U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3172

2001

Training Marine Oil Spill Response Workers

Under OSHA’s Hazardous Waste Operations

and Emergency Response Standard
About this Booklet

This informational booklet is intended to provide

a generic, non-exhaustive overview of a particular

standards-related topic. This publication does

not itself alter or determine compliance responsibilities, which are set forth in OSHA standards

themselves and the Occupational Safety and

Health Act. Moreover, because interpretations

and enforcement policy may change over time,

for additional guidance on OSHA compliance

requirements, the reader should consult

current and administrative interpretations and

decisions by the Occupational Safety and Health

Review Commission and the Courts.

Material contained in this publication is in the

public domain and may be reproduced, fully or

partially, without permission of the Federal

Government. Source credit is requested but not

required.

This information will be made available to

sensory impaired individuals upon request.

Voice phone: (202) 693-1999

Teletypewriter: (TTY) 1-877-889-5627

See also OSHA’s Website at www.osha.gov
U.S. Department of Labor

Elaine L. Chao, Secretary

Occupational Safety and Health Administration

John L. Henshaw, Assistant Secretary

OSHA 3172

2001

Training Marine Oil Spill Response Workers

Under OSHA’s Hazardous Waste Operations

and Emergency Response Standard

Training Marine Oil Spill Response Workers Under HAZWOPER v

Contents

Introduction ................................................................................................................................ 1

How Marine Oil Spill Responses Are Organized and Managed ......................................................... 2

Applying the HAZWOPER Standard to Marine Oil Spills ................................................................... 4

Hazards to Marine Oil Spill Responders ........................................................................................ 5

Training Requirements ................................................................................................................. 7

Oil Spill Scenario ...................................................................................................................... 17

Other Sources of OSHA Assistance ............................................................................................ 21

Appendix A: Related OSHA Standards and Directives ................................................................... 23

Appendix B: Related OSHA Publications ...................................................................................... 24

Appendix C. OSHA Offices Directory............................................................................................ 25

Figures and Tables

Figure 1. Training Decisions Flowchart for Emergency Response Workers ........................................ 9

Figure 2. Training Decisions Flowchart for Post-Emergency Response Cleanup Workers .................. 10

Figure 3. Sample Certifications .................................................................................................. 16

Figure 4. Illustration of Incident.................................................................................................. 17

Table 1. Hazardous Chemicals and Their

 Effects ..................................................................................................................................... 6

Table 2. Training for Workers Who Perform

 Emergency Response .............................................................................................................. 11

Table 3. Training for Workers Who Perform

 Only Post-Emergency Response................................................................................................ 13

Table 4. Training Topics and Competency Areas ........................................................................... 15

Training Marine Oil Spill Response Workers Under HAZWOPER 1

Introduction

This booklet, written for marine oil spill response

employers,* describes the training your employees need under HAZWOPER, the Hazardous

Waste Operations and Emergency Response

standard, Title 29 of Code of Federal Regulations

(CFR)

1910.120.

The Occupational Safety

and Health

Administration (OSHA)

published

HAZWOPER

to protect

workers involved in hazardous substance emergency response and cleanup operations.

Not every spill response worker needs the

same amount of training. The type of training

you give your workers depends on how close they

will be to a spill and what role they will have in

stopping, containing, or recovering the spilled

material from the release. For example, if you

have workers who control an oil spill early in an

incident, they need more training than workers

who simply warn others about a spill. This

booklet explains how HAZWOPER training requirements apply to the range of workers who participate in marine oil spill response. To use this

guidance effectively, you need to know the duties

you expect your workers to perform and the

Train workers to the

HIGHEST LEVEL of

responsibility you

may assign them.

exposure conditions under which you would allow

them to work. You must train your workers to the

highest level of skill, responsibility, and exposure

that you will assign them.

This booklet was prepared by OSHA’s Office of

Health Compliance Assistance in conjunction

with the U.S. Coast Guard Office of Response.

*Oil spill response accounts for the majority of marine spill response operations and is the focus of this pamphlet. HAZWOPER

training, however, is required for all marine spill response operations conducted under the National Contingency Plan. The

training you provide must cover the range of hazardous substance spills you expect your marine response employees to handle.
2 Training Marine Oil Spill Response Workers Under HAZWOPER

A spill and safety briefing at a major oil spill.

HAZWOPER requires that a senior official who

is present at the response site, an Incident

Commander, lead an emergency response

operation. For marine oil spills, the ranking Coast

Guard officer or EPA official at the spill scene

usually functions as the On-Scene Incident

Commander. The emergency response remains

in effect until the Incident Commander declares

it completed.

OSHA is responsible for assuring safe and

healthful working conditions for working men and

women. During marine oil spill response, OSHA

provides advice and consultation at the request

of other government agencies. If necessary,

OSHA uses enforcement action to assure that

workers are properly protected.

Emergency Response vs.

Post-Emergency Response

The HAZWOPER standard identifies two basic

phases of a response action: emergency response and post-emergency response. Depending on the size of the spill, these phases may be

managed differently. In addition, workers who

participate ONLY in post-emergency response

require different training than emergency

response workers receive.

Emergency response is “a response effort...to

an occurrence which results, or is likely to result,

in an uncontrolled release of a hazardous

substance” (29 CFR 1910.120(a)(3)). For marine

oil spills, an uncontrolled release is a situation in

which the oil and its associated airborne and

surface contamination hazards are releasing into

the environment or are in danger of releasing

into the environment and posing a worker

exposure hazard. Oil in grounded ships, which is

in danger of being released into the environment,

represents an emergency response situation. Onwater containment, skimming operations, and

underwater oil recovery operations also are

considered to be emergency response activities

because the oil is still in danger of being released into the environment. Shoreline cleanup

is normally considered to be a post-emergency

response unless the oil is below the high-tide

mark or storm surge boundary (active or forecasted) and can reasonably be expected to be

re-released into the marine environment.

Marine oil spill response is organized and

managed according to the regulations found in

40 CFR 300, the National Oil and Hazardous

Substance Pollution Contingency Plan (NCP).

These regulations describe procedures for

responding to hazardous substance releases and

oil discharges. Appendix E of the regulation

specifically addresses oil spill response. The

U.S. Coast Guard (USCG) and the Environmental

Protection Agency (EPA) jointly led the

development of the NCP.

Marine oil spill response involves a network of

government agencies, community organizations,

industry groups, and contractors. Federal and/or

state agencies usually monitor the responsible

party (generally the owner or operator of the

vessel, facility, port, or pipeline involved in the

spill). The Federal Government can direct cleanup operations if the responsible party does not

respond adequately, is not capable of taking

action, or is unknown.

An On-Scene Coordinator (OSC) acts as the

leader for response activities. In the coastal

areas of the United States, USCG serves as the

OSC for oil spill responses. In inland areas,

including rivers and other inland waters, EPA

generally takes the lead.

How Marine Oil Spill Responses Are Organized and Managed
Post-emergency response is performed “after

the immediate threat of a release has been

stabilized or eliminated and cleanup of the site

has begun” (29 CFR 1910.120(a)(3)). Oil spilled

into a marine environment is considered to be

stabilized when it is in a stable container with no

compromised structural integrity, to limit the

potential for worker exposure to associated

hazards. This includes floating bladders, barges,

drums, and roll-off containers on shore. Oil also

is considered to be stabilized when it is stranded

on shore and not reasonably expected to rerelease into the environment through wave or

storm effects. Floating oil is not considered to be

stabilized, even if contained within a boom.

During response to a large release such as a

marine oil spill, emergency response and postemergency response cleanup activities may

occur at the same time. In these cases, the

boundaries between the emergency response

area and the post-emergency response area

must be well defined and explained to

responders and cleanup workers.

Training Marine Oil Spill Response Workers Under HAZWOPER

3
4 Training Marine Oil Spill Response Workers Under HAZWOPER

HAZWOPER Requirements that

Apply to Marine Oil Spills

The NCP defines oil as any kind of oil in any

form, including petroleum, fuel oil, sludge, oil

refuse, and oil mixed with wastes but not

dredged spoil (dirt or rock).

Response actions conducted under the NCP

must comply with the provisions of HAZWOPER.

You’ll find this requirement in 40 CFR 300.150.

Therefore, if your workers are participating in a

response action under the NCP, you must have an

occupational safety and health program consistent with HAZWOPER and you must train your

workers according to HAZWOPER’s training

requirements. This applies whether the responsible party or a government agency is directing

the cleanup.

For marine oil spill emergency response, the

HAZWOPER provisions that most directly apply

include:

• Emergency response operations in

HAZWOPER paragraph (q), and

• Post-emergency response cleanup

operations in paragraph (q)(11).

See also emergency response training provisions in paragraph (q)(6), and post-emergency

response training requirements in paragraph

(q)(11).

The NCP defines oil as

any kind of oil in any

form, including petroleum, fuel oil, sludge,

oil refuse, and oil

mixed with wastes but

not dredged spoil (dirt

or rock.)

A ship exploded and caught fire off the coast of New Jersey. About

127,000 gallons of oil were unaccounted for after the incident.

When HAZWOPER Does Not Apply

HAZWOPER does not apply to incidental releases

that are limited in quantity and pose no safety

and health threat to employees working in the

immediate vicinity of the spill. These oil spills

can be

absorbed

or controlled at

the time of

the

release by

employees

in the

immediate

vicinity.

The

difference

between

emergency

spills and incidental releases is described in the

definition of emergency response in HAZWOPER

paragraph (a)(3). An incidental release does not

have the potential to become an emergency

within a short time. If an incidental release

occurs, employers do not need to implement

HAZWOPER.

HAZWOPER Coverage for

Volunteers

Volunteers frequently participate in marine oil

spill response, but Federal OSHA standards do

not cover uncompensated workers. In states

approved to manage their own occupational

health and safety program (called OSHA state

plan states), volunteers are often covered under

state plan HAZWOPER requirements. In states

administered by Federal OSHA, volunteers are

covered by the EPA HAZWOPER standard (40 CFR

311). EPA’s HAZWOPER standard has identical

requirements, but the coverage is different from

Federal OSHA standard coverage. The EPA

standard covers local and state government

employees, both compensated and volunteers.

Applying the HAZWOPER Standard to Marine Oil Spills
Training Marine Oil Spill Response Workers Under HAZWOPER 5

Fire ensues after oil is released during a lightering accident.

Additional Hazards

Marine oil spill responders need training to work

safely around these and other potential hazards.

You should decide which hazards apply to your

operations.

• Biological (e.g., plants, animals, insects,

remediation materials)

• Drowning

• Noise

• Electricity

• Slips and Trips

• Biohazardous debris

(e.g., syringes on shoreline)

• Ergonomic Stresses

 (e.g., repetitive strain, low back pain)

• Sunburn

• Confined Spaces

• Underwater Diving

• Falls

• Unguarded Equipment

• Cranes

• Fatigue

• Vehicles (e.g., aircraft, boats, cars, trucks)

• Cutting and Welding

• Fire and Explosion

• Degreasers

• Heat or Cold Stress

• Dispersants

• In-Situ Burning Particles

Other OSHA standards apply to marine oil spill

response and cleanup operations. See Appendix A,

Related OSHA Standards.

Marine oil spill responders face a variety of

health and safety hazards, including fire and

explosion, oxygen deficiency, exposure to carcinogens and other chemical hazards, heat and cold

stress, and safety hazards associated with

working around heavy equipment in a marine

environment. A full discussion of these hazards

is beyond the scope of this training booklet, but

a brief list of hazards and their known health

consequences is shown in Table 1. Your workers

should be trained to anticipate and control

exposure to the hazards associated with their

assigned duties.

To determine acceptable levels of exposure

and train your workers about them, consult

OSHA’s exposure limits in Subparts G and Z. If

OSHA does not regulate an exposure of concern,

consult the National Institute of Occupational

Safety and Health (NIOSH) Recommended

Exposure Limits (RELs) and Immediately Dangerous to Life and Health (IDLH) levels. If neither

OSHA nor NIOSH has established a limit, consult

the American Conference of Government Industrial Hygienists (ACGIH) Threshold Limit Values

(TLVs) and Biological Exposure Indices (BEIs) for

chemical, physical, and biological agents. You

may use a more protective limit than OSHA’s if

one has been established and plan your controls

accordingly. Material Safety Data Sheets from

the product manufacturer may provide useful

information for worker training.

Hazards to Marine Oil Spill Responders
6 Training Marine Oil Spill Response Workers Under HAZWOPER

Table 1. Hazardous Chemicals and Their Effects

Benzene (crude oils high in BTEX, benzene, toluene, ethylbenzene, and

xylene)

Benzo(a)pyrene (a polycyclic aromatic hydrocarbon reproductive

[see below], formed when oil or gasoline burns)

Carbon dioxide (inerting atmosphere, byproduct of combustion)

Carbon monoxide (byproduct of combustion) Irritation to eyes, skin, and

respiratory

Ethyl benzene (high in gasoline)

Hydrogen sulfide (oils high in sulfur, decaying plants and animals)

Methyl tert-butyl ether (MTBE) (octane booster and clean air additive for

gasoline, or pure MTBE)

Polycyclic aromatic hydrocarbons (PAHs) (occur in crude oil, and formed

during burning of oil)

Sulfuric acid (byproduct of combustion of sour petroleum product)

Toluene (high BTEX crude oils)

Xylenes (high BTEX crude oils)

Irritation to eyes, skin, and respiratory system; dizziness; rapid heart rate;

headaches; tremors; confusion; unconsciousness; anemia; cancer

Irritation to eyes and skin, cancer, possible effects

Dizziness, headaches, elevated blood pressure, rapid heart rate, loss of

consciousness asphyxiation, coma

Dizziness, confusion, headaches, nausea, weakness, loss of

consciousness, asphyxiation, coma

Irritation to eyes, skin, and respiratory system; loss of consciousness;

asphyxiation; nervous system effects

Irritation to eyes, skin, and respiratory system; dizziness; drowsiness;

cough; headaches; nervous system effects

Irritation to eyes, skin, and respiratory system; headaches; nausea;

dizziness; confusion; fatigue; weakness; nervous system, liver, and kidney

Irritation to eyes and skin, cancer, possible reproductive effects, immune

system effects

Irritation to eyes, skin, teeth, and upper respiratory system; severe tissue

burns; cancer

Irritation to eyes, skin, respiratory system; fatigue; confusion; dizziness;

headaches; memory loss; nausea; nervous system, liver, and kidney

effects

Irritation to eyes, skin, respiratory system; dizziness; confusion; change in

sense of balance; nervous system gastrointestinal system, liver, kidney,

and blood effects

Hazardous Chemicals Adverse Health Effects
Training Marine Oil Spill Response Workers Under HAZWOPER 7

Training Requirements

HAZWOPER training requirements that apply to

marine oil spill emergency response are located

in 29 CFR 1910.120(q)(6). Requirements and

training guidance for post-emergency response

are in HAZWOPER paragraph (q)(11) and in OSHA

Instruction CPL 2-2.51, Inspection Guidelines for

Post-Emergency Response Operations Under 29

CFR 1910.120. The HAZWOPER training requirements are based on your workers’ assigned

duties during an oil spill. For example, if you have

deck hands who are assigned to equipment

decontamination during and after an oil spill, you

need to provide the level of HAZWOPER training

required for the duties and hazards of the

decontamination tasks.

Figures 1 and 2 comprise a training decision

flowchart. Begin at the top of the chart (Figure 1)

if your workers participate in emergency response. Begin at Figure 2 (indicated by the

arrow) if your workers perform cleanup only after

the release is stabilized (post-emergency).

Emergency response workers may perform

cleanup activities without further HAZWOPER

training if you can certify that they have the skills

and knowledge to do so safely.

After you determine the type(s) of training your

workers need, turn to Table 2 or 3, as indicated

on Figure 1. These tables show each type or

category of training described in the flowchart.

Table 2 contains the emergency response

training requirements. For each type of emerA vessel carrying more than 7 million gallons of oil

breaks apart, spilling its entire cargo.

gency response training shown in the flowchart,

Table 2 lists the specific HAZWOPER training

requirements and examples of corresponding oil

spill job functions.

Table 3 shows post-emergency response

training. In the left-hand column, you’ll find the

hazard characteristics that distinguish each type

of training because this is how the HAZWOPER

standard itself separates cleanup training

categories. Verify that the hazards your workers

might face fit within the training category you’ve

chosen. Table 3 also lists the HAZWOPER

training requirements and examples of job

functions that might require that training.

Training Content

Because workers need to be trained before they

respond, you should train your emergency

response workers to the highest level of responsibility they might need to assume. You should

train your cleanup workers to the highest exposure conditions they may encounter. You must

never expect or allow your workers to perform an

emergency response or cleanup operation

without proper training and certification.

Table 4 lists training topics and competencies

for categories of training described in Tables 2

and 3. The listed topics paraphrase the

HAZWOPER required competencies listed in

paragraphs (q) and (e) of the standard. As an

example, if your workers perform defensive

actions for all emergency response operations,

they need 8 hours of training in areas 31-36 and

competency in areas 25-30 on Table 4. This is

equivalent to HAZWOPER requirements for the

first-responder operations level in (q)(6)(ii) of the

standard.
8 Training Marine Oil Spill Response Workers Under HAZWOPER

Certifying and Updating Training

Workers who receive HAZWOPER training must

receive a written certificate when they successfully complete the training. This is a requirement

of paragraphs (e)(6) and (q)(6). Figure 2, Sample

Certifications, illustrates

examples of training

certification cards given to

workers completing various

levels of HAZWOPER

training. You do not need to

repeat the initial training if

the worker goes to work at

a new site. The worker

must have additional

training or site briefings,

however, that are needed to

work safely at the new spill incident or cleanup

site. Every year, your emergency responders and

cleanup workers must receive refresher training

to maintain and demonstrate competency.

Note that Tables 2, 3, and 4 clarify HAZWOPER

training requirements. You cannot use these

tables as a substitute for the language of the

regulation. Also, training required by other OSHA

standards that may also apply to your employees

is not discussed in this booket.

For information about the

acceptability of various

technology-based training

formats, see OSHA letters

of interpretation on OSHA’s

website at:

http://www.osha.gov.
Training Marine Oil Spill Response Workers Under HAZWOPER 9

Yes

No No futher

training required

Will the worker

participate in post-emergency

response cleanup?

START HERE

If your workers perform

EMERGENCY

RESPONSE

What action will the 

worker be assigned in the

emergency response?

Incident Commander

On-Scene Coordinators

Supervisors

Incident Commander

1910.120(q)(6)(v)

24 hours

+

Demonstrated

Competencies

+

Annual Refresher

Table 2:

Incident Commander

First-Responder

Operations Level

1910.120(q)(6)(ii)

8 hours

+

Demonstrated

Competencies

+

Annual Refresher

Table 2:

Defensive Response

First-Responder

Awareness Level

1910.120(q)(6)(i)

Hours Sufficient to 

Demonstrated

Competencies

+

Annual Refresher

Table 2:

Initiate Response

Skilled Support

Personnel

1910.120(q)(4)

Spill Site

Briefing Only

 

Table 2:

Skilled Support

Hazardous Materials

Technician or 

Specialist

1910.120(q)(6)(iii) or (v)

24 hours

+

Demonstrated

Competencies

+

Annual Refresher

Table 2:

Active Response

Initiate

Response

Only:

Notifying

Authorities

Active Response:

Taking action at

the source

Stopping the release

Defensive Response:

Containing at a distance

people, property, and 

environment at a

 safe distance

Skilled Support:

Usually not a response

team employee

Immediate, short-term,

intervention only.

Specialist

Employee:

Providing technical

assistance to

individual in charge

Specialist

Employee

1910.120(q)(5)

Demonstrate

Competencies in

Specialization

Annually 

Table 2:

Specialist Employee

Figure 1. Training Decisions Flowchart for Emergency Response Workers
10 Training Marine Oil Spill Response Workers Under HAZWOPER

START HERE

If your workers perform ONLY

Post-Emergency

Response Cleanup

No

Yes

Is the worker’s

work experience and/or training

equivalent to the appropriate

training below?*

Will the worker face ANY 

 of the following:

Exposures above Permissible/Published Limits?

Repirators Needed?

Potential for Emergency

to Develop?

Yes

Yes Yes

Yes

No

No No

No

Manager?

Will the worker be exposed to oil

or other hazardous substances?

Spill site briefing. Training

under other OSHA standards

may be required

(see Appendix A)

General Spill Site Worker

1910.120(e)(3)(i)

Table 3:

Moderate-High Exposure

No futher training required; employer must

document equivalency per 1910.120 (e)(9)

Site-specific traing is required

Manager?

• 40 hours initial

• 24 hours field

• 8 hours annual refresher

• 40 hours initial

• 24 hours field

• 8 hours manager

• 8 hours annual refresher

Workers Unlikely to Be

Exposed Above Limits**

1910.120(e)(3)(ii), (e)(3)(iii)

Table 3:

Low Exposure

• 24 hours initial**

• 8 hours field

• 8 hours annual refresher

Managers/Supervisors of

Workers Unlikely to Be

Exposed Above Limits

1910.120(e)(4)

Table 3:

Low Exposure

• 24 hours initial

• 8 hours field

• 8 hours manager

• 8 hours annual refresher

Managers/Supervisors

1910.120(e)(4)

Table 3:

Moderate-High Exposure 

*Typically, First Responder Awareness Level training (1910.120 (q)(6)(i) will NOT prepare a worker for cleanup operations because it addresses emergency notification procedures only. Workers who could have 

 direct contact with or potential exposure to hazardous substances often need additional training.

**If you need to train workers for a specific spill and for tasks that involve minimal exposure (e.g., beach cleanup workers) you may be able to use the reduced traing provision OSHA describe in its compliance 

 directive, CPL2-2.51. This directive applies in limited circumstances. See the directive and Table 1B. 

Figure 2. Training Decisions Flowchart for Post-Emergency Response Cleanup Workers
Training Marine Oil Spill Response Workers Under HAZWOPER 11

- On-Scene Coordinators - Supervisors/Managers As shown on Figure 1

- On-Scene Coordinator Representatives - ICS Safety Officer 24 hours initial emergency response training covering

areas 25-36 AND competency in areas 1-6

- On-Scene Industry Representatives - ICS Group Supervisors

Annual refresher training or annual demonstration of

- ICS Operations Section Chief competency, ensuring competencies in areas 25-36 and 1-6

- ICS Site Safety Enforcement Personnel

- Work close to flammable/combustible liquids - Marine chemist activities As shown on Figure 1

 such as in a pumping operation

- Salvage response Technician Level [(q)(6)(iii)]:

- Work in confined or enclosed spaces • 24 hours initial emergency response training covering

 containing volatile oil - Booming operations at source areas 25-36 AND competency in areas 7-15

- Underwater free-floating oil removal - Vessel damage assessment • Annual refresher training or annual demonstration of

 competency, ensuring competencies in areas 25-36 and 7-15

- Soil/sand subsurface oil assessment - Accident investigation

- Plugging holes/emergency repairs to source - Firefighting response

OR

- Diving operations close to source

Specialist Level [(q)(6)(iv)]:

- Work adjacent to volatile fuel during initial spill hours (boat operations, etc.) • 24 hours initial emergency response training covering

 areas 7-15 and 25-36 AND competency in areas 16-24

- Site characterization of chemical exposures, air monitoring/sampling

• Annual refresher training or annual demonstration of

- Soil investigation/sampling competency, ensuring competencies in areas 7-36

- Dispersant application and monitoring operations

- In-situ burn and monitoring operations

- Application of herding agents/emulsion breakers

- Booming operations at a safe distance* - Staging area managers As shown on Figure 1

- Surface level shoreline impact assessment - Vacuum truck operations at a safe distance • 8 hours initial emergency response training

 covering areas 31-36 AND competency in areas 25-30

- Manual pickup and removal of irritant oil and - Security operations

 oily debris for oils that could be re-released • Annual refresher training or annual demonstration of

 into environment - Safety zone enforcement competency, ensuring competencies in areas 25-36

- Damming/diking at a safe distance - Skimmer/boat operations at a safe distance

- Loading of oil into receptacles at a safe distance

- Emergency medical personnel (if working in contaminated areas)

Job Function Examples Minimum Training & Experience

Incident Commander Active Response Defensive Response

Table 2. Training for Workers Who Perform Emergency Response

Job functions are examples only. Workers should be trained to the highest level of responsibility you would assign them. See Table 4 for descriptions of training topics and competency areas.
12 Training Marine Oil Spill Response Workers Under HAZWOPER

- Crew members who discover a release and alert the proper As shown on Figure 1

 emergency response personnel • Sufficient hours to demonstrate competency in

 areas 31-36

- Industry and government watchstanders

• Annual refresher training including demonstation

 of competency in areas 31-36

• Additional training required for post-emergency

 cleanup activities unless there is no exposure to

 hazardous substances. See Figure 1 for guidance.

- Immediate, short-term intervention - Aerial assessment As shown on Figure 1

 of a specialized nature that cannot be

 performed by other workers - Remote sensing aerial platforms • Spill site briefing in areas 55-59

- On-scene resource documentation - Photo-documentation

- Operation of certain equipment - Administrative/finance support

 such as mechanized digging equipment,

 cranes, and other hoisting equipment

- Dispersion modeling personnel As shown on Figure 1

- Meteorologist • Briefing covering areas 55-59

- Analytical chemical/oil specialist • Training or demonstrated competency in area of

 specialization annually

- Professional engineer/spill recovery system or shipbuilding specialist

Job Function Examples Minimum Training & Experience

Initiate Response Skilled Support Specialist Employer

Table 2. Training for Workers Who Perform Emergency Response (Cont).

NOTES:

1. Tables 2, 3, and 4 are intended to clarify HAZWOPER (29 CFR 1910.120 or 1926.65) training requirements for marine oil spill response. The tables do not relieve

employers from the requirements of HAZWOPER, nor do they specifically address training that may be required by other OSHA standards.

2. All employees should receive pre-entry site briefings covering, at a minimum, training areas 55-59 in Table 4.

3. Table 4 lists the training areas referenced throughout Tables 2 and 3. For example, an Incident Commander must receive 24 hours of initial training covering training

areas 25-36 in Table 4.

*Defensive personnel must be at a safe distance from the point of release, outside the hot zone or danger zone.
Training Marine Oil Spill Response Workers Under HAZWOPER 13

• Unknown oil or unknown hazardous - Manual cleanup of stranded oil with potential

 substance mixed with oil skin carcinogens (e.g., benzo (a) pyrene)

• Exposures equal or exceed exposure limits - Cleanup of stranded oil when toxic • 40 hours of initial training in areas 37-43

 or other published limits chemicals are persistent and above and 3 days supervised field experience,

 exposure limits or equivalent training certification

• Respiratory protection required

• At least 8 hours of annual refresher training

• Concentrations at or above 10 percent of the - Wildlife capture and treatment depending on

 Lower Explosive Limit (LEL) explosives • Supervisory/management personnel

 must also receive 8 hours of additional

• Oxygen levels ≥ 19.5 <22 percent) - Load and transfer piled oil-saturated initial training covering at a minimum

 decaying plants and animals that provide a areas 51-54

• Carcinogen: known or suspected hydrogen sulfide risk

• Situations in which oil is known but - Cleanup of stranded oil in confined spaces

 parameters above cannot be reasonabily

 assessed - On land marsh burning operations

Routine spill cleanup workers [(e)(3)(iii)]: - Pressure washing operations of stranded As shown in Figure 1

 weathered oil

• Oil and other hazards of spill constituents • 24 hours of initial training in areas 44-50

 known - Cutting of contaminated live vegetation and 1 day supervised field experience,

 or equivalent training

• Exposures may cause irritation (skin, eye, - Natural resource damage assissment

 respiratory) but are below permissible • At least 8 hours of annual refresher

 published limits - Bioremediation operations training

• Oxygen levels ≥ 19.5 <22 percent) - Shoreline cleanup assessment • Supervisory management personnel

 must also receive 8 hours of additional

• Concentrations less than 10 percent, but more - Vessel/equipment decontamination initial training covering at a minimum

 than the LEL areas 51-54

- Underwater stranded oil removal operations

• Other significant hazards may be present:

 Physical, safety, ergonomic, thermal. - Soil/sand substance oil removal

[(e)(3)(ii)]: - Containerized/packaged waste handling and

 disposal for transport operations

• Oil and other hazards of spill constituents

 known

• Exposures below permissible/published limits

Job Function Examples Minimum Training & Experience

Table 3. Training for Workers Who Perform Only Post-Emergency Response

Job functions are examples only. Workers should be trained to the highest level of responsibility you would assign them.

Job/Site Characterization

Low (Below Exposure Limits) Moderate-High (At/Above Exposure Limits)
14 Training Marine Oil Spill Response Workers Under HAZWOPER

• Oil and other spill constituents known - Workers who do not participate in marine As footnoted in Figure 1

 oil spill responses on a frequent recurring

• Exposures below permission/ basis and who will have minimal exposure • If conditions described in CPL 2-2.51

 published limits are met, reduced initial training

- Tarball shoreline cleanup or equivalent training certification

• Respirators not required covering items 44-50

- On scene cost documentation

• Oxygen levels ≥ 19.5 <22 percent) • Up-to-date training consistent with

- Operators of large construction vehicles 1910.38(a) and 1910.1200, and health

• No potential for chemical emergency, during stranded oil removal and safety training associated with assigned tasks

 explosion, or fire

Supervisory/management personnel

• Minimal irritants to respiratory system, must receive:

 eyes, or skin

• At least 24 hours of initial training in areas 44-50

• No significant physical, safety, and 1 day of supervised field experience;

 ergonomic, and thermal hazards

• 8 hours of additional initial training

 covering at a minimum areas 51-54; and

• 8 hours annual refresher training

• Area characterized and stable with: - Aerial photo documentation - Historians As shown in Figure 1

• No potential for exposure to hazardous - Command Post support - Press • Briefing covering areas 55-59

 waste or substances by any route

 (i.e., inhalation, skin absorption, ingestion - Food service personel

No safety hazards associated with hazardous - Legal representation

waste or hazardous substances

- Over-flight assessment (if no potential for exposure)

- Resource tracking (if no potential for exposure)

- Financial services personnel

Job Function Examples

Table 3. Training for Workers Who Perform Only Post-Emergency Response (Cont.)

Job/Site Characterization

NOTES:

 1. Tables 2, 3, and 4 are intended to clarify HAZWOPER (29 CFR 1910.120 or 1926.65) training requirements for marine oil spill response. The tables do not relieve employers from

the requirements of HAZWOPER, nor do they specifically address training that may be required by other OSHA standards.

 2. All employees should receive pre-entry site briefings covering, at a minimum, training areas 55-59 in Table 4.

 3. Equivalent training must be documented or certified by the employer. The documentation or certification must show that an employee’s work experience and/or training has

resulted in training equivalent to the training required in paragraphs (e)(1) through (e)(4) of 1910.120. Equivalently trained employees must receive appropriate, site-specific

training prior to site entry and have appropriate supervised experience at the new site. Equivalent training includes any academic training or the training that existing employees

might have received from prior spill site experience. Certification or documentation as equivalently trained does not apply to refresher training requirements.

 4. Table 4 lists the training areas referenced throughout Tables 2 and 3. For example, SupervisorylManagement personnel in low exposure level conditions must receive 8 hours of

additional initial training covering those training areas 51-54 in Table 4.

 5. The oxygen concentration range used in these tables, ≥ 19.5 < 22 percent, is consistent with 29 CFR 1915 Subpart B, Confined and Enclosed Spaces and Other Dangerous

Atmospheres in Shipyard Employment.

Minimum Training & Experience

No Exposure Non-Recurring/Minimal Exposure
15

Table 4. Training Topics and Competency Areas (from Tables 2 and 3)

ON-SCENE COORDINATOR

1) Know and be able to implement the employer’s incident

command system.

2) Know how to implement the employer’s emergency

response plan.

3) Know and understand the hazards and risks associated

with employees working in personal protective clothing.

4) Know how to implement the local emergency

response plan.

5) Know the state emergency response plan and

the Federal Regional Response Team.

6) Know and understand the importance of

decontamination procedures.

ACTIVE RESPONSE

7) Know how to implement the employer’s emergency

response plan.

8) Know how to use field survey instruments and

equipment to classify, identify, and verify known and

unknown materials.

9) Be able to function within an assigned role in the

Incident Command System.

10) Know how to select and use proper specialized

personal protective equipment provided to the

hazardous materials echnician.

11) Understand and be able to apply hazard and risk

assessment techniques.

12) Be able to perform advanced control, containment,

and/or confinement operations within the capabilities

of the resources and available personal protective

equipment.

13) Understand and implement decontamination

procedures.

14) Understand termination procedures.

15) Understand terminology and behavior of chemicals and

their toxic effects.

16) Know how to use advanced survey instruments and

equipment to classify, identify, and verify known and

unknown materials.

17) Understand in-depth hazard and risk techniques.

18) Be able to determine and implement decontamination

procedures.

19) Know how to implement the local emergency response

plan.

20) Know the state emergency response plan.

21) Be able to develop a site safety and control plan.

22) Understand chemical, radiological, and toxicological

terminology and behavior.

23) Be able to select and use proper specialized chemical

personal protective equipment provided to the

hazardous materials specialist.

24) Be able to perform specialized control, containment,

and/or confinement operations within the capabilities

of the resources and personal protective equipment

available.

DEFENSIVE RESPONSE

25) Know basic hazard and risk assessment techniques.

26) Know how to select and use proper personal protective

equipment necessary for the first responder operation

level.

27) Understand basic hazardous materials terms.

28) Know how to perform basic control, containment, and/

or confinement operations within the capabilities of the

resources and available personal protective equipment.

29) Know how to implement basic decontamination

procedures.

30) Understand the relevant standard operating and

termination procedures.

INITIATE RESPONSE ONLY

31) Understand the hazards of oil and the risks in a spill.

32) Understand what happens during an emergency

involving spilled oil.

33) Recognize the presence of oil or related hazardous

materials in an emergency.

34) Identify hazardous substances, if possible (e.g.,

appearance, smell, monitoring equipment).

35) Understand individual role in employer’s emergency

response plan.

36) Recognize when help is needed and when to request

assistance from the response team.

POST-EMERGENCY CLEANUP—EXPOSURES ABOVE

EXPOSURE LIMITS

37) Know the name(s) of and how to contact the site safety

and health personnel for spill cleanup.

38) Know the safety, health, and other hazards present

during oi spill cleanup.

39) Know safe cleanup work practices including decontamination procedures to minimize risks.

40) Know how to use available controls and equipment,

including contamination control procedures and

personal protective equipment, to minimize risks.

41) Know the contents of the safety and health plan for the

specific cleanup.

42) Know and be able to recognize signs and symptoms of

overexposure to hazards present.

43) Know the medical surveillance requirements.

POST-EMERGENCY CLEANUP—EXPOSURES BELOW

EXPOSURE LIMITS OR NON-RECURRING MINIMAL

EXPOSURE

44) Know the name(s) of and how to contact site safety and

health personnel for spill cleanup.

45) Know the safety, health, and other hazards present

during oil spill cleanup.

46) Know safe cleanup work practices including

decontamination procedures to minimize risks.

47) Know how to use available controls and equipment,

including contamination control and personal protective

equipment, to minimize risks from hazards present.

48) Know the contents of the safety and health plan

prepared for the specific cleanup.

49) Know and be able to recognize signs and symptoms of

overexposure to hazards present.

50) Know the medical surveillance requirements.

SUPERVISOR/MANAGER FOR CLEANUP OPERATIONS

51) Know and be able to implement effectively the

employer’s safety and health program.

52) Know and be able to implement effectively the

employer’s personal protective equipment plan.

53) Know and be able to implement effectively the

employer’s spill containment program.

54) Know and be able to implement effectively health

hazard monitoring procedure and techniques.

BRIEFING TOPICS

55) Purpose of visit or duties to be performed.

56) Site personnel, chain-of-command, and communications

procedures.

57) Chemical/physical hazards involved, signs and

symptoms o exposure.

58) Emergency alarm system, escape routes, and places of

refuge.

59) Appropriate contamination control procedures, personal

protective equipment, decontamination, and other

control measures provided.

Training Marine Oil Spill Response Workers Under HAZWOPER
16 Training Marine Oil Spill Response Workers Under HAZWOPER

Figure 3. Sample Certifications

 No. 00233

This is to certify that

Jane Smith

has satisfactorily completed

8-Hour HAZWOPER Marine Oil Spill

Supervisor Training

as described in 29 CFR 1910.120(e)(4)

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001

 No. 00234

This is to certify that

Joy Smith

satisfactorily completed

HAZWOPER Post-Emergency Response

Cleanup Training for Minimal Exposure Conditions

Only for (insert name of spill) Spill

consistent with OSHA CPL 2-2.51

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001

 No. 00232

This is to certify that

John Smith

has satisfactorily completed

40-Hour HAZWOPER Marine Oil Spill Training

as described in 29 CFR 1910.120(e)

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001

 No. 00235

This is to certify that

James Smith

has satisfactorily completed

24-Hour Marine Oil Spill Training

for Hazardous Materials Technicians

and demonstrated the necessary competencies

as described in 29 CFR 1910.120(q)(6)(iv)

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001

 No. 00236

This is to certify that

Julie Smith

has satisfactorily completed

8-Hour HAZWOPER Marine Refresher Training

for Hazardous Waste Site Workers

as described in 29 CFR 1910.120(e)(8)

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001

 No. 00237

This is to certify that

Joe Smith

has satisfactorily demonstrated competency

in lieu of annual refresher training for

Marine Oil Spill First Responder Operations Level

as described in 29 CFR 1910.120(q)(8)

 H.L. Teacher, Instructor Date

 SEA Training Institute

 Street, City, ST 00001
Training Marine Oil Spill Response Workers Under HAZWOPER 17

Oil Spill Scenario

This scenario is not intended to represent a

typical marine oil spill. It illustrates levels of

training needed for several job functions and

hazardous exposure levels. Information in

parentheses refers to the training levels in the

Figure 1 flowchart.

Incident

A tugboat is pushing a barge loaded with a sour

crude that contains sulfur, benzene, toluene, and

xylene to an anchorage for lightering (See Figure

4). The anchorage is within sight of the local

Coast Guard Marine Safety Office. Contractor

resources also are located in the port within view

of the anchorage. The tug pushing the barge

miscalculates the turning radius, causing the

barge to collide with the stern of a tank vessel.

The vessels lock together. As a result, two of the

barge’s port cargo tanks are breached, releasing

several thousand gallons of crude oil into the

water. Prevailing winds and currents carry the oil

away from the vessels. Some oil is trapped

between the barge and the tank vessel.

It is midday on a sunny summer day. The wind

is 5 knots. The water temperature is around 70

degrees Fahrenheit. Air temperature is around

84 degrees Fahrenheit.

Discovery

Members of the tug crew immediately notify the

Coast Guard of the incident (Figure 1: First

Responder Awareness Level).

The tug and tank vessel crews remain with

their vessels to ensure control of their ships.

Vapors from the fresh oil begin to irritate the

eyes of the captains and the crews. Both captains order crew members to remain upwind of

the oil and avoid the area between the vessels

where the oil is trapped.

Initial Emergency Response

The owner of the barge is located

across the country. According to the

company’s emergency response plan,

the owner calls an Oil Spill Removal

Organization (OSRO) to clean up the

spill. The tug captain is designated

by the owner to be the company’s

representative. Because the owner

is not on-scene and does not

participate in spill response

activities, he is not required to

have HAZWOPER training. The tug

captain is on-scene making

decisions in the response. Therefore, the tug captain must have

Incident Commander training for

emergency response (Figure 1:

Incident Commander).

Figure 4. Illustration of Incident
Training Marine Oil Spill Response Workers Under HAZWOPER

The Coast Guard radios the tug captain to

confirm the oil type, the same type listed on the

cargo manifest faxed by the owner. The owner

also faxes the cargo manifest to the OSRO. The

Coast Guard uses references and advice from

federal health professionals to estimate a safe

distance from the spill.

After consultation with references, mathematical computer models, and federal health and

safety professionals, the Coast Guard creates a

safety zone around the spill and uses its boats

to enforce it (Figure 1: First-Responder

Operations Level).

The safety zone is conservatively large to

maximize public safety. Support staff, news

media, and other workers who will have no

exposure to hazardous substances (Figure 1:

Workers unlikely to be exposed over limits) will

use the safety zone.

Initial Assessment

An hour after the initial oil release, two OSRO

boats approach the spill from downwind to

characterize the plume and determine the

release zone boundaries. Their crews will monitor

exposure levels using air-monitoring equipment

(Figure 1: Hazardous Materials Technician or

Specialist). Because exposure to hydrogen

sulfide and benzene is expected, these

responders must wear self-contained breathing

apparatus (SCBA) while confirming estimated

exposures. They may be able to switch to airpurifying respirators after the assessment.

They continue monitoring as the OSRO boats

approach the spill until reaching permissible

exposure limits. The boats work around the spill

area to identify the limits of the High Exposure

zone caused by vapors escaping the oil. Colorimetric tubes confirm air concentrations of 0.5

ppm of benzene and 4 ppm hydrogen sulfide at

200 feet (61 meters) downwind of the slick and

100 feet (30 meters) across the widest part of

the plume.

The responders complete site characterization

in areas where oil could be trapped between

vessels, beneath piers, and in dock corners and

other bounded spaces.

Outside the high exposure zone (the hot zone),

workers prepare deflection and exclusion booms

to divert the oil to a recovery site (Figure 1: FirstResponder Operations Level).

The response team sets up a command

center to coordinate response and cleanup

activities. This area supports the Incident

Commander, (Figure 1: Incident Commander),

supervisors of the clean-up crews (Figure 1:

Managers/Supervisors) with hourly requirements

dependent on exposure, and other personnel

(training depends on duties and exposures).

Mechanical Recovery

Four hours have passed. Air measurements of

hydrogen sulfide, benzene, toluene, and xylene,

taken with colorimetric tubes, register well below

permissible exposure limits near the leading

edge of the slick. An industrial hygienist and a

marine chemist conduct a more detailed site

characterization using advanced air-monitoring

equipment such as a portable infrared analyzer

and portable gas chromatograph (Figure 1a:

Hazardous Materials Technician/Specialist, or

Specialist Employee, depending on job duties).

They confirm that the air exposures from the oil

slick are below permissible limits. Air concentrations are above permissible limits, however, near

oil trapped between the vessels and oil

remaining in the damaged tanks.

18
Training Marine Oil Spill Response Workers Under HAZWOPER 19

 Oil recovery skimmers arrive to skim free-floating

oil. Containment boom and skimmer operators

work from a boat. These operators wear goggles

and protective clothing because the oil could

irritate their skin and eyes. Because air concentrations are below permissible limits, operators

are not required to wear respirators (Figure 1:

First-Responder Operations Level).

The ships’ support crews remain upwind of the

spill (Figure 1: Skilled Support Personnel or

Figure 1: Workers unlikely to be exposed over

limits).

Shoreline Cleanup

Six hours have passed. Oil reaches the shoreline. Skimmers near the shore remove oil that

was deflected into recovery areas (Figure 1: FirstResponder Operations Level, if these workers

also participate in emergency response; or

Figure 1: Workers unlikely to be exposed over

limits, if these workers perform cleanup only).

The oil continues to irritate skin and eyes, so

workers cleaning the shoreline wear chemical

protective clothing, gloves, booties, and goggles.

Because of the increased clothing requirements,

site safety officer assistants begin monitoring for

heat stress (Figure 1: Skilled Support Personnel

or Figure 2: Workers unlikely to be exposed over

limits, depending on the assistants’ job duties).

Responders form decontamination lines at

each shoreline cleanup area. Each worker

decontaminates before a break period and at the

end of the shift. Workers dispose of outer

booties, wash or remove oiled clothing, dispose

of outer gloves, wash goggles and remove inner

gloves. To minimize the spread of contamination,

workers conduct their own decontamination while

a worker stands by to assist. The decontamination assistants take responsibility for maintaining

and dismantling the decontamination line (Figure

2: Workers unlikely to be exposed over limits, if

these workers perform cleanup operations only).

Vessel

A skimming team recovers oil trapped between

the vessels. Vessel personnel in SCBAs measure

chemical and oxygen concentrations and the

percentage of the lower explosive limit (LEL) for

the space between the vessels (Figure 1:

Hazardous Materials Technician/Specialist, or

Specialist Employee, depending on job duties).

Results of the monitoring indicate that workers

conducting skimming operations must also be in

SCBA. The workers decide to wait until exposure

levels register below permissible limits before

removing the oil.

Tending an oil skimmer.

Cleanup worker in Level C personal

protective equipment.
20 Training Marine Oil Spill Response Workers Under HAZWOPER

Aboard the barge, a pumping team prepares to

pump oil from the damaged cargo tanks into the

tank vessel (Figure 1: Hazardous Materials

Technician or Specialist). Explosion is a risk

during pumping operations, so responders

measure the LEL percentage and oxygen concentration throughout the operation. Before starting

the pumping operations, workers in SCBAs put

vapor recovery systems in place. Once the vapor

recovery systems are in place, measured chemical concentration levels drop below permissible

exposure limits and workers begin pumping.

Final Stages

Two days later, no free-floating oil remains.

Pumping operations are completed. No hazardous chemicals are detected by air-monitoring

equipment. The oil is weathered and is no longer

an irritant; however, slip and trip hazards persist.

Shoreline cleanup operations continue.

No repair facility is located within a reasonably

safe distance for transport, so workers conduct

initial, temporary repairs for safe sailing. They

clean the damaged tanks inside and out before

patching and welding them. There is a risk of

explosion, oxygen deficiency, and overexposures

to chemicals (Figure 1: General Spill Site Worker,

if the workers perform cleanup only). Forced

ventilation makes the holds safe, and a competent person tests them before the cleaning

begins. A marine chemist tests and certifies the

areas Safe for Hot Work before cutting and/or

welding operations begin.

The company’s site safety and health plan does

not cover the disposal of waste containers.

Because of this oversight, oiled debris and waste

decay in the containers, releasing hydrogen

sulfide. A hazardous materials response team

removes the contaminated waste from the

containers (Figure 1: General

Spill Site Worker).

A week has passed. To speed

removal of remaining debris on

shore, training is offered to a

team of local volunteers

(Figure 2: Workers unlikely to

be exposed above limits, and

associated footnote). Trained

supervisors (Figure 2: Managers/Supervisors of workers

unlikely to be exposed above

limits, with training level

dependent on anticipated

exposures) oversee the

volunteers. As shoreline

cleanup progresses, shoreline clean-up assessment teams begin to verify that shorelines are

clean (Figure 2: Workers unlikely to be exposed

above limits).

Shoreline cleanup operations during New Carissa oil spill,

March 2000.
Training Marine Oil Spill Response Workers Under HAZWOPER 21

Safety and Health Program

Management Guidelines

Effective management of worker safety and

health protection is a decisive factor in reducing

the extent and severity of work-related injuries

and illnesses and their related costs. To assist

employers and employees in developing effective

safety and health programs, OSHA published

recommended Safety and Health Program

Management Guidelines (Federal Register 54(16):

3904-3916, January 26, 1989). These voluntary

guidelines apply to all places of employment

covered by OSHA.

The guidelines identify four general elements

that are critical to the development of a successful safety and health management program:

• Management leadership and employee

 involvement,

• Worksite analysis,

• Hazard prevention and control, and

• Safety and health training.

The guidelines recommend specific actions,

under each of these general elements, to

achieve an effective safety and health program.

The Federal Register notice containing the

guidelines is available online at www.osha.gov.

Other Sources of OSHA Assistance

State Programs

The Occupational Safety and Health Act of 1970

(OSH Act) encourages states to develop and

operate their own job safety and health plans.

OSHA approves and monitors these plans. There

are currently 26 state plan states; 23 of these

states administer plans covering both private

and public (state and local government) employment; the other 3 states—Connecticut, New

Jersey, and New York—cover the public sector

only.

The 25 states and territories with their own

OSHA-approved occupational safety and health

plans must adopt standards identical to, or at

least as effective as, the federal standards. Until

a state standard is promulgated, OSHA will

provide interim enforcement assistance, as

appropriate, in these states. A listing of states

with approved plans appears at the end of this

booklet.

Consultation Services

Consultation assistance is available on request

to employers who want help in establishing and

maintaining a safe and healthful workplace.

Largely funded by OSHA, the service is provided

at no cost to the employer. Primarily developed

for smaller employers with more hazardous

operations, the consultation service is delivered

by state governments employing professional

safety and health consultants. Comprehensive

assistance includes an appraisal of all mechanical systems, physical work practices, and

occupational safety and health hazards of the

workplace and all aspects of the employer’s

present job safety and health program. In

addition, the service offers assistance to employers in developing and implementing an effective

safety and health program. No penalties are

proposed or citations issued for hazards

identified by the consultant.

For more information concerning consultation

assistance, see the list of consultation projects

listed at the end of this publication, or visit

OSHA’s website at www.osha.gov.
22 Training Marine Oil Spill Response Workers Under HAZWOPER

Voluntary Protection Programs

(VPPs)

Voluntary Protection Programs and onsite consultation services, when coupled with an effective

enforcement program, expand worker protection

to help meet the goals of the OSH Act. The three

VPPs—Star, Merit, and Demonstration—are

designed to recognize outstanding achievements

by companies that have successfully incorporated comprehensive safety and health programs

into their total management system. The VPPs

motivate others to achieve excellent safety and

health results in the same outstanding way as

they establish a cooperative relationship between

employers, employees, and OSHA.

For additional information on VPPs and how to

apply, contact the OSHA regional offices listed at

the end of this publication.

Training and Education

OSHA’s area offices offer a variety of information

services, such as publications, audiovisual aids,

technical advice, and speakers for special

engagements. OSHA’s Training Institute in Des

Plaines, IL, provides basic and advanced courses

in safety and health for federal and state compliance officers, state consultants, federal agency

personnel, and private sector employers,

employees, and their representatives.

The OSHA Training Institute also has established

OSHA Training Institute Education Centers to

address the increased demand for its courses

from the private sector and from other federal

agencies. These centers are nonprofit colleges,

universities, and other organizations that have

been selected after a competition for participation in the program. They are located in various

parts of the U.S.

OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace

training and education in subjects where OSHA

believes there is a lack of workplace training.

Grants are awarded annually. Grant recipients are

expected to contribute 20 percent of the total

grant cost.

For more information on grants, training, and

education, contact the OSHA Training Institute,

Office of Training and Education, 1555 Times

Drive, Des Plaines, IL 60018, (847) 297-4810.

For further information on any OSHA program,

contact your nearest OSHA area or regional

office listed at the end of this publication.

Electronic Information

Internet—OSHA standards, interpretations,

directives, and additional information are now on

the World Wide Web at http://www.osha.gov.

CD-ROM—A wide variety of OSHA materials,

including standards, interpretations, directives,

and more, can be purchased on CD-ROM from

the U.S. Government Printing Office. To order,

write to the Superintendent of Documents, P.O.

Box 371954, Pittsburgh, PA 15250-7954 or

phone (202) 512-1800. Specify OSHA Regulations, Documents and Technical Information on

CD-ROM (ORDT), GPO Order No. S/N 729-013-

00000-5. The price is $46 per year ($57.50

foreign); $17 per single copy ($21.25 foreign).

Emergencies

For life-threatening situations, call (800)

321-OSHA. The teletypewriter (TTY) number is

(877) 889-5627. Complaints will go immediately

to the nearest OSHA area or state office for help.

For further information on any OSHA program,

contact your nearest OSHA area or regional

office listed at the end of this publication.
Training Marine Oil Spill Response Workers Under HAZWOPER 23

1910 Subpart D - Walking-Working Surfaces

1910 Subpart E - Means of Egress

1910 Subpart F - Powered Platforms, Manlifts,

and Vehicle-Mounted Work

Platforms

1910 Subpart G - Occupational Health and

Environmental Control

1910 Subpart H - Hazardous Materials

1910 Subpart I - Personal Protective

Equipment

1910 Subpart J - General Environmental

Controls

1910 Subpart K - Medical and First Aid

1910 Subpart L - Fire Protection

1910 Subpart M - Compressed Gas and

Compressed Air Equipment

1910 Subpart N - Materials Handling

1910 Subpart O - Machinery and Machine

Guarding

1910 Subpart P - Hand and Portable Powered

Tools and Other Hand-Held

Equipment

1910 Subpart Q - Welding, Cutting, and Brazing

1910 Subpart S - Electrical

1910 Subpart T - Commercial Diving

Operations

1910 Subpart Z - Toxic and Hazardous

Substances

Occupational Safety and Health

Standards for Shipyard

Employment

1915 Subpart B Confined and Enclosed Spaces

and Other Dangerous Atmospheres in Shipyard

Employment

1915 Subpart C - Surface Preparation and

Preservation

1915 Subpart D - Welding, Cutting, and Heating

1915 Subpart E - Scaffolds, Ladders, and

Other Working Surfaces

1915 Subpart F - General Working Conditions

1915 Subpart G - Gear and Equipment for

Rigging and Materials

Handling

1915 Subpart H - Tools and Related

Equipment

1915 Subpart I - Personal Protective

Equipment

1915 Subpart J - Ship’s Machinery and Piping

Systems

1915 Subpart L - Electrical Machinery

1915 Subpart Z - Toxic and Hazardous

Substances

Compliance Directives

Inspection Guidelines for Post-Emergency

Response Operations Under 29 CFR 1910.120 -

Directive Number: CPL 2-2.51

Inspection Procedures for the Hazardous Waste

Operations and Emergency Response Standard,

29 CFR 1910.120 and 1926.65, Paragraph (q):

Emergency Response to Hazardous Substance

Releases - Directive Number: CPL 2-2.59A

Appendix A: Related OSHA Standards and Directives

Occupational Safety and Health Standards

OSHA standards, interpretations, and directives are available online at http://www.osha.gov
24 Training Marine Oil Spill Response Workers Under HAZWOPER

Single copies of the following booklets can be

obtained from the nearest OSHA area or regional

office or the U.S. Department of Labor, OSHA/

OSHA Publications, P.O. Box 37535, Washington,

DC 20013-7535. Telephone (202) 693-1888 or

fax (202) 693-2498. Please send a self-addressed mailing label with your request.

Many copies are available online at http://

www.OSHA.gov.

Chemical Hazard Communication - OSHA 3084

Concepts & Techniques of Machine Safeguarding

 - OSHA 3067 (Available only online.)

Control of Hazardous Energy (Lockout/Tagout)

 - OSHA 3120

Controlling Electrical Hazards - OSHA 3075

Ergonomics: The Study of Work - OSHA 3125

Handbook for Small Businesses - OSHA 2209

Hazardous Waste Operations and Emergency

 Response - OSHA 3114

Hearing Conservation - OSHA 3074

How to Prepare for Workplace Emergencies

 - OSHA 308

Job Hazard Analysis - OSHA 3071

Respiratory Protection - OSHA 3079

Sling Safety - OSHA 3072

Stairways and Ladders - OSHA 3124

Appendix B: Related OSHA Publications
OSHA Regional Offices

REGION I

(CT,* ME, MA, NH, RI, VT*)

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860

REGION II

(NJ,* NY,* PR,* VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378

REGION III

(DE, DC, MD,* PA,* VA,* WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900

REGION IV

(AL, FL, GA, KY,* MS, NC,* SC,* TN*)

Atlanta Federal Center

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(404) 562-2300

REGION V

(IL, IN,* MI,* MN,* OH, WI)

230 South Dearborn Street, Room 3244

Chicago, IL 60604

(312) 353-2220

REGION VI

(AR, LA, NM,* OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(214) 767-4731 or 4736 x224

REGION VII

(IA,* KS, MO, NE)

City Center Square

1100 Main Street, Suite 800

Kansas City, MO 64105

(816) 426-5861

REGION VIII

(CO, MT, ND, SD, UT,* WY*)

1999 Broadway, Suite 1690

Denver, CO 80202-5716

(303) 844-1600

REGION IX

(American Samoa, AZ,* CA,* HI, NV*)

71 Stevenson Street, Room 420

San Francisco, CA 94105

(415) 975-4310

REGION X

(AK,* ID, OR,* WA*)

1111 Third Avenue, Suite 715

Seattle, WA 98101-3212

(206) 553-5930

*These states and territories operate their own OSHA-approved job safety and health programs (Connecticut, New Jersey, and New York plans cover public

employees only). States with approved programs must have a standard that is identical to, or at least as effective as, the federal standard.

Training Marine Oil Spill Response Workers Under HAZWOPER 25

Appendix C. OSHA Offices Directory
OSHA Area Offices

Area Telephone

Albany, NY ...................................................................... (518) 464-4338

Albuquerque, NM ............................................................ (505) 248-5302

Allentown, PA .................................................................. (610) 776-0592

Anchorage, AK ................................................................ (907) 271-5152

Appleton, WI ................................................................... (920) 734-4521

Austin, TX ....................................................................... (512) 916-5783

Avenel, NJ ...................................................................... (908) 750-3270

Bangor, ME ..................................................................... (207) 941-8179

Baton Rouge, LA ............................................................. (225) 389-0474

Bayside, NY .................................................................... (718) 279-9060

Bellevue, WA................................................................... (206) 553-7520

Billings, MT .................................................................... (406) 247-7494

Birmingham, AL .............................................................. (205) 731-1534

Bismarck, ND ................................................................. (701) 250-4521

Boise, ID ........................................................................ (208) 321-2960

Bowmansville, NY ........................................................... (716) 684-3891

Braintree, MA ................................................................. (617) 565-6924

Bridgeport, CT ................................................................ (203) 579-5516

Calumet City, IL............................................................... (708) 891-3800

Carson City, NV ............................................................... (702) 885-6963

Charleston, WV ............................................................... (304) 347-5937

Cincinnati, OH................................................................. (513) 841-4132

Cleveland, OH ................................................................. (216) 522-3818

Columbia, SC.................................................................. (803) 765-5904

Columbus, OH ................................................................ (614) 469-5582

Concord, NH ................................................................... (603) 225-1629

Corpus Christi, TX ........................................................... (512) 888-3420

Dallas, TX ....................................................................... (214) 320-2400

Denver, CO ..................................................................... (303) 844-5285

Des Plaines, IL ............................................................... (847) 803-4800

Des Moines, IA ............................................................... (515) 284-4794

Eau Claire, WI ................................................................. (715) 832-9019

El Paso, TX ..................................................................... (915) 534-6251

Englewood, CO................................................................ (303) 843-4500

Erie, PA .......................................................................... (814) 833-5758

Fairview Heights, IL ......................................................... (618) 632-8612

Fort Lauderdale, FL ......................................................... (954) 424-0242

Fort Worth, TX ................................................................. (817) 428-2470

Frankfort, KY .................................................................. (502) 227-7024

Guaynabo, PR ................................................................. (787) 277-1560

Harrisburg, PA................................................................. (717) 782-3902

Hartford, CT.................................................................... (860) 240-3152

Hasbrouck Heights, NJ .................................................... (201) 288-1700

Honolulu, HI ................................................................... (808) 541-2685

Houston, TX.................................................................... (281) 286-0583

Houston, TX.................................................................... (281) 591-2438

Indianapolis, IN............................................................... (317) 226-7290

Jackson, MS ................................................................... (601) 965-4606

Jacksonville, FL ............................................................... (904) 232-2895

Kansas City, MO ............................................................. (816) 483-9531

Linthicum, MD ................................................................ (410) 865-2055

Little Rock, AR ................................................................ (501) 324-6291

Lubbock, TX .................................................................... (806) 472-7681

Madison, WI ................................................................... (608) 441-5388

Marlton, NJ..................................................................... (609) 757-5181

Methuen, MA .................................................................. (617) 565-8110

Milwaukee, WI ................................................................ (414) 297-3315

Minneapolis, MN ............................................................. (612) 664-5460

Mobile, AL ..................................................................... (334) 441-6131

Nashville, TN .................................................................. (615) 781-5423

New York, NY .................................................................. (212) 466-2482

Norfolk, VA ..................................................................... (757) 441-3820

North Aurora, IL .............................................................. (630) 896-8700

Oklahoma City, OK .......................................................... (405) 231-5351

Omaha, NE ..................................................................... (402) 221-3182

Parsippany, NJ ................................................................ (201) 263-1003

Peoria, IL........................................................................ (309) 671-7033

Philadelphia, PA .............................................................. (215) 597-4955

Phoenix, AZ ................................................................... (602) 640-2007

Pittsburgh, PA ................................................................. (412) 644-4903

Training Marine Oil Spill Response Workers Under HAZWOPER

Area Telephone

26
Portland, ME ..................................................................(207) 780-3178

Portland, OR ..................................................................(503) 326-2251

Providence, RI ................................................................(401) 528-4663

Raleigh, NC ...................................................................(919) 856-4770

Sacramento, CA .............................................................(916) 566-7470

Salt Lake City, UT ...........................................................(801) 487-0680

San Diego, CA ...............................................................(619) 557-2909

Savannah, GA ................................................................(912) 652-4393

Smyrna, GA ...................................................................(770) 984-8700

Springfield, MA ..............................................................(413) 785-0123

St. Louis, MO ................................................................(314) 425-4249

Syracuse, NY .................................................................(315) 451-0808

Tampa, FL......................................................................(813) 626-1177

Tarrytown, NY.................................................................(914) 524-7510

Toledo, OH.....................................................................(419) 259-7542

Tucker, GA .....................................................................(770) 493-6644

Westbury, NY .................................................................(516) 334-3344

Wichita, KS....................................................................(316) 269-6644

Wilkes-Barre, PA .............................................................(717) 826-6538

Wilmington, DE ..............................................................(302) 573-6115

Area Telephone

Training Marine Oil Spill Response Workers Under HAZWOPER 27
States with Approved Plans

Commissioner

Alaska Department of Labor

1111 W. 8th Street, Room 306

P.O. Box 21149

Juneau, AK 99802-1149

(907) 465-2700

Director

Industrial Commission of Arizona

800 W. Washington

Phoenix, AZ 85007

(602) 542-5795

Director

California Department of Industrial Relations

455 Golden Gate Avenue - 10th floor

San Francisco, CA 94102

(415) 703-5050

Commissioner

Connecticut Department of Labor

200 Folly Brook Boulevard

Wethersfield, CT 06109

(860) 566-5123

Director

Hawaii Department of Labor and

 Industrial Relations

830 Punchbowl Street

Honolulu, HI 96831

(808) 586-8844

Commissioner

Indiana Department of Labor

State Office Building

402 West Washington Street - Room W195

Indianapolis, ID 46204

(317) 232-2378

Commissioner

Iowa Division of Labor

1000 E. Grand Avenue

Des Moines, IA 50319

(515) 281-3447

Commissioner

Indiana Department of Labor

State Office Building

402 West Washington Street

Room W195

Indianapolis, IN 46204

(317) 232-3325

Secretary

Kentucky Labor Cabinet

1047 U.S. Highway 127 South, Suite 4

Frankfort, KY 40601

(502) 564-3070

Commissioner

Maryland Division of Labor and Industry

Department of Labor Licensing and Regulation

1100 N. Eutaw Street, Room 613

Baltimore, MD 21201-2206

(410) 767-2215

Director

Michigan Department of Consumer

 and Industry Services

P.O. Box 30004 - 4th Floor, Law Building

Lansing, MI 48909

(517) 373-7230

Commissioner

Minnesota Department of Labor and Industry

443 Lafayette Road

St. Paul, MN 55155

(651) 296-2342

Commissioner

North Carolina Department of Labor

4 West Edenton Street

Raleigh, NC 27601-1092

(919) 807-2900

Commissioner

New Jersey Department of Labor

John Fitch Plaza - Labor Building

Market and Warren Streets

P.O. Box 110

Trenton, NJ 08625-0110

(609) 292-2975

28 Training Marine Oil Spill Response Workers Under HAZWOPER
Secretary

New Mexico Environment Department

1190 St. Francis Drive

P.O. Box 26110

Santa Fe, NM 87502

(505) 827-2850

Commissioner

New York Department of Labor

W. Averell Harriman State Office

Building-12, Room 500

Albany, NY 12240

(518) 457-2741

Administrator

Nevada Division of Industrial Relations

400 West King Street

Carson City, NV 89703

(775) 687-3032

Administrator

Oregon Department of Consumer and

 Business Services

Occupational Safety and Health Division

 (OR-OSHA)

350 Winter Street, N.E. Room 430

Salem, OR 97310-0220

(503) 378-3272

Secretary

Puerto Rico Department of Labor and

 Human Resources

Prudencio Rivera Martinez Building

505 Munoz Rivera Avenue

Hato Rey, PR 00918

(787) 754-2119

Director

South Carolina Department of Labor,

 Licensing and Regulation

Koger Office Park, Kingstree Building

110 Centerview Drive

P.O. Box 11329

Columbia, SC 29210

(803) 896-4300

Commissioner

Tennessee Department of Labor and

 Workforce Development

710 James Robertson Parkway

Nashville, TN 37243-0659

(615) 741-2582

Commissioner

Labor Commission of Utah

160 East 300 Street, 3rd floor

P.O. Box 146650

Salt Lake City, UT 84114-6650

(801) 530-6901

Commissioner

Virginia Department of Labor and Industry

Powers-Taylor Building

13 South 13th Street

Richmond, VA 23219

(804) 786-2377

Commissioner

Virgin Islands Department of Labor

2203 Church Street

Christiansted, St. Croix, VI 00820-4660

(340) 773-1990

Commissioner

Vermont Department of Labor

 and Industry

National Life Building—Drawer 20

120 State Street

Montpelier VT 05620-3401

(802) 828-2288

Director

Washington Department of Labor

 and Industries

P.O. Box 44001

Olympia, WA 98504-4001

(360) 902-4200

(360) 902-5430

Administrator

Worker’s Safety and Compensation Division

(WSC)

Wyoming Department of Employment

Herschler Building, 2nd Floor East

122 West 25th Street

Cheyenne, WY 82002

(307) 777-7786

Training Marine Oil Spill Response Workers Under HAZWOPER 29
OSHA Consultation Projects

Alabama.................................................................... (205) 348-3033

Alaska ...................................................................... (907) 269-4957

Arkansas................................................................... (501) 682-4522

Arizona...................................................................... (602) 542-1695

California .................................................................. (916) 574-2555

Colorado ................................................................... (970) 491-6151

Connecticut ............................................................... (860) 566-4550

District of Columbia ................................................... (202) 541-3727

Delaware ................................................................... (302) 761-8219

Florida ...................................................................... (813) 974-9962

Georgia ..................................................................... (404) 894-2643

Guam........................................................................ 9-1-(671) 475-1101

Hawaii ....................................................................... (808) 586-9100

Idaho ........................................................................ (208) 426-3283

Illinois ....................................................................... (312) 814-2337

Indiana ..................................................................... (317) 232-2688

Iowa.......................................................................... (515) 281-7629

Kansas ..................................................................... (785) 296-7476

Kentucky ................................................................... (502) 564-6895

Louisiana .................................................................. (225) 342-9601

Maine ....................................................................... (207) 624-6460

Maryland ................................................................... (410) 880-4970

Massachusetts .......................................................... (617) 727-3982

Michigan ................................................................... (517) 322-1809

Minnesota ................................................................. (651) 297-2393

Mississippi ................................................................ (601) 987-3981

Missouri .................................................................... (573) 751-3403

Montana ................................................................... (406) 444-6418

Nebraska .................................................................. (402) 471-4717

Nevada ..................................................................... (702) 486-9140

New Hampshire ......................................................... (603) 271-2024

New Jersey ................................................................ (609) 292-3923

New Mexico ............................................................... (505) 827-4230

New York ................................................................... (518) 457-2238

North Carolina ........................................................... (919) 807-2905

North Dakota ............................................................. (701) 328-5188

Ohio.......................................................................... (614) 644-2631

Oklahoma.................................................................. (405) 528-1500

Oregon ...................................................................... (503) 378-3272

Pennsylvania ............................................................. (724) 357-2396

Puerto Rico ............................................................... (787) 754-2171

Rhode Island ............................................................. (401) 222-2438

South Carolina ........................................................... (803) 734-9614

South Dakota ............................................................ (605) 688-4101

Tennessee................................................................. (615) 741-7036

Texas ........................................................................ (512) 804-4640

Utah ......................................................................... (801) 530-6901

Vermont .................................................................... (802) 828-2765

Virginia ..................................................................... (804) 786-6359

Virgin Islands............................................................. (809) 772-1315

Washington ............................................................... (360) 902-5638

West Virginia ............................................................. (304) 558-7890

Wisconsin ................................................................. (608) 266-9383 (H)

................................................................................ (262) 523-3044 (S)

Wyoming ................................................................... (307) 777-7786

(H) - Health

(S) - Safety

30 Training Marine Oil Spill Response Workers Under HAZWOPER