Hazardous Waste Management

Basic Elements of a HAZWOPER Health and Safety Plan

6. Monitoring (29 CFR 1910.120(h))

Since site monitoring data are the basis for selecting many of your exposure controls, generating accurate and complete data is critical and must be addressed in HASP. Your HASP must identify how often monitoring will be conducted and the method and equipment for each contaminant. HAZWOPER requires monitoring during initial site entry (see #1 from yesterday’s Advisor) and periodic monitoring during site operations.

Periodic monitoring must be conducted when there is the possibility of an immediately dangerous to life or health (IDLH) condition, a flammable atmosphere, or when employee exposures may have risen above published values (Occupational Safety and Health Administration (OSHA) permissible exposure limits (PELs), National Institute for Occupational Safety and Health (NIOSH) RELs, ACGIH TLVs®) since prior monitoring). For example, periodic monitoring must be conducted when:

  • Site conditions change (new tasks, locations, or hazards).
  • New operations are started (such as drum opening after exploratory drilling).
  • Leaky containers are handled.
  • Work is conducted in areas with obvious liquid contamination.

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You must monitor the breathing zones of employees who have the highest potential exposure(s). If their exposures meet or exceed published values, you must monitor all employees likely to be exposed over those published limits. Your HASP must also indicate the airborne concentrations at which you reevaluate your site’s engineering controls, work practices, and personal protective equipment (PPE).

Calibration and maintenance schedules, as per manufacturers’ recommendations, should also be maintained. You must take lab-analyzed samples and compare your real-time readings to the laboratory results. You may want to consult with an accredited laboratory to determine proper analytical sampling procedures. Results of personal sampling are considered employee exposure records.

7. Handling Drums and Containers (29 CFR 1910.120(j))

If you have drums or containers on your site (buried or aboveground) and you plan to move them, you must (1) inspect them BEFORE movement, (2) move them sparingly, and (3) stage them carefully. If drums or containers could create a major spill, you also need to develop a spill containment program. Employees inspecting drums must evaluate the integrity of the container. Employees should also locate and interpret important label information and assume the worst if a label does not exist. Drums in staging areas should be arranged to allow employees easy access and egress. Drum opening and sampling operations must be isolated if the contents are unknown. If spills, leaks, or ruptures may occur, you must provide proper training and containment equipment to personnel who will control and contain spilled material. You also must stock equipment such as salvage drums or containers, absorbent material, shovels, and PPE for spill response. All containers transported off-site must have proper Department of Transportation (DOT) labels, bills of lading, etc.

Shock-sensitive wastes must be treated with special precautions, including evacuating all nonessential employees. There must be the availability of continuous communications between the employee in charge of the handling area, the site health and safety supervisor, and the command post. Any container or drum showing signs of pressure buildup, such as bulging or swelling, cannot be moved until the source of the pressure is found and relieved. Lab waste packs must be opened only when necessary and only by knowledgeable personnel. If crystalline material is found in the lab pack(s), it must be treated as shock-sensitive material until proven otherwise. Tanks and vaults containing hazardous substances must be handled similar to drums and containers, taking into account the size of the tank or vault. If tanks or vaults will be entered, appropriate entry procedures must be identified in HASP and be followed by employees conducting the entry.

8. Decontamination (29 CFR 1910.120(k))

Decontamination procedures address how employees’ contact with contaminants or contaminated equipment (including PPE) will be minimized. Your HASP must include written decontamination procedures that address this goal, eliminate the movement of contaminants to clean areas, and prevent mixing of incompatible substances. Decontamination procedures must be appropriate for the contaminants present, for the equipment, and PPE used on-site. In addition, you must evaluate the effectiveness of the decontamination procedures you implement. One way to evaluate your procedures is to collect samples from key surfaces and analyze them for site contaminants. Samples should be collected from the surfaces of decontaminated reusable PPE, heavy equipment, and “clean” areas such as break and changing rooms.

Your HASP should also identify how disposable PPE and site decontamination waste will be discarded and how reusable PPE will be cleaned and placed back in service. If you use a commercial laundry or cleaners, they must be informed of the potential effects of the hazardous substances.

9. Emergency Response by Employees at Uncontrolled Hazardous Waste Sites (29 CFR 1910.120(l))

You must have a written emergency response plan (ERP) that identifies the actions employees will take if fire, personal injury, chemical release, or other emergencies occur on the site. The items needed to be included in your ERP are listed in paragraphs (l)(2) and (l)(3) of HAZWOPER. The ERP must be tested and critiqued regularly.

If your plan is to rely on local emergency response organizations such as the fire department, you must contact them and explain your response needs. If they cannot provide the services you need, you must retain a service provider who can. Even if you have an on-site hazmat team, you must coordinate your ERP with the local response plan, including incident reporting procedures. The ERP must contain information on the following topics:

  • Personnel roles, lines of authority, training, and communication
  • Employee recognition and prevention of emergencies
  • Safe distances and places of refuge
  • Site security and control in the event of an emergency
  • Evacuation routes and procedures, including site topography, layout, and prevailing weather conditions
  • Emergency decontamination procedures not covered elsewhere in HASP
  • Emergency alerting and response procedures, including PPE and emergency equipment

Rather than an ERP, you may also choose to evacuate your employees and follow an emergency action plan developed in accordance with 1910.38(a). Choosing this option requires that you provide an emergency action plan and integrate the plan with the local response plan as a separate part of your HASP.


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10. Illumination and Sanitation at Temporary Workplaces (29 CFR 1910.120s(m) and 29 CFR 1910.120s(n))

You must provide suitable lighting, potable water, and toilet facilities. When work operations are expected to exceed 6 months, you must also provide showers and change rooms. Site illumination levels must meet the minimum illumination levels provided in Table H-120.1 in paragraph (m). Adequate potable water with proper dispensers must be maintained on-site. Showers and change rooms must meet OSHA requirements in the Sanitation standard at 29 CFR 1910.141. Site water sources must be labeled as either potable or nonpotable. Adequate toilet and hand-washing facilities must also be provided.

11. New Technology Programs (29 CFR 1910.120(o))

OSHA requires that you have procedures for evaluating technological innovations that could provide more effective protection to your employees. Manufacturers’ literature can be a useful source of information. Before you implement the use of new technologies, equipment, or control measures on a large scale, however, ensure that they offer the protection you anticipate.