The best way to determine which occupational

hazards exist at such a site is to conduct a job hazard analysis for each task. A job hazard analysis

combines employee exposure information with

equipment and procedural information and results

in a list of chemical and physical hazards associated with each task. When the employer has identified the hazards that may be present and that

could result in employee exposure, it can find the

applicable OSHA standards designed to protect its

employees.

Common hazards experienced during site assessment and cleanup work at Brownfield sites

include:

• Chemical hazards from surface or subsurface soil

contamination or from contaminants present in

buildings or containers (e.g., drums, underground storage tanks, confined spaces)

• Heat stress hazards

• Fall hazards from elevated work surfaces

• Slip, cave-in, and fall hazards from trenches and

excavations

• Noise hazards

• Electrical hazards

• Hazards from heavy equipment, handheld tools,

and other construction or demolition-related

activities.

Applicable OSHA Standards

All OSHA general industry and construction standards (29 CFR 1910 and 1926) may apply to work

at Brownfield sites, depending on the type of work

performed and the hazards to which employees

may be exposed. (Requirements may differ in

states with OSHA-approved State Plans).

Potentially applicable standards include, but are

not limited to: Personal Protective Equipment (29

CFR 1910.132/1926.28), Respiratory Protection (29

CFR 1910.134/1926.103), Air Contaminants (29 CFR

1910.1000/1926.55), Hazard Communication (29

CFR 1910.1200/1926.59), Hand Tools (29 CFR

Brownfield Sites

In general, a “Brownfield site”, as defined in the

Small Business Liability Relief and Brownfields

Revitalization Act (SBLRBR), is real property, the

expansion, redevelopment or reuse of which may

be complicated by the presence or potential presence of a hazardous substance, pollutant, or contaminant. Brownfield sites are generally not highly

contaminated, however, the types and levels of

contaminants present can vary considerably.

When contaminants are present, they may be

located in surface soil, buildings, containers

(drums, underground tanks), subsurface soil, and

groundwater aquifers. The types of contaminants

present will depends on the industry or commercial facility that previously operated on the site. In

addition to chemical exposure, the potential hazards at a Brownfield site may resemble those

found on a construction site.

The SBLRBR describes certain properties that are

specifically included and excluded from the definition of a “Brownfield site.” That law, and if necessary an EPA office or state environmental agency,

should be consulted to determine if a particular

site is a Brownfield. In general, a key characteristic

of a Brownfield site is that it is targeted for redevelopment. The site is not necessarily contaminated, but it is not assumed to be “clean” because of

its prior commercial or industrial use.

Identifying Hazards Commonly Found at

Brownfield Sites

Generally, Brownfield sites are not likely to cause

immediate or serious health effects to individuals

living or working around them, but they may pose

serious safety or health hazards for employees

working on the sites. The kind of work involved

will determine the types of exposures found. For

instance, an employee doing site cleanup, as

opposed to one performing a site assessment, will

likely experience higher levels and longer durations of exposure.

FactSheet

Brownfield Site Cleanup and

Redevelopment
This is one in a series of informational fact sheets highlighting OSHA programs, policies or

standards. It does not impose any new compliance requirements. For a comprehensive list of

compliance requirements of OSHA standards or regulations, refer to Title 29 of the Code of Federal

Regulations. This information will be made available to sensory impaired individuals upon request.

The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.

U.S. Department of Labor

www.osha.gov

(800) 321-OSHA

For more complete information:

DEP 4/2008

1926.301), Fall Protection (29 CFR 1926 Subpart M),

and Excavations (29 CFR 1926 Subpart P).

OSHA’s Hazardous Waste Operations and

Emergency Response (HAZWOPER) standard (29

CFR 1910.120 and 1926.65) may apply if the work

to be done includes:

• Cleanup operations required by a governmental

body involving hazardous substances which are

conducted at an uncontrolled hazardous waste

site.

• Corrective actions involving cleanup operations

at sites covered by the Resource Conservation

and Recovery Act of 1976.

• Voluntary cleanup operations at sites recognized

by a governmental body as an uncontrolled hazardous waste site.

Cleanup operations are defined in paragraph (a)(3)

of the HAZWOPER standard to include operations

where hazardous substances are removed, contained, stabilized or processed in order to make the

site safer for people or the environment.

Please note that even if operations performed at a

Brownfield site are not covered by the HAZWOPER

standard, other federal and state government programs (e.g., a funding contract or a state voluntary

clean up program) may require HAZWOPER compliance.

Contents of a Written Health and

Safety Plan (HASP)

If OSHA’s HAZWOPER standard applies, the

employer must prepare a site-specific HASP which

addresses the safety and health hazards, control

measures, and work tasks of each phase of site

operation and includes requirements and procedures for employee protection. It must be kept on

site while work is being conducted and revised as

site personnel, conditions, and work tasks change.

A HASP includes site-specific information on the

following:

• Site characterization and hazard analysis

• Site control measures

• Personal protective equipment for site tasks and

operations

• Employee training

• Monitoring and sampling

• Medical surveillance

• Decontamination procedures

• Emergency response

• Spill containment

• Confined space entry (if applicable)

Employers whose operations are not covered by

the HAZWOPER standard may still want to address

site safety and health with a written HASP that

records hazards, identifies applicable OSHA standards, and recommends appropriate exposure

controls.

For further information on Brownfields, please visit

OSHA’s Brownfields Safety and Health Topics page

at http://www.osha.gov/SLTC/brownfields/

index.html. Also visit the Environmental Protection

Agency’s (EPA) Brownfields site at http://www.epa.

gov/brownfields/index.html.