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1995-01-22
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INFORMATION DATE 19890626
DESCRIPTION USDOL Program Highlights, Hazard Waste Operations
SUBJECT Hazardous Waste Operations and Emergency Response
U.S. Department of Labor
Program Highlights
Fact Sheet No. OSHA 89-31
HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE
SCOPE
Employees involved in:
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;
Operations involving hazardous wastes that are conducted at treatment,
storage and disposal facilities licensed under RCRA;
Emergency response operations for release of, or substantial threats
of release of, hazardous substances.
Exceptions are permitted if the employer can demonstrate that the
operation does not involve employee exposure or a reasonable possibility of
such exposure to hazards.
GENERAL REQUIREMENTS
A. Development by each hazardous waste site employer of a safety and
health program designed to identify, evaluate, and control safety and
health hazards, and provide for emergency response.
B. A preliminary evaluation of the site's characteristics prior to
entry by a trained person to identify potential site hazards and to aid in
the selection of appropriate employee protection methods. Included would
be all suspected conditions immediately dangerous to life or health, or
which may cause serious harm.
C. Implementation of a site control program contamination of
employees. At a minimum it must have a site map, site work zones, site
communications, safe work practices and identification of the nearest
medical assistance. Also required is the use of a "buddy system" as a
protective measure in particularly hazardous situations so that employees
can keep watch on one another to provide quick aid if needed.
D. Training of employees before they are allowed to engage in
hazardous waste operations or emergency response that could expose them to
safety and health hazards. However, experienced workers will be allowed to
continue operations and then be given refresher courses when appropriate.
Specific training requirements are listed for clean-up personnel, equipment
operators, general laborers and supervisory employees and for various
levels of emergency response personnel. Persons completing specific
training for hazardous waste operations shall be certified; those not
certified nor with proper experience shall be prohibited from engaging in
those operations specified by the standard. (See additional details in
this fact sheet.)
E. Medical Surveillance at least annually and at the end of
employment for all employees exposed to any particular hazardous substance
at or above established exposure levels and/or those who wear approved
respirators for 30 days or more on site. Such surveillance also will be
conducted if a worker is exposed by unexpected or emergency releases.
F. Engineering controls, work practices and personal protective
equipment, or a combination of these methods, must be implemented to reduce
exposure below established exposure levels for the hazardous substance
involved.
G. Air monitoring to identify and quantify levels of hazardous
substances with periodic monitoring to assure that proper protective
equipment is being used.
H. An informational program with the names of key personnel and their
alternates responsible for site safety and health; and the listing of these
requirements of the standard.
I. Implementation of a decontamination procedure before any employee
or equipment may leave an area of potential hazardous exposure; operating
procedures to minimize exposure through contact with exposed equipment,
other employees, or used clothing; and showers and change rooms where
needed.
J. An emergency response plan to handle possible on-site emergencies
prior to beginning hazardous waste operations. Such plans must address:
personnel roles; lines of authority, training and communications; emergency
recognition and prevention; safe places of refuge; site security;
evacuation routes and procedures; emergency medical treatment; and
emergency alerting.
K. An off-site emergency response plan to better coordinate emergency
action by the local services and to implement appropriate control action.
TRAINING REQUIREMENTS
Training requirements will vary with the type of operation involved.
The various operations and their dependent training requirements are:
--Uncontrolled hazardous waste operations mandated by various levels
of government. These workers must have 40 hours of initial training before
entering a site and at least three days of actual field experience under a
trained, experienced supervisor. Employees visiting the site occasionally
need only 24 hours of prior training and one day of supervised field
experience. Managers and supervisors directly responsible for clean-up
operations must have an additional eight hours of specialized training in
waste management. Annual refresher training of eight hours is required for
regular site workers and the managers.
--Sites licensed under RCRA. Employees must have 24 hours of training
plus eight hours of annual refresher training.
--Emergency response operations at other than RCRA sites or
uncontrolled hazardous waste site clean-ups. Different levels of initial
training are required depending on the duties and functions of each
responder plus demonstrated competence or annual refresher training
sufficient to maintain competence.
(1) First responders at the "awareness level" (individuals likely to
witness or discover a hazardous substance release and initiate the
emergency response) must demonstrate competency in such areas as
recognizing the presence of hazardous materials in an emergency, the risks
involved, and the role they should perform.
(2) First responders at the "operations level" (individuals who
respond for the purpose of protecting property, persons, or the nearby
environment without actually trying to stop the release) must have eight
hours of training plus "awareness level" competency or demonstrate
competence in their role.
(3) Hazardous materials technicians (individuals who respond to stop
the release) must have 24 hours of training equal to the "operations level"
and demonstrate competence in several specific areas.
(4) Hazardous materials specialists (those who support the
technicians but require a more specific knowledge of the substances to be
contained) must have 24 hours of training equal to the technical level and
demonstrate competence in certain areas.
(5) On-scene incident commanders (who assume control of the incident
scene beyond the "awareness level" and demonstrate competence in specific
areas.
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This is one of a series of fact sheets highlighting U.S. Department of
Labor programs. It is intended as a general description only
and does not carry the force of legal opinion.