HAZWOPER Activities
Ensuring the Safety and Health of Oil Spill Cleanup Workers
An oil spill is the release of a liquid
petroleum hydrocarbon into the environment
due to human activity, and is a
form of pollution. The April 2010 Gulf of
Mexico oil spill involves crude oil released
from the explosion of an offshore,
deepwater drilling rig.
While BP PLC has struggled to stop
the estimated 5,000 barrel-a-day leak
more than a mile below the surface, activities
related to stopping an oil spill or
containing the spilled oil are considered “emergency response”
activities under OSHA’s Hazardous Waste Operations and
Emergency Response (HAZWOPER) standard, 29 CFR
1910.120 and 1926.65.
In addition, cleanup sites may be considered or may become
hazardous waste sites and should follow the requirements for
hazardous waste sites under HAZWOPER, requiring specific
training and control measures if certain criteria apply.
Shoreline cleanup is considered “post-emergency clean-up operations.”
Response actions conducted under the
National Contingency Plan must comply
with the provisions of HAZWOPER,
specifically the HAZWOPER provisions in
paragraph (q) (Emergency response operations)
and paragraph (q)(11) Post-emergency
response cleanup operations.
According to the National Institute of
Environmental Health Sciences’ (NIEHS)
Worker Education and Training Program
(WETP), personnel involved in these activities should be given:
• An initial briefing utilizing the Site Safety Plan or an
assignment form at the site prior to their participation;
• A briefing on emergency procedures under the site-specific
health and safety plan;
• Instruction in the wearing of appropriate personal protective
equipment;
• Information on what health hazards from oil and other
chemicals might be encountered;
• Explanation of what duties are to be performed;
• Chain of command;
• Instruction on the decontamination procedures to be
followed;
• All other appropriate safety and health precautions.
During an oil spill cleanup, workers may encounter many
types of crude oil, including fresh and weathered, which contain
carcinogenic volatile aromatic compounds like benzene, toluene
and naphthalene. The petroleum involved in the April 2010 oil
spill appears not to be the light, easily treated Louisiana sweet
crude, but a thicker, more viscous type that will be harder to remove
from coastline marshes, according to the NIEHS.
What is Crude Oil?
Crude oil is a mixture of hydrocarbons and consists of light,
medium and heavy chemicals. The hydrocarbons are mostly alkanes, cycloalkanes and various aromatic hydrocarbons,
while the other organic compounds contain nitrogen, oxygen
and sulfur, and trace amounts of metals such as iron, nickel,
copper and vanadium. The exact molecular composition varies
widely.
• The light parts, such as benzene, xylene, toluene and ethyl benzene
generally evaporate into the air in the first 24 hours of a
spill (usually before reaching the shore).
• The medium and heavy parts (consistency much like motor
oil) is what cleanup operations on the land and near shore
areas focus on.
What is in the Crude Oil from this Spill?
Shore clean up operations will be dealing with highly weathered
oil and other environmental conditions. The crude oil
changes over time as the volatile part evaporates and the oil
weathers and rots (degrades) and mixes with seawater, seaweed
and other vegetation and debris.
Weathered crude or “mousse” is crude petroleum that has lost
an appreciable quantity of its more volatile components and has
mixed with seawater and organic matter. This is caused by evaporation
and other natural causes during the spill landing on the
shore and during oily waste handling, storage and treatment or
disposal.
Weathering is a series of chemical and physical changes that
cause spilled oil to break down and become heavier than water.
Winds, waves, and currents may result in natural dispersion,
breaking a slick into droplets, which are then distributed
throughout the water. These droplets may also result in the
creation of a secondary slick or thin film on the surface of the
water.
Evaporation occurs when the lighter substances within the
oil mixture become vapors and leave the surface of the water.
This process leaves behind the heavier components of the oil,
which may undergo further weathering or may sink to the ocean
floor.
Oxidation occurs when oil contacts the water and oxygen
combines with the oil to produce water-soluble compounds. This
process affects oil slicks mostly around their edges.
HazComm Training
Specific Hazard Communication training is required on the
hazards from the oil and from any hazardous materials being
used or that workers may come in contact with.
Material Safety Data Sheets (MSDS) must be available for
all hazardous materials. Review them and follow as appropriate.
Warning labels, such as NFPA 704M may be found on chemical
containers being used, but do not handle unmarked, unlabeled
containers.
Workers should be sure to use the decontamination procedures
set by their employer before eating or drinking, and
using the toilet during the workday, and do a full decontamination,
including a shower if available, at the end of each
shift.
They must also wash and sanitize immediately if exposed to
toxic substances. Rubber type steel toe/shank footwear should be
worn to protect feet from injury and from oil exposure.
Also, wear oil-resistant gloves when in contact with oil
and oil waste and outer durable gloves when handling debris.
Do not stand in or come in contact with unknown liquids or
substances.
Weathering of oil occurs rapidly at first and slows down
over time as light and medium hydrocarbon chains are evaporated
or dissolved away by sunlight, waves, and winds. Inside
of storage containers and bags, oily waste will degrade over
time, especially in high temperatures and give off foul smelling
and possibly toxic gases and vapors. FSM
