HAZWOPER Records Checkup

One of the most tedious aspects of an EHS manager’s job is to keep track of a host of records. Don’t get caught without the necessary records in the event of an OSHA or EPA inspection. One of the first things inspectors will ask for is records of compliance. Good recordkeeping indicates to them good housekeeping practices. Conversely, poor recordkeeping tells the inspectors that you are not quite keeping up to speed and will likely cause them to dig deeper for other possible problems. The Advisor will provide you with records “checkups” on a regular basis. Today we will help you determine if you have all the necessary HAZWOPER records.

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