Appendix A - Management
strategies and paradigms
used in the report
Risky Business: Invasive species management on National
A review and summary of needed changes in current plans,
policies and programs
by George Wooten and Marlene Renwyck
The following management strategies and frameworks are
noted in the report on invasive species management and are outlined in
more detail in this appendix.
1. Prevention strategies
True Integrated Pest Management
The following list compiles specific prevention measures that relate
to invasive species which should be given consideration in public land
management. Not all of these measures may be practical to every situation,
however, when used together, they provide the foundation for a holistic
invasive species management program where prevention is the primary goal.
The following list has been compiled from a number of different sources,
including some of the recommendations from the annual Mediated Agreement
meeting held in Corvallis, Oregon on December 4-5, 2000.
Recommended prevention measures
2. True Integrated Pest Management
The scope of policies, plans and programs should be prevention and control
of "aggressive exotic species" or “invasive species”, not "noxious weeds."
The scope of policies, plans and programs should be determined by biological
and ecological criteria, e.g., what invasive species are impairing biological
diversity and ecological integrity?
The stated purpose and goals of policies, plans, and programs should be
to prevent further spread of invasive species, to prevent impacts from
existing infestations, and to restore the land's resistance to exotic species.
Policies, plans and programs should articulate a 100-year vision of how
the public and the Forest Service wants National Forest lands to be, in
terms of ecosystem health and invasive species, at a region-wide, landscape
level. This vision should detail what steps need to be taken to get there
in project-planning, and thus, should "back-cast" from the desired long-range
Policies, plans and programs should examine the nature and causes of invasive
species establishment and spread. Consideration should be given to all
soil disturbing activities, which would include logging, road construction
and reconstruction, regular and off-road motorized vehicle use, and livestock
grazing. Such “root causes” should be clearly identified in policies, plans
and programs with respect to their role in invasive species’ spread.
Policies, plans and programs should analyze the proportional contributions
of various human-caused or unnatural disturbances relative to natural weed
Policies, plans and programs should take currently degraded lands, their
existing conditions and the local abundance of invasive species’ seed pools
into account during the analysis and planning of activities, regardless
of whether they are 'weed treatment' projects.
Policies, plans and programs should focus equally on prevention, treatment,
The focus on prevention should result in a reduction in the root causes
of species invasions.
Policies, plans and programs should identify damage thresholds for restricting
and prohibiting particular activities at the site-specific level, which
contribute to the spread of invasive species.
Policies, plans and programs should direct National Forests to reduce their
reliance on herbicides through prevention, reliance on natural processes
and pre-project planning (e.g., not thinning beyond certain thresholds
of canopy cover). Herbicides should be used only as a last resort and only
in the context of prevention and restoration such that a treadmill of chemical
treatments and re-treatments will not occur.
Restoration of degraded public lands should include passive restoration
wherever possible in an effort to minimize soil disturbance.
Policies, plans and programs should analyze current conditions and make
project decisions using baseline data, including maps of known infestations,
maps of treatment areas, monitoring results of treatment, monitoring of
other project activities, etc. Policies, plans and programs should include
the following data for all National Forest lands:
Describe and map remaining intact, uninvaded native plant communities,
partially invaded areas, and areas that have lost their native plant components.
Analyze roadless, wilderness, and livestock-free areas for the presence
of invasive species. Use analysis methods that can result in comparisons
with areas that are actively managed.
NEPA documents pertaining to new policies, plans and programs should have
an alternative that focuses on prevention and restoration and involves
restricting and prohibiting activities that are known to be causing weed
invasions or are not being monitored.
Off-road vehicle (ORV) trails should be closed unless posted open.
Motorized travel should be limited to designated travel routes
Cross-country motorized travel should not be allowed.
If no monitoring or insufficient monitoring of invasive species infestations
is occurring on ORV travel routes, then use should be curtailed.
If enforcement of ORV travel is not occurring to insure that users are
remaining on designated routes, then use should be curtailed.
ORV use should not be allowed in Wilderness areas, wilderness study areas,
or roadless areas.
There should be no distinction made between cars, trucks and ORVs, because
there is essentially no difference in their on-the-ground impacts with
respect to invasive species spread.
Ground disturbance should be limited in areas where there are invasive
There should be no logging on sites with extensive invasive species’ infestations.
There should be no logging on steep slopes or erosive sites.
There should be no new construction of roads
Minimum canopy closure requirements should be established for logging and
Downed woody debris requirements should be established for logging and
There should be consideration of the value in retiring livestock allotments
as they become vacated to prevent the spread of invasive species.
Livestock grazing should be restricted in areas infested with weeds, and
prohibited in areas where prevention, control and restoration efforts have
Livestock grazing should be prohibited in sensitive areas and rare species'
habitat, such as, but not limited to, riparian areas, wetlands, TES habitat,
Monitor livestock grazing using an increaser/decreaser species procedure
(including microbiotic crusts, wildlife, and endemic/sensitive plant species)
to track biodiversity and health.
Livestock grazing should be excluded from burned (natural or prescribed)
areas for at least five years.
Establish site-specific monitoring to detect biological degradation on
grazing allotments and establish procedures which would restrict renewal
of allotment permits following unsatisfactory monitoring results.
Identify thresholds of exotic plants that should trigger the restriction
and/or prohibition of livestock grazing.
Insure that implemented monitoring procedures include replicates and independent
If no monitoring or insufficient monitoring of invasive species infestations
is occurring on livestock allotments, then consider restricting use of
Use area closures and road closures in serious weed infestations.
Require the use of certified weed-free animal feed that takes into account
all invasive species, not just noxious weeds.
Monitor disturbed areas for impacts to invasive species.
Use warning signs at prominent infestation centers.
Provide educational materials to the public and workers.
Provide weed barrels for volunteers.
Clean road equipment.
Change the way in which the roads are graded to include consideration of
impacts to invasive species' spread.
Definitions of Integrated Pest Management (IPM) are not consistent.
Wooten (1999b) used a synthesis of existing definitions to define a system
of true IPM (including IWM), to differentiate it from invalid claims by
agencies to be using IPM. He found, True IPM is an interdisciplinary system
of techniques for controlling invasive plants that is both practical
and environmentally sensitive.
Components of a true IPM program should include:
A wide variety of pest control options is considered in true IPM with preference
integration of multiple objectives
A wealth of alternatives to chemical controls exist (Wooten, 1999c).
Practicality -programs should be effective and cost-efficient.
Environmental sensitivity -programs should reduce environmental risks.
3. Ecosystem management
Some of the principles of ecosystem management have been spelled out
by Noss (1999). Ecosystem management should consider the biology of invading
species and their interactions within the affected environment, prior to
implementing control actions. Preventive measures should be used to stop
further spread and prioritize control measures on small populations of
new invaders. For different invading species, different control methods
should be considered. Decisions made under the premise of ecosystem management
need to be based on informed judgment as well as a system of principles
that acknowledges the factors which are prohibiting successful restoration
of ecosystem integrity. In the case of invasive species, these factors
would include activities which create soil disturbances and aid in the
transport of seeds. Using the principles cited in Noss, Wooten (1999) listed
a number of corollary principles for the use of true Integrated Pest Management
within an ecosystem management framework:
Social and Cultural Objectives
Ecosystem Management Objectives
Education should be an integral part of weed management projects.
Public involvement should be open and welcome during the planning, preparation,
and if necessary, legal redress, of weed management projects.
Weed management projects should be designed in the interests of the general
public, without favor to special interests or chemical companies.
Proposed projects should include integration of cultural values with resources.
Proposed projects involving the use of pesticides or herbicides should
include risk analyses for public health and safety. Thresholds for health
and safety tolerance should be publicly available. Faulty analyses or risks
exceeding thresholds should be cause for rejection of proposals and abandonment
Proposed projects should describe and analyze the economics of manual control
methods without bias.
Proposed projects should describe and analyze costs/benefit ratios. Faulty
analyses or net losses will be cause for rejection of proposals.
Proposed projects should provide clear and concise definitions and terms.
Goals of proposed projects should be realistic and objectives should be
Monitoring should be incorporated in all weed management programs.
Preferred Alternative objectives
Managers should describe weed control measures within an ecosystem management
framework involving an understanding of the biology, demographics and etiology
of weed spread.
Managers should describe weed control measures within an ecosystem management
framework involving an understanding of the differences in ecology between
native and introduced species' ecology.
Damage thresholds should be established for invading species that activate
a process of strategic weed management.
Areas in which eradication of certain species may not be feasible should
be identified and goals should be directed toward control strategies rather
than eradication in these areas.
Areas in which control or containment may not be feasible should be identified
and management should not use funds in these situations until control mechanisms
have been established.
Use of native species for recovery should be required. The use of introduced
forage grasses should be discouraged, as many introduced grasses are also
ecosystem invaders and attract livestock into recovery zones.
Monitoring should be incorporated in all weed management programs.
Herbicides use objectives
Preferred alternatives should have clearly stated goals
Preferred alternatives should substantially involve the public.
Preferred alternatives should be long-term solutions.
Preferred alternatives should be economically cost-effective
Preferred alternatives should have clearly stated costs.
Preferred alternatives should be specific about dates and times.
Preferred alternatives should be site-specific.
Preferred alternatives should be species-specific and should use scientific
nomenclature for plant names.
Preferred alternatives should incorporate effectiveness monitoring.
Examples: As an example of how ecosystem management could improve
the management of public lands, consider how plant invaders become established.
Initial introductions often arise through the use of roads and trails in
which seeds are brought in on cars, off-road vehicles, livestock, wildlife,
hiker's boots, mountain bikes, contaminated feed or contaminated seed mixtures.
Natural and man-made disturbances adjacent to those introductions then
act as sites for further spread. It is ineffective to treat roads in an
area where new road building will subsequently act as a vector for reinvasion
of a treated species. It is also ineffective to use herbicide on a site
where large populations of weeds are adjacent to the site for reinfection.
And similarly, it is ineffective to treat grazed public lands through herbicide
treatments when livestock will bring the seeds back to the site each year.
Decision documents should provide analyses of health and safety risks associated
with pesticides and should do so openly and without bias. Descriptions
of potential hazards should be available to the public and should include
discussion and analysis of potential effects on vulnerable groups of people.
Decision documents should describe the effects of proposed treatments on
the environment and should include discussion and analysis of potential
and known effects of herbicides including, but not limited to, above- and
below-ground transport, breakdown factors, food- web incorporation, nature
of targets, synergistic effects, non-target effects and aquatic effects.
If certain effects are completely unknown, herbicide use should be restricted
to emergency cases in which eradication is imminently attainable and for
which other documentation has been completed.
Decision documents should include worst-case scenarios including a discussion
of potential effects resulting from chemical spills, herbicide drift, off-target
contamination and accidental over-application.
Permits for use on public lands should be rejected for chemicals containing
so-called "inert ingredients". Manufactured products containing trade secrets
for ingredients have no place on public lands.
All areas treated with herbicides should be posted for the duration of
pesticide residuals on the site.
Cumulative effects should be analyzed including the potential for development
of herbicide tolerance, chemical buildup and selective changes in vegetation
structure resulting in loss of resources.
Only permitted applicators should be allowed to use herbicides.
The use of herbicides should be a LAST resort.
Treatments should be consistent with the management objectives for an
area. Inappropriate seeding of forage grasses should not be combined with
cattle grazing and invasive species management. Pasture grasses such as
the wheatgrasses and the bromes have been commonly used in the Pacific
Northwest with a number of undesirable ecosystem effects. Their high protein
content acts as an attractant to livestock, resulting in increased soil
disturbance and weed spread in recovery zones. Seed mixes are often contaminated
with seeds of the very weeds that the grasses are supposed to replace.
If successful, introduced perennial grasses often act as ecosystem invaders,
spreading without control across the landscape, encouraging livestock and
thus soil disturbance to new areas.
4. Adaptive management
Adaptive management is another emerging paradigm with promise for the
Forest Service. It was defined in Everett (1994, p. 110, citing Baskerville,
The formalized process of adaptive management allows restoration
activities to be initiated based on current information, but efforts need
to be constantly updated and redirected as new information becomes available.
The Interior Columbia Basin Ecosystem Management Project (ICBEMP) proposed
decision (ICBEMP, 2000) chose to use adaptive management approach (ICBEMP,
2000, p. 19):
. . . the ICBEMP decision will use an adaptive management approach
to modify management plans and activities to incorporate new knowledge
gained over time.
The process of adaptive management was described in more detail in ICBEMP
(2000, Ch. 3, p. 7):
. . . The intent of adaptive management is to incorporate and
build on current knowledge, observation, experimentation, and experience
to adjust management methods and policies, and to accelerate learning.
The intent is for management direction to be modified if a site-specific
situation is different than what was assumed during ICBEMP planning; if
a flood, fire, or other event changes the characteristics of the environment;
if new information gathered through monitoring indicates objectives are
not being met; or if new science information indicates a need for change.
. . . Monitoring and evaluation are an integral part of adaptive management
and are key to achieving the short- and long-term goals and objectives
When used in the context as presented above, adaptive management can be
a useful tool for restoring degraded areas and identifying successful methods.
However, adaptive management is inherently dependent on the long-term commitment
to ask questions and acquire information about the effectiveness and appropriateness
of actions being taken. Monitoring is thus integral to a successful adaptive
management approach which should be applied for invasive species management.
5. Precautionary principles
The risk assessment procedures that have been used by government EIS
analysts are beginning to give way to precautionary principles, as described
by Montague, 1999d):
Science has no way to analyze the effects of multiple exposures,
and almost all modern humans are routinely subjected to multiple exposures:
pesticides; automobile exhaust; dioxins in meat, fish and dairy products;
prescription drugs; tobacco smoke; food additives; ultraviolet sunlight
passing through the earth's damaged ozone shield; and so on. Determining
the cumulative effect of these insults is a scientific impossibility; so
most risk assessors simply exclude these inconvenient realities. But the
resulting risk assessment is bogus.
Certainly, this method of protecting public interests should be incorporated
into invasive species management.
Risk assessment is inherently an undemocratic process because most people
cannot understand the data, the calculations, or the basis for the risk
Now after 20 years, the public is catching on, that risk assessment
has been a failure and in many cases a scam. Rather than allowing citizens
to reach agreement on what's best, it has provided a patina of "scientific
objectivity" that powerful corporations have used to justify continued
contamination of the environment. With a few rare exceptions (sulfur dioxide
emissions, for example) dangerous discharges have increased geometrically
during the period when risk assessment has been the dominant mode of decision-making.
It is now obvious to most people that risk assessment is a key part of
the problem, not an important part of any solution.
In place of risk assessment, a new paradigm is ripening: the principle
of precautionary action. The precautionary principle acknowledges that
we are ignorant about many important aspects of the environment and human
health. It acknowledges scientific uncertainty and guides our actions in
response to it.
The precautionary principle says, ‘When an activity raises threats of
harm to human health or the environment, precautionary measures should
be taken even if some cause and effect relationships are not fully established
scientifically. In this context the proponent of an activity, rather than
the public, should bear the burden of proof. [See Rachel's Environmental
and Health Weekly #586.] The process of applying the Precautionary Principle
must be open, informed and democratic and must include potentially affected
parties. It must also involve an examination of the full range of alternatives,
including no action.’
Appendix B - Chemical safety
Forest Chemical Safety Plan
Personnel. Personnel should be knowledgeable about the handling
of hazardous substances, and procedures for ordering and procurement of
Incidents and Accidents
The use of proper material handling equipment, protective apparel, and
Emergency procedures, including the cleanup of spills and the disposal
of broken containers;
The dangers of contacting chemicals by skin absorption, inhalation, or
The meaning of the various DOT labels on shipping packages;
The proper methods of material handling and storage, especially the incompatibility
of some common substances, the dangers associated with alphabetical storage,
and the sensitivity of some substances to heat, moisture, light, and other
The special requirements of heat-sensitive materials, including those shipped
refrigerated or packed in dry ice;
The hazards associated with flammable liquids (especially the danger of
their vapors catching fire some distance from the container) (e.g., alkali
metals, burning magnesium, metal hydrides, acid chlorides, phosphides,
The federal and state regulations governing controlled substance such as
radioactive material, drugs, ethyl alcohol, explosives, and needles and
Chemicals that have offensive smells; and
Packages that exhibit evidence that the inside container has broken and
leaked its contents.
1. Introduction: Reporting incidents and accidents is required by law.
Relatively minor incidents without personal injury or only minor injury
should be reported on the incident report form. Serious accidents (fatalities
and multiple hospitalization injuries) must be reported directly to OSHA.
Forms will be available from the Safety Officer.
2. Reportable Incidents Include:
A. Every accident (injurious or non-injurious). B. Accidents
resulting in damage to instruments or the building. C. Situations or conditions,
which have a potential for injury, hazard to health, or damage to the property.
D. Situations in which a member of the public claims to be harmed.
3. Serious Accidents Include:
A. Fatalities B. Injuries requiring hospitalization C. Injuries
requiring medical treatment D. Property damage E. Chemical exposure resulting
in lost time which may involve the public
A. Minor incidents reported to the supervisor will be investigated
and a report filed in a 30-year archive file with an evaluation and recommendations.
B. Major accidents or serious incidents will be investigated by the supervisor
and Safety Officer in conjunction with the safety committee and a full
report given to the supervisor.
5. Reporting Accidents.
A. All accidents and injuries, no matter how minor, shall be
reported PROMPTLY to the immediate supervisor, Office Director or person
in charge of the work area. The agency's employee personal injury report
form will be used to report all injuries or incidents.
Accidents, Spills, and Releases. Spills of toxic substances or accidents
involving any hazardous chemical shall be resolved immediately according
to the State Public Health Laboratories' emergency procedure plan. Clean
up of hazardous chemicals will be performed by qualified personnel from
the area where the spill occurred. All accidents must be documented, and
reported to the Safety Officer.
B. The injured worker's immediate supervisor or the person in charge
must conduct a thorough unbiased investigation to determine the cause(s)
of the accident.
C. The injured employee and his/her supervisor shall handle and complete
the Labor and Industries (L&I) Injury Claim Report, Form F242-130-111
D. The circumstances of any injury accident resulting in an immediate
or suspected fatality shall be reported immediately to the local office
of the Department of Labor and Industries and to the Safety and Benefits
(1) Except where removal is essential to prevent further injury,
equipment involved in a fatal accident shall not be moved until the investigation
is completed or the equipment is released by the L&I investigator.
E. Cases involving injuries which are so severe that the employee may be
off work for an extended period require the employee to be counseled with
respect to benefits and various employment/compensation options available
and how they may affect pay, retirement and leave provisions.
(2) All personnel shall cooperate fully with the L&I Industrial
Safety and Health investigators and inspectors.
Emergency procedures for spills and accidents. All spills are
different, and remediation requires judgement; below are some guidelines
for reaction to spills.
Emergency procedures for spills and accidents. In handling emergencies:
Attend to any person who may have been contaminated or injured.
Notify your supervisor and appropriate emergency responders immediately.
If spilled chemical is flammable, extinguish all nearby sources of ignition.
Notify persons in the immediate area about the spill.
Evacuate all nonessential persons from the spill area.
If the spilled material is flammable turn off any heat source.
If a person has been splashed with a chemical, remove all contaminated
clothing, flush the contaminated area with running water for at least 15
minutes, and GET MEDICAL ATTENTION, CALL 911.
If a person has been overexposed by inhalation, get victim to fresh air
if it is safe to do so, begin rescue breathing if necessary, and GET MEDICAL
ATTENTION, CALL 911.
Avoid breathing vapors of the spilled material; if necessary use a respirator.
Ingestion: GET MEDICAL ATTENTION, CALL 911and the local poison control
center and follow their instructions.
Leave on or establish exhaust ventilation if it is safe to do so.
In other cases of overexposure, GET MEDICAL ATTENTION, CALL 911 and follow
the instructions of the medical professional.
Secure supplies to effect cleanup. Promptly clean up spills using appropriate
protective apparel and equipment and proper disposal.
Inform the safety officer if a regulated substance is involved.
Release of hazardous substances. The release of hazardous substances
should minimize exposure of personnel and property. This preplanning should
include consideration of the following factors:
DO NOT handle emergencies alone, GET HELP.
DO NOT linger at the accident scene if you are not one of the emergency
DO NOT apply medical aid procedures without training in first aid. If you
are not trained in first aid, get MEDICAL ATTENTION, CALL 911, or contact
a medical professional as soon as possible.
Commercial spill kits must be available with all applicators complete with
instructions, absorbent, reactants, and protective equipment. These kits
should also be strategically located in work areas where chemicals are
stored, and with field personnel who will be travelling to treated areas.
potential location of the release;
the quantities of material that might be released and whether the substance
is a piped material or a compressed state;
chemical and physical properties of the material (e.g., its physical state,
vapor pressure, and air or water reactivity);
hazardous properties of the material (its toxicity, corrosivity, and flammability),
the types of personal protective equipment that might be needed.
Supplies and equipment must be on hand to deal with spills, consistent
with the hazards and quantities of the spilled substance. These cleanup
supplies should include neutralizing agents (such as vermiculite and sand).
Paper towels and sponges may also be used as absorbent-type cleanup aids,
although this should be done cautiously. Appropriate gloves should be worn
when wiping up toxic materials with paper towels. Also, when a spilled
flammable solvent is absorbed in vermiculite or sand, the resultant solid
is highly flammable and gives off flammable vapors and, thus, must be properly
contained or removed to a safe place.
Handling of Spilled Liquids:
Exposure Evaluations and Medical Consultations
Wear appropriate personal protective apparel; gloves, overcoat, mask, eyewear,
or face shields as necessary.
Confine or contain the spill to a small area. Do not let it spread.
For small quantities of materials, absorb the spill with nonreactive material
such as vermiculite, dry sand, or towels.
Carefully pick up and remove any cartons or bottles that have been splashed.
If the spilled material is extremely volatile, let it evaporate and be
exhausted before attempting to clean it up without protective clothing
and respiratory gear. Be sure that associated mechanical equipment in the
area is spark-proof.
Dispose of residues according to safe disposal procedures (keep references
manufacturer's references and material safety data sheets available to
Suspected Exposures to Toxic Substances. When employees or supervisors
suspect that an employee has been exposed to a hazardous chemical to a
degree and in a manner that might have caused harm to the victim (circumstances
suggest a reasonable suspicion of exposure), the affected employee shall
be provided an opportunity for medical consultation. Such consultation
shall be for the purpose of determining the need for a medical examination.
All medical examinations and consultations shall be performed by or under
the direct supervision of a licensed physician and shall be provided at
no cost to the employee, without loss of pay and a reasonable time and
Criteria of "Reasonable" Suspicion of Exposure. It is the policy
of the Forest Service to promptly investigate all employee-reported incidents
in which there is even a remote possibility of employee overexposure to
a toxic substance. Regular medical surveillance should be established to
the extent required by the regulations.
Circumstances That Constitute a Suspected Exposure:
Exposure Evaluation. All complaints and their disposition, no matter
what the ultimate disposition may be, are to be documented. If no further
assessment of the event is deemed necessary, the reason for that decision
should be included in the documentation. If the decision is to investigate,
a formal exposure assessment will be initiated.
Anyone whose work involves regular and frequent handling of toxicologically
significant quantities of a chemical should consult a qualified physician
to determine on an individual basis whether a regular schedule of medical
surveillance is desirable.
Where exposure monitoring reveals an exposure level routinely above the
action level (or in the absence of an action level, the PEL) for an OSHA
regulated substance for which there are exposure monitoring and medical
surveillance requirements, medical surveillance shall be established for
the affected employee as prescribed by the particular standard.
A hazardous chemical leaked, spilled or was otherwise rapidly released
in an uncontrolled manner.
Odor was noticed, especially if person was working with any chemical, which
has a lower TLV than odor threshold.
An employee had direct skin or eye contact with a hazardous chemical.
An employee manifests symptoms, such as headache, rash, nausea, coughing,
tearing, irritation or redness of eyes, irritation of nose or throat, dizziness,
loss of motor dexterity or judgement, etc.
Some or all of the symptoms disappear when the person is taken away from
the exposure area and breathes fresh air.
The symptoms reappear soon after the employee returns to work with the
same hazardous chemicals.
Two or more persons in the work area have similar complaints.
All complaints will be promptly investigated to determine risk of employee
overexposure to the toxic substances in their work place.
Exposure Assessment. In cases of emergency, exposure assessments
are to be conducted by a Chemical Hygienist after the victim has been treated.
It is not the purpose of an exposure assessment to determine that a
failure on the part of the victim, or others, to follow proper procedures
was the cause of an exposure. The purpose of an exposure assessment is
to determine that there was, or was not, an exposure that might have caused
harm to one or more employees or members of the public, and, if so, to
identify the hazardous chemical or chemicals involved. Exposure assessments
determine facts; they do not make recommendations. Unless circumstances
suggest other or additional steps, these actions constitute an exposure
Physician Written Opinion. For examination or consultation required
under this standard, the employer shall obtain a written opinion from the
examining physician (WAC 296-62-40013) which shall include the following:
Interview the complainant and also the victim, if not the same person.
List the essential information about the circumstances of the complaint,
A. The chemical and physical properties involved and the quantity in
use; the potential for overexposure associated with the operation involved
and an estimation of the duration of exposure;
B. Other chemicals used by victim;
C. All chemicals being used by others in the immediate area;
D. Other chemicals stored in that area;
E. Symptoms exhibited or claimed by the victim;
F. How these symptoms compare to symptoms stated in the materials safety
data sheets for each of the identified chemicals;
G. Were control measures, such as personal protective equipment and
clothing, being used properly?;
H. Were any air sampling or monitoring devices in place? If so, are
the measurements obtained from these devices consistent with other information?;
I. Monitor or sample the air in the area for suspect chemicals;
J. Determine whether the present control measures and safety procedures
Notification of Monitoring Results. Within 15 working days of receipt
of the results of any monitoring, employees will be notified of those results
either individually or by posting results in an appropriate location that
is accessible to employees.
Any recommendations for further medical follow-up.
The results of the medical examination and any associated tests.
Any medical condition, which may be revealed in the course of the examination,
which may place the employee at increased risk as a result of exposure
to a hazardous chemical, found in the workplace.
A statement that the employee has been informed by the physician of the
results of the consultation or medical examination and any medical condition
that may require further examination or treatment.
The written opinion shall not reveal specific finding of diagnoses unrelated
to occupational exposure.
Medical Consultation. When employees are suspected or known to
be overexposed to toxic chemicals, they should receive prompt medical attention.
To ensure that they do receive proper and informed medical attention, the
Forest Service will designate preferred medical facilities for consultation
Medical Consultation Authority. It is the authority of the Safety
Officer, to authorize medical consultation in Non-Emergency cases. The
employee to be examined will consult with or visit previously designated
medical facility. It is the responsibility of supervisory staff or designee
to arrange transportation to and from the medical facility. (Note; if chemical
exposure is confirmed or suspected, a supervisor cannot assure the victim
can properly operate a motor vehicle). The medical report will be sent
directly to the Safety Officer, who will pass the appropriate information
along to those involved.
Documentation. All memos, notes, and reports related to a complaint
of actual or possible exposure to hazardous chemicals are to be maintained
as part of the record.
Notification. Employees shall be notified of the results of any
medical consultation or examination with regard to any medical condition
that exists or might exist as a result of overexposure to a hazardous chemical.
Pesticides. A pesticide label containing information on use and
safety must be attached to all pesticide containers. The label includes
the product name, name and amount of active ingredients, EPA registration
number and establishment number, name and address of the manufacturer,
and net contents.
The use classification (general use or restricted use) is noted on the
label. The signal word (danger, warning, or caution) provides information
about hazard classification. Precautionary statements inform users of handling
requirements, procedures, and special concerns. Directions for use specify
legal application sites, rates, and mixing and handling instructions. The
pesticide label is a binding legal agreement between the EPA, the registrant,
and the user. It is illegal to use a pesticide in a way or place not specified
on the label.
Procedures for Carcinogens, Reproductive Toxins, Substances with
a High Degree of Acute Toxicity and Chemicals of Unknown Toxicity.
Follow the procedures described in this section when performing work with
any carcinogen, reproductive toxin, substance that has a high degree of
acute toxicity, or a chemical whose toxic properties are unknown. This
includes pesticides with "inert ingredients" that have not been profiled
by the EPA.
The following definitions will apply:
1. Select carcinogen: Any substance defined as such in 29 CFR
1910.1450 and any other substance described as such in the applicable MSDS.
"Select carcinogen" means any substance, which meets one of the following
A. It is regulated by OSHA as a carcinogen;
2. Reproductive toxin: Any substance described as such in the applicable
MSDS, or any substance identified as a reproductive toxin by the Oak Ridge
Toxicology Information Resource Center (TIRC), (615)576-1746; or for teratogen
only: Any substance identified as such in Thomas H. Shepard, "Catalog of
Teratogenic Agents", 6th ed., John Hopkins Press, 1989. 3. Substance with
a high degree of acute toxicity: any substance for which the LD50 data
described in the applicable MSDS cause the substance to be classified as
a "highly toxic chemical" as defined in ANSI Z129.1 4. Chemical whose toxic
properties are unknown: A chemical for which there is no known statistically
significant study conducted in accordance with established scientific principles
that establishes its toxicity.
B. It is listed under the category, "known to be carcinogens," in the
Annual Report on Carcinogens published by the National Toxicology Program
(NTP) (latest edition); or
C. It is listed under Group 1 ("carcinogenic to humans") by the International
Agency for Research on Cancer Monographs (IARC) (latest edition); or 7.4Procedures
for Carcinogens, Reproductive Toxins, Substances with a High Degree of
Acute Toxicity and Chemicals of Unknown Toxicity
D. It is listed in either Group 2A or 2B by IARC or under the category,
"reasonable anticipated to be carcinogens" by NTP, and causes statistically
significant tumor incidence in experimental animals in accordance with
any of the following criteria: a) After inhalation exposure of 6-7 hours
per day, 5 days per week for a significant portion of a lifetime to dosages
of less than 10 mg/m3; b) After repeated skin application of less than
300 (mg/kg of body weight) per week; or c) After oral dosages of less than
50 mg/kg of body weight per day.
All work involving carcinogens must be done using barrier clothing out
of doors to reduce the risks of employee exposure to the vapors.
Records. This section reviews the value of documenting compliance
with this safety standard for general liability and the ability to periodically
assess the safe conduct of employees.
Record keeping. All records should be kept for at least as long
as the employees affected are employed with the Government. Require medical
records to be kept for 30 years beyond the employee's time of employment.
It is prudent to set up an archiving system to keep all-important documents
related to safety employee training and distribution of Material Safety
Data Sheets for the lifetime of the company. Medical records of employees
who have worked less than one year need not be retained after employment,
but the employer must provide these records to the employee upon termination
Accident records should be written and retained.
Chemical Hygiene Plan records should document that the facilities and precautions
were compatible with current knowledge and regulations.
Inventory and usage records for high-risk substances should be kept as
specified. Maintain records of the amounts of these materials on hand,
amounts used, and the names of the workers involved.
Medical records should be retained by the institution in accordance with
the requirements of state and federal regulations.
Specific records may be required in the event of time loss resulting from
an exposure by accident on the job. The standard form OSHA 200 is used
to document lost workdays from incidents that occur at work.
In addition to records required by OSHA, it will be desirable to keep special
records developed internally which document suspected exposures and employee
exposure complaints regardless of the outcome of the Exposure Evaluation.
Other incidents and activities could be documented for future reference.
A. COMPLAINTS FROM EMPLOYEES - Even if the complaint is found to be
unjustified, it is desirable to keep a record of the complaint, the investigation,
and the outcome. The complaint might be about chemical exposure, but could
include complaints about inoperative-engineered controls or defective personal
B. REPAIR AND MAINTENANCE RECORDS FOR CONTROL SYSTEMS - Demonstrate
that equipment such as protective clothing and gear is well maintained
and kept in clean, proper operating order. These are useful; they suggest
corrective actions and indicate that equipment was or was not well maintained
and kept in working order.
C. MAJOR SAFETY SUGGESTION FROM EMPLOYEES - Can be valuable to improve
workplace safety. Even if the issue is decided to be non-workable, the
fact that the suggestion was take seriously and examined is valuable.
D. NEAR-MISS REPORTS - Employees who participate in or witness events
that could have caused harm, but fortunately did not, should prepare reports
of the incidents. These reports are used to develop changes in procedures
that will prevent a future more serious occurrence.
E. RECORDS TO BE KEPT - The Forest Chemical Safety Plan requires that
records of air concentration monitoring results, exposure assessments,
medical consultation, and examinations be maintained for at least 30 years
and that they be accessible to employees or their representatives. A system
will be developed to retain documents related to distribution and maintenance
of Material Safety Data Sheets and to the safety training of employees.
Specific records may be required in the event of lost work time resulting
from injury on the job.
Storage of Records and Documents. All records pertaining to personnel
training, and safety concerns or actions will be kept in a locked fireproof
container. These records will be accessible to the employee to whom they