Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVES). | Occupational Safety and Health Administration

Record Type:

OSHA Instruction
Current Directive Number:

CPL 02-00-035
Old Directive Number:

CPL 2.35 CH-14
Title:

Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVES).
Information Date:

12/03/1990
Standard Number:

1910.120

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

U.S. Department of Labor Occupational Safety and Health Administration

Washington, D.C. 20210

Reply to the Attention of:

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

Subject: Changes to the Regulatory and General Industry Standard Alleged Violation Elements (SAVEs) Manual

A. Purpose. This instruction transmits revised and new pages to the Regulatory and General Industry SAVEs Manual for "Hazardous Waste Operations and Emergency Response" and "Control of Hazardous Energy Source (Lockout/Tagout)."

B. Scope. This instruction Applies OSHA-wide.

C. Action. Regional Administrators and Area Directors shall ensure that all compliance personnel:

1. Make the following page changes to the Regularoty and Genreal Industry (SAVEs) Manual:

Remove Pages Insert Pages

146.1 through 146.102

175-176 175 through 176

2. File a copy of this transmittal sheet behind OSHA Instruction CPL 2.35 CH-13 in the appropriate OSHA Directives System binder.

D. Background. Final rule and regulations for 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response, were published in the Federal Register, Vol. 54, No. 42, on March 6, 1989. Corrections to the regulations were published in the Federal Register, Vol. 55, No. 72, on April 13, 1990. The final rule for Control of Hazardous Energy Source (Lockout/Tagout) was published in the Federal Register, Vol. 54, No. 169, on September 1, 1989. Corrections and Technical Amendments to the final rule were published in the Federal Register, Vol. 55, No. 183, on September 20, 1990.

OSHA Instruction CPL 2.34 CH-14 DEC 03, 1990 Office of General Industry Compliance Assistance

E. State Plan States. Regional Administrators shall advise State designees of the action required by this instruction and encourage their participation in the SAVEs program.

Patricia K. Clark, Director Directorate of Compliance Programs

DISTRIBUTION: National, Regional, and Area Offices Compliance Officers State Designees Area Office Clericals 11(c)/405 Programs NIOSH Regional Program Directors

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1

1 29 CFR 1910.120(b)(1)(i): The employer did not develop and/or implement a written safety and health program for its employees involved in hazardous waste operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 2 2 29 CFR 1910.120(b)(1)(i): The employer did not develop and/or implement a written safety and health program that was designed to identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.1

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-7 1 29 CFR 1910.120(b)(1)(ii) * : The written safety and health program did not incorporate: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(G)):

   NOTE:  These SAVEs may be grouped with 29 CFR 1910.120(b)(3)
        as appropriate.

OPTION 1 (A) An organizational structure:

OPTION 2 (B) A comprehensive workplan:

OPTION 3 (C) A site-specific safety and health plan:

OPTION 4 (D) The safety and health training program:

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(3)(iv), 1910.120(b)(4)(ii)(B), or 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 5 (E) The medical surveillance program:

NOTE: This SAVE may be group with 29 CFR 1910.120(b)(ii)(D).

OPTION 6 (F) The employer's standard operating procedures for safety and health:

OPTION 7 (G) Any necessary interface between general program and site-

specific activities:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.2

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(b)(1)(iii): The employer did not shore or slope site excavations created during initial site preparation or during hazardous waste operations as appropriate to prevent accidental collapse in accordance with Subpart P of 29 CFR Part 1926:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS, SHIFT, AND DATE)

2 29 CFR 1910.120(b)(1)(iv): Contractor(s), subcontractor(s), or their representative(s) retained by the employer to work in hazardous waste operations were not informed of the site emergency response procedures and/or any potential fire, explosion, health, safety, or other hazards of the hazardous waste operation that had been identified by the employer, including those identified in the employer's information program:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: For informational programs violation this SAVE may be group with 29 CFR 1910.120(i) when appropriate.

146.3

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-5 1 29 CFR 1910.120(b)(1)(v): The written safety and health program was not made available to: ENTER THE APPROPRIATE OPTION:

OPTION 1 Any contractor, subcontractor, or their representative who will be involved with the hazardous waste operation:

OPTION 2 Employees:

OPTION 3 Employee-designated representatives:

OPTION 4 Personnel of other Federal, State, or local agencies with regulatory authority over the site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(b)(2)(i): The organizational structure part of the safety and health program did not establish the specific chain of command and specify the overall responsibilities of supervisors and employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED (DESCRIBE CONDITIONS)

146.4

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 2-5 1 29 CFR 1910.120(b)(2)(i) * : The organizational structure part of the safety and health program did not include: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-D)):

OPTION 2 (A) A general supervisor who has the responsibility and authority to direct all hazardous waste operations:

OPTION 3 (B) A site safety and health supervisor who has the responsibility and authority to develop and implement the site safety and health plan and verify compliance:

OPTION 4 (C) All other personnel needed for hazardous waste site operations and emergency response and their general functions and responsibilities:

OPTION 5 (D) The lines of authority, responsibility, and communication:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(b)(2)(ii): The employer did not review and/or update the organizational structure part of the safety and health program as necessary to reflect the current status of waste site operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.5

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(b)(3): The comprehensive workplan part of the site safety and health program did not address the tasks and objectives of the site operations and the logistics and resources required to reach those tasks and objectives:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTIONS 2-6 2 29 CFR 1910.120(b)(3) * : The comprehensive workplan part of the site safety and health program did not: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(vi)):

OPTION 2 (i) Address anticipated clean-up activities as well as normal operating procedures:

OPTION 3 (ii) Define work tasks and objectives and methods for accomplishing those tasks and objectives:

OPTION 4 (iii) Establish personnel requirements for implementing the plan:

OPTION 5 (iv) Provide for the implementation of the training required in 29 CFR 1910.120(e):

NOTE: This SAVE may be group with 29 CFR 1910.120(b)(1)(ii)(D) as appropriate.

OPTION 6 (v) Provide for the implementation of the informational programs required in 29 CFR 1910.120(i):

NOTE: This SAVE may be grouped with 29 CFR 1910.120(i) as appropriate.

NOTE: Option 7 is on top of next page.

146.6

OSHA Instruction CPL 2.35 CH-14 DEC 03 1991 Office of General Industry Compliance Assistance

OPTION 7 (vi) Provide for the implementation of the medical surveillance program described in 29 CFR 1910.120(f):

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(1)(ii)(D) as appropriate.

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 1 29 CFR 1910.120(b)(4)(i): The site-specific safety and health plan part of the program required under 29 CFR 1910.120(b)(1)(i) was not available on site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(1)(ii) as appropriate.

OPTION 2 2 29 CFR 1910.120(b)(4)(i): The site-specific safety and health plan part of the program required under 29 CFR 1910.120(b)(1)(i) did not address the safety and health hazards of each phase of site operation and/or did not include the requirements and procedures for employee protection:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.7

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-10 1 29 CFR 1910.120(b)(4)(ii) * : The site safety and health plan, at a minimum, did not address: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(J)):

OPTION 1 (A) A safety and health risk or hazard analysis for each site task and operation found in the workplan:

OPTION 2 (B) Employee training assignments to assure compliance with 29 CFR 1910.120(e):

NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120 (e)(1)(i) through 29 CFR 1910.120(e)(8) as appropriate.

OPTION 3 (C) Personal protective equipment to be used by employees for each of the site tasks and operations being conducted as required by the protective equipment program in 29 CFR 1910.120(g)(5):

NOTE: This SAVE may be consider to be grouped with 29 CFR 1910.120(g)(5) using the SAVEs in 29 CFR 1910.120 (g)(5(x) as appropriate.

OPTION 4 (D) Medical surveillance requirements in accordance with the program in 29 CFR 1910.120(f):

NOTE: This SAVE may be grouped with grouped with SAVEs 29 CFR 1910.120(f) through 29 CFR 1910.120(f)(8)(ii)(A)- (D) as appropriate.

OPTION 5 (E) Frequency and types of air monitoring, personal monitoring, and/or environmental sampling techniques and instrumentation to be used, including methods of maintenance and/or calibration of monitoring and/or sampling equipment to be used:

NOTE: Options 6 through 10 continued on next page.

146.8

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 6 (F) Site control measures in accordance with the site control program required in 29 CFR 1910.120(d):

   NOTE:  This SAVE may be grouped with SAVEs 29 CFR 1910.120(d)(1)
        through 29 CFR 1910.120(d)(3) Options 1 to 6 as
        appropriate.

OPTION 7 (G) Decontamination procedures in accordance with 29 CFR 1910.120(k):

NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120 (k)(2)(i) through 29 CFR 1910(k)(8) as appropriate.

OPTION 8 (H) An emergency response plan meeting the requirements of 29 CFR 1910.120(l) for safe and effective responses to emergencies including the necessary personal protective equipment and other equipment:

NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120 (l)(1)(i) through 29 CFR 1910.120(l)(3)(vii) as appropriate.

OPTION 9 (I) Confined space entry procedures:

NOTE: This SAVE may be group with 29 CFR 1910.120(j)(9)(ii) as appropriate.

OPTION 10 (J) A spill contamination program meeting the requirements of 29 CFR 1910.120(j):

NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120 (j)(1)(vi) through 29 CFR 1910.120(j)(1)(xii) as appropriate.

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.9

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(b)(4)(iii): The site-specific safety and health plan did not provide for pre-entry briefings to be held prior to initiating any site activity:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(b)(4)(iii): The site-specific safety and health plan did not provide for pre-entry briefings at such other times as necessary to ensure that employees were apprised of the site safety and health plan and that this plan was being followed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 3 3 29 CFR 1910.120(b)(4)(iii): The information and data obtained from site characterization and analysis work required in 29 CFR 1910.120(c) were not used to prepare and update the site safety and health plan:

NOTE: This SAVE may be grouped with SAVEs 29 CFR 1910.120 (c)(1) through 29 CFR 1910.120(c)(8) as appropriate.

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.10

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(b)(4)(iv): Inspections were not conducted by the site safety and health supervisor or, in the absence of that individual, another individual who was knowledgeable in occupational safety and health, acting on behalf of the employer as necessary to determine the effectiveness of the site safety and health plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(b)(4)(iv): Deficiencies in the effectiveness of the site safety and health plan were not corrected by the employer:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS WHERE RELEVANT, AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(c)(1): Hazardous waste sites were not evaluated in accordance with the requirements of 29 CFR 1910.120(c) to identify specific site hazards and/or to determine the appropriate safety and health control procedures needed to protect employees from the identified hazards:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

146.11

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(c)(2): A preliminary evaluation of the site's characteristics was not performed prior to site entry by a qualified person to aid in the selection of appropriate employee protection methods prior to entry:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 19102.120 (b)(4)(iii) as appropriate.

OPTION 2 2 29 CFR 1910.120(c)(2): A more detailed evaluation of the site's specific characteristics was not performed by a qualified person immediately after site entry to further identify existing site hazards and/or to further aid in the selection of the appropriate engineering controls and/or personal protective equipment for the tasks to be performed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

3 29 CFR 1910.120(c)(3): All suspected conditions that may pose inhalation or skin absorption hazards that were immediately dangerous to life or health (IDLH) or other conditions that may cause death or serious harm, were not identified during the preliminary survey and evaluated during the detailed survey:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: THis SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

146.12

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-8 1 29 CFR 1910.120(c)(4) * : Prior to allowing employees to enter a site, the employer did not obtain to the extent available: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(viii)):

NOTE: These SAVEs listed under Options 1 through 8 below may be grouped with 29 CFR 1910.120(b)(4)(iii) as appropriate.

OPTION 1 (i) Location and approximate size of the site:

OPTION 2 (ii) Description of the response activity and/or the job task to be performed:

OPTION 3 (iii) Duration of the planned employee activity:

OPTION 4 (iv) Site topography and accessibility by air and roads:

OPTION 5 (v) Safety and health hazards expected at the site:

OPTION 6 (vi) Pathways for hazardous substance dispersion:

OPTION 7 (vii) Present status and capabilities of emergency response teams that would provide assistance to hazardous waste clean-up site employees at the time of an emergency:

OPTION 8 (viii) Hazardous substances and health hazards involved or expected at the site, and their chemical and physical properties:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.13

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(c)(5)(i): An ensemble of personal protective equipment (PPE) was not selected, based upon the results of the preliminary site evaluation, and used during initial site entry which would provide protection to a level of exposure below permissible exposure limits and/or published exposure levels for known or suspected hazardous substances and health hazards:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

OPTION 2 2 29 CFR 1910.120(c)(5)(i): An ensemble of personal protective equipment (PPE) was not selected and used during initial site entry which would provide protection against other known and suspected hazards identified during the preliminary site evaluation:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

146.14

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(c)(5)(ii): An escape-type self-contained breathing apparatus of at least five minutes' duration was not carried by employees during initial site entry when positive- pressure self-contained breathing apparatus was not used as part of the entry ensemble and/or when respiratory protection was warranted by the potential hazards identified during the preliminary site evaluation:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

OPTION 1 2 29 CFR 1910.120(c)(5)(iii): An ensemble providing protection equivalent to Level B PPE was not provided as minimum protection when the preliminary site evaluation did not produce sufficient information to identify the hazards or suspected hazards of the site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

OPTION 2 3 29 CFR 1910.120(c)(5)(iii): Direct reading instruments were not used as appropriate to identify IDLH conditions when the preliminary site evaluation did not produce sufficient information to identify hazards or suspected hazards of the site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

146.15

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(c)(5)(iv): The appropriate PPE was not selected and used in accordance with 29 CFR 1910.120(g) once the hazards of the site had been identified:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

OPTION 1-4 2 29 CFR 1910.120(c)(6) * : During initial site entry when the site evaluation produce information that showed the potential for ionizing radiation or IDLH conditions, or the site information was not reasonably sufficient to eliminate these conditions: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iii)):

NOTE: These SAVEs listed under Options 1-3 may be grouped with 29 CFR 1910.120(b)(4)(iii) and 29 CFR 1910.120(h) as appropriate.

OPTION 1 (i) Monitoring was not conducted with direct reading instruments for hazardous levels of ionizing radiation:

OPTION 2 (ii) Monitoring was not conducted of the air with appropriate direct reading test equipment (i.e., combustible gas meters, detector tube(s)) for IDLH and other conditions that could cause death or serious harm (combustible or explosive atmospheres, oxygen deficiency, toxic substances):

OPTION 3 (iii) The employer did not visually observe for signs of actual or potential IDLH or other dangerous conditions:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.16

OSHA Instruction CPl 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(c)(7): After the presence and concentrations of specific hazardous substances and health hazards had been established, the risks associated with these substances were not identified:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: These SAVEs listed under Options 1 and 2 may be grouped with 29 CFR 1910.120(b)(4)(iii) as appropriate.

OPTION 2 2 29 CFR 1910.120(c)(7): Employees who would be working on the site were not informed of any risks that had been identified:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: Risks to be considered included but were not limited to: exposures exceeding PELs or published exposure levels; IDLH concentrations; potential skin absorption and irritation sources; potential eye irritation sources; explosion sensitivity and flammability ranges; and oxygen deficiency.

146.17

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(c)(8): Information concerning the chemical, physical, and toxicological properties of each substance known or expected to be present on site that was available to the employer and relevant to the duties employees were expected to perform was not made available to the affected employees prior to the commencement of their work activities:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(iii) as appropriate.

2 29 CFR 1910.120(d)(1): Appropriate site control procedures to control employee exposure to hazardous substances were not implemented before clean-up work began:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(d)(2): A site control program for protecting employees, which was a part of the employer's site safety and health program required in 29 CFR 1910.120(b), was not developed during the planning stages of the hazardous waste clean-up operation and was not modified as necessary as new information became available:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)ii)(f) as appropriate.

146.18

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-6 1 29 CFR 1910.120(d)(3): The site control program did not, as a minimum, include: ENTER THE APPROPRIATE OPTION:

NOTE: These SAVES listed Options 1-6 below may be grouped with 29 CFR 19101.120(b)(4)(ii)(F) as appropriate.

OPTION 1 A site map:

OPTION 2 Site work zones:

OPTION 3 The use of a "buddy system":

OPTION 4 Site communications including alerting means for emergencies:

OPTION 5 The standard operating procedures or safe work practices:

OPTION 6 Identification of the nearest medical assistance:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(e)(1)(i): Employees working on site who were exposed to hazardous substances, health hazards, or safety hazards and/or their supervisors and management responsible for the site did not receive training meeting the requirements of this paragraph before they were permitted to engage in hazardous waste operations that could expose them to hazardous substances, safety, or health hazards:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.19

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(e)(1)(i): Employees working on site who were exposed to hazardous substances, health hazards, or safety hazards and/or their supervisors and management responsible for the site did not receive review training as specified in this paragraph:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) and any of the SAVEs listed under 29 CFR 1910.120(e) as appropriate.

2 29 CFR 1910.120(e)(1)(ii): Employees were permitted to participate in or to supervise field activities before they were trained to a level required by their job function and responsibility:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.20

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-7 1 29 CFR 1910.120(e)(2) * : Employee training did not cover the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)- (vii)):

   NOTE:  These SAVEs listed Options 1-7 below as well as SAVE
        29 CFR 1910.120(b)(4)(ii)(B) may be grouped as appropriate.

OPTION 1 (i) Names of personnel and alternates responsible for site safety and health:

OPTION 2 (ii) Safety, health and other hazards present on the site:

OPTION 3 (iii) Use of personal protective equipment:

OPTION 4 (iv) Work practices by which the employee can minimize risks from hazards:

OPTION 5 (v) Safe use of engineering controls and equipment on the site:

OPTION 6 (vi) Medical surveillance requirements, including recognition of symptoms and signs which might indicate overexposure to hazards:

OPTION 7 (vii) Contents of 29 CFR 1910.120(b)(4)(ii)(G) through (J) of the site safety and health plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.21

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(e)(3)(i): General site workers engaged in hazardous substance removal or other activities which exposed or potentially exposed workers to hazardous substances and health hazards have not received a minimum of 40 hours of instruction off the site and/or received a minimum of three days actual field experience under the direct supervision of a trained, experienced supervisor:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

2 29 CFR 1910.120(e)(3)(ii): Workers on site only occasionally for a specific limited task and who were unlikely to be exposed over permissible exposure limits and/or published exposure limits have not received a minimum of 24 hours of instruction off the site and/or received the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

146.22

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(e)(3)(iii): Workers regularly on site who worked in areas which had been monitored and fully characterized indicating exposures were under permissible exposure limits and/or published exposure limits where respirators were not necessary, and there were no health hazards or the possibility of an emergency developing, and/or received a minimum of 24 hours of instruction off the site have not received the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

2 29 CFR 1910.120(e)(3)(iv): Workers with 24 hours of training who were covered by 29 CFR 1910.120(e)(3)(ii) and (e)(3)(iii), and who became general site workers or who were required to wear respirators, did not have the additional 16 hours and/or two days of training necessary to total the training specified in 29 CFR 1910.120(e)(3)(i):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

146.23

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(e)(4): On-site management and supervisors directly responsible for, or who supervise employees engaged in hazardous waste operations did not receive 40 hours of initial training and three days of supervised field experience, and/or at least eight additional hours of specialized training at the time of job assignment on topic(s) such as, but not limited to: ENTER THE APPROPRIATE OPTION:

NOTE: These SAVEs listed Options 1-4 below may be grouped with 29 CFR 1910.120(b)(4)(ii)(B) as appropriate.

   OPTION 1  The employer's safety and health program and the
             associated employee training program:

OPTION 2 Personal protective equipment program:

OPTION 3 Spill containment program:

OPTION 4 Health hazard monitoring procedures and techniques:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.24

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 5-8 1 29 CFR 1910.120(e)(4): On-site management and supervisors who supervise only employees covered by 29 CFR 1910.120(e)(3)(ii) and (e)(3)(iii) did not receive 24 hours of initial training and one day of supervised field experience and/or at least eight additional hours of specialized training at the time of job assignment on topic(s) such as, but not limited to: ENTER THE APPROPRIATE OPTION:

NOTE: These SAVEs listed under Options 5-8 may be grouped with 29 CFR 1910.120(b)(4)(ii)(B) as appropriate.

OPTION 5 Employer's safety and health program and the associated employee training program:

OPTION 6 Personal protective equipment program:

OPTION 7 Spill containment program:

OPTION 8 Health hazard monitoring procedures and techniques:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.25

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(e)(5): Trainers were not qualified to instruct employees about the subject matter that was presented in training and/or had not satisfactorily completed a training program for teaching the subjects they were expected to teach, or they did not have the academic credentials and instructional experience necessary for teaching the subjects:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

OPTION 2 2 29 CFR 1910.120(e)(5): Instructors did not demonstrate competent instructional skills and/or knowledge of the applicable subject matter:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

OPTION 1 3 29 CFR 1910.120(e)(6): Employees and supervisors that had received and successfully completed the training and field experience specified in 29 CFR 1910.120(e)(1) through (e)(4) were not certified by their instructor or the head instructor and/or trained supervisor as having successfully completed the necessary training:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

146.26

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(e)(6): A written certificate was not given to each person certified as having successfully completed the training and/or field experience specified in 29 CFR 1910.120(e)(1) through (e)(4):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

OPTION 3 2 29 CFR 1910.120(e)(6): All persons who had not been certified as successfully completing the training and field experience specified in 29 CFR 1910.120(e)(1) through (e)(4) were not prohibited from engaging in hazardous waste operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

3 29 CFR 1910.120(e)(7): Employees engaged in responding to hazardous emergency situations at hazardous waste clean-up sites that could expose them to hazardous substances were not trained in how to respond to such expected emergencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

146.27

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 29 CFR 1910.120(e)(8): Employees specified in 1910.120(e)(1), and/or managers and supervisors specified in 1910.120(e)(4), did not receive eight hours of refresher training annually on the items specified in 29 CFR 1910.120(e)(1) and/or (e)(4):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

OPTION 2 2 29 CFR 1910.120(e)(8): Employees specified in 1910.120(e)(1), and managers and supervisors specified in 29 CFR 1910.120(e)(4), did not receive eight hours of refresher training annually or any critique of incidents that had occurred in the past year that could serve as training examples of related work:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

3 29 CFR 1910.120(e)(9): Certified employees or employees with equivalent training new to a site did not receive appropriate site-specific training before site entry and/or did not have appropriate supervised field experience at the new site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(B) as appropriate.

146.28

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(f)(2) * : A medical surveillance program was not instituted by the employer for: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iv)):

NOTE: These SAVEs listed under Options 1-4 below may be grouped 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (i) Employee(s) who were or could be exposed to hazardous substances or health hazards at or above the permissible exposure limits or, where there were no permissible exposure limits, above the published exposure levels for these substances, without regard to the use of respirators, for 30 days or more per year:

OPTION 2 (ii) Employee(s) who wear a respirator for 30 days or more a year, as required by 29 CFR 1910.134:

OPTION 3 (iii) All employees who were injured, became ill or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards from an emergency response or hazardous waste operation:

OPTION 4 (iv) Members of HAZMAT teams:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.29

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-5 1 29 CFR 1910.120(f)(3) * : Medical examinations and consultations were not made available by the employer to each employee covered under 29 CFR 1910.120(f)(2)(i), (ii), and (iv): ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(E)):

NOTE: These SAVEs listed under Options 1-5 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (A) Prior to assignment:

OPTION 2 (B) At least once every 12 months unless the attending physician believes a longer interval (not greater than biennially) is appropriate:

OPTION 3 (C) At termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months:

OPTION 4 (D) As soon as possible upon notification by an employee that he/she had developed signs or symptoms indicating possible overexposure to hazardous substances or health hazards or that the employee had been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation:

OPTION 5 (E) At intervals more frequently than specified by 29 CFR 1910.120(f)(3)(i), when the examining physician determined that an increased frequency of examination was medically necessary:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.30

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-2 1 29 CFR 1910.120(f)(3)(ii) * : Medical examinations and consultations were not made available by the employer to employees covered under 29 CFR 1910.120(f)(2)(iii) including those covered by 29 CFR 1910.120(a)(1)(v) who could have been injured, received a health impairment, developed signs or symptoms which could have resulted from exposure to hazardous substances resulting from an emergency incident, or could have been exposed during an emergency incident to hazardous substances at concentrations above the permissible exposure limits or published exposure levels without the use of necessary personal protective equipment: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A) or (B)):

NOTE: These SAVEs listed under Options 1 and 2 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (A) As soon as possible following the emergency incident or development of signs or symptoms:

OPTION 2 (B) At additional times, when the examining physician determined that follow-up examinations or consultations were necessary:

(a) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.31

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-2 1 29 CFR 1910.120(f)(4)(i): Medical examinations required by 29 CFR 1910.120(f)(3) did not include: ENTER THE APPROPRIATE OPTION:

NOTE: These SAVEs listed under Options 1 and 2 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 A medical and work history with special emphasis on symptoms related to the handling of hazardous substances and health hazards:

OPTION 2 Evaluation of fitness for duty including the ability to wear any required PPE under conditions that could be expected at the work site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.32

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(f)(4)(ii): The content of medical examinations or consultations made available to employees was not determined by the attending physician:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(D) as appropriate.

OPTION 1 2 29 CFR 1910.120(f)(5): Medical examinations and procedures were not performed by or under the supervision of a licensed physician knowledgeable in occupational medicine:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(D) as appropriate.

OPTION 2 3 29 CFR 1910.120(f)(5): Medical examinations and procedures were not provided without cost to the employee, without loss of pay, and at a reasonable time and place:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(D) as appropriate.

146.33

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-5 1 29 CFR 1910.120(f)(6) * : The employer did not provide a copy of 29 CFR 1910.120 and its appendices to the attending physician, and, for each employee: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(v)):

NOTE: These SAVEs listed under Options 1-5 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (i) A description of the employee's duties as they relate to the employee's exposures:

OPTION 2 (ii) The employee's exposure levels or anticipated exposure levels:

OPTION 3 (iii) A description of any personal protective equipment used or to be used:

OPTION 4 (iv) Information from previous medical examinations of the employee which was not readily available to the examining physician:

OPTION 5 (v) Information required by 29 CFR 1910.134:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.34

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(f)(7)(i) * : The employer did not obtain and furnish the employee with a copy of the written opinion from the attending physician that contained: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):

NOTE: These SAVEs listed under Options 1-4 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (A) The physician's opinion as to whether the employee had any detected medical conditions which would place the employee at increased risk of material impairment of the employee's health from work in hazardous waste operations or emergency response, or from respirator use:

OPTION 2 (B) The physician's recommended limitations upon the employee's assigned work:

OPTION 3 (C) The results of the medical examination and tests when requested by the employee:

OPTION 4 (D) A statement that the employee had been informed by the physician of the results of the medical examination and any medical conditions which required further examination or treatment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS) 146.35

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance 1 29 CFR 1910.120(f)(7)(ii): The written opinion obtained by the employer revealed specific findings or diagnoses unrelated to occupational exposures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(d) as appropriate.

OPTION 1 2 29 CFR 1910.120(f)(8)(i): An accurate record of the medical surveillance required by 29 CFR 1910.120(f) was not retained:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(D) as appropriate.

OPTION 2 3 29 CFR 1910.120(f)(8)(i): An accurate record of the medical surveillance required by 29 CFR 1910.120(f) was not retained for the period specified, and/or did not meet the criteria of 29 CFR 1910.20:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(D) as appropriate.

146.36

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(f)(8)(ii) * : The accurate record of the medical surveillance required in 29 CFR 1910.120(f)(8)(i) did not include at least: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):

NOTE: These SAVEs listed under Options 1-4 may be grouped with 29 CFR 1910.120(b)(4)(ii)(D) as appropriate.

OPTION 1 (A) The name and social security number of the employee:

OPTION 2 (B) The physician's written opinions, recommended limitations, and results of examinations and tests:

OPTION 3 (C) Any employee medical complaints related to exposure to hazardous substances:

OPTION 4 (D) A copy of the information provided to the examining physician by the employer, with the exception of the standard and its appendices:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(g)(1)(i): Engineering controls and work practices were not instituted to reduce and maintain employee exposures to or below the permissible exposure limits for substances regulated by 29 CFR 1910, Subpart Z:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: See "NOTE to (g)(1)(i)" for explanation of engineering controls/work practices which may be feasible.

146.37

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(g)(1)(ii): Whenever engineering controls and work practices are not feasible or not required, any reasonable combination of engineering controls, work practices and PPE were not instituted by the employer:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

2 29 CFR 1910.120(g)(1)(iii): The employer implemented a schedule of employee rotation to achieve compliance with permissible exposure limits or dose limits:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(g)(1)(iv): The employer did not comply with the provisions of 29 CFR 1910, Subpart G:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

4 29 CFR 1910.120(g)(2): An appropriate combination of engineering controls, work practices, and personal protective equipment was not used to reduce and maintain employee exposures to or below published exposure levels for hazardous substances and health hazards not regulated by 29 CFR 1910, Subparts G and Z:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.38

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(g)(3)(i): Personal protective equipment (PPE) was not selected and/or used which would protect employees from the hazards and potential hazards they were likely to encounter as identified during the site characterization and analysis:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTIONS 1-3 2 29 CFR 1910.120(g)(3)(ii): Personal protective equipment was not selected based on an evaluation of the performance characteristics of the PPE relative to: ENTER THE APPROPRIATE OPTION:

OPTION 1 The requirements and limitations of the site:

OPTION 2 Task-specific conditions and duration:

OPTION 3 The hazards and potential hazards identified at the site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.39

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-3 1 29 CFR 1910.120(g)(3)(iii): Positive pressure self-contained breathing apparatus or positive pressure air-line respirators equipped with an escape air supply were not used when the chemical exposure levels present created a substantial possibility of: ENTER THE APPROPRIATE OPTION:

OPTION 1 Immediate death:

OPTION 2 Immediate serious illness or injury:

OPTION 3 Impairment of the ability to escape:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTIONS 1-3 2 29 CFR 1910.120(g)(3)(iv): Totally encapsulating chemical protective suits (equivalent to Level A protection as recommended in Appendix B) were not used in conditions where skin absorption of a hazardous substance could result in a substantial possibility of: ENTER THE APPROPRIATE OPTION:

OPTION 1 Immediate death:

OPTION 2 Immediate serious illness or injury:

OPTION 3 Impairment of the ability to escape:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.40

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(g)(3)(v): The level of protection provided by PPE was not increased when additional information on site conditions indicated that increased protection was necessary to reduce employee exposures below permissible exposure limits and/or published exposure levels for hazardous substances and health hazards:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

2 29 CFR 1910.120(g)(3)(vi): Personal protective equipment was not selected and/or used to meet the requirements of 29 CFR 1910, Subpart I, and additional requirements specified in this section:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(g)(4)(i): Totally encapsulating protective suits did not protect employees from the particular hazards which were identified during site characterization and analysis:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.41

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(g)(4)(ii): Totally encapsulating suits were not capable of maintaining positive air pressure:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(g)(4)(iii): Totally encapsulating suits were not capable of preventing inward test gas leakage of more than 0.5 percent:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 3 29 CFR 1910.120(g)(5): A written personal protective equipment program, which was part of the employer's safety and health program required in 29 CFR 1910.120(b) or required in 29 CFR 1910.120(p)(1) and which was also a part of the site-specific safety and health plan was not established:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.42

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 2-11 1 29 CFR 1910.120(g)(5) * : The PPE program did not address the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(x)):

NOTE: These SAVEs listed as Item 1 and under Options 2-10 may be grouped with 29 CFR 1910.120(b)(4)(ii)(C) as appropriate.

OPTION 2 (i) PPE selection based upon site hazards:

OPTION 3 (ii) PPE use and limitations of the equipment:

OPTION 4 (iii) Work mission duration:

OPTION 5 (iv) PPE maintenance and storage:

OPTION 6 (v) PPE decontamination and disposal:

OPTION 7 (vi) PPE training and proper fitting:

OPTION 8 (vii) PPE donning and doffing procedures:

OPTION 9 (viii) PPE inspection procedures prior to, during, and after use:

OPTION 10 (ix) Evaluation of the effectiveness of the PPE program:

OPTION 11 (x) Limitations during temperature extremes, heat stress, and other appropriate medical considerations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.43

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(h)(1)(i): Monitoring was not performed in accordance with this paragraph where there could have been a question of employee exposure to hazardous concentrations of hazardous substances in order to assure proper selection of engineering controls, work practices, and personal protective equipment so that employees were not exposed to levels which exceeded permissible exposure limits, or published exposure levels if there are no permissible exposure limits, for hazardous substances:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

2 29 CFR 1910.120(h)(1)(ii): Air monitoring was not used to identify and quantify airborne levels of hazardous substances and safety and health hazards in order to determine the appropriate level of employee protection needed on site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.44

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(h)(2): Representative air monitoring was not conducted upon initial entry to identify: ENTER THE APPROPRIATE OPTION:

OPTION 1 Any immediately dangerous to life or health (IDLH) condition:

OPTION 2 Exposure over permissible exposure limits or published exposure levels:

OPTION 3 Exposure over a radioactive material's dose limit:

OPTION 4 Other dangerous conditions such as the presence of flammable atmospheres or oxygen-deficient environments:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 2 29 CFR 1910.120(h)(3): Periodic monitoring was not conducted when the possibility of an IDLH condition had developed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 2 3 29 CFR 1910.120(h)(3): Periodic monitoring was not conducted when the possibility of a flammable atmosphere had developed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.45

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 3-6 1 29 CFR 1910.120(h)(3) * : Periodic monitoring was not conducted when there was an indication that exposures could have risen over permissible exposure limits or published exposure levels since prior monitoring: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(iv)):

OPTION 3 (i) When work was begun on a different portion of the site:

OPTION 4 (ii) When contaminants other than those previously identified were being handled:

OPTION 5 (iii) When a different type of operation was initiated:

OPTION 6 (iv) When employees were handling leaking drums or containers or were working in areas with obvious liquid contamination:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 2 29 CFR 1910.120(h)(4): After the actual clean-up phase of the hazardous waste operation commenced, the employer did not monitor those employees likely to have the highest exposures to hazardous substances and health hazards likely to be present above permissible exposure limits or published exposure levels by using personal sampling frequently enough to characterize their exposures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.46

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(h)(4): When the employees likely to have the highest exposure were over permissible exposure limits or published exposure limits, monitoring was not continued to determine all employees likely to be above those limits:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

2 29 CFR 1910.120(i): The employer did not develop and implement a program, which is part of the employer's safety and health program required in 29 CFR 1910.120(b), to inform employees, contractors, and subcontractors (or their representatives) actually engaged in hazardous waste operations of the nature, level and degree of exposure likely to result from participation in such hazardous waste operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(1)(iv) as appropriate.

3 29 CFR 1910.120(j)(1)(i): The employer did not handle, transport, label, and dispose of hazardous substances and contaminated soils, liquids, and other residues in accordance with 29 CFR 1910.120(j)(1)(ii)-(xii):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(j)(1)(ii): Drums and containers meeting the appropriate DOT, OSHA, and EPA regulations for the wastes they contain were not used during the clean-up:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.47

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(j)(1)(iii): When practical, drums and containers were not inspected and/or their integrity was not assured prior to being moved:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(j)(1)(iii): Drums or containers that could not be inspected before being moved because of storage conditions were not moved to an accessible location and/or inspected prior to further handling:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(j)(1)(iv): Unlabeled drums and containers were not labeled as if they contain hazardous substances:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(j)(1)(v): Site operations were not organized to minimize the amount of drum or container movement:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.48

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(1)(vi): Prior to movement of drums or containers, all employees exposed during the transfer operation were not warned of the potential hazards associated with the contents of the drums or containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

OPTION 1 2 29 CFR 1910.120(j)(1)(vii): U.S. Department-of-Transportation-

specified salvage drums or containers were not kept available and/or used in areas where spills, leaks, or ruptures may occur:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

OPTION 2 3 29 CFR 1910.120(j)(1)(vii): Suitable quantities of proper absorbent were not kept available and/or used in areas where spills, leaks, or ruptures may occur:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

146.49

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(1)(viii): Where major spills may occur, a spill containment program, which is part of the employer's safety and health program required in 29 CFR 1910.120(b), was not implemented to contain and isolate the entire volume of the hazardous substance being transferred:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

2 29 CFR 1910.120(j)(1)(ix): Drums and containers that could not be moved without rupture, leakage, or spillage of the contents were not emptied into a sound container using a device classified for the material being transferred:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

3 29 CFR 1910.120(j)(1)(x): A ground-penetrating system or other type of detection system or device was not used to estimate the location and depth of buried drums or containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

4 29 CFR 1910.120(j)(1)(xi): Soil or covering material was not removed with caution to prevent drum or container rupture:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.50

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(1)(xii): Fire extinguishing equipment meeting the requirements of 29 CFR 1910, Subpart L, was not on hand and ready for use to control incipient fires:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(J) as appropriate.

OPTIONS 1-7 2 29 CFR 1910.120(j)(2) * : In areas where drums or containers were being opened, the following procedures were not followed:

ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(vii)):

OPTION 1 (i) Where an airline respirator system was used, connections to the source of air supply were not protected from contamination and the entire system was not protected from physical damage:

OPTION 2 (ii) Employees not actually involved in opening drums or containers were not kept a safe distance from the drums or containers being opened:

OPTION 3 (iii) If employees must work near or adjacent to drums or containers being opened, a suitable shield that did not interfere with the work operation was not placed between the employee and the drums or containers being opened to protect the employee in case of accidental explosion:

OPTION 4 (iv) Controls for drum or container-opening equipment, monitoring equipment, and fire-suppression equipment was not located behind the explosion-resistant barrier:

NOTE: Option 5 and 7 are continued on the next page.

146.51

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 5 (v) When there was a reasonable possibility of flammable atmospheres being present, material-handling equipment and hand tools were not of the type to prevent sources of ignition:

OPTION 6 (vi) Drums and containers were not opened in such a manner that excess interior pressure would be safely relieved.

If pressure could not be relieved from a remote location, appropriate shielding was not placed between the employee and the drums or containers to reduce the risk of employee injury:

OPTION 7 (vii) Employees stood upon or worked from drums or containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

1 29 CFR 1910.120(j)(3): Material-handling equipment used to transfer drums and containers was not selected, positioned, and/or operated to minimize sources of ignition related to the equipment from igniting vapors released from ruptured drums or containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(j)(4): Drums and containers containing radioactive wastes were handled before such time as their hazard to employees was properly assessed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.52

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(5)(i): All non-essential employees were not evacuated from the area where drums and containers containing or suspected of containing shock-sensitive waste were being handled:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: Drums and containers containing shock-sensitive or explosive materials are considered to contain shock- sensitive or explosive materials until they have been clarified.

2 29 CFR 1910.120(j)(5)(ii): Material-handling equipment was not provided with explosive containment devices or protective shields to protect equipment operators from exploding containers in areas where drums or containers containing or suspected of containing shock-sensitive wastes were being handled:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(j)(5)(iii): An employee alarm system capable of being perceived above surrounding light and noise conditions was not used to signal the commencement and completion of explosive waste-handling activities in areas where drums or containers containing or suspected of containing shock-sensitive wastes were being handled:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.53

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(j)(5)(iv): Continuous communications were not maintained between the employee-in-charge of the immediate handling area and/or both the site safety and health supervisor and the command post until such time as the handling operation in areas where drums or containers containing or suspected of containing shock-sensitive wastes was being conducted:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(j)(5)(iv): Communication equipment or methods that could cause shock sensitive materials to explode were used in areas where drums or containers containing or suspected of containing shock-sensitive wastes were handled:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 3 29 CFR 1910.120(j)(5)(v): Drums and/or containers under pressure, as evidenced by bulging or swelling, were moved before such time as the cause of the excess pressure was determined:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.54

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(j)(5)(v): Drums and/or containers under pressure, as evidenced by bulging or swelling, were moved before such time as appropriate containment procedures had been implemented to protect employees from explosive relief of the drums or containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(j)(6)(i): Lab packs were not opened only when necessary and then not by an individual knowledgeable in the inspection, classification, and segregation of the containers within the pack according to the hazards of the wastes:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(j)(6)(ii): When crystalline material was noted on a container, the contents was not handled as a shock- sensitive waste:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.55

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(7): Containers and drums were not sampled in accordance with a sampling procedure which was part of the site safety and health plan developed for and available to employees and others at the specific worksite:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(j)(8)(i): Drums and containers were not identified and classified prior to packaging for shipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(j)(8)(ii): Drum or container staging areas were not kept to the minimum number necessary to identify and classify materials safely and prepare them for transport:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(j)(8)(iii): Staging areas were not provided with adequate access and egress routes:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.56

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(j)(8)(iv): Bulking of hazardous wastes was permitted before a thorough characterization of the materials had been completed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(j)(9)(i): Tanks and vaults containing hazardous substances were not handled in a manner similar to that for drums and containers, taking into consideration the size of the tank or vault:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(j)(9)(ii): Appropriate tank or vault entry procedures as described in the site safety and health plan were not followed whenever employees must enter a tank or vault:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(k)(2)(i): A decontamination procedure was not developed, communicated to employees, or implemented before any equipment or employee entered areas on site where potential for exposure to hazardous materials exists:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.57

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(k)(2)(ii): Standard operating procedures were not developed to minimize employee contact with hazardous substances or with equipment that had contacted hazardous materials:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(g) as appropriate.

OPTION 1 2 29 CFR 1910.120(k)(2)(iii): All employees leaving a contaminated area were not appropriately decontaminated:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 2 3 29 CFR 1910.120(k)(2)(iii): All contaminated clothing and/or equipment leaving a contaminated area was not appropriately disposed of or decontaminated:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.58

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(k)(2)(iv): Decontamination procedures were not monitored by the site safety and health supervisor to determine their effectiveness:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 2 2 29 CFR 1910.120(k)(2)(iv): Appropriate steps were not taken to correct deficiencies in decontamination procedures when they were found to be ineffective:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

3 29 CFR 1910.120(k)(3): Decontamination was not performed in geographical areas that would minimize the exposure of uncontaminated employees or equipment to contaminated employees or equipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.59

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(k)(4): All equipment and/or solvents used for decontamination were not decontaminated or disposed of properly:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

2 29 CFR 1910.120(k)(5)(i): Protective clothing and equipment were not decontaminated, cleaned, laundered, maintained, or replaced as needed to maintain their effectiveness:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 1 3 29 CFR 1910.120(k)(5)(ii): Employees whose non-impermeable clothing became wetted with hazardous substances did not immediately remove that clothing and/or proceed to shower:

(a) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.60

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(k)(5)(ii): The employer did not ensure that non-impermeable clothing that became wetted with hazardous substances was disposed of or decontaminated before it was removed from the work zone:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

2 29 CFR 1910.120(k)(6): Unauthorized employees removed protective clothing or equipment from change rooms:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

3 29 CFR 1910.120(k)(7): Commercial laundries or cleaning establishments that decontaminate protective clothing or equipment were not informed of the potentially harmful effects of exposures to hazardous substances:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.61

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(k)(8): Showers and/or change rooms meeting the requirements of 29 CFR 1910.141 were not provided where the decontamination procedure indicated a need for regular showers and change rooms outside of a contaminated area:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 2 2 29 CFR 1910.120(k)(8): Other effective means for cleansing were not provided and/or used when temperature conditions prevented the effective use of water:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

OPTION 1 3 29 CFR 1910.120(l)(1)(i): An emergency response plan was not developed and/or implemented by all employers within the scope of 29 CFR 1910.120(a)(1)(i)-(ii) prior to the commencement of hazardous waste operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(G) as appropriate.

146.62

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(l)(1)(i): The emergency response plan was not in writing and/or available for inspection and copying by employees, employee representatives, OSHA personnel, or other government agencies with relevant responsibilities:

(a) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

OPTIONS 1-11 1 29 CFR 1910.120(l)(2) * : The employer did not develop an emergency response plan that addressed: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(xi)):

   NOTE:  These SAVEs listed under Options 1-11 may be grouped with
        29 CFR 1910.120(b)(4)(ii)(H) as appropriate.

OPTION 1 (i) Pre-emergency planning:

OPTION 2 (ii) Personnel roles, lines of authority, and communication:

OPTION 3 (iii) Emergency recognition and prevention:

OPTION 4 (iv) Safe distances and places of refuge:

OPTION 5 (v) Site security and control:

OPTION 6 (vi) Evacuation routes and procedures:

NOTE: Options 7 through 11 top of next page.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 7 (vii) Decontamination procedures not covered by the site safety and health plan:

OPTION 8 (viii) Emergency medical treatment and first aid:

OPTION 9 (ix) Emergency alerting and response procedures:

OPTION 10 (x) Critique of response and follow-up:

OPTION 11 (xi) PPE and emergency equipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTIONS 1-2 1 29 CFR 1910.120(l)(3)(i) * : The employer did not include in the emergency response plan the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A) or (B)):

NOTE: These SAVEs listed under Options 1 and 2 may be grouped with 29 CFR 1910.120(b)(4)(ii)(H0 as appropriate.

OPTION 1 (A) Site topography, layout, and prevailing weather conditions:

OPTION 2 (B) Procedures for reporting incidents to local, State, and Federal Government agencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.64

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(l)(3)(ii): The emergency response plan was not maintained as a separate section of the Site Safety and Health Plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

2 29 CFR 1910.120(l)(3)(iii): The emergency response plan was not compatible and integrated with the disaster, fire, and/or emergency response plans of local, State, and/or Federal agencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

3 29 CFR 1910.120(l)(3)(iv): The emergency response plan was not rehearsed regularly as part of the overall training program for site operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(l)(3)(v): The emergency response plan was not reviewed periodically or amended as necessary to keep it current with new or changing site conditions:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

OPTIONS 1-3 2 29 CFR 1910.120(l)(3)(vi): An employee alarm system was not installed in accordance with 29 CFR 1910.165 to notify employees of an emergency situation: ENTER THE APPROPRIATE OPTION:

   NOTE:  These SAVEs listed under Options 1-3 may be grouped with
        29 CFR 1910.120(b)(4)(ii)(H) as appropriate.

OPTION 1 To stop work activities if necessary:

OPTION 2 To lower background noise to speed communication:

OPTION 3 To begin emergency procedures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE) 146.66

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(l)(3)(vii): Based upon the information available at the time of the emergency, the employer did not evaluate the incident and the site response capabilities and/or proceed with the appropriate steps to implement the site emergency response plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b)(4)(ii)(H) as appropriate.

2 29 CFR 1910.120(m): While work was in progress, areas accessible to employees were not lighted to not less than the minimum illumination intensities listed in Table H-120.1:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(n)(1)(i): An adequate supply of potable water was not provided on the site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 4 29 CFR 1910.120(n)(1)(ii): Portable containers used to dispense drinking water were not capable of being tightly closed and/or were not equipped with a tap:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.67

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(n)(1)(ii): Water was dipped from containers:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 2 29 CFR 1910.120(n)(1)(iii): A container used to distribute drinking water was not clearly marked as to the nature of its contents:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 2 3 29 CFR 1910.120(n)(1)(iii): A container used to distribute drinking water was used for another purpose:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

4 29 CFR 1910.120(n)(1)(iv): Where single service cups were supplied, a sanitary container for the unused cups and/or a receptacle for disposing of the used cups were not provided:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.68

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(n)(2)(i): The employer did not identify outlets for nonpotable water to indicate clearly that the water was unsafe and was not to be used for drinking, washing, or cooking purposes:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(n)(2)(ii): There was an open, or potential, cross-connection between a system furnishing potable water and a system furnishing nonpotable water:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(n)(3)(i): Toilets were not provided for employees in accordance with the requirements contained in Table H-120.2:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(n)(3)(ii): Under temporary field conditions, provisions were not made to assure that at least one toilet facility was available:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.69

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-4 1 29 CFR 1910.120(n)(3)(iii) * : The hazardous waste site, which was not provided with a sanitary sewer, although not prohibited by local codes, was not provided with: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(D)):

OPTION 1 (A) Chemical toilets:

OPTION 2 (B) Recirculating toilets:

OPTION 3 (C) Combustion toilets:

OPTION 4 (D) Flush toilets:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(n)(3)(v): Doors entering toilet facilities were not provided with entrance locks controlled from inside the facilities:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(n)(4): Food service facilities and operations for employees did not meet applicable laws, ordinances, and regulations of the jurisdictions in which they were located:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.70

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(n)(5): When temporary sleeping quarters were provided, they were not heated, ventilated, and lighted:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(n)(6): Adequate washing facilities were not provided for employees engaged in operations where hazardous substances may be harmful to employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(n)(6): Washing facilities were not in near proximity to the worksite; in areas where exposures were below permissible exposure limits and published exposure levels and which were under the control of the employer; and were not so equipped as to enable employees to remove hazardous substances from themselves:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(n)(7): When hazardous waste clean-up or removal operations had commenced on a site and the duration of the work required six months or longer to complete, showers and change rooms were not provided for all employees exposed to hazardous substances and health hazards involved in hazardous waste clean- up or removal operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.71

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(n)(7)(i): Showers meeting the requirements of 29 CFR 1910.141(d)(3) were not provided:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(n)(7)(ii): Change rooms meeting the requirements of 29 CFR 1910.141(e) were not provided:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(n)(7)(ii): Change rooms did not consist of two separate change areas separated by the shower area required in 29 CFR 1910.120(n)(7)(i):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 3 4 29 CFR 1910.120(n)(7)(ii): One change area, with an exit leading off the worksite, did not provide employees with a clean area where they could remove, store, and put on street clothing:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 4 1 29 CFR 1910.120(n)(7)(ii): The second change area, with an exit to the worksite, did not provide employees with an area where they could put on, remove, and store work clothing and personal protective equipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(n)(7)(iii): Showers and change rooms were not located in areas where exposures were below the permissible exposure limits and published exposure levels:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(n)(7)(iii): Where showers and change rooms were not feasible, a ventilation system was not provided that would supply air that was below the permissible exposure limits and published exposure levels:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(n)(7)(iv): The employer did not ensure that employees showered at the end of their work shift and when leaving the hazardous waste site:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.73

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(o)(1): Procedures were not developed for the introduction of effective new technologies and equipment for the improved protection of employees working with hazardous waste operations and were not implemented as part of the site safety and health program to assure that employee protection was being maintained:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(o)(2): New technologies, equipment, or control measures available to the industry to suppress the level of air contaminants while excavating the site or for spill control were not evaluated by employers or their representatives:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(o)(2): An evaluation to determine the effectiveness of the new methods, materials, or equipment was not done before they were used on a large scale for enhancing employee protection:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.74

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(p)(1): Employers conducting operations at treatment, storage, and disposal (TSD) facilities specified in 29 CFR 1910.120(a)(1)(iv) and who are not exempted by 29 CFR 1910.120(a)(2)(iii) did not provide and/or implement a written safety and health program for employees involved in hazardous waste operations that was available for inspection by employees and their representatives:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: See the Notes and Exceptions to 29 CFR 1910.120(a)(2)(iii) for employers not covered.

OPTION 2 2 29 CFR 1910.120(p)(1): The program was not designed to identify, evaluate and control safety and health hazards in their facilities for the purpose of employee protection, to provide for emergency responses meeting the requirements of 29 CFR 1910.120(p)(8), and to address as appropriate site analysis, engineering controls, maximum exposure limits, hazardous waste handling procedures, and uses of new technologies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (p)(8)(i) as appropriate.

146.75

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(p)(2): A hazard communication program meeting the requirements of 29 CFR 1910.1200, was not implemented as part of the employer's safety and health program:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with violations of 29 CFR 1910.1200 as appropriate.

2 29 CFR 1910.120(p)(3): A medical surveillance program meeting the requirements of 29 CFR 1910.120(f) was not developed and implemented:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with violations of 29 CFR 1910.120(f) as appropriate.

3 29 CFR 1910.120(p)(4): A decontamination procedure meeting the requirements of 29 CFR 1910.120(k) was not developed and implemented:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with violations of 29 CFR 1910.120(k) as appropriate.

146.76

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(p)(5): Procedures meeting the requirements of 29 CFR 1910.120(o) for introducing new and innovative equipment into the workplace were not developed and implemented:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with violations of 29 CFR 1910.120(o) as appropriate.

2 29 CFR 1910.120(p)(6): Where employees will be handling drums or containers, procedures meeting the requirements of 29 CFR 1910.120(j)(1)(ii) through (j)(1)(viii) and (xi), as well as (j)(3) and (j)(8), were not developed and implemented prior to such work:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with violations of 29 CFR 1910.120(j)(1)(ii) through (viii) and (xi), 29 CFR 1910.120(j)(3) and (j)(8) as appropriate.

OPTION 1 3 29 CFR 1910.120(p)(7)(i): A training program for employees exposed to health hazards or hazardous substances at TSD operations was not developed and implemented to enable employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.77

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(p)(7)(i): Initial training for 24 hours and/or refresher training for 8 hours annually was not provided for employees exposed to health hazards or hazardous substances at TSD operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 3 2 29 CFR 1910.120(p)(7)(i): Employees who had received the initial training required were not given a written certificate attesting that they had successfully completed such training:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(p)(7)(ii): Current employees did not receive 8 hours of refresher training annually:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.78

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(p)(7)(iii): Trainers who taught initial training had not satisfactorily completed a training course for teaching the subjects they were expected to teach:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(p)(7)(iii): Trainers who taught initial training did not have the academic credentials and instruction experience necessary to demonstrate a good command of the subject matter of the courses and competent instructional skills:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 3 29 CFR 1910.120(p)(8)(i): The employer did not develop and implement an emergency response plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 4 29 CFR 1910.120(p)(8)(i): The emergency response plan was not a part of the safety and health program developed by the employer as required in 29 CFR 1910.120(p)(1):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (p)(1) Option 2 as appropriate.

146.79

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 3 1 29 CFR 1910.120(p)(8)(i): An emergency action plan in accordance with 29 CFR 1910.38(a) was not provided by the employer who will evacuate their employees from the danger area when an emergency occurs and who do not permit any of their employees to assist in handling the emergency:

(a) (LOCATION) IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with a violation of 29 CFR 1910.38(a) as appropriate.

OPTIONS 1-11 2 29 CFR 1910.120(p)(8)(ii) * : An emergency response plan for emergencies that addressed, to the extent not addressed in any specific program required in this paragraph, the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(K)):

OPTION 1 (A) Pre-emergency planning and coordination with outside parties:

OPTION 2 (B) Personnel roles, lines of authority, and communication:

OPTION 3 (C) Emergency recognition and prevention:

OPTION 4 (D) Safe distances and places of refuge:

OPTION 5 (E) Site security and control:

OPTION 6 (F) Evacuation routes and procedures:

NOTE: Options 7 through 11 are continued on the next page.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 7 (G) Decontamination procedures:

OPTION 8 (H) Emergency medical treatment and first aid:

OPTION 9 (I) Emergency alerting and response procedures:

OPTION 10 (J) Critique of response and follow-up:

OPTION 11 (K) PPE and emergency equipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 1 29 CFR 1910.120(p)(8)(iii)(A): Training for emergency response employees was not completed before they were called upon to perform in real emergencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(p)(8)(iii)(A): Training given to emergency response employees did not include the elements of the emergency response plan, standard operating procedures the employer had established for the job, personal protection equipment to be worn, and procedures for handling emergency incidents:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.81

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(p)(8)(iii)(B): Employee members of TSD facility emergency response organizations were not trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(p)(8)(iii)(C): The employer did not certify that each covered employee had attended and successfully completed the training required in 29 CFR 1910.120(p)(8)(iii):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(p)(8)(iii)(C): The employer did not certify the employee's competence at least yearly:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 3 4 29 CFR 1910.120(p)(8)(iii)(C): The method used to demonstrate competency for certification of training was not recorded and maintained by the employer:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.82

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-2 1 29 CFR 1910.120(p)(8)(iv)(A) * : The emergency response plan did not include the following elements to the extent that they did not repeat any information already contained in the emergency response plan: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((1) or (2)):

OPTION 1 (1) Site topography, layout, and prevailing weather conditions:

OPTION 2 (2) Procedures for reporting incidents to local, State, and Federal Governmental agencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(p)(8)(iv)(B): The emergency response plan was not compatible and integrated with the disaster, fire, and/or emergency response plans of local, State, and/or Federal agencies:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(p)(8)(iv)(C): The emergency response plan was not rehearsed regularly as part of the overall training program for site operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.83

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(p)(8)(iv)(D): The site emergency response plan was not reviewed periodically and amended, as necessary, to keep it current with new or changing site conditions or information:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

2 29 CFR 1910.120(p)(8)(iv)(E): An employee alarm system was not installed in accordance with 29 CFR 1910.165 to notify employees of an emergency situation; to stop work activities if necessary; to lower background noise to speed communication; and to begin emergency procedures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(p)(8)(iv)(F): Based upon information available at the time of the emergency, the employer did not evaluate the incident and the site response capabilities and proceed with the appropriate steps to implement the site emergency response plan:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 4 29 CFR 1910.120(q)(1): Employers whose employees were engaged in emergency response no matter where it occurs except for employees engaged in operations specified in 29 CFR 1910.120(a)(1)(i) through (a)(1)(iv), did not develop and implement an emergency response plan to handle anticipated emergencies prior to commencement of emergency response operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.84

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(q)(1): The emergency response plan was not in writing and was not available for inspection and copying by employees and their representatives:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTIONS 1-11 2 29 CFR 1910.120(q)(2) * : The emergency response plan did not address, to the extent not addressed elsewhere, the: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((i)-(xi)):

OPTION 1 (i) Pre-emergency planning and coordination with outside parties:

OPTION 2 (ii) Personnel roles, lines of authority, and communication:

OPTION 3 (iii) Emergency recognition and prevention:

OPTION 4 (iv) Safe distances and places of refuge:

OPTION 5 (v) Site security and control:

OPTION 6 (vi) Evacuation routes and procedures:

OPTION 7 (vii) Decontamination:

OPTION 8 (viii) Emergency medical treatment and first aid:

   NOTE:  Options 9 through 11 are continued top of next page.
                              146.85

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 9 (ix) Emergency alerting and response procedures:

OPTION 10 (x) Critique of response and follow-up:

OPTION 11 (xi) PPE and emergency equipment:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 1 29 CFR 1910.120(q)(3)(i): The senior emergency response official responding to an emergency did not become the individual in charge of a site-specific Incident Command System (ICS):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 2 29 CFR 1910.120(q)(3)(i): All emergency responders and their communications were not coordinated and controlled through the individual in charge of the ICS, assisted by the senior official present for each employer:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

3 29 CFR 1910.120(q)(3)(ii): The individual in charge of the ICS did not identify, to the extent possible, all hazardous substances or conditions present and did not address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and use of any new technologies:

(a) (LOCATION) (I ENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(q)(3)(iii): Based on the hazardous substances and/or conditions present, the individual in charge of the ICS did not implement appropriate emergency operations and did not assure that the personal protective equipment worn was appropriate for the hazards to be encountered:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 2 2 29 CFR 1910.120(q)(3)(iii): Personal protective equipment did not meet the criteria contained in 29 CFR 1910.156(e) when worn while performing firefighting operations beyond the incipient stage for any incident:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

3 29 CFR 1910.120(q)(3)(iv): Positive-pressure self-contained breathing apparatus was not worn by employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or potential inhalation hazard, until such time that the individual in charge of the ICS determined through the use of air monitoring that a decreased level of respiratory protection would not result in hazardous exposures to employees:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with violation of 29 CFR 1910.134 as appropriate.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.120(q)(3)(v): The individual in charge of the ICS did not limit the number of emergency response personnel at the emergency site, in those areas of potential or actual exposure to incident or site hazards, to those who were actively performing emergency operations:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 2 2 29 CFR 1910.120(q)(3)(v): All operations performed by groups of two or more in hazardous areas were not performed using the buddy system:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 3 29 CFR 1910.120(q)(3)(vi): Back-up personnel did not stand by with equipment ready to provide assistance or rescue:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 4 29 CFR 1910.120(q)(3)(vi): Advanced first aid support personnel did not stand by with medical equipment and transportation capability:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (q)(2)(viii) as appropriate.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(q)(3)(vii): The individual in charge of the ICS did not designate a safety officer, who was knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and provide direction with respect to the safety of operations for the emergency at hand:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 2 29 CFR 1910.120(q)(3)(viii): When the safety official judged activities to be an IDLH condition and/or to involve an imminent danger condition, the safety official did not have the authority to alter, suspend, or terminate those activities:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(q)(3)(viii): The safety official did not immediately inform the individual in charge of the ICS of any actions that needed to be taken to correct the hazards at the emergency scene:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

4 29 CFR 1910.120(q)(3)(ix): The individual in charge of the ICS did not implement appropriate decontamination procedures after emergency operations had terminated:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(q)(3)(x): Compressed air cylinders used with self-contained breathing apparatus did not meet U.S. Department of Transportation and the National Institute for Occupational Safety and Health criteria:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 1 2 29 CFR 1910.120(q)(4): Skilled support personnel, such as those operating earth moving or digging equipment or cranes and hoisting equipment who would or could be exposed to the hazards at an emergency response scene, were not given an initial briefing at the site prior to their participation in any emergency response:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(q)(4): The initial briefing did not include instruction in the wearing of appropriate personal protective equipment, what chemical hazards were involved, and what duties were to be performed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 3 4 29 CFR 1910.120(q)(4): All other appropriate safety and health precautions provided to the employer's own personnel were not used to assure the safety and health of those skilled support personnel:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(q)(5): Employees who, in the course of their regular job duties, worked with and were trained in the hazards of specific hazardous substances and who were called upon to provide technical advice or assistance to the individual in charge at a hazardous substance release incident did not receive training or demonstrate competency in the area of their specialization annually:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (q)(6) as appropriate.

OPTION 1 2 29 CFR 1910.120(q)(6): Training was not based on the duties and function to be performed by each responder of an emergency response organization:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTION 2 3 29 CFR 1910.120(q)(6): The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, were not conveyed to them through training before they were permitted to take part in actual emergency operations on an incident:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(i) * : Employees who participated, or were expected to participate, in emergency response as first responders at the awareness level did not have sufficient training or sufficient experience to objectively demonstrate competency in: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):

NOTE: These SAVEs listed under Options 1-6 below may be grouped with 29 CFR 1910.120(q)(6) as appropriate.

OPTION 1 (A) An understanding of what hazardous substances are and the risk associated with them in an incident:

OPTION 2 (B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present:

OPTION 3 (C) The ability to recognize the presence of hazardous substances in an emergency:

OPTION 4 (D) The ability to identify hazardous substances, if possible:

OPTION 5 (E) An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and the U.S. Department of Transportation's Emergency Response Guidebook:

OPTION 6 (F) The ability to realize the need for additional resources and to make appropriate notifications to the communication center:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(ii) * : Employees who participated, or were expected to participate, in emergency response as first responders at the operational level had not received at least 8 hours of training and/or had not been certified as having such training and/or did not have sufficient experience to demonstrate competency, in addition to the areas listed for the awareness levels, in: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):

NOTE: These SAVEs listed under Options 1-6 below may be grouped with 29 CFR 1910.120(q)(6) as appropriate.

OPTION 1 (A) Knowledge of basic hazard and risk assessment techniques:

OPTION 2 (B) Know how to select and use proper personal protective equipment provided to the first responder operational level:

OPTION 3 (C) An understanding of basic hazardous materials terms:

OPTION 4 (D) Know how to perform basic control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit:

OPTION 5 (E) Know how to implement basic decontamination procedures:

OPTION 6 (F) An understanding of the relevant standard operating procedures and termination procedures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.93

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-9 1 29 CFR 1910.120(q)(6)(iii) * : Employees who participated, or were expected to participate, as hazardous material technicians had not received at least 24 hours of training equal to the first responder operations level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(I)):

   NOTE:  These SAVEs listed under Options 1-9 below may be grouped
           with 29 CFR 1910.120(q)(6) as appropriate.

OPTION 1 (A) Know how to implement the employer's emergency response plan:

OPTION 2 (B) Know the classification, identification, and verification of known and unknown materials by using field instruments and equipment:

OPTION 3 (C) Be able to function within an assigned role in the Incident Command System:

OPTION 4 (D) Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician:

OPTION 5 (E) Understand hazard and risk assessment techniques:

OPTION 6 (F) Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit:

OPTION 7 (G) Understand and implement decontamination procedures:

NOTE: Option 8 and 9 are continued on the following page.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 8 (H) Understand termination procedures:

OPTION 9 (I) Understand basic chemical and toxicological terminology and behavior:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

OPTIONS 1-9 1 29 CFR 1910.120(q)(6)(iv) * : Employees who participated, or were expected to participate, as hazardous material specialists had not received 24 hours of training equal to the hazardous materials technician level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(I)):

OPTION 1 (A) Know how to implement the local emergency response plan:

OPTION 2 (B) Understand classification, identification, and verification of known and unknown materials by using advanced survey instruments and equipment:

OPTION 3 (C) Know the State emergency response plan:

OPTION 4 (D) Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist:

OPTION 5 (E) Understand in-depth hazard and risk assessment techniques:

NOTE: Option 6 through 9 are continued on the following page.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 6 (F) Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available:

OPTION 7 (G) Be able to determine and implement decontamination procedures:

OPTION 8 (H) Have the ability to develop a site safety and control plan:

OPTION 9 (I) Understand chemical, radiological, and toxicological terminology and behavior:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.96

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTIONS 1-6 1 29 CFR 1910.120(q)(6)(v) * : Employees who participated, or were expected to participate, as an on-scene incident commander had not received 24 hours of training equal to the first responder operations level and/or had not been certified as having such training and/or in addition did not have competency to: ENTER THE APPROPRIATE OPTION AND SUBPARAGRAPH * ((A)-(F)):

NOTE: These SAVEs listed under Options 1-6 below may be grouped with 29 CFR 1910.120(q)(6) as appropriate.

OPTION 1 (A) Know and be able to implement the employer's incident command system:

OPTION 2 (B) Know how to implement the employer's emergency response plan:

OPTION 3 (C) Know and understand the hazards and risks associated with employees working in chemical protective clothing:

OPTION 4 (D) Know how to implement the local emergency response plan:

OPTION 5 (E) Know the State emergency response plan and of the Federal Regional Response Team:

OPTION 6 (F) Know and understand the importance of decontamination procedures:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

146.97

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(q)(7): Trainers who taught the training subjects specified in 29 CFR 1910.120(q)(6) had not satisfactorily completed a training course for teaching the subjects they were expected to teach and/or did not have academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they were to teach:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

2 29 CFR 1910.120(q)(8)(i): Employees who were trained in accordance with 29 CFR 1910.120(q)(6) did not receive annual refresher training of sufficient content and duration to maintain their competencies or did not demonstrate competency in those areas at least yearly:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (q)(6) as appropriate.

OPTION 1 3 29 CFR 1910.120(q)(8)(ii): A statement of the training or competency of each employee was not made:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (q)(6) as appropriate.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.120(q)(8)(ii): The employer did not keep a record of the methodology used to demonstrate competency when a statement of competency was made:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (q)(6) as appropriate.

2 29 CFR 1910.120(q)(9)(i): Members of an organized and designated HAZMAT team and hazardous materials specialists did not receive a baseline physical examination and were not provided with medical surveillance as required in 29 CFR 1910.120(f):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (f) as appropriate.

3 29 CFR 1910.120(q)(9)(ii): Emergency response employees who exhibited signs or symptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident, either immediately or subsequently, were not provided with medical consultation as required in 29 CFR 1910.120(f)(3)(ii):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (f) as appropriate.

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.120(q)(10): Chemical protective clothing and equipment to be used by organized and designated HAZMAT team members, or to be used by hazardous materials specialists, did not meet the requirements of 29 CFR 1910.120(g)(3) through (5):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS)

NOTE: This SAVE may be grouped with 29 CFR 1910.120 (b) through (o) as appropriate.

2 29 CFR 1910.120(q)(11)(i): When it had been determined, upon completion of the emergency response, that it was necessary to remove hazardous substances, health hazards, and materials contaminated with them from the site of the incident, the employer conducting the clean-up did not comply with all of the requirements of 29 CFR 1910.120(b) through (o):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

OPTION 1 3 29 CFR 1910.120(q)(11)(ii): Where the clean-up was done on plant property using plant or workplace employees, such employees had not completed the training requirements of 29 CFR 1910.38(a); 1910.134; 1910.1200; and other appropriate safety and health training made necessary by the tasks that they were expected to perform:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

NOTE: This SAVE may be grouped with 29 CFR 1910.38(a), 29 CFR 1910.134 or 29 CFR 1910.1200 violations.

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OSHA Instruction CPl 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 4 29 CFR 1910.120(q)(11)(ii): Equipment to be used in the performance of clean-up work was not in serviceable condition and had not been inspected prior to use:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR DEPARTMENTS AND THE NUMBER OF EMPLOYEES EXPOSED) (DESCRIBE CONDITIONS AND EXPOSURE LEVELS, SHIFT, AND DATE)

146.101

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

Left Blank for Future Use

146.102

OSHA Instruction CPL 2.35 CH-11 JUNE 25, 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.145(c)(3):Safety instruction sign(s) were not used where there was a need for general instructions and suggestions relative to safety measure(s):

(a) (LOCATION) (OPERATION AND/OR HAZARD(S) REQUIRING SIGN)

175

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.147(c)(1): The employer did not establish a program consisting of an energy control procedure and employee training to ensure that before any employee performed any servicing or maintenance on a machine or equipment where the unexpected energizing, start up or release of stored energy could occur and cause injury, the machine or equipment would be isolated, and rendered inoperative in accordance with 29 CFR 1910.147(c)(4):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

2 29 CFR 1910.147(c)(2)(i): Where an energy isolating device was not capable of being locked out, the employer's energy control program under 29 CFR 1910.147(c)(1) did not utilize a tagout system:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

3 29 CFR 1910.147(c)(2)(ii): The employer's tagout energy control program procedures did not successfully comply with 29 CFR 1910.147(c)(3) and no lockout was provided for employee protection:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT)

NOTE: IF THE EMPLOYER CAN DEMONSTRATE HIS TAGOUT ENERGY CONTROL PROCEDURES PROVIDES FULL EMPLOYEE PROTECTION AS LOCKOUT DEVICE WOULD, HE MAY USE THE TAGOUT EVEN IF THE MACHINE OR EQUIPMENT IS CAPABLE OF ACCEPTING A LOCKOUT DEVICE)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.147(c)(2)(iii): Where major replacement, repair, renovation or modification of machine or equipment was performed after January 2, 1990, the employer did not provide an energy isolating device designed to accept a lockout device:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY AND EQUIPMENT)

OPTION 2 2 29 CFR 1910.147(c)(2)(iii): New machines and equipment that were installed after January 2, 1990, were not provided with energy isolating devices designed to accept lockout devices:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT AND DATE
             INSTALLATION)

3 29 CFR 1910.147(c)(3)(i): The tagout device used on an energy isolating device, which was capable of being locked out, was not attached at the same location that the lockout device would have been attached:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINE OR EQUIPMENT)

NOTE: THIS REQUIREMENT IS NOT TO BE INCLUDED WITH THE ITEMS LISTED UNDER 29 CFR 1910.147(c)(2)(ii), BUT IS TO BE CITED INDEPENDENTLY. (FOR CITING 29 CFR 1910.147(c)(3)(i) AND (c)(3)(ii), SEE SAVE FOR 1910.147(c)(2)(ii)).

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.147(c)(4)(i): Procedures were not developed, documented and utilized for the control of potentially hazardous energy when employees were engaged in activities covered by this section:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT) (THIS
             INCLUDES ENFORCEMENT OF PROCEDURES)

NOTE: IF EMPLOYEES VERIFY THE USE OF CORD AND PLUG EQUIPMENT, INCLUDING INSTRUCTIONS AND PROCEDURES TO BE FOLLOWED, THEN THESE INSTRUCTIONS AND PROCEDURES MUST BE IN THE PROGRAM PROCEDURES. IN THE ABSENCE OF ANY OF THESE REQUIREMENTS, CITE UNDER THIS STANDARD AND SPECIFY AS TO THE CORD AND PLUG EQUIPMENT USED.

NOTE: SEE EXEMPTIONS; EMPLOYER NOT REQUIRED TO HAVE WRITTEN PROCEDURES WHEN ALL OF ITEMS 1-8 ARE IN EFFECT.

OPTION 1 2 29 CFR 1910.147(c)(4)(ii): The energy control procedures did not clearly and specifically outline the scope, purpose, authorization, rules, and techniques to be utilized for the control of hazardous energy, including, but not limited to Items A-D of this section:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 2 1 29 CFR 1910.147(c)(4)(ii): Energy control procedures did not provide a means to enforce compliance:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

NOTE: IF THE EMPLOYER PROVIDED FOR A MEANS TO ENFORCE COMPLIANCE, BUT DID NOT ENFORCE THAT MEANS, THEN HE IS IN VIOLATION OF 29 CFR 1910.147(c)(4)(i).

2 29 CFR 1910.147(c)(5)(i): Locks, tags, chains, wedges, key blocks, adapter pins, self-locking fasteners, or other hardware were not provided by the employer for isolating, securing, or blocking of machines or equipment from energy sources:

        (a)  (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR
              CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

OPTION 1 3 29 CFR 1910.147(c)(5)(ii): Lockout devices and tagout devices were not singularly identified:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

OPTION 2 4 29 CFR 1910.147(c)(5)(ii): Device other than lockout devices and tagout devices were used for controlling energy:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT) (SPECIFIC DEVICES USED)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 3 1 29 CFR 1910.147(c)(5)(ii): Lockout devices and tagout devices were utilized for other purposes than controlling energy:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT) (EXPLAIN OTHER PURPOSES)

2 29 CFR 1910.147(c)(5)(ii)(A)(1): Lockout and tagout devices were not durable; they were not capable of withstanding the environment to which they were exposed for the maximum period of time that exposure was expected:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

OPTION 1 3 29 CFR 1910.147(c)(5)(ii)(A)(2): Tagout devices were not constructed so that exposure to wet and damp locations would not cause the tag to deteriorate:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

OPTION 2 4 29 CFR 1910.147(c)(5)(ii)(A)(2): Tagout devices were not printed so that exposure to wet and damp locations would not cause the message on the tag to become illegible:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

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OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.147(c)(5)(ii)(A)(3): Tags in use were not durable to prevent their deterioration in corrosive environments such as areas where acid and alkali chemicals were handled and stored:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT AND CHEMICALS)

OPTION 1 2 29 CFR 1910.147(c)(5)(ii)(B): Lockout and tagout devices were not standardized within the facility in at least one criteria: Color; shape; or size:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

OPTION 2 3 29 CFR 1910.147(c)(5)(ii)(B): Print and format utilized for tagout devices were not standardized within the facility:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

4 29 CFR 1910.147(c)(5)(ii)(C)(1): Lockout devices were not substantial enough to prevent removal without the use of excessive force or unusual techniques, such as with the use of bolt cutters or other metal cutting tools:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

175.6

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

OPTION 1 1 29 CFR 1910.147(c)(5)(ii)(C)(2): Tagout devices and their means of attachment were not substantial enough to prevent inadvertent or accidental removal:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT, DEVICE AND MEANS OF ATTACHMENT)

OPTION 2 2 29 CFR 1910.147(c)(5)(ii)(C)(2): Means of attachment of tagout devices utilized by the employer were not of a non- reusable type, attachable by hand, self-locking, and non- releasable with a minimum unlocking strength of no less than 50 pounds:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT, DEVICE AND MEANS OF ATTACHMENT)

3 29 CFR 1910.147(c)(5)(ii)(D): Lockout devices and tagout devices did not indicate the identity of the employee applying the device(s):

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

4 29 CFR 1910.147(c)(5)(iii): Tagout devices utilized did not warn against hazardous conditions if the machine or equipment was energized:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY AND EQUIPMENT)

175.7

OSHA Instruction CPL 2.35 CH-14 DEC 03 1990 Office of General Industry Compliance Assistance

1 29 CFR 1910.147(c)(6)(i): The employer did not conduct an annual or more frequent inspection of the energy control procedure to ensure that the procedure and requirements of this standard were followed:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT AND DATE OF LAST INSPECTION)

2 29 CFR 1910.147(c)(6)(i)(A): The periodic inspection of the energy control procedure was not performed by an authorized employee other than the one utilizing the energy control procedure being inspected:

(a) (LOCATION) (IDENTIFY SPECIFIC OPERATIONS AND/OR CONDITIONS) (IDENTIFY MACHINERY OR EQUIPMENT)

3 29 CFR 1910.147(c)(6)(i)(B): The periodic inspection of the energy control procedure was not conducted to correct any deviations or inadequacies
Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.