SlideShare a Scribd company logo
1 of 137
Download to read offline
Unexploded ordnance (UXO) are explosive weapons such as bombs, mines, bullets, grenades, and/or 
shells that did not explode when they were used. As a result of this weapons failure, the UXO poses a 
risk of detonation, potentially many years after they were either used or discarded. Another term used in 
place of UXO is Munitions and Explosives of Concern, or MEC. Throughout this manual, the term of UXO 
will be used. 
Unexploded ordnance poses a hazard worldwide, in both current and former military firing ranges and 
combat areas. UXO can be found on the North American continent dating as far back as the American 
Civil War. Even UXO this old still poses a threat. One of the primary safety hazards with unexploded 
ordnance is that the detonator and main charge deteriorate over time, frequently making them more 
sensitive to being disturbed, and therefore more 
dangerous to handle. One of the most feared 
UXOs is corroded artillery shells containing 
chemical warfare agents such as mustard gas. 
There are numerous examples of civilians 
carelessly tampering with unexploded ordnance 
that is many years old. Unfortunately, these 
experiences are often fatal and are not always 
limited to uneducated civilians. For this reason it 
is universally recommended that unexploded 
ordnance should not be touched or handled by 
unqualified persons. Instead, the location should 
be reported to the local police so that trained and 
qualified professionals under closely controlled 
circumstances can render the device safe. 
German artillery shell from World War I left beside a field for disposal by the army 
in 2004 - still live and dangerous. 
A dramatic example of the global threat from 
UXO is the wreck of the SS Richard 
Montgomery, off the coast of Kent, England, which still contains 3,000 tons of munitions. When the Polish 
ship Kielce, a similar World War II wreck, exploded in 1967, it produced an earth tremor measuring 4.5 on 
the Richter scale. 
UXO cleanup in the continental United States involves more than 10 million acres of land and 1,400 
different sites. This is an area roughly the size of the state of Florida, with some individual sites in excess 
of 500 square miles. To date, construction crews throughout the continental United States are discovering 
UXO in new development areas and frequently have to halt construction efforts until the UXO can be 
rendered safe. According to the U.S. Environmental Protection Agency (EPA), UXO at more than 16,000 
inactive domestic military ranges within the United States pose an “imminent and substantial” public 
health risk and could require the largest environmental cleanup ever. Because it costs approximately 
$1,000 to demolish a single UXO on-site, estimated clean-up costs are in the tens of billions of dollars. 
Included in this cost estimate are site assessment, surveying and mapping, removing soil and/or 
vegetation from the site, transportation, and UXO technicians to manually detect munitions. 
Searching for UXOs is tedious work. It is not uncommon for 100 holes to be dug in the effort to locate one 
(1) UXO. In addition to the obvious danger of unintentional explosion, buried UXO poses an additional 
risk of environmental contamination. In some heavily used military training areas, munitions-related 
1 
Introduction 
HAZ-021-000-L 
Introduction HAZ-021-000-L
chemicals such as explosives and perchlorate from rocket fuel can enter soil and groundwater. One of the 
most obvious examples of this can be seen at the Massachusetts Military Reservation on Cape Code. 
Decades of artillery training at this site have contaminated the only drinking water for thousands of 
surrounding residents. An extensive UXO recovery effort is under way there. 
UXO on US military bases also causes problems for the EPA’s Base Realignment and Closure (BRAC) 
program. Through the BRAC program, the EPA works to restore former munition testing areas in order to 
transfer it to public use. The military uses millions of training rounds per year that lead to a substantial 
amount of UXO. One of the common questions associated with UXO efforts on military properties is 
whether or not the OSHA HAZWOPER standard applies on U.S. military property. This question was 
answered in March of 1996 in written correspondence between OSHA and the U.S. Army Corps of 
Engineers. Following is the text of the OSHA interpretation of the HAZWOPER standard: 
Colonel Walter J. Cunningham, Commanding 
Huntsville Division, 
U.S. Army Corps of Engineers 
Post Office Box 1600 
Huntsville, Alabama 35807-4301 
Dear Colonel Cunningham: 
This is in response to your memorandum to the Occupational Safety and Health Administration (OSHA) requesting 
clarification of whether the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 
CFR 1910.120 and 1926.65) applies to the remediation of unexploded conventional ordnance at formerly used defense 
sites (FUDS) and active military installations. 
Specifically, you asked whether 40-hour training for general site workers, mandated in 1910.120(e)(3) and 1926.65(e)(3), 
is necessary for workers engaged in site activities that are not ground-intrusive, such as brush clearing and surveying, in 
which the primary hazard is the detonation of unexploded conventional ordnance. In a subsequent telephone conversation 
with Mr. William Chaffin of your staff, Mr. Chaffin further clarified that the remediation sites involved unexploded ordnance 
both at and below the soil surface and that detonations could result if workers inadvertently stepped on or struck the 
ordnance with an axe. 
The Department of Transportation classifies conventional ordnance as a hazardous material in Title 49 of the Code of 
Federal Regulations Part 172.101 (49 CFR 172.101). Based on this classification, conventional ordnance meets the 
definition of a hazardous substance under OSHA's HAZWOPER standard. Accordingly, remediation work at FUDS and 
active military installation sites contaminated with unexploded conventional ordnance falls within the scope of the 
HAZWOPER standard. Workers performing remediation activities (including clearing and surveying activities) at these 
sites, therefore, must meet the intent of the 40 hours of instruction off the site and a minimum of three days supervised 
field experience in accordance with 29 CFR 1910.120(e)(3) (or 1926.65(e)(3)). 
Your letter expressed concerns that the 40-hour training currently provided to workers engaged in remediation activities 
on sites contaminated with unexploded conventional ordnance was of little value. Mr. Chaffin elaborated on this concern 
in a subsequent telephone conversation, indicating that the 40-hour "standard HAZWOPER course" provided to these 
workers does not address explosives hazards and therefore, does not seem pertinent to their work. We share your 
concerns and acknowledge that training that does not address the hazards present on the worksite is of little value. We do 
not agree, however, that the 40-hour training described by Mr. Chaffin and in your letter is consistent with the OSHA 
HAZWOPER standard. The OSHA standard does not mandate a rigid, "standard" curriculum for the 40-hour training 
requirement but rather specifies in paragraph (e)(2) of the standard that required training must address the safety and 
health hazards present on the site and the related procedures and controls necessary for worker protection. Accordingly, 
the training provided to workers engaged in remediation activities on sites contaminated with unexploded conventional 
ordnance must address the hazards of unexploded ordnance and the related controls, as well as other hazards 
associated with the remediation site and proposed activities. 
Compliance with the intent of the training requirements of 29 CFR 1910.120(e) or 1926.65(e) is achieved when 
employees are trained to a level required by their job functions and responsibilities. When sufficient training on safety and 
health issues pertinent to a specific worksite is provided to cleanup workers, but the specific number of hours required by 
the standard is not given, a de minimis violation may exist. If an employer complies with the clear intent of a standard but 
deviates from its particular requirements in a manner that has no direct or immediate relationship to employee safety or 
health, such a violation is characterized as de minimis. Citations are not issued for de minimis violations. 
2 
Introduction HAZ-021-000-L
We hope that this response provides the clarification you need. If you have further questions, please contact this office at 
(202) 219-8045. 
Sincerely, 
John B. Miles, Director 
Directorate of Compliance Programs 
Based on the interpretation above, Front Range Training and Consulting, has developed this 
HAZWOPER course to provide worksite specific hazard training to UXO employees. 
3 
Introduction HAZ-021-000-L
Notes 
4 
Introduction HAZ-021-000-L
There are numerous safety polices, guidelines, regulations and laws which govern clean-up activities on 
UXO sites. Without a firm understanding of these various rules, the UXO worker can be left with many 
unanswered questions. It is the goal of this Student Manual to clarify and explain the many different rules 
that govern activities on UXO sites, including but not limited to: 
· Resource Conservation and Recovery Act (RCRA) 
· Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) 
· Superfund Amendments and Reauthorization Act (SARA) 
· OSHA Hazardous Waste Operations and Emergency Response standard 
· Military Munitions Rule 
· Department of Defense Directive 6055.9 - DoD Explosives Safety Board 
· DoD Directive 4715.11 – Environmental and Explosives Safety Management on Active and 
· DoD Directive 4145.26M: Contractors’ Safety Manual for Ammunition and Explosives 
In addition to the above list, it is important for the reader to understand that there are specific policies and 
guidelines that impact UXO operations on military property. UXO personnel working on a federal facility 
must be aware of the specific policies, regulations and guidelines that are pertinent to that worksite. 
The Federal Emergency Management Agency (FEMA) is responsible for administering all of the federal 
government’s civil emergency planning, management, mitigation and assistance functions. FEMA is the 
primary federal agency responsible for planning and related training for hazardous materials emergency 
management. Their authority includes accidents at manufacturing, processing, storage and disposal 
facilities, as well as hazardous material in transit. 
The Environmental Protection Agency (EPA) exists to protect and enhance the environment. The EPA 
is the primary agency responsible for overseeing hazardous waste site operations and cleanup activities. 
The Department of Transportation (DOT) establishes the nation’s overall transportation policy and has 
responsibility for issuing standards and regulations relating to the transportation of hazardous materials. 
The DOT trains and inspects carriers and shippers of hazardous materials to ensure that they remain in 
full compliance with all applicable guidelines. 
The Department of Energy (DOE) coordinates and administers the national energy functions. With 
regard to hazardous materials, the DOE is heavily involved in administration of the radioactive waste 
generated by both the nuclear weapons program as well as by the nuclear reactors which provide much 
of the nation’s energy. 
The Department of Defense (DoD) manufactures, tests and discards the full range of hazardous 
materials and is also one of the nation’s largest shippers of these same hazardous materials. 
The Department of Labor (DOL) exists to maintain and/or improve the welfare of the nation’s workers. 
The Occupational Safety and Health Administration (OSHA) is one branch of the DOL. OSHA's 
5 
Regulatory Overview 
HAZ-021-001-L 
Inactive Ranges within the United States 
Responsibilities of Federal Agencies 
Regulatory Overview HAZ-021-001-L
mission is to prevent work-related injuries, illnesses, and deaths. OSHA has broad range in administering 
this mission throughout the nation. 
Resource Conservation and Recovery Act (RCRA)1 
There are numerous requirements contained within the Resource Conservation and Recovery Act 
(RCRA) that apply to managing, handling, transporting, storing and disposing of conventional explosive 
ordnance. RCRA gives the United States Environmental Protection Agency (EPA) the authority to 
develop a nationwide program to regulate hazardous waste from the point at which is created, through it’s 
lifespan until it is ultimately destroyed and/or disposed. 
Section 6001 of the RCRA states that "Each department of the Federal Government…engaged in any 
activity resulting in the disposal or management of solid or hazardous waste shall be subject to, and 
comply with, all federal, state, interstate, and local requirements, both substantive and procedural 
(including any requirements for permits and reporting)." 
The Federal Hazardous and Solid Waste Amendments (HSWA) are the 1984 amendments to RCRA that 
focused on waste minimization and phasing out land disposal of hazardous waste ,as well as corrective 
action for releases. Some of the other mandates of this law include increased enforcement authority for 
EPA and more stringent hazardous waste management standards. 
RCRA Compliance 
40 CFR 270.1(c) requires an RCRA permit for the owners and operators of any facility where solid or 
hazardous waste is treated, stored and/or disposed. Under RCRA, any hazardous waste generator is 
responsible for that waste from its "cradle to its grave." 
There are several definitions codified within RCRA that are important for the UXO worker to understand. 
Hazardous Waste: A solid waste, or combination of solid wastes, which because of its quantity, 
concentration, or physical, chemical, or infectious characteristics may: 
a. cause, or significantly contribute to an increase in mortality or an increase in serious 
irreversible, or incapacitating reversible, illness; or 
b. pose a substantial present or potential hazard to human health or the environment when 
improperly treated, stored, transported, or disposed of, or otherwise managed. 
c. any facility for the collection, source separation, storage, transportation, transfer, 
processing, treatment or disposal of solid wastes, including hazardous wastes, whether 
such facility is associated with facilities generating such wastes or not. 
Hazardous Waste Generator: Any person whose act or process produces hazardous waste or 
whose act causes a hazardous waste to become subject to regulation. 
Mixed Waste: Contains both hazardous waste and source, special nuclear, or by-product 
material subject to the Atomic Energy Act of 1954 (42 U.S.C. 2011 et seq.). 
Storage: The containment of hazardous waste, either on a temporary basis or for a period of 
years, in such a manner as not to constitute disposal of such hazardous waste. 
6 
1 http://www.epa.gov/lawsregs/laws/rcra.html 
Regulatory Overview HAZ-021-001-L
Treatment: Any method, technique, or process, including neutralization, designed to change the 
physical, chemical, or biological character or composition of any hazardous waste so as to 
neutralize such waste or so as to render such waste nonhazardous, safer for transport, amenable 
for recovery, amenable for storage, or reduced in volume. Such term includes any activity or 
processing designed to change the physical form or chemical composition of hazardous waste so 
as to render it nonhazardous. 
The EPA has also provided an interpretation of the RCRA regulation2 which states that explosives may 
indeed be a solid waste from the moment a decision is made that the explosives must be destroyed and 
not returned to the original owners. The basis for this decision is that the explosives are not being used 
for their originally-intended purpose (e.g., demolition of a building, military use, etc.), but rather are being 
detonated to discard the materials. The explosives, therefore, would meet the definition of a solid waste. If 
these explosives exhibit one of the characteristics of reactivity as defined below, they would be subject to 
the RCRA hazardous waste regulations for storage, treatment and disposal. 
Characteristics of Reactivity (per 40 CFR 261.23): 
If a representative sample of the explosive exhibits any of the following characteristics of reactivity, it shall 
be classified and treated as a solid waste according to RCRA regulation: 
1. It is normally unstable and readily undergoes violent change without detonating. 
2. It reacts violently with water. 
3. It forms potentially explosive mixtures with water. 
4. When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to 
present a danger to human health or the environment. 
5. It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 
12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to 
human health or the environment. 
6. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if 
7. It is readily capable of detonation or explosive decomposition or reaction at standard temperature 
8. It is a forbidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 
CFR 173.53 or a Class B explosive as defined in 49 CFR 173.88. 
Conventional explosive ordnance may also be considered as hazardous waste under the following 
conditions: 
1. An authorized official written record determination that the conventional explosive ordnance will 
2. Custodians of the conventional explosive ordnance receive this written determination. 
Therefore, based on the above information, it can be seen that generation, transportation, storage, 
treatment, or disposal of conventional explosive ordnance designated as hazardous waste is subject to 
RCRA requirements. 
Permit and Record Keeping Requirements 
Installations that generate, transport, treat, store, or dispose of solid or hazardous waste are required to 
apply to local, state or federal regulatory agencies for an EPA identification number. Some state and local 
2 Detonating Explosive Wastes, RCRA On-Line Document # 11305 
7 
heated under confinement. 
and pressure. 
be discarded; and 
Regulatory Overview HAZ-021-001-L
environmental regulations may require an emergency interim permit for transportation or thermal 
treatment of conventional explosive ordnance that does not present an immediate threat to human life or 
property. 
For on-site emergency response operations, UXO actions are those associated with a call for immediate 
action by EOD to render safe conventional explosive ordnance. These emergency actions might involve 
destruction of the conventional ordnance in-place or removal to a safer location. Conventional ordnance 
item on a range intended for that purpose can be treated in place without a permit and its requirements. 
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)3 
The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), often referred 
to as “Superfund,” was enacted by Congress in 1980. The law provided broad Federal authority to 
respond directly to releases or threatened releases of hazardous substances that may endanger public 
health or the environment. The basic provisions of the law include: 
· Establishing requirements and restrictions concerning closed and abandoned hazardous waste 
· Providing for liability of persons responsible for releases of hazardous waste at these sites; and 
· Establishing a fund to pay for cleanup when no responsible party can be identified. 
1. Short-term removals where actions may be taken to address releases or threatened releases 
2. Long-term remedial response actions that permanently and significantly reduce the dangers 
associated with releases or threats of releases of hazardous substances that are serious but not 
immediately life threatening. These actions can be conducted only at sites listed on EPA's 
National Priorities List (NPL). 
CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the 
guidelines and procedures needed to respond to releases and threatened releases of hazardous 
substances, pollutants, or contaminants. The NCP also established the NPL. The NCP outlines a 
sequential investigation/evaluation process to determine the need for response action and the most 
appropriate response actions to take. 
· Preliminary Assessment of the site: A qualitative site investigation and a review of operational 
and historical records. If this assessment indicates a potential for release of hazardous 
substances to the environment, a Site Investigation is conducted. 
· Site Investigation: Involves on-site sampling and analysis of the potentially affected area to 
quantify the original findings from the Preliminary Assessment. If the Site Investigation confirms 
significant releases of hazardous substances to the environment, a Remedial Investigation and 
Feasibility Study is conducted. 
· Remedial Investigation and Feasibility Study: The objectives of this process are to: 
- Determine the nature and extent of contamination from the release, 
- Determine the impacts associated with the release, and 
8 
sites; and 
The law authorizes two kinds of response actions: 
requiring prompt response. 
3 http://www.epa.gov/superfund/policy/cercla.htm 
Regulatory Overview HAZ-021-001-L
- Evaluate possible alternatives for remediating the problem. 
The most appropriate remedial alternative is recommended for implementation and 
becomes the legally binding remedy for the site. 
· If the effected property is being transferred outside the control of the federal government, it is to 
document that all remedial action necessary to protect human health and the environment has 
been taken, and that the United States shall conduct any additional remedial action found to be 
necessary after transfer. 
CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) in 1986. 
CERCLA does not apply directly to UXO sites because UXO is typically considered a solid waste rather 
than as a hazardous waste under most conditions. However, should the ordnance be classified as 
hazardous waste, it does fall under CERCLA requirements. Additionally, the CERCLA process provides 
an excellent framework for defining a good UXO clean-up process, as exhibited by the U.S. Army Corps 
of Engineers following a process similar to CERCLA at their UXO sites. Because of these similarities, the 
UXO worker should become familiar with the CERCLA process. 
Superfund Amendments and Reauthorization Act (SARA)4 
SARA made several important changes and additions to CERCLA, based on the EPA's experience in 
administering the complex Superfund program during its first six years: 
1. Stresses the importance of permanent remedies and innovative treatment technologies in 
2. Requires Superfund actions to consider the standards and requirements found in other State and 
Federal environmental laws and regulations; 
3. Provides new enforcement authorities and settlement tools; 
4. Increases State involvement in every phase of the Superfund program; 
5. Increases the focus on human health problems posed by hazardous waste sites; and 
6. Encourages greater citizen participation in making decisions on how sites should be cleaned up. 
SARA also required EPA to revise their Hazard Ranking System to ensure that it accurately assessed the 
relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites 
that may be placed on the National Priorities List. 
OSHA Hazardous Waste Operations & Emergency Response Standard 
The OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standard applies to 
all UXO remediation operations. The HAZWOPER requirement is primarily established under federal 
regulation 29 CFR 1910.120. Specific HAZWOPER requirements applicable to construction and 
excavations can be found in 29 CFR 1926.65. The HAZWOPER standard will be discussed in detail in 
subsequent sections of this manual. 
9 
cleaning up hazardous waste sites; 
4 http://www.epa.gov/superfund/policy/sara.htm 
Regulatory Overview HAZ-021-001-L
Military Munitions Rule:5 
Section 107 of the Federal Facilities Compliance Act of 1992 requires the Environmental Protection 
Agency (EPA), in consultation with the Department of Defense (DOD) and each individual state, to issue 
a rule that: 
· Identifies when munitions become a solid waste, and 
· If the waste is hazardous and subject to regulations under RCRA, and 
· Provides for protective storage and transportation of that waste. 
The overall objective of the Munitions Rule is to minimize health hazards and environmental damage 
caused by the use or misuse of ordnance. Military munitions must be stored, transported, used, and 
maintained in such a way as to ensure their effective, efficient, and safe employment to protect human 
health and the environment. Because of their wider applicability, the provisions of the Munitions Rule are 
incorporated into the current RCRA regulations. Within this Rule, the EPA has the option to delegate 
RCRA program administration and enforcement authority to a state or territory. In turn, states or territories 
may either adopt the federal Rule or develop their own state waste military munitions regulations that are 
at least as stringent as those of the federal program. Therefore, compliance requirements for dealing with 
waste military munitions differ throughout the country. 
The regulatory structure of the Munitions Rule reflects the EPA’s recognition that military munitions are 
different from other forms of industrial waste. The two most important provisions of the federal MR include 
addressing emergency responses to incidents involving munitions or explosives and the promulgation of 
a new RCRA unit standard for the storage of waste munitions or explosives. Other aspects of the 
Munitions Rule address the management of all munitions and explosives, both military and non-military. 
Definition of Military Munitions 
At its simplest, Military Munitions can be defined as all types of both conventional and chemical 
ammunition products, and their components, that are produced by and/or for the military for national 
defense and/or security. This includes munitions under the control of the Department of Defense, the 
United States Coast Guard, United States Department of Energy and National Guard personnel. 
Examples of Military Munitions include confined gases, liquid and solid propellants, explosives, 
pyrotechnics, chemical and riot-control agents, chemical munitions, rockets, guided and ballistic missiles, 
bombs and warheads, mortar rounds, artillery ammunition, small-arms ammunition, grenades, mines, 
torpedoes and depth charges, cluster munitions and dispensers, demolition charges, smokes and 
incendiaries including bulk explosives and chemical-warfare agents, and devices and components 
thereof. 
Definition of Solid Waste 
The Military Munitions Rule clarifies when conventional and chemical/ military munitions become a 
hazardous waste under the RCRA. Unused military munitions are considered to be a solid waste when 
any of the following four (4) conditions occur: 
1. The unused munition is abandoned by being disposed of, burned, detonated (except during 
intended use), incinerated or otherwise treated prior to disposal. 
2. The unused munition is removed from storage for the purpose of being disposed of, burned, 
5 PROACT Fact Sheet – Military Munitions Rule, December 2000 
10 
incinerated or treated prior to disposal. 
Regulatory Overview HAZ-021-001-L
3. The unused munition is deteriorated or damaged to the point that it can no longer be returned to 
serviceable condition and cannot be reasonably recycled or used for other purposes. 
4. The unused munition has been declared a solid waste by an authorized military official. 
The rule further clarifies that military munitions are not a solid waste for regulatory purposes when they 
are used for their intended purposes or for research and development, even when that use results in 
depositing the munition on the ground. The EPA also considers range management as a critical part of 
the safe use of munitions. Therefore, range clearance activities, including those performed by UXO 
personnel, are an intrinsic part of training and testing and are not regulated under RCRA. However, it is 
important to understand that used and/or fired munitions are still classified as a solid waste and 
potentially subject to RCRA regulation when: 
1. The munition is removed or managed off-range. 
2. The munition is recovered, collected and then disposed of on-range. 
3. The munition lands off-range. 
Department of Defense Directive 6055.9 - DoD Explosives Safety Board (DDESB):6 
The Directive requires that various military departments each develop and maintain comprehensive and 
effective explosives safety program. It establishes uniform safety standards that are applicable to 
ammunition and explosives, associated personnel and property, and unrelated personnel and property 
that are or could be exposed to potential damaging effects of an accident that involves ammunition and/or 
explosives during their development, manufacturing, testing, transportation, handling, storage, 
maintenance, demilitarization, and/or disposal. The Standard is mandatory for the Office of the Secretary 
of Defense, the various military departments, the Joint Chiefs of Staff, the Combatant Commands, and 
the Defense agencies. 
This document contains policies and procedures to provide protection to personnel by every means 
possible from hazards related to DoD ammunition, explosives and/or chemical agent contamination of 
real property currently and/or formerly owned, leased or used by DoD. These locations include 
manufacturing areas such as pads, pits, basins, ponds, streams, burial sites and other locations incident 
to such operations. This chapter also prohibits permanent contamination of real property (including land 
burial, discharge into watersheds, sewers, lakes, streams, or waterways) by final disposal of ammunition 
and explosives or chemical agents. Real property that is known to contain ammunition, explosives or 
chemical agents must be decontaminated with the most appropriate technology to assure protection of 
the public consistent with the proposed end use of the property. 
Formerly Used Defense Site (FUDS) Remediation 
The agency and/or contractor responsible for the remediation of the FUDS are required to develop 
procedures to safely remediate sites contaminated with ammunition, explosives or chemical agents. 
Priority is given to the remediation of sites with contamination that poses an immediate public risk. 
Included in the remediation is the requirement to Identify the degree and extent of contamination, assess 
the potential for migration of contamination, and implement steps to halt such migration. For land being 
returned to the public domain the U.S. Army Corps of Engineers is responsible for coordinating all UXO 
actions. 
6 DoD 655.9 – Ammunition and Explosives Safety Standards, Office of the Deputy Undersecretary of Defense 
(Installations and Environment), February 29, 2009. 
11 
Regulatory Overview HAZ-021-001-L
Plans for UXO removal actions on FUDS must be submitted to the DDESB for coordination and approval. 
These plans must provide site specific information as well as document the types of UXO that are 
suspected to exist at the site, the technologies and techniques that will be used for the identification of the 
UXO, a UXO risk assessment, and the measures that will be taken to minimize the risk to workers and the 
public during the assessment, cleanup and disposal phases. Site specific information includes identifying 
the site boundaries, types of ordnance, and soil characteristics. The depth at which UXO may be present 
must also be provided. In cases where site specific planning is not possible based on lack of information, 
the following default assessment depths are used for interim planning. 
Default Clearance Standards 
Planned Use Examples Depth 
Commercial, Residential, Utility, Subsurface Recreational 
Construction Activity 
Farming, Agriculture, Surface Recreation, Vehicle Parking, 
Surface Supply Storage 
Limited Public Access Livestock Grazing, Wildlife Preserve 1 ft 
Not Yet Determined Surface 
* (or 4 ft below planned excavation depths). 
DoD Directive 4715.11: Environmental and Explosives Safety Management on Active and 
Inactive Ranges within the United States 
This Directive sets policy and responsibility for the use and management of active and inactive ranges 
located within the United States. The goal of the policy is to protect DoD personnel and the public from 
explosive hazards on active and inactive DoD ranges. This Directive gives overall responsibility for safety, 
explosives safety, environment and technology policies related to this Directive to the Undersecretary of 
Defense for Acquisition and Technology. 
· The directive instructs all DoD contracted agents who are responsible for the coordination of UXO 
· Restrict access to ranges containing or suspected of containing UXO. 
· Take appropriate action to prevent unauthorized access to DoD ranges, including establishing 
access controls such as posting warning signs, fencing the area, security patrols, etc. 
· Provide explosives safety training to individuals who access DoD ranges. 
· Develop EOD escort guidelines. 
· Maintain permanent records of munitions expended, all UXO clearance operations and EOD 
· Document UXO areas on installation maps or master plans. 
· Minimize the use of submunitions and depleted uranium (DU) ordnance. 
· Conduct appropriate range clearance operations consistent with the any new proposed uses of a 
· Conduct a hazard assessment before range clearance operations. 
· Establish safe and practical methods for recycling or disposing of range residues in accordance 
12 
Unrestricted 
10 ft* 
Public Access 
4 ft 
clearance on DoD ranges to: 
incidents. 
UXO area. 
with DoD policies. 
Regulatory Overview HAZ-021-001-L
· Notify public when explosives hazards exist off-range. 
· Participate in established national public-involvement Programs to discuss explosives hazards. 
· Educate DoD personnel, their dependents, and the public living near DoD ranges on the 
DoD Directive 4145.26M: Contractors’ Safety Manual for Ammunition and Explosives 
This Manual provides standardized safety principles, methods, practices, requirements, and information 
for contractual work or services involving ammunition and explosives. This manual and additional safety 
requirements of the contract are intended to minimize the potential for mishaps that could interrupt DoD 
operations or delay production, damage or destroy DoD material, cause injury to DoD personnel, or 
endanger the general public. Adherence to the Manual's requirements and principles are intended to 
support the DoD mission, provide a safe environment, and foster cooperation between contract and DoD 
personnel. 
The requirements of this Manual apply to contractors performing work or services on DoD contracts, 
subcontracts, purchase orders, or other purchasing methods for ammunition or explosives. These 
requirements also apply to other contractor operations to the extent they impact DoD work or services. 
The directive states that the contractors shall: 
· Comply with the requirements of this Manual and any other safety requirements contained within 
· Develop and implement a demonstrable safety program, including operational procedures, 
intended to prevent ammunition and explosive related mishaps. 
· Designate qualified individuals to administer and implement this safety program. 
· Provide information to the administrative contracting officer (ACO) pertaining to subcontractors 
retained for ammunition and explosive work. 
· Require subcontractors to comply with this manual and other safety requirements within the 
· Conduct mishap investigations in accordance with, but not limited to, provisions of this Manual. 
13 
explosives hazards. 
the contract. 
contract. 
Regulatory Overview HAZ-021-001-L
Notes 
14 
Regulatory Overview HAZ-021-001-L
OSHA Hazardous Waste Operations & 
Emergency Response (HAZWOPER) Standard 
HAZ-021-002-L 
The Occupational Safety & Health Administration (OSHA) Hazardous Waste Operations and Emergency 
Response (HAZWOPER) standard (29 CFR 1910.120 and 1926.65) applies to all UXO remediation 
operations including FUDS, BRAC, and all active military sites. The primary HAZWOPER standard that is 
enforced by OSHA is 29 CFR 1910.120, while 29 CFR 1926.65 is designed specifically for construction 
and excavation, with additional reference to 29 CFR 1926.650 and 1926.900 – 914. 
The HAZWOPER standard was initially developed for commercial/industrial work sites. However, as 
discussed previously, it has been determined to be applicable to UXO operations. The HAZWOPER 
requirements for a written site health and safety plan, a comprehensive work plan, personnel training, and 
excavation will be discussed in this section. The HAZWOPER standard also addresses numerous other 
health and safety requirements, including but not limited to: personal protective equipment, respiratory 
protection, environmental monitoring and many other more specific safety-related requirements. These 
requirements will be discussed in detail in other sections of this manual. 
In order to ensure that everyone is using the same terms with the same meanings, let’s establish a few 
definitions that we will refer to throughout this manual. The following definitions have been copied directly 
from the HAZWOPER standard (29 CFR 1910.120). 
Buddy System: A system of organizing employees into work groups so that each employee is observed 
by at least one other employee in the same work group. The purpose of the buddy system is to provide 
rapid assistance to employees in the event of an emergency. 
Clean-up Operation: An operation where hazardous substances are removed, contained, incinerated, 
neutralized, stabilized, cleared-up, processed or handled in any other manner intended to make the site 
safer for people or the environment. 
Decontamination: The removal of hazardous substances from employees and their equipment to the 
extent necessary to prevent the occurrence of preventable adverse health effects. 
Emergency Response: A response effort by employees from outside the immediate release area, or by 
other designated responders from outside agencies, to an occurrence which results or is likely to result in 
an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous 
substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of 
release by employees in the immediate release area or by on-site personnel are not considered to be 
emergency responses within the scope of this standard. In addition, responses to releases of hazardous 
substances where there is no potential health or safety hazard are not considered to be emergency 
responses. 
Facility: Any building, structure, installation, equipment, pipe or pipeline, well, pit, pond, lagoon, 
impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft. Any site or area where a 
15 
Definitions 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
hazardous substance has been deposited, stored, disposed of, or placed or otherwise come to be 
located. This does not include any consumer product in consumer use or any water-borne vessel. 
Hazardous Materials (HAZMAT) Response Team: An organized group of employees who are trained to 
handle and control actual or potential releases of hazardous materials requiring possible direct contact 
with the material. Their purpose is to control or stabilize the incident. 
Hazardous Material: Any substance which may result in adverse effects to the health and/or safety of a 
person, animal or the environment. Examples include, but are not limited to, a biologic agent or other 
disease causing agent, a hazardous waste, or any substance designated as a hazardous material by the 
U.S. Department of Transportation. 
Hazardous Waste: A waste or combination of wastes as defined in the Resource Conservation and 
Recovery Act or by the Pipeline and Hazardous Materials Safety Administration. 
Health Hazard: A chemical, mixture of chemicals or pathogen that may cause acute and/or chronic 
health effects in exposed persons. The term includes chemicals which are carcinogens, toxic or highly 
toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins 
and agents which damage the lungs, skin, eyes, or mucous membranes. It also includes stress due to 
temperature extremes. 
Immediately Dangerous to Life or Health (IDLH): An atmospheric concentration of any toxic, corrosive 
or asphyxiant substance that poses an immediate threat to life, or could interfere with an individual’s 
ability to escape from a location. 
Oxygen Deficiency: A concentration of oxygen which is detrimental to human survival, in which some 
type of atmosphere-supplying respiratory protection must be provided. It exists in atmospheres where the 
percentage of oxygen is less than 19.5%. 
Uncontrolled Hazardous Waste Site: An area where an accumulation of hazardous substances creates 
a threat to the health and safety of persons, animals and/or the environment. These sites are usually 
identified and designated as uncontrolled hazardous waste sites by a governmental body, either Federal, 
state, local or other. Sites may be found on either public or private lands. 
Site Health and Safety Plan 
There are numerous requirements when it comes to the site’s health and safety plan. OSHA requires that 
the plan be site-specific, meaning that a work site cannot use a “canned” program unless it is adapted to 
the specific needs and issues at each individual site. The major requirements of this plan include: 
The site-specific health and safety plan should also address the frequency and types of air monitoring, 
personnel monitoring, and environmental monitoring programs being used on the site, including 
maintenance and calibration methods for any monitoring equipment used. Site control measures be 
16 
· Organizational Structure 
· Emergency Response Plan 
· Employee Training Program 
· Employee Medical Surveillance Program 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
thoroughly established and discussed, including the presence of any confined spaces and requirements 
for entry into these confined spaces. 
The tailgate safety briefing is another important requirement of the site-specific health and safety plan. 
Tailgate safety briefings are required to be held prior to the beginning of any site activity, and at any other 
time it becomes necessary to ensure that employees are kept up-to-date on changing conditions at the 
site. 
Organizational Structure 
The site health and safety plan must clearly establish the specific chain of command. It must also specify 
the overall responsibilities of supervisors and employees. While every UXO site is organized differently, 
there is generally a common organizational structure that is found throughout the UXO community. The 
organizational structure must include the following minimum elements: 
· A general supervisor who has the responsibility and authority to direct all hazardous waste 
· A site health and safety supervisor who has the responsibility and authority to develop and 
implement the site health and safety plan, and to verify compliance. 
· All other personnel needed for site operations and emergency response and their general 
· The lines of authority, responsibility and communication. 
The next page shows a simplified flow-chart of what might be expected for a normal chain-of-command 
on a typical UXO site. 
17 
operations 
functions and responsibilities. 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
It can be seen by looking at the above organizational structure that the UXO Tech 1 will usually be near 
the bottom of the worksite’s chain of command. In spite of the seemingly low rank of the UXO Tech 1, it is 
important for every employee on the UXO worksite to remember that s/he has leadership potential and is 
in a leadership position. Leadership responsibilities will be discussed later in this manual. 
Emergency Response Plan 
Each work site must develop and implement a comprehensive emergency response plan. Oftentimes, the 
contents of these plans will be dictated by various permits issued by the federal government. All 
18 
Sample UXO site chain of command: 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
emergency response plans, whether required by a permit or not, must be written components of the site’s 
overall health and safety plan for the site. The plan must be compatible and integrated with the 
emergency response plans of local, state and federal agencies in proximity to the site. In order to be 
comprehensive, and truly effective, the plan must be rehearsed regularly as part of the overall training 
program for the site. Additionally, the plan must be reviewed and updated periodically so that it remains 
current with new or changing site conditions or information. The emergency response plan should 
address the following topics: 
· Emergency recognition and prevention 
· Pre-emergency planning and coordination with agencies outside the boundaries of the UXO site 
· Pre-established roles, lines of authority, and training requirements for every individual on the site 
· Internal as well as external communication plans, including methods for announcing an 
· Site topography, layout and prevailing weather conditions 
· Site security and control during emergencies 
· Designation of minimum safe distances and places of refuge 
· Evacuation routes, responsibilities and procedures 
· Decontamination procedures 
· Emergency medical treatment and first aid protocols 
· Critique of response and follow-up 
· Personal protective equipment and emergency equipment requirements 
· Procedures for reporting incidents to local, state and federal governmental agencies 
All employees on the UXO site must be trained to be able to recognize the various health and/or safety 
hazards they may encounter on the site. This requirement includes not only the proper selection and use 
of personal protective equipment, but also extends to the use of power equipment, working with other 
employees to minimize risks, and the recognition of signs and symptoms of excessive exposure to 
harmful conditions. 
Employees on the site who are expected and/or required to respond to emergencies must receive specific 
training for that response before they are called upon to perform in real emergencies. Such training must 
include all of the elements addressed in the site’s emergency response plan as well as the standard 
operating procedures established on the work site. The employee must also be trained in the specific 
personal protective equipment they will be wearing during their response, as well as all of the other 
various types of PPE that are worn or used by other employees on the work site. 
Employee Training Requirements 
All employees working on a UXO site, including UXO Technicians, equipment operators, and general 
laborers, who have the potential to be exposed to any hazardous substance, health hazard or safety 
hazard must receive health and safety training prior to completing any job responsibilities on the work 
site. Supervisors and managers must receive advanced training prior to beginning their responsibilities. 
The training specified by OSHA is intended to be site-specific training over and above the HAZWOPER 
course requirements listed below. 
Initial Training: 40-Hour (Off-Site) And 3-Day (On-Site) 
HAZWOPER requires that all workers on a UXO site, not just the UXO Technicians, complete at 
least a 40-hour off-site classroom course as well as three (3) days of supervised, on-site field 
19 
emergency and response procedures 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
experience. OSHA does not provide specific guidelines for the training requirements but states 
that the training must address the specific safety and health hazards present on the site and the 
related procedures and controls necessary for worker protection. Site-specific training should 
thoroughly cover the following material: 
· Names of people on the site who are responsible for site health and safety programs 
· Health, safety and other hazards present on the site 
· Use of personal protective equipment 
· Work practices and engineering controls that can reduce employee risk 
· Overview of the site’s medical surveillance program requirements 
Workers who are on the UXO site occasionally for specific, limited tasks including, but not limited 
to, ground water monitoring, land surveying, or geophysical surveying, and who are unlikely to be 
exposed over permissible exposure limits and published exposure limits are required to complete 
at least 24 hours of instruction off the site and at least one (1) day of on-site field experience 
under the direct supervision of a trained, experienced supervisor. 
Supervisor Training 
On-site supervisors and managers who are directly responsible for or who supervise employees 
engaged in hazardous waste operations must complete the initial 40-hour course and the three 
(3) days of supervised field experience, plus at least eight (8) additional hours of specialized 
training at the time of their assignment. The additional training may include, but need not be 
limited to, the employer's safety and health program, personal protective equipment program, spill 
containment program, and/or health hazard monitoring procedure and techniques. 
Refresher Training 
Employees, managers and supervisors must complete at least eight (8) hours of refresher 
training annually. OSHA permits the refresher training to include any critique of incidents that 
have occurred in the past year and other topics relevant to the work being performed. 
Equivalent Training 
Employers who can show by documentation or certification that an employee's previous work 
experience and/or training is equivalent to or exceeds HAZWOPER requirements is not be 
required to provide the initial employee training. However, all employees who are new to a UXO 
site must receive appropriate, site-specific training before site entry. New employees must also 
receive appropriate, supervised field experience at the new site. Equivalent training includes any 
academic training or the training from actual hazardous waste site experience. Currently, in 
accordance with the guidance from the Department of the Army Office for Environment, Safety 
and Occupational Health, completion of EOD school meets the training requirements of 
HAZWOPER. Compliance with the intent of the training requirements of HAZWOPER is achieved 
when employees are trained to a level required by their job functions and responsibilities. 
20 
24-hour Occasional Workers 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
The comprehensive work plan portion is separate and distinct from the site’s health and safety plan. The 
work plan is intended to address the goals, objectives and tasks to be accomplished on the site. As such, 
this plan establishes and describes the various operations that will take place on the work site, and it 
addresses the logistics and resources necessary to accomplish the goals, objectives and tasks specified 
in the plan. It also provides for the implementation of the training required by OSHA and any other 
oversight agencies. In general the comprehensive work plan: 
· Defines expected clean-up activities. 
· Defines normal operating procedures. 
· Defines work tasks, objectives and overall project goals. 
· Identifies the methods for accomplishing these tasks and objectives. 
· Establishes personnel requirements for implementing the plan. 
· Establishes and implements the required training programs. 
· Implements the required informational programs. 
· Develops and implements the employee medical surveillance program. 
Other Requirements of the Site Health and Safety Plan 
HAZWOPER requires employers to develop, document, and implement a written health and safety 
program for their employees who are or may become involved in hazardous waste operations. The Site 
Health and Safety Plan should be designed to identify, evaluate, and control safety and health hazards. It 
must address site analysis, engineering controls, exposure limits, handling procedures and uses of new 
technologies. It also must provide for emergency response for hazardous waste operations. Finally, the 
plan must meet all applicable federal, state and local regulations. 
All portions of the site’s health and safety program must be made available to all employees as well as 
any contractor or subcontractor, or their representative, who will be involved with the operations on the 
job site. In addition, the plan must be made available to OSHA personnel and to personnel of any other 
government entity with regulatory authority over the site. 
Some of the more minor sections of the Site Health and Safety Plan will be addressed in this section of 
the manual, while many of the more complex requirements will be discussed in later sections of this 
manual. As a quick review, the plan must include the following sections: 
a. An identification of any hazardous materials expected to be found on-site 
b. A detailed map of the site 
c. A detailed organizational structure 
d. A comprehensive work plan 
e. An emergency procedures plan 
f. A site-specific health and safety training program 
g. A medical monitoring program 
h. The employer's standard operating procedures for health and safety, and 
i. Any necessary interface between general program and site specific activities. 
21 
Comprehensive Work Plan 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
Sanitation Facility Requirements 
Potable Water – OSHA requires that the work site provide an adequate supply of potable water for 
employees. If portable containers are used to dispense drinking water, the containers must be able to be 
tightly closed and equipped with a tap. This helps prevent unintentional contamination of the water 
supply. In addition, any container that is used to distribute drinking water must be clearly marked to show 
its contents and it cannot used for any other purpose. 
Non-Potable Water – If there are outlets for non-potable water, such as water for firefighting, must be 
clearly identified to indicate that it is unsafe for drinking, washing, or cooking. 
Toilet Facilities – Toilet facilities must be provided based on the total number of employees and visitors 
on the work site. If employees work “in the field,” the work site must make provisions for at least one 
temporary toilet to be available. These toilets may either be chemical toilets, recirculating toilets or 
common flush toilets. The following table provides a breakdown of the number of required toilet facilities. 
Minimum Number of Required Toilet Facilities 
Number of Employees Number of Required Toilets 
20 of Fewer One 
More than 20 Fewer than 200 One Toilet and One Urinal per 40 Employees 
More than 200 One Toilet and One Urinal per 50 Employees 
OSHA requires that the work site provide adequate illumination to any area in which employees are 
working. This is usually not something that is at the forefront of the employee’s mind. However, working in 
an area with diminished lighting can be difficult. The following table provides a brief list of the OSHA 
lighting requirements. For reference, unobstructed sunlight has an intensity of approximately 10,000 foot-candles, 
an overcast day has an intensity of around 1,000 foot-candles and the intensity of light near a 
window can range from 100 to 5,000 foot-candles, depending on the orientation of the window and time of 
year. 
Minimum Illumination Intensities ( Measured in Food-Candles) 
Excavation and Waste Areas, Accessways, Active Storage Areas, Loading Platforms, Refueling, 
and Field Maintenance Areas 
5 Indoors: Warehouses, Corridors, Hallways, and Exitways 
Tunnels, Shafts, and General Underground Work Areas: (Exception: Minimum at 10 foot-candles 
is required at tunnel and shaft heading during drilling, mucking, and scaling.) Mine 
Safety and Health Administration Approved Cap Lights shall be acceptable for use in the tunnel 
heading. 
General Shops (e.g., Mechanical and Electrical Equipment Rooms, Active Storerooms, Barracks 
or Living Quarters, Locker or Dressing Rooms, Dining Areas, and Indoor Toilets and Workrooms 
22 
Illumination Requirements 
5 General Site Areas 
3 
5 
10 
30 First Aid Stations, Infirmaries, and Offices 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
Because of the nature of work on a UXO site, OSHA requires that the work site provide adequate 
washing facilities for employees who are engaged in operations with potentially hazardous substances. 
These facilities must be in close proximity to the actual work area, in an area free from contamination. 
These washing facilities must include showers and changing rooms. OSHA further requires that 
employees must shower at the end of their works shift as well as when leaving the hazardous work site. 
New Technology Programs 
One aspect of the OSHA HAZWOPER standard that is frequently disregarded is the requirement that the 
employer must constantly strive to maintain the highest level of technology available to ensure a safe and 
efficient working environment. One example of this technology is the integration of new and more 
advanced metal detectors on the UXO site. However, this requirement also extends to personal protective 
equipment and any other equipment that promotes or improves the health and/or safety of the employee. 
Examples could include improved decontamination methods, new air monitoring equipment or improved 
excavation capabilities. 
Emergency Response Personnel Training Requirements 
Employees who are involved in emergency response to hazardous materials incidents must be trained to 
a different level than the typical employees. Most commonly, these requirements apply to personnel 
employed by fire and police departments; however, the requirements also include any employee who is 
expected to respond to an emergency situation on a hazardous job site. Employees who are required to 
engage in emergency response and could be exposed to hazardous substances that are a potential 
inhalation hazard must wear positive pressure self-contained breathing apparatus while engaged in the 
emergency response until air monitoring determines that a decreased level of respiratory protection is 
acceptable. Obviously, there is the potential for a UXO Technician to be expected to respond to 
emergency situations on the UXO site. Therefore, it is necessary to spend a few moments discussing the 
various training requirements for emergency response personnel. 
The training requirements, as established in 29 CFR 1910.120 are intended to provide for a means to 
train and certify employees in either a support role or as a specialist. Personnel who are skilled in the 
operation of a certain piece of equipment may be viewed as support personnel. Another example of 
support personnel could be those individuals needed to assist with the maintenance of site security 
measures. Specialists are those who are involved in the incident and have the potential for direct contact 
with the source of contamination. Examples would be individuals working on decontamination procedures 
or those who are rendering the scene safe. 
First Responder Awareness 
Awareness level training is provided to personnel who are likely to witness or discover a hazardous 
substance release. These personnel are trained to initiate an emergency response sequence by making 
proper notifications about the release. Awareness level training addresses the following topics: 
· Understanding what hazardous substances are and the risks associated with them in an incident 
· Potential outcomes associated with an emergency created when hazardous substances are 
· Recognizing the presence of hazardous substances in an emergency 
23 
Washing Facility Requirements 
present 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
· Identifying the hazardous substances, if possible 
· The role of the awareness-level responder in the employer's emergency response plan including 
site security and control and use of the U.S. Department of Transportation's Emergency 
Response Guidebook 
· Recognizing the need for additional resources and making appropriate notifications to the 
Operations level training is primarily directed at those individuals who respond to reports of hazardous 
material release and take defensive action to protect nearby persons, property, or the environment from 
the effects of the release. This level of training does not include actually working to stop the release. Their 
function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. 
Operations level responders must demonstrate the following competencies: 
· Knowledge of basic hazard and risk assessment techniques. 
· Ability to select and use proper personal protective equipment. 
· Understanding basic hazardous materials terms. 
· How to perform basic control, containment and/or confinement operations. 
· How to implement basic decontamination procedures. 
· An understanding of the relevant standard operating procedures and termination procedures. 
Hazardous materials technicians are individuals who respond to releases or potential releases for the 
purpose of stopping the release. They take an aggressive role by approaching the point of release in 
order to plug, patch or otherwise stop the release. Hazardous materials technicians must demonstrate 
competency in the following areas: 
· Knowing how to implement the agency’s emergency response plan. 
· Knowing the proper procedures for the classification, identification and verification of known and 
unknown materials by using field survey instruments and equipment. 
· Being able to function within an assigned role in the Incident Command System. 
· Knowing how to select and use the proper types of specialized chemical personal protective 
· Understanding hazard and risk assessment techniques. 
· Being able to perform advance control, containment, and/or confinement operations. 
· Understanding and implementing decontamination procedures. 
· Understanding termination procedures. 
· Understanding basic chemical and toxicological terminology and behavior. 
Hazardous materials specialists respond with and provide support to hazardous materials technicians. 
Their duties are very similar to the hazardous materials technician. However, the specialist is required to 
have a more directed or specific knowledge of the various substances they may be called upon to 
contain. The specialist would also act as the site liaison with Federal, state, local and other government 
authorities in regards to site activities. These individuals must demonstrate the same competencies as 
the hazardous materials technicians, as well as meeting the following additional requirements: 
24 
communication center 
First Responder Operations 
Hazardous Materials Technician 
equipment. 
Hazardous Materials Specialist 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
· Knowing how to implement the local emergency response plan. 
· Using advanced survey instruments and equipment to properly classify, identify and verify known 
· Knowing the state’s emergency response plan. 
· Selecting and using proper specialized chemical personal protective equipment. 
· Understanding in-depth hazard and risk techniques. 
· Being able to perform specialized control, containment, and/or confinement operations. 
· Being able to determine and implement decontamination procedures. 
· Having the ability to develop a site safety and control plan. 
· Understanding chemical, radiological and toxicological terminology and behavior. 
Incident commanders are persons who are required to take control of the emergency incident scene 
beyond the awareness level. The most senior person who responds to an emergency should take charge 
of the incident. This person is referred to as the Incident Commander and s/he is in charge of 
implementing a site-specific Incident Command System (ICS). All other emergency responders report to 
the Incident Commander through the chain of command established for the incident. The incident 
commander has the ultimate responsibility for identifying all hazardous substances or conditions present 
and for establishing a safe operating environment for all emergency responders. 
Incident commanders must receive at least 24 hours of training equal to the first responder operations 
level and also demonstrate competency in the following areas: 
· Having an understanding of, and ability to implement, the agency’s incident command system. 
· Knowing how to implement the agency's emergency response plan. 
· Knowing and understanding the hazards and risks associated with employees working in 
· Knowing how to implement the local emergency response plan. 
· Understanding the requirements of the state’s emergency response plan and of the Federal 
· Knowing and understanding the importance of decontamination procedures. 
25 
and unknown materials. 
Hazardous Materials Incident Commander 
chemical protective clothing. 
Regional Response Team. 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
Notes 
26 
OSHA Hazardous Waste Operations & HAZ-021-002-L 
Emergency Response (HAZWOPER) Standard
Nuclear, Biological & Chemical Hazard Safety 
HAZ-021-003-L 
Nuclear Hazard Safety 
In general, nuclear safety in the United States is governed by federal regulations and is studied by the 
Nuclear Regulatory Commission (NRC). The NRC does not have regulatory authority over nuclear safety 
issues pertaining to nuclear weapons. However, the NRC has extensive information available on the 
issue of nuclear and/or radiological emergencies. The essence of the NRC’s Emergency Preparedness 
Program centers on good planning. Their programs exist to enable personnel to quickly identify, evaluate 
and react to a wide variety of radiological emergencies. Typically, these programs are geared towards 
emergency response personnel, rather than UXO Technicians. However, the NRC training programs 
emphasize the integration of safety, security and preparedness as the basis for nuclear safety. These 
three factors not only apply to nuclear safety, but also to the general safety of the UXO Technician. 
There is a potential, however small, that the UXO Technician may be called upon to inspect or otherwise 
interact with a small tactical nuclear weapon. Before handling any nuclear weapon, the handler must have 
a firm understanding of nuclear weapon safety. Nuclear weapons should never be handled by untrained 
persons. 
All nuclear weapons must be maintained in a subcritical state until detonation is desired. This is usually 
accomplished by keeping the nuclear fuel in many separate pieces, each piece below the critical size for 
that material. For a detonation to occur, these pieces must be brought together very rapidly. Often, this is 
done by producing some type of explosion around the nuclear material. Thus, the best way to prevent 
unwanted nuclear explosions is to avoid moving the weapon in any way. This is best accomplished by not 
touching the weapon and leaving that responsibility to the properly trained and experienced explosive 
ordnance disposal technician. 
Radiation Poisoning 
Radiation poisoning, also called radiation sickness is damage to a person’s internal organ tissue resulting 
from excessive exposure to ionizing radiation. Radiation sickness or poisoning usually refers to acute 
problems, or problems associated with short-term exposure to a large dose of radiation. The Centers for 
Disease Control and Prevention (CDC) gives the clinical name for radiation sickness as Acute Radiation 
Syndrome (ARS). Radiation exposure can also increase a person’s susceptibility to other diseases such 
as cancer, tumors and genetic damage. 
Ionizing Radiation1 
Ionizing radiation is made up of subatomic particles or electromagnetic waves that contain enough energy 
to detach electrons from an atom or molecule. The ability of a substance to be ionizing radiation is made 
up of subatomic particles or electromagnetic waves that contain enough energy to detach electrons from 
an atom or molecule. The ability of a substance to be ionizing depends entirely on its inherent energy, not 
on the number of particles or waves it emits. Ionizing radiation consists of Alpha particles, Beta particles, 
Gamma particles and Neutrons. 
1 http://epa.gov/radiation/understand/ionize_nonionize.html 
27 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
Alpha (α) Particles– These particles are commonly given off by all of the larger radioactive 
elements, such as uranium and radium. An Alpha particle is the same thing as the nucleus of a 
Helium atom. These particles can only travel a short distance, so are usually thought of as being 
the least hazardous type of radiation. However, Alpha particles are 
extremely toxic if they are swallowed or inhaled because they are 
quickly absorbed by the body. Alpha radiation is the most 
destructive form of ionizing radiation because it has the greatest 
capacity to ionize cells within the body. Radiation damage from 
Alpha radiation is roughly 100 times greater than damage caused 
by the equivalent amount of any other radiation. 
Beta (β) Particles – These particles are high-energy, high-speed 
particles that are given off by certain types of radioactive elements 
such as Potassium-40. Beta radiation is in the middle in terms of 
penetrating power and ionizing capability, as compared to Alpha 
and Gamma radiation. Most beta particles can be stopped by a few 
millimeters of aluminum shielding. 
Gamma (γ) Particles – Gamma radiation is extremely high 
frequency radiation that is produced at the sub-atomic level, such 
as through radioactive decay, fission or fusion. The only effective 
shielding from gamma radiation is very large amounts of mass. 
Gamma radiation is most effectively blocked by extremely dense 
materials, but the total mass in the path of the gamma ray is the 
most important factor. Thicker shielding is required for higher 
energy gamma radiation. 
Neutrons – Neutrons are produced when Alpha particles impact 
one of many different types of elements with low atomic weights. 
They can only be created by nuclear disintegrations, nuclear 
reactions or other high-energy reactions such as cosmic events. In other words, Neutrons are 
extremely rare in the UXO field, so they will not be discussed in this document. 
Alpha radiation is stopped by a sheet of paper. 
Beta radiation is stopped by an aluminum 
plate. Gamma radiation is able to penetrate 
most materials 
Other types of ionizing radiation include X-rays and Ultraviolet radiation. Most people are familiar 
with these types of radiation and their health effects. Therefore, they will not be discussed in this 
document. 
Health Effects from Radiation Exposure 
All forms of ionizing radiation cause damage at the cellular level. However, exposure to Alpha and Beta 
radiation causes only minor, localized tissue damage because of their relative inability to penetrate skin. 
As mentioned previously, Alpha particles are extremely toxic if they are inhaled or ingested. Gamma 
radiation is able to penetrate most types of shielding and result in widespread damage throughout the 
body. 
Exposure to low doses of radiation causes cancer, tumors and genetic damage. High dose exposures 
can cause burns to the skin, radiation sickness, and even death. Radiation sickness is usually associated 
with a single, intense exposure to the radiation. The amount of time between the exposure and the 
beginning of symptoms can be a good indicator of how much radiation was absorbed. Symptoms will 
appear much sooner with greater exposure. As the amount of exposure increases, the symptoms of 
28 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
radiation sickness become more serious and the chance of survival drops. Signs and symptoms of 
radiation sickness will include: 
· Nausea and vomiting are the primary symptoms. They usually occur within one to two days after 
· Headache, fatigue, and weakness are associated with mild exposure. 
· Fever, diarrhea, hair loss, infections, bloody vomit, bloody feces, and poor ability to heal small 
wounds are common symptoms of moderate radiation exposure. 
· Dizziness, disorientation, and low blood pressure will occur with exposure to high amounts of 
Signs and symptoms of internal exposure to radiation will be significantly different than those from 
external exposure to radiation. When a radioactive substance enters the human body, the internal organs 
are directly affected. This exposure can severely damage organs and symptoms will be similar to those of 
a massive poisoning. 
Protection from Radiation 
There are four recognized ways to prevent unwanted exposure to possible sources of radiation: 
· Time - The longer a person is exposed to radiation, the greater the dose their body absorbs. 
Minimize the time of exposure to minimize the associated risk. 
· Distance – The greater the distance from the source of radiation, the lower the potential 
exposure will be. Distance can be gained by something as simple as using a tool, rather than a 
hand, to handle an object suspected of containing ionizing radiation. 
· Shielding – Being aware of the types of radiation that may be present and wearing appropriate 
personal protective equipment will dramatically reduce the risk of unintentional exposure to 
harmful radiation. 
· Containment – Materials that are known to be radioactive, or suspected of being radioactive, 
should be kept in the smallest possible space at all times. Confinement includes controlling 
ventilation. 
Treatment of Radiation Exposure 
At this time, there is currently no treatment for exposure to ionizing radiation. At best, people who 
experience signs or symptoms of radiation sickness can only have those signs or symptoms treated, such 
as through administration of drugs to reduce pain or prevent vomiting. If a person is only exposed over a 
small part of his/her body, it is easier to treat that exposure because the human body is able to withstand 
large exposures to its non-vital parts, such as the hands and feet, without affecting the entire body. This is 
not to say that the person will not experience any ill effects from the exposure. S/he will quite likely lose 
the body part(s) that experienced the exposure, but the problems may not progress to full-blown radiation 
sickness and eventual death. This type of injury is referred to as a radiation burn. 
The primary danger of whole-body exposure is the effect the exposure has on the body’s ability to fight off 
infection. One result of whole-body exposure is that the body’s bone marrow is destroyed, which 
eliminates the body’s ability to produce white blood cells, which are the primary cells involved in fighting 
off infection. The only treatment for this type of exposure is placing the person into a sterile environment 
and beginning both blood transfusions and bone marrow transplants. 
29 
exposure to mild exposure to radiation. 
radiation. 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
Biological Hazard Safety 
Biological warfare is a military technique that uses disease-causing biological agents, such as viruses, 
bacteria or other toxins, to kill, injure or impair a person or person. Biological warfare is very similar to 
chemical warfare, which will be discussed later in this section. A toxin is a poisonous substance that is 
produced by living cells or organisms. Title 18 of the United States Code defines a toxin as the toxic 
material or product of plants, animals, micro-organisms, infectious substance, or a man-made substance. 
Toxins are inanimate and cannot reproduce themselves. Toxins vary greatly in their ability to cause harm, 
from something as mild as a bee sting to something as deadly as anthrax. 
Biotoxins 
A biotoxin is a toxin that is produced by some type of living creature. They typically have one of two 
primary functions – predation or defense. Biotoxins can be extremely complex substances capable of 
causing severe tissue damage or death. Examples of biotoxins include: 
· Hematotoxins – Target and destroy red blood cells. These toxins spread through the blood 
stream and are produced by pit vipers such as rattlesnakes 
· Necrotoxins – Cause death in the cells they enter and destroy all types of tissue. They spread 
through the blood stream and are produced by the brown recluse and puff adder. 
· Neurotoxins – Affect the nervous system. These types of toxins are produced by the black 
· Cytotoxins – Substances that are toxic at the level of the individual cell. An example of a 
cytotoxin is ricin, which is found in the castor bean plant. 
Biological Hazards 
A biological hazard, or biohazard, is an organism or a substance derived from an organism that poses a 
threat to human health. Biohazards include a broad range of substances, from medical waste to samples 
of an active virus or toxin. If the biohazard is used as a weapon, it is termed a biological agent. There are 
more than 1,000 different types of biological agents that have been 
studied and/or used. 
The universal symbol that represents a biohazard is often referred to as a 
cloverleaf. It is very distinctive in appearance, as shown to the right. 
Biohazardous agents are assigned UN numbers for classification during 
transportation: 
· UN 2814 – Infectious Substance Affecting Humans 
· UN 2900 – Infectious Substance Affecting Animals 
· UN 3373 – Clinical Specimen 
· UN 3291 – Medical Waste 
The United States Center for Disease Control and Prevention (CDC) has established four levels of risk 
associated with biological hazards: 
· Biohazard Level 1 – The lowest level of risk. Examples include chicken pox and E. coli. 
Precautions against the infectious substance are minimal – gloves and some type of facial 
protection. Decontamination procedures consist of hand-washing and the disinfecting all exposed 
surfaces. 
30 
widow and scorpions. 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
· Biohazard Level 2 – Bacteria or viruses that cause mild disease symptoms or are difficult to 
contract when in the air. Examples include hepatitis, influenza, mumps and measles. 
Decontamination procedures are the same as for Biohazard Level 1. 
· Biohazard Level 3 – Bacteria or viruses that can cause severe to fatal disease or for which 
vaccines or other treatments exist. Examples include anthrax, West Nile virus, SARS virus, 
smallpox, and malaria. Decontamination procedures are similar to Level 2, but consist of more 
involved disinfection. 
· Biohazard Level 4 – Viruses or bacteria that cause severe to fatal disease and for which there 
are no known treatments or vaccines. Examples include Ebola virus, Dengue hemorrhagic fever, 
and hantavirus. It is necessary to wear a fully-encapsulating hazardous materials suit and self-contained 
air supply when dealing with Biohazard Level 4 substances. Decontamination 
procedures involve extensive disinfection and sterilization. 
As described in the different Biohazard Levels, the primary means for maintaining protection against 
biological weapons or other biohazards it to maintain cleanliness. In addition, it is important to be aware 
of, and to use, the appropriate personal protective equipment, including respiratory protection. Finally, 
proper cleaning, sanitizing and disinfecting is absolutely critical to prevent the spread of any potential 
toxins. 
Hazardous materials, or dangerous goods, are solids, liquids or gases that can harm living organisms, 
property or the environment. These hazardous materials may be radioactive, biohazardous, explosive, 
flammable, corrosive, toxic, or corrosive. They also frequently have potentially harmful physical 
characteristics, such as compressed gases or liquids. As discussed in previous sections of this manual, 
there are numerous regulations governing how hazardous materials are marked, labeled and transported. 
However, it is not uncommon on any worksite, especially a UXO site, to encounter unmarked or 
improperly marked hazardous materials. Thus, it is important to have a good understanding of how to 
safely mitigate the hazards associated with these materials. 
Hazardous materials are divided into Packing Groups for the purposes of segregating them during 
storage and transport. 
Group I These materials pose the greatest danger and require the most extensive and protective 
Group II These materials pose a moderate danger 
Group III These materials pose the least amount of danger and have the least stringent packaging 
These packing groups and other material handling information will be discussed more thoroughly in 
Section 14 of this manual. 
Chemical Warfare 
Chemical Warfare has many similarities with Biological Warfare, in that it uses substances to injure, kill or 
otherwise incapacitate people. The difference between Biological and Chemical warfare lies in the 
substances that are used. As their names imply, Biological Warfare uses biological, or naturally occurring, 
31 
Chemical Hazard Safety 
packaging 
requirements 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
substances, while Chemical Warfare uses substances that are created in a laboratory and are not 
naturally occurring. It is extremely likely that the UXO Technician will encounter chemical weapons while 
working in the field. 
Once exposed to the atmosphere, the chemical contaminants will generally dissipate to safe levels within 
two to three days. So there is usually little hazard associated with handling a chemical weapon that 
discharged as intended. The hazard arises when dealing with chemical weapons that failed to operate 
properly and must be made safe. 
Examples of some of the chemical warfare weapons that the UXO Technician may encounter include 
ricin, mustard gas, sarin and butulinum toxin. However, it is important to know that there are at least 70 
different chemicals that have been known to be used as chemical warfare agents over the past century. 
Chemicals that are toxic enough to be used as chemical weapons or that may be used to manufacture 
chemical weapons are divided into three groups, or Schedules, according to their purpose and how their 
exposure is treated. The classification of chemical weapons is managed internationally under the 
Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical 
Weapons and on their Destruction. This agreement is commonly referred to as the Chemical Weapons 
Convention. This Convention is an arms control agreement that is administered by the Organisation for 
the Prohibition of Chemical Weapons (OPCW), an independent organization located in The Hague, 
Netherlands. More than 188 countries have currently ratified and signed the agreement. 
Schedule 1 – These substances have few, if any, legitimate uses. They may only be produced or 
used for research, medical, pharmaceutical or protective purposes such as the testing of 
chemical protective clothing or chemical weapon sensors. Any production of more than 100 
grams of a Schedule 1 substance requires that the producer notify the OPCW. No country is 
allowed to store or stockpile more than one ton of these substances. 
Schedule 2 – These substances do not have large-scale industrial uses but they may have 
legitimate small-scale uses. For example, dimethyl methylphosphonate is used as a flame 
retardant and also is a precursor for sarin production. Thiodiglycol is commonly used as solvent in 
many inks and is also a precursor for the production of mustard gas. 
Schedule 3 – These are substances that have legitimate large-scale industrial uses. The OPCW 
must be notified of any plant that produces more than 30 tons of these substances annually. 
Once notified, the OPCW must be allowed to inspect those plants. Examples of Schedule 3 
substances include phosgene, which is used in the production of plastics, and chloropicrin, which 
is a fumigant. Both of these chemicals have also been used as chemical weapons. 
Persistency 
Modern chemical warfare doctrine requires that a person exposed to the chemical delivery should inhale 
a lethal does in one breath. Obviously, if the UXO Technician has the potential to be working with 
chemical weapons, this poses a very obvious hazard. It is important to understand the potential for the 
chemical to remain viable if a container of suspected chemical agent is discovered. 
A common way to classify chemical warfare agents that is particularly useful to the UXO Technician is by 
their persistency or the length of the time that they remain effective after being exposed to the 
atmosphere or after being dispersed. Chemical agents are classified as being either persistent or 
nonpersistent. Agents that are classified as nonpersistent lose their effectiveness after a few minutes or a 
few hours. These chemicals must be dispersed as very fine droplets, similar to a mist or aerosol. 
Examples of nonpersistent chemical agents include chlorine gas, sarin and most nerve agents. By 
contrast, a chemical agent that is classified as a persistent agent will remain viable in the atmosphere for 
32 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
several weeks. Unfortunately for the UXO Technician, it is not always possible to view a spent warhead or 
shell and know without a doubt that it contains a particular chemical weapon. Thus, the only reasonable 
defense against chemical weapons is the use of appropriate personal protective equipment. 
The Development of Chemical Warfare Agents 
Chemical Agent Distribution Mandatory Personal 
Appropriately Rated Gas 
Masks 
Gas Mask 
Rosin Oil Clothing 
Agents Aerodynamic Gas Mask with Water Supply Nerve Gas Alarm 
1980s Binary Munitions Improved Gas Masks Laser Detection 
Unknown Unknown Unknown 
Chemical weapons typically are inert agents that are designed to effect the human body in one of six 
ways: nerve, asphyxiant/blood, blistering, choking/pulmonary, incapacitating and cytotoxic proteins. 
Nerve Agents – These agents act by inactivating a specific enzyme in the brain. This inhibits the 
ability of the brain to secrete a necessary neurotransmitter, which impairs the ability of the 
effected person’s body to function properly. Inhaled vapors may take effect within seconds. If the 
agent comes into contact with skin, effects can be delayed for several hours. Examples of nerve 
agents include: cyclosarin, sarin, VX, Novichok agents, soman, tuban and some insecticides. VX 
is a contact hazard and is classified as persistent. Most other nerve agents are inhalation hazards 
and are nonpersistent. 
Signs and symptoms of exposure to a nerve agent include: pinpoint pupils, headache, 
nausea/vomiting, diarrhea, blurred or dimmed vision, muscle twitches, profuse sweating, difficulty 
breathing, seizures, loss of consciousness and death. 
Asphyxiant/Blood Agents – These agents have many different modes of action on the human 
body. Some agents cause massive internal bleeding, others prevent the cells of the body from 
using oxygen, and others cause the body to create excessive amounts of lactic acid which slowly 
33 
Protective Equipment 
Means of 
Detection 
1900s 
Chlorine 
Chloropicrin 
Phosgene 
Mustard Gas 
Atmospheric / Wind 
Dispersal 
Smell 
1910s Lewisite Chemical Shells 
1930s 
G-Series Nerve 
Agents Aircraft Bombs 
Blister Agent 
Detectors Color 
Change Paper 
1960s V-Series Nerve 
1990s Novichok Nerve 
Agents 
Classes of Chemical Weapons 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
turns the blood into an acid. The agents are fast-acting and are typically nonpersistent inhalation 
hazards. Examples of asphyxiant/blood agents include arsine, a derivative of arsenic; cyanogens 
chloride and hydrogen cyanide. 
Signs and symptoms of exposure to these agents include: confusion, nausea/vomiting, blueness 
of the lips or nailbed (cyanosis), gasping for air, seizures and death. 
Blistering Agents – These agents are contact hazards that are persistent. They act by forming 
acids or other compounds that damage skin and the respiratory system, leading to burns and 
breathing problems. Examples of blistering agents include: sulfur mustard, nitrogen mustard, 
lewisite and phosgene oxime. Lewisite has immediate effects upon contact, while the effects from 
the mustards may be delayed by four to 48 hours depending upon weather the agent is inhaled or 
comes into contact with the skin. 
Signs and symptoms of exposure to blistering agents include: severe irritation to the skin, eye 
and mucous membranes; redness and blistering of the skin; damage to the eyes; and respiratory 
problems ranging from mild distress to severe airway damage. 
Choking/Pulmonary Agents – These agents are very similar to blistering agents, in that they 
usually form acids. However, in these agents, the blisters are much more pronounced within the 
victim’s respiratory system. They typically act immediately upon contact and they are persistent 
inhalation hazards. The blisters they form within the respiratory system end up flooding the lungs 
with fluid, causing the victim to drown or suffocate. Examples of this type of chemical agent 
include: chlorine, hydrogen chloride, nitrogen oxides and phosgene. 
Signs and symptoms of exposure to these agents include: eye and skin irritation, difficulty 
breathing, excessive coughing, sore throat, chest tightness and wheezing. 
Incapacitating Agents – There is only one identified incapacitating agent – Agent 15, also called 
BZ. This agent acts by inhibiting the acetylcholine in the body’s peripheral nervous system. 
Acetylcholine is the neurotransmitter responsible for coordinating muscle function. It is extremely 
persistent in soil, in water and on most surfaces. It is a contact hazard that acts within 30 minutes 
if inhaled and up to 36 hours after contact with the skin. 
Signs and symptoms of exposure to BZ often are confused with drug intoxication. They include 
hallucination, erratic behavior, confusion, dilated pupils, dry mouth, lack of coordination and high 
body temperature. 
Cytotoxin Protein Agents – These agents degrade quickly in the atmosphere. They are 
designed to inhibit the creation of protein within the body, leading to flu-like symptoms. Examples 
include ricin and abrin. Signs and symptoms are usually seen between four and 24 hours of 
exposure, with more pronounced symptoms showing if the agent is inhaled or injected. 
Signs and symptoms of exposure to these agents are similar to those seen with the common flu, 
such as nausea/vomiting, coughing, difficulty breathing and gastrointestinal upset. However, 
there is typically gastrointestinal bleeding that is demonstrated by visible blood in the feces or 
vomit. Eventually, these symptoms progress towards liver and kidney failure, resulting in death. 
Other chemical weapons that the UXO Technician may encounter are not controlled or limited by the 
Chemical Weapons Convention but still pose a definite hazard to the Technician. These weapons include: 
34 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
Defoliants – Defoliants destroy vegetation but are not immediately toxic to people. Agent Orange 
is a good example of a defoliant. 
Incendiaries – These are explosive chemicals that are used because of their destructive force 
from fire or explosion, not their chemical action. Napalm is a good example of an incendiary 
chemical weapon. 
Protection Against Chemical Warfare Agents 
It is obvious that chemical weapons pose a tremendous risk to human beings. Because the most common 
cause of any workplace injury is the unintentional accident, it is absolutely critical that any weapon that 
could potentially be a chemical weapon be treated with the utmost care. Suspected chemical weapons 
must be thoroughly and carefully analyzed prior to any handling in order to determine what hazards may 
be present. 
When handling potential or known chemical weapon, protection begins with wearing the appropriate 
personal protective equipment (PPE). Appropriate protection usually involves some level of respiratory 
protection as well as protective clothing. The specific appropriate PPE can only truly be determined once 
the specific chemical threat is identified. However, if the threat is unknown, it must be treated the same as 
the highest possible threat, which would include a fully-encapsulated chemical resistant suit with a self-contained 
air supply. Personal protective equipment and respiratory protection will be discussed in more 
detail in later sections of this manual. 
Another key point in the safe handling of chemical weapons involves the protection of structures or 
buildings within the hazard zone. By carefully protecting the buildings and structures within the chemical 
weapon’s hazard zone, people can continue to function in those spaces without fear of contamination. 
Protection may be as simple as erecting barriers of plastic sheeting, or as complex as mobile air supplies 
and substantial physical barriers. 
Decontamination 
If an individual, structure or area has been exposed to a real or suspected chemical weapon, it is 
imperative that immediate decontamination take place. The decontamination procedure differs with each 
specific chemical agent. Decontamination of some nonpersistent pulmonary agents, such as chlorine and 
phosgene, may be as simple as providing improved ventilation to the area. However, in some cases it 
may be necessary to chemically neutralize a substance, such as through the use of ammonia to 
neutralize hydrogen cyanide. Or the individual may require immediate medical intervention in order to 
survive. A thorough discussion of decontamination procedures can be found in later sections of this 
manual. 
35 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
Notes 
36 
Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
Fire & Explosive Hazard Recognition 
HAZ-021-004-L 
Dangers of Uncontrolled Fire on UXO Sites 
Sites containing unexploded ordnance are typically not locations where fire is desirable, for obvious 
reasons. Many of the devices or other objects that the UXO Technician will potentially be working with are 
either heat sensitive or shock sensitive, or both. In order to prevent uncontrolled fires and provide the 
greatest measure of employee safety, there must first be a good understanding of what creates fire and 
how it can be controlled. 
Definitions 
Combustion – The sequence of heat-releasing chemical reactions between a fuel (something that can 
burn) and an oxidant (something which helps promote burning), which produces heat and light. 
Combustion does not necessarily require the presence of oxygen, such as when hydrogen gas burns 
upon contact with chlorine to form hydrogen chloride. 
Complete Combustion – The fuel burns in oxygen, producing a limited number of products, 
usually carbon dioxide and water. Complete combustion is almost impossible to achieve. 
Incomplete Combustion – Occurs when there isn't enough oxygen to allow the fuel to react 
completely with the oxygen to produce carbon dioxide and water. Most combustion results in the 
creation of carbon soot or ash as well as various other compounds. 
Smoldering Combustion - Slow, low-temperature, flameless combustion, sustained by the heat 
created when oxygen reaches the surface of a fuel. Solid materials that can sustain a smoldering 
reaction include coal, cellulose, wood, cotton, and tobacco. 
Conflagration – An uncontrolled burning or fire that threatens human life, health, property or ecology. It 
can be created either accidentally or intentionally. Sometimes, a conflagration may produce a firestorm in 
which the central column of rising heated air creates strong inward winds, which supply oxygen to the fire, 
further feeding its growth. 
Deflagration – A subsonic combustion process that propagates through a substance’s ability to conduct 
heat to adjacent materials. 
Detonation – A process of combustion that creates a supersonic shock wave through a body of 
detonable material, such as an oxygen-methane mixture or a high explosive. In a detonation, the 
supersonic shock wave compresses the surrounding material, which increases that material’s 
temperature to its ignition point. The ignited material burns behind the shock wave, releasing heat energy 
and a high-pressure volume of gas that propagates the shock wave, creating a self-sustaining reaction. 
Detonations can be produced by explosives, reactive gaseous mixtures, certain dusts and aerosols. 
Explosion – An extremely rapid and violent increase in volume of gas, accompanied by a release of 
energy usually in the form of high temperature. An explosion creates a shock wave. If the shock wave is a 
supersonic, then the then the source of the explosion is called a “high explosive.” If the shock wave is 
subsonic, then the sources of the explosion are called a “low explosive. 
37 
Fire & Explosive Hazard Recognition HAZ-021-004-L
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER
HAZWOPER

More Related Content

Viewers also liked

Viewers also liked (19)

40 Hr HAZWOPER
40 Hr HAZWOPER40 Hr HAZWOPER
40 Hr HAZWOPER
 
Bldg Construction Chapter 04
Bldg Construction Chapter 04Bldg Construction Chapter 04
Bldg Construction Chapter 04
 
DOT _hAZMAT CERTIFICATE 118913
DOT _hAZMAT CERTIFICATE 118913DOT _hAZMAT CERTIFICATE 118913
DOT _hAZMAT CERTIFICATE 118913
 
HazMat Ch11
HazMat Ch11HazMat Ch11
HazMat Ch11
 
HazMat Ch10
HazMat Ch10 HazMat Ch10
HazMat Ch10
 
HazMat Ch07
HazMat Ch07 HazMat Ch07
HazMat Ch07
 
HazMat Ch02 ppt
HazMat Ch02 pptHazMat Ch02 ppt
HazMat Ch02 ppt
 
HazMat Ch03
HazMat Ch03HazMat Ch03
HazMat Ch03
 
HazMat Ch05 ppt
HazMat Ch05 pptHazMat Ch05 ppt
HazMat Ch05 ppt
 
HazMat Ch06
HazMat Ch06HazMat Ch06
HazMat Ch06
 
HazMat Ch04 ppt
HazMat Ch04 pptHazMat Ch04 ppt
HazMat Ch04 ppt
 
HazMat Ch01 ppt
HazMat Ch01 pptHazMat Ch01 ppt
HazMat Ch01 ppt
 
Hazardous Materials Training by NETS
Hazardous Materials Training by NETSHazardous Materials Training by NETS
Hazardous Materials Training by NETS
 
Hazardous Materials Awareness by PA L&I
Hazardous Materials Awareness by PA L&IHazardous Materials Awareness by PA L&I
Hazardous Materials Awareness by PA L&I
 
Hazardous Materials Training by
Hazardous Materials Training byHazardous Materials Training by
Hazardous Materials Training by
 
Hazardous Materials Safety by The International Trade Association of Greater ...
Hazardous Materials Safety by The International Trade Association of Greater ...Hazardous Materials Safety by The International Trade Association of Greater ...
Hazardous Materials Safety by The International Trade Association of Greater ...
 
Hazardous Materials Training by HERRING FETI
Hazardous Materials Training by HERRING FETIHazardous Materials Training by HERRING FETI
Hazardous Materials Training by HERRING FETI
 
HazMat Ch08
HazMat Ch08HazMat Ch08
HazMat Ch08
 
HAZMAT AWARENESS
HAZMAT AWARENESSHAZMAT AWARENESS
HAZMAT AWARENESS
 

Similar to HAZWOPER

02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
artba
 
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
artba
 
Ag avt-140-01
Ag avt-140-01Ag avt-140-01
Ag avt-140-01
ceginc
 
Old Dominion University
Old Dominion UniversityOld Dominion University
Old Dominion University
butest
 
Old Dominion University
Old Dominion UniversityOld Dominion University
Old Dominion University
butest
 

Similar to HAZWOPER (11)

How to Understand the HAZWOPER Standard
How to Understand the HAZWOPER StandardHow to Understand the HAZWOPER Standard
How to Understand the HAZWOPER Standard
 
How to understand Hazwoper standard
How to understand Hazwoper standardHow to understand Hazwoper standard
How to understand Hazwoper standard
 
Life of-the-ship-reactors-and-accelerated-testing
Life of-the-ship-reactors-and-accelerated-testingLife of-the-ship-reactors-and-accelerated-testing
Life of-the-ship-reactors-and-accelerated-testing
 
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
 
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure02/11: OSHA Proposed Rule on Crystalline Silica Exposure
02/11: OSHA Proposed Rule on Crystalline Silica Exposure
 
H2 s common questions
H2 s common questionsH2 s common questions
H2 s common questions
 
The 8 Types of Trenching and Excavation Hazards
The 8 Types of Trenching and Excavation HazardsThe 8 Types of Trenching and Excavation Hazards
The 8 Types of Trenching and Excavation Hazards
 
Ag avt-140-01
Ag avt-140-01Ag avt-140-01
Ag avt-140-01
 
Old Dominion University
Old Dominion UniversityOld Dominion University
Old Dominion University
 
Old Dominion University
Old Dominion UniversityOld Dominion University
Old Dominion University
 
10 10-2017 The Use of Thermobaric Weapons: An English Translation from Finnish
10 10-2017 The Use of Thermobaric Weapons: An English Translation from Finnish10 10-2017 The Use of Thermobaric Weapons: An English Translation from Finnish
10 10-2017 The Use of Thermobaric Weapons: An English Translation from Finnish
 

HAZWOPER

  • 1.
  • 2. Unexploded ordnance (UXO) are explosive weapons such as bombs, mines, bullets, grenades, and/or shells that did not explode when they were used. As a result of this weapons failure, the UXO poses a risk of detonation, potentially many years after they were either used or discarded. Another term used in place of UXO is Munitions and Explosives of Concern, or MEC. Throughout this manual, the term of UXO will be used. Unexploded ordnance poses a hazard worldwide, in both current and former military firing ranges and combat areas. UXO can be found on the North American continent dating as far back as the American Civil War. Even UXO this old still poses a threat. One of the primary safety hazards with unexploded ordnance is that the detonator and main charge deteriorate over time, frequently making them more sensitive to being disturbed, and therefore more dangerous to handle. One of the most feared UXOs is corroded artillery shells containing chemical warfare agents such as mustard gas. There are numerous examples of civilians carelessly tampering with unexploded ordnance that is many years old. Unfortunately, these experiences are often fatal and are not always limited to uneducated civilians. For this reason it is universally recommended that unexploded ordnance should not be touched or handled by unqualified persons. Instead, the location should be reported to the local police so that trained and qualified professionals under closely controlled circumstances can render the device safe. German artillery shell from World War I left beside a field for disposal by the army in 2004 - still live and dangerous. A dramatic example of the global threat from UXO is the wreck of the SS Richard Montgomery, off the coast of Kent, England, which still contains 3,000 tons of munitions. When the Polish ship Kielce, a similar World War II wreck, exploded in 1967, it produced an earth tremor measuring 4.5 on the Richter scale. UXO cleanup in the continental United States involves more than 10 million acres of land and 1,400 different sites. This is an area roughly the size of the state of Florida, with some individual sites in excess of 500 square miles. To date, construction crews throughout the continental United States are discovering UXO in new development areas and frequently have to halt construction efforts until the UXO can be rendered safe. According to the U.S. Environmental Protection Agency (EPA), UXO at more than 16,000 inactive domestic military ranges within the United States pose an “imminent and substantial” public health risk and could require the largest environmental cleanup ever. Because it costs approximately $1,000 to demolish a single UXO on-site, estimated clean-up costs are in the tens of billions of dollars. Included in this cost estimate are site assessment, surveying and mapping, removing soil and/or vegetation from the site, transportation, and UXO technicians to manually detect munitions. Searching for UXOs is tedious work. It is not uncommon for 100 holes to be dug in the effort to locate one (1) UXO. In addition to the obvious danger of unintentional explosion, buried UXO poses an additional risk of environmental contamination. In some heavily used military training areas, munitions-related 1 Introduction HAZ-021-000-L Introduction HAZ-021-000-L
  • 3. chemicals such as explosives and perchlorate from rocket fuel can enter soil and groundwater. One of the most obvious examples of this can be seen at the Massachusetts Military Reservation on Cape Code. Decades of artillery training at this site have contaminated the only drinking water for thousands of surrounding residents. An extensive UXO recovery effort is under way there. UXO on US military bases also causes problems for the EPA’s Base Realignment and Closure (BRAC) program. Through the BRAC program, the EPA works to restore former munition testing areas in order to transfer it to public use. The military uses millions of training rounds per year that lead to a substantial amount of UXO. One of the common questions associated with UXO efforts on military properties is whether or not the OSHA HAZWOPER standard applies on U.S. military property. This question was answered in March of 1996 in written correspondence between OSHA and the U.S. Army Corps of Engineers. Following is the text of the OSHA interpretation of the HAZWOPER standard: Colonel Walter J. Cunningham, Commanding Huntsville Division, U.S. Army Corps of Engineers Post Office Box 1600 Huntsville, Alabama 35807-4301 Dear Colonel Cunningham: This is in response to your memorandum to the Occupational Safety and Health Administration (OSHA) requesting clarification of whether the OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120 and 1926.65) applies to the remediation of unexploded conventional ordnance at formerly used defense sites (FUDS) and active military installations. Specifically, you asked whether 40-hour training for general site workers, mandated in 1910.120(e)(3) and 1926.65(e)(3), is necessary for workers engaged in site activities that are not ground-intrusive, such as brush clearing and surveying, in which the primary hazard is the detonation of unexploded conventional ordnance. In a subsequent telephone conversation with Mr. William Chaffin of your staff, Mr. Chaffin further clarified that the remediation sites involved unexploded ordnance both at and below the soil surface and that detonations could result if workers inadvertently stepped on or struck the ordnance with an axe. The Department of Transportation classifies conventional ordnance as a hazardous material in Title 49 of the Code of Federal Regulations Part 172.101 (49 CFR 172.101). Based on this classification, conventional ordnance meets the definition of a hazardous substance under OSHA's HAZWOPER standard. Accordingly, remediation work at FUDS and active military installation sites contaminated with unexploded conventional ordnance falls within the scope of the HAZWOPER standard. Workers performing remediation activities (including clearing and surveying activities) at these sites, therefore, must meet the intent of the 40 hours of instruction off the site and a minimum of three days supervised field experience in accordance with 29 CFR 1910.120(e)(3) (or 1926.65(e)(3)). Your letter expressed concerns that the 40-hour training currently provided to workers engaged in remediation activities on sites contaminated with unexploded conventional ordnance was of little value. Mr. Chaffin elaborated on this concern in a subsequent telephone conversation, indicating that the 40-hour "standard HAZWOPER course" provided to these workers does not address explosives hazards and therefore, does not seem pertinent to their work. We share your concerns and acknowledge that training that does not address the hazards present on the worksite is of little value. We do not agree, however, that the 40-hour training described by Mr. Chaffin and in your letter is consistent with the OSHA HAZWOPER standard. The OSHA standard does not mandate a rigid, "standard" curriculum for the 40-hour training requirement but rather specifies in paragraph (e)(2) of the standard that required training must address the safety and health hazards present on the site and the related procedures and controls necessary for worker protection. Accordingly, the training provided to workers engaged in remediation activities on sites contaminated with unexploded conventional ordnance must address the hazards of unexploded ordnance and the related controls, as well as other hazards associated with the remediation site and proposed activities. Compliance with the intent of the training requirements of 29 CFR 1910.120(e) or 1926.65(e) is achieved when employees are trained to a level required by their job functions and responsibilities. When sufficient training on safety and health issues pertinent to a specific worksite is provided to cleanup workers, but the specific number of hours required by the standard is not given, a de minimis violation may exist. If an employer complies with the clear intent of a standard but deviates from its particular requirements in a manner that has no direct or immediate relationship to employee safety or health, such a violation is characterized as de minimis. Citations are not issued for de minimis violations. 2 Introduction HAZ-021-000-L
  • 4. We hope that this response provides the clarification you need. If you have further questions, please contact this office at (202) 219-8045. Sincerely, John B. Miles, Director Directorate of Compliance Programs Based on the interpretation above, Front Range Training and Consulting, has developed this HAZWOPER course to provide worksite specific hazard training to UXO employees. 3 Introduction HAZ-021-000-L
  • 5. Notes 4 Introduction HAZ-021-000-L
  • 6. There are numerous safety polices, guidelines, regulations and laws which govern clean-up activities on UXO sites. Without a firm understanding of these various rules, the UXO worker can be left with many unanswered questions. It is the goal of this Student Manual to clarify and explain the many different rules that govern activities on UXO sites, including but not limited to: · Resource Conservation and Recovery Act (RCRA) · Comprehensive Environmental Response, Compensation and Liability Act (CERCLA) · Superfund Amendments and Reauthorization Act (SARA) · OSHA Hazardous Waste Operations and Emergency Response standard · Military Munitions Rule · Department of Defense Directive 6055.9 - DoD Explosives Safety Board · DoD Directive 4715.11 – Environmental and Explosives Safety Management on Active and · DoD Directive 4145.26M: Contractors’ Safety Manual for Ammunition and Explosives In addition to the above list, it is important for the reader to understand that there are specific policies and guidelines that impact UXO operations on military property. UXO personnel working on a federal facility must be aware of the specific policies, regulations and guidelines that are pertinent to that worksite. The Federal Emergency Management Agency (FEMA) is responsible for administering all of the federal government’s civil emergency planning, management, mitigation and assistance functions. FEMA is the primary federal agency responsible for planning and related training for hazardous materials emergency management. Their authority includes accidents at manufacturing, processing, storage and disposal facilities, as well as hazardous material in transit. The Environmental Protection Agency (EPA) exists to protect and enhance the environment. The EPA is the primary agency responsible for overseeing hazardous waste site operations and cleanup activities. The Department of Transportation (DOT) establishes the nation’s overall transportation policy and has responsibility for issuing standards and regulations relating to the transportation of hazardous materials. The DOT trains and inspects carriers and shippers of hazardous materials to ensure that they remain in full compliance with all applicable guidelines. The Department of Energy (DOE) coordinates and administers the national energy functions. With regard to hazardous materials, the DOE is heavily involved in administration of the radioactive waste generated by both the nuclear weapons program as well as by the nuclear reactors which provide much of the nation’s energy. The Department of Defense (DoD) manufactures, tests and discards the full range of hazardous materials and is also one of the nation’s largest shippers of these same hazardous materials. The Department of Labor (DOL) exists to maintain and/or improve the welfare of the nation’s workers. The Occupational Safety and Health Administration (OSHA) is one branch of the DOL. OSHA's 5 Regulatory Overview HAZ-021-001-L Inactive Ranges within the United States Responsibilities of Federal Agencies Regulatory Overview HAZ-021-001-L
  • 7. mission is to prevent work-related injuries, illnesses, and deaths. OSHA has broad range in administering this mission throughout the nation. Resource Conservation and Recovery Act (RCRA)1 There are numerous requirements contained within the Resource Conservation and Recovery Act (RCRA) that apply to managing, handling, transporting, storing and disposing of conventional explosive ordnance. RCRA gives the United States Environmental Protection Agency (EPA) the authority to develop a nationwide program to regulate hazardous waste from the point at which is created, through it’s lifespan until it is ultimately destroyed and/or disposed. Section 6001 of the RCRA states that "Each department of the Federal Government…engaged in any activity resulting in the disposal or management of solid or hazardous waste shall be subject to, and comply with, all federal, state, interstate, and local requirements, both substantive and procedural (including any requirements for permits and reporting)." The Federal Hazardous and Solid Waste Amendments (HSWA) are the 1984 amendments to RCRA that focused on waste minimization and phasing out land disposal of hazardous waste ,as well as corrective action for releases. Some of the other mandates of this law include increased enforcement authority for EPA and more stringent hazardous waste management standards. RCRA Compliance 40 CFR 270.1(c) requires an RCRA permit for the owners and operators of any facility where solid or hazardous waste is treated, stored and/or disposed. Under RCRA, any hazardous waste generator is responsible for that waste from its "cradle to its grave." There are several definitions codified within RCRA that are important for the UXO worker to understand. Hazardous Waste: A solid waste, or combination of solid wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may: a. cause, or significantly contribute to an increase in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or b. pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. c. any facility for the collection, source separation, storage, transportation, transfer, processing, treatment or disposal of solid wastes, including hazardous wastes, whether such facility is associated with facilities generating such wastes or not. Hazardous Waste Generator: Any person whose act or process produces hazardous waste or whose act causes a hazardous waste to become subject to regulation. Mixed Waste: Contains both hazardous waste and source, special nuclear, or by-product material subject to the Atomic Energy Act of 1954 (42 U.S.C. 2011 et seq.). Storage: The containment of hazardous waste, either on a temporary basis or for a period of years, in such a manner as not to constitute disposal of such hazardous waste. 6 1 http://www.epa.gov/lawsregs/laws/rcra.html Regulatory Overview HAZ-021-001-L
  • 8. Treatment: Any method, technique, or process, including neutralization, designed to change the physical, chemical, or biological character or composition of any hazardous waste so as to neutralize such waste or so as to render such waste nonhazardous, safer for transport, amenable for recovery, amenable for storage, or reduced in volume. Such term includes any activity or processing designed to change the physical form or chemical composition of hazardous waste so as to render it nonhazardous. The EPA has also provided an interpretation of the RCRA regulation2 which states that explosives may indeed be a solid waste from the moment a decision is made that the explosives must be destroyed and not returned to the original owners. The basis for this decision is that the explosives are not being used for their originally-intended purpose (e.g., demolition of a building, military use, etc.), but rather are being detonated to discard the materials. The explosives, therefore, would meet the definition of a solid waste. If these explosives exhibit one of the characteristics of reactivity as defined below, they would be subject to the RCRA hazardous waste regulations for storage, treatment and disposal. Characteristics of Reactivity (per 40 CFR 261.23): If a representative sample of the explosive exhibits any of the following characteristics of reactivity, it shall be classified and treated as a solid waste according to RCRA regulation: 1. It is normally unstable and readily undergoes violent change without detonating. 2. It reacts violently with water. 3. It forms potentially explosive mixtures with water. 4. When mixed with water, it generates toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. 5. It is a cyanide or sulfide bearing waste which, when exposed to pH conditions between 2 and 12.5, can generate toxic gases, vapors or fumes in a quantity sufficient to present a danger to human health or the environment. 6. It is capable of detonation or explosive reaction if it is subjected to a strong initiating source or if 7. It is readily capable of detonation or explosive decomposition or reaction at standard temperature 8. It is a forbidden explosive as defined in 49 CFR 173.51, or a Class A explosive as defined in 49 CFR 173.53 or a Class B explosive as defined in 49 CFR 173.88. Conventional explosive ordnance may also be considered as hazardous waste under the following conditions: 1. An authorized official written record determination that the conventional explosive ordnance will 2. Custodians of the conventional explosive ordnance receive this written determination. Therefore, based on the above information, it can be seen that generation, transportation, storage, treatment, or disposal of conventional explosive ordnance designated as hazardous waste is subject to RCRA requirements. Permit and Record Keeping Requirements Installations that generate, transport, treat, store, or dispose of solid or hazardous waste are required to apply to local, state or federal regulatory agencies for an EPA identification number. Some state and local 2 Detonating Explosive Wastes, RCRA On-Line Document # 11305 7 heated under confinement. and pressure. be discarded; and Regulatory Overview HAZ-021-001-L
  • 9. environmental regulations may require an emergency interim permit for transportation or thermal treatment of conventional explosive ordnance that does not present an immediate threat to human life or property. For on-site emergency response operations, UXO actions are those associated with a call for immediate action by EOD to render safe conventional explosive ordnance. These emergency actions might involve destruction of the conventional ordnance in-place or removal to a safer location. Conventional ordnance item on a range intended for that purpose can be treated in place without a permit and its requirements. Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)3 The Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), often referred to as “Superfund,” was enacted by Congress in 1980. The law provided broad Federal authority to respond directly to releases or threatened releases of hazardous substances that may endanger public health or the environment. The basic provisions of the law include: · Establishing requirements and restrictions concerning closed and abandoned hazardous waste · Providing for liability of persons responsible for releases of hazardous waste at these sites; and · Establishing a fund to pay for cleanup when no responsible party can be identified. 1. Short-term removals where actions may be taken to address releases or threatened releases 2. Long-term remedial response actions that permanently and significantly reduce the dangers associated with releases or threats of releases of hazardous substances that are serious but not immediately life threatening. These actions can be conducted only at sites listed on EPA's National Priorities List (NPL). CERCLA also enabled the revision of the National Contingency Plan (NCP). The NCP provided the guidelines and procedures needed to respond to releases and threatened releases of hazardous substances, pollutants, or contaminants. The NCP also established the NPL. The NCP outlines a sequential investigation/evaluation process to determine the need for response action and the most appropriate response actions to take. · Preliminary Assessment of the site: A qualitative site investigation and a review of operational and historical records. If this assessment indicates a potential for release of hazardous substances to the environment, a Site Investigation is conducted. · Site Investigation: Involves on-site sampling and analysis of the potentially affected area to quantify the original findings from the Preliminary Assessment. If the Site Investigation confirms significant releases of hazardous substances to the environment, a Remedial Investigation and Feasibility Study is conducted. · Remedial Investigation and Feasibility Study: The objectives of this process are to: - Determine the nature and extent of contamination from the release, - Determine the impacts associated with the release, and 8 sites; and The law authorizes two kinds of response actions: requiring prompt response. 3 http://www.epa.gov/superfund/policy/cercla.htm Regulatory Overview HAZ-021-001-L
  • 10. - Evaluate possible alternatives for remediating the problem. The most appropriate remedial alternative is recommended for implementation and becomes the legally binding remedy for the site. · If the effected property is being transferred outside the control of the federal government, it is to document that all remedial action necessary to protect human health and the environment has been taken, and that the United States shall conduct any additional remedial action found to be necessary after transfer. CERCLA was amended by the Superfund Amendments and Reauthorization Act (SARA) in 1986. CERCLA does not apply directly to UXO sites because UXO is typically considered a solid waste rather than as a hazardous waste under most conditions. However, should the ordnance be classified as hazardous waste, it does fall under CERCLA requirements. Additionally, the CERCLA process provides an excellent framework for defining a good UXO clean-up process, as exhibited by the U.S. Army Corps of Engineers following a process similar to CERCLA at their UXO sites. Because of these similarities, the UXO worker should become familiar with the CERCLA process. Superfund Amendments and Reauthorization Act (SARA)4 SARA made several important changes and additions to CERCLA, based on the EPA's experience in administering the complex Superfund program during its first six years: 1. Stresses the importance of permanent remedies and innovative treatment technologies in 2. Requires Superfund actions to consider the standards and requirements found in other State and Federal environmental laws and regulations; 3. Provides new enforcement authorities and settlement tools; 4. Increases State involvement in every phase of the Superfund program; 5. Increases the focus on human health problems posed by hazardous waste sites; and 6. Encourages greater citizen participation in making decisions on how sites should be cleaned up. SARA also required EPA to revise their Hazard Ranking System to ensure that it accurately assessed the relative degree of risk to human health and the environment posed by uncontrolled hazardous waste sites that may be placed on the National Priorities List. OSHA Hazardous Waste Operations & Emergency Response Standard The OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standard applies to all UXO remediation operations. The HAZWOPER requirement is primarily established under federal regulation 29 CFR 1910.120. Specific HAZWOPER requirements applicable to construction and excavations can be found in 29 CFR 1926.65. The HAZWOPER standard will be discussed in detail in subsequent sections of this manual. 9 cleaning up hazardous waste sites; 4 http://www.epa.gov/superfund/policy/sara.htm Regulatory Overview HAZ-021-001-L
  • 11. Military Munitions Rule:5 Section 107 of the Federal Facilities Compliance Act of 1992 requires the Environmental Protection Agency (EPA), in consultation with the Department of Defense (DOD) and each individual state, to issue a rule that: · Identifies when munitions become a solid waste, and · If the waste is hazardous and subject to regulations under RCRA, and · Provides for protective storage and transportation of that waste. The overall objective of the Munitions Rule is to minimize health hazards and environmental damage caused by the use or misuse of ordnance. Military munitions must be stored, transported, used, and maintained in such a way as to ensure their effective, efficient, and safe employment to protect human health and the environment. Because of their wider applicability, the provisions of the Munitions Rule are incorporated into the current RCRA regulations. Within this Rule, the EPA has the option to delegate RCRA program administration and enforcement authority to a state or territory. In turn, states or territories may either adopt the federal Rule or develop their own state waste military munitions regulations that are at least as stringent as those of the federal program. Therefore, compliance requirements for dealing with waste military munitions differ throughout the country. The regulatory structure of the Munitions Rule reflects the EPA’s recognition that military munitions are different from other forms of industrial waste. The two most important provisions of the federal MR include addressing emergency responses to incidents involving munitions or explosives and the promulgation of a new RCRA unit standard for the storage of waste munitions or explosives. Other aspects of the Munitions Rule address the management of all munitions and explosives, both military and non-military. Definition of Military Munitions At its simplest, Military Munitions can be defined as all types of both conventional and chemical ammunition products, and their components, that are produced by and/or for the military for national defense and/or security. This includes munitions under the control of the Department of Defense, the United States Coast Guard, United States Department of Energy and National Guard personnel. Examples of Military Munitions include confined gases, liquid and solid propellants, explosives, pyrotechnics, chemical and riot-control agents, chemical munitions, rockets, guided and ballistic missiles, bombs and warheads, mortar rounds, artillery ammunition, small-arms ammunition, grenades, mines, torpedoes and depth charges, cluster munitions and dispensers, demolition charges, smokes and incendiaries including bulk explosives and chemical-warfare agents, and devices and components thereof. Definition of Solid Waste The Military Munitions Rule clarifies when conventional and chemical/ military munitions become a hazardous waste under the RCRA. Unused military munitions are considered to be a solid waste when any of the following four (4) conditions occur: 1. The unused munition is abandoned by being disposed of, burned, detonated (except during intended use), incinerated or otherwise treated prior to disposal. 2. The unused munition is removed from storage for the purpose of being disposed of, burned, 5 PROACT Fact Sheet – Military Munitions Rule, December 2000 10 incinerated or treated prior to disposal. Regulatory Overview HAZ-021-001-L
  • 12. 3. The unused munition is deteriorated or damaged to the point that it can no longer be returned to serviceable condition and cannot be reasonably recycled or used for other purposes. 4. The unused munition has been declared a solid waste by an authorized military official. The rule further clarifies that military munitions are not a solid waste for regulatory purposes when they are used for their intended purposes or for research and development, even when that use results in depositing the munition on the ground. The EPA also considers range management as a critical part of the safe use of munitions. Therefore, range clearance activities, including those performed by UXO personnel, are an intrinsic part of training and testing and are not regulated under RCRA. However, it is important to understand that used and/or fired munitions are still classified as a solid waste and potentially subject to RCRA regulation when: 1. The munition is removed or managed off-range. 2. The munition is recovered, collected and then disposed of on-range. 3. The munition lands off-range. Department of Defense Directive 6055.9 - DoD Explosives Safety Board (DDESB):6 The Directive requires that various military departments each develop and maintain comprehensive and effective explosives safety program. It establishes uniform safety standards that are applicable to ammunition and explosives, associated personnel and property, and unrelated personnel and property that are or could be exposed to potential damaging effects of an accident that involves ammunition and/or explosives during their development, manufacturing, testing, transportation, handling, storage, maintenance, demilitarization, and/or disposal. The Standard is mandatory for the Office of the Secretary of Defense, the various military departments, the Joint Chiefs of Staff, the Combatant Commands, and the Defense agencies. This document contains policies and procedures to provide protection to personnel by every means possible from hazards related to DoD ammunition, explosives and/or chemical agent contamination of real property currently and/or formerly owned, leased or used by DoD. These locations include manufacturing areas such as pads, pits, basins, ponds, streams, burial sites and other locations incident to such operations. This chapter also prohibits permanent contamination of real property (including land burial, discharge into watersheds, sewers, lakes, streams, or waterways) by final disposal of ammunition and explosives or chemical agents. Real property that is known to contain ammunition, explosives or chemical agents must be decontaminated with the most appropriate technology to assure protection of the public consistent with the proposed end use of the property. Formerly Used Defense Site (FUDS) Remediation The agency and/or contractor responsible for the remediation of the FUDS are required to develop procedures to safely remediate sites contaminated with ammunition, explosives or chemical agents. Priority is given to the remediation of sites with contamination that poses an immediate public risk. Included in the remediation is the requirement to Identify the degree and extent of contamination, assess the potential for migration of contamination, and implement steps to halt such migration. For land being returned to the public domain the U.S. Army Corps of Engineers is responsible for coordinating all UXO actions. 6 DoD 655.9 – Ammunition and Explosives Safety Standards, Office of the Deputy Undersecretary of Defense (Installations and Environment), February 29, 2009. 11 Regulatory Overview HAZ-021-001-L
  • 13. Plans for UXO removal actions on FUDS must be submitted to the DDESB for coordination and approval. These plans must provide site specific information as well as document the types of UXO that are suspected to exist at the site, the technologies and techniques that will be used for the identification of the UXO, a UXO risk assessment, and the measures that will be taken to minimize the risk to workers and the public during the assessment, cleanup and disposal phases. Site specific information includes identifying the site boundaries, types of ordnance, and soil characteristics. The depth at which UXO may be present must also be provided. In cases where site specific planning is not possible based on lack of information, the following default assessment depths are used for interim planning. Default Clearance Standards Planned Use Examples Depth Commercial, Residential, Utility, Subsurface Recreational Construction Activity Farming, Agriculture, Surface Recreation, Vehicle Parking, Surface Supply Storage Limited Public Access Livestock Grazing, Wildlife Preserve 1 ft Not Yet Determined Surface * (or 4 ft below planned excavation depths). DoD Directive 4715.11: Environmental and Explosives Safety Management on Active and Inactive Ranges within the United States This Directive sets policy and responsibility for the use and management of active and inactive ranges located within the United States. The goal of the policy is to protect DoD personnel and the public from explosive hazards on active and inactive DoD ranges. This Directive gives overall responsibility for safety, explosives safety, environment and technology policies related to this Directive to the Undersecretary of Defense for Acquisition and Technology. · The directive instructs all DoD contracted agents who are responsible for the coordination of UXO · Restrict access to ranges containing or suspected of containing UXO. · Take appropriate action to prevent unauthorized access to DoD ranges, including establishing access controls such as posting warning signs, fencing the area, security patrols, etc. · Provide explosives safety training to individuals who access DoD ranges. · Develop EOD escort guidelines. · Maintain permanent records of munitions expended, all UXO clearance operations and EOD · Document UXO areas on installation maps or master plans. · Minimize the use of submunitions and depleted uranium (DU) ordnance. · Conduct appropriate range clearance operations consistent with the any new proposed uses of a · Conduct a hazard assessment before range clearance operations. · Establish safe and practical methods for recycling or disposing of range residues in accordance 12 Unrestricted 10 ft* Public Access 4 ft clearance on DoD ranges to: incidents. UXO area. with DoD policies. Regulatory Overview HAZ-021-001-L
  • 14. · Notify public when explosives hazards exist off-range. · Participate in established national public-involvement Programs to discuss explosives hazards. · Educate DoD personnel, their dependents, and the public living near DoD ranges on the DoD Directive 4145.26M: Contractors’ Safety Manual for Ammunition and Explosives This Manual provides standardized safety principles, methods, practices, requirements, and information for contractual work or services involving ammunition and explosives. This manual and additional safety requirements of the contract are intended to minimize the potential for mishaps that could interrupt DoD operations or delay production, damage or destroy DoD material, cause injury to DoD personnel, or endanger the general public. Adherence to the Manual's requirements and principles are intended to support the DoD mission, provide a safe environment, and foster cooperation between contract and DoD personnel. The requirements of this Manual apply to contractors performing work or services on DoD contracts, subcontracts, purchase orders, or other purchasing methods for ammunition or explosives. These requirements also apply to other contractor operations to the extent they impact DoD work or services. The directive states that the contractors shall: · Comply with the requirements of this Manual and any other safety requirements contained within · Develop and implement a demonstrable safety program, including operational procedures, intended to prevent ammunition and explosive related mishaps. · Designate qualified individuals to administer and implement this safety program. · Provide information to the administrative contracting officer (ACO) pertaining to subcontractors retained for ammunition and explosive work. · Require subcontractors to comply with this manual and other safety requirements within the · Conduct mishap investigations in accordance with, but not limited to, provisions of this Manual. 13 explosives hazards. the contract. contract. Regulatory Overview HAZ-021-001-L
  • 15. Notes 14 Regulatory Overview HAZ-021-001-L
  • 16. OSHA Hazardous Waste Operations & Emergency Response (HAZWOPER) Standard HAZ-021-002-L The Occupational Safety & Health Administration (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120 and 1926.65) applies to all UXO remediation operations including FUDS, BRAC, and all active military sites. The primary HAZWOPER standard that is enforced by OSHA is 29 CFR 1910.120, while 29 CFR 1926.65 is designed specifically for construction and excavation, with additional reference to 29 CFR 1926.650 and 1926.900 – 914. The HAZWOPER standard was initially developed for commercial/industrial work sites. However, as discussed previously, it has been determined to be applicable to UXO operations. The HAZWOPER requirements for a written site health and safety plan, a comprehensive work plan, personnel training, and excavation will be discussed in this section. The HAZWOPER standard also addresses numerous other health and safety requirements, including but not limited to: personal protective equipment, respiratory protection, environmental monitoring and many other more specific safety-related requirements. These requirements will be discussed in detail in other sections of this manual. In order to ensure that everyone is using the same terms with the same meanings, let’s establish a few definitions that we will refer to throughout this manual. The following definitions have been copied directly from the HAZWOPER standard (29 CFR 1910.120). Buddy System: A system of organizing employees into work groups so that each employee is observed by at least one other employee in the same work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency. Clean-up Operation: An operation where hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared-up, processed or handled in any other manner intended to make the site safer for people or the environment. Decontamination: The removal of hazardous substances from employees and their equipment to the extent necessary to prevent the occurrence of preventable adverse health effects. Emergency Response: A response effort by employees from outside the immediate release area, or by other designated responders from outside agencies, to an occurrence which results or is likely to result in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area or by on-site personnel are not considered to be emergency responses within the scope of this standard. In addition, responses to releases of hazardous substances where there is no potential health or safety hazard are not considered to be emergency responses. Facility: Any building, structure, installation, equipment, pipe or pipeline, well, pit, pond, lagoon, impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft. Any site or area where a 15 Definitions OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 17. hazardous substance has been deposited, stored, disposed of, or placed or otherwise come to be located. This does not include any consumer product in consumer use or any water-borne vessel. Hazardous Materials (HAZMAT) Response Team: An organized group of employees who are trained to handle and control actual or potential releases of hazardous materials requiring possible direct contact with the material. Their purpose is to control or stabilize the incident. Hazardous Material: Any substance which may result in adverse effects to the health and/or safety of a person, animal or the environment. Examples include, but are not limited to, a biologic agent or other disease causing agent, a hazardous waste, or any substance designated as a hazardous material by the U.S. Department of Transportation. Hazardous Waste: A waste or combination of wastes as defined in the Resource Conservation and Recovery Act or by the Pipeline and Hazardous Materials Safety Administration. Health Hazard: A chemical, mixture of chemicals or pathogen that may cause acute and/or chronic health effects in exposed persons. The term includes chemicals which are carcinogens, toxic or highly toxic agents, reproductive toxins, irritants, corrosives, sensitizers, hepatotoxins, nephrotoxins, neurotoxins and agents which damage the lungs, skin, eyes, or mucous membranes. It also includes stress due to temperature extremes. Immediately Dangerous to Life or Health (IDLH): An atmospheric concentration of any toxic, corrosive or asphyxiant substance that poses an immediate threat to life, or could interfere with an individual’s ability to escape from a location. Oxygen Deficiency: A concentration of oxygen which is detrimental to human survival, in which some type of atmosphere-supplying respiratory protection must be provided. It exists in atmospheres where the percentage of oxygen is less than 19.5%. Uncontrolled Hazardous Waste Site: An area where an accumulation of hazardous substances creates a threat to the health and safety of persons, animals and/or the environment. These sites are usually identified and designated as uncontrolled hazardous waste sites by a governmental body, either Federal, state, local or other. Sites may be found on either public or private lands. Site Health and Safety Plan There are numerous requirements when it comes to the site’s health and safety plan. OSHA requires that the plan be site-specific, meaning that a work site cannot use a “canned” program unless it is adapted to the specific needs and issues at each individual site. The major requirements of this plan include: The site-specific health and safety plan should also address the frequency and types of air monitoring, personnel monitoring, and environmental monitoring programs being used on the site, including maintenance and calibration methods for any monitoring equipment used. Site control measures be 16 · Organizational Structure · Emergency Response Plan · Employee Training Program · Employee Medical Surveillance Program OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 18. thoroughly established and discussed, including the presence of any confined spaces and requirements for entry into these confined spaces. The tailgate safety briefing is another important requirement of the site-specific health and safety plan. Tailgate safety briefings are required to be held prior to the beginning of any site activity, and at any other time it becomes necessary to ensure that employees are kept up-to-date on changing conditions at the site. Organizational Structure The site health and safety plan must clearly establish the specific chain of command. It must also specify the overall responsibilities of supervisors and employees. While every UXO site is organized differently, there is generally a common organizational structure that is found throughout the UXO community. The organizational structure must include the following minimum elements: · A general supervisor who has the responsibility and authority to direct all hazardous waste · A site health and safety supervisor who has the responsibility and authority to develop and implement the site health and safety plan, and to verify compliance. · All other personnel needed for site operations and emergency response and their general · The lines of authority, responsibility and communication. The next page shows a simplified flow-chart of what might be expected for a normal chain-of-command on a typical UXO site. 17 operations functions and responsibilities. OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 19. It can be seen by looking at the above organizational structure that the UXO Tech 1 will usually be near the bottom of the worksite’s chain of command. In spite of the seemingly low rank of the UXO Tech 1, it is important for every employee on the UXO worksite to remember that s/he has leadership potential and is in a leadership position. Leadership responsibilities will be discussed later in this manual. Emergency Response Plan Each work site must develop and implement a comprehensive emergency response plan. Oftentimes, the contents of these plans will be dictated by various permits issued by the federal government. All 18 Sample UXO site chain of command: OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 20. emergency response plans, whether required by a permit or not, must be written components of the site’s overall health and safety plan for the site. The plan must be compatible and integrated with the emergency response plans of local, state and federal agencies in proximity to the site. In order to be comprehensive, and truly effective, the plan must be rehearsed regularly as part of the overall training program for the site. Additionally, the plan must be reviewed and updated periodically so that it remains current with new or changing site conditions or information. The emergency response plan should address the following topics: · Emergency recognition and prevention · Pre-emergency planning and coordination with agencies outside the boundaries of the UXO site · Pre-established roles, lines of authority, and training requirements for every individual on the site · Internal as well as external communication plans, including methods for announcing an · Site topography, layout and prevailing weather conditions · Site security and control during emergencies · Designation of minimum safe distances and places of refuge · Evacuation routes, responsibilities and procedures · Decontamination procedures · Emergency medical treatment and first aid protocols · Critique of response and follow-up · Personal protective equipment and emergency equipment requirements · Procedures for reporting incidents to local, state and federal governmental agencies All employees on the UXO site must be trained to be able to recognize the various health and/or safety hazards they may encounter on the site. This requirement includes not only the proper selection and use of personal protective equipment, but also extends to the use of power equipment, working with other employees to minimize risks, and the recognition of signs and symptoms of excessive exposure to harmful conditions. Employees on the site who are expected and/or required to respond to emergencies must receive specific training for that response before they are called upon to perform in real emergencies. Such training must include all of the elements addressed in the site’s emergency response plan as well as the standard operating procedures established on the work site. The employee must also be trained in the specific personal protective equipment they will be wearing during their response, as well as all of the other various types of PPE that are worn or used by other employees on the work site. Employee Training Requirements All employees working on a UXO site, including UXO Technicians, equipment operators, and general laborers, who have the potential to be exposed to any hazardous substance, health hazard or safety hazard must receive health and safety training prior to completing any job responsibilities on the work site. Supervisors and managers must receive advanced training prior to beginning their responsibilities. The training specified by OSHA is intended to be site-specific training over and above the HAZWOPER course requirements listed below. Initial Training: 40-Hour (Off-Site) And 3-Day (On-Site) HAZWOPER requires that all workers on a UXO site, not just the UXO Technicians, complete at least a 40-hour off-site classroom course as well as three (3) days of supervised, on-site field 19 emergency and response procedures OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 21. experience. OSHA does not provide specific guidelines for the training requirements but states that the training must address the specific safety and health hazards present on the site and the related procedures and controls necessary for worker protection. Site-specific training should thoroughly cover the following material: · Names of people on the site who are responsible for site health and safety programs · Health, safety and other hazards present on the site · Use of personal protective equipment · Work practices and engineering controls that can reduce employee risk · Overview of the site’s medical surveillance program requirements Workers who are on the UXO site occasionally for specific, limited tasks including, but not limited to, ground water monitoring, land surveying, or geophysical surveying, and who are unlikely to be exposed over permissible exposure limits and published exposure limits are required to complete at least 24 hours of instruction off the site and at least one (1) day of on-site field experience under the direct supervision of a trained, experienced supervisor. Supervisor Training On-site supervisors and managers who are directly responsible for or who supervise employees engaged in hazardous waste operations must complete the initial 40-hour course and the three (3) days of supervised field experience, plus at least eight (8) additional hours of specialized training at the time of their assignment. The additional training may include, but need not be limited to, the employer's safety and health program, personal protective equipment program, spill containment program, and/or health hazard monitoring procedure and techniques. Refresher Training Employees, managers and supervisors must complete at least eight (8) hours of refresher training annually. OSHA permits the refresher training to include any critique of incidents that have occurred in the past year and other topics relevant to the work being performed. Equivalent Training Employers who can show by documentation or certification that an employee's previous work experience and/or training is equivalent to or exceeds HAZWOPER requirements is not be required to provide the initial employee training. However, all employees who are new to a UXO site must receive appropriate, site-specific training before site entry. New employees must also receive appropriate, supervised field experience at the new site. Equivalent training includes any academic training or the training from actual hazardous waste site experience. Currently, in accordance with the guidance from the Department of the Army Office for Environment, Safety and Occupational Health, completion of EOD school meets the training requirements of HAZWOPER. Compliance with the intent of the training requirements of HAZWOPER is achieved when employees are trained to a level required by their job functions and responsibilities. 20 24-hour Occasional Workers OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 22. The comprehensive work plan portion is separate and distinct from the site’s health and safety plan. The work plan is intended to address the goals, objectives and tasks to be accomplished on the site. As such, this plan establishes and describes the various operations that will take place on the work site, and it addresses the logistics and resources necessary to accomplish the goals, objectives and tasks specified in the plan. It also provides for the implementation of the training required by OSHA and any other oversight agencies. In general the comprehensive work plan: · Defines expected clean-up activities. · Defines normal operating procedures. · Defines work tasks, objectives and overall project goals. · Identifies the methods for accomplishing these tasks and objectives. · Establishes personnel requirements for implementing the plan. · Establishes and implements the required training programs. · Implements the required informational programs. · Develops and implements the employee medical surveillance program. Other Requirements of the Site Health and Safety Plan HAZWOPER requires employers to develop, document, and implement a written health and safety program for their employees who are or may become involved in hazardous waste operations. The Site Health and Safety Plan should be designed to identify, evaluate, and control safety and health hazards. It must address site analysis, engineering controls, exposure limits, handling procedures and uses of new technologies. It also must provide for emergency response for hazardous waste operations. Finally, the plan must meet all applicable federal, state and local regulations. All portions of the site’s health and safety program must be made available to all employees as well as any contractor or subcontractor, or their representative, who will be involved with the operations on the job site. In addition, the plan must be made available to OSHA personnel and to personnel of any other government entity with regulatory authority over the site. Some of the more minor sections of the Site Health and Safety Plan will be addressed in this section of the manual, while many of the more complex requirements will be discussed in later sections of this manual. As a quick review, the plan must include the following sections: a. An identification of any hazardous materials expected to be found on-site b. A detailed map of the site c. A detailed organizational structure d. A comprehensive work plan e. An emergency procedures plan f. A site-specific health and safety training program g. A medical monitoring program h. The employer's standard operating procedures for health and safety, and i. Any necessary interface between general program and site specific activities. 21 Comprehensive Work Plan OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 23. Sanitation Facility Requirements Potable Water – OSHA requires that the work site provide an adequate supply of potable water for employees. If portable containers are used to dispense drinking water, the containers must be able to be tightly closed and equipped with a tap. This helps prevent unintentional contamination of the water supply. In addition, any container that is used to distribute drinking water must be clearly marked to show its contents and it cannot used for any other purpose. Non-Potable Water – If there are outlets for non-potable water, such as water for firefighting, must be clearly identified to indicate that it is unsafe for drinking, washing, or cooking. Toilet Facilities – Toilet facilities must be provided based on the total number of employees and visitors on the work site. If employees work “in the field,” the work site must make provisions for at least one temporary toilet to be available. These toilets may either be chemical toilets, recirculating toilets or common flush toilets. The following table provides a breakdown of the number of required toilet facilities. Minimum Number of Required Toilet Facilities Number of Employees Number of Required Toilets 20 of Fewer One More than 20 Fewer than 200 One Toilet and One Urinal per 40 Employees More than 200 One Toilet and One Urinal per 50 Employees OSHA requires that the work site provide adequate illumination to any area in which employees are working. This is usually not something that is at the forefront of the employee’s mind. However, working in an area with diminished lighting can be difficult. The following table provides a brief list of the OSHA lighting requirements. For reference, unobstructed sunlight has an intensity of approximately 10,000 foot-candles, an overcast day has an intensity of around 1,000 foot-candles and the intensity of light near a window can range from 100 to 5,000 foot-candles, depending on the orientation of the window and time of year. Minimum Illumination Intensities ( Measured in Food-Candles) Excavation and Waste Areas, Accessways, Active Storage Areas, Loading Platforms, Refueling, and Field Maintenance Areas 5 Indoors: Warehouses, Corridors, Hallways, and Exitways Tunnels, Shafts, and General Underground Work Areas: (Exception: Minimum at 10 foot-candles is required at tunnel and shaft heading during drilling, mucking, and scaling.) Mine Safety and Health Administration Approved Cap Lights shall be acceptable for use in the tunnel heading. General Shops (e.g., Mechanical and Electrical Equipment Rooms, Active Storerooms, Barracks or Living Quarters, Locker or Dressing Rooms, Dining Areas, and Indoor Toilets and Workrooms 22 Illumination Requirements 5 General Site Areas 3 5 10 30 First Aid Stations, Infirmaries, and Offices OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 24. Because of the nature of work on a UXO site, OSHA requires that the work site provide adequate washing facilities for employees who are engaged in operations with potentially hazardous substances. These facilities must be in close proximity to the actual work area, in an area free from contamination. These washing facilities must include showers and changing rooms. OSHA further requires that employees must shower at the end of their works shift as well as when leaving the hazardous work site. New Technology Programs One aspect of the OSHA HAZWOPER standard that is frequently disregarded is the requirement that the employer must constantly strive to maintain the highest level of technology available to ensure a safe and efficient working environment. One example of this technology is the integration of new and more advanced metal detectors on the UXO site. However, this requirement also extends to personal protective equipment and any other equipment that promotes or improves the health and/or safety of the employee. Examples could include improved decontamination methods, new air monitoring equipment or improved excavation capabilities. Emergency Response Personnel Training Requirements Employees who are involved in emergency response to hazardous materials incidents must be trained to a different level than the typical employees. Most commonly, these requirements apply to personnel employed by fire and police departments; however, the requirements also include any employee who is expected to respond to an emergency situation on a hazardous job site. Employees who are required to engage in emergency response and could be exposed to hazardous substances that are a potential inhalation hazard must wear positive pressure self-contained breathing apparatus while engaged in the emergency response until air monitoring determines that a decreased level of respiratory protection is acceptable. Obviously, there is the potential for a UXO Technician to be expected to respond to emergency situations on the UXO site. Therefore, it is necessary to spend a few moments discussing the various training requirements for emergency response personnel. The training requirements, as established in 29 CFR 1910.120 are intended to provide for a means to train and certify employees in either a support role or as a specialist. Personnel who are skilled in the operation of a certain piece of equipment may be viewed as support personnel. Another example of support personnel could be those individuals needed to assist with the maintenance of site security measures. Specialists are those who are involved in the incident and have the potential for direct contact with the source of contamination. Examples would be individuals working on decontamination procedures or those who are rendering the scene safe. First Responder Awareness Awareness level training is provided to personnel who are likely to witness or discover a hazardous substance release. These personnel are trained to initiate an emergency response sequence by making proper notifications about the release. Awareness level training addresses the following topics: · Understanding what hazardous substances are and the risks associated with them in an incident · Potential outcomes associated with an emergency created when hazardous substances are · Recognizing the presence of hazardous substances in an emergency 23 Washing Facility Requirements present OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 25. · Identifying the hazardous substances, if possible · The role of the awareness-level responder in the employer's emergency response plan including site security and control and use of the U.S. Department of Transportation's Emergency Response Guidebook · Recognizing the need for additional resources and making appropriate notifications to the Operations level training is primarily directed at those individuals who respond to reports of hazardous material release and take defensive action to protect nearby persons, property, or the environment from the effects of the release. This level of training does not include actually working to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. Operations level responders must demonstrate the following competencies: · Knowledge of basic hazard and risk assessment techniques. · Ability to select and use proper personal protective equipment. · Understanding basic hazardous materials terms. · How to perform basic control, containment and/or confinement operations. · How to implement basic decontamination procedures. · An understanding of the relevant standard operating procedures and termination procedures. Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They take an aggressive role by approaching the point of release in order to plug, patch or otherwise stop the release. Hazardous materials technicians must demonstrate competency in the following areas: · Knowing how to implement the agency’s emergency response plan. · Knowing the proper procedures for the classification, identification and verification of known and unknown materials by using field survey instruments and equipment. · Being able to function within an assigned role in the Incident Command System. · Knowing how to select and use the proper types of specialized chemical personal protective · Understanding hazard and risk assessment techniques. · Being able to perform advance control, containment, and/or confinement operations. · Understanding and implementing decontamination procedures. · Understanding termination procedures. · Understanding basic chemical and toxicological terminology and behavior. Hazardous materials specialists respond with and provide support to hazardous materials technicians. Their duties are very similar to the hazardous materials technician. However, the specialist is required to have a more directed or specific knowledge of the various substances they may be called upon to contain. The specialist would also act as the site liaison with Federal, state, local and other government authorities in regards to site activities. These individuals must demonstrate the same competencies as the hazardous materials technicians, as well as meeting the following additional requirements: 24 communication center First Responder Operations Hazardous Materials Technician equipment. Hazardous Materials Specialist OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 26. · Knowing how to implement the local emergency response plan. · Using advanced survey instruments and equipment to properly classify, identify and verify known · Knowing the state’s emergency response plan. · Selecting and using proper specialized chemical personal protective equipment. · Understanding in-depth hazard and risk techniques. · Being able to perform specialized control, containment, and/or confinement operations. · Being able to determine and implement decontamination procedures. · Having the ability to develop a site safety and control plan. · Understanding chemical, radiological and toxicological terminology and behavior. Incident commanders are persons who are required to take control of the emergency incident scene beyond the awareness level. The most senior person who responds to an emergency should take charge of the incident. This person is referred to as the Incident Commander and s/he is in charge of implementing a site-specific Incident Command System (ICS). All other emergency responders report to the Incident Commander through the chain of command established for the incident. The incident commander has the ultimate responsibility for identifying all hazardous substances or conditions present and for establishing a safe operating environment for all emergency responders. Incident commanders must receive at least 24 hours of training equal to the first responder operations level and also demonstrate competency in the following areas: · Having an understanding of, and ability to implement, the agency’s incident command system. · Knowing how to implement the agency's emergency response plan. · Knowing and understanding the hazards and risks associated with employees working in · Knowing how to implement the local emergency response plan. · Understanding the requirements of the state’s emergency response plan and of the Federal · Knowing and understanding the importance of decontamination procedures. 25 and unknown materials. Hazardous Materials Incident Commander chemical protective clothing. Regional Response Team. OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 27. Notes 26 OSHA Hazardous Waste Operations & HAZ-021-002-L Emergency Response (HAZWOPER) Standard
  • 28. Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L Nuclear Hazard Safety In general, nuclear safety in the United States is governed by federal regulations and is studied by the Nuclear Regulatory Commission (NRC). The NRC does not have regulatory authority over nuclear safety issues pertaining to nuclear weapons. However, the NRC has extensive information available on the issue of nuclear and/or radiological emergencies. The essence of the NRC’s Emergency Preparedness Program centers on good planning. Their programs exist to enable personnel to quickly identify, evaluate and react to a wide variety of radiological emergencies. Typically, these programs are geared towards emergency response personnel, rather than UXO Technicians. However, the NRC training programs emphasize the integration of safety, security and preparedness as the basis for nuclear safety. These three factors not only apply to nuclear safety, but also to the general safety of the UXO Technician. There is a potential, however small, that the UXO Technician may be called upon to inspect or otherwise interact with a small tactical nuclear weapon. Before handling any nuclear weapon, the handler must have a firm understanding of nuclear weapon safety. Nuclear weapons should never be handled by untrained persons. All nuclear weapons must be maintained in a subcritical state until detonation is desired. This is usually accomplished by keeping the nuclear fuel in many separate pieces, each piece below the critical size for that material. For a detonation to occur, these pieces must be brought together very rapidly. Often, this is done by producing some type of explosion around the nuclear material. Thus, the best way to prevent unwanted nuclear explosions is to avoid moving the weapon in any way. This is best accomplished by not touching the weapon and leaving that responsibility to the properly trained and experienced explosive ordnance disposal technician. Radiation Poisoning Radiation poisoning, also called radiation sickness is damage to a person’s internal organ tissue resulting from excessive exposure to ionizing radiation. Radiation sickness or poisoning usually refers to acute problems, or problems associated with short-term exposure to a large dose of radiation. The Centers for Disease Control and Prevention (CDC) gives the clinical name for radiation sickness as Acute Radiation Syndrome (ARS). Radiation exposure can also increase a person’s susceptibility to other diseases such as cancer, tumors and genetic damage. Ionizing Radiation1 Ionizing radiation is made up of subatomic particles or electromagnetic waves that contain enough energy to detach electrons from an atom or molecule. The ability of a substance to be ionizing radiation is made up of subatomic particles or electromagnetic waves that contain enough energy to detach electrons from an atom or molecule. The ability of a substance to be ionizing depends entirely on its inherent energy, not on the number of particles or waves it emits. Ionizing radiation consists of Alpha particles, Beta particles, Gamma particles and Neutrons. 1 http://epa.gov/radiation/understand/ionize_nonionize.html 27 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 29. Alpha (α) Particles– These particles are commonly given off by all of the larger radioactive elements, such as uranium and radium. An Alpha particle is the same thing as the nucleus of a Helium atom. These particles can only travel a short distance, so are usually thought of as being the least hazardous type of radiation. However, Alpha particles are extremely toxic if they are swallowed or inhaled because they are quickly absorbed by the body. Alpha radiation is the most destructive form of ionizing radiation because it has the greatest capacity to ionize cells within the body. Radiation damage from Alpha radiation is roughly 100 times greater than damage caused by the equivalent amount of any other radiation. Beta (β) Particles – These particles are high-energy, high-speed particles that are given off by certain types of radioactive elements such as Potassium-40. Beta radiation is in the middle in terms of penetrating power and ionizing capability, as compared to Alpha and Gamma radiation. Most beta particles can be stopped by a few millimeters of aluminum shielding. Gamma (γ) Particles – Gamma radiation is extremely high frequency radiation that is produced at the sub-atomic level, such as through radioactive decay, fission or fusion. The only effective shielding from gamma radiation is very large amounts of mass. Gamma radiation is most effectively blocked by extremely dense materials, but the total mass in the path of the gamma ray is the most important factor. Thicker shielding is required for higher energy gamma radiation. Neutrons – Neutrons are produced when Alpha particles impact one of many different types of elements with low atomic weights. They can only be created by nuclear disintegrations, nuclear reactions or other high-energy reactions such as cosmic events. In other words, Neutrons are extremely rare in the UXO field, so they will not be discussed in this document. Alpha radiation is stopped by a sheet of paper. Beta radiation is stopped by an aluminum plate. Gamma radiation is able to penetrate most materials Other types of ionizing radiation include X-rays and Ultraviolet radiation. Most people are familiar with these types of radiation and their health effects. Therefore, they will not be discussed in this document. Health Effects from Radiation Exposure All forms of ionizing radiation cause damage at the cellular level. However, exposure to Alpha and Beta radiation causes only minor, localized tissue damage because of their relative inability to penetrate skin. As mentioned previously, Alpha particles are extremely toxic if they are inhaled or ingested. Gamma radiation is able to penetrate most types of shielding and result in widespread damage throughout the body. Exposure to low doses of radiation causes cancer, tumors and genetic damage. High dose exposures can cause burns to the skin, radiation sickness, and even death. Radiation sickness is usually associated with a single, intense exposure to the radiation. The amount of time between the exposure and the beginning of symptoms can be a good indicator of how much radiation was absorbed. Symptoms will appear much sooner with greater exposure. As the amount of exposure increases, the symptoms of 28 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 30. radiation sickness become more serious and the chance of survival drops. Signs and symptoms of radiation sickness will include: · Nausea and vomiting are the primary symptoms. They usually occur within one to two days after · Headache, fatigue, and weakness are associated with mild exposure. · Fever, diarrhea, hair loss, infections, bloody vomit, bloody feces, and poor ability to heal small wounds are common symptoms of moderate radiation exposure. · Dizziness, disorientation, and low blood pressure will occur with exposure to high amounts of Signs and symptoms of internal exposure to radiation will be significantly different than those from external exposure to radiation. When a radioactive substance enters the human body, the internal organs are directly affected. This exposure can severely damage organs and symptoms will be similar to those of a massive poisoning. Protection from Radiation There are four recognized ways to prevent unwanted exposure to possible sources of radiation: · Time - The longer a person is exposed to radiation, the greater the dose their body absorbs. Minimize the time of exposure to minimize the associated risk. · Distance – The greater the distance from the source of radiation, the lower the potential exposure will be. Distance can be gained by something as simple as using a tool, rather than a hand, to handle an object suspected of containing ionizing radiation. · Shielding – Being aware of the types of radiation that may be present and wearing appropriate personal protective equipment will dramatically reduce the risk of unintentional exposure to harmful radiation. · Containment – Materials that are known to be radioactive, or suspected of being radioactive, should be kept in the smallest possible space at all times. Confinement includes controlling ventilation. Treatment of Radiation Exposure At this time, there is currently no treatment for exposure to ionizing radiation. At best, people who experience signs or symptoms of radiation sickness can only have those signs or symptoms treated, such as through administration of drugs to reduce pain or prevent vomiting. If a person is only exposed over a small part of his/her body, it is easier to treat that exposure because the human body is able to withstand large exposures to its non-vital parts, such as the hands and feet, without affecting the entire body. This is not to say that the person will not experience any ill effects from the exposure. S/he will quite likely lose the body part(s) that experienced the exposure, but the problems may not progress to full-blown radiation sickness and eventual death. This type of injury is referred to as a radiation burn. The primary danger of whole-body exposure is the effect the exposure has on the body’s ability to fight off infection. One result of whole-body exposure is that the body’s bone marrow is destroyed, which eliminates the body’s ability to produce white blood cells, which are the primary cells involved in fighting off infection. The only treatment for this type of exposure is placing the person into a sterile environment and beginning both blood transfusions and bone marrow transplants. 29 exposure to mild exposure to radiation. radiation. Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 31. Biological Hazard Safety Biological warfare is a military technique that uses disease-causing biological agents, such as viruses, bacteria or other toxins, to kill, injure or impair a person or person. Biological warfare is very similar to chemical warfare, which will be discussed later in this section. A toxin is a poisonous substance that is produced by living cells or organisms. Title 18 of the United States Code defines a toxin as the toxic material or product of plants, animals, micro-organisms, infectious substance, or a man-made substance. Toxins are inanimate and cannot reproduce themselves. Toxins vary greatly in their ability to cause harm, from something as mild as a bee sting to something as deadly as anthrax. Biotoxins A biotoxin is a toxin that is produced by some type of living creature. They typically have one of two primary functions – predation or defense. Biotoxins can be extremely complex substances capable of causing severe tissue damage or death. Examples of biotoxins include: · Hematotoxins – Target and destroy red blood cells. These toxins spread through the blood stream and are produced by pit vipers such as rattlesnakes · Necrotoxins – Cause death in the cells they enter and destroy all types of tissue. They spread through the blood stream and are produced by the brown recluse and puff adder. · Neurotoxins – Affect the nervous system. These types of toxins are produced by the black · Cytotoxins – Substances that are toxic at the level of the individual cell. An example of a cytotoxin is ricin, which is found in the castor bean plant. Biological Hazards A biological hazard, or biohazard, is an organism or a substance derived from an organism that poses a threat to human health. Biohazards include a broad range of substances, from medical waste to samples of an active virus or toxin. If the biohazard is used as a weapon, it is termed a biological agent. There are more than 1,000 different types of biological agents that have been studied and/or used. The universal symbol that represents a biohazard is often referred to as a cloverleaf. It is very distinctive in appearance, as shown to the right. Biohazardous agents are assigned UN numbers for classification during transportation: · UN 2814 – Infectious Substance Affecting Humans · UN 2900 – Infectious Substance Affecting Animals · UN 3373 – Clinical Specimen · UN 3291 – Medical Waste The United States Center for Disease Control and Prevention (CDC) has established four levels of risk associated with biological hazards: · Biohazard Level 1 – The lowest level of risk. Examples include chicken pox and E. coli. Precautions against the infectious substance are minimal – gloves and some type of facial protection. Decontamination procedures consist of hand-washing and the disinfecting all exposed surfaces. 30 widow and scorpions. Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 32. · Biohazard Level 2 – Bacteria or viruses that cause mild disease symptoms or are difficult to contract when in the air. Examples include hepatitis, influenza, mumps and measles. Decontamination procedures are the same as for Biohazard Level 1. · Biohazard Level 3 – Bacteria or viruses that can cause severe to fatal disease or for which vaccines or other treatments exist. Examples include anthrax, West Nile virus, SARS virus, smallpox, and malaria. Decontamination procedures are similar to Level 2, but consist of more involved disinfection. · Biohazard Level 4 – Viruses or bacteria that cause severe to fatal disease and for which there are no known treatments or vaccines. Examples include Ebola virus, Dengue hemorrhagic fever, and hantavirus. It is necessary to wear a fully-encapsulating hazardous materials suit and self-contained air supply when dealing with Biohazard Level 4 substances. Decontamination procedures involve extensive disinfection and sterilization. As described in the different Biohazard Levels, the primary means for maintaining protection against biological weapons or other biohazards it to maintain cleanliness. In addition, it is important to be aware of, and to use, the appropriate personal protective equipment, including respiratory protection. Finally, proper cleaning, sanitizing and disinfecting is absolutely critical to prevent the spread of any potential toxins. Hazardous materials, or dangerous goods, are solids, liquids or gases that can harm living organisms, property or the environment. These hazardous materials may be radioactive, biohazardous, explosive, flammable, corrosive, toxic, or corrosive. They also frequently have potentially harmful physical characteristics, such as compressed gases or liquids. As discussed in previous sections of this manual, there are numerous regulations governing how hazardous materials are marked, labeled and transported. However, it is not uncommon on any worksite, especially a UXO site, to encounter unmarked or improperly marked hazardous materials. Thus, it is important to have a good understanding of how to safely mitigate the hazards associated with these materials. Hazardous materials are divided into Packing Groups for the purposes of segregating them during storage and transport. Group I These materials pose the greatest danger and require the most extensive and protective Group II These materials pose a moderate danger Group III These materials pose the least amount of danger and have the least stringent packaging These packing groups and other material handling information will be discussed more thoroughly in Section 14 of this manual. Chemical Warfare Chemical Warfare has many similarities with Biological Warfare, in that it uses substances to injure, kill or otherwise incapacitate people. The difference between Biological and Chemical warfare lies in the substances that are used. As their names imply, Biological Warfare uses biological, or naturally occurring, 31 Chemical Hazard Safety packaging requirements Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 33. substances, while Chemical Warfare uses substances that are created in a laboratory and are not naturally occurring. It is extremely likely that the UXO Technician will encounter chemical weapons while working in the field. Once exposed to the atmosphere, the chemical contaminants will generally dissipate to safe levels within two to three days. So there is usually little hazard associated with handling a chemical weapon that discharged as intended. The hazard arises when dealing with chemical weapons that failed to operate properly and must be made safe. Examples of some of the chemical warfare weapons that the UXO Technician may encounter include ricin, mustard gas, sarin and butulinum toxin. However, it is important to know that there are at least 70 different chemicals that have been known to be used as chemical warfare agents over the past century. Chemicals that are toxic enough to be used as chemical weapons or that may be used to manufacture chemical weapons are divided into three groups, or Schedules, according to their purpose and how their exposure is treated. The classification of chemical weapons is managed internationally under the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on their Destruction. This agreement is commonly referred to as the Chemical Weapons Convention. This Convention is an arms control agreement that is administered by the Organisation for the Prohibition of Chemical Weapons (OPCW), an independent organization located in The Hague, Netherlands. More than 188 countries have currently ratified and signed the agreement. Schedule 1 – These substances have few, if any, legitimate uses. They may only be produced or used for research, medical, pharmaceutical or protective purposes such as the testing of chemical protective clothing or chemical weapon sensors. Any production of more than 100 grams of a Schedule 1 substance requires that the producer notify the OPCW. No country is allowed to store or stockpile more than one ton of these substances. Schedule 2 – These substances do not have large-scale industrial uses but they may have legitimate small-scale uses. For example, dimethyl methylphosphonate is used as a flame retardant and also is a precursor for sarin production. Thiodiglycol is commonly used as solvent in many inks and is also a precursor for the production of mustard gas. Schedule 3 – These are substances that have legitimate large-scale industrial uses. The OPCW must be notified of any plant that produces more than 30 tons of these substances annually. Once notified, the OPCW must be allowed to inspect those plants. Examples of Schedule 3 substances include phosgene, which is used in the production of plastics, and chloropicrin, which is a fumigant. Both of these chemicals have also been used as chemical weapons. Persistency Modern chemical warfare doctrine requires that a person exposed to the chemical delivery should inhale a lethal does in one breath. Obviously, if the UXO Technician has the potential to be working with chemical weapons, this poses a very obvious hazard. It is important to understand the potential for the chemical to remain viable if a container of suspected chemical agent is discovered. A common way to classify chemical warfare agents that is particularly useful to the UXO Technician is by their persistency or the length of the time that they remain effective after being exposed to the atmosphere or after being dispersed. Chemical agents are classified as being either persistent or nonpersistent. Agents that are classified as nonpersistent lose their effectiveness after a few minutes or a few hours. These chemicals must be dispersed as very fine droplets, similar to a mist or aerosol. Examples of nonpersistent chemical agents include chlorine gas, sarin and most nerve agents. By contrast, a chemical agent that is classified as a persistent agent will remain viable in the atmosphere for 32 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 34. several weeks. Unfortunately for the UXO Technician, it is not always possible to view a spent warhead or shell and know without a doubt that it contains a particular chemical weapon. Thus, the only reasonable defense against chemical weapons is the use of appropriate personal protective equipment. The Development of Chemical Warfare Agents Chemical Agent Distribution Mandatory Personal Appropriately Rated Gas Masks Gas Mask Rosin Oil Clothing Agents Aerodynamic Gas Mask with Water Supply Nerve Gas Alarm 1980s Binary Munitions Improved Gas Masks Laser Detection Unknown Unknown Unknown Chemical weapons typically are inert agents that are designed to effect the human body in one of six ways: nerve, asphyxiant/blood, blistering, choking/pulmonary, incapacitating and cytotoxic proteins. Nerve Agents – These agents act by inactivating a specific enzyme in the brain. This inhibits the ability of the brain to secrete a necessary neurotransmitter, which impairs the ability of the effected person’s body to function properly. Inhaled vapors may take effect within seconds. If the agent comes into contact with skin, effects can be delayed for several hours. Examples of nerve agents include: cyclosarin, sarin, VX, Novichok agents, soman, tuban and some insecticides. VX is a contact hazard and is classified as persistent. Most other nerve agents are inhalation hazards and are nonpersistent. Signs and symptoms of exposure to a nerve agent include: pinpoint pupils, headache, nausea/vomiting, diarrhea, blurred or dimmed vision, muscle twitches, profuse sweating, difficulty breathing, seizures, loss of consciousness and death. Asphyxiant/Blood Agents – These agents have many different modes of action on the human body. Some agents cause massive internal bleeding, others prevent the cells of the body from using oxygen, and others cause the body to create excessive amounts of lactic acid which slowly 33 Protective Equipment Means of Detection 1900s Chlorine Chloropicrin Phosgene Mustard Gas Atmospheric / Wind Dispersal Smell 1910s Lewisite Chemical Shells 1930s G-Series Nerve Agents Aircraft Bombs Blister Agent Detectors Color Change Paper 1960s V-Series Nerve 1990s Novichok Nerve Agents Classes of Chemical Weapons Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 35. turns the blood into an acid. The agents are fast-acting and are typically nonpersistent inhalation hazards. Examples of asphyxiant/blood agents include arsine, a derivative of arsenic; cyanogens chloride and hydrogen cyanide. Signs and symptoms of exposure to these agents include: confusion, nausea/vomiting, blueness of the lips or nailbed (cyanosis), gasping for air, seizures and death. Blistering Agents – These agents are contact hazards that are persistent. They act by forming acids or other compounds that damage skin and the respiratory system, leading to burns and breathing problems. Examples of blistering agents include: sulfur mustard, nitrogen mustard, lewisite and phosgene oxime. Lewisite has immediate effects upon contact, while the effects from the mustards may be delayed by four to 48 hours depending upon weather the agent is inhaled or comes into contact with the skin. Signs and symptoms of exposure to blistering agents include: severe irritation to the skin, eye and mucous membranes; redness and blistering of the skin; damage to the eyes; and respiratory problems ranging from mild distress to severe airway damage. Choking/Pulmonary Agents – These agents are very similar to blistering agents, in that they usually form acids. However, in these agents, the blisters are much more pronounced within the victim’s respiratory system. They typically act immediately upon contact and they are persistent inhalation hazards. The blisters they form within the respiratory system end up flooding the lungs with fluid, causing the victim to drown or suffocate. Examples of this type of chemical agent include: chlorine, hydrogen chloride, nitrogen oxides and phosgene. Signs and symptoms of exposure to these agents include: eye and skin irritation, difficulty breathing, excessive coughing, sore throat, chest tightness and wheezing. Incapacitating Agents – There is only one identified incapacitating agent – Agent 15, also called BZ. This agent acts by inhibiting the acetylcholine in the body’s peripheral nervous system. Acetylcholine is the neurotransmitter responsible for coordinating muscle function. It is extremely persistent in soil, in water and on most surfaces. It is a contact hazard that acts within 30 minutes if inhaled and up to 36 hours after contact with the skin. Signs and symptoms of exposure to BZ often are confused with drug intoxication. They include hallucination, erratic behavior, confusion, dilated pupils, dry mouth, lack of coordination and high body temperature. Cytotoxin Protein Agents – These agents degrade quickly in the atmosphere. They are designed to inhibit the creation of protein within the body, leading to flu-like symptoms. Examples include ricin and abrin. Signs and symptoms are usually seen between four and 24 hours of exposure, with more pronounced symptoms showing if the agent is inhaled or injected. Signs and symptoms of exposure to these agents are similar to those seen with the common flu, such as nausea/vomiting, coughing, difficulty breathing and gastrointestinal upset. However, there is typically gastrointestinal bleeding that is demonstrated by visible blood in the feces or vomit. Eventually, these symptoms progress towards liver and kidney failure, resulting in death. Other chemical weapons that the UXO Technician may encounter are not controlled or limited by the Chemical Weapons Convention but still pose a definite hazard to the Technician. These weapons include: 34 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 36. Defoliants – Defoliants destroy vegetation but are not immediately toxic to people. Agent Orange is a good example of a defoliant. Incendiaries – These are explosive chemicals that are used because of their destructive force from fire or explosion, not their chemical action. Napalm is a good example of an incendiary chemical weapon. Protection Against Chemical Warfare Agents It is obvious that chemical weapons pose a tremendous risk to human beings. Because the most common cause of any workplace injury is the unintentional accident, it is absolutely critical that any weapon that could potentially be a chemical weapon be treated with the utmost care. Suspected chemical weapons must be thoroughly and carefully analyzed prior to any handling in order to determine what hazards may be present. When handling potential or known chemical weapon, protection begins with wearing the appropriate personal protective equipment (PPE). Appropriate protection usually involves some level of respiratory protection as well as protective clothing. The specific appropriate PPE can only truly be determined once the specific chemical threat is identified. However, if the threat is unknown, it must be treated the same as the highest possible threat, which would include a fully-encapsulated chemical resistant suit with a self-contained air supply. Personal protective equipment and respiratory protection will be discussed in more detail in later sections of this manual. Another key point in the safe handling of chemical weapons involves the protection of structures or buildings within the hazard zone. By carefully protecting the buildings and structures within the chemical weapon’s hazard zone, people can continue to function in those spaces without fear of contamination. Protection may be as simple as erecting barriers of plastic sheeting, or as complex as mobile air supplies and substantial physical barriers. Decontamination If an individual, structure or area has been exposed to a real or suspected chemical weapon, it is imperative that immediate decontamination take place. The decontamination procedure differs with each specific chemical agent. Decontamination of some nonpersistent pulmonary agents, such as chlorine and phosgene, may be as simple as providing improved ventilation to the area. However, in some cases it may be necessary to chemically neutralize a substance, such as through the use of ammonia to neutralize hydrogen cyanide. Or the individual may require immediate medical intervention in order to survive. A thorough discussion of decontamination procedures can be found in later sections of this manual. 35 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 37. Notes 36 Nuclear, Biological & Chemical Hazard Safety HAZ-021-003-L
  • 38. Fire & Explosive Hazard Recognition HAZ-021-004-L Dangers of Uncontrolled Fire on UXO Sites Sites containing unexploded ordnance are typically not locations where fire is desirable, for obvious reasons. Many of the devices or other objects that the UXO Technician will potentially be working with are either heat sensitive or shock sensitive, or both. In order to prevent uncontrolled fires and provide the greatest measure of employee safety, there must first be a good understanding of what creates fire and how it can be controlled. Definitions Combustion – The sequence of heat-releasing chemical reactions between a fuel (something that can burn) and an oxidant (something which helps promote burning), which produces heat and light. Combustion does not necessarily require the presence of oxygen, such as when hydrogen gas burns upon contact with chlorine to form hydrogen chloride. Complete Combustion – The fuel burns in oxygen, producing a limited number of products, usually carbon dioxide and water. Complete combustion is almost impossible to achieve. Incomplete Combustion – Occurs when there isn't enough oxygen to allow the fuel to react completely with the oxygen to produce carbon dioxide and water. Most combustion results in the creation of carbon soot or ash as well as various other compounds. Smoldering Combustion - Slow, low-temperature, flameless combustion, sustained by the heat created when oxygen reaches the surface of a fuel. Solid materials that can sustain a smoldering reaction include coal, cellulose, wood, cotton, and tobacco. Conflagration – An uncontrolled burning or fire that threatens human life, health, property or ecology. It can be created either accidentally or intentionally. Sometimes, a conflagration may produce a firestorm in which the central column of rising heated air creates strong inward winds, which supply oxygen to the fire, further feeding its growth. Deflagration – A subsonic combustion process that propagates through a substance’s ability to conduct heat to adjacent materials. Detonation – A process of combustion that creates a supersonic shock wave through a body of detonable material, such as an oxygen-methane mixture or a high explosive. In a detonation, the supersonic shock wave compresses the surrounding material, which increases that material’s temperature to its ignition point. The ignited material burns behind the shock wave, releasing heat energy and a high-pressure volume of gas that propagates the shock wave, creating a self-sustaining reaction. Detonations can be produced by explosives, reactive gaseous mixtures, certain dusts and aerosols. Explosion – An extremely rapid and violent increase in volume of gas, accompanied by a release of energy usually in the form of high temperature. An explosion creates a shock wave. If the shock wave is a supersonic, then the then the source of the explosion is called a “high explosive.” If the shock wave is subsonic, then the sources of the explosion are called a “low explosive. 37 Fire & Explosive Hazard Recognition HAZ-021-004-L