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November 4, 2005
In Reply Refer To:
1703 (360) P
Instruction Memorandum No. 2006-037
Expires: 09/30/2007

To:              All Washington Office and Field Officials

From:          Assistant Director, Minerals, Realty and Resource Protection

Subject:      Discovery Policy on Hazardous Substances for All BLM Employees

Program Area: Protection and Response, Field Operations Safety

Purpose: This Instruction Memorandum (IM) provides guidance for BLM employees who may encounter suspected hazardous substances in the course of conducting their job responsibilities. This guidance applies to all BLM employees, including employees who may not normally think of themselves as involved with hazardous substances, such as natural resource specialists, law enforcement officers, firefighters, oil and gas specialists (including drilling operations), realty and mining (including abandoned mine lands) staff.

In addition, this policy applies to volunteers authorized by the BLM to enter areas of archaeological significance, or other lands managed by the BLM. The goals of this policy are to protect the health and safety of all employees of the BLM, minimize potential liability for the BLM and emphasize compliance with regulations under the Occupational Safety and Health Act (OSHA), which applies to the BLM and its employees.

Policy/Action:  Employees of the BLM that discover any unauthorized waste dump or spill that indicates the presence of potential hazardous substances (e.g., containers of unknown substances, pools of unidentifiable liquids, piles of unknown solid materials, unusual odors or any materials out of place or not associated with an authorized activity) shall take the following precautions:

·        Treat each site as if it contains hazardous materials;
·        Do not handle, move, or open any containers, breathe vapors or make contact with any materials ;
·        Move a safe distance upwind from the site; and
·        Contact the appropriate personnel as outlined in the Field Office/Resource Area Hazardous Materials Incident                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  Contingency Plan. Generally, this is the Hazardous Materials Coordinator for the area.

The OSHA's health and safety regulations are contained in 29 CFR 1910.120, and are referred to as the HAZWOPER regulations. The HAZWOPER regulations identify requirements for first responders, who are described as "...individuals who are likely to witness or discover a hazardous substance release, and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release."

Any BLM employee working in the field may witness or discover a hazardous substance release while conducting their job responsibilities. In order to ensure that field personnel are familiar with the potential hazards associated with such a release:
   A minimum of two hours of First Responder Training must be completed by all new field personnel; this training should
    be provided by a Hazardous Materials Coordinator in the state or field office who has completed the National Training
    Center’s (NTC) Hazardous Materials Awareness Class Module (1703-07/11).

Additional training materials such as films and presentations are available through the NTC.
Field office managers are responsible to ensure that field personnel meet this health and safety requirement.

Time frame: This IM is effective upon receipt.

Budget Impact: This IM should have no effect upon the budget.

Background: This policy is intended to protect the health and safety of BLM personnel by providing guidance on actions that are required in the event that suspected hazardous substances are encountered. The BLM is also revising the site entry policy for employees who enter sites with potential or known hazardous substances for specific purposes within their job responsibilities.

Manual/Handbook Sections Affected: Manual Section 1703 is affected by this policy.

Coordination: This policy has been coordinated by the State Office Program Leads and National Science Technology Center (NSTC) personnel.
Contact: Questions or comments concerning this policy should be directed to Georgette Fogle, Protection and Response Group, at 202-557-3569.
Signed by:                                                  
Authenticated by:
Thomas P. Lonnie                                       
Robert M. Williams
Assistant Director                                       
Policy and Records Group,WO-560
Minerals, Realty and Resource Protection

Last updated: 10-21-2009