Purpose

OSHA personnel are not first responders. Normally, OSHA provides only technical assistance and information during the active stages of response and mitigation. Chemical releases, fire, explosions, collapses, and other events have an immediate and potentially long-term affect not only to the workers involved, but also to those entities responding to or investigating the incident. This includes OSHA employees. No evidence or investigation is of such importance that OSHA employees should endanger themselves or others in the course of OSHA’s work.

Scope

This procedure serves as a guideline for protecting OSHA employees during incident/accident investigations.

Definitions

1. Hot zone. The incident area at a site where there is or may be the presence of hazardous materials that can or could pose a serious hazard to an employee if it is entered without appropriate personal protective devices.

2. Mitigation. Using any device, method, or system to lessen the hazard to an employee at an incident.

3. Special Hazard Investigation. Investigations that include the need to utilize SCBAs or other uniquely personal protective equipment.

Responsibilities

1. Responsible OSHA Manager(s) will ensure that:

   1. Employees responding to incidents are trained and qualified in the necessary procedures and directives.

   2. Employees are familiar with this procedure.

   3. There is coordination with the Region, the Health Response Team, and the National Office.

2. The investigating employee will make sure that appropriate personal protective equipment and monitoring equipment are brought to the scene and are in proper working order.

Procedures

1. When investigating an incident or accident:

   1. Report to the On Scene Incident Commander, when one exists, before entering the site;

   2. Determine what site assessments, if any, have been made and if any mitigation has taken place;

   3. In conjunction with the Incident Command System, identify "hot" zones that may be present;

   4. DO NOT enter any "hot" zone without appropriate personal protective equipment and monitors;

   5. Establish evidence protocols and security with appropriate parties;

   6. DO NOT under any circumstances enter or access any structure or equipment whose structural integrity or safety may have been compromised or is in question. A structural engineer must be consulted, and the area and/or equipment secured before entry or access is made;

   7. Keep open communication with the Responsible OSHA Manager(s) and provide sufficient detail in keeping them appraised of developing situations;

   8. Direct media inquiries to the Responsible OSHA Manager(s); and

   9. Maintain sufficient safe distance until the "All Clear" is given.

2. Assistance or Expertise

   1. If assistance or expertise is needed, contact the Responsible OSHA Manager(s) and identify the necessity.

   2. The Responsible OSHA Manager(s) will coordinate with the Assistant Regional Administrator for Enforcement Programs or equivalent unit for specific equipment and expertise, such as the Health Response Team, structural engineers, and chemical engineers.

3. Training

   All employees who could be involved in incident investigations will receive training on this chapter annually.