Personal Protective Equipment Selection for Oil Spill Responders

API RECOMMENDED PRACTICE 98 FIRST EDITION, AUGUST 2013

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Foreword

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OSHA specifically notes in their report, “Deepwater Horizon Oil Spill: OSHA’s Role in the Response, May 2011,” that personal protective equipment (PPE) was “essential for protecting workers...,” but they (OSHA) “stressed throughout the response that decisions about PPE should be based on a scientific characterization of the hazards, including air sampling…” On their PPE Matrix used during Deepwater Horizon, it is footnoted that certain PPE (e.g. full body chemical protective clothing) should only be worn when a “specific hazard associated with the given job exists and warrants wearing of this protection,” and that this is decided by the on-site safety representative conducting a field job hazard analysis. This seemingly mundane footnote is in fact at the crux of the matter, which supports the need of literature that this document is meant to alleviate. During the Deepwater Horizon Oil Spill, untrained safety personnel regularly failed to properly follow the model. Instead, the “one-size-fits-all” approach is viewed as the quickest and easiest answer to what PPE should be worn, and the PPE Matrix is implemented and codified in the Site Safety Plan.

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Contents

Page

1. Scope 1

   1. General 1

   2. Purpose 1

   3. Background 1

   4. Benefits 2

   5. Responsibilities 2

2. Terms, Definitions, Acronyms, and Abbreviations 3

   1. Terms and Definitions 3

   2. Abbreviations and Acronyms 9

3. Conducting a JSA for PPE Selection 10

   1. General 10

   2. Mandatory Requirements 10

   3. Responsibility for Conducting JSA 10

   4. Methodology for Determining PPE Requirements 11

4. Hazard Control for Conducting Oil Spill Site Evaluation 18

   1. General 18

   2. Mandatory Requirements 18

   3. Site Evaluation Procedure 18

5. Training for Oil Spill Responders on Use of PPE 21

   1. General 21

   2. Regulatory Requirements 21

6. Effects of Weather on PPE Selection 23

   1. General 23

   2. Cold Weather Stress 23

   3. Hot Weather Stress 26

   4. Sunlight Hazards 28

   5. Lightning. 28

7. Fatigue and Stress Effects of PPE 29

   1. General 29

   2. Monitoring and Maintaining Responder Health On-Site 29

8. PPE for Respiratory Protection 30

   1. General 30

   2. Mandatory Requirements 30

   3. Engineering Controls 30

   4. Respiratory Hazard Identification and Site Characterization 30

   5. Respiratory Protection Program 33

9. PPE for Chemical and Physical Hazards 36

   1. General 36

   2. Mandatory Requirements 36

   3. Hazards 36

   4. Routes of Entry 37

   5. Selecting Protective Clothing 38

      Contents

      Page

   6. Eye and Face Protection 39

   7. Hand and Arm Protection 40

   8. Foot Protection 41

   9. Head Protection 44

10. PPE for Hearing Protection 46

    1. General 46

    2. Mandatory Requirements 47

    3. Hazard Assessment 48

    4. Engineering and Administrative Controls 48

    5. PPE for Hearing Protection 49

11. PPE for Slip, Trip, and Fall Protection 50

    1. General 50

    2. Slip and Trip Hazards 50

    3. Fall Protection PPE 51

12. PPE for Wildlife and Vector-borne Diseases 52

    1. General 52

    2. Types of Hazards 52

    3. Hazard Mitigation 53

    4. Exposure Types 53

    5. Preventing Insect Stings and Tick Bites 54

13. PPE for Responders near Traffic, ATVs, and UTVs 55

    1. General 55

    2. Mandatory Requirements 55

    3. ATVs and UTVs 55

    4. Traffic 56

14. PPE for Water Safety 57

    1. General 57

    2. Mandatory Requirements 57

    3. Types of Hazards 58

    4. Drowning Prevention 58

    5. Water Hypothermia Prevention 60

    6. Purposeful Water Entry 61

15. PPE for In Situ Burning 62

    1. General 62

    2. Types of Hazards 62

    3. PPE Selection 62

    4. Other Issues to Keep in Mind 64

Annex A (informative) PPE Selection Matrix 65

Annex B (informative) Example Documents for Conducting a JSA 70

Annex C (informative) Example Training Matrix 73

Annex D (informative) Example Action Levels 75

Contents

Page

Bibliography 76

Figures

1. Job Safety Analysis Flow Chart (Forms Referenced are Used as Examples) 11

2. Air Monitoring Planning Process 32

3. Skin Absorption of Chemicals 37

4. U.S. Coast Guard 50-50 Box 61

Tables

1. Risk Assessment Matrix 15

2. Severity 16

3. Probability of Occurrence 16

4. Wind-chill Chart 25

5. Likelihood of Heat Disorders: NOAA's National Weather Service Heat Index 27

6. Markings Used on Safety Shoes 44

7. OSHA Permissible Noise Exposures 47

8. Water Hypothermia Chart 60

Personal Protective Equipment Selection for Oil Spill Responders

1. Scope

   1. General

      This recommended practice (RP) provides general information and guidance for the development of oil spill responder personal protective equipment (PPE) control measures. Although an extensive amount of information has been developed on the topic of PPE for emergency responders, this document focuses on the PPE selection process as well as its technical evaluation based on the hazards present.

      
      

      This RP is intended for any company, organization, or agency that oversees or responds to oil spills. It is not a comprehensive “how-to” guide to selecting PPE for every type of situation that may be encountered; rather, it is a guidance document that discusses how proper PPE selection may be a useful control measure for responders when engineering and administrative controls may not be feasible or effective in reducing exposure to acceptable levels.

      
      

   2. Purpose

      
      

      The purpose of this RP is to assist users in developing effective PPE control measures for oil spill responses using a systematic approach.

      
      

   3. Background

PPE is often the primary control employed during emergency response operations. PPE and administrative controls often rise to the forefront of oil spill response activities due to inherent delays involved in the implementation of effective engineering controls.

Choosing and implementing PPE as a response control measure is never a “one-size-fits-all” solution. A general PPE selection matrix such as the one shown in Annex A is a useful tool, but the proper selection of PPE requires a risk assessment (RA). Further, when working conditions change or the training provided to responders is no longer appropriate due to changing conditions, a reassessment is necessary. Response organizations, due to the failure to assess hazards appropriately, may overprescribe PPE in an attempt to ensure both compliance and protection; however, this approach has its drawbacks because the unnecessary use of PPE may actually increase the risk of injury or illness.

“In general, the greater the level of chemical protective clothing, the greater the associated risks. For any given situation, equipment and clothing should be selected that

provide an adequate level of protection. Overprotection as well as under-protection can be hazardous and should be avoided.” (OSHA Technical Manual) 1

Though practitioners may use other terminology and similar processes, this RP provides a methodology for conducting an evaluation of the conditions and choosing the appropriate PPE by assessing the hazards associated with the work environment. The process consists of:

job hazard analysis (JHA) + risk assessment (RA) = job safety analysis (JSA)

Often a JHA is done without the RA. As the work, environment, or responder conditions change, or if there is an indication that the control measures are not working as intended (e.g. several responders

1 U.S. Department of Labor, Occupational Safety and Health Administration, 200 Constitution Avenue, NW, Washington, DC 20210, www.osha.gov.