Attachment_26_Chemical_Hygiene_Plan.pdf

Training Operations and Support

Services – COBRATF

Attachment 26

CDP Chemical Hygiene Plan

CDP COBRATF Chemical Hygiene Plan Revision 7

Effective Date: 5/11/11

TABLE OF CONTENTS

(Page 1 of 3)

1.0 INTRODUCTION

1.1 Purpose

1.2 Development

1.3 Elements

2.0 POLICY AND RESPONSIBILITIES

2.1 Policy

2.2 Responsibilities

3.0 PHYSICAL FACILITY AND VENTILATION SYSTEM

3.1 Description of Facility

3.2 Ventilation of Chemical Agent Areas

4.0 ENVIRONMENTAL MONITORING

4.1 Policy

4.2 Airborne Exposure Limits (AEL)

4.3 Limitations and Restrictions

4.4 CDP COBRATF Toxic Chemical Agent Detection

4.5 Detection Equipment

4.6 CDP COBRATF Air Monitoring Plan and Requirements

4.7 Quality Control

5.0 STANDARD OPERATING PROCEDURES

5.1 Policy

5.2 Responsibilities

5.3 Operational SOPs

5.4 Personnel Limits

6.0 HAZARD ANALYSES

6.1 Criteria

6.2 Hazard Risk Assessment Matrix

6.3 Hazard Analysis Process

6.4 Risk Acceptance

6.5 Records

TABLE 1. CDP COBRATF HAZARD RISK ASSESSMENT MATRIX………………………19

7.0 PERSONAL PROTECTIVE EQUIPMENT

7.1 Use of Personal Protective Equipment

7.2 Hazard Assessment and Equipment Selection

7.3 Levels of Protection

7.4 Respiratory Protection Program…...……………………………………………..22

7.5 Temperature Considerations

7.6 Personal Protective Equipment (PPE) Training

(Page 2 of 3)

8.0 TRAINING AND INFORMATION

8.1 CDP COBRATF Personnel Training Requirement

8.2 Initial Training

8.3 Annual Training

8.4 Hazard Communications (HAZCOM) Training

9.0 PERSONNEL PRACTICES

9.1 Two-Person Rule

9.2 Laboratory/Training Bay Restrictions

9.3 Emergency Supplies

9.4 Chemical Agents

9.5 Other Chemicals

9.6 Material Safety Data Sheets (MSDS)

10.0 INSPECTIONS/MAINTENANCE

10.1 Safety Inspections

10.2 Personnel Participation

10.3 Safety Equipment

10.4 Passageways

10.5 Equipment Maintenance and Repair

11.0 RECORD KEEPING

11.1 Personnel Medical Records…………………………..……………………...…...27

11.2 Personnel Exposure Records

11.3 Training Records

12.0 MEDICAL SURVEILLANCE PROGRAM

12.1 Physical Examinations

12.2 Medical Surveillance Criteria for Personnel Working With Nerve Agents

12.3 Pre-Placement, Periodic, and Termination Medical Examinations

12.4 Non-Routine Medical Examinations

12.5 Competent Medical Authority (CMA) Information…………………………….. 30

12.6 RBC-ChE Determinations for Personnel Working With Nerve Agents

12.7 Medical Personnel and Facilities

13.0 EMERGENCY RESPONSE

13.1 Laboratory Spills and Accidents

13.2 Facility-Wide Emergency Response

13.3 Evacuation Procedures

13.4 Chemical Event Criteria, Reporting, and Investigation

(Page 3 of 3)

14.0 DECONTAMINATION AND WASTE DISPOSAL

14.1 Decontamination

14.2 Guidelines for Determining the Decontamination Level of Items or Materials

14.3 Storage and Transport

14.4 Decontamination Procedures

14.5 Waste Disposal

15.0 CHEMICAL AGENT HAZARDS AND EFFECTS

15.1 General Information

15.2 Signs and Symptoms of Exposure

15.3 Rate of Action

15.4 Dosage

15.5 Chemical and Physical Properties

1.0 INTRODUCTION

1.1 Purpose. This document constitutes the Center for Domestic Preparedness (CDP)

Chemical, Ordnance, Biological, Radiological Training Facility (COBRATF) Chemical

Hygiene Plan (CHP) for conducting work with chemical agents at the CDP COBRATF.

The purpose of the plan is to describe the practices, procedures, equipment, and facilities used at the CDP COBRATF to protect the health of the personnel who work in, or are visitors to, the facility; and to keep potential agent exposures below specified limits. The plan was prepared in accordance with (IAW) the guidelines presented in the CDP

COBRATF Standards Document (CDP COBRATFSD) for Use of Chemical Agents, and the applicable documents referenced in the CDP COBRATFSD.

1.2 Development. The development and implementation of the CHP is predicated on the cardinal principle for any location or operation involving chemical warfare agents - limit potential exposure to a minimum number of personnel, for a minimum period of time, and to a minimum amount of the agent and other hazardous materials consistent with safe and efficient operations.

1.3 Elements. The CHP includes the elements of both the CDP COBRATFSD and 29 Code of Federal Regulations (CFR) 1910.1450, Appendix A, DA PAM 385-61 Toxic Chemical

Agent Safety Standards, and clearly identifies the responsibilities of both the CDP

COBRATF first line supervisors and the CDP COBRATF workers.

2.0 POLICY AND RESPONSIBILITIES

2.1 Policy

2.1.1 Applicability. The CHP applies to all CDP COBRATF personnel involved in chemical agent operations or with the potential for possible exposure to chemical agents. These personnel must read and understand applicable procedures referenced in this document as part of the initial in-processing/certification program.

2.1.2 The Cardinal Principle. Toxic chemical operational safety procedures will enforce the cardinal principle to limit the potential exposure to a minimum number of personnel, for a minimum period of time, and to a minimum amount of the chemical agent, consistent with safe and efficient operations.

2.2 Responsibilities

2.2.1 Chemical Agent Manager (CAM)/CDP COBRATF Assistant Director (AD).

In the CDP COBRATF Assistant Director’s capacity as the CDP COBRATF

CAM, or working in conjunction with the CAM, the CDP COBRATF Assistant

Director shall:

a. Work with CDP COBRATF administrators to develop policies and practices for the safe handling of chemicals

b. Ensure that required inspections are conducted and that records are properly maintained

c. Advise CDP COBRATF personnel on safety matters and provide technical assistance as needed

d. Review the CHP annually

e. Serve as the chair person of the CDP COBRATF Safety Committee

f. Provide technical oversight in the development and implementation of the provisions of the CHP

g. Observe dry runs and approve readiness to conduct chemical agent operations

h. Determine the level and types of required personal protective equipment

(PPE)

i. Ensure implementation of the CHP

2.2.2 Chemical Hygiene Officer (CHO) shall:

a. Prepare and implement a CHP

b. Ensure CHP procedures are understood and followed, and that assistance is provided

c. Work with the CAM to develop policies and practices for the safe handling of all chemicals stored, used at, delivered to, and removed from the CDP

COBRATF

d. Ensure that required inspections are conducted and records are maintained

e. Assist personnel with safety matters and provide technical assistance when needed

f. Review the CHP annually and prepare and submit necessary revisions

g. Serve as advisor to the CDP COBRATF Safety Committee

h. Provide technical guidance in the development and implementation of the provisions of the CHP

i. Observe dry runs and recommend collective and individual readiness to conduct chemical agent operations

j. Assist in the determination of the level and types of required PPE used throughout the CDP COBRATF

2.2.3 Laboratory Director shall:

a. Assume supervisory responsibility for Chemical Hygiene Program requirements in the CDP COBRATF Laboratory

b. Verify agent accountability forms

c. Ensure CDP COBRATF lab workers:

1) Know and follow chemical hygiene rules

2) Know protective equipment and clothing requirements and that protective equipment is available and in working order

3) Are properly trained

4) Verify and sign agent accountability documents

d. Provide regular, formal chemical hygiene and housekeeping inspections including routine inspections of emergency equipment, IAW the requirements of the CDP COBRATFSD and applicable CDP COBRATF SOPs

e. Know the current legal requirements concerning regulated substances

f. Ensure that the facilities and training are adequate for any material being ordered or in use

2.2.4 CDP COBRATF Laboratory Workers shall:

a. Plan and conduct each operation IAW CDP COBRATF chemical hygiene procedures

b. Develop and maintain good personal chemical hygiene habits

2.2.5 Agent Pourers shall:

a. Plan and conduct chemical agent pouring operations IAW CDP COBRATF chemical hygiene principles and procedures

b. Verify and sign agent accountability documents

2.2.6 Instructor Personnel shall:

a. Plan and conduct chemical agent training IAW CDP COBRATF chemical hygiene procedures

b. Follow accepted chemical safety practices

3.0 PHYSICAL FACILITY AND VENTILATION SYSTEM

3.1 Description of Facility

3.1.1 Criteria for Chemical Agent Emissions. The CDP COBRATF is designed to prevent agent release exceeding the source emission limits specified in Figure 6.1 of the CDP COBRATFSD. Agent emissions are controlled at the CDP

COBRATF by the use of negative pressure, controlled pressure, controlled airflow, walled and multiple walled containment structures, filtered enclosures, and filtered exhaust ventilation systems.

3.1.2 Agent Process Elimination. Floor drains are installed in the training bays and laboratories utilizing chemical agents, and in other locations where personnel emergency showers are located. All drains receiving agent or agent contaminated effluent are connected to a sump and waste collection tank. Treatment and monitoring of final chemical agent neutralization and waste water takes place in the CDP COBRATF wastewater storage tank prior to the water being burned in the incinerator.

3.1.3 Facility Construction and Plans. The exterior of the CDP COBRATF is constructed of conventional concrete, steel, and brick materials. All toxic areas are constructed and provided with surface finishes (walls, floors, and ceilings) such that chemical agents and decontaminated materials are contained in these areas, do not react chemically with the components and finishes used in the construction and are not adsorbed by the materials that they might come in contact with. Agent resistant Epoloid Epoxy paint is the sealant used on the walls, floors, and ceilings. The exits and fire protection systems were designed

IAW the National Fire Protection Association (NFPA) guidelines. The electrical system is designed IAW the National Electric Code (NEC). The following plans and drawings are maintained on file at the CDP COBRATF for review to assess the adequacy of the CDP COBRATF physical facilities for chemical agent operations:

a. Floor plans of the chemical agent areas, which depict the location of hoods, sinks, showers, glove boxes, training bays, etc.

b. Site map showing the location of the chemical agent areas in relation to other

CDP facilities and the surrounding area

c. Ventilation system diagram and drawings to include filter banks, fan and motor ratings and all associated chemical agent handling systems

d. Alarm sensors/ Intrusion Detection Systems (IDS)

3.1.4 Chemical Agent Rooms. Entry to the chemical agent laboratory and training bays is restricted to authorized personnel. Exits are never blocked. Means of egress from a room or training bay where chemical agent is present always exits into an area of lesser hazard. Showers and sinks are available for washing hands and arms prior to leaving chemical agent areas. Emergency deluge showers and eyewash fountains are readily accessible to all work situations within the chemical agent laboratory. One deluge hose is located in the hot anteroom to the medical facility. Compressed gas cylinders are stored in a safely arranged location outside of the laboratory or training bays.

3.1.5 Signs. All entrances to laboratory rooms, training bays and storage containers

(e.g., refrigerators, cabinets, hoods) where chemical agent is present are posted with signs warning personnel of the presence and type of chemical agent within the room or bay and any special entrance requirements. Emergency telephone numbers are posted next to each phone in the laboratory and training bays. All chemical containers, including waste containers, are properly labeled to show contents and associated hazards. All safety and first aid equipment are labeled, including showers and eye washes.

3.1.6 Effluent Control. Engineering controls are used to avoid inadvertent transfer of chemical agent to uncontaminated areas and equipment. All water outlets in agent areas are fitted with check valves to prevent backflow of water into the supply lines. The air-carrying systems for the nine ventilation systems are constructed of welded 316L stainless steel to preclude leakage or entrapment of agents from pickup to exhaust stacks.

3.2 Ventilation of Chemical Agent Areas

3.2.1 Hoods and Glove boxes. Laboratory personnel perform all toxic agent operations in laboratory hoods that provide an average face velocity of 100+/-10 linear feet per minute (lfpm) through the working opening. No reading may deviate more than 15%. There are three ventilation hoods in the laboratory. One hood contains four tornado proof vaults, which store the neat agent. Additionally, this agent-storage hood has a glove box ducted into the hood. The other two hoods are used for analytical work. Neat agent work in the hoods and glove boxes is conducted over spill trays of suitable size to contain agent spills. The glove box is equipped with a differential pressure gauge to monitor the negative water gauge pressure within the glove box. The laboratory fume hoods have the following characteristics:

a. Surfaces impervious to agent penetration and easily decontaminated

b. Streamlined edges over surfaces over which air flows

c. Constant and uniform air flow across the face of the hood independent of hood sash opening

d. Additional exhaust at lower back of the hood

e. Make-up air supplied to the hood is un-tempered and uniformly distributed through the ceiling

f. Both visual and audible alarms are installed on each laboratory hood to ensure the air flow remains at 100 +/- 10 lfpm. Alarms engage when any condition causes the average face velocity to fall below 85 lfpm for fume hoods, or -

0.25 inches of water column for glovebox internal pressure. The visual hood alarms are visible outside of the laboratory. During non-duty hours, if loss of negative pressure occurs, an alarm will sound in the guard house. The hood alarms are connected to back-up power systems.

3.2.2 Ventilation Systems. There are nine separate ventilation systems within the CDP

COBRATF complex. Each system has a set of pre-filters, high efficiency air filters (HEPA) and high efficiency gas air filters (HEGA). The filter elements of each bank are 24" x 24" with the capability of handling 1000 cubic feet per minute (cfm), and the filter elements are of "bag-in bag-out" design. The exhaust stack and filter banks are continuously monitored with a Miniature Continuous

Air Monitoring System (MINICAMS). Depot Area Air Monitoring System

(DAAMS) sampling and analysis is conducted any time an unknown alarm occurs when monitoring the filter banks or the exhaust stack to verify or deny the presence of agent. These ventilation systems are designed so that the air flow throughout the CDP COBRATF is from the clean areas (dressing area and laundry) to the agent training bays. Starting with the hot area of the showers and continuing to the training bays, negative pressure is employed and incrementally decreased in order to maintain air flow toward the agent training bays. All systems are manifolded into a single 75-foot exhaust stack.

3.2.3 Backup-Emergency Power and Blowers. Backup emergency power (automatic start generators) are installed to prevent exposure in the event of a power failure.

Backup systems are maintained under a rigid preventive maintenance program.

All MINICAMS in continuous operation are connected to uninterruptible power supply (UPS) systems, except when a UPS is being repaired or replaced. The emergency backup power generators are tested weekly. The tests are documented, and the records are available for inspection and review as requested.

3.2.4 Filter Tests and Records. Records are maintained which note filter replacement dates for each air filtering system, filter test results for new and replacement filters, and between-filter-bank monitoring results. Monitoring between filters is conducted continuously by MINICAMS. A rigorous preventive maintenance program has been established, implemented, and is routinely audited by the CDP

QA Program. All records are available for inspection as requested.

3.2.5 Filter Banks. Each filter bank is equipped with a differential pressure gauge to continuously monitor the differential pressure across the filter bank. All filter pad magnehelic gauges will be calibrated on an annual basis. Readings shall be recorded on a daily basis. The differential pressure is checked at the filter banks daily for any increase in pressure which might be an indication of the filters starting to saturate. The pre-filters are changed-out every six months which eliminates small particles from entering the charcoal filters. Once each year, a leak test is performed on both High Efficiency Gas Air (HEGA) and High

Efficiency Particulate Air (HEPA) filters per American National Standards

Institute/ American Society of Mechanical Engineers (ANSI/AMSE) N510-2007.

Should any breakthrough be determined during the halide testing, the filters in front of the breakthrough will be replaced. Should any agent be detected, the filter in front of the affected area will be replaced.

4.0 ENVIRONMENTAL MONITORING

4.1 Policy

4.1.1 Various detection methods and equipment are available and will be utilized as required by the CDP COBRATFSD. Real time, low level monitors with alarms will be utilized whenever personnel are allowed to enter CDP COBRATF toxic chemical agent training areas and work places where toxic chemical agents are being used or toxic chemical agent operations are being conducted.

4.1.2 No CDP COBRATF personnel or students will be permitted to train in toxic chemical agent concentrations which exceed the COBRATF Maximum

Concentration Limit (CMCL) standards established for both GB and VX agents.

4.1.3 The "Cardinal Principle" and the "Two Person Rule" will be observed and enforced at all times during the conduct of and participation in CDP COBRATF toxic chemical agent operations.

4.2 Airborne Exposure Limits (AEL)

4.2.1 General Overview. CDP COBRATF personnel working without protection from the inhalation of agent vapors in areas where toxic chemical agents may be present will not be exposed to concentrations exceeding the AELs listed in Figure

6-1 of the CDP COBRATFSD. These limits are:

a. GB: 0.0001 mg/m3 based on Short Term Exposure Limit (STEL) [15 minute time weighted average (TWA)]

b. VX: 0.00001 mg/m3 based on Short Term Exposure Limit (STEL) [15 minute time weighted average (TWA)]

4.2.2 CDP COBRATF personnel working or training without respiratory protection in areas where chemical agent may be present will not be exposed to concentrations exceeding the AEL in Figure 6-1 of the CDP COBRATFSD.

When known or suspected chemical agent concentrations exceed these values, appropriate protective clothing and equipment are worn. Unless otherwise noted, AEL in this document refers to 15 minutes (STEL) for workers without regard to respiratory protection.

4.2.3 For emergency escape, a National Institute of Occupational Safety and Health

(NIOSH) Chemical, Biological, Radiological, Nuclear (CBRN) approved Air

Purifying Escape Respirator (APER) is acceptable.

4.3 Limitations and Restrictions

4.3.1 Eight Hour Exposure Limit. Unmasked CDP COBRATF personnel in work areas monitored at up to the worker population limits (WPL) will not be exposed to concentrations of chemical agents GB greater than 0.00003 mg/m3 and agent

VX greater than 0.000001 mg/m3 averaged over 8 hours (DA PAM 385-61 Toxic

Chemical Agent Safety Standards; table 2-1). Where a deliberate release of chemical agent into training operation areas is an operational requirement, means, methods and procedures (including use of engineer controls) will be implemented to ensure unrelated personnel are protected within the above limits. This concentration does not apply to the toxic training activities at the CDP

COBRATF, but will be applied to selected cold areas of the training building.

4.3.2 Source Emission Limit. In no case will the concentration of chemical agent at the point of deliberate release from engineering controls (effluent/emission from exhaust ventilation agent filtration systems or the CDP COBRATF solid waste incinerator) exceed the source emission limit of 0.0003 mg/m3 for GB and VX

(DA PAM 385-61, table 6-1).

4.4 CDP COBRATF Toxic Chemical Agent Detection

4.4.1 Prior to entry into toxic chemical agent training bays and hot laundry areas, remote monitoring using a low-level near real time monitor (NRTM) with alarm capability will be performed to assure interior airborne agent concentrations do not exceed Immediately Dangerous to Life and Health (IDLH) levels. Current

CDP COBRATF methodologies utilize MINICAMS for continuous low level monitoring with the DAAMS as a confirmation method.

4.4.2 Low-level NRTMs with alarm capability will also be used to monitor perimeter areas outside and around the training bay areas to include the laboratory and laboratory hood areas.

4.4.3 MINICAMS, which include alarm capability, are used to monitor the air inside toxic chemical training bays during the conduct of toxic chemical agent training.

4.4.4 Low-level NRTMs with alarm capability will be used to monitor for agent break-through in filter banks, filter bank air emission stack and the solid waste incinerator stack.

4.5 Detection Equipment

NOTE: M8 detector paper will not detect agent vapor or small droplets of agent. It does not provide any indication of agent concentration levels.

4.5.1 M8 Detector Paper. M8 detector paper is an off-white paper that has been treated with a combination of dyes that produce a distinctive color change when touched to a nerve agent.

a. VX: When touched to VX agent the paper will turn a dark green color

b. GB: When touched to GB agent the paper will turn a yellow color

4.5.2 M256A1 Detector Kit Sampler

a. The plastic detector component has all the reagents self-contained in finger crushable glass ampoules. The detector is issued in a manner similar to the detector paper.

b. In the absence of GB/VX, a distinctive blue-color change is obtained after proceeding according to the instructions for use of the sampler. The instructions are printed on the outside of the heat sealed container base.

c. The sensitivity of the sampler decreases as the temperature decreases

4.5.3 MINICAMS

a. The MINICAMS is a non-portable continuous low-level air sampling monitor and alarm

b. The MINICAMS is capable of detecting agent concentrations which are below the STEL for GB (0.0001 mg/m ) and VX (0.00001 mg/m

c. MINICAMS are used to monitor agent vapor concentrations throughout areas in the CDP COBRATF Training Building that potentially have or are confirmed to have agent vapor present

4.5.4 Depot Area Air Monitoring System (DAAMS)

a. The DAAMS is a portable air-sampling unit which is designed to draw a controlled volume of air through a tube filled with a solid sorbent (e.g., Chromosorb 106®)

b. As air is passed through the solid sorbent tube, agent is collected. After sampling for the predetermined period of time and flow rate, the tube is removed from the vacuum line and sent to the CDP COBRATF Laboratory for analysis to determine the presence, type and quantity of agent collected in the sample. Laboratory analysis is conducted by means of gas chromatography (GC) utilizing a flame photometric detector.

c. The sensitivity of this technique allows for sampling down to the STEL and provides low-level detection capability

4.5.5 Improved Chemical Agent Monitor (ICAM). The ICAM is a hand-held, battery-powered ion-mobility spectrometer alarm, used in CDP COBRATF responder training to detect GB at concentrations of 0.03 mg/m with a response time of less than 30 seconds.

4.6 CDP COBRATF Air Monitoring Plan and Requirements. A written CDP COBRATF

Air Monitoring Plan has been developed IAW the requirements specified in Section 6.3.4 of the CDP COBRATFSD. The Air Monitoring Plan addresses the air monitoring of all chemical agent areas within the CDP COBRATF. Refer to the CDP COBRATF Air

Monitoring Plan for details.

4.7 Quality Control. A CDP COBRATF Air Monitoring Quality Control Plan and a

Laboratory Quality Control Plan have been developed IAW the requirements specified in the CASARM Quality Assurance Plan developed by Research, Development and

Engineering Command (RDECOM). Refer to each of the QC Plans for specific details.

5.0 STANDARD OPERATING PROCEDURES

5.1 Policy

5.1.1 Standard Operating Procedures (SOPs) will be prepared for any CDP COBRATF operation directly involving the use of toxic chemical agents or operations which pose potential hazards which are associated with the effects of toxic chemical agents.

5.1.2 All CDP COBRATF toxic chemical operational safety procedures will be developed from and be consistent with the guidelines in the CDP COBRATFSD.

5.1.3 CDP COBRATF SOPs and changes to SOPs that are to be used to support execution of toxic chemical agent operations will be prepared, reviewed, validated and approved prior to the operation it is effecting.

5.1.4 CDP COBRATF SOPs and changes to SOPs will be coordinated with and reviewed at a minimum by the CDP COBRATF CHO, Quality Manager, and approved by the CDP COBRATF Assistant Director prior to being used to support toxic chemical agent operations.

5.1.5 CDP COBRATF SOPs being used to support execution of toxic chemical agent operations will be made available at applicable work sites. Where reliable communication between instructors/cadre and operations control is in effect, SOPs need not be posted within the toxic chemical agent operational area(s).

5.1.6 The following procedures will be applicable to all SOPs regardless of the operation:

a. Work not necessary for operations involving toxic chemicals will not be conducted concurrently, i.e., lab equipment calibration or toxic agent training in the CDP COBRATF hot area. Additionally, during the conduct of CDP

COBRATF toxic chemical agent operations, no other operation will be conducted that may potentially disrupt or distract emergency response or operations personnel designated to support the on-going toxic chemical agent operation.

b. No chemical agent handling operation in the chemical agent laboratory will be conducted without a minimum of three personnel present. Two personnel will be present to meet the "Two Person Rule" requirements. The third individual will serve as a Safety Monitor. The Safety Monitor will supervise and monitor the operation for unsafe acts and provide emergency action notification to Safety Control.

c. The "Two Person Rule" will always be in effect when conducting agent operations in the lab, toxic chemical agent "pouring" operations, or any other operation that results in the handling of toxic chemical agents or gaining access to them.

d. Safe work practices will be observed at all times.

NOTE: Prior to participating in any activity requiring the use of respiratory protection, personnel shall submit to pre-activity and post-activity vital monitoring (blood pressure and heart rate). The recording of pre-activity vitals will serve as objective evidence of acceptable physiological condition required for respirator use. Post vital recording will provide comparative data where the use of respirator protection was required. Data collected from pre and post vitals will be considered when conducting hazard analyses and risk assessments. See Paragraph 7.5, Temperature Considerations.

e. There will be no deviations from SOP requirements without prior approval from the CDP COBRATF Assistant Director, or his/her designated representative.

5.2 Responsibilities

5.2.1 CDP COBRATF Assistant Director shall:

a. Ensure standard operating and Hazard Analysis Program procedures are developed, implemented, reviewed and approved for the conduct of CDP

COBRATF toxic chemical agent-related operations

b. Ensure development of the necessary policies, procedures and requirements for the review by and training of operators/workers required to implement established procedures

c. Establish and enforce policies for strict compliance with approved operational procedures

5.2.2 Chemical Hygiene Officer shall:

a. Ensure a formal index of approved CDP COBRATF SOPs is maintained

b. Ensure a procedure for the recording and filing of approved procedural changes effecting CDP COBRATF SOPs is implemented

c. Ensure approved procedural changes are implemented during annual revision of SOPs

d. Conduct annual review and revision (if required) of all toxic chemical agent related CDP COBRATF SOPs. The recommended changes will be reviewed by appropriate staff representatives for approval.

e. Ensure a formal index of approved SOPs requiring hazard analysis/risk assessment program review is maintained

f. Enforce requirements for the conduct of an annual review of hazard analysis/risk assessments IAW established policies

g. Review hazard analysis program and risk assessment results; forward to all applicable staff agencies for review and approval

h. Ensure risk assessments are conducted for all approved programs of instruction (POI) lesson plans, and that an annual review is conducted and properly reviewed and approved

i. Observe dry runs and recommend readiness to conduct chemical agent operations

5.2.3 Supervisors shall:

a. Ensure all personnel have reviewed, been trained in, and verified their understanding of applicable SOPs by demonstrating proficiency in these operations

b. Stop any operation which is not being executed IAW prescribed procedures or is viewed as unsafe

5.2.4 Individuals shall:

a. Review all SOPs applicable to assigned operation or SOPs which are designated for reading by supervisory personnel

b. Verify reading and understanding of applicable SOPs by signing a verification-and-understanding statement and by demonstrating proficiency in the SOPs

c. Stop any procedure or operation which is not being executed IAW prescribed procedures or is viewed as being unsafe

5.3 Operational SOPs. Operational SOPs will describe in detail all necessary operational procedures, safety and health requirements, operating limits, and actions to be taken during an event or emergency, and the location of required equipment needed.

5.4 Personnel Limits. Personnel limits will allow for necessary supervisory and transient personnel (in the context of the cardinal principle), and for reinforcing requirements specified in SOPs and/or local policy (safety/security/surety). Supervisors/instructors will be responsible for monitoring the areas and enforcing requirements specified/ outlined in CDP COBRATF SOPs.

6.0 HAZARD ANALYSES

6.1 Criteria. A job hazard analysis/risk assessment will be conducted IAW the CDP

COBRATF Hazard Analysis Program for all new toxic chemical agent operations involving chemical agents or whenever there is a change in process or control measures that may result in any increase in airborne or contact concentrations of chemical agents.

The CDP COBRATF has adopted and modified as necessary the Chemical Defense

Training Facility (CDTF) Risk Assessment Program. Three criteria are used in the hazard analysis process to describe and assess the hazards associated with a given operation or process; the severity of the hazard, the probability of occurrence, and the resulting risk level. The levels within each criterion category are defined as follows:

6.1.1 Severity

a. Catastrophic - Likely to cause death

b. Critical - Likely to cause severe injury

c. Marginal - Likely to cause minor injury

d. Negligible - Likely to cause no injury

6.1.2 Probability

a. Frequent - Likely to occur continuously or very often

b. Likely - Likely to occur several times

c. Occasional - Likely to occur some time

d. Remote - Possible (but not likely) to occur

e. Unlikely - Will not occur

6.1.3 Risk Levels

a. Extremely High Risk – Loss of ability to accomplish mission

b. High Risk - Significantly degrades operational capabilities in terms of required safety standards

c. Moderate Risk – Degrades operational capabilities in terms of required safety standards

d. Low Risk – Little or no impact on accomplishment of mission

6.2 Hazard Risk Assessment Matrix. The severity, probability, and risk-level criteria are correlated in a Risk Assessment Matrix to define the risk level associated with each combination of severity-level and probability of occurrence. The Risk Assessment

Matrix that will be used at the CDP COBRATF is shown in Table 1.

6.3 Hazard Analysis Process. In conducting a hazard analysis for a given operation, all of the hazards associated with the operations are first identified and individually listed on a

Risk Assessment Worksheet (RAW). The severity level of each hazard on personnel or equipment is determined and documented on the RAW. Then the safety procedures and precautions that have been implemented in the SOP to mitigate the hazard are listed for each hazard on the RAW, and the probability of occurrence of the hazard after the implementation of the hazard-mitigation procedures is determined and noted on the

RAW. Then, from the identified severity-level and probability of occurrence (after mitigation), the risk level of each hazard is determined from the Risk Assessment Matrix and listed on the RAW. The overall risk level of the operation is then assigned and listed on the RAW as the highest risk level identified for any of the individual hazards. The hazard analysis evaluation for each operation will be performed by a team that will include at least one CDP COBRATF employee/contractor who has experience and knowledge specific to the procedure or operation being evaluated. In addition, at least one member of the team will be knowledgeable in the specific hazard analysis methodology being used.

6.4 Risk Acceptance. Decisions to accept risks from identified hazards will be made at a management level commensurate with the risk. To accomplish this, the identified risk level for an operation or SOP will be categorized in a tiered hierarchy. The risk acceptance criteria for the CDP COBRATF are shown in Table 1. The risk acceptance will be approved in writing on the RAW.

6.5 Records. Documentation of the personnel participation in the development and implementation of each hazard analysis will be maintained. A written record of the hazard analysis (the signed and approved Risk Assessment Worksheet) will be maintained. Personnel and their representatives will have access to all of the information developed.

TABLE 1. CDP COBRATF HAZARD RISK ASSESSMENT MATRIX

PROBABILITY

Frequent Likely Occasional Remote Unlikely

Catastrophic

EXTREMELY HIGH

HIGH

MODERATE

Critical MODERATE

Marginal HIGH MODERATE LOW

Negligible MODERATE

RISK ACCEPTANCE CRITERIA

Risk Level Acceptance

Extremely High Unacceptable

High Undesirable, but acceptable with authorization by Superintendent, CDP

Moderate Acceptable with concurrence of CAM and CHO

Low Acceptable without review

SEVERITY

7.0 PERSONAL PROTECTIVE EQUIPMENT

7.1 Use of PPE. PPE for the protection of the eyes, face, ears, and extremities, protective clothing, respiratory devices, and protective shields and barriers will be provided to CDP

COBRATF personnel, used by the personnel, and maintained in a sanitary and reliable condition. The level of protection required for each category of CDP COBRATF personnel will be determined by the hazard analysis for each operation or as otherwise specified in the SOP. Protective clothing requirements will vary depending on the type of toxic chemical operations being conducted. Supervisors are responsible for ensuring all personnel are in the proper Protective Clothing & Equipment (PC&E) levels prior to engaging in any toxic chemical agent related operation.

7.2 Hazard Assessment and Equipment Selection. The CHO will conduct an annual hazard assessment of the workplace to determine which current or potential hazards necessitate the use of PPE. From the hazards identified in the hazard assessment, the

CHO will select the types of PPE that will protect personnel from the identified hazards, communicate selection decisions to each affected individual, select PPE that properly fits each affected individual, and ensure that personnel use the selected PPE. CDP

COBRATF Assistant Director/Chemical Agent Manager (AD/CAM) will verify that the required workplace hazard assessment for PPE has been performed. The written verification will identify the workplace evaluated, the person who certifies that the evaluation has been performed, the date(s) of the hazard assessment, and a statement that identifies the document as a certification of hazard assessment. Defective or damaged

PPE will not be used.

7.3 Levels of Protection. The levels of PPE are based on the operation of the job, the work processes involved, and any job and/or hazard assessments which have been conducted.

The levels of PPE will be from levels A-D. The following are the different levels of protection:

NOTE 1: Any items marked with an asterisk are optional.

NOTE 2: The annual CDP COBRATF Hazard Assessment will be an additional basis used for determining any and/or all optional PPE required to be worn.

7.3.1 Level A

a. Self Contained Breathing Apparatus (SCBA)

b. Fully encapsulating chemical-resistant suit

c. Coveralls*

d. Undergarments

e. Latex inner gloves (except when unexploded ordnance is present)

f. Chemical-resistant outer gloves

g. Chemical-resistant boots with toe and shank (worn over or under fully encapsulating suit, depending on suit construction)

h. Hard hat under suit*

i. Disposable protective suit, gloves, and boots may be worn over fully encapsulating suit*

7.3.2 Level B

a. Self Contained Breathing Apparatus (SCBA)

b. Hooded Chemical-resistant clothing

c. Latex inner gloves (except when unexploded ordnance is present)

d. Chemical-resistant outer gloves

e. Chemical-resistant outer boots

f. Chemical-resistant, disposable outer boots*

g. Hard hat*

7.3.3 Level C

a. Air Purifying Respirator (APR)

b. Hooded Chemical-resistant clothing

c. Underclothing

d. Chemical glove liners

e. Chemical-resistant outer gloves

f. Chemical-resistant outer boots

g. Chemical-resistant, disposable outer boots*

h. Hard hat*

7.3.4 Level D

a. Coveralls and/or work clothes

b. Gloves*

c. Leather or chemical-resistant boots or shoes with steel toe and shank*

d. Chemical-resistant, disposable outer boots*

e. Safety glasses or chemical splash proof goggles*

f. Hard hat*

g. Escape mask*

7.4 Respiratory Protection Program. A full face piece negative pressure respirator has been approved for use by both CDP COBRATF personnel and students. The use, medical evaluation requirements, fit testing procedures, and training for the approved protective mask are described in the CDP COBRATF Respiratory Protection Program

Plan.

7.5 Temperature Considerations. The CDP Heat and Cold Stress Plan shall be the guideline to prevent heat exhaustion and fatigue while wearing Chemical Agent

Protective Clothing. For new protective over-garments that may be used at the CDP

COBRATF, the CDP develops, reviews and complies with heat stress guidelines based on the specific PPE, environmental factors, and physiological conditions of personnel.

7.6 Personal Protective Equipment (PPE) Training. Before being allowed to perform work requiring the use of PPE, each individual must demonstrate an understanding of the training and ability to use PPE properly. PPE training records that contain the name of each employee trained, the training date(s), and the scope of training will be maintained.

When the CDP COBRATF Assistant Director/CAM or the CHO has reason to believe that any affected individual who has already been trained does not have the understanding and skill required; the employee will be retrained. Circumstances requiring re-training include changes in the workplace that render previous training obsolete, changes in the types of PPE to be used that render previous training obsolete, or inadequacies in an individual's knowledge or use of assigned PPE that indicate that the individual has not retained the requisite understanding or skill. Each person who is required to use PPE will be trained in at least the following items:

a. When the use of PPE is necessary

b. What specific PPE is required

c. How to properly don, doff, adjust, and wear the appropriate PPE

d. Limitations of the PPE

e. Proper care, maintenance, useful life, and disposal of the PPE

8.0 TRAINING AND INFORMATION

8.1 CDP COBRATF Personnel Training Requirements. In addition to the PPE Training described above in Section 7.4, the CDP COBRATF AD/CAM, with technical assistance from safety and medical personnel, will ensure that the training outlined below is accomplished. The CHO will approve the programs of instruction and lesson plans and will monitor selected training sessions. CDP COBRATF employees will receive the appropriate training and demonstrate proficiency prior to performing hazardous operations. Worker attendance at initial and annual training will be documented and kept on file for the duration of employment plus five years. The training shall be appropriate to the duties of each individual trained.

8.2 Initial Training. All CDP COBRATF personnel who work with, or have some association with, chemical agent, or who have a potential for exposure, will receive sufficient training to enable them to work safely and to understand the significance of chemical agent exposures. As a minimum, prior to being assigned to chemical agent operations or in support of chemical agent operations, personnel will receive training and demonstrate an understanding and/or proficiency in:

a. Operating procedures, including safety requirements and practices/controls used to avoid exposure.

b. Recognizing hazards involved in the operation.

c. Recognizing signs and symptoms of chemical agent exposure, sources of exposure, and adverse health effects.

d. Administering first aid and self-aid, buddy-aid techniques, and antidote treatment nerve agent auto-injector (ATNAA).

e. Personnel decontamination procedures.

f. The execution of emergency procedures.

g. Environmental monitoring and its rationale.

h. Medical surveillance purposes and procedures and why employee participation and cooperation is required.

i. Cardiopulmonary Resuscitation and Automated External Defibrillator (CPR/AED).

8.3 Annual Training. Annual training for CDP COBRATF personnel who have access to agent shall include at a minimum:

a. Techniques of wearing, adjusting, inspecting, and caring for personal protective clothing and equipment.

b. Use of first-aid, self-aid, and first-aid equipment, including ATNAA.

c. Recognition of signs and symptoms of nerve agent exposure.

d. CPR (Frequency of re-training based on local certifying authority).

e. Emergency procedures.

f. Decontamination procedures.

g. Review of chemical agent handling techniques.

h. New or updated chemical agent requirements.

i. Medical surveillance.

8.4 Hazard Communications (HAZCOM) Training. All CDP COBRATF personnel who are assigned to work with or could be potentially exposed to hazardous chemicals will receive HAZCOM training upon initial assignment to the facility and at least annually thereafter.

8.4.1 Training Focus. HAZCOM training will focus on information and program procedures necessary to safeguard personnel against associated hazards when working with or around chemicals. Facility material safety data sheets (MSDS) will be emphasized as the main means for providing detailed procedures for protection and required PPE needed for each chemical being used.

8.4.2 Required Training Topics. Specific HAZCOM topics to be taught for all newly assigned personnel and annual refresher training are as follows:

a. A summary of the HAZCOM program and standards.

b. Hazardous chemical properties including visual appearance and odor.

Additionally, the methods which could be used to detect the presence or release of hazardous chemicals will be discussed.

c. Procedures to protect against hazards, such as PC&E, work practices, and emergency procedures.

d. Procedures for chemical leaks or spills.

e. Use and location of facility MSDSs.

9.0 PERSONNEL PRACTICES

9.1 Two-Person Rule. When conducting chemical agent activities, only personnel necessary to the operation are permitted in the work/training area. For safety and security purposes, a minimum of two CERP members are required to access chemical agent and are present in the laboratory work area/training bay the entire time chemical agent is being handled.

The two agent handlers must maintain visual contact with each other and the chemical agent at all times. Note that very dilute solutions of agents GB and VX are used to calibrate and challenge MINICAMS. These solutions are contained in septum capped vials when used by air monitoring technicians. The two-person rule does not apply when using these dilute solutions to calibrate or challenge MINICAMS.

9.2 Laboratory/Training Bay Restrictions. Mechanical pipetting aids will be used for all pipetting of chemical agent or chemical agent solutions. The following practices are strictly prohibited in the Laboratory and Training Bays:

a. The storage or consumption of food or beverages

b. The storage or application of cosmetics

c. The use or storage of smoking materials or tobacco products

d. The storage or use of chewing tobacco or other chewing products

e. The use of laboratory glassware to prepare or consume food or beverages

f. Use of cellular communication devices (unless approved by the CDP COBRATF AD)

9.3 Emergency Supplies. Emergency first-aid and decontamination supplies for personnel will be maintained in the laboratory and the training bays. Emergency supplies will include the appropriate decontaminating materials and solutions (see Section 14.0 of this document) and three ATNAAs per person.

9.4 Chemical Agents. All chemical agents within the CDP COBRATF are securely stored in a locked storage vault located in a ventilation hood in the restricted, positively controlled Chemical Laboratory. The CDP COBRATF Laboratory contains chemical agent liquid and vapor at all times, and as such, is under continuous engineering controls and environmental monitoring.

When chemical agent is removed from the containment provided by engineering controls, the agent is double contained at all times. Both the inner container and the outer container are labeled. The chemical agent labels are distinctive from non-chemical agent labels used in the laboratory and are large enough to be easily identifiable. The labels contain the following information:

a. Toxic Chemical (in all caps and bold letters)

b. Concentration of solution if dilute, or neat if not dilute

c. Solvent involved if dilute

d. Type of chemical agent involved (name or code name)

e. Accountability document number

Containers that are too small for the inclusion of complete information on the label will have at least the name or code name of the chemical agent clearly marked. Note that dilute solutions of GB and VX used to calibrate or challenge MINICAMS do not have to be double contained when in use. Also, neither the words TOXIC CHEMICAL nor the accountability document number are needed on the label for such solutions.

9.5 Other Chemicals. Labels on incoming containers or hazardous chemicals will not be removed or defaced. All containers will be labeled with at least the identity of the chemical. All MSDSs that are received with incoming shipments of hazardous chemicals will be maintained and be made readily accessible to laboratory employees.

Incompatible chemicals are stored separately in placarded areas. Flammable liquids are stored in storage cabinets specifically designed for that use and located in well ventilated areas.

9.6 Material Safety Data Sheets (MSDS). MSDSs for all of the chemical warfare (CW) agents and other chemicals used in the CDP COBRATF are maintained in the CDP

COBRATF Technical Library and in the Chemical Laboratory for immediate reference and use by all CDP COBRATF personnel. All MSDSs that are received with incoming shipments of hazardous chemicals will be maintained and made readily accessible to all

CDP COBRATF employees. The MSDS for each chemical contains the following types of information:

a. Physical properties of the chemical

b. Any possible fire or explosion hazards

c. First-aid procedures

d. Reactivity of the chemical with other materials

e. Proper response to spills or leaks

f. Personal protection required when working with the chemical

g. Any special precautions required when working with the chemical

10.0 INSPECTIONS/MAINTENANCE

10.1 Safety Inspections. Quarterly internal safety inspections are conducted and documented for all chemical agent areas and areas which could impact chemical agent operations, as directed in section 6.9.1 of the CDP COBRATFSD. Inspection documentation includes the inspection date, area or areas inspected, notation of all safety violations, and annotation of when the violations are corrected. The inspections will address both CDP

COBRATF and OSHA safety requirements. The inspection documentation will be made available for inspection as required.

10.2 Personnel Participation. Both CDP COBRATF employees and supporting contractor personnel may participate in the safety inspections. All personnel will be made aware of observations and findings noted during the inspections through internal debriefing sessions and internal memos.

10.3 Safety Equipment. All safety equipment will be inspected on a routine basis. The safety equipment inspected will include eye wash stations, emergency use respirators, and deluge showers.

10.4 Passageways. Stairways and hallways within the CDP COBRATF will not be used as storage areas. Access to all exits, emergency equipment, and utility controls will never be blocked.

10.5 Equipment Maintenance and Repair. A continuing program for equipment maintenance and facility maintenance has been established, implemented, and documented for all chemical agent operations at the CDP COBRATF. Routine maintenance and repair of equipment normally does not occur while chemical agent is being used or is outside of storage containment. Of course, any equipment that fails while chemical agent is in use will be repaired or replaced as quickly as possible if this failure occurs during such operations. Any operation deemed to be unsafe as a result of equipment failure will be suspended until the equipment can be repaired or replaced.

11.0 RECORD KEEPING

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