Hazardous Waste Operations and Emergency Response (HAZWOPER)

1. Hazardous Waste Operations and Emergency Response (HAZWOPER) 29 CFR 1910.120

2. Scope, application, and definitions Safety and health program Site characterization and analysis Site control Training Medical surveillance Engineering controls, work practices and personal protective equipment (PPE) Monitoring Informational programs Handling drums and containers Decontamination An Outline of the Provisions of 1910.120

3. Emergency response by employees Illumination Sanitation at temporary workplaces New technology programs Operations under RCRA Hazardous substance release An Outline of the Provisions of 1910.120

4. Purpose The purpose of HAZWOPER is to improve the ability of employees and employers to respond to emergencies caused by releases of hazardous substances. 1910.120

5. Scope Covers the following operations: Clean-up operations required by a governmental body, whether federal, state, local or other, involving hazardous substances that are conducted at uncontrolled hazardous waste sites. Corrective actions involving clean-up operations at sites covered by Resource Conservation and Recovery Act (RCRA). Voluntary clean-up operations at sites recognized by federal, state, local or other governmental bodies as uncontrolled hazardous waste sites. 1910.120(a)(1)

6. Scope Operations involving hazardous wastes that are conducted at treatment, storage and disposal facilities licensed under the Resource Conservation and Recovery Act (RCRA). Emergency response operations for release of, or substantial threats of release of, hazardous substances. 1910.120(a)(1)

7. Scope Unless The employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards. 1910.120(a)(1)

8. Definitions Hazardous substance Any substance to which exposure results or may result in adverse effects on the health or safety of employees. Any substance defined under section 101(14) of CERCLA Any biologic agent and other disease causing agent Listed by the U.S. DOT (49 CFR 172.101) Hazardous waste 1910.120(a)(3)

9. Definitions Hazardous Waste EPA defines hazardous waste as by-products of society that can pose a substantial or potential hazard to human health or the environment when improperly managed. It possesses at least one of four characteristics (ignitability, reactivity, toxicity, or corrosiveness), or appears on special EPA lists. Hazardous waste operations Any operation conducted within the scope of the HAZWOPER standard. 1910.120(a)(3)

10. Definitions Hazardous materials response (HAZMAT) team An organized group of employees, designated by the employer, who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances. 1910.120(a)(3)

11. Definitions Emergency response A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual aid groups, local fire departments, etc.) 1910.120(a)(3)

12. Definitions Incidental release Release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become an emergency. 1910.120(a)(3)

13. Definitions Post emergency response That portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated and clean-up of the site has begun. 1910.120(a)(3)

14. Safety and Health Program Employers shall develop and implement a written safety and health program for their employees involved in hazardous waste operations. 1910.120(b)(1)(i) Safety & Health Program Safety & Health Program

15. Safety and Health Program Program shall incorporate: Organizational structure Comprehensive work plan Site-specific safety and health plan Safety and health training program Medical surveillance program Employer’s standard operating procedures for safety and health Any necessary interface between general program and site-specific program 1910.120(b)(1)(ii)

16. Contractors and subcontractors Shall be informed of: Emergency response procedures Any potential fire, explosion, health, safety or other hazards of the operation Program availability Shall be made available to any contractor or subcontractor Safety and Health Program 1910.120(b)(1)(iv)-(v)

17. Safety and Health Program Organizational structure Elements General supervisor Site safety and health supervisor Other personnel needed for HAZWOPER Lines of authority, responsibility and communication Organizational structure shall be updated as necessary. 1910.120(b)(2)

18. Safety and Health Program Comprehensive workplan shall: Define anticipated clean-up activities Define work tasks and objectives Shall establish personnel requirements Shall provide for the implementation of training Provide for implementation of informational programs Implementation of medical surveillance program 1910.120(b)(3)

19. Safety and Health Program Site-specific safety and health plan Elements Hazard analysis for each site task Employee training assignments Personal protective equipment Used by employees for each site task Medical surveillance requirements Frequency and types of air monitoring Personnel Environmental sampling 1910.120(b)(4)

20. Safety and Health Program Site control measures Site map Work zones Use of buddy system Site communications Safe work practices Identification of nearest medical facilities Decontamination procedures Emergency response plan Confined space entry procedures Spill containment program 1910.120(b)(4)

21. Site Characterization/Analysis Hazardous waste sites shall be evaluated to identify specific site hazards and to determine the appropriate safety and health control procedures needed to protect employees. 1910.120(c)(1)

22. Site Characterization/Analysis Preliminary evaluation Performed prior to site entry Hazard identification Conditions that may pose inhalation or skin absorption hazard that are immediately dangerous to life or health (IDLH) shall be identified. 1910.120(c)(2)-(3)

23. Site Characterization/Analysis Required information Location and approximate size of the site Description of response/job to be performed. Duration of employee activity Site topography and accessibility Expected safety and health hazards Status and capabilities of emergency response teams Expected or involved hazardous substances 1910.120(c)(4)

24. Site Characterization/Analysis Personal protective equipment Shall be provided and used during initial site entry If respiratory protection is warranted, an escape SCBA of at least five minutes shall be carried. Level B PPE shall be provided if sufficient information is not available to identify the hazards. Once hazards identified, the appropriate PPE shall be selected. 1910.120(c)(5)

25. Monitoring 1910.120(c)(6) • Shall be conducted during initial site entry when the site evaluation produces information which shows the potential for ionizing radiation or IDLH conditions, or when the site information is not sufficient reasonably to eliminate these conditions

26. Risk Identification 1910.120(c)(7)+(c)(8) • Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances shall be identified. • Employees who will be working on the site shall be informed of any risks that have been identified.

27. Training Employees shall not be permitted to participate in or supervise field activities until they have been trained to a level required by their job function and responsibility. 1910.120(e)(1)

28. Training Program Elements Names of personnel and alternates responsible for site safety and health Safety, health and other hazards on site Safe use of engineering controls and equipment on site Work practices by which the employee can minimize risks from hazards Use of PPE Medical surveillance requirements Contents of site safety and health plan 1910.120(e)(2)

29. Initial Training General site workers Equipment operators General laborers Supervisory personnel Training Minimum 40 hours off-site Three days field experience—minimum 1910.120(e)(3)(i)

30. Initial Training Workers on-site to complete specific limited tasks Ground water monitoring Land surveying Geophysical surveying On-site workers unlikely to be exposed over permissible exposure limits (PEL) Training Receive 24 hours of instruction off-site One day actual field experience 1910.120(e)(3)(ii)

31. Initial Training Regular on-site workers Exposures under PEL and respirators not required Training Receive 24 hours of instruction off-site One day actual field experience 1910.120(e)(3)(iii)

32. Initial Training Workers with 24 hours of training Who become general site workers or are required to wear respirators Training Receive 16 additional hours of instruction off-site Two days of actual field experience 1910.120(e)(3)(iv)

33. Initial Training Management and supervisors Supervise employees engaged in hazardous waste operations Training Receive 40 hours of instruction off-site Three days of actual field experience 1910.120(e)(4)

34. Initial Training Management and supervisors Training may be reduced to 24 hours and one day if only responsible for: Workers on site occasionally Workers exposures under permissible exposure limits 1910.120(e)(4)

35. Qualifications for Trainers Trainers shall be qualified to instruct employees about the subject matter that is being presented. Instructors shall be competent and knowledgeable in subject matter. Means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer 1910.120(e)(5)

36. Qualifications for Trainers Qualifications shown by academic degrees, completed training courses and/or work experience. OSHA does not certify instructors. 1910.120(e)(5)

37. Training Certification Certification Employees shall be certified by an instructor as having completed the training. Those not certified are prohibited from engaging in hazardous waste operations. Written certificate 1910.120(e)(6)

38. Equivalent Training Employers who can show documentation or certification that an employee has equivalent trainingand/or work experience. Initial training not required Employees new to a site must receive site-specific training before entry. 1910.120(e)(9)

39. Equivalent Training Equivalent training includes any academic training or the training that existing employees might have already received from actual hazardous waste site experience. 1910.120(e)(9)

40. Refresher Training Employees, managers and supervisors shall receive eight hours of refresher training annually. 1910.120(e)(8)

41. Training FAQ Is computer-based training acceptable for refresher training? Standard Interpretation [11/22/1994] - The use of computer-based training to satisfy OSHA training requirements. May meet some refresher training requirements Not sufficient by itself Interpretation

42. Training FAQ What if refresher training isn’t received in 12 months? Standard Interpretation [03/12/1993] - Hazardous waste operations and emergency response lapsed refresher training requirements. If the date of refresher training has lapsed Repeat of initial training must be based on the employee’s familiarity with safety and health procedures used on site. Employee should take next available refresher training course. Interpretation

43. Training FAQ Can refresher training be given in segments? Standard Interpretation [07/21/1992] - Refresher training and HAZWOPER Refresher training may be given in segments so long as the required eight hours have been completed by the employee’s anniversary date. Interpretation

44. Training Records Recordkeeping Should be maintained for a minimum of five years after the training date Appendix E HAZWOPER

45. Medical Surveillance Instituted by the employer for the following employees: Exposed to hazardous substances or health hazards at or above the PEL Employees who wear a respirator 30 days or more a year Employees who are injured, become ill or possible overexposure Members of HAZMAT teams 1910.120(f)

46. Medical Surveillance Medical examinations shall be made available: Prior to assignment At least once every twelve months At termination of employment As soon as possible after notification that employee has developed signs of overexposure More frequently as determined by a doctor At no cost to employee Without loss of pay Reasonable time and place 1910.120(f)

47. Medical Surveillance Physician’s written opinion Employer furnish the employee with a copy of written opinion Whether employee has any medical conditions that place employee at increased risk Recommended limitations on employees assignments Results of medical examination Statement that employee has been informed of results 1910.120(f)(7)

48. Medical Surveillance Records Recordkeeping Employee exposure and medical records (1910.1020) Medical record for each employee shall be preserved and maintained for at least the duration of employment plus 30 years. 1910.120(f)

49. Engineering Controls and Work Practices Engineering controls and work practices are the preferred means to control employee exposure. Instituted to reduce and maintain employee exposure to or below the permissible exposure limits. Employee rotation prohibited except when there is no other way of complying with ionizing radiation dose limits. 1910.120(g)

50. May include: Equipment operated remotely Removing non-essential employees from potential exposure Wetting down dusty operations Locate employees upwind of hazard Engineering Controls and Work Practices 1910.120(g)(1)