Introduction to the Health and Safety Plan Guidelines



INTRODUCTION

These guidelines have been developed by a working group consisting of
both field and headquarters personnel to provide new direction to the
EM-40 program in the preparation of site-specific Health and Safety
Plans (HASPs).  While based on the minimum requirements of 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER),
and DOE orders, these guidelines have been developed with the express
purpose of implementing a high quality safety and health program.  These
EM-40 HASP Guidelines are a "living document" to be modified and updated
as new regulations and other requirements are issued.  Guiding the
development of this document has been the principle that an effective
and high-quality HASP must provide:

     * A clear chain of command for safety and health activities,
     * Accountability for safety and health performance,
     * Well defined headquarters expectations regarding safety and health,
     * Well defined task and operational hazards/risks,
     * Comprehensive hazard prevention and control methods, and
     * Recordkeeping requirements to track program progress.

As this document was developed the working group applied the following
assumptions:

     * It is a generic document to be adapted on a site-by-site basis,
     * An adequate site characterization and comprehensive workplan
       exists at each field site,
     * Operations analysis and risk identification methods are adequate,
     * A written site safety and health program exists as required in
       29 CFR 1910.120 (b),
     * Written site Standard Operating Procedures exist, and
     * Site specific information is available.

Each chapter of these guidelines represents an element listed in 29 CFR
1910.120(b)(4)(ii) for a HASP.  The first chapter, Regulatory Framework,
provides direction on what should be included in a site-specific HASP.
29 CFR 1910.120(b)(4) has been issued as the minimum criteria, and
starting point.  In several instances this guidance goes beyond this
requirement. In addition to the requirements of 29 CFR 1910.120(b)(4)
the guidance is based on good industry practice, Environmental
Protection Agency recommendations, specific DOE need (radiation
protection), and DOE orders and directives.  Chapters 2 through 14
provide guidance on how to meet the requirements specified in Chapter 1.

Each chapter provides detailed information on a particular component of
a site-specific HASP. When utilizing this guidance to prepare
site-specific HASPs, the preparer of the HASP should be able to provide
appropriate documentation on how decisions were made relative to the
relevant sections of the guidance.  In some cases, the requirements of
different sections overlap.  The preparer of a site-specific HASP need
not repeat overlapping information but should indicate by reference
where the information is located.