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May 3, 2006
In Reply Refer To:
1703 (360) P
Instruction Memorandum No. 2006-037, Change 1
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: The Change 1 provides the Bureau of Land Management (BLM) Employees with the current training course module provided by the National Training Center and additional training criteria. This Instruction Memorandum (IM) provides guidance for BLM employees who may encounter hazardous substances in the course of conducting their job responsibilities. This guidance applies to all BLM employees, including employees who normally do not think of themselves as involved with hazardous substances, such as natural resource specialists, law enforcement officers, firefighters, oil and gas specialists (including drilling operations), and 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 for further guidance. 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."

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:

All new field personnel must take a minimum of two hours of First Responder Awareness Level training. All field personnel must complete an annual refresher course.  The National Training Center (NTC) offers course 1703-21 HazMat Awareness Train-the Trainer which should be taken by Hazardous Materials Coordinators who will be instructing field personnel. The BLM NTC has available a HazMat First Responder Awareness Computer Based Training CD and a HazMat Awareness Video Series DVD for training purposes.

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.

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

Coordination: This policy has been coordinated with the State Office Program Leads, National Science and Technology Center (NSTC), and the National Training Center (NTC) personnel.

Contact: Questions or comments concerning this policy should be directed to Georgette A. Fogle, Protection and Response Group, at 202-557-3569 or
Miyoshi Stith, Protection and Response Group, at 202-557-3578.
Signed by:                                                                   
Authenticated by:
Thomas P. Lonnie                                                        
Robert M. Williams
Assistant Director                                                        
Division of IRM Governance,WO-560
Minerals, Realty and Resource Protection

Last updated: 10-21-2009