Some Current Bio-agent Considerations

6.0 RECORDKEEPING

EPA’s recordkeeping goal is to ensure that nationally consistent, readily accessible records are maintained at each EPA organization. Table 4 and the rest of this section provide details about the specific recordkeeping procedures that must be followed, who is expected to complete specific forms, and who must retain copies of the records.

Table 4
Recordkeeping Requirements Associated With the
Chemical and Biological Agents Program

Required Record	Details/Specified Forms	Completed/Compiled By^a	Retained By^a
Awareness training records	Training certificates (or other forms of documentation)	Course instructor or SHEMP Manager	Individual employee^b
Documentation of onsite medical monitoring	Onsite Medical Monitoring Tracking Form (see the “Forms” section of the manual’s website )	Medical Monitor (see glossary for a definition)	SHEMP Manager
^aThe delegation of recordkeeping responsibilities presented in this table reflects the chapter authors’ opinions. The assignments have been made with regional audiences in mind; the positions listed might not be applicable for OLEM special teams and HQ. Users can adjust the assignments when they go through the process of customizing this chapter. ^b Employees must provide documentation certifying the completion of their training requirements to the SHEMP Manager or HSPC (or another designated person), who in turn will document it in the FRM.

6.1 Training Records

Employees must obtain a training certificate (or an equivalent form of documentation) that certifies that they have completed Chemical and Biological Awareness training. They must present this documentation to the SHEMP Manager or HSPC (or another designated person), who in turn will ensure that the training is documented in the FRM. Upon completing that task, the SHEMP Manager or HSPC (or another designated person) is not required to retain a hardcopy of the training documentation. Emergency responders should, however, retain proof that they have completed the training.

6.2 Documentation of Onsite Medical Monitoring

The Medical Monitor (e.g., an emergency medical technician [EMT] or health professional who has been hired to perform onsite monitoring) must use a form (see the sample posted in the “Forms” section of the manual’s website) to track employee vital signs in the field. These forms must be given to the Onsite Safety Officer, who will submit them to the SHEMP Manager (or another designated person).

APPENDIX A

Chemical and Biological Agents:
Designation of Roles and Responsibilities

Instructions for Users
Appendix A provides a place for users to insert organization-specific information into the Chemical and Biological Agents chapter. The appendix presents a list of tasks that must be performed to ensure chemical and biological agents are addressed properly during a response. The tasks are listed in rows. EPA position titles (e.g., the Removal Manager or the Health and Safety Program Contact) are listed in columns. Each task has been assigned to a default position. For some of the tasks, check marks have been placed in two or more columns to indicate that more than one person is responsible for that task. Please note that users can re-delegate tasks.
Users must take the following steps to customize Appendix A:

• 
  Fill in the background information requested at the top of page A-3. For example, indicate when the table is being updated and who is doing the updating.
  
• 
  Fill in actual names under the position titles.
  
• 
  Add additional key players to the table (if necessary). Note: The chapter authors have already provided a placeholder to add a new position, as the last column is labeled “Other.” Users should customize this column to identify the position title (and name) of any additional key player assigned responsibility to implement this chapter. Users can insert more columns to include additional key players (if necessary).
  
• 
  Add rows to the table (if necessary) to provide information about activities that exceed the minimum requirements already included in Appendix A. (See Appendix B for a list of your organization’s additional policies and procedures related to this chapter.)
  
• 
  Determine whether any of the recommended task assignments must be delegated to another person. (If so, move the check marks to re-assign the task.)
  

ATTENTION OLEM Special Teams and HQ Users: The tasks and position titles that appear in Appendix A have been written with regional audiences in mind. OLEM special teams and HQ users should modify the language that appears in the rows and column headers to reflect the needs of their organization.
Ensure that each task has been assigned.

APPENDIX A

Task Table for Implementing the Chemical and Biological Agents Chapter
This table has been customized for: EPA Organization .

Last Updated on: Month Day, Year.

Updated by: Name .

		Who Is Responsible for Each Task or Action?
TASKS ▼	ROLES ► Name of person in role ►	Removal Manager	SHEMP Manager	Health and Safety Program Contact	Immediate Supervisors	Onsite Safety Officers	Emergency Responders*	Medical Monitors (defined in glossary)	Other
		See Appendix A-2 in the Introduction chapter for the names of personnel that fill these roles.
General Tasks
1.Ensure that procedures outlined in the Chemical and Biological Agents chapter are followed by all responsible parties.		
2.Serve as the organization’s health and safety expert (or establish a link to a technical expert) for responses to chemical and biological agents.									
3.Facilitate and coordinate chemical/biological emergency response health and safety issues for EPA’s emergency responders.				
4.Implement the Chemical and Biological Agents chapter by: (1) customizing the chapter with organization-specific information, (2) reviewing/updating the customized version annually, and (3) adopting the requirements and practices in the chapter. Post the customized chapter to the manual’s website and inform stakeholders of its availability.							
Tasks Associated With Chemical and Biological Agents Awareness Training (Section 3.0)
5.Attend and complete Chemical and Biological Agent Awareness training. (Note: The awareness training may be provided as a standalone course or as part of initial 40-hour HAZWOPER training or annual 8-hour refresher training.)							
6.Develop (and/or arrange for) emergency responders to receive Chemical and Biological Agent Awareness training.				
Tasks Associated With Medical Surveillance (Section 5.1)
7.Ensure that emergency responders receive appropriate immunizations or prophylactic treatment, such as antibiotics, before going on site (see the manual’s Medical Surveillance Program chapter). Once in the field, continuously reassess the situation to determine whether chemical or biological hazards are present. Ensure that emergency responders receive appropriate antibiotics or other prophylaxis if the onsite Medical Monitor (see glossary for a definition) deems it necessary.								
8.Determine whether onsite medical monitoring is necessary. If monitoring is necessary, make arrangements for a trained Medical Monitor (see glossary for a definition) to observe responders on site.						
9.If onsite medical monitoring is necessary, establish a checkpoint for employees to go through when entering/exiting the work zone. Take vital signs as employees pass through the checkpoint. Alert employees, their immediate supervisors, and the Onsite Safety Officer if monitoring results suggest that an employee may have been exposed to a chemical or biological agent, or other site hazard.								
Tasks Associated With Onsite Health and Safety Controls (Section 5.2 and (Section 5.3)
10.Determine whether a biological agent poses a risk of infection or a chemical agent poses acute and/or chronic health hazards. Perform environmental monitoring and determine the level of PPE that is to be worn (see the manual's Respiratory Protection Program chapter and PPE Program chapter for guidance on respirator and PPE selection), incorporate information about these controls into the site-specific HASP, and ensure that the controls are implemented in the field.						
11.Upon request, assist the Onsite Safety Officer in determining/implementing work practice, engineering, or administrative controls.				
12.Upon request, perform task-specific evaluations to assess the hazards posed by chemical or biological agents.						
13.Provide emergency responders with the Quick Reference Guide in the Chemical and Biological Agents chapter.						
14.Ensure that employees have access to emergency medical services in a reasonable time frame.						
15.Provide technical support to emergency responders to ensure that the HASP addresses management of exposure to chemical or biological agents.				
16.Ensure that all chemical/biological agent components of the HASP are implemented in the field.						
Tasks Associated With Recordkeeping Activities (Section 6.0)
17.Retain a certificate (or an equivalent form of documentation) certifying that you have completed Chemical and Biological Awareness training.							
18.Ensure that training requirements are tracked in the FRM and that the Removal Manager or supervisor is aware of which employees have/have not completed their training requirements.					
19.Retain copies of onsite medical monitoring records.			
Additional Tasks That Reflect Organization-Specific Procedures (Appendix B)
Attention users: Add rows if necessary.

_________________________________

*Note: A list of the organization’s emergency responders is provided in Appendix A-2 of the Introduction chapter.