Reference_-_O_Ohmsett_HASP_9_30_22_3f_3.pdf

Operation and Maintenance of Ohmsett Contract E17PC00014 Ohmsett Health and Safety Plan

Operation and Maintenance of Ohmsett Contract E17PC00014

Ohmsett Health and Safety Plan

Prepared for:

BSEE Contracting Officer’s Representative (COR) Frank Jurado

BSEE Oil Spill Preparedness Division 45600 Woodland Road

Sterling, VA 20166 Email: Frank.Jurado@bsee.gov

Ph. 571-279-7896

BSEE Safety and Occupational Health Manager (SOM) Rose Capers-Webb

BSEE Management Support Division 45600 Woodland Road

Sterling, VA 20166 Email: Rose.Capers-Webb@bsee.gov

Ph. 703-787-1541

Prepared by:

Applied Research Associates, Inc.

Operating Contractor

Ohmsett Facility

Naval Weapons Station Earle (NWSE) Waterfront Route 36

P.O. Box 150, Leonardo, NJ 07737

Date: September 30, 2022

TABLE OF CONTENTS

1. SAFETY POLICY AND ORGANIZATION

1.1. SAFETY POLICY

1.2. SITE CHARACTERIZATION

1.3. KEY OHMSETT FEATURES

1.4. SAFETY ORGANIZATION AND RESPONSIBILITIES

Program and Facility Manager (PFM)

Health and Safety Officer (HSO)

Health and Safety Specialist (HSS)

Safety Consultant (SC)

Project Managers (PM)

Administrator

2. PROGRAMATIC EXECUTION

2.1. SAFETY MEETINGS

2.2. PROJECT SPECIFIC SAFETY PLAN

2.3. VISITOR SAFETY MANAGEMENT

3. EMERGENCY PROCEDURES

3.1. EMERGENCY RESPONSE

3.2. MEDICAL EMERGENCY

3.3. REPORTING AN EMERGENCY

3.4. PRIMARY SURVEY

4. SECURITY

4.1. FACILITY SECURITY

4.2. VISITOR ACCESS

5. INJURY AND ILLNESS REPORTING AND INVESTIGATION

5.1. MINOR INCIDENTS

Treatment Response

5.2. OSHA REPORTABLE INCIDENTS

Treatment Response

Care Follow-Up

Reporting

OSHA Paperwork

Investigations

6. ACCIDENT PREVENTION PLAN AND JOB HAZARD ANALYSIS

6.1. EXECUTION

6.2. ANALYSIS PROCEDURES

6.3. POTENTIAL JOB HAZARD ANALYSIS AND TRAINING AREAS

7. HAZARD COMMUNICATION PROGRAM

7.1. RESPONSIBILITIES

7.2. EMPLOYEE TRAINING

7.3. CONTRACTING

7.4. CHEMICAL INVENTORY

7.5. HAZARD DETERMINATIONS

7.6. EMPLOYEE RIGHTS

8. DOCUMENTATION AND RECORDKEEPING

9. OTHER AVAILABLE REFERENCE MATERIALS

Ohmsett Health and Safety Plan

1. SAFETY POLICY AND ORGANIZATION

1.1. SAFETY POLICY

The health and safety of each employee is of paramount importance to Ohmsett and contract operators of Applied Research Associates, Inc. (ARA). Ohmsett’s policy is to provide safe and healthful working environment for all employees, customers, and visitors. Ohmsett will comply with all pertinent regulations promulgated by the Occupational Safety and Health Administration (OSHA), the Environmental Protection Agency (EPA), the U.S. Coast Guard (USCG), the Department of Transportation (DOT), the Department of Defense (Navy), the Department of the Interior’s Bureau of Safety and Environmental Enforcement (BSEE), and other relevant jurisdictions including the State of New Jersey, local municipalities, and Naval Weapons Station Earle (NWSE).

Ohmsett staff will be provided with a safe place in which to work and proper equipment with which to do their job safely. All Ohmsett staff will make the safety of all employees a daily focus.

ARA believes that nothing is more important than safety—productivity, quality, and safety must all be considered together. Safety is a shared responsibility, and each employee is a partner in contributing to safe work practices and conditions. Ohmsett staff will perform their work as safely as possible, be alert for any possible adverse consequences of their actions and comply with the provisions of this Health and Safety Plan (HASP).

Approvals:

Name: Dr. Thomas Coolbaugh Name: Mr. Tom Schmidt Title: Ohmsett Program Manager Title: Ohmsett Health and Safety Officer

(Signature) (Signature)

(Date) (Date)

1.2. SITE CHARACTERIZATION

Ohmsett is located at the Naval Weapons Station Earle Waterfront in Leonardo, New Jersey (approximately one hour south of New York City). Ohmsett's above ground, external concrete test tank is one of the largest of its kind, measuring 203 meters long by 20 meters wide by 2.4 meters deep. The tank is filled with 2.6 million gallons of saltwater (https://ohmsett.bsee.gov/facility.html). The Ohmsett facility exists on a flat parcel of land adjoining a marsh area of the Sandy Hook Bay. The size of the Ohmsett facility is approximately five acres, which contains the administrative building with laboratory and high bay work area, test basin, tank farm, maintenance building, warehouse, and oil/fluid storage building.

Government agencies, academia, and public and private companies use Ohmsett as a research center to test oil spill containment/clean-up equipment and techniques, to test new designs in response equipment, and to conduct training with actual oil spill response technologies.

ARA, Inc. operates Ohmsett for the Department of the Interior (DOI) Bureau of Safety and Environmental Enforcement (BSEE) using a full-time staff, with potential use of temporary staff and/or specialized subcontractors. Tank tests and routine maintenance occur throughout the year, i.e., under a full range of weather conditions.

1.3. KEY OHMSETT FEATURES

Ohmsett was originally built by the EPA in 1974. Operations were discontinued in September 1988 until refurbishment by the DOI/ Minerals Management Service (MMS) for continued operations. The primary feature of the facility is a pile-supported steel reinforced concrete tank.

Spanning the tank is a 110,000-pound main towing bridge and two other smaller bridges, each weighing about 20,000 pounds, one to the south of the main bridge and the other to the north. The bridges ride on steel rails and may be pulled at speeds up to approximately six knots via a cable driven by two DC variable-speed motors.

Primary systems associated with the tank include:

• A hydraulically driven wave generator at the south end

• An artificial beach at the north end

• Filtration and in-line chlorination systems

The water quality is maintained by circulating the water through a 410 cubic meter (m3)/hour (1800 gallons/minute) pressure leaf-filtering system, which employs diatomaceous earth (DE). Treated wastewater is discharged by agreement to the Township of Middletown Sewerage Authority (TOMSA) or Sandy Hook Bay (by exception) using a New Jersey Department of Environmental Protection (NJDEP) permit.

https://ohmsett.bsee.gov/facility.html

1.4. SAFETY ORGANIZATION AND RESPONSIBILITIES

The Ohmsett Project and Facility Manager (PFM), with the direct assistance and execution from the Health Safety Officer (HSO), administers the HASP. The HASP management plan includes specific work practices/procedures, protective equipment requirements, hazard awareness training, specific equipment/task training, personal exposure monitoring, and required/planned audits or inspections.

The HSO reports to the PFM at the Ohmsett facility and has the responsibility to review the HASP annually for updates and corrections. The HSO coordinates HASP implementation, specifies necessary safety equipment, performs and/or coordinates training of personnel, arranges medical testing for employees/subcontractors, and interacts with the client BSEE representatives.

The following are the key personnel necessary to execute the HASP management effort.

Program and Facility Manager (PFM)

The PFM manages the general operations, various testing and evaluation (T&E), and research and development (R&D) programs at Ohmsett. The PFM oversees the implementation and enforcement of the HASP and communicates safety actions to BSEE. The PFM is responsible for allocating time and the necessary resources required for the safe accomplishment of all tasks assigned to any Ohmsett employee.

Health and Safety Officer (HSO)

The on-site HSO is the primary coordinator for all activities outlined in the Ohmsett HASP. This includes maintaining awareness of health and safety issues and serving as a focal point for reviewing the safety concerns of staff, contractors, and visitors. The HSO ensures any outstanding safety issues are brought to the attention of the PFM. The HSO duties include coordination of training, review of project or test safety plans, purchase/deployment of safety equipment, preparation of reports, and monthly interface with an external Safety Consultant.

Health and Safety Specialist (HSS)

The HSS provides direct assistance to the HSO as needed.

Safety Consultant (SC)

The Safety Consultant is an external subject matter expert contracted by ARA to assist the PFM and HSO in maintaining safety standards at Ohmsett. The SC visits the Ohmsett facility monthly and meets with the facility HSO and PFM (as necessary) to review inspection reports, incident reports, project specific safety and hazard analysis. The SC also conducts on-site training for staff, such as the HAZWOPER refresher, and specific equipment operation.

Project Managers (PM)

PMs are usually engineers and scientists who plan and execute research projects/maintenance programs at Ohmsett. PMs work with the HSO to identify potential safety concerns for their projects and develop mitigation plans as required.

Administrator

The Administrator assists the HSO in maintaining records of training and any on-site safety-related occurrence such as a near miss, accident, environmental release, etc.

2. PROGRAMATIC EXECUTION

2.1. SAFETY MEETINGS

The Ohmsett PFM and HSO will ensure that relevant safety discussions occur regularly, e.g., as part of daily “tool-box” or pre-test familiarization meetings. As needed, the Safety Management Core Team (PFM, HSO, HSS) will meet separately to review:

• Standard Operating Procedure (SOP) Updates

• Project Specific Safety Plans

• Incident Reports and Corrective Action Plans

2.2. PROJECT SPECIFIC SAFETY PLAN

The HSO will develop a standardized template for development of any needed project specific safety plans at Ohmsett. The content of the project specific safety plan may include:

• Summary of the project and associated tasks

• Listing of any unique hazards (including chemical products) that will be utilized for the effort and how they will be managed.

2.3. VISITOR SAFETY MANAGEMENT

Visitors will receive a brief safety orientation from the HSO or other competent staff member at the beginning of their visit. This briefing will cover:

• Necessary PPE

• Site orientation (restrooms, break area, photo security requirements, etc.)

• Specific hazards that may be encountered

• Other emergency information such as location of first aid kit and mustering points

• A visitor log will be kept

Note: Subcontractors and visitors are not permitted to handle test petroleum/chemical products unless they possess proper HAZWOPER certificate training.

3. EMERGENCY PROCEDURES

3.1. EMERGENCY RESPONSE

Emergency response at Ohmsett could be necessary in cases of medical or safety emergency and support is available from Naval Weapons Station Earle (NWSE) or the nearest full service emergency hospital (Riverview Medical Center).

NSWE Fire and Emergency Services – Waterfront Area

Medical/Fire/Security Ohmsett or Navy Telephone Line: Ext. 2911 Other Phone/Mobile: (732) 866-2911

Riverview Medical Center (Hackensack Meridian)

1 Riverview Plaza Red Bank, NJ 07701 Emergency Department: (732) 530-2204 General: (732) 741-2700

3.2. MEDICAL EMERGENCY

In the event of a medical emergency, the first employee on-scene shall initiate response procedures.

• Survey and assess the situation including assessment of potential hazards.

• If the incident is still ongoing, the employee shall attempt to remove victim(s) from hazardous area, if possible, so that no further injury can occur. The employee will do this only without causing any danger to themselves or others. DO NOT ATTEMPT TO MOVE THE VICTIM(S) UNLESS THEY

ARE IN IMMEDIATE DANGER OF ADDITIONAL INJURY.

• Employee will alert additional staff members for assistance.

• Designate a specific employee to:

o Call emergency support services o Retrieve first aid supplies o Meet and escort responding emergency support personnel (police, fire, ambulance) o Notify HSO or PFM o Render first aid until emergency support personnel arrive. Remember to calm and reassure the victim

3.3. REPORTING AN EMERGENCY

The following information should be provided:

• Type of emergency, e.g., Medical situation/suspected injury

• Exact address/location, with specific address to incident location and escort location

Ohmsett Facility/Naval Weapons Station Earle Waterfront 801 State Route 36 BLDG R-24/26/25/41 Leonardo, NJ 07737

• Number/name of injured/Present condition of the victim(s)

• Status of any first aid treatment being rendered

• Caller’s phone should remain online until emergency support personnel arrive

Ohmsett Main Phone Number: (732) 866-7183 Ohmsett Alternate Phone Number: (732) 866-7285

3.4. PRIMARY SURVEY

Many conditions may be life-threatening, but three require immediate action:

1. Respiratory Arrest

2. Severe Bleeding

3. Circulatory Failure

These may result in death and the responder should follow the ABC method to check for life-threatening conditions:

• Airways – Establish responsiveness, position the victim, and ensure adequate breathing. If there are no signs of breathing, artificial ventilation must be given immediately.

• Bleeding – Make a careful and thorough check for any bleeding. Control serious bleeding.

• Circulation – If no pulse is detected, CPR should be started immediately.

Do not move the victim any more than is necessary. If the victim is unconscious or there are any complications with any of these components, activate emergency medical support immediately.

4. SECURITY

Ohmsett is located on a controlled access military installation. To gain access to the facility, all staff and visitors are required to enter through the NWSE Waterfront main gate on 801 Route 36, Leonardo, NJ.

4.1. FACILITY SECURITY

Ohmsett employees and staff are responsible for basic facility security, including the following.

• Securing buildings at the end of the workday.

• Ensuring outdoor security lighting is working.

The BSEE on-site representative controls disposition of building keys.

4.2. VISITOR ACCESS

It is mandatory for all visitors without a US government issued CAC/DBIDS card to complete the Navy Visitor Access Request Form prior to their visit. The specific procedures can be found at:

https://ohmsett.bsee.gov/visit.html

5. INJURY AND ILLNESS REPORTING AND INVESTIGATION

All work-related near misses, injuries, or illnesses, will be reported to the HSO (or HSS) and PFM. The HSO or PFM will determine the seriousness of an incident or illness, but in general:

Minor Incidents are defined as treatable on-site with no outside care, such as first aid, and have no lost time or work restriction.

OSHA Reportable Incidents are more serious events that encompass the following:

• Injuries/illnesses that require more than first aid

• An occupational illness is defined as one that is produced by exposure to or activities related to the work environment occurring over a longer period of time than one day or work shift (e.g., systemic infections or disease, continued or repeated stress or strain, and exposure to toxic or hazardous agents).

5.1. MINOR INCIDENTS

Treatment Response

Obtain care from nearest facility first aid location. After self-treatment, or prior to treatment if assistance is necessary, parties will report all accidents, injuries, illnesses, and near misses to the HSO (or HSS) or PFM immediately.

5.2. OSHA REPORTABLE INCIDENTS

Treatment Response

Ensure the employee is treated and stabilized on-site as appropriate.

If employee presents any emergency symptoms, use medical emergency response protocol, and follow guidance of dispatcher until emergency support personnel arrive.

EMERGENCY SUPPORT PERSONNEL WILL TAKE CHARGE OF ALL MEDICAL CARE FOR INJURED PARTIES IF

DETERMINED TO BE NECESSARY.

In almost all scenarios, it is recommended that the employee be transported by an escort.

As soon as possible, or while employee is in-route to clinic, the HSO or PFM will contact the WC insurance carrier:

CNA Insurance Phone (preferred for first report of claim): (877) 262-2727; Press Option 2 – New Claim] ARA Policy Number (New Jersey): 4026390760 https://ohmsett.bsee.gov/visit.html

Fax: (800) 953-7389 Email: lossreport@cnaasap.com Web: www.cna.com

The HSO or PFM will Inform the CNA operator that they are an authorized ARA/Ohmsett Safety Manager and need to initiate a claim so treatment can be rendered. Provide all relevant employee information to operator and REQUEST IMMEDIATE CLAIM NUMBER. It takes approximately 10 minutes of discussion to obtain a claim number. Do not end call until claim number is issued.

The HSO or PFM will provide the claim number to employee or employee escort as soon as possible. At some care facilities, a valid claim number must be presented for treatment to begin.

Care Follow-Up

The HSO or PFM will ensure that the employee has appropriate follow-up care coordinated and scheduled.

The HSO and PFM may assist in the following determinations:

• Employee ability to continue work, or return to work, in either light or full duty capacity.

Employees who are unable to work because of an on-the-job injury/illness may be placed on Personal Leave status until their WC insurance payments commence.

• Guidance and assistance on WC insurance benefits, procedures, and claim forms to management team.

• Submission of WC insurance claims.

Reporting

Upon on-site treatment being resolved, the HSO and/or PFM will initiate a series of notifications:

ARA RMD Division Manager RMD Safety Officer

BSEE Contracting Officer Technical Representative Contracting Officer Safety Manager

NSWE Safety Office

OSHA The ARA Corporate Safety Manager will process any direct notifications to OSHA. This includes mandatory reporting within eight hours of any incident resulting in the death of an employee or the hospitalization of three or more employees.

The known information of the incident will be summarized and supplied to above parties.

OSHA Paperwork

The HSO or PFM will execute any OHSA mandated paperwork to document the incident. This will include:

• Complete OSHA 301 First Report of Injury using information supplied by the employee.

• Record OSHA Reportable Incidents on the OSHA 300 Log within six days of the incident.

• Complete OSHA 300A Summary by end of January for the previous Calendar Year, including signature by ARA RMD Division Manager.

• Post the OSHA 300A Summary for the previous year in a central location by February 1 each year and keep it posted all year.

• Send a copy of the OSHA 300 Log to ARA Corporate Safety Manager or designee when requested.

• Maintain the OSHA 300A Summary, 300 Logs, and 301 Forms (First Report of Injury) for five years with Administrator.

Investigations

Any Ohmsett OSHA reportable incidents will be investigated by the HSO, PFM, and ARA Safety Managers, and reviewed by the SC. Serious or potentially life-threatening incidents will be reviewed by the ARA Corporate Safety Manager, in addition to any higher agency requests.

Incident investigations and reviews may cover:

• Actions of all employees, customers, contractors, and visitors in the vicinity of the incident

• Use of tools, machines, equipment, vehicles, or instrumentation involved in the incident

• Specific circumstances of the incident and any underlying factors

• Methods or actions to prevent similar events

Results will be presented to the PFM and reviewed by the SC at the next monthly visit. Any incident patterns or trends will be noted and addressed in safety meetings or daily safety briefs. Depending on the incident, additional guidance on investigation and corrective actions may be made by ARA, BSEE, NSWE or OSHA.

6. ACCIDENT PREVENTION PLAN AND JOB HAZARD ANALYSIS

Ohmsett will execute an Accident Prevention Plan (APP) using an appropriate Job Hazard Analysis (JHA).

This will be performed in accordance with OSHA requirements to identify existing or potentials hazards in daily job duties and mitigation strategies. The HSO and HSS will work with employees to identify work tasks in sequence and reviewing them to identify any existing or potential job hazards.

• Talking to an employee to identify the steps involved in performing a task.

• Looking at the general work area to see if any specific hazards are apparent.

• Observing employees perform a task while documenting potential hazards.

• Developing ways to eliminate potential hazards via training, equipment procurement or selection if appropriate PPE if the hazards cannot be eliminated.

The AAP will serve to evaluate the tasks completed by the primary Ohmsett duty positions:

• Program Manager (PFM)

• Health and Safety Officer (HSO)

• Health and Safety Specialist (HSS)

• Administrator

• Professional Staff

• Technicians

6.1. EXECUTION

The HSO and HSS will analyze job tasks to determine potential hazards the employee may face during their daily work. The HSO and HSS will:

• Identify operations that could result in an injury or exposure to chemical or physical agents.

• Engineer out the hazards, if possible.

• Alter work practices whenever a hazard cannot be engineered out.

• Specify PPE for any hazards that cannot be engineered out or worked around.

6.2. ANALYSIS PROCEDURES

The PFM and HSO will prioritize JHA completion or update based on operational needs and programmatic requirements. Potential areas of focus include jobs with:

• Potential for catastrophic injury or death

• Documented near misses

• Recent changes, that are non-routine, or are performed by a new employee

• Existing jobs being performed by an established employee over an extended period

The HSS and HSO could develop specific questions for JHA development, such as:

• Is the lighting adequate for the task?

• Are there any explosive or flammable hazards associated with the job?

• Are the tools and equipment in good condition or do they need repair?

• Does the ventilation appear to be adequate or inadequate?

• Is the safety equipment on all associated equipment operating properly?

• Is the employee performing repetitive tasks that could result in muscle strain?

• Can the employee be injured from lifting, pushing, or pulling heavy objects?

• Is the workflow properly organized?

• Are there any sharp objects that could cause injury?

• Is equipment properly guarded?

• Do suspended loads or potential energy such as compressed springs, hydraulics, or jacks pose hazards?

• Is the employee wearing PPE? Does it fit properly? Was the employee trained in its use? Was it properly selected? Is it being maintained properly?

Based upon the type of operations required for maintenance and testing protocols, potential health and safety exposures can exist at Ohmsett in the testing laboratory, workshop, around the wave tank, and during transfer of various hydrocarbon fluids, e.g., crude oil.

6.3. POTENTIAL JOB HAZARD ANALYSIS AND TRAINING AREAS

As needed, Ohmsett may conduct job hazard analysis and training in several of the following areas:

General Safety Training

• Safety Rules

• Hazard Communications

• HAZWOPER (eight-hour annual refresher)

• PPE

• First Aid/CPR

• Respiratory Protection Program

• Fall Protection and Safeguarding

• Hearing Protection

• Heat and Cold

• Stress

Task and Job-Specific Training Received by Selected Employees

• Forklift operations

• Front loader operators

• Skid steer operators

• Crane operations

• Bridge operations

• Wave generator operations

• Filter operations

• Filter operations

• Welding, cutting, brazing

• Electrical maintenance

• Oil transfer operations

• Skimmer and prime mover operations

• Pressure washer operations

7. HAZARD COMMUNICATION PROGRAM

The Ohmsett Hazardous Communication Program (HCP) is a direct corollary to the JHA with focus on chemical safety and is guided by the OSHA Hazard Communication Standard. The standard mandates that employees have both a requirement and a right to know the identities and hazards of the chemicals they are exposed to when working, and what protective measures should be implemented to prevent any adverse effects from occurring. Ohmsett obtains this information from suppliers and provides it to employees who may be exposed to chemicals during daily duties.

Ohmsett will comply with the OSHA mandates by:

• Developing and maintaining a list of hazardous chemicals in use in the workplace

• Establishing proper work practices for using these chemicals

• Ensuring that every container of hazardous chemicals in the workplace is properly labeled

• Having SDS sheets readily accessible in common directories

• Training employees on the hazards of chemicals involved in their work effort, and their safe use

• Making the Ohmsett Hazard Communication Program available to all employees

7.1. RESPONSIBILITIES

The HSO, HSS, and PFM will manage the Ohmsett HCP and ensure the following.

• Hazardous chemical containers are properly labeled.

• SDS directories are managed appropriately.

• Ensure employees know where to find SDS directories.

• Notify the HSO when a new product is purchased that may require an SDS.

• Develop an inventory list of all hazardous chemicals in use at Ohmsett.

• Ensure the employee rights under this program are posted in a central location.

Employees have the following HCP responsibilities.

• Understand and comply with the requirements of this HCP.

• Forward SDSs received with shipments to the HSO for inclusion in the SDS directories.

• Do not remove any manufacturers’ label on a container of hazardous substance.

• Re-label any container whose label comes off or becomes obliterated during use.

• Properly label any container into which a hazardous chemical is placed.

• Comply with the safety precautions and directions for use included on the labels and SDSs for all hazardous chemicals in use in the workplace.

7.2. EMPLOYEE TRAINING

The HSO and PFM will ensure Ohmsett employees are trained on this Hazard Communications Program.

Training sessions will encourage questions and will focus on employee comprehension and understanding.

7.3. CONTRACTING

Ohmsett will require contractors to provide a list and appropriate SDSs of any hazardous substances to which Ohmsett employees may be exposed during the execution of a test.

7.4. CHEMICAL INVENTORY

The HSO and HSS will prepare a baseline chemical inventory and file it in accordance with NSWE regulations. The HSO and HSS shall also conduct periodic (not less than annually) inventories to keep the inventory list as current as possible. The inventory may be used to cross-check SDS directories.

7.5. HAZARD DETERMINATIONS

Ohmsett will rely on hazard determinations performed the chemical manufacturers, importers, and distributors for those chemicals obtained commercially.

The OSHA Hazard Communication Standard (HCS), which as be found in 29 CFR 1910.1200. Most chemical products used in the workplace have some hazard and are covered by the standard. A complete list of OSHA regulated hazardous chemicals and Permissible Exposure Limits (PELs) can be found in 29 CFR Part 1910, Subpart Z, Toxic and Hazardous Substances. Non-OSHA listed chemicals can be found in the American Conference of Industrial Hygienists (ACGIH) current “Threshold Limit Value (TLV)” booklet.

7.6. EMPLOYEE RIGHTS

Employees have a right to know the identities and hazards of all chemicals in use at Ohmsett. Employees have the right to be informed of the location of operations where hazardous chemicals are present.

Employees may request an SDS on any hazardous chemical found at Ohmsett, or de-directed to container.

8. DOCUMENTATION AND RECORDKEEPING

The HSO, in consultation with the PFM, and Administrator, will keep track of any required or optional employee training in an appropriate manner, e.g., Excel spreadsheet, physical or scanned copies of certificates of completion.

9. OTHER AVAILABLE REFERENCE MATERIALS

In support of the Ohmsett HASP, ARA has developed materials that provide additional details. While these are not updated annually and may contain details that are not directly relevant to current operations, they do provide information that may be of use in discussions related to health and safety:

• Overview of Oil & Water Laboratory Operation and Safety Program

• Overview of Employee Training Program

• JHA/Training/PPE By Position