A PROGRAM APPROACH FOR SITE SAFETY AT OIL SPILLS1

Abstract

ABSTRACT When OSHA developed the hazardous waste operations (Hazwoper) regulations (29 CFR 1910.120) members of the response community envisioned a separation of oil and “hazmat” response operations. Organizations that deal with oil spills have had difficulty applying Hazwoper regulations to oil spill operations. This hinders meaningful implementation of the standard for their personnel. We should approach oil spills with the same degree of caution that is applied to hazmat response. Training frequently does not address the safety of oil spill response operations. Site-specific safety and health plans often are neglected or omitted. Certain oils expose workers to carcinogens, as well as chronic and acute hazards. Significant physical hazards are most important. In responding to oil spills, the hazards must be addressed. It is the authors' contention that a need exists for safety programs at oil spill sites. Gone are the days of labor pool hires cleaning up spills in jeans and sneakers. The key to meaningful programs for oil spills requires application of controls focused on relevant safety risks rather than minimal chemical exposure hazards. Working with concerned reviewers from other agencies and organizations, we have developed a generic safety and health program for oil spill response. It is intended to serve as the basis for organizations to customize their own written safety and health program (required by OSHA). It also provides a separate generic site safety plan for emergency phase oil spill operations (checklist) and long term post-emergency phase operations.