.
If a case is removed from the log as a result of the investigation, Respondent will maintain a record of the reasons for removal and make it available to the appropriate OSHA Area Director upon request.
G. Within seven months of the execution of this Agreement by all parties hereto, Respondent shall provide OSHA-OFP (in Washington, D.C.) with a report certifying that the actions required herein have been implemented. the report will outline all programmatic actions and changes made by Respondent to implement this Agreement and it will include copies of all written and other materials utilized by Respondent for training, instruction, or guidance to recordkeepers.
Respondent agrees to require no warrants for entry by the Secretary's representative or for access to any documents related to compliance with this Agreement. Respondent agrees to permit reasonable inspections by representatives of the Secretary to ensure compliance with the terms of this Agreement.
The parties agree that the Secretary is entitled to seek and obtain an order under Section 11(b) of the Act, 29 U.S.C. Sec, 660(b), in an appropriate United States court of appeals to enforce the terms of this Agreement.
Each party agrees to bear its own attorney's fees and costs incurred as a result of this action and Agreement.
For purposes of service and notice, Respondent certifies that a copy of this Agreement has been served on the representative of affected employees in the facilities cited by OSHA pursuant to Commission Rules of Procedure 29 CFR 2200.7 and .100. Respondent also certifies that copies of the Agreement have been posted at two cited facilities in accordance with 29 CFR 2200.7(g).
None of the foregoing agreements, statements, stipulations, or actions taken by the Respondent, its officers, agents or employees, (hereinafter referred to collectively as "the respondent"), shall be deemed an admission by the respondent of any violation of the Occupational Safety and Health Act of 1970 (29 U.S.C. ? 651 et seq.) or standards or regulations promulgated thereunder, the allegations contained in the citations, the Notification of Penalties or the Complaint; and by entering into this Agreement, Respondent does not admit that the alleged violations were the cause proximate or otherwise of any accident or damages which may have occurred. The agreements, statements, stipulations, findings (if any) and actions taken hereunder are made for the purpose of settling this matter economically and amicably, and they shall not be used for any purpose except proceedings brought directly under the provisions of the Occupational Safety and Health Act by the Secretary.
WHEREFORE, the parties agree that under the above-noted conditions, the recordkeeping portions of the above-noted cases presently pending before the commission are hereby settled. All other matters pending before the Commission under these docket numbers remain as alleged by the Secretary and contested by Respondent.
FOR COMPLAINANT: FOR RESPONDENT:
_________________________ _________________________
2/27/92 3-6-92
Date Date
_________________________
2/27/92
____________________________
LYNN MARTIN, ) OSHRC DOCKET Nos.:
SECRETARY of LABOR, UNITED, )
STATES DEPARTMENT OF LABOR, ) 91-0721 90-1553
) 92-0300 91-1170
Complainant, ) 91-2587 90-2673
) 92-3173 90-2933
v. ) 91-2620 91-2706
) 91-2521 92-0076
UNITED PARCEL SERVICE, INC.,)
and its Successors )
)
Respondent. ) FEBRUARY 27, 1992
____________________________)
Complainant, Lynn Martin, Secretary of Labor, United States Department of Labor, and Respondent, United Parcel Service and its successors, have reached a settlement of issues relating to citations issued under the standard at 29 CFR ? 1910.120 in the above-captioned matters presently pending before the Occupational Safety and Health Review Commission. In addition to providing the basis for settlement of abatement issues in specific pending cases, the parties intend this Agreement to provide an effective methodology for UPS to approach emergency response in its facilities and operations covered by the Occupational Safety and Health Act of 1970 (29 U.S.C. 652 et seq., hereinafter the "Act"). The aforementioned parties hereby agree as follows:
A. The Occupational Safety and Health Review Commission (hereinafter the "Commission") has jurisdiction of these matters pursuant to Section 10(c) of the Act.
B. Respondent, United Parcel Service, Inc. ("UPS"), is a corporation with its principal place of business located at 643 West 43rd Street, New York, New York and 2600 Warenville Road, Room 210, Downers Grove, Illinois. It has been at all times material to this proceeding engaged in the business of package delivery. During the course of its business, its employees perform various tasks in the nature of package delivery. During the course of its business, Respondent transports packages in interstate commerce and uses materials and equipment which it receives from places located outside the state of New York. Respondent, as a result of these aforesaid activities, is an employer engaged in a business affecting commerce as defined in Sections 3(3) and 3(5) of the Act, and has employees as defined by Section 3(6) of the Act, and is subject to the requirements of the Act.
C. As a result of inspections of various UPS facilities and operations as set forth in cover agreements submitted herewith in settlement of specific cases pending before the Occupational Safety and Health review Commission, Complainant issued to Respondent citations pursuant to Sections 9 and 10 of the Act. The citations related to this Agreement pertain to violations of the Secretary's standard at 29 CFR ? 1910.120. Notifications of proposed penalties were also issued in each of the aforementioned cases.
D. Respondent disagreed with the citations and notifications of proposed penalties and filed notices of contest to all citations and proposed penalties. The contests were duly transmitted to the Commission. The authorized employee representative, the International Brotherhood of Teamsters (IBT), has elected party status in some of these proceedings.
A. Respondent agrees to pay fifty percent (50%) of the proposed penalties for pending citations issued for alleged violations of 29 CFR ?1910.120. Complainant agrees to accept this payment as full and complete satisfaction of all penalties in the pending cases.
B. Respondent agrees to withdraw its notices of contest as they relate to citations and proposed penalties issued for alleged violations of 29 CFR ?1910.120.
C. Respondent agrees to abate the conditions noted in the citations relating to the standard at 29 CFR ?1910.120 in these cases by implementing, in accordance with the further provisions of this Agreement at section IV below.
D. The parties agree that this Agreement, including the documents referred to in Section IV below, shall become a final order of the Commission. Included with this Agreement is a draft Order approving this settlement. The parties hereby consent to the entry of the order as the final order so that the litigation of these matters may be concluded.
As abatement for the cited conditions, UPS agrees to implement the following in all its facilities covered by the Act:
A. UPS has developed the following documents to comply with 29 CFR ? 1910.120: "UPS Damaged Package Response Procedure" and a Training Outline for Designated Persons. In addition, UPS has developed emergency evacuation plans. These documents were produced as the result of discussions and negotiations by the parties involved herein, and are hereby incorporated by reference into the terms of this Agreement to set forth the basis of agreed abatement procedures. The procedures shall be provided to each covered UPS establishment to form the framework of a hazardous material handling program. Each establishment, as part of the implementation of this Agreement and UPS program, shall establish in writing and implement necessary specific procedures, e.g., evacuation plans, identification of and coordination with outside emergency entities and agencies, lines of communication and authority, and identification of appropriate personnel both by position and name. In response to a request from a Union Business Agent to a UPS District Labor Manager, the Company, through the District Labor Manager, will provide copies of the above-referenced materials to the local Business Agent for the International Brotherhood of Teamsters (IBT).
B. All necessary training of personnel and full implementation of the UPS program shall occur as soon as possible but no later than nine (9) months after the date of execution of this Agreement by the parties.
C. It shall be the responsibility of the UPS corporate headquarters to assure and direct the implementation of this Agreement and the UPS procedures at the covered facilities. D. Reports 1. Six months after the date of execution of this Agreement by the parties, UPS corporate headquarters will provide OSHA's National Office with a report detailing progress on implementation of this Agreement. Six months thereafter, UPS will provide to OSHA's National Office a report detailing the final implementation of the agreement. Copies of all reports sent to the OSHA National Office shall also be sent to the Safety and Health Director for International Brotherhood of Teamsters.
E. Within thirty days after execution of this Agreement by the parties, UPS agrees to provide to the Secretary a complete list of all UPS' establishments covered by the Act.
2.a Within twelve months after execution of this Agreement by the parties, UPS shall provide to each OSHA Area Office a report detailing the manner in which this Agreement and the UPS procedures were implemented within the relevant OSHA area. This report shall include specific evaluation plans, identification and methods of coordination with outside emergency responders, internal lines of communication and authority, and identification of designated responsible personnel by position and name. A copy of these materials shall be provided to the IBT Director of Safety and Health. OSHA agrees to provide UPS with a list OSHA Area Offices and the specific geographical areas they serve.
2.b Each UPS establishment shall keep records of all responses to damaged packages involving hazardous materials. The records shall identify the specifics of each event including the location, date, time, and nature of the event, the response by UPS and/or outside responder, and an evaluation of the adequacy of the actual responsive action taken. Fifteen (15) months after execution of this Agreement by the parties, copies of the reports shall be submitted to the appropriate OSHA Area Office. In response to a request from a Union Business Agent to a UPS District Labor Manager, the Company, through the District Labor Manager, shall provide copies of these reports to the Union Business Agent.
A. The parties shall meet on a semi-annual basis to discuss UPS' progress in implementing this Agreement. The contact persons for initiation of these meetings shall be the Deputy Director for the Office of Field Programs for OSHA, and appropriate individuals designated by UPS and the International Brotherhood of Teamsters.
B. Within thirty days of the execution of this Agreement by all parties hereto, UPS shall provide the Secretary with the address of the District Safety Manager for each of UPS' seventy-seven districts nationwide.
UPS agrees to allow OSHA access to the facilities and appropriate documents to determine compliance with this Agreement and to conduct compliance inspections under the Act. During the term of this Agreement OSHA agrees that, assuming good faith implementation of this Agreement by UPS, it shall not conduct general schedule inspections as to compliance with 29 CFR ?1910.120 covered by this Agreement, except that OSHA may conduct monitoring inspections to determine compliance with this Agreement and all other types of inspections permitted under the Act.
If, during the course of any inspection conducted by OSHA during the implementation period of this Agreement set forth above, OSHA detects a situation or condition which would ordinarily result in a citation, the Secretary will determine whether the condition is being or will be addressed as part of the facility's activities pursuant to this Agreement. If the condition is reasonably being or will be addressed pursuant to this Agreement, no citation shall be issued. This provision shall not be applicable after nine (9) months after execution of this Agreement by the parties.
OSHA retains the right to issue related citations to any facility in the event UPS is determined by OSHA not to be implementing this Agreement in good faith.
This Agreement shall continue in effect for a period of twenty-one (21) months after execution of the Agreement by the parties. Thereafter, UPS shall continue to utilize the program herein incorporated by reference or an equivalent.
The parties recognize that certain of the establishments covered by this Agreement are located in states which have assumed authority for the enforcement of OSHA standards pursuant to section 18 of the Act. the states are encouraged to honor or to agree to the terms of this Agreement.
None of the foregoing agreements, statements, stipulations, or actions taken by the Respondent, UPS, its officers, agents or employees, (hereinafter referred to collectively as "the Respondent"), shall be deemed an admission by Respondent of any violation of the Act or standards or regulations promulgated thereunder, the allegations contained in the citations, the notification of penalties or the complaints; and by entering into this Agreement, Respondent does not admit that the alleged violations were the cause proximate or otherwise of any accident or damages which may have occurred. the agreements, statements, stipulations, findings (if any) and action taken hereunder are made for the purpose of settling this matter economically and amicably, and they shall not be used for any purpose except for proceedings brought directly under the provisions of the Act by the Secretary.
The parties agree that the Secretary is entitled to seek and obtain an order under Section 11(b) of the Act, 29 U.S.C. Sec. 660(b), in an appropriate United States Court of Appeals to enforce the terms of this Agreement.
UPS agrees to post a copy of this Agreement in a prominent place at each establishment covered by the pending citations for a period of thirty days. In additions, UPS agrees to provide a copy of the agreement to the Safety and Health Director of the International Brotherhood of Teamsters.
A. Each party agrees to bear its own fees and other expenses incurred by such party in connection with any stage of the proceedings in all pending cases and the negotiation of this Agreement.
FOR COMPLAINANT: FOR RESPONDENT:
____________________________ ___________________________
________________ 2/26/92
Date Date
_____________________________
2/27/92
FOR INTERNATIONAL BROTHERHOOD OF TEAMSTERS:
_______________________________
_________________
Date
U P S
DAMAGED PACKAGE
RESPONSE PROCEDURE
TABLE OF CONTENTS
SUBJECT SECTION #
Damaged package response procedure 1
Decision tree/response sheets 2
Response equipment 3
Training outline for designated persons 4
I. INTRODUCTION
UPS has developed the following procedure to be used whenever a damaged package is encountered. Damaged packages may contain hazardous materials which present a danger to UPS employees. This procedure outlines the appropriate steps to be taken by an employee if they encounter any leaking package. The type of material leaking from the package as well as the role the employee will play in the cleanup of the material determines the actions they will take and the associated training they will receive.
This procedure supplements, and does not replace, any other applicable UPS procedures, which must be followed in addition to the steps outlined here. The objectives of this procedure are to provide uniform procedures for responding to damaged package incidents. To assist in meeting this objective, the substances, equipment, and methods to be applied in the process are standardized.
II. OVERVIEW OF PROCEDURE
The role the employee will play in dealing with a leak determines what level of training will be given to the employee. Most UPS employees will do nothing in response to a hazardous spill other than to notify their supervisors of the problem. Only specially trained and equipped employees will take specific steps to properly remove the package from the work area and, if necessary, to properly cleanup spilled material. Outside contractors or fire departments may be called in to deal with specific situations outside of the capabilities of UPS designated persons. In UPS facilities without specially trained employees no one will clean up leaks or spills involving hazardous materials or materials which cannot be identified as non-hazardous. Such work will be done by outside contractors or local fire departments, who will be called in as needed.
Employees involved in a damage package response would typically be as follows:
* Package handlers and Drivers who perform loading, unloading, sorting and delivery work.
* Managers and Supervisors of Package Handlers (may be designated to respond to hazardous spills).
* Employees in the Package or Customer Service areas (may be designated to respond to hazardous spills).
III. PACKAGE HANDLERS
Personnel that handle packages may discover a damaged package that is releasing a hazardous substance. These personnel are only to notify their supervisor. They are not to contain hazardous material spills themselves. Package handlers, drivers or other UPS employees engaged in accepting, loading, unloading, sorting and distributing packages as well as supervisors who are not designated to respond to spills shall follow these steps:
A. For damaged packages on belts, in a building, or in a vehicle being loaded or unloaded, the following actions should be taken:
1. Determine whether or not the package contains a hazardous material. This can be done by: (These items are examples of the ways in which a package could be identified as hazardous. Employees are not to deliberately expose any part of their body, e.g. skin, nose, throat, mouth or eyes, to unknown leaking substances in order to determine the nature of the substance. Interaction with unknown substances should be limited to passive observation of the leaking substance and the package.)
a. Reading the label on the package
* If a package carries a DOT label, making or five-part form, it should be regarded as hazardous.
* If a package carries any other warnings as to dangers associated with its contents, the package should be regarded as hazardous.
b. Observing whether the spilled substance is reacting in any way.
* If a package is generating smoke or visible fumes, it should be regarded as hazardous.
c. Observing whether the spilled substance is giving off fumes which are irritating to the skin, nose, throat, mouth or eyes. If this occurs, the package should be regarded as hazardous.
d. If a package carries no labels or indications as to its contents, it should be regarded as hazardous even though it is not generating smoke, visible fumes, or irritating fumes.
2. If it is determined that the package contains hazardous material clear the immediate area. DO NOT TOUCH THE PACKAGE. After leaving the area, notify the supervisor or, if the supervisor is not available, the Package Service Center. The supervisor or Package Service Center will contact the appropriate person to coordinate the response.
3. If it is determined that the package contains non-hazardous material, allow the package to remain on the belt until it reaches an appropriate point. While wearing protective gloves, place the package in a spill tub and remove it to an area that will not interfere with work operations. Contact the supervisor immediately so that other appropriate measures can be taken to deal with the package.
B. For damaged packages in delivery vehicles on route.
1. Determine whether or not the package contains a hazardous material (see Paragraph III-A-1).
2. If it is determined that the package contains a hazardous material, the following steps should be taken:
a. Close the bulkhead door to prevent fumes from entering the driver's compartment.
b. Park the vehicle in a location which does not present a threat to road traffic.
c. Secure the vehicle so that it cannot be entered except by authorized personnel.
d. Call supervisor in order to report problem. The supervisor will contact the appropriate person to deal with the package from that point forward.
e. DO NOT TOUCH THE PACKAGE.
3. If it is determined that the package does not contain a hazardous material, the following steps should be taken:
a. Segregate the package from others to prevent damage to the load.
b. The driver should not attempt to clean up package spills.
c. Contact your supervisor who, in turn, will provide instructions on how to proceed.
C. If a Supervisor encounters a release, the supervisor should do the following:
1. Determine whether or not the package contains a hazardous material (see Paragraph III-A-1).
2. If it is determined that the package contains a hazardous material, stop the belt and insure that the area has been cleared of all personnel. If the supervisor is not trained to be a designated person to respond to a hazardous leak, he/she should contact an appropriate designated supervisor to take charge of the situation.
3. If it is determined that the package does not contain a hazardous material, the supervisor should insure that the package is properly placed in a spill tub and should then notify the re-wrap area that there is a spill tub with a damaged package that needs attention.
IV. PERSONS DESIGNATED TO RESPOND TO HAZARDOUS SPILLS
A. In Hubs, persons so designated will be responsible for handling hazardous material spills to the extent that such incidents are dealt with by UPS personnel. Their work will primarily involve the placement of a package in a spill tub and clean-up of relatively small amounts of spilled material.
When called to respond to a release from a package which contains a hazardous material, (see Paragraph III-A-1), the person designated to respond to a hazardous spill should take the following actions:
1. Make certain that the immediate area remains clear, taking appropriate steps to assure proper control of access to the area. This can be done by:
a. Cordoning off the area.
b. Placing supervisors in key locations to prevent employees from returning to the area.
c. Utilizing available public address systems to inform people to stay away from the area.
2. Obtain and wear appropriate personal protective equipment, e.g. protective gloves, apron, goggles, boots, and, if necessary, a respirator (SCBA). A respirator shall be worn if:
a. The package is generating smoke or visible fumes.
b. The package is giving off fumes which irritate the noise, throat, mouth or eyes.
c. The package is giving off a strong odor.
3. Identify the material spilled. This can be done by:
a. Reading the package labels.
b. Calling the shipper (see emergency contact numbers) on five-part form or certification.
c. Calling CHEMTREC.
d. Consulting MSDS sheets.
e. For unlabelled packages; first determine if the material is appropriate for clean-up by UPS personnel (see Paragraph 4 below), only then should the work be performed pursuant to the procedures outlined in the Unlabelled Package Procedure in Section 2.
4. Determine whether the material can be cleaned up; by UPS personnel. In making this determination, apply the decision-tree which is attached as an Appendix to this procedure. In the following situations, the services of an outside contractor or fire department will be utilized to handle the situation:
a. Spills involving chemical fumes which produce skin irritation on contact with the body, including spills involving corrosives which are giving off visible fumes.
b. Spills involving explosive chemicals.
c. Spills involving chemicals which are DOT inhalation hazards.
d. Spills which, due to their volume, cannot be effectively absorbed or neutralized by available supplies at the UPS facility.
e. When outside contractors or the local Fire Department is called in to handle a spill, the danger area surrounding the leaking package must be evacuated.
5. If a spill is inside a vehicle located in or near a building, move the vehicle away from the building, if practicable and safe to do so.
6. If material is appropriate for clean-up by UPS personnel, (see Paragraph 4 above), the work should be performed pursuant to the chemical-specific procedures outlined in Section 2 and in any additional information obtained from the shipper or relevant MSDS sheets. ALWAYS WEAR REQUIRED PERSONAL PROTECTIVE EQUIPMENT.
B. In facilities other than Hubs, trained, designated persons will only be allowed to respond to spills of hazardous materials that do not require respiratory protective equipment. While these individuals will not clean up spills of hazardous materials requiring respiratory protection, they will receive the same training as all designated persons.
C. Designated persons in either Hubs or non-Hub facilities may wear negative pressure respirators in dealing with chemicals which give off unpleasant odors but are not regarded as hazardous.
D. All of the above activities shall involve an appropriately trained supervisor or manager who has been designated to respond to hazardous spills.
E. Ultimate responsibility for insuring compliance with the response procedures rests with the Center or Hub Manager. In most situations, a designated supervisor or manager from the package service area will be responsible for supervising the clean-up of a spill. Typically, clean-up activity will be performed by designated employees from the package service area. If such individuals will not be available, package handling employees will be designated for this work and appropriately trained. Each facility shall maintain a list of designated managers and employees.
F. The Center or Hub Manager shall be responsible for identifying the appropriate outside contractor or fire department to perform clean-up on an as-needed basis. The Center or Hub Manager shall insure that such outside contractor or fire department is contacted prior to any emergency in order to discuss conditions and procedures at the UPS facility. In the event of an incident requiring outside assistance, the Center Manager or the most senior designated manager shall be responsible for contacting the contractor or fire department and, if necessary, ordering an evacuation.
V. TRAINING
A. Training for Package Handlers, Package Service Center Personnel, and Other UPS Employees who assist in the acceptance, loading and unloading, sorting, and distribution of packages.
1. Objective
To train employees to respond safely to leaks of substances from damaged packages to protect their health and the environment.
Package handlers, package service center personnel, and otheremployees engaged in accepting, loading, unloading, sorting, or distributing packages must be trained to identify potential incidents. Their function is to summon assistance to respond to releases of hazardous materials, or releases of materials which cannot be identified as non-hazardous materials, or releases of materials which cannot be identified as non-hazardous without actually attempting to clean up the release. Because these employees will not be involved in clean-up activities and will evacuate the area, it is only necessary that the employees be able to identify potential hazards and take steps to notify supervision and evacuate the area.
2. Areas of Training.
a. An understanding of what hazardous materials are, and the risks associated with them in an emergency.
b. An understanding of the potential outcomes associated with an emergency when hazardous materials are present.
c. How to identify that a package is leaking.
d. How to identify package markings which indicate the presence of hazardous materials, (e.g., DOT symbols, five-part forms) as well as the physical signals that package contains hazardous materials (e.g., smoke, a heavy odor).
e. The understanding of their role in the UPS response plan and specific actions as outlined on pages 2 through 4.
f. The ability to recognize the need for additional resources and the method to notify supervision of these needs.
3. As part of their orientation and other UPS training, these employees will have previously been trained in the following:
a. Where to obtain necessary supplies, including smalls bags, rain sheets and spill tubs for cleaning up non-hazardous spills.
b. How to escape from the work area and the building in an emergency.
c. The location of emergency first aid and wash stations and proper procedures for removing material from the skin.
d. The chain-of-command and how to contact a supervisor.
4. Length of Training
Approximately one hour, or sufficient experience to demonstrate competency in the above-described key areas. Annual refresher training will be provided, and certification of completed original and refresher training sessions will he placed in each employee's personnel file.
B. Training for persons designated to respond to spills.
1. Objective
To train the designated person to assess the situation and determine if the package may be cleaned up by them or if an outside contractor or fire department is required.
The designated person will be trained in safe methods for removing a leaking package and in cleaning up any spilled material.
2. Areas of Training
The designated person will undergo the same training as the package handler, and in addition, will receive training in the following areas.
a. Their role in an emergency.
b. Hazard and risk assessment technique, particularly in the assessment of inhalation and skin contact hands.
c. An understanding of basic hazardous material terms.
d. Means of determining the contents of packages including unmarked or packages not marked completely.
e. Handling of materials which cannot be identified.
f. Use of the UPS Guidelines to determine the proper methods, materials and PPE to be used to neutralize and contain released materials.
g. Proper methods for containing released material within the capabilities, resources and personal protective equipment available to them.
h. Proper labeling of contained material.
i. Use of appropriate protective equipment.
j. Decontamination of himself and the equipment used to contain the release.
k. Chain-of-command.
3. Length of Training
UPS has designed a special 12-hour program for this level of personnel. The contents of the 12-hour program are set forth in an attachment to this SUMMARY. Refresher training would also be provided on an annual basis.
Certain supervisors and managers will undergo the same training as described above. In addition, they will receive training in the following areas:
a. Their role in the Damaged Package Response Procedure.
b. When and how to contact outside contractors or local fire departments.
c. How to evacuate personnel from the immediate area.
d. Chain-of-command as it relates to them.
e. Decontamination of themselves, other UPS employees, equipment and work areas.
The length of training will he dependent on the size of the facility and prior training of the supervisors involved.
C. UPS Training Personnel
1. Objective
To provide training to UPS personnel who will train management, supervisors, designated personnel and other UPS employees in safe spill response procedures.
2. Areas of Training
Training Personnel will be trained pursuant to the Instruction Manual developed by UPS. Upon completion of the training, Trainers will be competent in all areas of the Damaged Package Response Procedure, as well as competent in the legal and regulatory scheme and the chemical properties which make the program necessary.
3. Length of Training
The training period for trainers will be 24 hours as indicated in the Trainers Instruction Manual.
VI. MEDICAL TREATMENT AND FIRST AID Medical assistance will be made available immediately to all personnel after any spill incident in the event of any symptoms or other reactions.
All designated persons will he required to undergo a complete physical examination before assuming duties under this program, annually thereafter, and within six months of terminating such duties.
VII. FOLLOW-UP AND REEVALUATION
UPS will monitor the effectiveness of the damaged package/spill response procedure in order to insure that the expectations for it are met. Any injuries or symptoms of discomfort or illness experienced by employees as a result of a damaged package or spill will be reported directly to the District Safety Manager, who, in consultation with the employees and supervisor who responded to the incident, will evaluate procedures in order to identify problem areas. If necessary, corrective action will be taken. In addition, on at least an annual basis, procedures will be reviewed by personnel within the company's safety and package service departments in order to determine whether the program needs to be revised.
ATTACHMENT: Flow Chart of "LEAKING PACKAGE DECISION TREE For
Designated Persons"
HAZARDS:
1. Contact causes burns to the eyes or skin 2. Fire may produce irritating or poisonous gases 3. May be Poisonous if inhaled or swallowed 4. Material is flammable 5. Note: The material may be toxic as well as flammable.
WEAR REQUIRED PROTECTIVE EQUIPMENT!i.e. goggles, gloves, apron and boots. Avoid any activity that will cause the material to become airborne. Use a clean shovel or dustpan to move the material into one or more plastic bags.
Keep all sources of ignition away from substance. Avoid creating friction or sparks.
Do not add any neutralizer to this material.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date___________________________________________________
DOT Name ___________________________________________________________
Hazardous Class ____________________________________________________
Sequence Number_____________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
FLAMMABLE LIQUIDS
HAZARDS:
1. Material is flammable 2. Skin contact may be poisonous 3. Contact may cause burns to the eyes or skin 4. Fire may produce irritating or poisonous gases 5. May be poisonous if inhaled or swallowed 6. Note: The material may be toxic as well & flammable.
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles, gloves, apron and boots. If there is a detectable odor, eye or nose irritation SCBA must be used. Have a fire extinguisher ready for immediate use by a second person wearing the same protective equipment in case of a fire. If there is noticeable skin irritation due to fumes or vapors, do not attempt to continue clean up, call for outside assistance.
Keep all sources of ignition away from substance. Avoid creating friction or sparks.
On all visible liquid spills, sprinkle Solusorb onto the material until the mixture appears dry.
Containerize the absorbed material into one or more plastic bags using a clean shovel or dust pan. Assure there is no visible liquid as a spark could cause a fire.
If the box is wet, but there is no noticeable liquid place the box into a plastic bag and that bag into another plastic bag.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date _____________________________________________________
DOT Name ______________________________________________________________
Hazardous Class _______________________________________________________
Sequence Number _______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
1. Skin contact poisonous 2. Contact may cause burns to the eyes or skin 3. Fire may produce irritating or poisonous gases 4. Poisonous if inhaled or swallowed 5. If producing visible fumes contact outside response team
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles, gloves, apron and boots. If there is a detectable odor, eye or nose irritation SCBA must be used. If there is noticeable skin irritation due to fumes or vapors, do not attempt to continue clean up, call for outside assistance.
On liquid acid, alkali, and corrosive spills, sprinkle sodium bicarbonate onto the material on any surfaces or in the recovery tub. A small amount of water should be carefully added if the mixture is too dry for the soda to dissolve. Sufficient moisture produces a fizzing reaction for acids; for alkalis, no audible reaction occurs. In either case, confirm neutralization by pH test, indicating acidity/alkalinity between six and nine:
* Tear off approximately five inches of pH indicator tape from the dispenser and immerse in the moist mixture. Match its color with the closest one in the color chart.
* If the color does not fall within the 6-9 range, mix in more sodium bicarbonate (and water, if needed) until the color of the tape falls in this range.
Containerize the absorbed material into one or more plastic bags. Place the completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date ____________________________________________________
DOT Name _____________________________________________________________
Hazardous Class ______________________________________________________
Sequence Number ______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
1. Contact may cause burns to the eyes or skin 2. May be poisonous if inhaled or swallowed 3. Material is not flammable, but causes other materials to burn 4. Note: The material may be toxic as well as an oxidizer.
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e.- goggles, gloves, apron and boots.
If there is a detectable odor, eye or nose irritation SCBA must be used. Have a fire extinguisher ready for immediate use by a second person wearing the same protective equipment in case of a fire.
Prevent liquid from coming into contact with other boxes or flammable materials.
On liquid spills, sprinkle Solusorb onto the material until the mixture appears dry.
Containerize the absorbed material into one or more plastic bags using a clean shovel or dust pan.
If the box is wet, but there is no noticeable liquid place the box into a plastic bag and that bag into another plastic bag.
Because this material may cause the packing box to ignite, move the material and packing box to an area that will be safe if it were to catch on fire.
Call the shipper to obtain specific neutralization instructions.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date ____________________________________________________
DOT Name _____________________________________________________________
Hazardous Class ______________________________________________________
Sequence Number ______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
ORM stands for Other Regulated Materials.
ORM A would have anesthetic, irritant, toxic or similar properties which would cause discomfort to passenger or crew on airplanes. Clean-up following the guideline for irritant materials.
ORM B is a material that could cause significant damage to a transport vehicle from leakage during shipping. Clean-up this material following the corrosive material guides for solids or liquids as appropriate.
ORM C is a material that is unsuitable for water shipment. Clean-up using the corrosive guides.
ORM D are consumer commodities that present a limited hazard during shipment. If the material is a liquid check the pH by tearing off approximately five inches of pH indicator tape from the dispenser and immerse in the liquid using approved gloves. Match its color with the closest one in the color chart.
* If the material is a liquid and out of the range of 6-9 use the corrosive liquid guide.
* If the material is a liquid within the 6-9 pH range use the flammable liquid guide.
* If the material is a solid use the corrosive solid guide.
HAZARDS:
1. Contact may cause burns to the eyes or skin 2. May be poisonous if inhaled or swallowed 3. Material may ignite if exposed to air 4. Material may explode if exposed to heat or there is a loss of cooling
CONTACT THE SHIPPER TO ASSURE THE MATERIAL IS NOT EXPLOSIVE. IF IT IS EXPLOSIVE EVACUATE THE AREA AND CONTACT THE FIRE DEPARTMENT.
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles. gloves. apron and boots. If there is a detectable odor, eye or nose irritation SCBA must be used. Have a fire extinguisher ready for immediate use by a second person wearing the same protective equipment in case of a fire.
Prevent liquid from coming into contact with other boxes or flammable materials.
Sprinkle Solusorb onto the material until the mixture appears dry.
Containerize the absorbed material into one or more plastic bags using a clean shovel or dust pan.
If the box is wet, but there is no noticeable liquid place the box into a plastic bag and that bag into another plastic bag.
Because this material may cause the packing box to ignite. move the material and packing box to an area that will be safe if it were to catch on fire.
Call the shipper to obtain specific neutralization instructions.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date ___________________________________________________
DOT Name ____________________________________________________________
Hazardous Class _____________________________________________________
Sequence Number ______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
1. Contact may cause irritation to the eyes or skin 2. Fire may produce irritating or poisonous gases 3. May be poisonous if inhaled or swallowed 4. If producing visible fumes contact outside response team
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles, gloves, apron and boots. If there is a detectable odor, eye or nose irritation SCBA must be used. If there is noticeable skin irritation due to fumes or vapors, do not attempt to continue clean up, call for outside assistance. On liquid spills, sprinkle Solusorb onto the material until the mixture appears dry.
Containerize the absorbed material into one or more plastic bags using a clean shovel or dust pan. Assure there is no visible liquid as a spark could cause a fire.
If the box is wet, but there is no noticeable liquid place the box into a plastic bag and that bag into another plastic bag.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date ____________________________________________________
DOT Name _____________________________________________________________
Hazardous Class _______________________________________________________
Sequence Number _______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
1. Skin contact poisonous 2. Contact may cause burns to the eye or skin 3. Fire may produce irritating or poisonous gases 4. Poisonous if inhaled or swallowed 5. If producing visible fumes contact outside response team
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles, gloves, apron and boots. Avoid any activity that will cause the material to become airborne. Use a clean shovel or dustpan to move the material into one or more plastic bags.
Do not add any neutralizer to this material.
Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date ___________________________________________________
DOT Name ____________________________________________________________
Hazardous Class _____________________________________________________
Sequence Number _____________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
1. Contact may cause burns to the eyes or skin 2. Fire may produce irritating or poisonous gases 3. May be poisonous if inhaled or swallowed 4. If producing visible fumes contact outside response team
WEAR REQUIRED PROTECTIVE EQUIPMENT! i.e. goggles, gloves, apron and boots. Avoid any activity that will cause the material to become airborne. Use a clean shovel or dustpan to move the material into one or more plastic bags. Do not add any neutralizer to this material. Place a completed bag label onto the bag by wrapping the label around the neck of the bag, adhesive sides pressed together. An example of a proper bag label is as follows:
HAZARDOUS WASTE
Accumulation Date _____________________________________________________
DOT Name ______________________________________________________________
Hazardous Class _______________________________________________________
Sequence Number _______________________________________________________
Decontaminate any areas of the body that may have been exposed by flushing with water for 15 minutes. Decontaminate reusable equipment and assure that the area is safe for resumption of operations.
HAZARDS:
NO LABEL 2. Skin contact may be poisonous
ON BOX 3. Contact may cause burns to the eyes or skin
4. Fire may produce irritating or poisonous gases
5. May be poisonous if inhaled or swallowed
6. Note: The material may be toxic as well as flammable.
Sometimes an unlabelled package will be leaking. Materials shipped in unlabelled packages should not be hazardous materials, however because we can not be certain that the materials arc non-hazardous they will be assumed to have some hazard associated with them.
If the package is producing visible smoke, or fumes that are irritating to the skin contact an outside contractor or fire department, do not attempt to clean up this spill.
If the spill has visible liquid wear gloves, goggles, apron, and boots. If there is no visible liquid but the box is wet, at a minimum wear gloves and goggles. If there is a strong odor, eye or nose irritation SCBA must be used.
If the material is a liquid check the pH by tearing off approximately five inches of px indicator tape from the dispenser and immerse in the liquid using approved gloves. Match its color with the closest one in the color chart.
* If the material is a liquid and out of the range of 6-9 use the corrosive liquid guide.
* If the material is a liquid within the 6-9 pH range use the flammable liquid guide.
If the material is a solid use the corrosive solid guide.
To process hazardous materials, the following specifies the required supplies to be kept on hand and in good repair at all operating hubs or centers. All items involved are ordered following the existing ordering procedure.
A. REQUIRED EQUIPMENT
Name Location Minimum Requirements
1. DOT Compliance Center Hubs One complete cabinet,
located in the (Large) Package
Service Center area.
DOT Compliance Center Package Centers One complete cabinet,
away from HUB located in the (Small)
Package Service Center area
2. SOLUSORB Hubs One container for
approximately every 10 doors
of primary unload, and an
additional three placed
in location convenient to the
greatest number of package
handling personnel.
Package Centers One for each 10 doors of
away from HUB primary unload
3. Sodium Bicarbonate Hubs One container on the spill
cart, and six on reserve at
the Package Service Center
Package Centers Three containers for each
away from HUB 10 doors of primary unload
4. Protective Wear Hub/Package Centers
away from Hub
Gloves - Multiple at various
designated locations
Aprons - Two
Boots - Two pairs, size "L
Goggles - Two pair
SCBA Hubs - Two units
Negative Pressure Hubs/Package - Two units
Respirators Centers away from
Hub
5. Broom, Dustpan & Shovel Hubs/Package Centers One each
away from Hub
6. pH Indicator Tape Hubs/Package Centers Two dispensers (one
away from Hub on reserve)
7. Reference Materials Hubs and - UPS Guide for Shipping
Package Centers Haz Mat
UPS Spill Response Procedure
- DOT Emergency Response
Guide
- Hazardous Materials
Posters:
"Preparing Hazardous
Materials Shipments"
"Hazardous Materials
Spill Response
B. MAINTENANCE OF EQUIPMENT
The actual quantities maintained at each operating location may exceed the above minimums, if the need is established. Customer Service is responsible for auditing the procedure as well as the inventory of supplies on a regular basis. Some general guidelines for taking care of the supplies are outlined below:
1. Solusorb and Sodium Bicarbonate must stay in their own cartons. The inner wrap should be kept sealed with a twist tie when not in use to protect them from moisture. The products have an indefinite shelf life, but will lose some of their qualities if allowed to get damp.
2. Gloves will be decontaminated after use. If they are damaged or the contamination can not be removed they must be discarded.
3. Aprons, Goggles, Brooms, Shovels and Dustpans must be rinsed off after each use. If they become too soiled or worn out, they are to be replaced.
4. Spill Tubs must be cleaned thoroughly after each use.
5. Self Contained Breathing Apparatus will be recharged with air after any use irrespective of the amount of air left in the cylinder. They must be inspected monthly by site personnel and yearly by the vendor.
TABLE A
SORBENTS CHART
APPLICATION WHAT IT DOES WHAT IT DOES NOT DO
SOLUSORB
On all hazardous spills absorbs liquids does not neutralize
acids or alkalis
On strong smelling spills reduces odors
reduces flammability
SPEEDI DRI
On all non-hazardous spills absorbs liquids does not suppress odors
except those with offensive
fumes does not reduce
flammability
SODIUM BICARBONATE
Apply directly, or add to neutralizes acids does not act as an
Solusorb* mixed with: absorbent
Acids neutralizes alkalis (bases)
Alkalis
Corrosives helps neutralize odors
*A small amount of water should be carefully added if the mixture is too dry for the soda to dissolve. Sufficient moisture produces a fizzing reaction for acids; for alkalis, no audible reaction occurs. In either case, neutralization is confirmed by a pH test, indicating acidity between six and nine.
DAY 1
I. INTRODUCTION AND REGULATORY ASPECTS (30 min) A. Course Overview B. Discussion of Hazardous material Response and Importance of Safe Procedures
II. CHEMICAL HAZARDS AND TOXICOLOGY (120 min) A. Overview Of Exposures To Hazardous Substances 1. Recognition of chemical hazards 2. Physical and Health hazards B. Basics of Toxicology 1. Routes of entry/anatomy 2. Dose/Response 3. Signs and symptoms of over exposure C. Permissible Exposure Limits (PELs) and Threshold Limit Values (TLVs) 1. History and application 2. Time weighted average (TWA) and short term exposure limit (STEL) 3. Activity II - Calculations D. Material Safety Data Sheets (MSDS) 1. History and application 2. Interpreting MSDS's 3. Activity II - understanding an MSDS
III.FIRE AND EXPLOSION HAZARDS (30 min)
1. Discussion of Fire/Explosion Hazards as they would present themselves at UPS
IV. ASSESSMENT OF HAZARDOUS MATERIALS INCIDENTS (90 min) A. Hazard Coding Systems and Other Sources of Hazard Identification 1. DOT/HMIS/NFPA 2. Activity III - Identifying labels.
B. Emergency Response Guidebook C. NIOSH Pocket Guide to Chemical Hazards D. UPS Hazard Data Sheets E. Overview of Available Monitoring Equipment 1. pH Paper or pH Meters 2. Activity IV - Using pH paper and meter
V. MEDICAL SURVEILLANCE AND FIRST AID (30 min) A. Video - "First Aid" B. Review of UPS System to Summon Medical Aid C. Medical Surveillance Program
VI. PERSONAL PROTECTIVE EQUIPMENT (120 min) A. Discussion and Equipment Demonstration; Gloves, Boots, Aprons, Goggles B. Principles of Respiratory Protection 1. Discuss and demonstrate 1/2 face and full face negative pressure respirators 2. Discuss fit test methods 3. Video - "Atmosphere Supplying Respirators" 4. Demonstrate SCBA 5. Activity V - SCBA Exercise
VII. BASICS OF DECONTAMINATION (45 min)
A. Decon Guidelines B. Types of Equipment C. Video - "DECON"
END OF DAY REVIEW (15 min)
DAY 2
VIII. UPS DAMAGED PACKAGE PROCEDURE (60 min)
A. Review of the Procedure B. The Role of the First Responder C. Review of the Materials Available for Response D. Walkthrough of the Procedure
IX. HANDS ON DRILL USING THE UPS PROCEDURES (120 min)
X. REVIEW AND CRITIQUE (60 min)