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General Oil Spill Response Plan SAFETY AND HEALTH GUIDELINES Section 16 Page 16-1 of 23 September 1999 16. SAFETY AND HEALTH GUIDELINES The activities and operations carried out during the response and cleanup of an oil spill will be conducted in a manner that protects the safety of project employees, others involved in the operations, and the public and will meet the requirements of the current Project Safety Manual. The prevention of accidents, injuries, and occupational illnesses will be a top priority, and requires the active participation of every employee. Continuous efforts will be made to identify and eliminate or manage safety risks associated with project activities, including those associated with a spill response. Project health and safety policy includes the following principles: Identify and evaluate health risks related to operations that potentially affect project employees and contractors or the public Implement programs and appropriate protective measures to control safety and health risks, including appropriate monitoring of potentially affected employees Communicate in a reasonable manner to potentially affected individuals or organizations and the scientific community, knowledge about health risks gained from project health programs and related studies Determine at the time of employment and thereafter, as appropriate, the medical fitness of employees to do their work without undue risk to themselves or others Provide or arrange for medical services necessary for the treatment of employee occupational illness or injuries and for the handling of medical emergencies Comply with all applicable laws and regulations and apply responsible standards where laws and regulations do not exist Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration or risk Design and maintain facilities, establish management systems, provide training, and conduct operations in a manner that safeguards people and property Respond quickly, effectively, and with care to emergencies or accidents resulting from project operations, cooperating with industry organizations and authorized government agencies Conduct and support research to extend knowledge about the health and safety effects of its operations, promptly applying significant findings and, as appropriate, sharing them with employees, contractors, government agencies, and others who might be affected Emphasize responsibility and accountability for safe performance on the job to all employees, contractors, and others working on the spill response and encourage safe behavior off the job Undertake reviews and evaluations of Project operations to measure progress and to ensure compliance with the Project’s health and safety policy 16.1. Purpose and Scope This section serves as a guide for all Project personnel, contractors, and subcontractors for the protection of health and safety of personnel working on oil spill responses. This section includes provisions for training, hazard communication to personnel, safety guidelines, site characterization, recommended work practices including the use of

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Page 1: 16. SAFETY AND HEALTH GUIDELINES - ExxonMobillocal.esso.com/Chad-English/PA/Files/Sect16.prn.pdf · SAFETY AND HEALTH GUIDELINES ... 16. SAFETY AND HEALTH GUIDELINES The activities

General Oil Spill Response Plan SAFETY AND HEALTH GUIDELINES

Section 16 Page 16-1 of 23 September 1999

16. SAFETY AND HEALTH GUIDELINES The activities and operations carried out during the response and cleanup of an oil spill will be conducted in a manner that protects the safety of project employees, others involved in the operations, and the public and will meet the requirements of the current Project Safety Manual. The prevention of accidents, injuries, and occupational illnesses will be a top priority, and requires the active participation of every employee. Continuous efforts will be made to identify and eliminate or manage safety risks associated with project activities, including those associated with a spill response.

Project health and safety policy includes the following principles: • Identify and evaluate health risks related to operations that potentially affect project

employees and contractors or the public • Implement programs and appropriate protective measures to control safety and

health risks, including appropriate monitoring of potentially affected employees • Communicate in a reasonable manner to potentially affected individuals or

organizations and the scientific community, knowledge about health risks gained from project health programs and related studies

• Determine at the time of employment and thereafter, as appropriate, the medical fitness of employees to do their work without undue risk to themselves or others

• Provide or arrange for medical services necessary for the treatment of employee occupational illness or injuries and for the handling of medical emergencies

• Comply with all applicable laws and regulations and apply responsible standards where laws and regulations do not exist

• Work with government agencies and others to develop responsible laws, regulations, and standards based on sound science and consideration or risk

• Design and maintain facilities, establish management systems, provide training, and conduct operations in a manner that safeguards people and property

• Respond quickly, effectively, and with care to emergencies or accidents resulting from project operations, cooperating with industry organizations and authorized government agencies

• Conduct and support research to extend knowledge about the health and safety effects of its operations, promptly applying significant findings and, as appropriate, sharing them with employees, contractors, government agencies, and others who might be affected

• Emphasize responsibility and accountability for safe performance on the job to all employees, contractors, and others working on the spill response and encourage safe behavior off the job

• Undertake reviews and evaluations of Project operations to measure progress and to ensure compliance with the Project’s health and safety policy

16.1. Purpose and Scope This section serves as a guide for all Project personnel, contractors, and subcontractors for the protection of health and safety of personnel working on oil spill responses. This section includes provisions for training, hazard communication to personnel, safety guidelines, site characterization, recommended work practices including the use of

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personal protective equipment, decontamination procedures, medical surveillance requirements, industrial hygiene monitoring programs, general hygiene, sanitation, and housekeeping guidelines.

16.2. Implementation It is the responsibility of each operations manager responsible for supervision of cleanup efforts, either directly or through the use of contractors, to ensure implementation of the safety program. For Tier 3 response, an industrial hygiene specialist will conduct periodic monitoring and observe operations for compliance with these health and safety provisions.

All personnel who may be directly involved in any cleanup activities are required to complete the training program covered in Section 17. Such involvement will include, but is not limited to, such tasks as: • Water skimming operations • Dispersant applications • In-situ burning • Shoreline protection • Shoreline cleanup operations • Cleaning of contaminated equipment and vessels • Handling, storage, and disposal of oily waste • Wildlife handling A copy of this plan will be kept at the Occurrence Notification Center (ONC) located at the Oil Traffic Control Center (OTCC) in Douala, Cameroon and at the OC Komé Base, Chad. It is the responsibility of each manager, supervisor, and crew foreman to become familiar with the plan and be responsible for implementation of safety and health provisions.

The following sections address specific programs and/or policies required for the health and safety of personnel involved in a cleanup effort. Specific elements are: • Health and safety considerations (Section 16.3) • Training program (Section 16.4 and Section 17) • Industrial hygiene compliance and monitoring program (Section 16.5) • Emergency medical response plan (Section 16.6) • Site control program (Section 16.7) • Personal protective equipment (Section 16.8) • Hazard communication(Section 16.9) • Personal hygiene/sanitation/housekeeping (Section 16.10) • Decontamination (Section 16.11) • Waste handling, transportation, and disposal (Section 16.12) • Site-specific safety plans (Section 16.13) • Exxon Environmental Health Fact Sheets (Section 16.14) • External Loads and Aerial Application Aircraft (Section 16.15)

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Section 16 Page 16-3 of 23 September 1999

• Material Safety Data Sheets

16.3. Health and Safety Considerations

16.3.1. Chemical Exposure Hazards

The chemical nature of crude petroleum is generally described in the material safety data sheets (MSDS). However, the MSDS represent unweathered crude petroleum. The chemical nature of unweathered, contained petroleum and spilled petroleum in the environment is appreciably different and will vary with the degree of weathering that has occurred. Weathering factors are time, temperature, biodegradation, nature of the contact surface (water, rocks, etc.), and degree of mixing with a medium such as water (see Section 4).

Crude petroleum is an organic liquid primarily containing hydrocarbons, with smaller percentages of sulfur, nitrogen, and oxygen. Trace metals also occur. The constituents have boiling points ranging from gases (methane) to solids (high molecular weight organic material and metals). The gaseous and volatile liquid fractions make petroleum highly flammable. Weathered crude petroleum (subjected to interaction with water, wind, salt, and air) is less flammable. Crude petroleum in the liquid state forms a thin film on the surface of water, causing sheen. In some cases, as the petroleum ages it emulsifies with the consistency of mousse. This material may adhere to vegetation, riverbanks, beach rocks and other objects.

16.3.2. Health Effects from Chemical Exposures to Petroleum

During the first hours following a spill, inhalation of volatile organic compounds may be an issue. Crude oil is highly complex and contains variable mixtures of non-aromatic hydrocarbons (paraffinic (alkene), cycloparaffinic (naphthenic)) and aromatic hydrocarbons of different molecular weight and structure. Typically these compounds are readily removed, and inhalation of volatiles quickly becomes insignificant. Chad crude oil also contains low percentages of sulfur and trace amounts of nitrogen and oxygen compounds, as well as metals such as nickel, vanadium, iron and sodium, which should not be a concern during the response operations.

The health effects associated with exposure to crude oil are related to the individual components that make up the crude and their respective concentrations. Generally, crude oil has a low order of acute oral and dermal toxicity and may cause slight to moderate skin irritation. Inhalation of the vapors or aromatic and paraffinic components may cause dizziness, lack of coordination nausea, headache, and fatigue at concentrations above 100 to 200 ppm.

Benzene exposure may also be a health concern in the early stages of a crude spill. Benzene is a known human carcinogen and long-term exposure (not expected during an oil spill cleanup) to benzene can cause anemia and other blood diseases including leukemia. Modeled benzene exposures predict toxic concentrations will have dissipated within six hours of being spilled.

The high molecular weight fraction of crude oil contains non-volatile components such as polycyclic aromatic hydrocarbons (PAHs). Some PAHs are carcinogenic to the skin after repeated, prolonged exposure if proper decontamination techniques are not used. Mists and aerosols generated during spill cleanup can also result in the inhalation of PAHs. Mists and aerosols containing PAHs are in principle, a cancer risk, but it is not clear

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whether such particles could be formed in sufficient quantities or of the appropriate size during spill cleanup operations to make the risk significant.

The International Agency for Research on Cancer (IARC) determined that crude oil is not classifiable as to its carcinogenicity to humans. The IARC evaluation states that there is inadequate and limited evidence for the carinogenicity of crude oil in humans and experimental animals, respectively. However, based on the high PAH content of the Chad crude oils, minimizing dermal and inhalation exposures is recommended.

Typical health and safety hazards and recommended personal protective equipment are presented in Table 16-1.

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Table 16-1. Health and Safety Information for Selected Contaminants

Oil Spill Components of Concern

8-Hour Exposure Criteria

15-Minute Exposure Criteria

Odor Threshold

Air Purifying Respirator

Criteria

Cartridge or Filter

Required

Exposure Requiring

Supplied Air Respirator

Protective Clothing Selection

Flammability Range

% LEL – % UEL

Hydrogen sulfide

10 ppm 15 ppm 0.005–0.013 ppm (2) none permitted N/A >15 ppm for more

than 15 minutes _ _ _ _ 4.3 – 7.9

Benzene 1 ppm (3) _ _ _ _ (4) 2.0 – 5.0 ppm >1 ppm <100 ppm

Organic Vapor >100 ppm Viton, CPF, Responder,

Tychem 10,000 1.3 – 7.9

Total Hydrocarbons

(Crude Oil) 100 ppm _ _ _ _ 0.11 ppm (5)

>100 ppm <1000 ppm

Organic Vapor >1000 ppm Nitrile, Viton, Barricade, Responder

Varies depending on

crude

PAHs (gas oil and Bunker C)

300 mg/m3 _ _ _ _ 1 mg/m3 (4) >0.2 mg/m3 < 15 mg/m3

Dust/Mist and Fume >15 mg/m3

Nitrile, Viton, Barricade, Responder

6.0 – 13.5

(gas oil)

Gasoline 300 mg/m3

(7) _ _ _ _ (8) 0.25 – 0.30

ppm >300 mg/m3 <3000 mg/m3

Organic Vapor >3000 mg/m3 Nitrile, Viton, Barricade, Responder

1.4 – 7.4

2-Butoxy Ethanol 25 ppm _ _ _ _ 0.11 ppm >25 ppm

<1000 ppm Organic Vapor >1000 ppm

Butyl Neoprene, Nitrile, Viton, Saranex

1.1 – 12.7

Carbon Monoxide (CO)

25 ppm 55 ppm N/A None permitted N/A >25 ppm _ _ _ _ 12.5 – 74.0

Oxygen (confined spaces)

Acceptable concentrations are

between 19.5% and 23%

N/A <19.5% None permitted

N/A <19.5% _ _ _ _ _ _ _ _

Exposure criteria are Project Occupational Exposure Limits (OELs). Footnotes define sources of other exposure limits. TLVs are the American Conference of Governmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs). PELs are the Occupational Safety and Health Administration (OSHA) Permissible Exposure Limits (PELs). (1) Follow local regulation if they are more stringent. (2) The perception of H2S “rotten egg” odor can diminish quickly. Odor should not be relied upon as the primary method to determine the presence or

absence of H2S. (3) The TLV is0.5 ppm. (4) The TLV is 2.5 ppm and the OSHA PEL is 5 ppm.

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(5) May vary significantly between crude types and ambient conditions. (6) Reported threshold of sensory irritation to upper respiratory system. (7) The TLV is 300 ppm (890 mg/m3) (8) The TLV is 500 ppm (1480 mg/m3) (9) Consult with Safety Professional

PAH = Polynuclear Aromatic Hydrocarbons

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16.3.3. Physical Hazards

During cleanup operations, the physical-working environment of operating personnel must be continually evaluated. Exposure to hot weather environments over long periods can adversely affect both the physiological and psychological condition of those involved. Continued exposure may result in physical discomfort, loss of efficiency, and a higher susceptibility to accidents and injuries. A major potential for injures is from slips, trips, and falls. Every worker must be aware of the environment at all times. This is called “staying safe” or “take 2 --- thinking before acting to evaluate risks”. The “buddy system” is another important aspect of safety. Simply stated, everyone should remain in visual contact with other workers at all times, and no one should work alone. The buddy system allows for making sure everyone is safe, assuring that each other’s physical or psychological condition is not deteriorating due to exposure or exhaustion, and getting immediate first aid if someone is ill or injured.

The primary kinds of physical hazards present during spill response operations include: Slips, Trips, and Falls — These are a major source of injuries and are primarily caused by inattention. Slips, trips, and falls occur while walking across rocks, boarding boats, walking on boats, and carrying objects. In some cases, using properly fitting boots with non-slip soles can minimize these hazards.

Noise — Sources of noise associated with cleanup operations may include generators, water pumps for the deluge system, warm water units, and landing craft and other motors. Aircraft operations may be a source of excessive noise. Impact noise (sharp or explosive inputs of energy) also exists in these operations. Adequate hearing protection is provided for optional use. An industrial hygienist will determine if a noise hazard exists and will identify those operations that require full-time use of hearing protection.

Heat Stress — Heat stress is a critical concern in equatorial Africa, and particularly for personnel wearing specialized protective clothing. Both encapsulating and non-encapsulating protective clothing are designed to protect the user from hostile environments and prevent passage of materials into the “protective envelope”. Protective equipment reduces the body's ability to discard excess heat and have natural body ventilation. Heat rash, heat cramps, heat exhaustion (heat prostration), and heat stroke may occur. The four “stages” of heat stress, with appropriate actions, are given in Table 16-2.

Work Exhaustion — Given the nature and magnitude of the cleanup operations, crews may work long hours. It is the responsibility of crew chiefs to identify members of the crew that exhibit symptoms of work exhaustion. Those identified will be taken off their work task and allowed time to recover. Signs and symptoms include the loss of concentration, increased frequency of trips and falls, and complaints of cramping and pain (back, shoulders, etc.).

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Table 16-2. Heat Stress Stages and Appropriate First Aid

Heat Stress Stage

Symptoms Typical Causes First Aid Recommendations

Heat Rash (Prickly Heat)

• Rash on the skin • Humid environment, or wearing protective equipment that holds moisture next to the skin

• Thorough washing

• Rest periods in cool location

• Medicated powder

Heat Cramps • Muscle spasms in hands, feet, abdomen

• May also be accompanied by nausea/vomiting

• Person becomes quiet/stops work

• Large electrolyte loss due to swelling, diluting electrolyte balance in the body

• Drink fluids with proper balance of electrolytes, such as commercially available sports drinks

• Allow rest periods for routine drinking

Heat Exhaustion

• Skin is pale, clammy/moist

• Nausea, headache, dullness of response/ work pace

• Person may become quiet, sit down, or faint

• Excessive water loss, inadequate replacement

• Worker may not be acclimatized to work, equipment, and/or climate

• Move worker to cool place (shade)

• Remove protective equipment (if appropriate)

• Drink plenty of liquids with electrolytes

• Seek medical care/advice

Heat Stroke • Skin may be dry, reddish, and hot

• Person may faint or become disoriented

• Convulsions may occur with vomiting and rapid pulse rates

• Temperature regulatory control has failed

• Body can no longer rid itself of excess heat

• Seek medical care immediately

• Remove protective clothing

• Wet with cool water, cold beverage bottles

• If person is conscious, provide small but continuous amount of cool water/electrolytes

• Do not leave person unattended

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Confined Spaces

No personnel may enter any confined space without meeting the requirements of Section 12 (Permitting Requirements) of the Project Safety Manual written permission from their supervisors. A confined space is defined as: • an enclosed space large enough to allow entry • has limited entry or exit, and is not continuously occupied • contains or has known potential to contain a hazardous atmosphere • contains a material with the potential to engulf the entrant • contains any other recognized serious safety or health hazard • has an internal configuration that can result in entrapment or asphyxiation by inwardly

converging walls or a floor that slopes downward Examples of confined spaces that may exist as part of cleanup operations include waste oil barge tanks, boat storage compartments containing oily wastes or animal carcasses, waste containers, dump trucks, and skimmer storage compartments.

Permits to enter will be issued by a designated person trained to test atmospheres for oxygen deficiency, explosivity, and presence of any substance for which an exposure limit is published. Entry will not be permitted in atmospheres that contain greater than 10% of the lower flammable limit, an oxygen concentration less than 19.5% or above 23%, and any substance in excess of its published exposure limit. In the event a confined space atmosphere does not meet these criteria, an industrial hygienist should be consulted.

16.3.4. Fire and Explosions

Care must be taken around hydrocarbons and fuels. Fuel storage and transfer facilities will be designed and constructed according to appropriate codes and regulations. Fire suppression equipment will be readily available. Smoking is not allowed near flammable materials. Welding and burning require work permits where hydrocarbon mixtures may exist (i.e., vessels tanks, etc.) that contain explosive mixtures.

16.3.5. Eye Safety

Potential eye hazards include splashing from chemicals used for decontamination and cleaning, splashing from salt water, oil and particles associated with pressure cleaning on the shoreline, entry of foreign bodies, and UV exposure associated with various maintenance activities. Suitable eye protection worn in all work areas would largely address this issue.

16.3.6. Personnel Back Care

Pulling of anchors or hoses on beaches, etc., are common sources of back strains and injuries. Proper lifting techniques will be discussed in appropriate training programs.

16.3.7. Equipment Safety

Training on equipment safety will include: • Special instruction in routine operations and maintenance of equipment (e.g., oil

skimmers) • Proper use of all personal protective equipment • Restrictions against personnel operating equipment without proper training

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• Techniques for the safe use of pressure hoses

16.3.8. Hand Tools

Safe working practices will be determined and reviewed with workers prior to working with hand tools and cleanup equipment. Common sense and team effort (buddy system) should be employed. Use the proper tool for the job. Do not take shortcuts.

16.3.9. Wildlife

Contact with wildlife may present a hazard to workers. Workers are instructed not to touch, harass, scare, or attempt to feed any wildlife. Wildlife hazing and rescue guidelines are covered in Section 15 – Wildlife Rescue.

Insect bites can cause infections or may be sources of vector-borne diseases such as trypanosomiasis (sleeping sickness), onchocerciasis (river blindness), and malaria. Seek medical attention if required.

Workers may be exposed to snake or scorpion bites while conducting field work. Spill responders will be briefed on local wildlife hazards and should seek immediate medical attention if severely stung or bitten. Snake control programs will be established, as well as medical treatment protocols for snake bites, scorpion stings, and other harmful injuries. Anti-venom will be kept with work crews.

16.3.10. Shoreline Safety

When cleaning rocky shorelines, the skipper and crew chief will decide if the vessel can be stabilized enough to clean the area safely. Slips, trips, and falls are special concerns. Slippery and jagged rocks create very hazardous walking conditions. Waterproof footgear with good non-slip soles is crucial. Footgear soles must be thick enough to prevent puncture wounds.

16.3.11. Air Safety

All air traffic will comply with Chad or Cameroon regulations, as appropriate, and with company command directives. General safety requirements when working on or around aircraft are:

• No one will board or exit any aircraft unless directed by the pilot or his designee. • When traveling in helicopters over water personal flotation devices (PFDs) must be

worn. • PFDs are not required to be worn in fixed wing aircraft, except during travel over

extended areas of water. • Seat belts are required to be worn at all times. • When entering or exiting a helicopter, walk straight to it from the front or side, never

from the rear. The invisible tail rotor causes the most severe injuries. • Avoid foot placement on pop-out pontoons on aircraft. Do not step on them because

they may be punctured. Additional aircraft safety guidelines are provided in Section 16.15.

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16.3.12. Boat/Water Safety

All boats will comply with local regulations for their size and class. Radio equipment shall be in good working order, comply with regulations, and be compatible with communications. Boats without navigational aide (radar) will not travel at night. When transferring from boat to boat, personal flotation devices must be worn. Handle anchors and anchor ropes carefully. Common accidents include dropping anchors on feet and catching hands between an anchor rope and the side of a boat. Extreme care is needed when beaching a boat because of strong currents, rocks, etc.

DO NOT:

• Stand up and move around in small boats • Overload boats or distribute loads unevenly • Decelerate suddenly, allowing the stern wake to overtake and swamp the boat by

washing over the transom. DO:

• Hold on to the boat when underway • Wear PFDs when transferring from boat to boat and boat to shore.

16.3.13. Vehicle Safety

Specific design measures will be in place to maintain a safe work environment and prevent accidents. Site-specific medical emergency response plans will be in place for all work locations. Should an incident occur, specific investigation procedures would be in place to determine the cause and prevent future occurrences. During orientation, on-site safety training will be provided for all project personnel and driver safety training for all drivers. The project work force, including drivers, would participate in a drug and alcohol random testing program. Employees will be required to use appropriate safety equipment and follow site safety practices.

16.4. Training Program The objective of the Safety and Health Training Program is to enable all workers associated with cleanup operations to understand the health and safety concerns associated with this activity. The training will enable workers to protect themselves and their fellow workers from any work hazard and to perform their work in a safe and healthy manner. Details of the training program are provided in Section 17.

All appropriate personnel will receive training before taking part in work activities. Personnel who have completed the training will be documented and designated “competent”, i.e. trained in health and safety factors associated with the cleanup effort. Necessary records of those people who have satisfactorily completed the training will be maintained at appropriate project offices. The records will include name, identification number, and company affiliation.

The primary Safety and Health Training emphasizes: • Safety during cleanup operations • Health hazards associated with operations • Personal protection

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• Decontamination Additional continuing training will provide updates to safety and health issues, and will reemphasize key sections of the primary program. Continuing training will be provided when workers are rotated back into the field.

16.5. Industrial Hygiene Compilation and Monitoring Program

The monitoring and control program provides health protection for all personnel working on the cleanup effort. In addition, it provides for the monitoring of residents potentially affected by oily residues or their vapors. If in-situ burning is used, monitoring of the smoke plume should be implemented.

Implementation of this program will be the responsibility of the Project safety and health staff and their contractors. It will consist of program oversight and controls conducted by Project industrial hygiene personnel and implementation by on-site staff and contractors. This program will be in effect for the duration of the cleanup efforts undertaken by employees or contractors.

The overall industrial hygiene compliance and monitoring program consists of four major components: • Surveillance — Observation of work practices to provide assurance of maximum

personnel protection from potential dermal and/or inhalation exposures by chemicals and equipment by-products associated with cleanup activities

• Compliance monitoring — systematic and periodic monitoring for exposure to crude petroleum components, (including benzene, toluene, xylene, and other volatile hydrocarbon constituents; hydrogen sulfide; PAHs) and other components demonstrated by chemical analysis of the weathered crude petroleum to be a potential health hazard through inhalation, ingestion, and/or dermal contact. Monitoring is continued until potential exposures reach acceptable levels. Additional monitoring will be done for components of chemical mixtures used in the cleanup process (e.g. degreasers, dispersants, etc.) that may present exposure hazards.

• Noise — Periodic monitoring of sound levels from mechanical and/or electrical powered equipment used in the cleanup operations

• Toxic by-products — Periodic monitoring of toxic combustion by-products from equipment used in the cleanup operations that may present a health hazard to workers in the immediate vicinity

16.6. Emergency Medical Response Plan The Emergency Medical Response Plan serves as a plan of action for the injury or illness of any Project personnel working on an oil spill cleanup effort. The plan covers all aspects of offshore work away from land-based control centers, as well as land-based operations.

The Emergency Medical Response Plan is kept in the Occurrence Notification Center (ONC) located at the Oil Traffic Control Center (OTCC) in Douala, Cameroon and at OC Komé Base, Chad. Specific site information will be included in a Site-specific Safety Plan developed at the time of an incident. A Medic station in Komé is available to handle

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medical emergencies. A site-safety checklist and a blank Site-Safety Plan are maintained in Appendix C, Checklists and Appendix D, Forms, respectively.

In the event of a spill, if necessary, the proper authorities will be immediately notified so that they may ensure the safety of the affected communities.

16.7. Site Control Program The Site Control Program serves as a basis for controlling all onshore and offshore cleanup activities so that they are done safely and according to defined work plans. This plan covers all aspects of cleanup work away from land-based control centers. Issues include:

• Permitting — Required permits or clearances will be obtained prior to entry and start-up of all shoreline and offshore cleanup operations.

• Chain of command — Each operation shall have a specific chain of command identifying specific individuals. In general, the chain of command will proceed upward from the worker according to the organizational charts presented in Section 3.1.

Site Access

If necessary, a spill cleanup site will be cordoned off to control access to the site. To mitigate hazards to the public and others, site access should be limited to those personnel who are trained and approved to conduct spill response and cleanup activities.

Communication

Communication will be maintained between the work crew, crew chief, and site manager by one of the following (the most appropriate tool for the situation at the time will be used).

• Radio (hand-held or marine VHF) • Hand signals • Air horns • Reporting through the chain of command The “buddy system” is another important aspect of communications. Simply stated, everyone should remain in visual contact with other workers at all times, and no one should work alone. Project communication guidelines are presented in more detail in Section 13.

16.8. Personal Protective Equipment To assure protection of all cleanup workers, PPE shall be used as required for specific job activities and during transit between sites or from berthing points to activity sites. Certain items of PPE are mandatory, and others are optional. The Safety Manager will advise site crew chiefs of the requirements, and the site crew chiefs will in turn inform their workers. Specific requirements by type of operation or type of protection are given below. Check with Dispersant/Burning Advisor regarding PPE requirements for dispersant application.

16.8.1. General Requirements

• Suitable eye protection must be worn in all work areas.

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• Hard hats are required where workers may be struck from above by objects or where they may strike something overhead.

• Adequate clothing and protection must be worn to prevent contact with oil. This may consist of oil-resistant boots, gloves, slicker suits, and goggles or face shields, depending on the exposure and job being done.

• Hearing protection is required in high noise areas, such as around heavy equipment, aircraft, and internal combustion engines. These areas will be identified following a noise survey or on the advice of the site Safety Manager.

16.8.2. Requirements for Personal Flotation Devices

• Type I Personal Flotation Devices (PFDs) are required when riding in boats. • Type III to Type V PFDs are required when working on boats and/or working where

there is a potential to fall in the water. • Wearing PFDs is not required in fixed wing aircraft; however, all aircraft traveling over

extended water areas must carry sufficient PFDs for all personnel on board.

16.8.3. Types of PPE Protection

Face and Eye Protection

Face and eye protection prevents injuries caused by flying objects and chemical splashes. It will be up to the operations safety personnel to determine the type of device to employ.

Types of equipment include: • Face shield — These protect against splashes and small, slow-moving projectiles.

These devices attach to hard hats or can be strapped directly to the forehead. • Safety glasses — Safety glasses protect eyes from large particles and projectiles.

They are worn just like regular glasses. • Goggles — Depending on the type of goggles, they protect against chemical

splashes, large particles, and projectiles. Gloves

• Oil-resistant gloves will be worn by all shoreline cleanup personnel to prevent oil contamination and reduce skin exposure and abrasions. Abrasions in tidal areas become infected easily. Gloves will be placed in trash bags at the end of each working day and recycled if possible, or disposable gloves will be utilized.

Protective Clothing

• Protective outer wear or rain suits (slicker suits) will be worn for all work where direct contact with oil is possible. At the end of each work shift, suits will be placed in trash bags for transport to a decontamination station. They will be recycled if possible.

Boots

• High top, oil-resistant boots will be used for all cleanup activities where direct contact with oil is possible. Boots for shoreline and offshore work will be selected based on traction suitability.

• Boots will be scraped clean daily before getting on crew quarters.

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• Crew quarters will have absorbent pads throughout footpath areas to absorb excess oil contamination.

• Boots will be cleaned after each field trip (shore, skimmer, etc.) at a decontamination station or at crew quarters

Respiratory Protection

Respiratory protection is generally not required for onshore and offshore cleanup operations; however, in those few instances where protection from dust, mist, odors, or vapors is necessary, disposable half-mask devices will be used. Respirators may be required where a permissible exposure limit for chemicals is exceeded. Training will be provided for the use of respirators if such a requirement exists.

Respiratory protection also may be used for odor control (petroleum or decaying matter). If respirators are used for odor control, they will not provide protection against other potentially toxic gases, such as carbon monoxide or hydrogen sulfide. If respirators are used for odor control, the user will be instructed by the Safety and Health representative to determine proper fit and identify limitations. The Safety and Health representative will make selection of respirators.

Standard PPE Issue

The following items will be issued to all cleanup workers dealing directly with the oil cleanup, e.g.: laborers, skimmer operators, boom handlers, etc. Other workers will receive equipment consistent with their job hazards. • cotton work coveralls • rain gear (pants and jacket) • oil-resistant boots • socks • oil-resistant gloves • cotton work gloves

16.9. Hazard Communication Regular safety meetings will be held at each level during response operations. These meetings should include discussions of all potential hazards.

Hazard communication advises all participants in the cleanup activities on the potential adverse health effects of crude petroleum and any additional chemicals that may be used in the cleanup operation. The use of MSDSs will be the primary means of notice regarding new chemicals. Hazard communication also provides strategies for minimizing chemical exposures through appropriate training regarding work procedures, chemical handling practices, and use of personal protective equipment.

All personnel participating in a cleanup effort will be provided hazard communication training during initial training. In addition, periodic update training sessions will reinforce initial training and provide information on new chemicals that may be used in a cleanup effort.

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16.10. Personal Hygiene/Sanitation/Housekeeping The program goal is to both minimize exposure and keep people and the environment clean and healthy. The program is designed for all personnel involved in cleanup.

Dermal Exposure

Protective clothing (e.g. rain gear, gloves, and rubber boots) prevents oil from getting on the skin. If skin contact occurs, remove the oil as soon as possible with paper towels and waterless hand cleaner or wet wipes available at each job site. Soap and water is preferred as a cleaning method if available. Specific decontamination procedures are covered separately.

Litter

Litter is not allowed. Do not dump anything from boats. Nothing should be left on shorelines. All litter should be removed at the end of each shift.

Sanitary Facilities

Showers, latrines, and laundry will be available for all response crews.

Potable Water and Food Handling

Specified personnel will collect water samples and conduct audits to help ensure the quality of drinking water and food. Water will be tested for bacteria. Food handling facilities will be audited for food quality, food protection, personnel practices, food equipment/utensil cleaning and sanitizing, and garbage/refuse disposal.

In the event of a large-scale cleanup operation, the influx of additional personnel may create stress on infrastructure and resources. Measures would be taken to maintain food and water supplies to prevent depletion of local food and water sources. Food sanitation standards for contractors who provide food service would include: • food protection; • food storage; • food preparation; • food display; • food transportation; • food handlers’ health, personal cleanliness, clothing, and practices; • equipment and utensil cleaning and sanitization and storage; • potable water supply, plumbing, and toilet facilities; • insect and rodent control; • construction and maintenance of physical food service facilities; • bacterial testing; and • work practice evaluations. Waterborne disease-prevention community programs would focus on: • water supply, • pit latrines,

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• laundry, • bathing, • refuse disposal, and • insect and rodent control. Education programs would focus on water source protection and safety including water-related disease transmission methodology and prevention. If activities during cleanup operations disrupt local water supplies, alternative supplies would be provided to the affected community.

16.11. Decontamination Decontamination ensures that oil-contaminated protective clothing is removed safely with minimum direct skin contact and is adequately cleaned or disposed of. In addition, all tools and boats that come in contact with oil will be cleaned by protected workers. This involves all clothing and equipment used in the oil cleanup.

The purpose of decontamination procedures is to remove all contamination from work clothing and to prevent direct skin contact and secondary contamination of other garments and clean areas. Exact procedures will vary according to location and will be described by the site supervisor.

Limited Decontamination

Before lunch and other breaks, workers will move to a designated area to remove oily gloves and clean their hands with soap and water or a waterless hand cleaner. Soap and water, if available, are preferred. Workers must avoid secondary contamination from oily suits during these periods.

Full Decontamination

At the end of a shift, clean-up workers will return to the living quarters. A designated “dirty” area will be attached to the living quarters, and that is where workers will remove oily protective clothing. Re-usable contaminated clothing will be segregated by type (i.e., boots, rain pants, rain jackets) and cleaned. Disposable clothing such as gloves will be put in waste containers. Body contamination will be removed by showering in a separate area from dirty clothing removal. Laundry bags are available for workers to place dirty clothes worn under their protective gear. Workers will then proceed to a clean area to change into clean street clothing.

Equipment Decontamination

Generally, oil-contaminated tools will be left on the boats and decontaminated only at the end of the cleanup efforts. Boats will be cleaned in designated boat wash areas at various docks by protected personnel, who daily go through the above-described decontamination sequences.

16.12. Waste Handling, Transportation and Disposal Handling and disposal of liquid and solid waste generated by oil spill cleanup operations is covered in Section 12 of this GOSRP.

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16.13. Site-specific Safety Plans Additional reports will be required for long-term oil spill response efforts. These will generally be site-specific or spill-specific reports developed to meet the information requirements of the particular spill. An example of a fill-in-the-blank site safety plan, to be developed for use in an emergency situation, is provided in Appendix D, Forms.

16.14. Environmental Health Fact Sheets Environmental health fact sheets for the following products are inserted at the end of this section:

• Crude oil • Gasoline • Heavy marine/industrial fuels • Marine fuels • Kerosene/Jet fuel • Corexit 9500 • Corexit 9527 In addition to these fact sheets, MSDSs will be maintained by the Operations Managers. The Safety Advisor will have the above sheets readily available for site safety plans developed at the time of incident response.

16.15. External Loads and Aerial Application Helicopters This section pertains to techniques and precautions relevant to operations involving loads carried externally on cargo hooks and slings or on external winches by helicopter. The information is applicable to all operations, but particularly to large-scale lifts. As a minimum, external load operations should be conducted in accord with local aviation regulations. The following activities should be coordinated with the Safety Advisor and the Air/On-water Supervisor (Tier 2) or the Aviation Supervisor (Tier 3).

16.15.1. Safety Programs

The helicopter contractor should have safety procedures in place, including the following minimum requirements:

• A helicopter safety program should be initiated prior to commencement of operations, and the helicopter contractor should conduct on-the-job safety meetings. Crew briefings will be conducted on a daily basis to ensure that the specific lift requirements are understood by all.

• Clear areas: All personnel not directly involved with the operation should keep clear of the ground beneath the arriving and departing route of the helicopters and remain outside a radius of 50 meters during hovering operations.

• Flight paths: The flight path of external load operations should be routed clear of built-up areas, roads, villages, etc., due to the possibility of unintentionally dropping a load.

• Hook-up responsibility: The contractor will be solely responsible for hook-up, air transportation, and release of all loads. Only trained operators will undertake the hook-up responsibilities.

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• Nylon ropes/straps: Nylon rope cargo nets and/or nylon straps may be used for certain load rigging depending on the nature of the load and its effect on fabric materials. However, the line between the load and the cargo hook should be steel wire rope. The cargo hook line should always terminate at the hook end with a large-diameter steel ring.

• Protective safety equipment: Personnel engaged in external sling work should be provided appropriate protective dress and safety outfits, including safety goggles, work gloves, safety boots, hard hats, and distinctive task-designated colored vests.

• Swivel connection: A swivel will be used between fixed hooks attached to helicopters and the load cable or sling.

• Authorized flight crews : Only approved flight crews are to be carried on flights having external loads.

• Cargo/passengers/crew: It is common practice in external lift operations for the helicopter to transport slings, nets, long lines, and other related cargo items. If not carried externally, this cargo must be secured to tie-down rings or secured by an appropriate net. Loose cargo is unacceptable on any flight. Helicopters carrying external loads generally should not carry passengers.

• Seating: The helicopter may be configured to be as light as possible by removing equipment not necessary for external loads, such as passenger seats, sound proofing, etc. However, when passengers are transported to the work site, the activity must be conducted in strict compliance with the regulations concerning the movement of passengers in public transport. Appropriate certified seats and seat belts will be installed, passenger briefings are required, and load sheets giving passenger details must be left at each departure point where passenger changes occur.

• Communication: It is important that an effective system of communication be developed between the supervisor responsible for moving the relevant loads, the contractor's ground marshal (or load master), and the pilot. Ideally, the supervisor and the load master should be in close liaison, so that the loads can be scheduled, positioned, and prepared for the pick-up and subsequent delivery. The load masters (usually at pick-up and drop points) should have radio contact with the helicopter in order to achieve maximum flexibility of operations.

• On flights over short distances, it may be sufficient for the helicopter to restrict communication to the load master crew who, in addition to handling the operational transmission, will also provide the "listening out" service should an in-flight emergency occur.

• On extended operations where communication with the load master can be lost at times, the helicopter must establish communication with either a company base station or a government base station in order to have this "listening out" flight-following capability.

• Helicopter operating hand signals: In addition to radio communications, knowledge and understanding of international standard hand signals are required on the part of operations personnel.

16.15.2. Selection of External Load Helicopters

The type of helicopter selected depends on the weight of the loads to be carried. As all external sling load work requires the helicopter to hover out of ground effect, a higher

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demand is placed on performance. The helicopter's engines and rotor efficiency may be further deteriorated by the effects of temperatures, altitude, and humidity. A qualified aviation consultant should be contacted in the initial phase of project planning for input on mission requirements, helicopter performance requirements, and equipment selection.

Special Equipment

Weight limitations placed on a helicopter are critical, and it is essential that loads be accurately weighed before being released for airborne movement. This may require weighing equipment/scales, etc., to be provided in the staging area. Consideration should be given to the following equipment:

• Helicopters should be fitted with an under-belly mirror, so that the pilot can see the load master under the helicopter attaching the sling to the hook and also observe the load's behavior in flight.

• Helicopters may be fitted with bubble door windows to allow the crew to observe operations in the staging and drop zone areas.

16.15.3. Flight Crew Standards

Flight operation involving external loads is a very specialized and exacting task that requires a high degree of training on the part of the operator's flight crew. Flight crew should have received formal training in coordination with the winch operator on external winch loads. The operator should be required to provide written assurance that all crews are experienced in external load techniques, such as short-coupled or long-line sling work.

• A qualified aviation consultant should review pilot background experience on external load operations.

• Flight crews should be fully aware of minimum fuel quantities in conjunction with external load operations.

• No helicopter controls should be left unattended while aircraft engine(s) are operating. • Pilot rotations: Due to the repetition and exacting demands of a high-cycle external

load operations, it may be necessary to rotate crews on a more frequent basis. It is not so much the hours flown, but rather the number of cycles or sling load turns that create stress and fatigue. Flight crews should be provided with comfortable noise-free rest accommodations.

16.15.4. Staging Area and Personnel Responsibilities

It should be clearly understood that the helicopter contractor is responsible for the hook-up, air transportation, and release of all loads. The contractor should supply the load master, whose task will be to inspect the manner in which the rigging is secured to the load and to hook up the load to the helicopter or supervise the designated hook-up man, while coordinating with the pilot. The following additional requirements apply to the load master:

• The load master on the ground should wear a brightly colored jacket and hard hat with chin strap, to identify him to the pilot and distinguish him from other workers in the marshaling area. Adequate ear and eye protection should be worn.

• The load master or hook-up man should be the only person beneath the helicopter during hook-up of equipment.

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• The load master should be aware of minimum fuel requirements and work with the flight crew for fast refueling turn-arounds.

• Load marshaling labor: Although the contractor will normally be responsible for providing the load master, laborers may be provided by the Project to assist the load preparation.

• Marshaling area: This area should be sufficiently large to permit the marshaling of loads for helicopter pick-up, providing room to move around and out of critical distances of the helicopter pick-up point (minimum of 50 m away). The marshaling area and heliport should not infringe on the minimum heliport and obstruction-free zones.

• Helipads should be constructed with adequate rotor clearance and proper footing for the type of helicopter being used.

• Drop zones or landing areas should be sufficiently large to prevent equipment from contacting trees or other obstructions while spotting or lifting.

16.15.5. Fuel Considerations

Helicopter external load operations, including aerial application of dispersants (see Section 6, Offshore Response), should be planned with fuel reserves of no less than 20 minutes. External load work is often conducted at high power settings and therefore require frequent fuel stops.

Helicopter fuel should be made available on site at the base camp staging area. It is therefore a requirement that the helicopter contractor follow proper procedures for the storage, handling, dispensing, and use of aviation fuel. These procedures should include the filtration equipment and the methods used to detect the presence of water or sediment. In the final analysis, the pilot has the ultimate responsibility for the fuel requirements for the aircraft.

16.15.6. Emphasis on Helicopter Maintenance

Helicopters conducting external load operations invariably operate at high engine power due to prolonged periods of hovering. Engines often suffer further stress from the effects of sand, dust, etc., ingested into the engine. All of these factors combine to increase the demands on the efficiency of the maintenance service for helicopter support.

• Back-up helicopter: A back-up helicopter may be desirable to augment operations. It is incumbent upon the contractors' maintenance staff to provide maximum availability consistent with the highest standards of airworthiness.

• Maintenance shelter: For relatively long-term operations or in areas of extreme weather conditions, adequate cover should be available for helicopter maintenance.

• Electricity and water: Other services, such as night lighting, fresh water for cleaning aircraft, electricity, and lifting devices for changing components, also shall be made available.

• Spare parts storage area: The contractor should also be provided adequate space in which to store spare parts, components, and other supplies. Storage should be consistent with climatic conditions to preserve airworthiness.

• Maintenance of slings: The maintenance and care of all slings, long lines, cargo hooks, cargo nets, etc. should be the responsibility of the helicopter contractor. All auxiliary equipment (hooks, line, etc.) are to be visually inspected each day before

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use and thereafter on a regular basis. Slings used should have strength to handle four times the maximum weight they will lift.

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Annex 16-A. Environmental Health Fact Sheets

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