Prepared: August 1992. Revised: July 1995

Workers at sewerage treatment plants (STP's) face a wide variety of potential health hazards. The New Jersey Public Employees Occupational Safety and Health (PEOSH) Act provides employee protection from many of these hazards. This information bulletin discusses some of the common health hazards and applicable standards designed to protect public employees at STP's.

These standards include:

• 29 CFR 1910.95 Occupational noise exposure,
• 29 CFR 1910.120 Hazardous waste operations and emergency response,
• 29 CFR 1910.132 Personal protective equipment,
• 29 CFR 1910.134 Respiratory protection,
• 29 CFR 1910.151 Medical services and first aid (eyewashes and drench showers), and
• 29 CFR 1910.1450 Occupational exposure to hazardous chemical in laboratories.

Precautions for avoiding infectious diseases during sewerage treatment work are also discussed. Workers should be aware that not all PEOSH standards are discussed and that other health hazards may exist at their worksite.

If other potential health hazards exist, they should be brought to the attention of the STP management, a joint labor/management health and safety committee, and/or the New Jersey Department of Health and Senior Services, PEOSH Program.

29 CFR 1910.95 - Occupational Noise Exposure

This standard requires that where employees are exposed to sound levels exceeding 90 decibels on the A-weighted scale (dBA), for an eight hour time-weighted average (TWA), (100 percent dose), feasible administrative or engineering controls shall be utilized to reduce that exposure. If such controls fail to reduce sound levels, personal protective equipment shall be provided and used. The standard further requires that if noise levels exceed 85 dBA for an eight hour TWA, (50 percent dose), an effective, continuing hearing conservation program that includes yearly audiometric examinations shall be instituted.

There are areas with high noise levels in STP's. Table 1 presents noise levels measured with a sound level meter in areas that are common to STP's. This Table is not inclusive of all areas in STP's that may have potentially hazardous noise levels but is a guide for pinpointing areas that may have potentially hazardous noise levels.

Noise Control Measures

Administrative controls include reducing employees exposures by job rotation and/or scheduling, thereby lowering the exposure to an individual employee by decreasing the amount of time that the employee is exposed. This method, however, is often not desirable because it increases the number of employees who are exposed to the health hazard. Engineering controls seek to contain the exposure by either isolating the source of the exposure or, conversely, isolating the employee from the source of the exposure.

Studies have indicated that excessive noise can also cause non-auditory problems such as fatigue, stress, emotional disturbances, vertigo, and vasoconstriction of the blood vessels in the extremities. The occupational noise standard does not protect all workers. Ten to fifteen of workers will develop noise induced hearing loss despite the 90 dBA standard.(1) Therefore, the PEOSH Program recommends that employers monitor the noise levels in various parts of the facility, particularly those buildings where hearing protection is not currently required, but in which future maintenance needs may necessitate extended employee presence. As plants age, more time is required for maintenance activities and employee exposure to excessive noise may be increased.

Three reasons to suspect high noise levels include:

• having to shout to be heard by nearby coworkers,
• having a ringing in your ears (tinnitus) after work,
• music or voices seem muted after work, but are clear in the morning.

If these conditions or symptoms are present, the work area should be monitored during the time that employees are in these areas.

If TWA levels greater than or equal to 85 dBA are measured, the employer must institute a hearing conservation program for exposed employees. If levels greater than the Permissible Noise Exposures presented in Table G-16 of 29 CFR 1910.95 are measured, feasible administrative or engineering controls must be utilized to decrease employee exposures. Table 2 presents the permissible noise exposures from Table G-16. If administrative or engineering controls do not reduce levels below those presented in Table 2, hearing protection must be provided to employees by the employer.

The employer should also ensure that employees are thoroughly trained in the proper fitting of hearing protection. Proper fitting is necessary in order to obtain the maximum protection that the equipment is capable of providing.

29 CFR 1910.120 - Hazardous Waste Operations and Emergency Response

This standard requires the development of an emergency response plan (ERP) designed to protect employees when they respond to emergencies involving hazardous materials (HazMat). Chlorine, sodium hypochlorite and other chemicals currently used at sewerage treatment plants are potentially hazardous materials and necessitate the development of an ERP. The major requirements are:

• development and implementation of a written Emergency Response Plan,
• adequate training for responding personnel based on the duties and functions to be performed,
• medical surveillance and consultation for responding personnel who are hazmat team members or hazardous materials specialists, and
• appropriate chemical resistant clothing and respiratory protection.

The following is a summary of the major provisions for each of these requirements.

Emergency Response Plan

An emergency response plan must be developed and implemented as outlined in paragraph (q)(2) of 29 CFR 1910.120.

Sewerage treatment plants may use applicable sections of their Toxic Catastrophe Prevention Act (TCPA) Risk Management Plan (RMP) as part of their 29 CFR 1910.120 (q)(2) ERP to avoid duplication. However, RMP's approved by the New Jersey Department of Environmental Protection (DEP) may or may not meet the minimum requirements of 29 CFR 1910.120. The TCPA emergency response plan cannot be considered a substitute for the ERP unless it contains detailed provisions for the protection of emergency response employees in each of the 11 required elements. Some chemicals, such as sodium hypochlodte (NaOCI), do not require TCPA registration. However, these chemicals are listed as hazardous chemicals and do require an ERP under 29 CFR 1910.120.

For guidance in developing these procedures listed below, obtain a copy of the "Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities" from the U.S. Department of Health and Human Services National Institute for Occupational Safety and Health (USDHHS NIOSH) (Publication No. 85-115). This document can be obtained from:

Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402

The PEOSH Program has developed an information bulletin on the requirements of 29 CFR 1910.120 and a model ERP that can be used by STP's. This bulletin and model ERP can be obtained from the New Jersey Department of Health and Senior Services' PEOSH Program by calling (609) 984-1863.

Training for Emergency Responders Training for emergency responders shall be based on the duties and functions of the employee. The required levels of training are:

• First Responder Awareness Level

  Employees who are likely to witness a release of a hazardous material and are only authorized to initiate appropriate action (such as notifying the proper authorities) are required to receive sufficient training or objectively demonstrate competency at this level. There is no minimum number of hours specified in the standard for this level of training.

• First Responder Operations Level

  Employees who respond by taking defensive measures only, such as diking, are required to receive sufficient training or objectively demonstrate competency at this level. These employees shall not handle or come into contact with the hazardous material at any time during the response. A minimum of eight hours of training is required for this level.

• Hazardous Materials Technician or Hazardous Materials Specialist Level

  Employees who respond to potential or actual releases of hazardous materials in an effort to terminate the release are required to receive a minimum of 24 hours of training.

• On Scene Incident Commander Level

  Employees who will assume control of an incident scene beyond the awareness level are required to receive a minimum of 24 hours of training that includes the operations level.

  The required training can be obtained through the use of private consultants or in-house training programs provided that all of the minimum elements are adequately covered in each level of training. Required training may also be arranged through the New Jersey State Police Office of Emergency Management, which administers free training programs for NJ public employee emergency responders involved in hazardous materials incidents. The Office of Emergency Management may be contacted at (609) 538-6067 for further information.

  All training levels require annual retraining or demonstrated competency.

Medical Surveillance

To evaluate the potential for impairment due to overexposure members of Hazardous Materials Teams responsible for handling leaking containers and other methods to terminate the release of a hazardous material must receive baseline physical examinations and yearly exams, unless the attending physician believes a longer interval (not greater than biannually) is appropriate. These examinations are to be provided at no cost to employees and at a reasonable time and place. Employees who exhibit signs orsymptoms which may have resulted from exposure to hazardous substances during the course of an emergency incident, either immediately or subsequently, shall be provided with medical consultation.

Chemical Protective Clothing

Employees shall be provided with chemical resistant clothing and proper respiratory protection. If there is a potential inhalation hazard, a positive pressure Self-Contained Breathing Apparatus (SCBA) shall be used until air monitoring determines that a decreased level of respiratory protection will not result in hazardous exposures.

29 CFR 1910.132 - Personal Protective Equipment

This standard requires that employees be provided with personal protective equipment (PPE) for protection from hazardous or harmful substances or conditions. This includes gloves, face shields, goggles, aprons or coveralls and other protective shields and barriers.

Areas where PPE may be needed include aeration and settling tanks where splashing may occur and lime and polymer rooms where dusty operations may cause employee exposures to chemicals.

29 CFR 1910.134 - Respiratory Protection

This standard requires that when employees are issued respirators, written standard operating procedures governing the selection and use of respirators must be provided by the employer.

The written program shall include provisions for employee training on the proper use of respirators, a program for proper storage. cleaning, disinfecting, and inspection of respirators, and evaluation of the effectiveness of the respiratory protection program. The program should also include a medical monitoring program to determine if employees are physically able to wear a respirator.

Areas in STP's where respiratory protection may be needed include chlorine rooms, confined spaces, and areas where employees may be exposed to hydrogen sulfide (H2S) or methane (CH4).

29 CFR 1910.151 - Medical Services and First Aid

One requirement of this standard is that an approved eyewash capable of providing at least fifteen minutes of continual flushing and/or an approved drench shower must be provided within 100 feet or ten seconds travel time in areas in which corrosive materials are used. The unit(s) should be located as close to the hazard as possible and on the same level. The maximum time required to reach the unit(s) should be determined by the potential effect of the chemical. For a strong acid or strong caustic,the unit(s) should be immediately adjacent to or within 10 feet of the hazard. It is recommended that the consulting physician be contacted for advice on the proper distance. The American National Standards Institute (ANSI) standard for emergency eyewash and shower equipment should be used as a guide for proper installation. This document is available from the American National Standards Institute, Inc., publication Z358.1-1990. ANSI, 11 West 42nd Street, 13th Floor, New York, NY 10018, (212) 642-4900.

Some areas in STP's that require approved eyewashes and/or drench showers include chlorine rooms, garages with parts cleaners, and areas where lime is added to the sludge. If the Material Safety Data Sheet (MSDS), supplied with each substance, or the New Jersey Hazardous Substance Fact Sheet states that 15 minutes of eye flushing is required for first aid in the event of eye contact an approved eyewash is necessary in the area where the substance is used.

Frequent inspections should be conducted to ensure that all eyewashes and drench showers are working, maintained in a clean condition, and are not blocked in a manner that will inhibit free access.

29 CFR 1910.1450 - Occupational Exposure to Hazardous Chemicals in Laboratories

This standard applies to laboratories in which chemicals are not produced, but are used as reagents in experiments and tests. Employee protection is provided for by standard operating procedures for training, test protocols, and the development and implementation of a written Chemical Hygiene Plan that delineates procedures for all laboratory operations.

The PEOSH Program has developed an information bulletin on the requirements of 29 CFR 1910.1450 and a model chemical hygiene plan(CHP) that can be used by STP's. These documents are available online: information bulletin and model CHP (Download: labstand.zip in WordPerfect 6.1 for Windows format or (PDF File size:27KB)) or by calling the New Jersey Department of Health and Senior Services, PEOSH Program at (609) 984-1863.

Infectious Diseases

Review of the literature indicates that infectious diseases are serious potential health hazards at sewerage treatment plants.

Some general recommendations for the prevention of disease include:

• Wear heavy-duty rubber gloves (especially if the hands are out or have open sores) and boots that are not water absorbent and are resistant to punctures.
• Wear protective clothing,including goggles, if there is any chance of wastewater spraying into the air.
• Change uniforms or other protective clothing that is visibly soiled or contaiminated as soon as possible.
• Work clothes should not be laundered at home. If work clothes are taken home for laundering they should be bagged at the worksite and the bag not opened until the clothes are placed in the washing machine. Work clothes should be separated from other household laundry and washed in the hot water cycle.
• Shower before changing into clean clothing and shoes to be worn home. Workplace bathrooms, showers, and locker facilities should be clean, well-maintained, adequately supplied with soap, towels or hand driers, and toilet paper.
• Wash hands frequently, with soap and water after coming in contact with wastewater, visiting restrooms and before eating or smoking.

  Hands should also be washed at the end of the work shift.

• Promptly treat all cuts and abrasions.

For further information on these or any health related subjects, please contact the PEOSH Program at (609) 984-1863.

(1) OCCUPATIONAL HEALTH - Recognizing and Preventing Work-Related Disease. Levy, Barry S. and Wegman, David H. editors, Little Brown and Company, Boston/Toronto, 1983, pp. 211 and 214-215.

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Last Updated: December 1, 1997