Hazardous Waste Management

11 Requirements Your HAZWOPER Plan May Be Missing

HASP is limited to the Occupational Safety and Health Administration’s (OSHA) HAZWOPER requirements at 29 CFR 1910.120(b)-(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.

Following is a section-by-section explanation of the basic elements that should be included in your facility’s HASP:

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1. Site Characterization and Analysis (29 CFR 1910.120(c))

Initial site characterization and analysis must be performed by a qualified person in order to choose and justify engineering controls, work practices, and personal protective equipment (PPE). The qualified person should examine historical data and the work plan to anticipate site conditions and then identify appropriate PPE and monitoring procedures. At the outset, site evaluations may be limited to conditions that:

  • Are immediately dangerous to life or health (IDLH).
  • Exceed published exposure levels (e.g., OSHA permissible exposure limits (PELs), ACGIH TLVs®, National Institute for Occupational Safety and Health (NIOSH) RELs).
  • Indicate exposure over radioactive dose limits (see 10 CFR 20).
  • Are otherwise dangerous conditions, including but not limited to the presence of flammable or oxygen-deficient atmospheres.

Historical data and known site processes should be used to identify potential chemical and physical hazards. After work begins, you must continue to evaluate conditions, update your hazard analysis, and choose appropriate controls, work practices, and PPE (see #5). Exposure controls and monitoring instruments (see #5) must be based on an up-to-date characterization and hazard analysis.

2. Site Control (29 CFR 1910.120(d))

Site control procedures should identify contaminated areas and appropriate work practices, address preventing unauthorized or unprotected workers from entering contaminated areas, and define controlling the migration of site contaminants. Your HASP must delineate work zones and establish safe work and communication procedures for each zone. It must contain a site map that shows work zone boundaries and identify how these boundaries will be visibly marked on the site. These boundaries may change as work operations change or if hazards migrate to clean areas. HASP must identify your method for controlling entry into contaminated areas, restricting this to authorized employees who are properly trained and protected. Employees entering contaminated zones must follow the work procedures in HASP, including using the buddy system. To enable a quick response, emergency medical information, including the name of and route to the nearest medical facility, must be posted in the contamination reduction or support zone. Emergency communication procedures must be written and explained to employees.

3. Training (29 CFR 1910.120(e)) and Information Programs (29 CFR 1910.120 (i))

Your employees must be trained to do their assigned duties safely before they begin work on-site. The required training, described in 29 CFR 1910.120(e), is a combination of classroom instruction, site-specific information, and supervised fieldwork. You can send your workers to an outside training organization for their classroom instruction, but you are ultimately responsible for ensuring that your employees are properly trained. The hours of initial training vary depending on an employee’s duties and anticipated exposures. Initial training must be updated with 8 hours of refresher training annually. You are also required by 29 CFR 1910.120(i) to inform employees and contractors of the types and level of hazards associated with operations.

Nonmandatory Appendix E provides training criteria and content guidance. Your HASP must identify which jobs require training, how much training is needed, and how all of the training requirements in 29 CFR 1910.120(e) are fulfilled. The location and maintenance of training documentation and certification must also be identified. In addition to the training requirements, your HASP must also document how information about changes in site-specific information is communicated to interested parties, including employees, contractors, etc. Each worker, however, must have 8 hours of refresher training annually.

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4. Medical Surveillance (29 CFR 1910.120(f))

If your employees are exposed to hazardous substances as a part of their work, you may be required to monitor their health through a medical surveillance program. Employees must be included in the medical surveillance program if they:

  • Are or may be exposed to hazardous substances above permissible limits for at least 30 days per year.
  • Wear a respirator for at least 30 days per year.
  • Become ill or show signs or symptoms of job-related overexposure to hazardous substances.
  • Are members of a hazardous materials (hazmat) team.

If you have employees who meet any of these criteria, you need to establish a medical surveillance program. You must consult a licensed physician to determine the content of the medical exams to be provided to your employees. Baseline, periodic, and exit exams are required by the standard. You will also need to keep the physician’s written opinion provided after each employee’s medical exam. With few exceptions, you must keep both employees’ medical and exposure records for the duration of their employment, plus 30 years. Employees and their representatives have the right to access these records during this time.

5. Engineering Controls, Work Practices, and PPE for Employee Protection (29 CFR 1910.120(g))

Engineering controls and work practices are the best ways to reduce employee exposures; they should be selected and highlighted first in HASP. Often these controls will need to be used in combination with PPE to provide sufficient protection during hazardous waste site operations. If your employees require PPE, you must include a written PPE program in your HASP. This portion of HASP must clearly describe how you select and use PPE based on the tasks and the nature and concentration of site contaminants. The PPE program must address how PPE will be used correctly and identify the limitations of its use; appropriate work mission durations; and procedures for decontaminating, maintaining, storing, and discarding PPE. Employees using PPE must be physically capable of doing so, and the PPE program must address the limitations of PPE use during temperature extremes, heat stress, and other appropriate medical considerations. Employees must also be trained to use PPE correctly, including how to inspect it before, during, and after use. If PPE will be used, the PPE program that includes all the elements listed must be evaluated to ensure that it is effective.

See tomorrow’s Advisor for the rest of the required elements of HASP.

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