Hazardous Waste

Operations and

Emergency Response

OSHA 3114-07R 2008
Employers are responsible for providing a safe

and healthy workplace for their employees.

OSHA’s role is to promote the safety and health of

America’s working men and women by setting and

enforcing standards; providing training, outreach

and education; establishing partnerships; and

encouraging continual improvement in workplace

safety and health.

This informational booklet provides a general

overview of a particular topic related to OSHA

standards. It does not alter or determine compliance responsibilities in OSHA standards or the

Occupational Safety and Health Act of 1970.

Because interpretations and enforcement policy

may change over time, you should consult current

OSHA administrative interpretations and decisions

by the Occupational Safety and Health Review

Commission and the courts for additional guidance

on OSHA compliance requirements.

This publication is in the public domain and may be

reproduced, fully or partially, without permission.

Source credit is requested but not required.

This information is available to sensory impaired

individuals upon request. Voice phone: (202) 693-

1999; teletypewriter (TTY) number: (877) 889-5627.

Edwin G. Foulke, Jr.

Assistant Secretary of Labor for

Occupational Safety and Health
U.S. Department of Labor

Occupational Safety and Health Administration

OSHA 3114-07R

2008

Hazardous Waste

Operations and

Emergency Response
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Contents

Introduction...5

Scope and Application...6

Provisions of HAZWOPER for Cleanup Operations...9

Safety and Health Program...9

Organizational Structure...9

ComprehensiveWorkplan...10

Site Characterization and Analysis...10

Health and Safety Plan (HASP)...11

Safety and Health Training Program...13

Medical Surveillance...15

Engineering Controls,Work Practices, and PPE...17

Exposure Monitoring...19

Informational Programs...20

Handling and Labeling Drums and Containers...20

Decontamination Procedures...22

HazardousWaste Site Emergency Response...23

Sanitation of TemporaryWorkplaces...24

New Technology Programs...24

Provisions of HAZWOPER for TSD Facilities...25

Safety and Health Program...25

Hazard Communication Program...25

Medical Surveillance, Decontamination, New

Technology, and Material Handling Programs...26

Training Program...26

TSD Facility Emergency Response...27

Provisions of HAZWOPER for Emergency

Response Operations...28

Emergency Response Plan...29

Procedures for Handling an Emergency Response...29

Training...30

Medical Surveillance...32

PPE...33

Post-Emergency Response Operations...33

Related Requirements...34

Recordkeeping...34

Hazard Communication Standard (HCS)...35

Bloodborne Pathogens Standard (BBP)...35

Other OSHA Standards...36

Other Resources...36

Summary...37

OSHA Assistance...38

OSHA Regional Offices...43
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This guidance document is not a standard or regulation,

and it creates no new legal obligations. The document is

advisory in nature, informational in content, and is intended

to assist employers in providing a safe and healthy workplace. The Occupational Safety and Health Act requires

employers to comply with hazard-specific safety and health

standards promulgated by OSHA or by a State with an

OSHA-approved State Plan. In addition, pursuant to Section

5(a)(1), the General Duty Clause of the Act, employers must

provide their employees with a workplace free from recognized hazards likely to cause death or serious physical

harm. Employers can be cited for violating the General Duty

Clause if there is a recognized hazard and they do not take

reasonable steps to prevent or abate the hazard. However,

failure to implement these recommendations is not, in itself,

a violation of the General Duty Clause. Citations can only be

based on standards, regulations, and the General Duty

Clause.
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ACRONYMS

BBP Bloodborne Pathogens

CERCLA Comprehensive Environmental Response, Compensation,

and Liability Act of 1980

CESQGs Conditionally Exempt Small Quantity Generators

CFR Code of Federal Regulations

DHS Department of Homeland Security

DOT Department of Transportation

EPA Environmental Protection Agency

ERP Emergency Response Plan

HASP Health and Safety Plan

HAZMAT Hazardous Materials

HAZWOPER Hazardous Waste Operations and Emergency Response

HCS Hazard Communication Standard

ICS Incident Command System

IDLH Immediately Dangerous to Life or Health

MSDS Material Safety Data Sheet

NIMS National Incident Management System

NPL National Priority List

OSHA Occupational Safety and Health Administration

PEL Permissible Exposure Limit

PPE Personal Protective Equipment

RCRA Resource Conservation and Recovery Act of 1976

SARA Superfund Amendments and Reauthorization Act of 1986

SCBA Self-contained breathing apparatus

SHARP Safety and Health Achievement Recognition Program

SSP Skilled Support Personnel

TSD Treatment, Storage, and Disposal

TRI Toxic Release Inventory

UST Underground storage tank

VPP Voluntary Protection Programs
Introduction

The dumping of hazardous substances poses a significant threat to

the environment. The U.S. Environmental Protection Agency’s (EPA)

Toxic Release Inventory (TRI) data show that over 18 million tons of

hazardous substances covered by TRI were disposed of or released

into the environment from 1998 through 2004.

1 Hazardous substances are a serious safety and health problem that continues to

endanger human and animal life and environmental quality. Discarded hazardous substances that are toxic, flammable, or corrosive can cause fires, explosions, and pollution of air, water, and

land. Unless hazardous substances are properly treated, stored, or

disposed of, they will continue to do great harm to living things that

contact them, now and in the future.

Because of the seriousness of the safety and health hazards

related to hazardous waste operations and emergency response,

the Occupational Safety and Health Administration (OSHA) issued

its Hazardous Waste Operations and Emergency Response

(HAZWOPER) standard, Title 29 Code of Federal Regulations (CFR)

Parts 1910.120 and 1926.65 (see 54 Federal Register 9294-9336,

March 6, 1989) to protect employees in this environment and to

help them handle hazardous substances safely and effectively.

The HAZWOPER standard for the construction industry, 29 CFR

1926.65, is identical to 29 CFR 1910.120. For brevity, the HAZWOPER

standard is referenced as 1910.120 throughout the remainder of this

publication.

The HAZWOPER standard covers all employers performing the

following three general categories of work operations:

■ Hazardous waste site cleanup operations [paragraphs (b)-(o)]

(e.g., SUPERFUND cleanup),

■ Operations involving hazardous waste that are conducted at

treatment, storage, and disposal (TSD) facilities [paragraph (p)]

(e.g., landfill that accepts hazardous waste), and

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1U.S. Environmental Protection Agency, TRI 2004 Public Data Release

(http://www.epa.gov/tri/tridata/index.htm).
■ Emergency response operations involving hazardous substance

releases [paragraph (q)] (e.g., chemical spill at a manufacturing

plant).

An understanding of how each of these sections are different

from each other and what they apply to is essential to ensure compliance with the appropriate section of HAZWOPER. The scope and

application [paragraphs (a)(1) and (a)(2)] sections of the standard

define these work operations and indicate what sections of the

standard they fall under.

State, county, and municipal employees, including hazardous

waste treatment, storage and disposal facility employees, and first

responders, such as fire and rescue personnel, police, and medical

personnel, are covered by HAZWOPER and other regulations issued

by the 26 states and territories operating their own OSHA-approved

safety and health programs (see listing at the end of this booklet or

visit OSHA’s website at www.osha.gov). EPA HAZWOPER regulations

cover these employees in states without OSHA-approved state plans.

The EPA adopted the HAZWOPER standard at 40 CFR Part 311 for

public employees (either compensated or non-compensated) who

perform operations within the scope of the standard in states that

do not have an OSHA-approved state plan.

This booklet provides an overview of the HAZWOPER requirements for each type of work operation and explains each section

separately to provide a clearer understanding of the standard.

Having this understanding enables employers to protect the health

and safety of their employees in these different environments.

Scope and Application

As briefly discussed in the introduction, HAZWOPER covers three

categories of work operations. First, paragraphs (b)-(o) of the

standard regulate those operations where employees are engaged in

the cleanup of uncontrolled hazardous waste sites. These operations

include those hazardous substance operations under the Comprehensive

Environmental Response, Compensation, and Liability Act of 1980

as amended (CERCLA), including initial investigations at CERCLA

sites before the presence or absence of hazardous substances has

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been determined. Examples of types of uncontrolled hazardous

waste sites that would be covered by HAZWOPER include those:

■ Listed or proposed for listing on the National Priority List (NPL),

■ Listed or proposed for listing on a State priority list,

■ Identified or listed by a governmental agency as an uncontrolled

hazardous waste site (Note: this includes voluntary cleanup

operations), and

■ Regulated as a corrective action covered by the Resource

Conservation and Recovery Act (RCRA).

The second category of work operation is covered by paragraph

(p) and includes those employees engaged in operations involving

hazardous waste TSD facilities regulated under 40 CFR Parts 264

and 265 pursuant to the RCRA. There are certain types of employers

who are exempted from paragraph (p) and these are addressed in

the section covering provisions for TSD facilities.

The third and final work operation category is covered by

paragraph (q) and includes those employees engaged in emergency

response operations for releases of, or substantial threats of releases

of, hazardous substances without regard to the location of the

hazard. Paragraph (q) also includes provisions for post-emergency

response operations, such as performing any necessary cleanup

activity. Table 1 provides a summary of the scope and application

of the standard, including some example work activities.

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Table 1 – Scope and Application of HAZWOPER

Work Operation HAZWOPER Examples of

(Applicable Work Activities

Paragraphs)

Cleanup Operations • Site Characterization of

− Cleanup operations required by a Hazardous Waste Site

governmental body or other operations • Drum Removal

involving hazardous substances that are • Contaminated Soil

conducted at uncontrolled hazardous Removal

waste sites. • Underground Storage

− Corrective actions involving cleanup 1910.120(b)-(o) Tank (UST) Removal

operations at sites covered by RCRA.

− Voluntary cleanup operations at sites

recognized by federal, state, local, or

other governmental bodies as

uncontrolled hazardous waste sites.

Operations atTSD Facilities • Treating Waste for

Operations involving hazardous waste Disposal at RCRA

conducted at TSD facilities regulated by Landfill

40 CFR 264 and 265 pursuant to RCRA 1910.120(p) • Handling Waste at

or by agencies under agreement with RCRA Landfill

the EPA to implement RCRA regulations.

Emergency Response Operations • Response to the spill of

Emergency response operations for a highly toxic substance

releases of, or substantial threats of from overturned 55-

releases of, hazardous substances gallon drum

without regard to the location of the • Response to leaking

hazards. 1910.120(q) storage tank

• Response to overturned

truck carrying hazardous

materials

• Response to chemical

fire
Provisions of HAZWOPER for

Cleanup Operations

Safety and Health Program

An effective and comprehensive safety and health program is

essential in reducing work-related injuries and illnesses and in

maintaining a safe and healthful work environment. The standard,

therefore, requires each employer to develop and implement a

written safety and health program that identifies, evaluates, and

controls safety and health hazards, and provides emergency

response procedures for each hazardous waste site. This written

program must include specific and detailed information on the

following topics:

■ An organizational structure,

■ A comprehensive workplan,

■ A site-specific safety and health plan (often referred to as a

health and safety plan or HASP),

■ A safety and health training program,

■ A medical surveillance program, and

■ Standard operating procedures.

The written safety and health program must be periodically

updated and made available to all affected employees, contractors,

and subcontractors. Necessary coordination between the general

program and site-specific activities also should be included in the

program. The employer also must inform contractors and subcontractors, or their representatives, of any identifiable safety and

health hazards or potential fire or explosion hazards before they

enter the worksite.

Organizational Structure

The organizational structure part of the program establishes the

overall chain of command as well as the roles and responsibilities

assigned to supervisors and employees. The organizational

structure must, at a minimum, include the following elements:

■ A general supervisor with the responsibility and authority to

direct all hazardous waste site operations,

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■ A site safety and health supervisor who develops and implements

the HASP and is responsible for ensuring compliance, and

■ The roles and responsibilities of all the other site personnel

necessary for hazardous waste site operations.

ComprehensiveWorkplan

Planning is the key element in a hazardous waste cleanup program.

Proper planning will greatly reduce employee hazards at hazardous

waste sites. A workplan should support the overall objectives of the

cleanup program and provide procedures for implementation, and

incorporate the employer’s standard operating procedures for safety

and health.

The plan must define the tasks and objectives of site operations

as well as the logistics and resources required to fulfill these tasks.

For example, the following topics must be addressed:

■ The anticipated cleanup and operating procedures,

■ A definition of work tasks and objectives, and methods of

accomplishment,

■ The established personnel requirements for implementing the

plan, and

■ Procedures for implementing training, informational programs,

and medical surveillance requirements.

Site Characterization and Analysis

Site characterization and analysis is the process of identifying

specific site hazards and determining the appropriate safety and

health control procedures necessary to protect site employees.

The more accurate, detailed, and comprehensive the information

available about a site, the more the protective measures can be

tailored to the actual hazards that the employees may encounter.

At each phase of site characterization, information is obtained and

evaluated to define the potential hazards of the site. Much of the

information obtained from the initial site characterization is used in

the development of the site health and safety plan (HASP) required

in 1910.120(b)(4). (Note: the site HASP is addressed further in the

next section.)

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A preliminary evaluation of the site’s characteristics must be

performed prior to site entry. A secondary more detailed evaluation

must be conducted to further identify existing hazards to aid in the

selection of appropriate engineering controls and personal protective equipment (PPE) for future site activities. The evaluation

must include all suspected conditions that are immediately dangerous to life or health (IDLH) or that may cause serious harm to

employees (e.g., confined space entry, potentially explosive or

flammable situations, visible vapor clouds, etc.). As available, the

evaluation must include the location and size of the site, site

topography, site accessibility by air and roads, pathways for

hazardous substances to disperse, a description of employee

duties, and the time needed to perform a given task, as well as the

present status and capabilities of the emergency response teams.

Additional requirements of the site characterization involve the

following:

■ PPE to be used during initial site entry,

■ Exposure monitoring for ionizing radiation and other IDLH

conditions. (Note: An ongoing air monitoring program in

accordance with paragraph (h) of HAZWOPER must be

implemented after site characterization has determined that

it is safe to begin start-up or cleanup operations), and

■ Risk identification based on the presence and concentrations of

hazardous substances and communication of the risks to those

employees who will be working on the site.

Health and Safety Plan (HASP)

A HASP is a critical program element that aids in eliminating or

effectively controlling anticipated safety and health hazards. The

HASP must be unique to the site and address all of the elements

under paragraph (b)(4)(ii), including:

■ Hazard analysis for each site task,

■ Employee training,

■ Personal protective equipment (PPE) to be used by employees

and based on hazard analysis,

■ Medical surveillance,

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■ Exposure monitoring,

■ Site control measures,

■ Decontamination procedures,

■ Emergency response plan,

■ Confined space entry procedures, and

■ Spill containment.

Although some of the above elements are a part of the overall

safety and health program, several others are additional to these

elements and are crucial in developing an effective HASP. For

example, the task hazard analysis may be the most critical

component of the site HASP and addresses the chemical, physical,

and biological hazards associated with each particular task or

operation and the control procedures that protect employees when

they perform that task. Information obtained from the hazard

analysis provides the basis for making important decisions

regarding the selection of PPE, medical monitoring, exposure

monitoring, etc.

It is important to thoroughly address in the HASP how exposure

monitoring will be performed as this is necessary for the protection

of site employees. Critical information includes the frequency and

types of air monitoring, personnel monitoring, environmental

sampling techniques and instrumentation including calibration and

maintenance methods, as well as the interpretation of monitoring

results. For example, there should be established criteria for

determining when to upgrade or downgrade PPE based on

exposure monitoring results.

Another important element of the HASP is site control, which

involves controlling the activities of employees and the movement

of equipment which minimizes potential contamination of employees. Site control also protects the general public from site

hazards and can prevent trespassing and vandalism. The following

information is useful in developing and implementing a site control

program: a site map; site work zones; site communication; safe

work practices; and the name, location, and phone number of the

nearest medical assistance.

The use of a "buddy system" is also required as a protective

measure to assist in the rescue of an employee who becomes

unconscious, trapped, or seriously disabled on site. In the buddy

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system, two employees must keep in visual contact with each other

and only one employee should be in a specific dangerous area at any

one time, so that if one gets in trouble the second can call for help.

The written HASP must be kept at the site and must always be

available for employee, contractor, or subcontractor review. Preentry briefings must be conducted prior to site entry and at other

times as necessary to ensure that employees are aware of the

HASP and its implementation. The employer also must ensure that

periodic safety and health inspections are made of the site and that

all known deficiencies are corrected prior to work at the site.

OSHA has developed an interactive software program (e-HASP2)

that assists employers in developing an appropriate HASP. This

eTool integrates decision logic and a large chemical database to

assist the user in determining appropriate controls for site health

and safety hazards. After site-specific information has been entered,

the program generates reports with “model” language that is

acceptable to OSHA in preparing a site-specific HASP. This eTool

can be found on OSHA’s Hazardous Waste web page.

Safety and Health Training Program

A training program is required under the safety and health program

and is also part of the site HASP. This training must be provided to

all employees who will work on the site such as equipment operators, general laborers, and supervisors or managers who may have

exposure to hazardous substances.

Before performing any work on a hazardous waste site, the

employer must provide its employees with initial training based

on the tasks and operations that employees will perform and the

exposures they are anticipated to experience (see Table 2). Employees

who have “equivalent” experience and skills from previous work

experience and/or training would not have to receive the initial

training provided that the employer can verify it through documentation or certification. Equivalently trained employees who are new to a

site must still receive site-specific training before site entry.

Training makes employees aware of the potential hazards they

may encounter and provides the necessary knowledge and skills

to perform their work with minimal risk to their own, and other

employees’, safety and health. Both supervisors and employees

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must be trained to recognize hazards and to prevent them; to

select, care for, and use respirators properly, as well as other types

of PPE; to understand engineering controls and their use; to use

proper decontamination procedures; to understand the emergency

response plan, medical surveillance requirements, confined space

entry procedures, spill containment program, and any appropriate

work practices. Employees also must know the names of personnel

and their alternates responsible for site safety and health. Site

personnel who are expected to respond to emergency situations at

the site must receive additional training in how to respond to

anticipated emergencies (e.g., fires/explosions, hazardous spills, etc.).

Table 2 –Training Requirements – HazardousWaste Cleanup Operations

Workers [1910.120(e)(3)]

• General site employees (e.g., equipment 40 hours initial training

operators, general laborers, etc.) 24 hours supervised field experience

[1910.120(e)(3)(i)] 8 hours annual refresher

• Employees occasionally on site for a 24 hours initial training

limited task (e.g., groundwater 8 hours supervised field experience

monitoring, land surveying, etc.) 8 hours annual refresher

with minimal exposure [1910.120(e)(3)(ii)]

• Employees regularly on site who are 24 hours initial training

not exposed to health hazards 8 hours supervised field experience

[1910.120(e)(3)(iii)] 8 hours annual refresher

• Employees under (e)(3)(ii) or (iii) who 16 hours of additional training

become general site workers under 16 hours of additional supervised

(e)(3)(i) [(e)(3)(iv)] field experience

Supervisors/Managers [1910.120(e)(4)]

• Supervisors of general site employees 40 hours initial training

(e.g., equipment operators, general 24 hours supervised field experience

laborers, etc.) 8 hours of specialized training in employer’s

safety and health-related programs

8 hours annual refresher

• Supervisors of employees occasionally on 24 hours initial training

site for a limited task (e.g., groundwater 8 hours supervised field experience

monitoring, land surveying, etc.) with 8 hours specialized training in employer’s

minimal exposure safety and health-related programs

8 hours annual refresher

• Supervisors of employees regularly on 24 hours initial training

site who are not exposed to health 8 hours supervised field experience

hazards 8 hours specialized training in employer’s

safety and health-related programs

8 hours annual refresher
Employees at all sites must not perform any hazardous waste

operations unless they have been trained to the level required by

their job function and responsibility, and have been certified by a

qualified trainer as having completed the necessary training.

Employees who receive the specified training must receive a

written certificate upon successful completion of that training. That

training need not be repeated if the employee goes to work at a

new site; however, the employee must receive the necessary

additional site-specific training needed to work safely at the new

site. All employees must receive 8 hours of annual refresher

training as indicated in Table 2.

It is critically important for a portion of the training program to

include hands-on experience and exercises to provide trainees with

an opportunity to become familiar with equipment and safe

practices in a non-hazardous setting. Traditional hands-on training

is the preferred method to ensure that employees are prepared to

safely perform these tasks. The purpose of hands-on training, for

example, in the donning and doffing of PPE, is twofold: first, to

ensure that employees have an opportunity to learn by experience,

and second, to assess whether they have mastered the necessary

skills.

Note: Non-mandatory Appendices C and E to HAZWOPER

provide useful compliance guidelines and assistance in developing

a site-specific training curriculum used to meet the training requirements in paragraph (e) of the standard.

Medical Surveillance

A medical surveillance program is required under the overall safety

and health program and is also part of the site HASP. This program

helps to assess and monitor the health and fitness of employees

working with hazardous substances. The employer must establish a

medical surveillance program for the following:

■ All employees exposed or potentially exposed to hazardous

substances or health hazards above permissible exposure limits

(PELs) (or above published exposure levels if there is no PEL) for

more than 30 days per year,

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■ Employees who wear a respirator for 30 days or more per year

on site or as required by 1910.134,

■ Employees who are exposed to unexpected or emergency

releases of hazardous wastes above exposure limits (without

wearing appropriate protective equipment) or who show signs,

symptoms, or illness that may have resulted from exposure to

hazardous substances, and

■ Employees responsible for responding to on-site hazardous

materials (HAZMAT) releases (i.e., on-site HAZMAT team).

All examinations must be performed by or under the supervision of a licensed physician, without cost to the employee,

without loss of pay, and at a reasonable time and place. Examinations must include a medical and work history with special

emphasis on symptoms related to the handling of hazardous

substances and health hazards and to fitness for duty, including

the ability to wear any required PPE under conditions that may be

expected at the worksite. These examinations must be given as

follows:

■ Prior to job assignment and annually thereafter (or every 2 years

if a physician determines that interval is appropriate),

■ At the termination of employment or reassignment to an area

where medical examinations are not required,

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■ As soon as possible for employees injured or who become ill

from exposure to hazardous substances during an emergency,

or who develop signs or symptoms of overexposure from

hazardous substances, and

■ At more frequent times if the examining physician believes that

an increased frequency is medically necessary.

The employer must give the examining physician a copy of the

standard and its appendices, a description of the employee’s duties

relating to his or her exposures, the exposure levels or anticipated

exposure levels, a description of any personal protective and

respiratory equipment used or to be used, and any information

from previous medical examinations. The employer must obtain a

written opinion from the physician that contains the results of the

medical examination and any detected medical conditions that

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2 If the employee has not had an examination within the last 6 months.
would place the employee at an increased risk from exposure, any

recommended limitations on the employee or upon the use of PPE,

and a statement that the employee has been informed by the

physician of the medical examination. The physician is not to

reveal, in the written opinion given to the employer, specific

findings or diagnoses unrelated to employment.

Employers should be aware that there are medical surveillance

requirements in other OSHA substance-specific standards that may

be applicable for individual sites where these hazardous substances

are present (e.g., lead, asbestos, and benzene). These substancespecific standards are included under 29 CFR Part 1910 Subpart Z –

Toxic and Hazardous Substances.

Engineering Controls, Work Practices, and PPE

To the extent feasible, the employer must institute engineering

controls and work practices to help reduce and maintain employee

exposure to or below permissible exposure limits. To the extent this

is not feasible, engineering and work practice controls may be supplemented with PPE. Examples of suitable and feasible engineering

controls include the use of pressurized cabs or control booths on

equipment and/or remotely operated material handling equipment.

Examples of safe work practices include removing all non-essential

employees from potential exposure while opening drums, wetting

down dusty operations, and placing employees upwind of potential

hazards.

When engineering controls and work practices are not sufficient

to reduce employee exposures to or below established exposure

limits or are not feasible for site operation, employers must provide

employees with and require the use of PPE. The HAZWOPER

standard further requires the employer to develop a written PPE

program for all employees involved in hazardous waste operations.

This program is required under the overall safety and health

program and the PPE to be used by employees for each of the site

tasks and operations being conducted must be included in the

HASP. The PPE program must include an explanation of equipment

selection and use, maintenance and storage, decontamination and

disposal, training and proper fit, donning and doffing procedures,

inspection, in-use monitoring, program evaluation, and equipment

limitations.

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PPE typically includes respiratory protection, dermal protection

(e.g., gloves and protective clothing), eye protection (e.g., safety

glasses, goggles, and face shields), and foot protection (e.g., steeltoed boots and chemical-resistant booties). Employers must select

and ensure that employees use PPE in accordance with 29 CFR Part

1910, Subpart I. PPE at hazardous waste sites is often identified as a

level of protection and frequently referred to as level A, B, C, or D.

Non-mandatory Appendix B to HAZWOPER provides guidelines for

selecting PPE and further discusses the levels of protection. The

bullets below summarize each level of protection.

■ Level A provides the greatest level of skin, respiratory, and eye

protection (e.g., totally-encapsulating chemical protective suit

with self-contained breathing apparatus (SCBA)),

■ Level B provides the greatest level of respiratory protection, but

a lesser level of skin protection than Level A (e.g., chemicalresistant clothing with SCBA),

■ Level C provides skin protection, but a lesser level of respiratory

protection than Level B (e.g., chemical-resistant clothing with airpurifying respirator), and

■ Level D provides only minimal protection for nuisance contamination only (e.g., general coveralls, hard hat, safety glasses, and

boots).

The level of PPE, including the type of material that the components are made from, will depend on the types of hazardous

substances present, their concentrations, the physical requirements

of the task, the duration of the task, environmental conditions (e.g.,

heat stress), and the needs of the user (e.g., dexterity). These

factors may be different for each site task or operation, which is

why HAZWOPER requires that PPE be evaluated for each task and

not for the site as a whole. In addition, hazardous conditions can

quickly change, requiring a modification (e.g., upgrading or

downgrading) to the level and type of PPE to provide the protection

needed for the new conditions. For example, a backhoe hitting a

pocket of contaminated soil can result in elevated chemical concentrations requiring a possible upgrade to the level of PPE. When

conditions exist that create the possibility of immediate death,

immediate serious injury or illness, or impairment of escape,

employees must be provided with the highest level of PPE. If the
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hazard is due to a chemical that poses an inhalation hazard, then a

positive pressure SCBA or positive pressure air-line respirator must

be used. If a chemical poses a severe skin hazard or is highly toxic

and can be readily absorbed through the skin, then appropriate

protective clothing (e.g., totally-encapsulating suit) must be worn.

In contrast, it is just as important to know when to downgrade

the level and type of PPE through exposure monitoring. Wearing

too much PPE increases certain hazards such as heat stress, physical

and psychological stress, and can impair vision, mobility and communication.

Exposure Monitoring

Airborne contaminants can present a significant threat to employee

safety and health, thus making air monitoring an important component of an effective safety and health program. The employer

must conduct monitoring during the initial site entry at uncontrolled

hazardous waste sites to identify conditions that are IDLH, exposures over PELs or other published exposure levels, exposures

over a radioactive material’s dose limits, or other dangerous

conditions, such as the presence of flammable atmospheres or

oxygen-deficient atmospheres. Accurate information on the identification and quantification of airborne contaminants is useful for the

following:

■ Indicating work areas and identifying tasks and operations

where exposure controls are needed,

■ Selecting PPE,

■ Assessing the potential health effects of exposure, and

■ Determining the need for specific medical monitoring.

After a hazardous waste cleanup operation begins, the employer

must periodically monitor those employees who are likely to have

higher exposures to determine if they have been exposed to

hazardous substances in excess of permissible exposure limits. The

employer also must monitor for any potential condition that is IDLH

or for exposures over PELs or other published exposure levels since

prior monitoring. Situations when periodic monitoring is required

include the following:

■ Work begins on a different portion of the site,
■ New contaminants are being handled,

■ Different type of operation is initiated, and

■ Handling leaking drums or working in areas

with obvious liquid contamination.

Informational Programs

As part of the overall safety and health program in paragraph (b) of

the standard, employers must develop and implement a program

that informs employees, contractors, and subcontractors of the

nature, level, and degree of exposure from performing hazardous

waste cleanup operations (Note: this requirement is typically addressed through initial and refresher training under paragraph (e)

of the standard). Those employees who are working outside of the

cleanup operations (e.g., clerical staff who work on the periphery

of the site) and there is no reasonable possibility for employee

exposure to safety or health hazards are not covered by the

standard.

Handling and Labeling Drums and Containers

The handling of hazardous substance-containing drums and containers presents a variety of potential health and safety hazards to

employees such as fires/explosions, vapor generation, and physical

injury caused by moving heavy containers by hand. As a result,

employers must ensure that appropriate methods, procedures, and

equipment are in place that address at least the following:

■ Drums and containers used during the cleanup must meet the

required OSHA, EPA (40 CFR Parts 264-265 and 300), and

Department of Transportation (DOT) regulations (49 CFR Parts

171-178), and must be properly inspected and labeled,

■ Damaged drums or containers that may rupture or spill when

moved must be emptied of their contents using a device

classified for the material being transferred, and must be

properly discarded,

■ In areas where spills, leaks, or ruptures may occur, the employer

must furnish employees with salvage drums or containers, an

adequate quantity of absorbent material, and approved fireextinguishing equipment in the event of small fires,

20
■ The employer must inform employees of the appropriate hazard

warnings for labeled drums, the removal of soil or coverings,

and the dangers of handling unlabeled drums or containers

without prior identification of their contents,

■ To the extent feasible, the moving of drums or containers must

be kept to a minimum, and a program must be implemented to

contain and isolate hazardous substances being transferred into

drums or containers, and

■ Ground penetrating systems or other detection devices must be

used to estimate the location and depth of buried drums and

containers.

The employer also must ensure that safe work practices are

instituted before opening a drum or container. For example, air-line

respirators and approved electrical equipment must be protected

from possible contamination, and all equipment must be kept behind

any existing explosion barrier.

3

Only tools or equipment that prevent ignition shall be used. All

employees not performing the operation shall be located at a safe

distance and behind a suitable barrier to protect them from accidental explosions. In addition, standing on or working from drums

or containers is prohibited. Special care also must be taken when

an employee handles containers of shock-sensitive waste, explosive

materials, or laboratory waste packs. When shock-sensitive wastes

are handled, the employer must ensure the following:

■ Evacuate non-essential employees from the transfer area,

■ Protect equipment operators from exploding containers by using

a barrier, and

■ Make available a continuous means of communication (e.g.,

suitable radios or telephones), and a distinguishable and distinct

alarm system to signal the beginning and end of activities where

explosive wastes are handled.

If drums or containers bulge or swell or show crystalline material

on the outside, they must not be moved onto or from the site unless

appropriate containment procedures have been implemented. In

21

3A physical barricade, natural or man-made, that has been designed and constructed

of sufficient thickness and density to withstand or deflect the impact loads of an

adjacent explosion.
addition, lab packs must be opened only when necessary and only by

a qualified person. Prior to shipment to a licensed disposal facility, all

drums or containers must be properly labeled and packaged for

shipment. Staging areas also must be kept to a minimum and

provided with adequate access and exit routes.

Decontamination Procedures

Decontamination procedures are a component of the site HASP

and, consequently, must be developed, communicated to employees, and implemented before employees enter a hazardous

waste site. As necessary, the site safety and health officer must

require and monitor decontamination of the employee and decontamination or disposal of the employee’s clothing and equipment,

as well as the substances used for decontamination, before the

employee leaves the work area. If an employee’s non-impermeable

clothing becomes grossly contaminated with hazardous substances,

the employee must immediately remove that clothing and take a

shower. Impermeable protective clothing must be decontaminated

before being removed by the employee.

Protective clothing and equipment must be decontaminated,

cleaned, laundered, maintained, or replaced to retain its effectiveness. The employer must inform anyone who launders or cleans

such clothing or equipment of the potentially harmful effects of

exposure to hazardous substances.

Employees who are required to shower must be provided

showers and change rooms that meet the requirements of 29

CFR 1910.141, Subpart J – General Environmental Controls.

(Note: HAZWOPER requires showers and change rooms when a

hazardous waste cleanup operation will take six months or longer

to complete). In addition, unauthorized employees must not remove

their protective clothing or equipment from change rooms unless

authorized to do so.

Note: Chapter 10 of the Occupational Safety and Health

Guidance Manual for Hazardous Waste Site Activities (“4-Agency

Manual”) provides more information on decontamination procedures; Appendix D of the manual offers example decontamination layouts for levels A, B, and C.

22
Hazardous Waste Site Emergency Response

Proper emergency planning and response are important elements

of the site HASP that help minimize employee exposure and injury.

The standard requires that the employer develop and implement a

written emergency response plan to handle possible emergencies

before performing hazardous waste site operations. Employers who

will evacuate their employees from the worksite location when an

emergency occurs and who do not permit any of their employees

to assist in handling the emergency are exempt from developing

an emergency response plan. These employers must, however,

develop an emergency action plan complying with 29 CFR 1910.38

to ensure the safe evacuation of personnel.

Employers that require site personnel to respond to site emergencies

must develop a written emergency response plan that includes the

following elements:

■ Personnel roles, lines of authority, and communication

procedures,

■ Pre-emergency planning,

■ Emergency recognition and prevention,

■ Emergency medical and first-aid treatment,

■ Methods or procedures for alerting on-site employees,

■ Safe distances and places of refuge,

■ Site security and control,

■ Decontamination procedures,

■ Critique of response and follow-up,

■ Personal protective and emergency equipment, and

■ Evacuation routes and procedures.

In addition to the above requirements, the plan must include site

topography, layout, prevailing weather conditions, and procedures

for reporting incidents to local, state, and federal government

agencies. The procedures must be compatible with and integrated

into the disaster, fire, and/or emergency response plans of the site’s

nearest local, state, and federal agencies.

The plan requirements also must be rehearsed regularly, reviewed periodically, and amended, as necessary, to keep them

current with new or changing site conditions or information. A dis23
tinguishable and distinct alarm system must be in operation to

notify employees of emergencies. The emergency plan also must

be made available for inspection and copying by employees, their

representatives, OSHA personnel, and other government agencies

with relevant responsibilities.

When deemed necessary, employees must wear a positivepressure self-contained breathing apparatus or a positive pressure

air-line respirator equipped with an escape air supply. In addition,

backup and first-aid support personnel must be available for

assistance or rescue.

Sanitation of Temporary Workplaces

Each temporary worksite must have a supply of potable water

(suitable for drinking) that is stored in tightly closed and clearly

labeled containers and equipped with a tap. Disposable cups and a

receptacle for cup disposal also must be provided. The employer

also must clearly mark all water outlets that are unsafe for drinking,

washing, or cooking. Temporary worksites must be equipped with

toilet facilities.

When sleeping quarters are provided, they must be heated. In

addition, washing facilities for all employees must be near the

worksite, within controlled work zones,

4 and equipped to enable

employees to remove hazardous substances. The employer also

must ensure that food service facilities are licensed.

New Technology Programs

New technology for improving the protection of employees on

worksites must be evaluated and implemented by employers.

Examples of such equipment may include new foams, absorbents,

adsorbents, and neutralizers that can be used to decrease the level

of exposures to hazardous substances. It is important that new

technologies, equipment, or control measures be evaluated by the

employer to determine the effectiveness of employee protection

before being implemented on site. Manufacturer and supplier

information should be reviewed by the employer as part of the

evaluation.

24

4A designated work area within the worksite.
Provisions of HAZWOPER for TSD Facilities

Safety and Health Program

The standard requires the employer at covered TSD facilities to

develop and implement a written safety and health program for

employees involved in hazardous waste operations at the facility.

The program must be designed to identify, evaluate, and control

safety and health hazards in the facility for the purpose of employee

protection. It must also include emergency response procedures

that meet the requirements of paragraph 1910.120(p)(8), discussed

below. Further, the written program must address appropriate site

analysis, engineering controls, maximum exposure limits, hazardous waste handling procedures, and uses of new technologies.

As conditions or operations change at a TSD facility, reevaluations

should be periodically conducted and necessary updates made to

the safety and health program.

Note that employers who are conditionally exempt small

quantity (hazardous waste) generators (CESQGs) under 40 CFR

261.5 and other (waste) generators who are qualified under 40 CFR

262.34 for exemptions (“excepted employers”) do not have to

comply with paragraphs (p)(1) – (p)(7), but do have to follow the

emergency response provisions under (p)(8). Excepted employers

have the option of evacuating their employees from the facility

under (p)(8)(i) unless the EPA or a state agency requires that those

employees perform emergency response.

Hazard Communication Program

An effective hazard communication program is a key element required

of TSD facilities. The employer must develop a hazard communication

program, including providing proper labeling of chemicals, access to

material safety data sheets (MSDSs), and appropriate employee

training in accordance with OSHA’s Hazard Communication standard

(HCS), 29 CFR 1910.1200. Hazardous wastes are specifically excluded

from the HCS and, therefore, do not have to be included in the TSD’s

hazard communication program. Other hazardous “non-waste”

chemicals to which employees may be exposed at the facility must be

included. For example, any neutralizer or other chemical that meets

the definition of a hazardous chemical and that is brought on site to

25
treat or process hazardous waste would be required to be included in

the TSD facility’s hazard communication program.

Medical Surveillance, Decontamination, New

Technology, and Material Handling Programs

TSD facilities are also required to implement some of the same requirements specified for hazardous waste sites. Paragraph (p) of HAZWOPER

references several sections within paragraphs (b)-(o) as follows:

■ Medical surveillance program 1910.120(p)(3) references

1910.120(f),

■ Decontamination program 1910.120(p)(4) references 1910.120(k),

■ New technology program 1910.120(p)(5) references 1910.120(o),

and

■ Material handling program 1910.120(p)(6) references

1910.120(j)(1)(ii) through (viii), (xi), (j)(3), and (j)(8).

See the discussion of these requirements earlier in this publication.

Training Program

Employers must develop a training program as part of the overall

safety and health program for employees who are exposed to

health hazards or hazardous substances at TSD operations. This

program must ensure that employees are properly trained to

perform their assigned duties and functions in a safe and healthful

manner so as not to endanger themselves or other employees.

Paragraph (p)(7) distinguishes between new employees and current employees with respect to required training, as indicated in

Table 3. Site personnel who are expected to respond to emergencies

at the TSD site must receive additional training. This training is

discussed under TSD Facility Emergency Response, below.

26

Table 3 –Training Requirements –TSD Facilities

• New employees 24 hours initial training

[1910.120(p)(7)(i)] 8 hours annual refresher

• Current employees Proven previous equivalent training or

[1910.120(p)(7)(ii)] experience or 24 hours initial training

8 hours annual refresher
27

Employees must not perform any operations involving exposure

to health hazards or hazardous substances at a TSD facility unless

they have been trained by a competent trainer to the level required

by their job function and responsibility. New employees must also

receive a certificate showing that they have completed the necessary

training.

TSD Facility Emergency Response

The standard requires that a TSD facility develop and implement a

written emergency response plan in accordance with paragraph

(p)(8) as part of their safety and health program to handle possible

emergencies at the facility. Employers who will evacuate their

employees from the facility when an emergency occurs and who

do not permit any of their employees to assist in handling the

emergency are exempt from developing an emergency response

plan and from the training requirements of paragraph (p)(8). These

employers must, however, develop an emergency action plan and

ensure that the training of site personnel is consistent with 29 CFR

1910.38.

Employers that require TSD employees to respond to site emergencies must develop a written emergency response plan that

includes the following elements:

■ Pre-emergency planning and coordination with outside parties,

■ Personnel roles, lines of authority, training and communication,

■ Emergency recognition and prevention,

■ Safe distances and places of refuge,

■ Site security and control,

■ Evacuation routes and procedures,

■ Decontamination procedures,

■ Emergency medical treatment and first aid,

■ Emergency alerting and response procedures,

■ Critique of response and follow-up, and

■ PPE and emergency equipment.

If a TSD facility has an emergency response plan required by 40

CFR 264 and 265, containing all of the elements above, a separate

written plan will not be required.
28

The employer must periodically review the facility’s emergency

response plan and update it as necessary to reflect new or changing

site conditions or information.

Employees of TSD facilities who are expected to perform

emergency response must be properly trained prior to responding

to emergencies. The training must cover the employer’s emergency

response plan, standard operating procedures, appropriate PPE, and

procedures for handling an emergency response. The employer must

also document the employee’s completion of training or certify the

employee’s competency.

Provisions of HAZWOPER for Emergency

Response Operations

As previously discussed, paragraph (q) of HAZWOPER applies to

releases of, or substantial threats of releases of, hazardous

substances without regard to their location. (Note: Except

emergency response on hazardous waste sites is covered by

paragraph (l) and emergency response on TSD facilities is covered

by paragraph (p)(8)). Covered employees generally include first

responders, such as HAZMAT team members, fire and rescue

personnel, police, and medical personnel who may respond to

emergency releases.

Note that paragraph (q) does not apply to “incidental releases”

of hazardous substances, which are releases that do not pose a

significant safety or health hazard to employees in the immediate

vicinity or to the employees cleaning it up. Incidental releases are

limited in quantity, exposure potential, or toxicity and present

minor safety or health hazards to employees in the immediate work

area or those assigned to clean them up. An example may include

a laboratory pint-size container that does not pose a significant

safety and health threat at that volume. Conversely, a release of

chlorine gas above the IDLH level, obscuring visibility and moving

through a facility, is an example of a release requiring an emergency

response under paragraph (q). In many cases, releases may be

incidental or require an emergency response depending on the

circumstances of the release (e.g., toxicity and volume of the

substance, training and experience of employees in the immediate

area, availability of response equipment and PPE, etc.).
29

Emergency Response Plan

A written emergency response plan (ERP) must be developed and

implemented prior to allowing or permitting an employee response

to a hazardous substance release. The plan must cover reasonably

anticipated worst-case scenarios. In facilities where the employer

has chosen to evacuate employees in the case of an emergency

and the employer does not permit any of their employees to assist

in handling the emergency, the employer is exempt from paragraph

(q) and does not need to develop an emergency response plan.

These employers must, however, develop an emergency action

plan for the safe evacuation of personnel and ensure that the

training of employees is consistent with 29 CFR 1910.38.

Employers that require employees to respond to emergencies

must develop a written emergency response plan that includes the

following elements:

■ Pre-emergency planning and coordination with outside parties,

■ Personnel roles, lines of authority, training, and communication,

■ Emergency recognition and prevention,

■ Safe distances and places of refuge,

■ Site security and control,

■ Evacuation routes and procedures,

■ Decontamination,

■ Emergency medical treatment and first aid,

■ Emergency alerting and response procedures,

■ Critique of response and follow-up, and

■ PPE and emergency equipment.

Employers may use the local emergency response plan, or the

state emergency response plan, if the above elements are covered,

as part of their emergency response plan. Those items of the local

and/or state emergency response plans that are addressed by Title III

of the Superfund Amendments and Reauthorization Act of 1986

(SARA) may be included in the employer’s emergency plan for the

employer’s and employees’ use.

Procedures for Handling an Emergency Response

HAZWOPER requires the implementation of an incident command

system (ICS) for responses to an emergency release of hazardous
30

substances. The ICS is a widely accepted approach to effectively

organize, control, and manage operations at an emergency

incident. The individual in charge of the ICS is the senior official

responding to the incident who oversees the coordination, direction,

and actions of the response operations. All site communications are

routed through the ICS and the senior official. Ultimately, the implementation of the ICS helps to reduce confusion, improve safety,

organize and coordinate actions, and facilitates the effective

management of the incident.

Compliance with the ICS, as defined by the National Incident

Management System (NIMS), is consistent with compliance with

using an ICS under this section of HAZWOPER. NIMS was

published by the Department of Homeland Security (DHS) on

March 1, 2004. The NIMS provides a consistent nationwide

template for incident management that allows responders to work

together more effectively. The NIMS adopts the ICS, including

operating characteristics, interactive management components, and

structure of incident management and emergency response organizations engaged throughout the life cycle of an incident.

The standard requires additional specific procedures for

response operations. It requires the individual in charge (i.e.,

Incident Commander) of the ICS to evaluate site conditions and

implement appropriate response operations, hazard controls, and

PPE. A safety officer must be designated to provide direction and

assistance to ensure the safety of response operations. It also

requires that personnel in the area of the incident and related

hazards be limited to those actively performing emergency

response operations and that backup personnel stand by with

appropriate equipment to provide assistance or rescue.

Training

Emergency responders must be trained prior to their participation

in emergency response operations and their training must be based

on the functions and duties the responders will be expected to

perform. For example, if an employee is simply expected to notify

the emergency response team upon discovery of an emergency

release and evacuate from the area, the employee would be trained

to the first responder awareness level; or if an employee who is

responding initially in a defensive manner for the purpose of

protecting nearby persons, property, or the environment from the
31

effects of the release, but does not approach the point of release,

the employee would be trained to the first responder operations

level. If, however, the employee is expected to approach the point

of release for the purpose of stopping the release, the employee

would minimally need to be trained to the HAZMAT technician

level. If an employee is expected to have more direct and specific

knowledge of the various hazardous substances and to assist the

HAZMAT technician in the response, the employee would minimally

need to be trained to the HAZMAT specialist level. Consequently,

employers must evaluate the roles and tasks that employees will

perform and train them appropriately.

In addition to the training levels established in the standard for

emergency responders, two additional personnel classifications are

provided: skilled support personnel (SSP) and specialist employees.

SSP are employees who are needed to temporarily perform immediate emergency support work (e.g., excavator operators). SSP

must be provided an initial site briefing covering PPE use, the

chemical hazards involved, and the tasks to be performed. Specialist

employees are those who, in the course of their regular job duties,

work with and are trained in the hazards of specific hazardous

substances. They may be called upon to provide technical advice or

assistance at a hazardous substance release incident.

SSP and specialist employees are covered in paragraphs (q)(4)

and (q)(5) of HAZWOPER. Required training and competencies for

emergency responders is covered in paragraph (q)(6) and trainer

qualifications is covered in paragraph (q)(7). Refresher training is

covered in paragraph (q)(8) of the standard (see Table 4).

Trainers who teach any of the training subjects must have either

completed a training course on the subjects they are expected to

Table 4 –Training Requirements – Emergency Response Operations

Emergency Responders [1910.120(q)(6)]

• First Responder Awareness Level Sufficient initial training and

(Witnesses or discovers a release of competencies

hazardous substances and is trained to Annual refresher

notify the proper authorities)

• First Responder Operations Level 8 hours initial training and

(Responds to the releases of hazardous competencies

substances in a defensive manner, Annual refresher

without trying to stop the release)
32

teach or they must have the training and/or academic credentials

and instructional experience to demonstrate competent teaching

skills. In addition, employees need not necessarily receive a

certificate, but the employer must certify training with some form of

documentation. (Note: the HAZWOPER standard does not contain a

specific certification requirement for Awareness Level training). It is

considered good practice to provide employees with a training

certificate as well as to document the training in the employer’s

records. The employer also must document in its ERP its training

plan for personnel who respond to hazardous substance incidents.

Medical Surveillance

Members of organized and designated HAZMAT teams and

HAZMAT specialists must receive a baseline physical examination

and medical surveillance in accordance with 1910.120(f). (Note: see

the previous discussion on medical surveillance at 1910.120(f)). The

examinations must be provided prior to initial assignment, at least

yearly thereafter, and at termination of employment. The medical

examination must include a medical and work history with the

actual content of medical examinations to be determined by the

attending physician.

• Hazardous Materials Technician 24 hours initial training and competencies

(Responds aggressively to stop the Annual refresher

release of hazardous substances)

• Hazardous Materials Specialist 24 hours initial training and competencies

(Responds with and in support of Annual refresher

HAZMAT technicians, but who have

specific knowledge of various hazardous

substances)

• On Scene Incident Commander 24 hours initial training and competencies

(Assumes control of the incident scene Annual refresher

beyond the first responder awareness

level)

Other Employees [1910.120(q)(4)-(q)(5)]

• Skilled Support Personnel Safety and health briefing at

(temporarily perform immediate response site

emergency support work)

• Specialist Employees Annual demonstration of

(provide technical advice/assistance specialized competencies

on specific hazardous substances)
33

Medical consultations must also be provided in cases where

employees are injured or develop signs or symptoms of overexposure to health hazards. Consultations must be provided as soon

as possible following an incident, and also at additional times if

the physician determines that it is necessary. Similar to examinations, the content of consultations is determined by the attending

physician.

PPE

Designated HAZMAT team members and hazardous materials

specialists must be provided with the appropriate protective

clothing and other necessary equipment. Furthermore, employers

must ensure that paragraphs (g)(3)-(g)(5) of HAZWOPER are

followed, which cover the requirements for PPE selection, totallyencapsulating chemical protective suits, and the PPE program.

(Note: see the previous discussion on PPE at 1910.120(g)).

Post-Emergency Response Operations

After an emergency release, it is often necessary to transition from

an emergency response operation to a hazardous substances

cleanup operation. In such cases, post-emergency cleanup begins

when the individual in charge of the emergency response declares

the site to be under control and ready for cleanup. The postemergency cleanup can be performed by two basic groups of

employees: employees of the site where the emergency release

occurred or employees from off the site.

Employees of the site who perform post-emergency cleanup on

plant property are employees that are typically more familiar with

the types of hazardous substances of the site, site conditions, and

methods to appropriately protect themselves from the related

hazards. As a result, these employees do not need to be trained in

accordance with 1910.120(e). However, these employees do have to

complete the training required by 1910.38, 1910.134, 1910.1200, and

other appropriate safety and health training made necessary by the

tasks they are expected to perform during the cleanup.

Employees who do not work at the facility where the release

occurred, and who arrive after the emergency is declared to be

over, must meet the requirements of 1910.120(b)-(o) and be trained

in accordance with 1910.120(e). In other words, their participation in
34

the post-emergency cleanup is to be treated as hazardous waste

site cleanup operations as discussed earlier in this publication. The

HAZWOPER standard does, however, allow emergency responders,

trained in accordance with 1910.120(q)(6), who took part in the initial

emergency response to continue working through the cleanup

operation without any additional training.

Related Requirements

Recordkeeping

In 1988, OSHA revised the standard requiring employers to provide

employees with information to assist in the management of their

own safety and health. The standard, Access to Employee Exposure

and Medical Records (29 CFR 1910.1020), permits direct access to

these records by employees exposed to hazardous materials, or by

their designated representatives, and by OSHA.

The employer must keep exposure records for 30 years and

medical records for at least the duration of employment plus 30

years. Records of employees who have worked for less than 1 year

need not be retained after employment, but the employer must

provide these records to the employee upon termination of

employment. First-aid records of one-time treatment need not be

retained for any specified period. Employers should be aware that

OSHA’s substance-specific standards under 29 CFR Part 1910

Subpart Z – Toxic and Hazardous Substances may have their own

record-retention requirements and these would take precedence

over 1910.1020.

The employer must inform each employee of the existence,

location, and availability of these records. Whenever an employer

plans to stop doing business and there is no successor employer

to receive and maintain these records, the employer must notify

employees of their right to access these records at least 3 months

before the employer ceases to do business. At the same time,

employers also must notify the National Institute for Occupational

Safety and Health.

Under paragraph (f)(8) of HAZWOPER, at a minimum, medical

records must include the following information:

■ Employee’s name and social security number,
35

■ Physicians’ written opinions,

■ Employee’s medical complaints related to exposure to

hazardous substances, and

■ Information provided to the treating physician.

Hazard Communication Standard (HCS)

Title III of SARA requires employers covered by the Hazard

Communication standard (29 CFR 1910.1200) to maintain material

safety data sheets (MSDSs) and submit such information to state

emergency response commissions, local emergency planning

committees, and the local fire department. Under this requirement,

employers covered by HCS must provide chemical hazard

information to both employees and surrounding communities.

Consequently, in the case of an emergency response to hazardous

substances at a site, the local fire department may already be

aware of the chemicals present at the site since data may have

been provided through MSDSs.

Bloodborne Pathogens Standard (BBP)

The Bloodborne Pathogens standard (29 CFR 1910.1030) may

interface with HAZWOPER in several scenarios, including, but not

limited to, cleanup of a hazardous waste site containing infectious

waste, operation of a RCRA-permitted incinerator that burns

infectious waste, and response to an emergency caused by the

uncontrolled release of infectious waste or where infectious waste

is part of the release.

A specific example includes first-aid providers on a hazardous

waste site who are expected to treat injured employees. Because

these personnel have an anticipated exposure to blood or other

potentially infectious materials, they would fall under the scope of

the standard. (Note: other potentially infectious materials is defined

in paragraph (b) of the BBP standard.)

Some basic requirements of the BBP standard include:

■ A written exposure control plan, to be updated annually,

■ Use of universal precautions,

■ Consideration, implementation, and use of safer needle devices,
36

■ Use of engineering and work practice controls and appropriate

PPE (e.g., gloves, face and eye protection, gowns, etc.),

■ Hepatitis B vaccination provided to exposed employees at no

cost,

■ Medical follow-up in the event of an “exposure incident,”

■ Use of labels or color-coding for items such as sharps disposal

containers and containers for regulated waste, contaminated

laundry, and certain specimens,

■ Employee training, and

■ Proper containment of all sharps and regulated waste.

Other OSHA Standards

In addition to the related OSHA standards above, there are many

other OSHA standards that can interface with HAZWOPER depending on the specific hazards on the site and the types of work

being performed. A few of these other standards may include:

■ 29 CFR 1910.146 (Permit-Required Confined Spaces),

■ 29 CFR 1910.147 (Control of Hazardous Energy

[Lockout/Tagout]),

■ 29 CFR Part 1910 Subpart Z (Toxic and Hazardous Substances),

and

■ 29 CFR Part 1926 Subpart P (Excavations)

Other Resources

■ OSHA, Hazardous Waste Safety and Health Topics web page,

http://www.osha.gov/SLTC/hazardouswaste/index.html;

■ OSHA, Emergency Preparedness and Response Safety and

Health Topics webpage, http://www.osha.gov/SLTC/emergencypreparedness/index.html;

■ OSHA, Brownfields Safety and Health Topics webpage,

http://www.osha.gov/SLTC/brownfields/index.html;

■ OSHA, e-HASP2 eTool,

http://www.osha.gov/dep/etools/ehasp/index.html;

■ OSHA, Occupational Safety and Health Guidance Manual for

Hazardous Waste Site Activities (“4-Agency Manual”),
37

http://www.osha.gov/Publications/complinks/OSHGHazWaste/4agency.html; and

■ OSHA, ICS eTool,

http://www.osha.gov/SLTC/etools/ics/index.html.

Summary

Hazardous substances, when not handled properly, can pose a

significant health and safety risk to employees. OSHA recognizes

the need to protect the health and safety of employees who are

exposed to these substances and work on hazardous waste sites or

at TSD facilities, and who perform emergency response. The

HAZWOPER standard provides employers and employees with the

information and training criteria necessary to improve workplace

health and safety, thereby reducing the number of injuries and

illnesses resulting from exposure to hazardous substances. To

effectively protect the health and safety of employees, it is critical

that employers understand the scope and application of the

standard and can determine which sections apply to their specific

scenario. For example, hazards generated from an explosion at a

chemical plant are very different from those existing on a hazardous

waste site where site conditions are more controlled and hazards

have been more fully identified. The purpose of this publication is

to provide an understanding of how HAZWOPER applies to

different work environments, and to address the related requirements for those worksites.
38

OSHA Assistance

OSHA can provide extensive help through a variety of programs,

including technical assistance about effective safety and health

programs, state plans, workplace consultations, voluntary protection

programs, strategic partnerships, training and education, and more.

An overall commitment to workplace safety and health can add

value to your business, to your workplace, and to your life.

Safety and Health Program Management Guidelines

Effective management of employee safety and health protection is

a decisive factor in reducing the extent and severity of work-related

injuries and illnesses and their related costs. In fact, an effective

safety and health program forms the basis of good employee

protection, can save time and money, increase productivity and

reduce employee injuries, illnesses, and related workers’ compensation costs.

To assist employers and employees in developing effective

safety and health programs, OSHA published recommended Safety

and Health Program Management Guidelines (54 Federal Register

(16): 3904-3916, January 26, 1989). These voluntary guidelines can

be applied to all places of employment covered by OSHA.

The guidelines identify four general elements critical to the

development of a successful safety and health management

system:

■ Management leadership and employee involvement,

■ Worksite analysis,

■ Hazard prevention and control, and

■ Safety and health training.

The guidelines recommend specific actions, under each of

these general elements, to achieve an effective safety and health

program. The Federal Register notice is available online at

www.osha.gov.

State Programs

The Occupational Safety and Health Act of 1970 (OSH Act)

encourages states to develop and operate their own job safety and
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health plans. OSHA approves and monitors these plans. Twentyfour states, Puerto Rico, and the Virgin Islands currently operate

approved state plans: 22 cover both private and public (state and

local government) employment; Connecticut, New Jersey, New

York, and the Virgin Islands cover the public sector only. States and

territories with their own OSHA-approved occupational safety and

health plans must adopt standards identical to, or at least as

effective as, the Federal OSHA standards.

Consultation Services

Consultation assistance is available on request to employers who

want help in establishing and maintaining a safe and healthful

workplace. Largely funded by OSHA, the service is provided at

no cost to the employer. Primarily developed for smaller

employers with more hazardous operations, the consultation

service is delivered by state governments employing professional safety and health consultants. Comprehensive assistance

includes an appraisal of all mechanical systems, work practices,

and occupational safety and health hazards of the workplace and

all aspects of the employer’s present job safety and health

program. In addition, the service offers assistance to employers

in developing and implementing an effective safety and health

program. No penalties are proposed or citations issued for

hazards identified by the consultant. OSHA provides consultation

assistance to the employer with the assurance that his or her

name and firm and any information about the workplace will not

be routinely reported to OSHA enforcement staff.

Under the consultation program, certain exemplary employers

may request participation in OSHA’s Safety and Health Achievement

Recognition Program (SHARP). Eligibility for participation in SHARP

includes receiving a comprehensive consultation visit, demonstrating exemplary achievements in workplace safety and health by

abating all identified hazards, and developing an excellent safety

and health program.

Employers accepted into SHARP may receive an exemption

from programmed inspections (not complaint or accident investigation inspections) for a period of 1 year. For more information

concerning consultation assistance, see OSHA’s website at

www.osha.gov.
40

Voluntary Protection Programs (VPP)

Voluntary Protection Programs and on-site consultation services,

when coupled with an effective enforcement program, expand

employee protection to help meet the goals of the OSH Act. The

VPPs motivate others to achieve excellent safety and health results

in the same outstanding way as they establish a cooperative relationship between employers, employees, and OSHA.

For additional information on VPP and how to apply, contact the

OSHA regional offices listed at the end of this publication.

Strategic Partnership Program

OSHA’s Strategic Partnership Program, the newest member of

OSHA’s cooperative programs, helps encourage, assist, and

recognize the efforts of partners to eliminate serious workplace

hazards and achieve a high level of employee safety and health.

Whereas OSHA’s Consultation Program and VPP entail one-onone relationships between OSHA and individual worksites, most

strategic partnerships seek to have a broader impact by building

cooperative relationships with groups of employers and employees.

These partnerships are voluntary, cooperative relationships

between OSHA, employers, employee representatives, and

others (e.g., trade unions, trade and professional associations,

universities, and other government agencies).

For more information on this and other cooperative programs,

contact your nearest OSHA office, or visit OSHA’s website at

www.osha.gov.

Alliance Program

Through the Alliance Program, OSHA works with groups

committed to safety and health, including businesses, trade or

professional organizations, unions and educational institutions,

to leverage resources and expertise to develop compliance

assistance tools and resources and share information with

employers and employees to help prevent injuries, illnesses and

fatalities in the workplace.

Alliance program agreements have been established with a wide

variety of industries including meat, apparel, poultry, steel, plastics,

maritime, printing, chemical, construction, paper and telecommunications. These agreements are addressing many safety and health
41

hazards and at-risk audiences, including silica, fall protection,

amputations, immigrant workers, youth and small businesses. By

meeting the goals of the Alliance Program agreements (training

and education, outreach and communication, and promoting the

national dialogue on workplace safety and health), OSHA and the

Alliance Program participants are developing and disseminating

compliance assistance information and resources for employers

and employees such as electronic assistance tools, fact sheets,

toolbox talks, and training programs.

OSHA Training and Education

OSHA area offices offer a variety of information services, such as

compliance assistance, technical advice, publications, audiovisual

aids, and speakers for special engagements. OSHA’s Training

Institute in Arlington Heights, IL, provides basic and advanced

courses in safety and health for Federal and state compliance

officers, state consultants, Federal agency personnel, and private

sector employers, employees, and their representatives.

The OSHA Training Institute also has established OSHA Training

Institute Education Centers to address the increased demand for its

courses from the private sector and from other federal agencies.

These centers include colleges, universities, and nonprofit training

organizations that have been selected after a competition for participation in the program.

OSHA also provides funds to nonprofit organizations, through

grants, to conduct workplace training and education in subjects

where OSHA believes there is a lack of workplace training. Grants

are awarded annually. Grant recipients are expected to contribute

20 percent of the total grant cost.

For more information on training and education, contact the

OSHA Training Institute, Directorate of Training and Education, 2020

South Arlington Heights Road, Arlington Heights, IL, 60005, (847)

297-4810, or see Training on OSHA’s website at www.osha.gov. For

further information on any OSHA program, contact your nearest

OSHA regional office listed at the end of this publication.

Information Available Electronically

OSHA has a variety of materials and tools available on its website

at www.osha.gov. These include electronic compliance assistance
42

tools, such as Safety and HealthTopics Pages, eTools, Expert

Advisors; regulations, directives, publications and videos; and other

information for employers and employees. OSHA’s software

programs and compliance assistance tools walk you through

challenging safety and health issues and common problems to find

the best solutions for your workplace.

A wide variety of OSHA materials, including standards, interpretations, directives, and more can be purchased on CD-ROM from

the U.S. Government Printing Office, Superintendent of Documents,

toll-free phone (866) 512-1800.

OSHA Publications

OSHA has an extensive publications program. For a listing of free

items, visit OSHA’s website at www.osha.gov or contact the

OSHA Publications Office, U.S. Department of Labor, 200

Constitution Avenue, NW, N-3101, Washington, DC 20210;

telephone (202) 693-1888 or fax to (202) 693-2498.

Contacting OSHA

To report an emergency, file a complaint, or seek OSHA advice,

assistance, or products, call (800) 321-OSHA or contact your nearest

OSHA Regional office listed at the end of this publication. The teletypewriter (TTY) number is (877) 889-5627.

Written correspondence can be mailed to the nearest OSHA

Regional or Area Office listed at the end of this publication or to

OSHA’s national office at: U.S. Department of Labor, Occupational

Safety and Health Administration, 200 Constitution Avenue, N.W.,

Washington, DC 20210.

By visiting OSHA’s website at www.osha.gov, you can also:

■ File a complaint online,

■ Submit general inquiries about workplace safety and health

electronically, and

■ Find more information about OSHA and occupational safety and

health.
43

OSHA Regional Offices

* These states and territories operate their own OSHA-approved job

safety and health programs and cover state and local government

employees as well as private sector employees. The Connecticut, New

Jersey, New York and Virgin Islands plans cover public employees only.

States with approved programs must have standards that are identical to,

or at least as effective as, the Federal OSHA standards.

Note: To get contact information for OSHA Area Offices, OSHAapproved State Plans and OSHA Consultation Projects, please visit us

online at www.osha.gov or call us at 1-800-321-0SHA.

Region I

(CT,* ME, MA, NH, RI, VT*)

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860

Region II

(NJ,* NY,* PR,* VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378

Region III

(DE, DC, MD,* PA, VA,* WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900

Region IV

(AL, FL, GA, KY,* MS, NC,* SC,* TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(404) 562-2300

Region V

(lL, IN,* MI,* MN,* OH, WI)

230 South Dearborn Street

Room 3244

Chicago, IL 60604

(312) 353-2220

Region VI

(AR, LA, NM,* OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145

Region VII

(IA,* KS, MO, NE)

Two Pershing Square

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745

Region VIII

(CO, MT, NO, SO, UT,* WY*)

1999 Broadway, Suite 1690

PO Box 46550

Denver, CO 80202-5716

(720) 264-6550

Region IX

(AZ,* CA,* HI,* NV,* and American

Samoa, Guam and the Northern

Mariana Islands)

90 7th Street, Suite 18-100

San Francisco, CA 94103

(415) 625-2547

Region X

(AK,* ID, OR,* WA*)

1111 Third Avenue, Suite 715

Seattle, WA 98101-3212

(206) 553-5930