OSHA's HAZWOPER standard provides clear guidelines for the safe and effective handling of hazardous waste, protecting both workers and the environment.
Hazardous substances are a serious safety and health problem that can endanger human and animal life and pose a significant threat to the environment. Discarded hazardous substances that are toxic, flammable, or corrosive can cause fires, explosions, and pollute our air, water, and land.
Because of the seriousness of the safety and health hazards related to hazardous waste, OSHA has created the Hazardous Waste Operations and Emergency Response standard, commonly known as HAZWOPER.
This standard aims to guide employers and protect employees so that hazardous substances can be handled safely and effectively.
The HAZWOPER standard 1926.65 for the construction industry is identical to the general industry standard 1910.120.
HAZWOPER does not apply to the accidental or foreseeable release of a hazardous substance that is limited in quantity and poses no emergency or significant threat to the safety and health of workers in the immediate vicinity. Referred to as incidental releases, they are limited in quantity, exposure potential, or toxicity, and have no potential of becoming emergencies within a short time frame.
Hazardous waste operations and emergency response covers three general categories of work:
- Hazardous waste site cleanup operations (examples: contaminated soil removal or underground storage tank removal)
- Operations involving hazardous waste at treatment, storage, and disposal facilities (example: a landfill that accepts hazardous waste)
- Emergency response for a hazardous substance release or a substantial threat of a release (examples: a leaking storage tank or a chemical fire)
Exceptions are permitted if the employer can demonstrate that the operation does not involve employee exposure or a reasonable possibility of such exposure to hazards.
OSHA Standards 1910.120(a)(3) and 1926.65(a)(3) Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.
Decontamination procedures and emergency response plans must be in place before employees begin working in hazardous waste operations. Specific training requirements must be met before employees engage in HAZWOPER.
If an organization engages in hazardous waste operations, they must adhere to specific requirements.
Perhaps most importantly, a written safety and health program that identifies, evaluates, and controls safety and health hazards and provides for emergency response must be developed and made readily-accessible.
OSHA Standards 1910.120(b)(1)(i) and 1926.65(b)(1)(i) Employers shall develop and implement a written safety and health program for their employees involved in hazardous waste operations. The program shall be designed to identify, evaluate, and control safety and health hazards, and provide for emergency response for hazardous waste operations.
A preliminary site evaluation should be conducted by a qualified person to identify potential site hazards and to aid in the selection of appropriate employee protection methods. Controls must be implemented to reduce and monitor exposure levels of hazardous materials.
A site control program to protect employees against hazardous contamination is required. At a minimum it must have a site map, site work zones, site communications, safe work practices, the use of a buddy system, and identification of the nearest medical aid.
Employee training must be provided for everyone working on a hazardous waste site.
Medical surveillance of workers exposed at or above permissible exposure limits for hazardous substances is to be conducted (1) at least annually, (2) when a worker moves to a new worksite, (3) when a worker experiences unexpected exposure, and (4) at the end of employment.
There should be an informational program describing any exposure during operations and the inspection of drums and containers prior to removal or opening.
Decontamination procedures and emergency response plans must be in place.
Exposures to hazardous substances pose a wide range of immediate and long-term health effects like chemical burns, sensitization, irritation, and other toxic effects that may lead to death. Hazardous substance releases can also result in fires, explosions, high-energy events, and toxic atmospheres causing significant danger to everyone in the facility or nearby.
OSHA Standards 1910.120(q)(1) and 1926.65(q)(1) An emergency response plan shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for inspection and copying by employees.
Even though every worker may not conduct emergency response or recovery operations, like rescue workers, law enforcement officers, or cleanup technicians, all employers and their workers should be prepared for emergencies.
Any worker or facility may be affected by a variety of emergency situations. Malfunctions, damage from natural events, intentional acts, or human error can all lead to emergencies.
Although only certain workers, like rescue workers, chemical operators, or cleanup technicians, may conduct emergency response or cleanup operations, it is important for employers to develop a plan, train workers, and have necessary equipment ready before a disaster or emergency occurs.
In the event of a hazardous substance emergency, two key actions can help protect workers and others in a place of business, 1) shelter-in-place, or 2) evacuation, and every facility should have a plan for both possibilities.
Employers must develop an Emergency Response Plan (ERP) to handle possible on-site emergencies and coordinate off-site response. The plan must cover reasonably anticipated worst-case scenarios.
OSHA Standards 1910.120(q)(2)(xii) and 1926.65(q)(2)(xii) Emergency response organizations may use the local emergency response plan or the state emergency response plan or both, as part of their emergency response plan to avoid duplication.
Rehearsed regularly and reviewed periodically, and amended as needed, the emergency response plan must address:
- personnel roles
- lines of authority, training, and communications
- emergency recognition and prevention
- site security
- evacuation routes and procedures
- decontamination procedures
- emergency medical treatment
- emergency alerting procedures
In facilities where the employer has chosen to evacuate employees in the case of an emergency and the employer does not permit any of their employees to assist in handling the emergency, an emergency response plan is not required. Instead, an Emergency Action Plan (EAP) should be in place that includes guidance for the safe evacuation of personnel.
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