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Pacific Southwest, Region 9

Serving: Arizona, California, Hawaii, Nevada, Pacific Islands, Tribal Nations

Solid Waste Management on Tribal Lands

Technical Advice for Cleanup of Accumulated Waste Sites on Tribal Lands

Tech Advice Contents
Cleanup Plan »Sample
Remediation Plan »Sample
Health & Safety Plan »Sample
Public Participation Plan »Sample
Record Keeping Plan »Sample
Site Cleanup
Sample Jurisdiction
Hantavirus Illness in the United States (20 pp, 166K, About PDF)
 Exiting EPA (disclaimer)

Health and Safety Plan

The objective of a Health and Safety Plan (HSP) is to assure that all work conducted in the process of waste site clean up and removal is done as safe as possible with full consideration and awareness of potential risks. The goal of this plan is to conduct a clean up and removal project in with no injury or impairment to human health.

Describe the health and safety concerns related to the clean up of the site. In developing a HSP a site/project specific hazard assessment must be conducted to identify and evaluate all potential risks. For example, falling rock hazards at sites located in canyons, potential heat stress or stroke, animal hazards such as snakes, and the various potential human health hazards presented by the wastes.

The HSP should include detailed information, as well as anticipated costs for each activity. Information should include, but not be limited to, potential hazards, including biological hazards, precautions to be taken, equipment, clothing, training of personnel, Health and Safety Officer duties, notices and signs, and activities to inform and protect the public. Maps showing the location and route to the nearest hospital should be on site at all times. A contingency plan that details procedures to be implemented in case of an emergency, such as an explosion, or release of hazardous materials, should be prepared and included in the first day briefing of workers

Health and Safety Plan

[Portions of this Health and Safety plan are derived from a Health and Safety Plan developed by the Bureau of Indian Affairs, Navajo Office.]

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Potential Hazards

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Physical - associated with working near construction equipment:
  • Crumbling high walls of canyons, washes and arroyos
  • Falling objects when on high walls Stressed cables and/or ropes
  • Vehicles
  • Cuts, bruises, and injuries from handling solid waste
  • Trips, falls and slides (personal and land)
  • Flying objects
  • Glare
  • Exploding aerosols, compressed gas cylinders, and cans
  • Heat injury
  • Fire/Combustible gas ignition
  • Dust
  • Hantavirus
  • Plague
  • Unknown viruses and bacteria
  • Venomous reptiles
  • Venomous and other insects
  • Poisonous or toxic plants.
  • Particulate matter from asbestos, burning waste, and plants such as poison oak or poison ivy.
  • Unknown vapors
  • Vehicle exhaust
  • Inclement weather


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General - All workers shall work in the "buddy system," maintaining visual contact with each other when on the job site. Workers shall not wear headphones or any other device that could impair hearing heavy equipment alarms or other warnings. Respiratory protection shall be worn if workers must enter any area in which there may be an excessive concentration of airborne contaminants. Workers actually handling or in the immediate vicinity of solid waste that is being moved shall wear at least a half mask respirator with twin NIOSH approved high efficiency cartridges. Workers required to wear respirators shall receive six hours training in the use and care of respirators. Workers subject to dust other than solid waste dust shall be required to wear quarter-face dust masks.

Personal Protective Equipment - All employees/workers on these projects shall be issued safety equipment and be required to wear the following: hard hat, eye protection (goggles with sun glasses or shatter-proof sun glasses), appropriate respiratory protection, long sleeve shirt, long pants, Tyvek overalls, steel-toed boots (over boots are required for those actually working in the site), and latex gloves under heavy leather work gloves. This equipment shall be worn whenever actively working on the job site. If any of the issued equipment becomes damaged, torn, etc., such that the effectiveness is questionable the worker will immediately be removed from the work area and have the damaged item replaced or repaired prior to reentering the job site. Fire extinguishers should also be readily available to personnel.

First Aid - The Contractor shall insure that there is a first aid kit in each vehicle on site complete with antiseptics and bandages. The Contractor/Site Supervisor and Health and Safety Officer shall also have a list of current, local emergency phone numbers, or other means of emergency communication, available in case an injury requires professional emergency medical services. Addresses and phone numbers of nearby hospitals, emergency rooms or trauma units should also be included.

Personal Hygiene - The Contractor shall insure that there is an emergency eye wash stand, portable toilet, and an adequate supply of potable water for drinking and washing prior to eating or leaving the work site. Tyvek overalls and any other outer personal protective clothing shall not be worn outside the job site or to an employee's home. Soiled Tyvek overalls will be collected daily in a paper or plastic bag and properly disposed of. The project Health and Safety Officer shall assure compliance with this mandate.

Inclement Weather - During the monsoon season violent afternoon thundershowers may occur and may be accompanied by lightning and/or flash flooding. These conditions are serious and may occur without warning. At the beginning of each workday the Health and Safety Officer or the Site Supervisor shall review the weather forecast, paying particular attention to conditions up stream from the work site. The Health and Safety Officer or the Site Supervisor may order a work stoppage if conditions warrant such action.

Electrical storms: If a crane is in use it shall be lowered and all work stopped. Workers shall assemble in enclosed, rubber tired vehicles until the storm passes or the decision is made to stop work for the day. Should a worker be caught away from a vehicle he/she should seek shelter in a low spot, such as ditches or concrete culverts, away from trees or large rocks.

Thunder storms/heavy rain: flash flooding may occur during heavy rains. Workers in arroyos or washes should immediately evacuate these areas. The Site Supervisor shall conduct a head count to ensure that all workers are safe and accounted for whenever inclement weather causes a work stoppage.

Specific Risks

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  • Whenever heavy equipment is in the area, workers should be alert to the possibilities of injury due to vehicles backing up or sliding. The dust generated by churning tracks or wheels can be irritating to the respiratory system and carry disease-causing organisms. The exhaust from diesel engines is also injurious due to the toxic components released during combustion.
  • The edges of canyons, washes, arroyos, and landfills can be unstable. Workers are advised to stay well back from such areas, unless secured by OSHA approved safety harness systems. If a worker is being lowered into a canyon or arroyo, the lowering system shall be of the involuntary type so that a worker is secured regardless of the state of consciousness.
  • When scaling the sides of a canyon or high wall objects may fall from above onto a worker. Therefore, hard hats shall be worn on slopes and no more that one person at a time shall be on the slope. Personnel above or below the climber shall watch for falling materials. If any objects begin to fall, these personnel shall shout a warning to the climber so they may take evasive action.
  • If cables and pulley systems are used to haul materials up the face of a slope, all workers shall stand well back from the tightening cable, preferably behind shelter. Any person who notices a frayed or otherwise unsafe cable shall immediately report it to the Site Supervisor and Health and Safety Officer.
  • A valid state driver's license or commercial operator's license is required for operators of all vehicles used at closure/clean up sites. No one shall ride in the bed of an ungated truck. All riders in a gated truck shall sit or lie down in the cargo bed and keep all parts of the body inside the truck bed.
  • The possibility of cuts or other open wounds exists when moving and collecting solid waste. Therefore, each worker must have had a Tetanus shot within the year prior to performing activities on this project. If a worker sustains an open wound he/she shall report immediately to the Site Supervisor for first aid. Such aid shall include cleansing the wound with soap and water, hydrogen peroxide and/or iodine or an iodine compound such as "Betadine"1. The wound shall be dressed with an air and dirt tight bandage. If the Site Supervisor or Health and Safety Officer believe the wound is serious enough, the worker shall be evacuated to a medical facility for further treatment.
    1 The use of brand names in this document does not constitute an endorsement by the USEPA. Brand names are used as examples of appropriate products.
  • Workers shall be made aware of the possibility of tripping and falling into piles of solid waste. Such falls have the potential to cause injury and damage personal protective equipment. Waste piles are unstable; therefore workers shall not climb onto piles of solid waste.
  • When solid waste is being consolidated or otherwise moved, the heavy equipment will often cause parts of the load to be in compression. The stress on the debris and the subsequent release of that stress may cause metal and wood objects to fly out of the waste piles. Therefore, no worker shall be closer than 25 feet from a pile of solid waste when it is being moved.
  • Exposure to bright sunlight and/or reflected light from polished surfaces and freshly scratched metal over long periods can cause deep eye damage and result in degeneration of vision. Workers shall wear sunglasses whenever the Health and Safety Officer or Site Supervisor believes that conditions warrant. A worker may choose to wear such glasses any time he/she feels the need.
  • Solid waste often contains defective or partially used aerosol cans. These aerosol cans may contain such things as spray paints, pesticides, oven cleaners, spot removers, and/or petrochemicals. When these cans are compacted in the landfill or crushed by vehicles, they can release residues of the contents. These contents can burn the skin and clothes, release toxic vapors, and severely damage eyesight. Often, aerosol and other cans contained in a trash pile become unstable and can explode when heated by the sun or disturbed by handling. Workers shall be cautioned about picking up individual cans by hand.
  • There exists a strong possibility for heat injury - heat distress, heat exhaustion and heat stroke - on projects being conducted during the summer months. Buddies shall observe each other for changes in the color of the skin and breathing rhythms. The Site Supervisor shall provide an air thermometer and take hourly temperature readings, which shall be recorded in the daily log by the Health and Safety Officer. Once the air temperature reaches 90ยบ F 10-minute rest periods will be provided each hour. The Site Supervisor shall provide adequate shade, adequate cool water, and electrolyte replacements drinks, for the workers. The signs of heat exhaustion are a deep reddening of the skin, panting, and profuse sweating. The individual shall be removed to a cool or shady area and allowed to rest. In cases of heat stroke, the skin becomes pale, breathing becomes shallow and rapid, sweating stops, and the skin becomes dry. The victim can rapidly lose consciousness. These conditions are life threatening and progress rapidly. If any of these signs occur the victim must be cooled down as rapidly as possible. Wet compresses, ice rubbed on the wrists, and fanning will help. If conscious, the victim shall be encouraged to drink lots of cool water or preferably an electrolyte replacement drink. Emergency medical assistance is mandatory.
  • Asbestos in the form of roofing tiles, insulation, and/or broken pipe may be present in waste piles. 40 CFR Part 61.50 sets forth reporting requirements and mandatory standards for disposal of asbestos containing wastes. If such wastes are found at any site a contractor licensed to properly dispose of asbestos must be used for such disposal. Any materials that are suspected of containing asbestos should be thoroughly soaked with water prior to being handled. Paper dust masks are not effective for asbestos particles. For questions concerning a potentially hazardous material and/or handling and disposition of potentially hazardous materials call the state or federal EPA.
  • Often there are fires, or the residues of fires, in the landfill trenches or scattered around surface dumps. Manipulating landfill debris can provide oxygen or fresh fuel to smoldering debris, which can cause fires to flare up. If a fire develops, the worker(s) shall notify the Health and Safety Officer. All workers shall be evacuated from the area of the fire until the Site Supervisor has investigated and determined the level of threat. Appropriate measures to extinguish the fire shall be used prior to resuming work.
  • There are very few reasons for a worker, other than an equipment operator, to enter any active trench or trench under construction. Workers on foot shall not be in a trench while heavy equipment is operating there. Only one worker at a time shall be in a trench where work is being conducted in the surrounding area.

Biological Hazards

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If there is no evidence of biological contamination (plague or Hantavirus) portions of this plan may be relaxed.

  • The dusts and vapors generated by disturbing mounds of solid waste can contain fungal spores, irritating products of decomposition, and disease bearing particulate. The foreman shall have a supply of dust masks available and ensure that workers wear them should conditions warrant or if a worker requests a mask. Masks shall be disposed of at the end of a work shift or more often if necessary. No worker shall wear another's mask. Paper masks provide no protection against bacteria, fungal spores, or viruses.
  • The threat of Hantavirus may exist at many work sites (for information on Hantavirus (PDF) (20 pp, 166K, About PDF)  Exiting EPA (disclaimer)). Rodents are attracted to solid waste and are known carriers of the Hantavirus. Rodent nests and dead rodents shall be avoided by workers. The Site Supervisor shall have available a two-gallon pump sprayer containing a 1% aqueous chlorine bleach solution to soak any rodent nests discovered before moving solid waste. Any dead animals found at the site area shall be sprayed with the same solution prior to handling and disposal. Mechanical equipment such as frontloaders and dozers shall be used for handling and burial. If mechanical equipment is not available, tongs or shovels shall be used for handling dead animals and nests. Under no circumstances shall workers handle dead animals with their hands, even if gloved. Any personal protective equipment, boots, gloves, etc; that has come into contact with dead rodents or rodent nests shall be disinfected with a 1% aqueous chlorine bleach solution. Under no circumstances shall workers be allowed to leave the site without undergoing decontamination procedures. To minimize exposure to biological hazards, rodent trapping may begin one week prior to commencing work and continue daily throughout the project.
    Note: Trapping shall be conducted by personnel trained and certified to conduct rodent trapping. Under no circumstances should untrained personnel attempt to conduct animal trapping.
  • Plague (Yersinia pestis infection) occurs naturally in some wild rodent populations throughout much of the western United States, although most (90%) human cases occur in only four states (Arizona, California, Colorado, and New Mexico). The disease is transmitted through the bites of infectious rodent fleas, direct contact with infected animals, or, very rarely, inhalation of respiratory secretions from humans or cats having respiratory plague. To protect against flea bites Tyvek overalls shall be worn with the legs tucked into work boots and/or taped. Any bites shall be reported and treated with antiseptic as soon as noticed. The risk of transmission of plague to humans in the United States is greatest when outbreaks of plague occur among susceptible wild rodent hosts, such as prairie dogs, cats, and some burrowing ground squirrels. As with Hantavirus, rodents and cats on the work site shall be avoided. Operations that bring workers in close proximity to flea-infested rodent nests or burrows, or result in the disturbance of these structures, are particularly likely to increase human plague risks. Workers are advised always to avoid contact with any sick or dead animals. It is recommended that the CDC publication Prevention of Plague and the Health and Safety Plan of this document be consulted for guidance in worker protection.
  • Other viruses and bacterial infections can be minimized through basic good hygiene. Workers shall wash their hands prior to eating, smoking, etc. The work uniform shall not be worn off the work site. A portable toilet will be available for use.
  • Poisonous snakes may be encountered during the movement of solid waste. Workers shall stay back from piles of trash being moved. Additionally, workers shall not place their hands under any boards, white goods, mattresses, etc., until the object has been moved at least once by mechanical equipment.
  • The same precautions for snakes apply to venomous insects; scorpions, wasps, hornets and biting flies. Most flying insects are attracted to sweet smelling after-shaves, deodorants, perfumes and soaps, as well as body heat. Workers shall be advised to avoid the use of such products during work on solid waste sites. Mosquito sprays and insect repellents shall be worn if the Site Supervisor deems it necessary for worker protection, or if a worker desires to do so.
  • Used truck and automobile tires provide an ideal habitat for rodents, snakes, and poisonous insects such as mosquitoes, spiders, and scorpions. In wet areas water-filled tires serve as a breeding ground for mosquitoes and constitute a continuing public health threat because of the potential contribution they can make to outbreaks of encephalitis and other mosquito transmitted diseases. Rodent nests in discarded tires also have the potential to spread plague and Hantavirus if they are moved without proper decontamination. It is essential that discarded tires be decontaminated prior to their removal from the site to eliminate the spread of disease vectors to other areas.
  • There can be poisonous plants, such as poison oak or ivy, in and around the work areas. Workers shall avoid these plants. Additionally, the smoke from burning these plants can be particularly toxic, producing acute respiratory distress. Under no circumstances shall burning of these plants be allowed at or near the work site. Workers who are subjected to smoke from burning poisonous plants shall be evacuated from the area and taken to medical facilities for treatment.

Health and Safety Officer

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All projects shall have at least one Health and Safety Officer. In situations where the Health and Safety Officer cannot observe the entire work area, such as the rim area and bottom of a canyon, wash or arroyo, two or more Health and Safety Officers shall be required. Following are the qualifications for and the duties of a Health and Safety Officer. Table I-2 provides the cost for Health and safety activities.

  • The Health and Safety Officer shall have completed the 40 hour HAZWOPER Health and Safety training and have current recertification.
  • On the morning of the first day of the project, the Health and Safety Officer shall conduct a briefing for all workers explaining each portion of the safety plan, including the contingency plan for emergencies. Adequate time shall be allocated to ensure that workers understand all aspects of the health and safety plan.
  • The Health and Safety Officer shall conduct a safety briefing each morning. The Health and Safety Officer shall use examples out of the Health and Safety Plan or observed unsafe practices as talking points.
  • The Health and Safety Officer shall maintain a daily safety log noting the date, weather conditions, hourly temperature, visitors, including duration of visit, number of workers on the job site, and any injuries.
  • Less serious injuries should be noted in the daily log. In conjunction with the Site Supervisor, the Health and Safety Officer shall investigate any injury. A written report shall be prepared for any injury necessitating a visit to a medical facility, requiring hospitalization, or resulting in death.
  • Each day the Health and Safety Officer shall ensure that the Site Supervisor has a supply of fresh potable water, electrolyte fluids, bandages, 1% aqueous chlorine bleach disinfectant spray, Tyvek plastic overalls, dust masks, gloves, etc., for distribution to the workers.
  • During weather emergencies and periods of potential heat injury, the Health and Safety Officer shall ensure that there is adequate shelter and that appropriate rest breaks are taken by the site workers.
  • The Health and Safety Officer shall periodically walk the site observing safety practices and issuing warnings, as appropriate.
  • The Health and Safety Officer shall report any flagrant violators of safety practices to the Site Supervisor. In cooperation with the Site Supervisor, the Health and Safety Officer shall evict flagrant violators.
  • The Health and Safety Officer shall serve as the local government's representative to unexpected visitors to the site. For their safety, visitors shall be escorted while on site and kept well away from the working areas.
  • The Health and Safety Officer shall refer the media to the appropriate regulatory agency Supervisor for information.

Protection of the Public

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  • Work at a solid waste site can be hazardous. The public shall not be allowed at site closure/clean up projects. The Site Supervisor shall establish tape barriers at the entrance to the work site and post signs indicating the limited access conditions. The public shall be asked to vacate the premises. The Health and Safety Officer shall insure that no one passes these tape barriers without the proper safety equipment and orientation. The Health and Safety Officer or Site Supervisor shall accompany legitimate visitors on the site. These include agents of the local, state, tribal, or federal governments performing official duties directly connected to the closure/clean up site.
  • News media personnel may want to tour the site and seek statements from the workers about the project. News media personnel are prohibited from entering the work site due to safety restrictions. They shall be instructed to contact the appropriate local, state, tribal, or federal government's regulatory agency Supervisor for information.
  • The Site Supervisor shall insure that yellow tape barriers are erected around any open trench at the end of the work day. "No Trespassing" signs shall be posted at the entrance to the work site at the end of each working day.
  • Each load of waste shall be disinfected with a 1% aqueous chlorine bleach solution as it is loaded into a transportation container.
  • All loads being transported shall be covered sufficiently to prevent loss of material during transport. If the nature of the waste may pose a threat to the public along the route to the designated MSWLF receiving it, appropriate warnings shall be issued to those likely to be affected. Containers with waste left at the site shall be covered overnight. Cover shall be sufficient to prevent animal invasion.
Table I-2 Health and Safety Costs
Personal protective equipment
Shovels, tongs, sprayers, etc.
Pulley & cable systems
First aid supplies
Portable toilets, rental
Fire fighting equipment, rental
Rodent eradication program
Tape barriers, signage

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