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First: Do you need to keep HAZWOPER records?
OSHA’s HAZWOPER standards are meant to protect employees engaged in hazardous waste operations and emergency response activities (HAZWOPER). OSHA’s rules are applicable to private (private businesses and nonprofit organizations) sector employees only. But, public employees are not off the hook. The EPA has identical health and safety standards to cover public (state and local government operations) sector workplaces, except for federal agencies.
HAZWOPER standards cover businesses with one or more employees and that engage in any of the following operations:
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- Cleanup operations required by federal, state, or local governments at uncontrolled hazardous waste sites (including sites on EPA’s National Priorities List (NPL), state priority site lists, sites recommended for the NPL, initial investigations of government-identified sites that are conducted before the presence or absence of hazardous substances has been determined), and where an accumulation or suspected accumulation of hazardous substances creates a threat to the health and safety of people or the environment;
- Corrective actions involving cleanup at Resource Conservation and Recovery Act (RCRA) -regulated sites;
- Voluntary cleanup at government-recognized uncontrolled hazardous waste sites;
- Treatment, storage, and disposal facilities (TSDFs) licensed under RCRA;
- Emergency response operations for release or substantial threats of release, of hazardous substances; and
- State and local government employees engaged in hazardous waste operations in states that are not covered under OSHA rules.
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Records checkup
If HAZWOPER applies to your facility or operations, make sure you keep the required records for the required amount of time.
|
Description |
Required Records |
Record Retention Period |
|
Hazardous waste operations training |
Issued certificates to employees and supervisors who successfully complete HAZWOPER training |
No specified retention period |
|
Medical surveillance |
Record of medical surveillance for workers exposed to health hazards and hazardous substances above permissible exposure limits for 30 days or more per year |
30 years |
|
Emergency response training |
Certifications that first responders (operations level), hazardous materials technicians, hazardous materials specialists, and on-scene incidence commanders received training and are competent; record of the methodology used to demonstrate competency |
No specified retention period |
|
Training at TSDFs |
Record of method used to demonstrate competency of site workers |
No specified retention period |
|
Annual certification of competency |
1 year |