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The HASP is limited to OSHA’s HAZWOPER requirements at 29 CFR 1910.120(b) to (o), and therefore, does not apply to treatment, storage, and disposal facilities (TSDFs) licensed under RCRA that are not subject to corrective actions, nor to the emergency responder requirements under section (q) of the standard.
Incorporate adequate site-specific information in the Plan. OSHA reports that the most consistent deficiency in HASPs is a lack of site-specificity in the plans. The HASP must be structured so that it integrates smoothly with those of the site’s coordinator or principal contractor and any applicable local, state, or federal emergency action plan. The up-to-date HASP must be readily available to all employees on the site. It must address the site’s organizational structure, lines of authority, accountability, and communication. It must also specify how the primary employer or site operator will inspect and evaluate the procedures to ensure that they are effective and if found to be ineffective, then how you, the primary employer, or site operator will make corrections.
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Ensure that the person preparing the HASP is a qualified professional. Decisions about the content of the Plan, especially site-specific issues, must be made by a qualified health and safety professional with practical hazardous waste site experience. The person developing the HASP should have the knowledge and skills necessary to identify and evaluate the range of hazards associated with hazardous waste site operations. This individual must also be qualified to identify the appropriate monitoring and exposure controls necessary for employee protection on the basis of the contaminants and other hazards anticipated on-site. For example, only an individual with experience in evaluating potential air contaminants and choosing appropriate instrumentation should select air-monitoring equipment and identify site action limits.
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Update the HASP whenever hazards or safety and health procedures change. Ongoing involvement of other safety and health personnel is also essential. Site conditions and work operations change over time; the health and safety procedures and the HASP must be updated to address these changes as they occur. The involvement of qualified safety and health staff will ease the development and maintenance of the HASP and will help ensure the well-being of your employees.