BUDGET ITEM SIGN-OFF SHEET

BUDGET ITEM #6: HAZMAT Level A Suits for Emergency Response Team: $2,360.00

Relevant Standard: OSHA 29 CFR 1910.120(H)&(c)(5)

Justification of Item: In the case of a hazardous chemical spill, company policy is to have a minimum of two Emergency Response Team (ERT) members respond and two stand by as backup. Level A suits provide the minimum requirements for responding to such an emergency. Use of training suits provide ERT members the opportunity to become familiar with the chemical suits prior to an incident and to minimize panic in an emergency. Each ERT member should be trained in these suits and self-contained breathing apparatus (SCBAs).

Implement as Stated Above:
Concur: HR______ Date _______________ MGR _____ Date _______________ PRES _____ Date _______________

Accept Risk of Criticality 2, Freq 2 = 2:
Concur: HR______ Date _______________ MGR _____ Date _______________ PRES _____ Date _______________

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I would also attach, as an appendix, a copy of the referenced standard—in this case OSHA Section 1910.120 and boldface or highlight the parts of the standard that support your proposal.

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APPENDIX A—THE OSHA STANDARD

1910.120: Hazardous Waste Operations and Emergency Response

    (a) Scope, application, and definitions. . .

    (iii) Voluntary clean up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;

    (iv) Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and

    (v) Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.

    (2) Application. (i) All requirements of Part 1910 and Part 1926 of Title 29 of the Code of Federal Regulations apply pursuant to their terms to hazardous waste and emergency response operations whether covered by this section or not. If there is a conflict or overlap, the provision more protective of employee safety and health shall apply without regard to 29 CFR 1910.5(c)(1).

    (ii) Hazardous substance clean up operations within the scope of paragraphs (a)(1)(i) through (a)(1)(iii) of this section must comply with all paragraphs of this section except paragraphs (p) and (q). . .

    (b) Safety and health program.

Note to (b): Safety and health programs developed and implemented to meet other federal, state, or local regulations are considered acceptable in meeting this requirement if they cover or are modified to cover the topics required in this paragraph. An additional or separate safety and health program is not required by this paragraph.

    (1) General. (i) Employers shall develop and implement a written safety and health program for their employees involved in hazardous waste operations. The program shall be designed to identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations.

    (ii) The written safety and health program shall incorporate the following:

    (A) An organizational structure;

    (B) A comprehensive workplan;

    (C) A site specific safety and health plan which need not repeat the employer's standard operating procedures required in paragraph (b)(1)(ii)(F) of this section;

    (D) The safety and health training program.

    (5) Personal protective equipment (PPE) shall be provided and used during initial site entry in accordance with the following requirements:

    (i) Based upon the results of the preliminary site evaluation, an ensemble of PPE shall be selected and used during initial site entry which will provide protection to a level of exposure below permissible exposure limits and published exposure levels for known or suspected hazardous substances and health hazards and which will provide protection against other known and suspected hazards identified during the preliminary site evaluation. If there is no permissible exposure limit or published exposure level, the employer may use other published studies and information as a guide to appropriate personal protective equipment. . .

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