Oiled Sea Otter Capture Course

OSHA Regulations for Handling Hazardous Substances

Wildlife capture teams may operate in the immediate area of an oil spill and be exposed to fresh crude oil and other chemicals. (See Chapter 14 for a discussion of the properties and potential hazards of petroleum hydrocarbons.) The OSHA requirements for capture teams in the spill area are covered by the “Hazardous Waste Operations and Emergency Response-HAZWOPER” standard (29 CFR 1910.120). In addition to many other requirements, the standard regulates worker safety and health during postemergency response operations. The standard defines postemergency response as “that portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated, and clean-up of the site has begun.”

The hazards to employees during an oil spill vary widely in terms of the potential severity of injury or illness. For job duties and responsibilities with a low magnitude of risk, such as oiled wildlife capture, fewer than twenty four hours of training may be appropriate. Although the number of hours of training may vary, a minimum of four hours is adequate in most situations. The U.S. Coast Guard and other concerned parties have requested flexibility in the amount of employee training required for petroleum spill clean ups and other types of response operations following emergency situations. The OSHA Regional Response Team representative will determine the acceptable training requirements for various job duties on a case by case basis.

OSHA has not specifically defined the HAZWOPER training requirements for wildlife capture teams, but general requirements should include: 1) initial or refresher training on the hazardous nature of petroleum hydrocarbons and methods to reduce exposure, 2) use of protective clothing and equipment to prevent absorption through the skin, and inhalation or ingestion of petroleum hydrocarbons, 3) medical examinations before and after the capture operation, and 4) regular decontamination of capture equipment and clothing.