7 Elements of a Compliant HAZWOPER S&H Program

OSHA rules say that HAZWOPER (hazardous waste operations and emergency response) safety and health programs must incorporate the following elements:

1. Organizational structure
2. Comprehensive work plan
3. Site-Specific Safety and Health Plan (SSAHP)
4. Safety and health training
5. Medical surveillance
6. Standard operating procedures (SOPs) for safety and health
7. Interface between general site conditions and site-specific activities

Written programs must be made available to all contractors and subcontractors or their representatives, employees and their representatives, OSHA personnel, and personnel of any other government agency with regulatory authority at the worksite.

Organizational Structure

Health and safety program organizational structure must show how a chain of command is established, specify responsibilities of supervisors and employees, and establish a clear line of authority and communication necessary to ensure the implementation and enforcement of safety and health rules.

The structure must include:

• The name of a general supervisor with the authority to direct all operations at the site
• The name of site safety and health supervisor(s) with authority to develop and implement the site safety and health plan and verify compliance
• An explanation of the general functions and responsibilities of all personnel involved in site operations and emergency response, including contractors and subcontractors
• Lines of authority, responsibility, and communication, including clear lines of authority between contractors and subcontractors
• Periodic updates to the program as necessary to reflect changes in site operations or conditions that will affect safety and health

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Comprehensive Work Plan

The comprehensive work plan part of the program defines the tasks and objectives of site operations and resources needed to meet goals. It must address anticipated cleanup activities and normal operating procedures.

The work plan will also define work tasks, identify the methods for accomplishing the tasks, establish personnel requirements for implementing the plan, and provide for implementation of training, informational, and medical surveillance programs.

SSAHP

An SSAHP must be incorporated into the safety and health program and must address the safety and health hazards of each phase of the site operation and include the requirements and procedures for employee protection.

This plan aids in eliminating or effectively controlling anticipated safety and health hazards and gives attention to the unique characteristics of the particular site. The plan must be kept at the worksite.

The SSAHP must incorporate:

• A detailed safety and health risk or hazard analysis for each site task and operation
• SOPs derived from the health risk or hazard analysis that identifies the site locations where hazards are likely to occur, and specify the appropriate types of PPE and control methods for each task to protect workers and the environment
• Employee training assignments
• PPE to be used by employees for each of the site tasks and operations being conducted as required by the PPE program
• Medical surveillance
• Frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instrumentation to be used, including methods of maintenance and calibration of monitoring and sampling equipment to be used

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• Site control measures in accordance with the site control program
• Decontamination procedures
• An emergency response plan that meets regulatory requirements for safe and effective responses to emergencies, including the necessary PPE and other equipment
• Confined space entry procedures
• A spill containment program
• Preentry briefings to be held before initiating any site activity, and whenever necessary to ensure that employees are apprised of the site safety and health plan and that this plan is being followed
• Inspections conducted by the site safety and health supervisor or, in the absence of that individual, another individual who is knowledgeable in occupational safety and health, acting on behalf of the employer as necessary to determine the effectiveness of the site safety and health plan

If there is more than one SSAHP (that is, if each contractor develops its own), the plans must be integrated and enforced consistently to ensure that all personnel understand health and safety expectations, lines of authority, and emergency response actions.