Department of Labor
Safety and Health Annex for CBRNE Events
Mission Statement
This annex provides necessary guidelines to minimize the risk of injury or illness to deployed personnel who are involved in disaster response, recovery or mitigation operations as a result of a Chemical, Biological, Radiological, Nuclear or Explosive (CBRNE) incident. The outcome of this annex is to ensure that deployed personnel work and reside in as safe and healthful an environment as possible for the duration of their emergency assignment.
This annex is designed to integrate with the New York State Disaster Preparedness Plan and allows smooth transition into the National Response Plan.
Assumptions
- Responders will be knowledgeable in the Incident Command System (ICS 200 or higher).
- Compliance with the following applicable Public Employee Safety & Health (PESH) standards, including but not limited to Hazardous Materials Emergency Response (1910.120), Personal Protective Equipment (1910. 132), Respiratory Protection (1910. 134), Permit Required Confined Space Entry (1910.146), Fire Brigade (1910.156), Bloodborne Pathogens (1910.1030) were considered when developing this hasp.
- Responders will be medically cleared;physically capable, trained and issued the appropriate task specific Personal Protective Equipment (PPE).
- Responders will utilize Level C or Level D personal protective equipment.
- If entry into an area requires a higher level of protection to perform a task such as collecting a sample or specimen, Department of Safety & Health (DOSH) personnel will instruct other appropriately trained and equipped personnel on how to perform the required task and provide the necessary additional equipment.
- Coordination with federal, local and private sector assets will be accomplished through the Incident Command System.
DOSH Responder Work Tasks
- On-site Hazard Assessment
- Training
- Sampling & Monitoring
- Fit Testing
- Providing Technical Assistance
Risk Assessment
- Risk assessment willbe performed by our designated agency safety and health representative using preliminary site characterization data provided by the site Incident Commander (IC) or his designee.
- Responders will not enter into uncharacterized environments.
Hazard Assessment
- On-going PPE evaluation and continued effectiveness of PPE selection is one of the key components in minimizing exposures to responders. Once monitoring results are made available, a Job Hazard Analysis (JHA) can be performed to help ensure the correct PPE is utilized and the required training is conducted for the assigned tasks using the attached Incident Command SystemSite Safety Plan (ICSSSP).
- Consider all other hazards, for example:
- Has an oxygen deficient or potentially oxygen deficient atmosphere been identified?
- Has an explosive atmosphere or a potentially explosive atmosphere been identified?
- Physical Hazard(s) List all known physical hazards and their important characteristics. For example, noise, temperature, ionizing and nonionizing radiation, heavy equipment, permit required confined spaces, heat stress or cold stress, vibration, climbing/fall hazard, scaffolding, fire, welding/ cutting/ brazing, slips/ trips/falls, illumination, etc.
Hazard Evaluation
Monitoring will be performed whenever there is the possibility of exposure to chemical or physical hazards as identified in the hazard assessment section. The results of the hazard evaluation will determine the selection of the appropriate controls or methods of protection to ensure the safety and health of responders. Hazard monitoring will continue for as long as the potential for exposure to the hazard exists. Additionally, any changes in site conditions or work activities, or the introduction of new work activities will require a new hazard assessment and evaluation to document the changes in personal exposure to the new hazards.
During the course of site activities, personnel may need to conduct more intrusive activities than originally planned. No work will be conducted until a re-evaluation of the site has been completed by the Site Safety and Health Officer (SSHSO). If any hazardous conditions are encountered during the course of site activities, work will be suspended until the hazard can be further evaluated by the SSHSO. These situations will also require that thesite specific Health and Safety Plan be re-evaluated and amended to account for the changes in the site conditions. Under both situations, the DOSH Health and Safety Officer will be consulted for concurrence or direction.
All monitoring equipment used for hazard evaluation will be calibrated daily or before the sample is collected. The flow rates of the air monitoring pumps used for media sampling will be calibrated before and after sample collection. The pre and post calibrations will be averaged to obtain the final flow rate. Direct reading instruments will be calibrated using a zero gas, appropriate span gas or outdoor air, before use or according to the manufacturer's instruction.
PPE Assessment
Level C
Respirator, either Filtering Face Piece, Air Purifying Respirator (APR) or Powered Air Purifying Respirator (PAPR) with appropriate filter cartridge
Hooded chemical resistant clothing
Chemical resistant outer gloves
Level D
Coveralls, work boots, work gloves, safety glasses
Decontamination
DOSHResponders or the designated agency safety and health representative will verify the locations and adequacy of designated decontamination prior to entering a contaminated area,
Medical Considerations
Medical examinations and procedures are performed by or under the supervision of a licensed physician and are provided to employees free of cost, without loss of pay, and at a reasonable time and place. The need to implement a more comprehensive medical surveillance program will be re-evaluated in the event of an over-exposure during an incident.
The examining physician should be informed of the stresses the responder will be under prior to beginning the examination. All CBNRE responders should be directly examined by a physician or licensed health care professional (PLHCP). Particular attention should be paid to cardiovascular fitness, weight, general condition and any factors which would limit the individual’s ability to deal with exertion in general and heat stress in particular. A pulmonary function test in addition toadministration of the OSHA respirator history and questionnaire should be performed.The presence of any condition or medication which compromises the individual’s immune status is a contraindication for assignment as a CBRN responder. Claustrophobia is also a clear contraindication for assignment.
With the exception of smallpox and anthrax, vaccines are not available for agents likely to be used in a CBRN event. The incubation times for smallpox and anthrax, and the availability of antibiotic treatment for anthrax, allow sufficient time for post exposure vaccination if this becomes necessary.
CBRN responders must demonstrate, after they have received medical clearance that they have sufficient physical ability to perform the duties expected of them in the protective ensemble including the ability to climb over reasonable obstacles.
Post Exposure evaluation and follow-up
The PLCHP Designated by DOSH will determine the need for, content of and the extent of the post exposure evaluation and follow-up based on the specifics of the incident. Post exposure evaluation and follow-up will be provided at no expense to employees.
ICS SITE SAFETY PLAN (SSP)
/ 1. Incident Name / 2. Date/Time Prepared / 3. Operational Period / 4. Safety Officer (include method of contact)5. Supervisor/Leader / 6. Location and Size of Site / 7. Site Accessibility
Land Water Air
Comments: / 8. For Emergencies Contact: / 9. Attachments: Attach MSDS for each Chemical
10. Job Task/Activity / Hazards* / Potential Injury and Health Effects / Exposure Routes / Controls: Engineering, Administrative, PPE
Inhalation
Absorption
Ingestion
Injection
Membrane
Inhalation
Absorption
Ingestion
Injection
Membrane
Inhalation
Absorption
Ingestion
Injection
Membrane
Inhalation
Absorption
Ingestion
Injection
Membrane
Inhalation
Absorption
Ingestion
Injection
Membrane
11. Prepared By: / 12. Date/Time Briefed: / *HAZARD LIST: Physical/Safety, Toxic, Explosion/Fire, Oxygen Deficiency, Ionizing Radiation, Biological, Biomedical, Electrical, Heat Stress, Cold Stress, Ergonomic, Noise, Cancer, Dermatitis, Drowning, Fatigue, Vehicle, Diving /