Hazardous Materials Emergency Response Plan

University of Maryland, Baltimore

Date of Preparation - February 9, 1996

Revised March 30, 1998

The University of Maryland, Baltimore is committed to providing a safe workplace and to protecting the environment. To meet this commitment, UMB has developed a Hazardous Materials Emergency Response Plan. The plan outlines the various roles each UMB department is responsible for and provides instructions on what to do during a hazardous material incident. The plan also calls for the development of a Hazardous Material Response Team capable of mitigating a majority of the hazardous material incidents UMB may encounter.

Table of Contents

I. Purpose
II. Responsibilities
III. Capability
IV. Personnel Roles and Responsibilities
V. Procedures for Handling Emergency Responses
VI. Pre-Emergency Planning and Coordination with Outside Parties
VII. Training
VIII. Medical Surveillance and Consultation
Appendix A - Control Zones
Appendix B- Decontamination Procedures and Information
Appendix C - HAZMAT Incident Response Flow Chart
Appendix D - PPE and Emergency Equipment
Appendix E - Hazardous Material Responders
Appendix F - Medical Surveillance and Consultation

Emergency Response Plan

I.  Purpose: The purpose of this policy is to establish procedures for emergency response operations covered under 29 CFR 1910.120 (q).

II.  Responsibilities: The office of Environmental Health and Safety (EHS) will be responsible of the overall implementation and annual review/update of the Hazardous Materials Emergency Response Plan (HMERP).

III.  Capability: EHS will have the capability to respond and mitigate the release of chemical, biological, and radioactive materials that present a moderate health and/or safety threat to UMB and responding personnel, present a moderate potential for adverse environmental impact, are of limited size, and have low fire/explosion potential. The following emergencies will not be covered under this plan:

Under any of the above circumstances, UMB personnel will be evacuated from the hazardous area and the appropriate outside organizations will be called in to handle the event. UMB's Emergency Action Plan (EAP) will be the governing plan under these circumstances.

IV. Personnel Roles and Responsibilities:

A. Incident Commander: The Incident Commander is the official on the site who has the responsibility for controlling the operations at the site. Initially it is the senior UMB emergency responder to arrive on the incident scene. As more senior emergency response personnel arrive, the position will be passed up the line of authority established under section V(A) of this policy. The Incident Commander responding to an emergency will be in charge of the Incident Command System (ICS). All emergency responders and their communications will be coordinated and controlled through the Incident Commander. The Incident Commander will have met the training requirements outlined in 29 CFR 1910.120 (q)(6)(v). The Incident Commander will have the following responsibilities:

1. The Incident Commander will identify, to the extent possible, all hazardous substances or conditions present, address appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling procedures, and the use of any new technologies

2. Based on the hazardous substances and/or conditions present, the Incident Commander will implement appropriate emergency operations, and assure that the PPE worn is appropriate for the hazards to be encountered

3. The Incident Commander will limit the number of emergency response personnel at the emergency site to those who are actively performing emergency operations

4. The Incident Commander will designate a site safety officer (SSO), who is knowledgeable in the operations being implemented at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect to the safety of operations for the emergency at hand

5. The Incident Commander will be responsible for ensuring that back up personnel are standing by with equipment ready to provide assistance or rescue. The Incident Commander will also be responsible for ensuring that qualified basic life support personnel are standing by with medical equipment and transportation capability

6. After emergency operations have terminated, the Incident Commander will implement appropriate decontamination procedures

7. The Incident Commander will coordinate activities with outside parties that respond to an HMI

B. Site Safety Officer (SSO): When activities are judged by the SSO to be Immediately Dangerous to Life and Health (IDLH) and/or to involve an imminent danger condition, the SSO will have the authority to alter, suspend, or terminate those activities. The SSO will immediately inform the Incident Commander of any actions needed to be taken to correct these hazards at the emergency scene.

C. Hazardous Material Technician: Hazardous material technicians are individuals who respond to releases or potential releases of hazardous materials. Hazardous material technicians will have met the training requirements outlined in 29 CFR 1910.120 (q)(6)(iii). In addition to the operations that the first responder at the operation level may perform, the hazardous material technician may:

1. Use field surveying instruments and equipment to determine the type of material involved and/or its level of hazard

2. Perform advance control, containment, and/or confinement operations within the capabilities of the resources and PPE available at the HMI

3. Implement decontamination procedures

D. First Responder Operation Level: First responders at the operation level are individuals who respond to releases or potential releases of hazardous materials as part of the initial response to the site for the purpose of protecting nearby personnel. First responders at the operation level will have met the training requirements outlined in 29 CFR 1910.120 (q)(6)(I). In addition to the operations that the first responder at the awareness level may perform, the first responder at the operation level may:

1. In a defensive fashion without actually trying to stop the release, attempt to contain the release from a safe distance, keep it from spreading, and prevent exposures

2. Provide basic decontamination of equipment and personnel

E. First Responders Awareness Level: First responders at the awareness level are individuals who are likely to witness or discover a hazardous material release and who have been trained to initiate an emergency response plan. First responders at the awareness level will have met the training requirements outlined in 29 CFR 1910.120 (q)(6)(I). First responders at the awareness level may perform the following at an HMI:

1. Initiate the emergency response plan by contacting the University Police and Public Safety

2. Attempt to identify the hazardous material(s) involved from a safe distance or by questioning UMB employees that are aware of the material involved at the HMI

3. Assist in site security and/or evacuation

F. Skilled Support Personnel (SSP): Personnel, not necessarily UMB employees, who are skilled in the operation of equipment, such as mechanical earth moving or digging equipment or crane and hoisting equipment, and who are needed temporarily to perform immediate emergency support work that cannot be performed in a timely fashion by emergency response personnel or UMB employees, and who will be or may be exposed to the hazards at an emergency response scene, are not required to meet the training requirements of this policy. However, they will be given an initial briefing at the site prior to their participation in any emergency response. The initial briefing will include instruction in the wearing of appropriate PPE, what hazardous materials are involved, and what duties are to be performed. All other appropriate safety and health precautions provided to UMB employees will be used to assure the safety and health of these personnel.

G. Specialist Employees: UMB employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substances release incident, will receive training or demonstrate competency in the area of their specialization annually.

V. Procedures for Handling Emergency Responses:

A. Lines of Authority: The Incident Commander will have overall authority of the HMI. A list of personnel qualified to serve as Incident Commanders is contained in Appendix E. In the event that two or more responders are capable of fulfilling the Incident Commanders' role, they will select an Incident Commander among them. The Incident Commander will have the authority to delegate responsibility to emergency responders at the HMI. If the Incident Commander determines that the HMI is beyond the capabilities of UMB, they will transfer authority to the agency with proper jurisdiction over the incident.

B. Emergency Recognition and Prevention: All UMB emergency responders will be trained in emergency recognition and prevention appropriate to their operation level.

C. Safe Distances and Places of Refuge: Control zones will be established at the HMI site. Only emergency response personnel designated by the Incident Commander will be allowed in these areas. Appendix A contains information and guidance on the safe establishment of control zones.

D. Site Security and Control: Site security and control will be maintained during the entire HMI operation. The Incident Commander and/or the University Police will be responsible for maintaining site security and control, when appropriate.

E. Evacuation Routes and Procedures: In the event that UMB personnel need to be evacuated, the established fire evacuation routes will be utilized. The University Police and Public Safety will assist with the evacuation, when necessary.

F. Decontamination: Decontamination procedures will begin upon arrival at the HMI, will provide for an adequate number of decontamination personnel, and will continue until the Incident Commander determines that decontamination is no longer required. Procedures and information on decontamination methods are contained in Appendix B.

G. Emergency Medical Treatment and First Aid: All emergency response personnel will have current CPR and first aid certification. In the event that a medical condition develops, the Incident Commander or his designee will immediately call for emergency medical assistance.

H. Emergency Alerting and Response Procedures: When an HMI develops, University Police and Public Safety will be immediately contacted. The police department will then contact EHS and the senior EHS representative available will implement EHS's internal notification plan (Appendix C).

I. Critique of Response and Follow-up: The Director of EHS will be responsible for ensuring that each HMI is critiqued in a timely fashion. A written report of the critique will be developed and reviewed with all members of the emergency response team. Any deficiencies discovered will be incorporated into the next revision of the ERP.

J. PPE and Emergency Equipment: PPE will be selected and used which will protect employees from the hazards and potential hazards they are likely to encounter during hazardous material mitigation. All emergency response personnel will be trained on the use and proper care of the PPE they may be required to use at an HMI. All PPE and emergency response equipment will be stored at EHS. Appendix D will be consulted for procedures on the use, selection, and maintenance of PPE.

VI. Pre-Emergency Planning and Coordination with Outside Parties:

A. University Police and Public Safety: The director of EHS or his designee will meet at least annually with the University Police and Public Safety Department to review and provide information on the following:

B. Office of Facility Management: The director of EHS or his designee will meet at least annually with the Office of Facilities Management to review and provide information on the following:

C. Baltimore Fire Department: The director of EHS or his designee will meet at least annually with the Baltimore Fire Department to review and provide information on the following:

D. Outside Hazardous Material Contractors: The director of EHS or his designee will meet at least annually with any contractors that may be utilized at an HMI. The purpose of the meeting will be to review and provide information on the following:

VII. Training: UMB employees will be trained at the appropriate response level prior to participating in any HMI operations. UMB personnel who have been designated as emergency responders will receive annual refresher training of sufficient content and duration to maintain their competencies, or will demonstrate competency in those areas at least yearly. All training records will be kept at EHS.

VIII. Medical Surveillance and Consultation: Members of EHS's HAZMAT team will receive medical surveillance and consultation as outlined in Appendix F.

Appendix A

Control Zones

Control Zones for Hazardous Material Incident

The following procedures are to be used when establishing control zones at an HMI.

I. Cold Zone:

1. The cold zone is set up in an area where no contamination is present.

2. No site specific personal protective equipment is necessary in this area.

3. Frequent air monitoring is preformed in this area to assure that the contamination is not spreading or to redefine the boundaries of the zones as necessary.

4. This area will typically house field administration offices and clean equipment.

5. Emergency equipment is stored at the interface of this area and the warm zone.

II. Warm Zone:

1. The warm zone is set up in an area where no contamination is present.

2. The warm zone requires a moderate level of personal protection as established by safety officer.

3. The warm zone is located between the cold zone and hot zone.

4. The warm zone is where decontamination is set up which allows for a cleanup of equipment, worker decontamination and removal of personal protective equipment.

5. Contaminants must not be allowed to pass through the warm zone into the clean zone.

III. Hot Zone:

1. The hot zone is set up to enclose the area where the contamination is present.

2. The hot zone requires the highest level of personal protection of all the zones as established by the Incident Commander.

3. Anyone going into this area will wear personal protective equipment.

4. All who leave the hot zone must do so through the warm zone where they will be decontaminated.

Appendix B

Decontamination Procedures and Information

DECONTAMINATION

I. General: Decontamination Procedures/Decontamination Site Set up should be initiated upon the determination by the Incident Commander that a Hazardous Material Incident (HMI) exists. The first step in decontamination is to establish standard operating procedures (SOP) that minimize contact with the hazardous material (HM) and associated waste materials. The Incident Commander must then implement decontamination procedures to include determining the decontamination method, designating a decontamination site, designating the decontamination team, and decommissioning of the decontamination site.

II. Decontamination Procedures:

A. Minimize Contamination: There are many ways to minimize contact with HM and associated waste materials. It can be accomplished through means such as:

1) Increase the distance between the responder and the HM by using remote sampling, container handling and opening techniques.

2) Implement shielding methods to protect monitoring and sampling equipment by bagging. Make openings in the bags for sample ports and sensors that must contact site materials.

3) Wear disposable outer garments and use disposable equipment where appropriate.

4) Limit the time that responders are exposed to the HM thereby limiting the exposure.

5) Isolate the area where the contamination exists and deny entry to unauthorized personnel.

6) Stress work practices that minimize contact with the HM.

B. Determine Decontamination Method: There are three widely used decontamination methods. These methods are dilution, chemical degradation, and absorption.

1) Dilution. This method is primarily accomplished with the use of water. Dilution often does not change the chemical composition of the product. The process is advantageous to use during decontamination generally because of the immediate availability of water at low cost. Unfortunately, the run off generated from this rinsing activity is in itself a hazardous material/waste and must be disposed in accordance with the appropriate local, state, and federal regulations. Caution should be used to assure that chemical composition of water does not create a negative reaction when mixed with the product.

2) Chemical degradation. The method results in a chemical composition change that should render the product less hazardous. The objective is accomplished by adding/mixing the product with additional chemicals (such as household bleach or drain cleaner) which will create a new product. Although clean up efforts are reduced, this advantage should not be the sole criteria used for selecting this method. Technical advice is a must prior to attempting chemical degradation. Extreme caution must be taken to avoid creating a more dangerous chemical reaction or by-product.

3) Absorption. This process is accomplished by utilizing absorbing materials that can be saturated with the spilled product. The immediate advantage is achieved by reducing the size of the spill area. It must be reemphasized that the spill/absorbed product continues to pose its hazards throughout the entire operation.

C. Decontamination Site Designation and Set up

1) Decontamination Site Placement. The site should be placed in an area large enough to accommodate all of the decontamination operations. Flat ground is preferred; however, if flat ground is not available the contamination run off must be contained and collected. The decontamination site should be located upwind adjacent to the "Hot Zone" and must have access to a water source.

2) Decontamination Site Set up The site should be set up specific to the situation and available resources. Figure 1 has a sample decontamination site. Considerations that must be considered are:

a. The decontamination stations should be physically separated to prevent cross contamination.

b. It is generally best to keep the site in a straight line. The most contamination should be closest to the "Hot Zone" and the least contamination closest to the "Cold Zone."

c. Designate single, clearly marked entry and exit points.

d. Keep the decontamination site physically separated from the entry point for the spill responders.

3) Decontamination Procedure Requirements

a. All employees leaving a contaminated area shall be appropriately deconned. All contaminated clothing shall be appropriately disposed of or decontaminated.

b. Decon Procedures will be monitored by the Site Safety Officer to determine effectiveness.

c. Equipment that are contaminated will be disposed of or deconned properly.

4) General Procedures to follow in a Decontamination Site.

a. Personnel enter the decontamination area and drop any tools used in the decontamination on the contaminated side.

b. Remove as much contamination as possible using the appropriate decontamination method. If dilution is used as the decontamination method, the area must be diked to contain the entire run off.

c. Remove SCBA and place on contaminated side.

d. Remove protective clothing and place on contaminated side.

e. Remove all personal clothing and isolate items on contaminated side. Bag all personal items.

f. Personnel shower with soap and sponges. Bag all cleaning items for disposal.

g. Personnel dry off. Bag towels for disposal. Put on clean clothes.

h. Personnel proceed to a medical evaluation/treatment site to receive medical attention as necessary.

D. The Incident Commander will designate the size and members of the decontamination team.

E. Once all personnel have been through the decontamination site, the Incident Commander will order that the site be decommissioned. All contaminated materials will be disposed of per Local, State, and Federal regulations.

Appendix C

HAZMAT Incident Response Flow Chart

Appendix D

PPE and Emergency Equipment

Selection of Personnel Protective Equipment

I. Selection of Chemical Protective Equipment: Chemical protective clothing (CPC) is found in a variety of materials, and offers a wide range of protection against chemicals. The most appropriate clothing material will depend on the chemicals present and the job to be done. The chosen material must resist permeation, degradation, and penetration. In addition to these factors, other factors must be considered during selection and include: durability, flexibility, temperature effects, ease of decontamination, compatibility with other equipment, and duration of use.

II. Work Mission Duration: Before the workers begin work in their PPE, the anticipated duration of the work mission should be established. Factors which limit the duration include:

A. Air supply consumption: The duration of air supply must be considered before planning any SCBA assisted work. The anticipated operating time of an SCBA is indicated on the breathing apparatus. This operating time is based on a moderate work rate. However, several factors can reduce the rate operating time including:

1. Work Rate: The duration may be reduced during strenuous work or any task requiring repetitive speed of motion.

2. Fitness: Well-conditioned workers have increased operating times compared to unfit individuals.

3. Body size: Larger individuals generally consume air at a higher rate thereby decreasing operating time.

4. Breathing: Quick, shallow or irregular breaths use air more rapidly than deep, regularly spaced breaths.

B. PPE permeation and penetration. The chance of chemical permeation or penetration during work is always of concern and may limit the work duration. Possible causes of penetration include:

1. Valve leakage, particularly under excessively hot or cold temperatures

2. Fastener leakage if suit is not properly maintained or if fasteners become brittle at cold temperatures

3. Exhalation valve leakage at excessively hot or cold temperatures

C. Ambient temperature. The ambient temperature will influence the duration as it affects both the worker and the protective integrity of the protective clothing. Hot and cold temperatures also influence the following:

1. Valve operation

2. Durability and flexibility of suit materials

3. Integrity of fasteners

4. Breakthrough time and permeation rate of chemicals

5. The concentration of airborne contaminants

III. Levels of Protection: Clothing will be selected by evaluating the performance characteristics of the clothing against the requirements and limitations of the site and task specific conditions. This evaluation will include the level of protection provided, when it should be used, limiting criteria, and equipment used.

A. Level - B: Protection when the highest level of respiratory protection is required, but at acceptable vapor exposure levels to skin. Level-B protection is the minimum level recommended on initial entries until the hazards have been further identified and defined by monitoring, sampling, and other reliable methods of analysis.

1. Should be used when:

a. When the highest level of respiratory protection is needed, but exposure to the small unprotected areas of the body (i.e. neck and taped areas of suit) is unlikely, or where concentrations are known to be within acceptable exposure standards

b. Oxygen deficient atmospheres (below 19.5%)

2. Limiting Criteria

a. Vapor(s), gases, or particulate present cannot be suspected of containing high concentrations of chemical that are harmful to skin or capable of being absorbed through the intact skin

b. The work being done will not generate high concentrations of vapors, gases, particulate, or splashes of material that will affect exposed skin

c. Chemical compatibility and permeability of the suit with certain chemicals

d. Most suits are not designed to handle high temperatures

3. Equipment:

a. Positive pressure self contained breathing apparatus (SCBA)

b. Hooded chemical-resistant suit (i.e. Tyvex)

c. Inner and outer chemical resistant gloves

d. Chemical resistant boots

e. Steel toe boots1

f. Coveralls1

g. Disposable boot covers1

h. Face shield1

I. Hard hat1

j. 2-way radio communications1

B. Level - C: Protection when the type(s) and concentration(s) of respirable material is known, has adequate warning properties, or is reasonably assumed to be not greater than the protection factors associated with air-purifying respirators; and exposure to the few unprotected areas of the body is unlikely to cause harm.

1. Should be used when:

a. When concentrations are within protection factors of air-purifying respirator and chemical(s) has adequate warning properties (i.e. it can be detected if filter break through occurs)

b. When exposure to the small unprotected areas of the body (i.e. neck and taped areas of suit) is unlikely, or where concentrations are known to be within acceptable exposure standards

c. Oxygen concentrations are at least 19.5%

2. Limiting Criteria:

a. Oxygen level at least 19.5%

b. Capability of respirator filters

c. Chemical(s) has adequate warning properties

d. Air purifying respirator cannot be used in an environment considered immediately dangerous to life and health (above IDLH threshold)

e. Vapor(s), gases, or particulate present cannot be suspected of containing high concentrations of chemical that are harmful to skin or capable of being absorbed through the intact skin

f. The work being done will not generate high concentrations of vapors, gases, particulate, or splashes of material that will affect exposed skin

g. Chemical compatibility and permeability of the suit with certain chemicals

h. Thermal conditions most suits are not designed to handle high temperatures

3. Equipment:

a. Full-faced air purifying respirator

b. Hooded chemical-resistant suit (i.e. Tyvex)

c. Inner and outer chemical resistant gloves

d. Chemical resistant boots

e. Steel toe boots1

f. Coveralls1

g. Disposable boot covers1

h. Face shield1

I. Hard hat1

j. 2-way radio communications1

C. Level - D: Protection when there are positively no toxic hazards present.

1. Should be used when:

a. Performing routine work with no toxic hazards present

2. Limiting Criteria:

a. Any toxins

3. Equipment:

a. Coveralls or lab coat

b. Steel toe boots1

c. Safety Glasses1

d. Disposable boot covers1

e. Face shield1

f. Hard hat1

g. Gloves1

h. Tyvex1

1 Optional

IV Maintenance and Inspection: Respirators should be cleaned after each use regardless of the duration. If not used, they will be cleaned monthly. Before leaving a site, gross contamination will be removed from the respirator. Respirator cleaning will involve disassembly of the respirator and washing with warm water and a mild detergent, never use a harsh solvent cleaner for deterioration of the rubber could result. Once clean, the respirator should be toughly rinsed and allowed to air dry.

A. Air Purifying Respirators

1. Mask and hood strap - Examine for contamination, damages or cracks, and deterioration

2. Inlet and exit valves - Check all valves for contamination, damage or creaks, and deterioration

3. Filters - Examine for contamination, damage or cracks, and deterioration

B. Self Contained Breathing Apparatus

1. Mask and hood strap - Examine for contamination, damages or cracks, and deterioration

2. Inlet and exit valves - Check all valves for contamination, damage or creaks, and deterioration

3. Stretch hose - Check for tightness of assembly and cracking

4. Examine harness for wear and function of hardware

5. Hydrostatic Test - SCBA cylinders are required to be hydrostatically tested at every 5 years for steel and aluminum cylinders and ever 3 years for composite cylinders. The month, year and unique identification symbol of the firm conducting the test is permanently marked on the outside of the cylinder

6. Test units

a. Check cylinder gage for full indication (2216 PSI or 300 PSI on Ultralite units; 4500 PSI on custom 4500 air mask). Replace or recharge the cylinder if pressure is less than that stamped on the cylinder

b. With mainline (yellow) closed, open cylinder valve to pressurize regulator and hose.

c. Open and close bypass valve to check operation and that air is released out of regulator outlet

d. Place hand over regulator outlet to block it leak tight

e. Open the mainline valve

f. Close cylinder valve. Compare regulator gage to cylinder gage. Plus or minus 100 PSI allowable

g. Watch regulator gage for drop in reading which would indicate leakage

h. Take hand from regulator outlet slightly and check regulator gage for indication of pressure at AudiLarm rings. Alarm should ring at about 1/4 full

Respirators should be stored in carrying cases or cartons that are sealed and kept in a cool dry place. Respirators should be packed or stored so that the face piece and exhalation valve will rest in a normal position and function will not be impaired by the elastomer setting in an abnormal position. Respirators will be stored to protect against dust, sunlight, heat, extreme cold, excessive moisture, or damaging chemicals. Plastic Ziplock bags are ideal to use for protection against contamination of cartridges and respirator.

Appendix E

Hazardous Material Responders

Appendix F

Medical Surveillance and Consultation

Medical Surveillance and Consultation

I. Scope. The following medical surveillance and consultation program covers only UMB HAZMAT team members.

II. Examination by a Physician and Costs. All medical examinations and procedures will be performed by a licensed physician at Student and Employee Health (SEH) and will be provided without cost to the employee.

III. Frequency of Medical Examinations and Consultations. Medical examinations and consultations will be made available as follows:

A. Prior to assignment

B. At least once every twelve months unless the attending physician believes a longer interval (not greater than biennially) is appropriate

C. At termination of employment or reassignment to an area where the employee would not be covered if the employee has not had an examination within the last six months

D. As soon as possible upon notification by an employee that the employee has developed signs or symptoms indicating possible over exposure to hazardous substances or health hazards, or that the employee has been injured or exposed above the permissible exposure limits or published exposure levels in an emergency situation

E. At more frequent/additional times, if the examining physician determines that an increased frequency of examination or follow-up examinations are medically necessary

IV. Content of medical examinations and consultations.

A. Medical examinations will include a medical and work history (or updated history if one is in the employee's file) with special emphasis on symptoms related to the handling of hazardous substances and health hazards, and to fitness for duty including the ability to wear any required PPE.

B. The content of medical examinations or consultations made available to employees will be determined by the attending physician. The guidelines in the Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (See Appendix D, reference # 10) should be consulted.

V. Information provided to the physician. EHS will provide a copy of this standard and its appendices to the SEH and in addition the following for each employee:

A. A description of the employee's duties as they relate to the employee's exposures,

B. The employee's exposure levels or anticipated exposure levels.

C. A description of any personal protective equipment used or to be used.

D. Information from previous medical examinations of the employee which is not readily available to the examining physician.

E. Information required by 1910.134.

VI. Physician's written opinion: EHS will obtain and provide each HAZMAT team member with a copy of the written opinion from the examining physician. This opinion will contain at a minimum the following:

A. The physician's opinion as to whether the employee has any detected medical conditions, which would place the employee at increased risk of material impairment of the employee's health from work in hazardous waste operations or emergency response, or from respirator use.

B. The physician's recommended limitations upon the employees assigned work.

C. The results of the medical examination and tests if requested by the employee.

D. A statement that the employee has been informed by the physician of the results of the medical examination and any medical conditions which require further examination or treatment.

The written opinion obtained by the employer will not reveal specific findings or diagnoses unrelated to occupational exposure.

VII. Record keeping: An accurate record of the medical surveillance will be kept on file at SEH. All records will be retained for the period specified and meet the criteria of 29 CFR 1910.20. Records will include at least the following information:

A. The name and social security number of the employee;

B. Physicians' written opinions, recommended limitations and results of examinations and tests;

C. Any employee medical complaints related to exposure to hazardous substances;

D. A copy of the information provided to the examining physician by the employer, with the exception of the standard and its appendices.