Hazmat Gear Considerations for Chemical Spills

Chemical spills vary from incidental to deadly. No matter the spill type, as a responder, you risk overexposure. When entering a hot zone, you must be protected against the actual or potential hazards. The good news is, personal protective equipment (PPE) and chemical protective clothing (CPC) may work to shield, isolate or otherwise protect you from not only chemical hazards but also physical and biological hazards when other control measures are not enough.

It’s important to know, though, this gear has its limits. No single set of PPE and CPC will guard against all hazards. These suits may even pose their own threats to wearers, such as heat illness; psychological/physiological stress; muscle fatigue; and impaired mobility, dexterity, tactility, vision, and communication.

Therefore, choosing the right PPE-CPC combination is a critical part of any spill response operation. Your goal, however, is to reach an adequate level of protection and avoid over- and under-protection.

Examples of PPE

PPE minimizes your exposure to chemical, physical and/or biological hazards that cause injuries, illnesses and/or fatalities. Examples of PPE include—but are not limited to—respiratory, head, eye, face, hearing, hand, foot and fall protection.

Examples of CPC

CPC protects your skin and/or body from chemical splashes, dusts, gases and vapors. Thoughts of CPC may conjure images of the fully encapsulating chemical-protective suit, which looks like an astronaut suit. However, there are plenty of other sorts of CPC, including hooded one- and two-piece chemical-protective suits, long-sleeved jackets/coats, chemical-protective gloves/over-gloves, protective sleeves/leggings, aprons, coveralls/pants, hoods and disposable shoe/boot covers.

and PPE at the same time. For instance, a glove that protects the hands from chemical contact (and subsequent skin absorption, chemical burns, etc.) would fall under all three terms.

Levels of protection

PPE and CPC are worn together in a “PPE ensemble,” informally called a “hazmat suit.” The Occupational Safety and Health Administration (OSHA) and the U.S. Environmental Protection Agency (EPS) have long referred to four ensemble levels — A, B, C and D. Table 1 describes the protection provided as well as the typical and optional types of PPE and CPC that make up each level.

Table 1: OSHA/EPA ensemble levels

Table 1 sources:

29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.

OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.

Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.

EPA’s Personal Protective Equipment webpage within the agency’s Emergency Response homepage.

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities(DHHS publication no. 85-115).

Hazard assessment

Before you try to work out which PPE ensemble level is appropriate for the spill at hand, size up the situation. Consider:

• The chemical(s) involved (or suspected) and its state, concentration, hazard(s) and exposure route(s);
• Oxygen deficiency and immediately dangerous to life or health (IDLH) conditions;
• Actual exposure levels and the required/recommended exposure limits;
• The chemical container(s) type, size, location and condition;
• The temperature, weather and changing conditions;
• Site hazards, such as uneven surfaces, confined spaces, electrical hazards and falling objects;
• The physical requirements of each response task and duration to complete them;
• Any engineering, administrative and work practice controls that will be in place;
• The relative risk (severity plus probability) for damage to people, property and/or the environment; and
• Available PPE and CPC (and their limitations), along with other resources.
  
  

Selecting levels of protection

Based on the hazard assessment, your next step is ensemble selection. This is complex, but the more you know about the hazards, the easier it becomes. OSHA and EPA suggest a starting point: a list of hazardous conditions under which each of the levels may be appropriate. These are described in Table 2.

Table 2: Ensemble-level selection quick start

Table 2 sources:

29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.

OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.

Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.

EPA’s Personal Protective Equipment webpage within the agency’s Emergency Response homepage.

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (DHHS publication no. 85-115).

Regardless of Tables 1 and 2 , it’s important to tailor your ensemble to your specific situation. Also, review the respirator selection requirements at 29 CFR 1910.134, Respiratory Protection, and the ensemble selection recommendations in Appendix B to 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response.

Performance factors

Imagine this scenario: You just entered a hot zone with your level A ensemble. Suddenly, chemical vapors begin to seep into your suit through the zipper. Your facepiece clouds over, then melts. You’re unable to proceed with the response. That kind of suit failure is an example of a “performance” issue.

An ensemble must provide an adequate level of protection. Yet, relying solely on the OSHA/EPA level criteria takes you only so far. You also need to consider performance factors related to:

• Permeation or chemicals moving through a material on a molecular level;
• Degradation or material changes, such as fading, swelling, loss of strength and deterioration;
• Penetration or chemicals leaking inwardly through zippers, seams or imperfections in material;
• Breathability or heat transfer of the material;
• Strength and durability of the material and components;
• Resistance to cuts, punctures, tears, abrasion, cracking, etc.;
• Functionality in extreme cold and heat;
• Flame-resistance of the material and components;
• Degree of dexterity, mobility and visibility for the wearer; and

The National Fire Protection Association (NFPA) publishes standards used by PPE/CPC manufacturers and others to test the performance of products. NFPA divides ensembles into several standards and classes, but Annex A to NFPA 1990-2022 offers a table that compares these standards and classes to the OSHA/EPA levels. Look for a label certifying that a product is compliant with NFPA’s performance criteria.

Upgrading/downgrading ensembles

Be aware that ensemble selection and re-selection is an ongoing process. You may decide to upgrade or downgrade the protection level because:

• Spill conditions change,
• You gain more insight about site hazards and conditions over time,
• A change in response tasks brings an increase or decrease in chemical exposure, or
• A worker simply requests an ensemble change.
  
  

Other factors to consider

Note that some factors might be considered prior to or during an ensemble purchase. These are listed in Table 3.

Table 3: Ensemble-purchasing factors

Table 3 sources:

NFPA 1891-2022, Standard on Selection, Care and Maintenance of Hazardous Materials, CBRN, and Emergency Medical Operations Clothing and Equipment.

J. J. Keller® Compliance Network – Institute Safety & Health: HAZWOPER subject.

29 CFR 1910.120 Appendix B, General Description and Discussion of the Levels of Protection and Protective Gear.

OSHA Technical Manual (OTM) Section VIII: Chapter 1, Chemical Protective Clothing.

Emergency Responder Health and Safety Manual (Version 2.0, January 2017): Chapter 5, Personal Protective Equipment Program.

Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (DHHS publication no. 85-115).

Final thoughts

A PPE ensemble is your last line of defense against hazards presented during spill response. As such, its selection is critical and complex.

OSHA and EPA give you a simple method for selecting a PPE-CPC combination. However, you must base this determination on a complete hazard assessment of the spill situation. You must also consider performance and other factors. There’s no substitute for paying attention to changing conditions and news to help you select (and re-select) the right gear for the task at hand.