Att_9.9_SLDA_CBDPP_SOW_Outlines.docx

SLDA Remediation Scope of Work CELRP Chronic Beryllium Disease Prevention Program (CBDPP) Outline The following is a suggested outline for a CBDPP and a guide as to the minimum content required. The CBDPP is a CONTRACTOR deliverable with the final format and any additional content to be determined by the CONTRACTOR.

Purpose

· Implement controls (administrative, engineering, medical monitoring) necessary to minimize the number of people exposed, the amount of the exposure and the duration of exposure to beryllium with the intention of minimizing the number of workers who will develop chronic beryllium disease.

Scope

· Define applicability of the site-specific CBDPP and its requirements

· Include formal plans and measures for maintaining 95% confidence that beryllium exposures are below the occupational exposure level and a detailed monitoring plan to verify controls are working as designed;

· Detail provisions for:

· minimizing the number of workers exposed &/or potentially exposed to beryllium;

· minimizing the number of opportunities for workers to be exposed to beryllium;

· minimizing the disability and lost work time of workers due to chronic beryllium disease, beryllium sensitization and associated medical care;

· Set specific exposure reduction and minimization goals that are appropriate for the beryllium activities covered by the CBDPP to further reduce exposure below the occupational exposure limit Definitions

· Define key specific terms such as:

· Beryllium Activity

· Beryllium Hazard Assessment

· Beryllium Affected Worker

· Beryllium Worker

· Negative Exposure Assessment (NEA)

· Beryllium Work Permit (BWP)

· Worker Exposure.

Roles and Responsibilities

· Explain how the Contractor will develop management systems necessary to implement the CBDPP Requirements

· Detail the general requirements for the project

Implementation

· Detail the process for the implementation of the CBDPP and control of beryllium exposures for all activities within the contract scope Compliance

· Establish policy that the Contractor and any of their subcontractors must conduct beryllium activities in compliance with this CBDPP as accepted by the USACE

· Detail how the Contractor will enforce the accepted CBDPP Baseline Beryllium Inventory

· Establish a baseline beryllium inventory, maintained by the Contractor Occupational Health Manager (OHM).

· The baseline beryllium inventory must:

· establish a process for how the facility characterization will be conducted and documented.

· identify the locations of beryllium operations and other locations of potential beryllium contamination

· identify the workers exposed or potentially exposed to beryllium at those locations

· include a review of current and historical records

· document the characteristics and locations of beryllium at the site

· include provisions for and details on conducting air, surface, and bulk sampling as necessary to confirm location(s) of beryllium

· include provisions for routine updates to the inventory

Beryllium Hazard Assessment (BHA)

· Explain what hazard assessments are and how they will be executed and how they are supportive of the job specific Beryllium Work Permit.

· The beryllium hazard assessment must:

· include an analysis of existing conditions, exposure data, and the exposure potential of planned activities

· prioritize the exposure determinants, characteristics and exposure potential of activities so that the activities with the greatest risks of exposure are evaluated first.

Job-Specific Beryllium Work Permit (BWP)

· Define when and where a BWP is required

· Minimal content of a BWP.

· Define roles and responsibilities for developing and approving the BWP

· Detail how the BWP will be coordinated with other safety, health, and radiological control documents

Exposure Limit(s)

· Detail how the Contractor will comply with the LRP-OEL variance of 0.2 µg/m3 as an 8 hour TWA including an Action Level of 0.1 µg/m3 as an 8 hour TWA.

Exposure Monitoring

· Detail how the Contractor will:

· determine the extent of exposure at the worksite;

· prevent worker overexposure;

· identify the sources of exposure to beryllium;

· collect exposure data so that the responsible employer can select the proper control methods to be used and evaluate the effectiveness of selected controls;

· provide continual feedback on the effectiveness of the CBDPP in controlling exposures

· conduct initial monitoring for all areas where there is a potential airborne exposure to beryllium above the Action Level

· conduct periodic monitoring in areas where airborne concentrations of beryllium are at or above the Action Level

· accommodate worker requests for air monitoring

· conduct air monitoring to further characterize exposure pathways.

· Define roles and responsibilities for monitoring and managing beryllium personal monitoring conducted at the site

· Detail methods for conducting a Negative Exposure Assessment (NEA) and how a documented NEA will be used to:

· reduce the number or frequencies of personal samples required

· reduce exposure controls, such as downgrading respiratory protection Notification of Monitoring Results

· Detail how documentation of field monitoring results will be provided to monitored employees

· Detail where monitoring results will be posted (without personal identifiers)

· Detail what will be done when the monitoring results indicate that a worker’s exposure is at or above the Action Level Exposure Reduction and Minimization

· Detail the exposure reduction and minimization processes the Contractor will implement for areas where airborne beryllium exposure levels are at or above the Action Level

· Detail the exposure reduction and minimization processes the Contractor will implement for areas where airborne beryllium exposure levels are below the Action Level Controlled Beryllium Contaminated Areas

· Detail how the Contractor will establish controlled areas, demark controlled areas, limit access to controlled areas, and keep records of all individuals who enter controlled areas Engineering and Administrative Controls

· Detail the engineering controls that will be designed into all work activities, and when they will be employed

· Detail the administrative controls that will be implemented if engineering controls are not adequate to mitigate the beryllium hazard Hygiene Facilities and Practices

· Detail accepted and prohibited practices for all areas of the site

· Detail the location and accommodations for separate, clean change room(s) or area(s) for workers to change into personal clothing and store personal items

· Detail the location and accommodations for clean areas and/or facilities where workers may eat

· Detail the location and accommodations for worker showers and hand washing facilities

· Detail how all clean hygiene areas and facilities will be kept free of beryllium, and will be cleaned and sampled/surveyed to ensure they are free of beryllium contamination Respiratory Protection

· Detail the Contractor’s respiratory protection program for protection of workers from airborne beryllium, including:

· where and when respiratory protection will be required

· selection of appropriate respiratory protection

· use and maintenance of respirators Personal Protective Equipment (PPE)

· Detail the planned use of protective clothing where particulate forms of beryllium may contact worker’s skin, enter openings in workers’ skin or contact workers’ eyes, including where airborne levels of beryllium meet or exceed the Action Level, including; procedures for donning or doffing of PPE for operations in beryllium- controlled areas

· selection of PPE to be used,

· where and when PPE use is required and post PPE directions at the worksite? (reference: Contractor Respiratory Protection Program)

· how beryllium-contaminated PPE and clothing will be handled in a manner to prevent the beryllium from becoming airborne Release Criteria for Equipment

· Establish limits on what surface contamination is acceptable prior to release from the site.

· Establish how and when the Contractor will notify the appropriate USACE field element of the intent to release contaminated equipment at least 30 calendar days prior to the release date. NOTE: notification is not required for transfer of items for laundering, storage of wrapped/labeled material, transfer of samples or sampling pumps, or waste transportation/disposal operations.

Beryllium Emergency

· Detail the plan for emergency evacuation, and public notification as necessary, in the event of a beryllium emergency

· Detail how the Contractor will manage a worker contaminated during an emergency Medical Surveillance

· Detail how beryllium medical surveillance will be provided

· Define who will be subject to the medical surveillance

· Detail how baseline medicals will be evaluated

· Detail how copies of all personal monitoring data reports are transmitted to the Contractor physician for inclusion in the worker’s medical folder and tracked for data analysis

· Detail plans for identifying and managing workers who exhibit signs or symptoms of beryllium exposure

· Detail provisions for privacy and security of personal medical records Medical Removal

· Detail how the Contractor will handle a worker diagnosed with beryllium sensitization

· Detail how the Contractor will handle a worker diagnosed with CBD.

· Detail any procedures for temporary medical removal of a worker who tests positive for beryllium sensitization from exposure to beryllium at the site

· Detail any procedures for the permanent removal of a worker from beryllium exposure at the site

· Detail any procedures for determining that continued exposure to beryllium at the site will not pose an increased risk to a removed worker’s health, and for incorporating the worker back into the job Training and Counseling

· Document plan to ensure all employees receive the appropriate level of training on beryllium hazards and that the level of training is based on the workers’ current beryllium activities

· Accomplish training in accordance with 29 CFR 1910.1200, Hazard Communication, including the contents of the CBDPP, and potential health risks to others who may come in contact with beryllium on workers clothing or other personal items

· Detail any counseling that will be provided to workers that have been diagnosed with beryllium sensitization or CBD Posting of Beryllium Areas

· Detail the sign/posting requirements the Contractor will implement

· Detail the signs and postings to be used, and where they will be posted

· Detail the methods and equipment the Contractor will use to control access to controlled areas Labeling of Material and Surfaces

· Detail how known and potentially contaminated items will be labeled

· Detail how the Contractor will identify potentially contaminated equipment or items that are being transferred off-site NOTE: beryllium samples that are controlled under a chain-of-custody do not need to be labeled.

· Detail how the contractor will label potentially contaminated on-site systems, such as piping, ductwork, and tanks Record Keeping and Use of Information

· Detail how the Contractor will establish and maintain accurate, confidential records of all beryllium inventory information, hazard assessments, exposure measurements, and exposure controls Performance Feedback

· Detail how the Contractor will conduct periodic analyses and assessments of the effectiveness of the CBDPP.

References

· List the references that the Contractor deems useful

CELRB Beryllium Hazard Assessment (BHA) Outline The following is a suggested outline for a BHA and a guide as to the minimum content required. The BHA is a CONTRACTOR deliverable with the final format and any additional content to be determined by the CONTRACTOR.

Purpose and Scope Define and establish the process and methods to:

· Evaluate the potential for employee exposure to beryllium;

· Evaluate the potential for beryllium contamination spread;

· Determine the methods to document the requirements and controls necessary to conduct work safely and minimize exposures;

· Document the job specific hazard assessment process;

· Communicate the beryllium hazards associated with a specific work activity; and

· Implement and standardize controls for all work activities in beryllium-regulated areas and beryllium-controlled areas.

Roles and Responsibilities Establish the roles and responsibilities for:

· Project Industrial Hygienist (IH)/Certified Industrial Hygienist (CIH)

· SHM and SSHO

· Workers Definitions

· Define key terms in the BHA and Beryllium (BWP).

Training Requirement

· Define the employee training requirements.

Procedures

· Define the performance oriented procedures.

Site Condition Walk Down

· Define what inspections are required as part of the BHA process Hazard Assessment Process

· Define the BHA Process and including:

· risk-based and graded approach when assessing beryllium exposure hazards/risks

· site condition walk downs

· documenting the results of the hazard assessment

· incorporating each of the specific work documents they support

· adequately identifying the level of hazards expected during a specific work activity

· development and preparation of the BWP to conduct specific work activities within the area specified on the BHA

· combining historical data and present conditions to establish the required information used to create a job specific BWP

CELRB Beryllium Work Permit (BWP) Outline The following is a suggested outline for a BWP and a guide as to the minimum content required. The BHP is a CONTRACTOR deliverable with the final format and any additional content to be determined by the CONTRACTOR.

· A job-specific BWP is required for all activities conducted in beryllium-controlled areas (e.g. exclusion zones)

· BWPs shall be reviewed and revised as necessary when field or other changes occur that could impact the validity of the supporting Beryllium Hazard Assessment/Activity Hazard Analysis

· Minimum required content for a BWP includes the following:

· Name of project site

· Names of employees working under the BWP

· Name of contractor(s)/subcontractor(s)

· Effective and expiration dates

· Location of the work

· Description of the work to be conducted

· Entry requirements for workers, including training, medical monitoring, etc.

· Any area postings

· Any access and engineering controls

· Respiratory protection and protective clothing requirements

· Air and surface sampling to be conducted

· Decontamination requirements for items and personnel

· Waste and equipment labeling requirements

· Any additional pertinent information or special instructions for work to be conducted

· Signatures of the preparer and approver(s)

· Acknowledgment signatures of all workers working under the BWP CELRP CBDPP BHA BWP Outlines Page 1