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focus-area/safety-and-health/hazwoper
555327187
['HAZWOPER']

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard covers three primary categories of work operations, any one or more of which may apply to a single employer — hazardous waste cleanup operations; operations involving hazardous waste treatment, storage, and/or disposal; and emergency operations for releases of hazardous substances. The HAZWOPER Standard provides a framework for employers to implement in order to protect their employees from hazards during any of these work operations.

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HAZWOPER

Think of ‘HAZWOPER,’ and large hazardous waste sites with workers in chemical suits spring to mind. Although much of the standard for Hazardous Waste Operations and Emergency Response (or HAZWOPER) applies to those types of waste cleanup operations, some portions of the standard apply to hazardous waste treatment, storage, and disposal, while still other portions apply to relatively small spills or releases of hazardous substances at industrial or construction sites.

Hazardous substances, including hazardous waste, hazardous materials, biological agents, and certain substances regulated by the Environmental Protection Agency (EPA), pose employee safety and health hazards if not approached and dealt with properly. The Occupational Safety and Health Administration's (OSHA) HAZWOPER Standard is intended to provide a framework for employers to implement in order to protect their employees from these hazards during any of the work operations listed in the scope section of the standard.

Key definitions

  • Several key definitions are relevant to understanding and complying with the HAZWOPER Standard.

Although the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard has been around for several decades, it continues to confuse employers. The standard defines 20 terms in its definitions section at paragraph (a)(3) of 29 CFR 1910.120 for general industry and 29 CFR 1926.65 for construction. In addition, Occupational Safety and Health Administration (OSHA) directives CPL 02-02-071 and 02-02-073 define 75 related terms.

The use of these words and phrases may make the regulation a challenge for employers to understand. Some definitions and clarification are provided below.

Buddy system: A system of organizing employees into work groups so that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.

Cleanup operation: An operation in which hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or the environment.

Decontamination: The removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects.

Emergency response or responding to emergencies: A response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.) to an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area or by maintenance personnel are not considered to be emergency responses within the scope of this standard. 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.

Appendix A to 29 CFR 1910.120 and 1926.65 provides further guidance on this term.

Facility: This term is divided into two types:

(A) Any building, structure, installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft; or

(B) Any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise comes to be located. This definition does not include any consumer product in consumer use or any water-borne vessel.

Hazardous materials response (HAZMAT) team: An organized group of employees, designated by the employer, who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance. The team members perform responses to releases or potential releases of hazardous substances for the purpose of controlling or stabilizing the incident. A HAZMAT team is not a fire brigade, nor is a typical fire brigade a HAZMAT team. A HAZMAT team, however, may be a separate component of a fire brigade or fire department.

Hazardous substance: Any substance designated or listed under paragraphs (A) through (D) of this definition, exposure to which results or may result in adverse effects on the health or safety of employees:

(A) Any substance defined under section 103(14) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (see 42 U.S.C. 9601(14)).

(B) Any biological agent or other disease-causing agent that, after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction), or physical deformations in such persons or their offspring;

(C) Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR 172.101 and appendices; and

(D) Hazardous waste as defined below.

The term “hazardous substance” as defined by 1910.120 and 1926.65 should not be confused with the definition of “hazardous chemical” in 29 CFR 1910.1200, Hazard Communication.

Hazardous waste: This term is divided into two types:

(A) A waste or combination of wastes as defined in 40 CFR 261.3, or

(B) Those substances defined as hazardous wastes in 49 CFR 171.8. Hazardous waste operation. Any operation conducted within the scope 1910.120 or 1926.65.

Hazardous waste site: Any facility or location within the scope of 1910.120 or 1926.65 at which hazardous waste operations take place.

Health hazard: This term includes two types:

(A) A chemical or a pathogen where acute or chronic health effects may occur in exposed employees, or

(B) Stress due to temperature extremes.

The term “health hazard” includes chemicals that are classified in accordance with the Hazard Communication Standard, 1910.1200, as posing one of the following hazardous effects: acute toxicity (any route of exposure), skin corrosion or irritation, serious eye damage or eye irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity (single or repeated exposure), aspiration toxicity, or asphyxiation.

See 1910.1200 Appendix A — Health Hazard Criteria (Mandatory) — for the criteria for determining whether a chemical is classified as a health hazard.

IDLH or Immediately dangerous to life or health: An atmospheric concentration of any toxic, corrosive, or asphyxiant substance that:

(A) Poses an immediate threat to life,

(B) Would cause irreversible or delayed adverse health effects, or

(C) Would interfere with an individual’s ability to escape from a dangerous atmosphere.

Post-emergency response: That portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated and cleanup of the site has begun. If response is performed by an employer’s own employees who were part of the initial emergency response, it is considered to be part of the initial response and not post-emergency response. However, if a group of an employer’s own employees, separate from the group providing initial response, performs the cleanup operation, then the separate group of employees would be considered to be performing post-emergency response and subject to 1910.120(q)(11) for general industry or 29 CFR 1926.65(q)(11) for construction.

Small quantity generator: This term must meet two criteria:

(A) Any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR 261 or whose act first causes a hazardous waste to become subject to EPA regulation; and

(B) This person, by site, generates in any calendar month no more than 1,000 kilograms (2,205 pounds) of hazardous waste in that month.

Uncontrolled hazardous waste site: An area identified as an uncontrolled hazardous waste site by a governmental body, whether federal, state, local, or other, where an accumulation of hazardous substances creates a threat to the health and safety of individuals or the environment or both.

Some sites are found on public lands, such as those created by former municipal, county, or state landfills, where illegal or poorly managed waste disposal has taken place. Other sites are found on private property, often belonging to generators or former generators of hazardous substance wastes. Examples of such sites include, but are not limited to, surface impoundments, landfills, dumps, and tank or drum farms.

Normal operations at hazardous waste treatment, storage, and disposal (TSD) sites are not covered by this definition

Historical background

  • Love Canal and Valley of the Drums disasters led to a series of laws, one of which required OSHA to promulgate regulations to protect employees in hazardous waste operations. Those regulations became the HAZWOPER Standard we know today.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard was not the Occupational Safety and Health Administration’s (OSHA) idea. The regulation itself was actually mandated by a law signed by President Reagan in 1986. To understand the HAZWOPER Standard, it may help to know the history behind the regulation and how the regulation came about.

In the past, massive quantities of hazardous waste were stored or disposed of in poor conditions at unsafe locations. Many of these “dump sites” were abandoned and presented potential danger to human health and/or the environment. In the 1970s, lawmakers and the public started to realize that improperly treated, stored, or discarded hazardous waste was a serious problem.

Two environmental disasters got the public’s attention:

  • Love Canal in Niagara Falls, New York — Large amounts of abandoned, buried hazardous waste caused extensive contamination of the area, declaration of the area as a disaster by the federal government, and eventual relocation of most area residents. While the disaster came to a head in the 1970s, its history started in the late 1800s. For further information, see the Love Canal information in the CERCLA, SARA, EPCRA topic.
  • Valley of the Drums in Louisville, Kentucky — Once investigations and cleanup began, over 100,000 drums were discovered on the property. Many of the drums were in poor condition and leaking into the soil and the waters of Wilson Creek, a tributary of the Ohio River. Around 140 different chemical compounds were found on the land, and it took years to clean up the site. For further information, see the Valley of the Drums information in the CERCLA, SARA, EPCRA topic.

Because of the seriousness of the problem, Congress enacted legislation to control it:

  • Resource Conservation and Recovery Act of 1976 (RCRA) — This law established a regulatory system to manage hazardous wastes from the time they are generated to their final disposal.
  • Comprehensive Environmental Resource, Compensation, and Liability Act of 1980 (CERCLA) —This law gave the government authority to deal with threats from hazardous waste sites to human health and the environment. It forced responsible parties to pay for the cleanup of abandoned hazardous waste sites and take action to respond to emergencies involving uncontrolled releases of hazardous substances.
  • Superfund Amendments and Reauthorization Act of 1986 (SARA) — This law made several changes to CERCLA, increased communities’ awareness of extremely hazardous chemicals located near them, and helped communities develop emergency response plans.

It turns out that the treatment and disposal of hazardous wastes under RCRA and CERCLA created a significant risk to the safety and health of employees who worked in cleanup, treatment, storage, disposal, and emergency response operations. This risk was addressed by SARA, which specifically required OSHA to issue a regulation for the health and safety of employees engaged in hazardous waste operations. This regulation became the HAZWOPER Standard, found at:

  • OSHA 29 CFR 1910.120, HAZWOPER Standard for general industry;
  • OSHA 29 CFR 1926.65, HAZWOPER Standard for construction; and
  • EPA 40 CFR 311, Worker Protection Standard for state and municipal workers not protected by OSHA or an OSHA-approved state agency.

Note that a “hazardous waste operation” means any operation conducted within the scope of the HAZWOPER Standard.

Scope and applicability

  • The HAZWOPER Standard covers hazardous waste cleanup operations; operations involving hazardous wastes at treatment, storage, and disposal facilities; and emergency responses involving release or threatened release of hazardous substances.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 29 CFR 1910.120 and 1926.65 covers three primary categories of work operations, any one or more of which may apply to a single employer.

General scope and applicability criteria

According to 1910.120(a)(1) for general industry and 1926.65(a)(1) for construction, the HAZWOPER regulations cover the following operations, unless the employer can demonstrate that the operation does not involve employee exposure or a reasonable possibility of employee exposure to safety or health hazards:

  • Hazardous waste cleanup operations;
  • Operations involving hazardous wastes that are conducted at treatment, storage, and disposal (TSD) facilities; and
  • Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.

In addition, 40 CFR 311 says, “The substantive provisions found at 29 CFR 1910.120 ... apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” Because the term “hazardous waste operation” means any operation conducted within the scope of 1910.120, state and local government employers must protect their employees who are engaged in any of the bulleted operations above if those employers are not covered by a state-plan state approved by the Occupational Safety and Health Administration (OSHA).

Covered hazardous waste cleanup operations

  • The HAZWOPER Standard applies to three types of hazardous waste cleanup operations.

The general category of hazardous waste cleanup operations is divided into three very specific groups in the scope of 29 CFR 1910.120(a)(1) and 1926.65(a)(1):

  • Cleanup operations required by a federal, state, local, or other governmental body involving hazardous substances that are conducted at uncontrolled hazardous waste sites. These sites include, but are not limited to:
    • The Environmental Protection Agency’s (EPA) National Priority Site List (NPL),
    • State priority site lists,
    • Sites recommended for the EPA NPL, and
    • Initial investigations of government-identified sites that are conducted before the presence or absence of hazardous substances has been ascertained.
  • Corrective actions involving cleanup operations at sites covered by the Resource Conservation and Recovery Act (RCRA) of 1976 as amended (42 U.S.C. 6901 et seq.).
  • Voluntary cleanup operations at sites recognized by federal, state, local, or other governmental bodies as uncontrolled hazardous waste sites.

All of these operations must comply with paragraphs (b) through (o) of 1910.120 and/or 1926.65.

Refer to the Definitions section to learn the meanings of the terms cleanup operation, hazardous waste site, and uncontrolled hazardous waste site.

Covered hazardous waste treatment, storage, and disposal operations

Hazardous waste treatment, storage, and disposal (TSD) facilities are those facilities regulated by 40 CFR 264, 40 CFR 265, or agencies under agreement with EPA to implement the Resource Conservation and Recovery Act (RCRA) regulations. Operations involving hazardous wastes conducted at these RCRA-permitted TSD facilities must also comply with paragraph (p) of 29 CFR 1910.120 and/or 1926.65.

What about hazardous waste generators?

In addition, the HAZWOPER Standard covers small and large quantity hazardous waste generators with the following characteristics:

  • They qualify for permitting exemptions under 40 CFR 264, 265, and 270, and
  • They are required by EPA or a state agency to have their employees engage in emergency response for hazardous waste storage areas, or they otherwise direct their employees to do so.

Instead of falling under the balance of paragraph (p), these operations are only required to meet paragraph (p)(8) of 1910.120 and/or 1926.65. As another option, compliance with the requirements of paragraph (q) of 1910.120 and/or 1926.65 is considered to be in compliance with the requirements of paragraph (p)(8).

EPA does not require very small quantity hazardous waste generators to have their employees engage in emergency response. Therefore, unless the state agency requires emergency response from the employees, this generator type does not need to worry about paragraph (p)(8).

The Notes and Exceptions in subparagraph (a)(2)(iii) of 1910.120 and/or 1926.65 provide further information regarding hazardous waste generators.

Covered emergency response operations

  • Under HAZWOPER, emergency response primarily involves employees or other responders from outside the immediate area of the hazardous substance release.
  • Incidental hazardous substance releases that are controlled or neutralized by employees in the area or that don’t pose any hazards do not count as emergency response operations.

Emergency response operations for releases of, or substantial threats of releases of, hazardous substances must comply with paragraph (q) of 29 CFR 1910.120 and/or 1926.65. The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard defines the term “emergency response or responding to emergencies” as follows: “A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance ...”

Responders from outside the immediate release area

The HAZWOPER Standard, at 1910.120(q) and 1926.65(q), uses the term “responders” generally to refer to employees who respond to emergencies.

The standard covers responses “by other designated responders.” Under the language of the standard, responders are a separate group, different from employees outside the immediate release area who are directed to respond to the emergency by the employer.

Emergency responders include employees who are working in the immediate release area (not just outsiders) if the employer designates them as such. For example, a release of chlorine gas above the “immediately dangerous to life and health” (IDLH) level, obscuring visibility and moving through a facility, is an emergency situation even if the initial responders are from the immediate release area. Employees who would respond to this situation, whether they work in the immediate area or come from outside, would need to act in accordance with 1910.120(q).

Employees are not barred from responding to releases in the immediate release area that would otherwise require outside assistance from a trained HAZMAT team, even though the definition of an emergency response states that an emergency response is “a response effort by employees from outside the immediate release area.”

Conversely, incidental releases of hazardous substances that are routinely cleaned up by employees from outside the immediate release area need not be considered emergency responses solely because those responsible for cleanup come from outside the immediate release area.

For example, paint thinner is spilled in an art studio, and the janitor is called from outside the immediate release area to mop it up. The janitor does not have to respond in accordance with 1910.120 and 1926.65. (The janitor would, however, be expected to understand the hazards associated with paint thinner through training under 29 CFR 1910.1200, Hazard Communication.)

What the term “emergency response” does not include

To clarify the definition of the term, the Occupational Safety and Health Administration (OSHA) explains that an “emergency response” does not include responses to:

  • Incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel.
  • Releases of hazardous substances where there is no potential safety or health hazard such as fire, explosion, or chemical exposure.

Exemption for no employee exposure to hazards

  • Employers can claim exemption from HAZWOPER if they can demonstrate that their employees won’t be exposed to hazards.

When determining applicability, employers should consider if they have an exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard.

The HAZWOPER Standard at 29 CFR 1910.120 and 1926.65 covers several listed operations unless the employer can demonstrate that the operation does not involve “employee exposure or the reasonable possibility for employee exposure to safety or health hazards.” Therefore, it is important to understand how to determine whether an exemption from the standard is met.

Employers must consider all routes of entry (inhalation, ingestion, and skin absorption) without regard to the use of personal protective equipment (PPE) when evaluating employee exposure or the reasonable possibility of employee exposure to safety or health hazards. The exposure or potential exposure must also be associated with a hazardous substance from the listed operations.

Safety hazards from a hazardous substance could include fire, explosion, corrosive action, etc., from flammable, corrosive, or otherwise hazardous substances associated with the site. Health hazards from a hazardous substance could include cancer or organ function impairment from toxic, carcinogenic, or infectious material associated with the site. The term “health hazard” is further defined at 1910.120(a)(3) and 1926.65(a)(3).

Safety hazards from sources not specifically associated with the hazardous substances at the site (e.g., trenching; moving machinery; and slips, trips, and falls) do not by themselves require coverage under HAZWOPER. Employees are considered “exposed” when they encounter any amount of a hazardous substance in the work environment that could cause them harm.

Exemptions related to releases

  • If all employees would be evacuated rather than help respond to an emergency release, employers may create an emergency action plan that includes the evacuation procedure in lieu of complying with the emergency response provisions.
  • Incidental releases are those that don’t pose a significant danger to the employees working in the area or cleaning up the substance. Incidental releases are not covered by the HAZWOPER Standard.

When determining applicability, employers should consider if they have a partial exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, as it relates to releases.

Emergency action plan exemption

Employers who will evacuate all employees from the danger area, and who will not permit any employees to assist in handling the emergency, have the option of creating a written emergency action plan (EAP) in accordance with 29 CFR 1910.38 or 1926.35 in lieu of an emergency response plan (ERP) and the other provisions of paragraph (q) of 1910.120 or 1926.65. Employers with 10 or fewer employees can communicate the EAP orally rather than maintaining a written plan.

When used to meet the requirements of HAZWOPER, 29 CFR 1910.38 and 1926.35 require employers to also have an effective alarm system to alert employees to an emergency, evacuate all employees, and notify an emergency response team, such as a fire department that is trained in accordance with HAZWOPER.

Employers who will train some of their employees to respond to an emergency release must create an ERP. The ERP must include an EAP for the evacuation of all employees in the area who are not essential for emergency response.

Incidental release exemption

One of the operations that falls under the HAZWOPER Standard is the emergency response operation for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. However, responding to incidental spills and releases is not considered an “emergency response.”

An understanding of the distinction between an incidental release of a hazardous substance and a release that requires an emergency response is fundamental to proper compliance with the provisions of the standard.

The definition of the term “incidental release” is found at 1910.120(a)(3) and 1926.65(a)(3) within the definition of “emergency response or responding to emergencies,” where it says, “Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.”

An incidental release is a release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employees cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up. An incidental spill poses an insignificant threat to health or safety and may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.

On the flip side, an emergency release is defined as an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance that requires a response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.). Emergency releases of hazardous substances pose a sufficient threat to health and safety that, by their very nature, require an emergency response regardless of the circumstances surrounding the release or the mitigating factors.

An emergency response includes, but is not limited to, the following situations:

  • The response comes from outside the immediate release area.
  • The release requires evacuation of employees in the area.
  • The release poses, or has the potential to pose, conditions that are immediately dangerous to life or health (IDLH).
  • The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit).
  • The release requires immediate attention because of imminent danger.
  • The release may cause high levels of exposure to toxic substances.
  • There is uncertainty about whether the employees in the work area can handle the severity of the hazard with the personal protective equipment (PPE) and other equipment that has been provided, and the exposure limit could easily be exceeded.
  • The situation is unclear, or data are lacking on important factors.

The quantity of a substance spilled does not by itself determine if an incidental spill or emergency release has occurred. The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, and corrosiveness, as well as the circumstances of the release itself, such as quantity, confined space considerations, and ventilation, will have an impact on what employees can handle safely and what procedures should be followed.

Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and PPE at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.

These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental spills and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.

Special issues

A few issues relating to the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard need particular attention. Knowledge of these special issues is essential to fully understanding HAZWOPER.

Certain industry or employer types

  • Whether an employer is in the construction, shipyard, marine terminal, longshoring, or healthcare industry poses special issues relating to HAZWOPER.
  • EPA adopted 1910.120 in 40 CFR 311 for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan.

Construction

Hazardous waste operations and emergency response for construction sites are covered by 29 CFR 1926.65 (a standard identical to 29 CFR 1910.120, except for its references to other Occupational Safety and Health Administration, or OSHA, regulations). Work for construction, alteration, and/or repair, including painting and decorating, is considered “construction work” according to 29 CFR 1910.12 and must comply with the Construction Safety and Health Regulations within 29 CFR 1926.

For construction, all requirements of Part 1926 apply pursuant to their terms to hazardous waste and emergency response operations, whether covered by 1926.65 or not. If there is a conflict or overlap between 1926.65 and another Part 1926 regulation, the provision more protective of employee safety and health applies.

Shipyards, marine terminals, and longshoring

OSHA directive CPL 02-02-073 states, “HAZWOPER is also applicable to shipyard work under [Part] 1915.”

Employers are required under 29 CFR 1917.30 and 1918.100 to develop and implement emergency action plans to ensure employee safety from fires and other emergencies. However, if employees are directed by their employer to respond to an emergency beyond the scope of an emergency action plan, then paragraph (q) of 1910.120 applies (see footnotes at bottom of 1917.30 and 1918.100).

Healthcare

First receivers include hospital-based staff (e.g., triage, decontamination, medical treatment, and security) that receive and treat contaminated victims from mass casualty incidents. These personnel are removed from the site of the emergency and the point of release and do not need to be trained — or equipped — for control, containment, or confinement operations, as is required for a HAZMAT team.

First receivers are still considered to be part of an emergency response and are required to wear appropriate personal protective equipment (PPE) and be provided effective training based on the duties and functions to be performed.

State and local government employees

The Environmental Protection Agency (EPA) adopted 1910.120 in 40 CFR 311 (Federal Register June 23, 1989) for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan is in place, and, therefore, there is no OSHA coverage for state and local government employees.

Part 311 says, “The substantive provisions found at 29 CFR 1910.120 … apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” The term “hazardous waste operation” means any operation conducted within the scope of 1910.120.

EPA specifically includes “non-compensated workers” (i.e., volunteer workers) who work for governmental agencies engaged in emergency response, such as volunteer firefighters. Therefore, volunteers who will take part in operations involving hazardous substances must be trained in accordance with the applicable sections of 1910.120.

Radioactive or infectious materials

  • Radioactive waste and infectious materials can both fall under the HAZWOPER Standard, depending on the circumstances.

Radioactive waste

The term “hazardous substance” as defined by 29 CFR 1910.120 includes radioactive waste in addition to hazardous waste. It should not be confused with the definition of “hazardous chemical” in 29 CFR 1910.1200, Hazard Communication, which specifically excludes any radioactive chemicals.

The U.S. Nuclear Regulatory Commission (NRC) has jurisdiction “inside the fence” at NRC-licensed nuclear facilities for the risks involved with licensed radioactive materials, including emergency response procedures. The Occupational Safety and Health Administration (OSHA) has jurisdiction “inside the fence” for non-licensed radioactive materials, such as x-ray equipment, accelerators, some electron microscopes, and some naturally occurring radioactive materials (see the memo of understanding between OSHA and the NRC that delineates employee protection responsibilities for each agency at facilities licensed by the NRC, effective October 21, 1988).

There may be both NRC and OSHA jurisdiction when there is an emergency involving mixed wastes (licensed radioactive materials and other hazardous substances) “inside the fence.” HAZWOPER may also be applicable “outside the fence” to emergency response and cleanup activities involving hazardous substances, including licensed radioactive wastes.

Infectious materials

Employers must include infectious materials in their effort to comply with 1910.120(q) if there is a possibility that a release could cause an emergency. Employers with employees engaged in emergency response activities involving infectious materials must comply with the requirements in 1910.120(q) and may also have to comply with the Bloodborne Pathogens Standard, 29 CFR 1910.1030. If there is a conflict or overlap between the standards, the provision that is more protective of employee safety and health applies.

Terrorist events and acts of nature

  • Terrorist events themselves are not covered under the HAZWOPER Standard because they are not considered foreseeable workplace emergencies, but any emergency response to a hazardous substance release does fall under the standard.
  • Acts of nature fall under HAZWOPER if they can be reasonably expected to occur in the area and may cause the release of hazardous substances.

Although terrorist events and dangerous weather phenomena can present serious workplace hazards, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard only applies to them under certain conditions.

Terrorist events

The Occupational Safety and Health Administration (OSHA) does not consider terrorist events to be foreseeable workplace emergencies for purposes of standards requiring employers to anticipate and prepare for such emergencies. The release of chemicals or hazardous substances into a workplace, whether caused by an accidental release or by a terrorist event, would, however, be considered a hazardous materials (HAZMAT) incident. All emergency responders and employees performing emergency response efforts for such releases would, therefore, fall under 29 CFR 1910.120(q).

The level of emergency responder training must be based on the duties and functions to be performed by each responder. Although under 1910.120(q), employers would not be required specifically to prepare for a potential terrorist event and to develop an emergency response plan (ERP) for such an event, using the elements of the standard may be of assistance to employers in developing a useful plan of action to respond to any emergency situation.

Acts of nature

Workplaces located in areas prone to natural phenomena, such as earthquakes, floods, tornadoes, and hurricanes, and potentially subject to a “substantial threat of release of hazardous substances” are covered by 1910.120. The ERP required in 1910.120(q)(1) must include responses to emergencies caused by such natural phenomena.

According to subparagraph (q)(1), the ERP “shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations.” This means that employers in areas prone to natural phenomena should anticipate whether such natural phenomena are likely to cause releases of hazardous substances and, if so, incorporate appropriate emergency response procedures into their ERP.

Related hazards

  • Employers must be aware of and account for both general and specific hazards of the worksite and how these may change/develop over time and as work progresses.

Knowledge of hazards, both in general and specific to the work setting, is crucial to development of a Hazardous Waste Operations and Emergency Response (HAZWOPER) program and employee training. Whether an employer has a hazardous waste cleanup site, hazardous waste treatment/storage/disposal facility, hazardous waste storage area, or emergency response operations, the work setting may pose a multitude of health and safety concerns, any one of which could result in serious injury, illness, or death. These hazards are a function of the nature of the site as well as a consequence of the work being performed.

Under HAZWOPER, worksites may pose an immediate danger to life or health that may:

  • Not be immediately obvious or identifiable,
  • Vary according to the location and task being performed, or
  • Change as site activities progress.

The employer’s written programs must provide comprehensive protection against all potential hazards and specific protection against individual known hazards, and these programs should adapt to new information and changing site conditions. The related hazards described in this section are general categories, and the employer may require more information on certain hazards that apply to its operations.

Chemical exposure

  • Chemical hazards can cause many different types of injuries or illnesses to humans, some not apparent until long after exposure.
  • Physical hazards are posed by the physical properties of a chemical, such as being combustible or reactive.
  • Health hazards are posed by properties of a chemical that are toxic to humans, such as being corrosive or carcinogenic.

Preventing exposure to toxic chemicals is a primary concern while working with hazardous waste or responding to a chemical emergency. Most facilities contain a variety of chemical substances in gaseous, liquid, or solid form. These substances can enter the unprotected body through the four routes of exposure:

  • Inhalation
  • Skin absorption
  • Ingestion
  • Injection (through a puncture wound)

A contaminant can cause damage at the point of contact or can act systemically, causing a toxic effect at a part of the body distant from the point of initial contact.

There are two main classifications of chemical hazards — physical hazards and health hazards. Physical hazards are those hazards posed by the physical properties of a chemical, such as being able to burn, corrode, or react with other chemicals. Chemicals that pose physical hazards include:

  • Explosives
  • Flammables (gases, aerosols, liquids, or solids)
  • Oxidizers (liquid, solid or gas)
  • Self-reactives
  • Pyrophorics (liquids or solids)
  • Self-heating chemicals
  • Organic peroxides
  • Chemicals corrosive to metal
  • Gases under pressure
  • Chemicals when in contact with water emit flammable gas

Health hazards mean the chemical possesses toxic properties that may poison or injure us. Obviously, the possible injury can take many forms, from a skin rash to cancer. Chemicals with health hazards pose one or more of the following health effects:

  • Acute toxicity (any route of exposure)
  • Skin corrosion or irritation
  • Serious eye damage or eye irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (single or repeated exposure)
  • Aspiration toxicity or simple asphyxiant

Hazardous chemicals also include simple asphyxiants, combustible dusts, pyrophoric gases, or hazards not otherwise classified.

Chemical exposures are generally divided into two categories: acute and chronic. Symptoms resulting from acute exposures usually occur during or shortly after exposure to a sufficiently high concentration of a contaminant. The concentration required to produce such effects varies widely from chemical to chemical.

The term “chronic exposure” generally refers to exposures to “low” concentrations of a contaminant over a long period of time. The “low” concentrations required to produce symptoms of chronic exposure depend upon the chemical, the duration of each exposure, and the number of exposures. For a given contaminant, the symptoms of an acute exposure may be completely different from those resulting from chronic exposure.

For either chronic or acute exposure, the toxic effect may be temporary and reversible, or it may be permanent (disability or death). Some chemicals may cause obvious symptoms such as burning, coughing, nausea, tearing eyes, or rashes. Other chemicals may cause health damage without any such warning signs (this is a particular concern with chronic exposures to low concentrations).

Health effects such as cancer or respiratory disease may not manifest for several years or decades after exposure. In addition, some toxic chemicals may be colorless and/or odorless, may dull the sense of smell, or may not produce any immediate or obvious physiological sensations. Thus, a worker’s senses or feelings cannot necessarily be relied upon to warn of potential toxic exposure.

The effects of exposure not only depend on the chemical, its concentration, the route of entry, and the duration of exposure, but may also be influenced by personal factors such as the individual’s smoking habits, alcohol consumption, medication use, nutrition, age, and sex.

Exposure routes

  • The most common exposure route is inhalation, but others include skin/eye contact, ingestion, and injection via puncture wounds.

Inhalation

One important exposure route is inhalation. The majority of toxic substances enter the body through breathing. That’s because the lungs are extremely vulnerable to chemical agents. Even substances that do not directly affect the lungs may pass through lung tissue into the bloodstream, where they are transported to other vulnerable areas of the body.

Some toxic chemicals present in the atmosphere may not be detected by human senses — they may be colorless and odorless, and their toxic effects may not produce any immediate symptoms. Respiratory protection is therefore extremely important if there is a possibility that the worksite atmosphere may contain such hazardous substances.

Chemicals can also enter the respiratory tract through punctured eardrums. Where this is a hazard, workers with punctured eardrums should be medically evaluated to determine if this condition would place them at unacceptable risk and preclude their working at the task in question.

Skin/Eye contact

Direct contact of the skin and eyes with hazardous substances is another important route of exposure. Some chemicals directly injure the skin. Some pass through the skin into the bloodstream, where they are transported to vulnerable organs. Skin absorption is enhanced by abrasions, cuts, heat, and moisture.

The eye is particularly vulnerable because airborne chemicals can dissolve in its moist surface and be carried to the rest of the body through the bloodstream (capillaries are very close to the surface of the eye). Wearing protective equipment, not using contact lenses in contaminated atmospheres (since they may trap chemicals against the eye surface), keeping hands away from the face, and minimizing contact with liquid and solid chemicals can help protect workers against skin and eye contact.

Ingestion

Although ingestion should be the least significant route of exposure, it is important to be aware of how this type of exposure can occur. Deliberate ingestion of chemicals is unlikely. However, personal habits such as chewing gum or tobacco, drinking, eating, smoking cigarettes, or applying cosmetics on the jobsite may provide a route of entry for chemicals.

Injection

The last primary route of chemical exposure is injection, whereby chemicals are introduced into the body through puncture wounds (for example, by stepping or tripping and falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical hazards, and taking common-sense precautions are important protective measures against injection.

Explosion and fire

  • Explosions and fires can happen spontaneously but more often come from worksite activities such as moving drums or accidentally mixing or igniting chemicals.
There are many potential causes of explosions and fires at any site where chemicals are present, like:
  • Chemical reactions that produce explosion, fire, or heat;
  • Ignition of explosive or flammable chemicals;
  • Ignition of materials due to oxygen enrichment;
  • Agitation of shock- or friction-sensitive compounds; and
  • Sudden release of materials under pressure.

Explosions and fires may arise spontaneously. However, more commonly, they result from worksite activities such as moving drums, accidentally mixing incompatible chemicals, or introducing an ignition source (such as a spark from equipment) into an explosive or flammable environment.

At chemical handling sites, explosions and fires not only pose the obvious hazards of intense heat, open flame, smoke inhalation, and flying objects but may also cause the release of toxic chemicals into the environment. Such releases can threaten both personnel onsite and members of the general public living or working nearby.

Protecting against this hazard means:

  • Having qualified personnel field monitor for explosive atmospheres and flammable vapors;
  • Keeping all potential ignition sources away from an explosive or flammable environment;
  • Using non-sparking, explosion-proof equipment; and
  • Following safe practices when performing any task that might result in the agitation or release of chemicals.

Oxygen deficiency

  • Oxygen deficiency is likeliest to occur in confined spaces, low-lying areas, and in poorly ventilated areas where another gas may displace oxygen (such as CO produced by a generator).

The oxygen content of normal air at sea level is approximately 21 percent. Physiological effects of oxygen deficiency in humans are readily apparent when the oxygen concentration in the air decreases to 16 percent. These effects include impaired attention, judgment, and coordination, as well as increased breathing and heart rate.

Oxygen concentrations lower than 16 percent can result in nausea and vomiting, brain damage, heart damage, unconsciousness, and death. To account for individual physiological responses and errors in measurement, concentrations of 19.5 percent oxygen or lower are considered to be indicative of oxygen deficiency.

Oxygen deficiency may result when oxygen is displaced by another gas or consumed by a chemical reaction. Confined spaces and low-lying areas are particularly vulnerable to oxygen deficiency and should always be monitored prior to entry. Qualified field personnel should always monitor oxygen levels and should use atmosphere-supplying respiratory equipment when oxygen concentrations drop below 19.5 percent by volume.

Asphyxiation is injury or death caused by the replacement of oxygen in the environment by another gas or vapor or by a chemical that keeps the body tissues from using oxygen. Carbon monoxide (CO) and benzene are examples of chemical asphyxiants.

CO is a poisonous, colorless, and odorless gas that is produced by the incomplete burning of fuel. Possible sources of exposure include emergency power generators used in poorly ventilated areas and gas-powered saws that need servicing.

Generators should never be used indoors or in enclosed spaces such as garages and basements. They also should not be used outdoors near doors, windows, and vents that could allow CO to enter. Opening windows and doors may not be enough to prevent CO from building up in those spaces

Radiation

  • The three types of harmful radiation, from least to most dangerous, are alpha, beta, and gamma.
  • Sunburn is caused by UV radiation from the sun and is best avoided by minimizing direct sun exposure.

Radioactive materials emit one or more of three types of harmful radiation:

  • Alpha radiation has limited penetration ability and is usually stopped by clothing and the outer layers of the skin. Alpha radiation poses little threat outside the body but can be hazardous if materials that emit alpha radiation are inhaled or ingested.
  • Beta radiation can cause harmful “beta burns” to the skin and damage the subsurface blood system. Beta radiation is also hazardous if materials that emit beta radiation are inhaled or ingested. Use of protective clothing, coupled with scrupulous personal hygiene and decontamination, affords good protection against alpha and beta radiation.
  • Gamma radiation easily passes through clothing and human tissue and can also cause serious permanent damage to the body. Chemical protective clothing affords no protection against gamma radiation itself. However, respiratory and other protective equipment can help keep radiation-emitting materials from entering the body by inhalation, ingestion, injection, or skin absorption.

If levels of radiation above natural background are discovered, a health physicist should be consulted. At levels greater than 2 mrem/hr, all site activities should cease until the site has been assessed by health physicists.

Sunburn

Prolonged exposure to ultraviolet radiation from the sun can produce sunburn. Symptoms include red, sensitive, inflamed skin and even blisters. General steps to relieve sunburn pain include:

  1. Soaking in cold water
  2. Drying the area
  3. Applying ointment
  4. Covering

For severe sunburn, medical treatment should be sought. The only way to prevent sunburn is to avoid sun exposure (by wearing a hat, long sleeves, and sunscreen).

When possible, work areas should be set up in a shaded location and tasks should be scheduled when individuals will not be exposed to direct sunlight, such as during the early morning or late afternoon.

Biological hazards

  • Biological hazards include disease-causing organisms; poisonous plants and animals; and biological agents used in bioterrorism.

Wastes from hospitals and research facilities may contain disease-causing organisms that could infect site personnel. Like chemical hazards, infectious agents may be dispersed in the environment via water and wind. Other biological hazards that may be present at a hazardous waste site include poisonous plants, insects, animals, and indigenous pathogens.

Protective clothing and respiratory equipment can help reduce the chances of exposure. Anyone who has been exposed should thoroughly wash any exposed body parts and equipment to help protect against infection.

Biological hazards can also stem from terrorist acts. Terrorism is the use of force or violence against persons or property for purposes of intimidation, coercion, or ransom. Bioterrorism is the use of biological agents to inflict casualties.

Biological agents are organisms, bacteria, viruses, or toxins that have illness-producing effects on people, livestock, and crops. Biological agents include:

AgentDisseminationTransmission (person to person)IncubationLethality
AnthraxSpores in aerosolNo (except cutaneous)1–5 daysHigh
CholeraIngestion and aerosolRare12 hours to 6 daysLow with treatment
PlagueAerosolHigh1–3 daysHigh if untreated
TularemiaAerosolNo1–10 daysModerate if untreated
Q FeverIngestion and aerosolRare14–16 daysVery low
SmallpoxAerosolHigh10–12 daysLow
VEEAerosol and infected vectorsLow1–6 daysLow
EbolaContact and aerosolModerate4–16 daysModerate to high
Botulinum ToxinIngestion and aerosolNoHours to daysHigh
T-2 MycotoxinsIngestion and aerosolNo2–4 hoursModerate
RicinIngestion and aerosoNoHours to daysHigh
Staphylococcal Enterotoxin BIngestion and aerosolNoHoursLess than 1 percent

Biological agents can be dispersed as aerosols or airborne particles. Some devices used for intentional biological terrorism may have the capacity to disseminate large quantities of biological materials in aerosols.

Terrorists may also use biological agents to contaminate food or water. Because biological agents cannot necessarily be detected and may take time to grow and cause harm, it is very difficult to determine that a biological attack has occurred until people begin showing the signs and symptoms.

Biological agents are infectious through one or more of the following mechanisms of exposure, depending upon the type of agent:

  • Inhalation, with infection through respiratory mucosa or lung tissues;
  • Ingestion;
  • Contact with the mucous membranes of the eyes or nasal tissues; or
  • Penetration of the skin through open cuts (even very small cuts and abrasions of which employees might be unaware).

Existing recommendations for protecting workers from biological hazards require the use of half-mask or full facepiece air-purifying respirators with particulate filter efficiencies ranging from N95 (for hazards such as pulmonary tuberculosis) to P100 (for hazards such as hantavirus) as a minimum level of protection.

Emergency first responders typically use self-contained breathing apparatus (SCBA) respirators with a full facepiece operated in the most protective, positive pressure (pressure demand) mode during emergency responses.

General safety hazards

  • General safety hazards include holes, steep hills, sharp objects, and bodies of water, among many other ways for workers to get hurt.

When people think of hazards during hazardous waste and emergency response operations, they might picture clouds of toxic gases being released in the workplace, or puddles of sulfuric acid eating through rubber boots. The reality is often far more mundane, but just as lethal.

Hazardous waste sites and in-plant emergency response operations may contain numerous safety hazards, such as:

  • Holes or ditches;
  • Precariously positioned structures and objects, such as drums or boards that may fall;
  • Sharp objects, such as nails, metal shards, and broken glass;
  • Slippery surfaces;
  • Steep grades;
  • Uneven terrain;
  • Unstable surfaces, such as walls that may cave in or flooring that may give way;
  • Falls from ladders and scaffolding;
  • Powered equipment with moving parts and unexpected startup;
  • Motor vehicle hazards, such as being struck or backed into by a vehicle;
  • Friction that causes blisters, rashes, and burns; and
  • Drowning.

Some safety hazards are a function of the work itself. For example, heavy equipment creates an additional hazard for workers in the vicinity of the operating equipment.

Personal protective equipment (PPE) can impair a worker’s agility, hearing, and vision, which can result in an increased risk of an accident. Stress and fatigue can play a role as well.

Accidents involving physical hazards can directly injure workers and can create additional hazards, such as increased chemical exposure due to damaged PPE or the danger of explosion caused by the mixing of chemicals. Site personnel should constantly look out for potential safety hazards and should immediately inform their supervisors of any new hazards so that mitigative action can be taken.

It is worth noting that according to a report by the Worker Education and Training Plan of the National Institute of Environmental Health Sciences, NIEHS WETP Response to the World Trade Center (WTC) Disaster, most response worker injuries at the 2001 World Trade Center disaster site were blisters and eye injuries, followed by headaches and sprains or strains. This demonstrates that general safety hazards are important and cannot be ignored at an emergency response site.

Electrical hazards

  • Employers should minimize electrical hazards to workers by identifying and deenergizing circuits workers might contact and communicating about potential dangers.
  • Power line and lightning hazards also pose risks to site employees working outdoors.

Electrical equipment

Electrical equipment used onsite may also pose a hazard to workers. To help minimize this hazard, low-voltage equipment with ground-fault circuit interrupters and watertight, corrosion-resistant connecting cables should be used onsite.

Capacitors

An additional electrical hazard involves capacitors that may retain a charge. All such items should be properly grounded before handling. OSHA standard 29 CFR 1910.137, Electrical Protective Equipment, describes clothing and equipment for protection against electrical hazards.

Power lines

Overhead power lines, downed electrical wires, and buried cables all pose a danger of shock or electrocution if workers contact or sever them during site operations.

Electrical lines should be assumed to be energized until proven otherwise. Lines and other conductors may become reenergized without warning as utilities are evaluated and restored after an emergency release or other disaster.

Employers should:

  • Identify the location of any energized electrical power circuit that employees (or their tools and equipment) could contact;
  • Deenergize and ground any such circuits; and
  • Post signs and advise individuals of the location, hazards, and protective work practices.

More information is provided in the Occupational Safety and Health Administration (OSHA) fact sheet, Working Safely Around Downed Electrical Wires, found at www.osha.gov/OshDoc/data_General_Facts/downed_electrical_wires.pdf.

Lightning

In addition, lightning is a hazard during outdoor operations, particularly for workers handling metal containers or equipment. To eliminate this work hazard, weather conditions should be monitored, and work should be suspended during electrical storms.

More information

Please refer to the Electrical safety and Personal protective equipment subjects for further information on electrical safety and electrical protective equipment.

Confined spaces

  • Confined spaces are difficult to enter, exit, and move within, and they pose a serious risk of asphyxiation.

There are safety and health hazards involved in responding to incidents in confined spaces. The openings are usually small and are difficult to move through easily, which makes the transport of protective equipment a chore.

Simply put, a confined space is any space that meets three criteria:

  • It’s large enough for a worker to enter,
  • It has limited means of entry or exit, and
  • It’s not designed for continuous occupancy.

Examples of confined spaces include tanks, vessels, silos, storage bins, hoppers, vaults, boilers, pits, sewers, and crawl spaces.

Confined space hazards

Because air may not move in or out of confined spaces freely due to the design, the atmosphere inside a confined space can be very different from the atmosphere outside. Deadly gases may be trapped inside, or there may not be enough oxygen to support life. Therefore, occasional worker entry for inspection, maintenance, repair, cleanup, or similar tasks is often difficult and dangerous due to chemical or physical hazards within the space.

In addition to oxygen deficiency and toxic air contaminants, confined spaces may contain combustible gases, electrical hazards, moving parts, and even snakes.

Permit spaces

With so many hazards, permits are often required just to perform work in a confined space. In fact, a confined space is considered a permit-required confined space (called a permit space) if it has:

  • A hazardous atmosphere;
  • The potential for engulfment or suffocation;
  • An internal layout that might trap an entrant, such as by inwardly converging walls or a sloped floor; or
  • Any other recognized serious hazard.

Please refer to the Confined spaces subject for further information.

Noise

  • Where workers are exposed to noise averaging at least 85 dBA for 8 hours, employers must administer a hearing conservation program and other administrative/engineering controls to protect workers’ hearing.

Work around large equipment often creates excessive noise. The effects of noise can include:

  • Workers being startled, annoyed, or distracted;
  • Ear damage, pain, and temporary and/or permanent hearing loss; and
  • Communication interference, which may increase potential hazards due to the inability to warn of danger and convey proper safety precautions.

In general industry, if employees are subjected to noise exceeding an 8-hour, time-weighted average sound level of 90 dBA (decibels on the A-weighted scale), feasible administrative or engineering controls must be utilized. In addition, whenever employee noise exposures equal or exceed an 8-hour, time-weighted average sound level of 85 dBA, employers must administer a continuing, effective hearing conservation program as described in Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.95.

In construction, employers will want to reference 29 CFR 1926.52, 1926.95, and 1926.101.

Please refer to the Personal protective equipment subject for further information.

Heat stress and cold exposure

  • Heat stress can occur within 15 minutes and is exacerbated by PPE, which traps body heat and moisture.
  • Cold exposure can lead to frostbite and hypothermia and impair the ability to work.

Heat stress is a major hazard, especially for employees wearing protective clothing. The same protective materials that shield the body from chemical exposure also limit the dissipation of body heat and moisture. Personal protective equipment (PPE) and protective clothing can therefore create a hazardous condition.

Depending on the ambient conditions and the work being performed, heat stress can occur very rapidly — within as little as 15 minutes. It can pose as great a danger to employee health as chemical exposure can. In its early stages, heat stress can cause rashes, cramps, discomfort, and drowsiness, resulting in impaired functional ability that threatens the safety of both the individual employee and coworkers.

Continued heat stress can lead to heatstroke and death. Ways to protect against this hazard include:

  • Avoiding overprotection,
  • Careful training,
  • Frequent monitoring of personnel who wear PPE,
  • Judicious scheduling of work and rest periods, and
  • Frequent replacement of fluids.

Cold exposure

Cold injury (frostbite and hypothermia) and impaired ability to work are dangers at low temperatures and when the wind-chill factor is low. Factors that guard against cold-exposure hazards include:

  • Appropriate clothing;
  • Warm shelter;
  • Carefully scheduled work and rest periods; and
  • Monitoring of employees’ physical conditions.

Please refer to the Heat and cold exposure subject for further information.

Animal and plant hazards

  • Workers conducting hazardous waste and emergency response operations outdoors should be prepared to guard against, check for, and avoid animal and plant hazards.

As with any work occurring outdoors, operations involving hazardous waste and/or emergency response may pose a host of animal and plant hazards. To prevent animal and insect bites and stings, employees should take the following safety and health measures:

  • To prepare for work:
    • Wear long pants and long-sleeved shirts.
    • Inspect and shake out clothing and shoes before getting dressed.
    • Cover exposed skin (as weather permits) when working in high grass to avoid potentially Lyme-transmitting deer tick bites.
    • Use insect repellent containing DEET or Picaridin on exposed skin.
    • Wear proper foot gear, such as high-top leather boots and leather gloves when handling materials where snakes, insects, and other animals may have nesting (e.g., firewood, lumber, rocks, or construction debris).
    • Discuss hazardous wildlife (e.g., alligators or poisonous snakes) with authorities familiar with these matters (e.g., game wardens or animal control officers).
  • Where animals may be present:
    • Inspect areas for nests and stray animals.
    • Remove all nearby sources of stagnant or standing waters.
    • Place hands and feet cautiously.
    • Avoid reaching into holes or under objects (e.g., lumber, scrap metal, overturned boats) without checking to see if snakes, insects, or other animals are present.
    • Avoid sitting or lying down in areas where snakes, insects, or other animals could be present (e.g., wood piles or high vegetation).
  • Where animals are or have been present:
    • Assume that all snakes are poisonous and that all animals are rabid.
    • Be on guard for stray or wild animals, as they can exhibit unpredictable or aggressive behavior.
    • Do not attempt to take custody of animals (unless trained to do so).
    • Watch animals from a safe distance while contacting animal rescue/control personnel.
    • Report all tick bites to medical personnel.

To prevent contact with poisonous plants, employees should:

  • Be trained on hazardous plant recognition.
  • Keep rubbing alcohol accessible, as it may remove the oily resin from plants, such as poison ivy up to 30 minutes after exposure.
  • Wear gloves, long pants, and long-sleeved shirts when possibly contacting poisonous plants.
  • Use a barrier cream formulated to protect against poison ivy/oak.
  • When appropriate, safely clear vegetation from areas where personnel are working and living (e.g., construction trailers or base camps).

Other hazards

  • Victims, witnesses, responders, and their families can all experience psychological trauma after an adverse event, so companies should provide assistance, known as “managing critical incident stress.”
  • Because environmental factors are all interconnected, damage can spread widely into various aspects of the environment.

Other hazards relate to hazardous waste operations and emergency response.

Psychological hazards

Witnessing or responding to a tragic event, such as an explosion, fire, or toxic release, can adversely impact a person psychologically. Emergency responders are no exception. Feelings of hopelessness, loss, and depression may affect a person months, even years, after an incident.

To lessen psychological effects, employers should provide for the mental well-being of victims; witnesses; responders; and families of victims, witnesses, and responders to an incident. This is called managing critical incident stress. Often, employee assistance programs are involved.

Property and environmental hazards

Depending on the type of release, the emergency response efforts, and the properties and environmental factors involved, property and environmental damage caused by an incident can be minimal to severe. Explosion and fire can cause the greatest damage to property.

Releases may vaporize and travel outside the immediate area, seep into groundwater, kill vegetation and wildlife, and cause other environmental damage. Air, water, land, vegetation, and wildlife interact with one another. Affecting one may affect them all.

Hazardous waste cleanup operations

  • The goal of hazardous waste cleanup is to make the site safer for people and the environment.
  • Exposure to hazardous wastes through skin contact, skin absorption, and inhalation pose the most significant risks to employees at cleanup sites.

Hazardous waste cleanup operations may include any of the following ways of dealing with hazardous waste:

  • Removing it
  • Containing it
  • Incinerating it
  • Neutralizing it
  • Stabilizing it
  • Clearing it up
  • Processing and handling it

Why is cleanup necessary?

When a large quantity of hazardous waste is stored or disposed of in an unsafe condition at unsafe locations, or when dump sites with hazardous waste have been abandoned, this presents a potential danger to human health and the environment. That’s because hazardous waste may be, for example:

  • Ignitable
  • Corrosive
  • Reactive
  • Toxic

Through the treatment or removal of improperly stored or discarded waste and subsequent disposal of it at an approved site, hazardous waste cleanup operations help to correct these problems. The ultimate goal of cleanup activities is to make the site safer for people and the environment.

Employee protection is important

Paragraphs (b) to (o) of 29 CFR 1910.120 and 1926.65 require employers to protect hazardous waste cleanup workers during cleanup operations and help them handle the wastes safely and effectively.

That’s because working with hazardous wastes can be dangerous and may require employees to enter potentially hazardous and unpredictable environments. Some chemical-related hazards they may encounter at a cleanup site include:

  • Toxic or poisonous substances
  • Corrosive materials
  • Eye or skin irritants
  • Respiratory or skin sensitizers
  • Asphyxiants
  • Cancer-causing agents
  • Oxygen-deficient or oxygen-rich atmospheres
  • Radioactive materials
  • Biological agents like bacteria and viruses
  • Flammable or explosive materials
  • Self-reactive substances
  • Compressed gases

In addition to hazardous wastes, there can be other site hazards, such as:

  • Electrical hazards
  • Confined spaces
  • Heat or cold stress
  • Equipment and tool hazards
  • Slip, trip, and fall hazards
  • Falling objects
  • Ergonomics issues
  • Excessive noise
  • Weather-related hazards

Exposure to hazardous wastes through skin contact, skin absorption, and inhalation pose the most significant risks to employees. Protecting employee safety and health is a major consideration when hazardous substances are present.

It is therefore important for employees to be sufficiently trained to recognize and deal with hazardous substances that may be present and any hazardous situation that may arise at a cleanup site.

Employee roles

  • Under hazardous waste cleanup operations, there are several roles — general, routine, and non-routine employees; onsite supervisor or managers; and emergency response personnel.

For hazardous waste cleanup operations, there are five distinct employee roles:

  • General site employee
  • Routine site employee
  • Non-routine site employee
  • Onsite supervisor or manager
  • Emergency response personnel

Depending on the nature of a site’s operations, the number of employee roles could vary. No matter which role they have, training is crucial for employees’ safety and health. The training they receive is dependent on the role.

However, employees may be able to bypass initial training if they received equivalent training (or work experience) somewhere else and have certification or documentation of it. Employees who bypass initial training must still receive site-specific training. Field experience at the new site is also required, except for emergency response personnel.

Most roles have both initial and refresher training requirements. All training should be provided in clear, concise language. Training consists of both classroom and hands-on instruction. Field experience under the direct supervision of a trained, experienced supervisor may also be required.

All employees working onsite must receive training before they are permitted to engage in hazardous waste operations that could expose them to hazardous substances, health hazards, or safety hazards.

In addition, all employees who are required to take annual refresher training will be prohibited from performing their duties if they fail to complete that training.

General site employee

General site employees are those engaged in hazardous substance removal or other site activities that expose or potentially expose them to hazardous substances and health hazards. This includes personnel like equipment operators, general laborers, and technicians.

Routine site employee

Routine site employees are those who work in areas that have been monitored that meet the following conditions:

  • Exposures are under the permissible exposure limits (PELs) and published exposure levels,
  • Respirators are not required,
  • There are no health hazards, and
  • There is no possibility of an emergency developing.

Non-routine site employee

Non-routine site employees are workers who are only onsite occasionally and are unlikely to be exposed over permissible exposure limits and published exposure levels. They include, for example, groundwater monitoring professionals or land surveyors.

Onsite supervisor or manager

Onsite supervisors or managers are employees who are directly responsible for or supervise employees who perform hazardous waste operations. They include project team leaders, command post officers, decontamination station officers, and the site safety and health officer.

Emergency response personnel

Emergency response personnel include any employees who are expected to respond to an emergency situation at a hazardous waste cleanup site.

Employee rights

  • OSHA-protected employees have rights including a safe work environment, adequate safety gear, access to information, and knowledge and use of these rights.
  • State and municipal workers aren’t protected by OSHA, except in “state-plan states” that have adopted OSHA-equivalent policies.

Employees have rights. In fact, that’s the reason the Occupational Safety and Health Administration (OSHA) was created by Congress. Its mission is to protect employees by creating and enforcing standards.

The Occupational Safety and Health Act (or OSH Act) lists what rights OSHA-protected employees have. It should be noted that federal OSHA only protects private employees. State and municipal employees have OSHA protections only if their state adopts those protections. Otherwise, state and municipal workers have no OSHA rights or protections.

Private employers in about half of the states and territories are covered by federal OSHA. However, states and territories that are approved by OSHA and have adopted protections identical or equivalent to OSHA’s protections are known as “state-plan states.” These state-plan states might cover private and public employers or just public employers. The list of state-plan states can be found at www.osha.gov/stateplans.

For employees who are protected, the top of the list of OSH Act rights is the right to a safe work environment. Other rights of covered employees that support their right to a safe work environment include:

  • The right to be provided personal protective equipment (PPE) and chemical protective clothing (CPC) at no charge (with a few exceptions).
  • The right to information about what hazards are present at work and how to protect themselves from those hazards.
  • The right to know about chemical hazards in their workplace. OSHA’s Hazard Communication (HazCom) Standard requires employers to:
    • Provide training on non-exempt hazardous chemicals,
    • Keep a current list of non-exempt hazardous chemicals,
    • Ensure non-exempt hazardous chemicals are properly labeled, and
    • Make safety data sheets (SDSs) available.
  • The right to request the following:
    • Copies of their own medical and exposure records,
    • Data from any tests that measure hazards (such as monitoring records),
    • The log of work-related injuries and illnesses (if any), and
    • To see any citations their employer received from OSHA.
  • The right to know about their rights. In fact, employers are required to post a poster about employee rights and employer responsibilities.
  • The right to be trained in a language they understand.
  • The right to use their rights.

OSHA-protected employees also have the right to refuse dangerous work under certain conditions. If employees are asked to perform tasks that put them at risk of serious physical harm or death, their right to refuse work will be protected if all of the following conditions are met:

  • Where possible, they have asked the employer to eliminate the danger, and the employer failed to do so;
  • They genuinely believe performing the tasks would put them in imminent danger;
  • Any reasonable person would agree there is a real danger of death or serious injury; and
  • The hazard is urgent, not allowing enough time for correction through enforcement such as an OSHA inspection.

OSHA says if such a “refuse-to-work” situation occurs, employees should:

  • Ask the employer to correct the hazard, or to assign other work,
  • Tell the employer they won’t perform the work unless and until the hazard is corrected, and
  • Remain at the worksite until ordered to leave by the employer.

Any employee who believes conditions are unsafe or unhealthy can request an OSHA inspection or file a complaint. Employees can request that their names be kept confidential, or an employee representative may contact OSHA for them.

Employees can even have an employee representative participate in an OSHA inspection and can speak in private with the inspector.

Finally, OSHA-protected employees have the right to exercise their rights without being retaliated against. Retaliation includes actions like being:

  • Fired or laid off
  • Blacklisted
  • Demoted
  • Denied overtime or promotion
  • Disciplined
  • Denied hire or rehire
  • Intimidated
  • Threatened
  • Reassigned in a manner that affects prospects for promotion
  • Given reduced pay or hours

An employee who is retaliated against for exercising any of these rights can file a complaint with OSHA but must act quickly — the complaint must be made within 30 days from the date the retaliation decision has been both made and communicated to the employee.

To file a complaint, employees can either call OSHA at (800) 321-OSHA (6742) or send a letter to the closest OSHA regional or area office.

Safety and health program

  • Hazardous waste cleanup operations must have a safety and health program with all required elements written down and implemented before any work begins.

Hazardous waste cleanup operation employees may be required to enter potentially hazardous environments with toxic substances, flammable materials, confined spaces, extreme heat, and slip-and-fall hazards. Therefore, their safety and health must come first in any hazardous waste cleanup operation.

Pre-planning all work activities is critical to employee safety and health. That’s why the “safety and health program” and all its elements must be written down and implemented prior to any work activities onsite, according to paragraph (b) of 29 CFR 1910.120 and 1926.65. The program may also be called a “health and safety program” (or HASP).

The safety and health program must include specific and detailed information on the following elements:

  • Organizational structure,
  • Comprehensive work plan,
  • Site-specific safety and health plan,
  • Safety and health training program,
  • Medical surveillance program,
  • Standard operating procedures (or SOPs) for safety and health, and
  • Any necessary interface between the general safety and health program and site-specific activities.

Program basics

The purpose of the program is to minimize risk to employees and the public. This is accomplished through the requirements to:

  • Identify, evaluate, and control safety and health hazards; and
  • Provide emergency response for hazardous waste cleanup operations.

The program must be available to:

  • Employees and their employee representatives;
  • Contractors, subcontractors, and their representatives involved in the hazardous waste operation;
  • Occupational Safety and Health Administration (OSHA) personnel; and
  • Any other government agency personnel with regulatory authority.

The safety and health program should be reviewed and updated to account for changes in the scope of work or hazardous substances onsite and any new information.

Interface between program and site-specific activities

One element of the safety and health program that lacks specific requirements but is very important requires coordination between the main program and site-specific activities. This also helps to ensure the safety and health program is revised as needed to reflect activities, changes, or new information specific to the site.

Organizational structure

  • The organizational structure of the safety and health program establishes the chain of command and shows lines of authority, responsibility, and communication.

The organizational structure defines clear roles and responsibilities of personnel, and it establishes a specific chain of command within the organization. Key roles to be identified include:

  • A general supervisor with the authority to direct activity;
  • A site safety and health supervisor who has the responsibility and authority to develop and implement the site-specific safety and health plan and verify its compliance; and
  • Other personnel needed for operations and emergency response, along with their duties.

Naming key personnel with their roles and titles in the organizational structure part of the program helps establish the chain of command. The structure shows lines of authority, responsibility, and communication between personnel and managers. In addition, it should identify how to communicate with response personnel.

The organizational structure must be kept current, meaning it must reflect the current status of a site’s operations.

The size of each operation will vary from site to site; therefore, the number and titles of personnel will also vary. The personnel who are essential at a safe hazardous waste cleanup site include:

  • Senior management
  • Project team leader
  • Field team leader
  • Command post supervisor
  • Decontamination station workers
  • Rescue team
  • Site safety and health officer
  • Work teams

Other personnel who may be present at a hazardous waste cleanup site include, but are not limited to:

  • Bomb squad experts
  • Communications experts
  • Environmental scientists
  • Health physicist
  • Industrial hygienists
  • Toxicologists

A strong commitment and good attitude toward safety is important from the beginning and for all levels of personnel, including management. Other organizational factors that contribute to successful safety and health programs include:

  • Open communication,
  • Good housekeeping and orderly work conditions,
  • Careful selection of personnel and job placement,
  • Advancement procedures and other employee support services,
  • Training in safety topics,
  • Effective safety practices, and
  • A disciplinary plan to ensure adherence to safety practices.

Comprehensive work plan

  • The comprehensive work plan in the safety and health program lays out the anticipated tasks and objectives with what’s required to achieve them.

Planning is the key element in a hazardous waste control program. Proper planning will greatly reduce worker hazards at waste sites.

Before work commences, the comprehensive work plan must be established. This plan describes the anticipated tasks and objectives of site operations, along with the logistics and resources required to accomplish them.

Specifically, the work plan must:

  • Address anticipated cleanup activities and normal operating procedures,
  • Define work tasks and objectives,
  • Identify how to accomplish work tasks and objectives,
  • Establish how many personnel are required to implement the work plan,
  • Provide for the implementation of required training and information, and
  • Provide for the implementation of required medical surveillance.

Items to consider when developing a comprehensive work plan include:

  • Site records,
  • Waste inventories,
  • Hazardous waste manifests,
  • Previous sampling and monitoring data,
  • Site photos,
  • State and local environmental and health agency records, and
  • Input from all levels of personnel and possibly consultants.

The work plan should support the overall objectives of the control program and provide standard operating procedures (SOPs) for implementation. The plan should incorporate the employer’s standard operating procedures for safety and health and should also include necessary coordination between the general program and site-specific activities.

Site-specific safety and health plan

  • The site-specific safety and health plan is an element of the larger safety and health program with the purpose of addressing the safety and health hazards of each phase of site operation.
  • Pre-entry briefings and periodic inspections work in concert with the plan to ensure continuing compliance with and effectiveness of the plan.

The site-specific safety and health plan (sometimes referred to as the site-specific HASP, for “health and safety plan”) aids in eliminating or effectively controlling anticipated safety and health hazards. The plan must identify the hazards of each phase of the specific site operation and must be kept on the worksite.

The plan needs to include all the basic requirements of the overall safety and health program, but with attention to those characteristics unique to the site. For example, it may outline confined space entry procedures, air and personal monitoring and environmental sampling, and a spill containment program to address the particular hazards present at the site.

Plan basics

The site-specific safety plan establishes policies and procedures to protect workers and the public from any potential hazards at a specific site. It must be kept onsite.

The plan is intended to minimize accidents and injuries during normal activity and adverse conditions like extreme temperatures. The information used to develop the plan (and revise the plan as new data or information is obtained) comes from the site characterization, which consists of three phases:

  1. A preliminary evaluation
  2. An initial site entry
  3. Ongoing evaluations

The plan should be developed by both onsite and offsite management, and it’s a good idea to have it reviewed by experts such as health physicists, chemists, and toxicologists.

Plan elements

Some of the elements (like training and medical surveillance) in the site-specific safety and health plan are also elements of the overall safety and health program. However, while the program addresses overall issues, the plan addresses site-specific concerns. It includes the following elements:

  • A hazard or risk analysis for each task and operation performed onsite found in the comprehensive work plan;
  • Confirmation that personnel have received proper training to perform their assigned tasks;
  • The personal protective equipment (PPE) to be used by workers for each task and operation performed onsite;
  • A description of site-specific medical surveillance requirements;
  • Types of monitoring and sampling to be performed onsite, including instruments (and their maintenance and calibration), methods, and frequency;
  • Site control measures under a site control program;
  • Decontamination procedures;
  • The emergency response plan or emergency action plan, whichever is applicable;
  • Confined space entry procedures; and
  • The spill containment program.

Pre-entry briefings

As a supplement to the plan, pre-entry briefings and safety meetings help to promote a safety-conscious work environment and apprise employees of the site-specific safety and health plan. These briefings should be conducted by the site safety officer or other informed, knowledgeable individual and may be held:

  • Prior to site activity, and
  • Any time new activities or changing conditions warrant it.

Safety meetings may also be held each day to ensure workers stay informed about safety expectations.

The purpose of briefings and safety meetings is to convey safety and health information and keep employees focused on safety and health. Topics they might address include:

  • The tasks to be performed and any associated hazards associated,
  • The coordination of activities,
  • Methods and precautions to prevent injury and illness,
  • Emergency plans,
  • Changes to the site-specific plan,
  • New conditions or information, and
  • Worker feedback on work conditions and the plan’s effectiveness.

Inspections

Inspections also help ensure the effectiveness of the site-specific safety and health plan. It’s important to inspect site conditions, facilities, equipment, and activities because conditions can change quickly with site activity, degradation of containers, equipment maintenance, and weather.

Inspections should be conducted by the site safety and health supervisor, or, in the absence of that individual, another person who is knowledgeable in occupational safety and health. When conducting inspections, employers should:

  • Use a checklist of items to inspect,
  • Review inspection results with supervisors and workers,
  • Reinspect identified issues to ensure they have been addressed,
  • Document all inspections and corrective actions, and
  • Retain inspection records.

Employers are responsible for correcting any deficiencies found in the site plan.

The frequency of inspections depends on the characteristics of the site and equipment. Things to consider:

  • The severity of onsite risks;
  • Regulations;
  • Operation and maintenance requirements;
  • The expected lifetime of equipment; and
  • Professional judgment, lab tests, and field experience.

Safety and health training program

  • Employees need to be trained in safety and health information and procedures applicable to their job duties before they do any work that might expose them to hazards.

Safety and health training is the program element that describes the training provided to general site employees. This training should be applicable to the work that employees will perform and consist of both classroom training and field experience under the direct supervision of a trained, experienced supervisor.

Employees must receive training before they are permitted to engage in hazardous waste operations that could expose them to hazardous substances, health hazards, or safety hazards.

General site employees are required to have initial training of at least 40 hours of classroom training and an additional three days of field experience. However, they may be able to bypass initial training if they received equivalent training (or work experience) somewhere else and have certification or documentation of the training (or work experience). In this case, they would still be required to have site-specific training before site entry, followed by appropriate supervised field experience at the new site.

Any employees who will be responding to hazardous emergency situations that may expose them to hazardous substances must also be trained in how to respond to expected emergencies.

Annual refresher training of at least eight hours is also required. Employees who fail to successfully complete this training must be prohibited from performing their duties.

The safety and health training program must address:

  • Names of personnel and alternates responsible for site safety and health,
  • Any hazards that are present onsite,
  • The proper use of personal protective equipment (PPE),
  • Work practices to minimize risks,
  • Safe use of engineering controls and equipment,
  • Decontamination procedures,
  • The emergency response plan,
  • Confined space entry procedures,
  • The spill containment program, and
  • Medical surveillance requirements.

More topics that may be included in the training program include:

  • Biology, chemistry, and physics of hazardous materials;
  • Toxicology;
  • Industrial hygiene;
  • Employee rights;
  • Monitoring and sampling;
  • Hazard evaluation;
  • Selection and care of PPE and chemical protective clothing (CPC);
  • The site-specific safety and health plan;
  • Standard operating procedures (SOPs); and
  • Applicable regulations.

Medical surveillance program

  • The medical surveillance component of the safety and health program provides for monitoring of the health of employees whose work puts them at high risk for illness.

Another required element of the safety and health program is the medical surveillance program. While much attention is focused on safety hazards, health hazards are also a real concern at hazardous waste cleanup sites.

One of the biggest health hazards is exposure to hazardous substances. It’s possible to be exposed to a hazardous substance and not even know it because some substances are odorless and colorless. Employees exposed can have no indication of its presence until they start feeling the effects of exposure, and the effects from some substances might not show up right away.

Because employees working around hazardous substances may be at high risk of illness, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires employers to provide initial and regular medical exams in addition to any needed medical attention. Five types of exams offered in the medical surveillance program include:

  • A pre-assignment exam
  • Periodic exams
  • A termination exam
  • Post-illness or -injury exams
  • Follow-up exams

The purpose of the medical surveillance program is to:

  • Establish employees’ baseline medical condition,
  • Assess fitness for duty,
  • Document exposures and medical conditions,
  • Detect and eliminate hazards, and
  • Ensure emergency and non-emergency treatment is provided.

Standard operating procedures (SOPs)

  • Employees should be trained in relevant SOPs — procedures for activities that can be standardized — prior to using them in the field.

As part of the safety and health program, the Occupational Safety and Health Administration (OSHA) requires employers to have written procedures for safe work practices. These standard operating procedures (SOPs) are used for activities that can be standardized. Some examples include:

  • Decontamination
  • Confined space entry
  • Respirator fit tests
  • Spill control
  • Emergency response

SOPs should be easy to understand; prepared in advance; and based on available information, operational principles, and technical guidance. In addition, they should be field tested and should be revised as necessary.

Employees should receive training on specific SOPs needed to perform their duties and should be encouraged to review them prior to using them in the field. This will ensure they understand all the steps involved in the tasks and are able to gather and prepare any equipment they may need.

Site characterization and analysis

  • Site characterization refers to a three-stage process of identifying and evaluating the hazards on a site.

Paragraph (c) of 29 CFR 1910.120 and 1926.65 addresses the requirements for site characterization and analysis.

When a cleanup site is “characterized,” the hazards on that site are identified. Knowing site hazards allows effective ways to be found to control those hazards. During site characterization, the idea is to get as much detailed information as possible in order to better protect site personnel.

Anyone responsible for site characterization must be qualified to identify hazards, interpret the data collected, and help select control methods. In addition, outside experts may be needed to help to fully interpret all the data. Chemists, health physicists, industrial hygienists, and toxicologists who have specialized knowledge can prove very helpful.

There are essentially three phases of site characterization:

  1. A preliminary evaluation
  2. Initial site entry
  3. Ongoing evaluation

Data gathered in the preliminary evaluation are used to write the initial plan and then, after the initial site entry, the plan is revised with the new data obtained during the entry. Any time ongoing evaluations reveal new information, the site-specific safety and health plan must be modified.

Cleanup site hazards

  • Workers at hazardous waste cleanup sites may be unable to avoid encountering a vast array of hazards, both chemical and physical.

An uncontrolled hazardous waste site means any site identified by the government where an accumulation of hazardous substances creates a threat to the health and safety of individuals, the environment, or both.

It may be impossible for hazardous waste cleanup site employees to avoid hazards. That’s because cleanup operations involve handling and processing hazardous substances to remove, contain, incinerate, neutralize, clear up, or stabilize them. The ultimate goal of a cleanup operation is to make the site safer for people and the environment.

Employees at a hazardous waste site might face both chemical and non-chemical health and physical hazards. The Occupational Safety and Health Administration (OSHA) considers a chemical to be a health hazard if it:

  • Is toxic
  • Is corrosive
  • Irritates the skin or eyes
  • Is a respiratory or skin sensitizer
  • Causes cells to mutate
  • Causes cancer, birth defects, or reproductive issues
  • Damages organs
  • Displaces (and thus deprives the employee of) oxygen
  • Is harmful or deadly if inhaled

Some chemicals can inflict physical damage when they react with the environment or other chemicals. The types of chemicals that can present physical hazards include:

  • Flammables
  • Explosives
  • Oxidizers
  • Self-reactive substances
  • Pyrophoric gases, liquids, and solids
  • Chemicals that emit flammable gas when in contact with water
  • Self-heating substances
  • Organic peroxides
  • Corrosive metals
  • Combustible dusts
  • Gases under pressure

Chemicals are not the only health and physical hazards employees may be exposed to. Other health hazards include:

  • Radiation (both ionizing and non-ionizing)
  • Biological hazards
  • Heat stress
  • Cold temperatures
  • Ergonomics issues
  • Noise
  • Psychological impacts

Some other physical hazards employees may encounter include:

  • Electrical hazards
  • Confined spaces
  • Equipment and tool hazards
  • Falling objects
  • Weather-related hazards like storms and lightning

More physical hazards that employees should be aware of as they move around onsite and perform their work activities include:

  • Holes, ditches, steep terrain, or uneven ground;
  • Slippery surfaces from rain or spills;
  • Sharp objects, such as nails, metal shards, and broken glass;
  • Precariously placed objects like drums or boards that may fall;
  • Unstable surfaces that may cave in or give way;
  • Heights from which an employee may fall; and
  • Tripping hazards.

Many hazards can also pose a threat to property and the environment. Chemical fires and explosions, for instance, can damage buildings, infrastructures, power sources, and technology.

Hazardous substances can seep into groundwater, ponds, and other bodies of water, killing off entire fish populations. In fact, the environment is very susceptible to hazardous substances. That’s because the air, land, water, vegetation, and wildlife all interact with each other. Damaging one may affect the others.

Preliminary evaluation

  • During the preliminary evaluation stage of site characterization, the site is evaluated without entry using interviews, records, sampling, and perimeter observations.

It’s important to have information about site hazards before anyone sets foot on a site, so that employers can make informed decisions about how to protect entry personnel.

During the first stage of site characterization — the preliminary evaluation — no one sets foot on the site. It’s all done offsite by a qualified person. (In fact, the preliminary evaluation is also referred to as an “offsite characterization.”)

The preliminary evaluation starts with conducting interviews and researching records.

Interviews should be with people who have knowledge about the site, such as former employees and their families or nearby residents. However, any information obtained through interviews must be verified.

Records, too, may turn up site information. Examples include:

  • Company records
  • Receipts
  • Workers’ compensation claims
  • Logbooks
  • Media reports
  • Historical and current aerial photos
  • Fire and police records
  • Land surveying records
  • Shipping papers
  • Water and sewage records

Next, air monitoring should be performed along the perimeter of the site to test concentrations of airborne contaminants. The perimeter should be monitored for:

  • Toxic substances
  • Flammable or combustible gases or vapors
  • Oxygen deficiency
  • Ionizing radiation
  • Specific substances that are known or suspected

Also, visual observations should be performed from the perimeter of the site. Things to look for include, but are not limited to:

  • Unusual odors;
  • Unusual conditions, such as vapor clouds, smoke, discolored liquids, oil slicks, or other suspicious substances;
  • Labels, markings, or placards on containers or vehicles;
  • Deterioration or damage of containers or vehicles;
  • Changes in vegetation, and
  • Changes in ground surfaces, such as mounding, depressions, and pits.

In addition, samples are usually collected and analyzed from offsite areas. A qualified person should take samples of the soil, surface water, site runoff, groundwater, and drinking water sources.

The Occupational Safety and Health Administration (OSHA) requires employers to obtain information prior to site entry that includes:

  • The location and approximate size of the site;
  • A description of the response activity and/or the job task to be performed;
  • The duration of the planned employee activity;
  • Site topography and accessibility by air and roads;
  • Safety and health hazards expected at the site, including conditions that may cause death or serious harm;
  • Pathways for hazardous substance dispersion;
  • The availability and capabilities of emergency response teams;
  • Hazardous substances involved or expected at the site and their chemical and physical properties;
  • Inhalation or skin absorption hazards that are immediately dangerous to life or health (IDLH);
  • Confined spaces;
  • Potentially flammable or explosive situations;
  • Visible vapor clouds; and
  • Biological indicators, such as dead animals or vegetation.

The employer should use all the information collected during the preliminary evaluation to determine what control measures to take to keep the initial site entry team safe during entry activities. For example, engineering controls like ventilation or wet methods may be needed. Respiratory protection is another type of control method an employer might require for entry.

Initial site entry

  • During the initial site entry phase of site characterization, a team of personnel in appropriate protective gear enters the site to make observations and take samples.

The second stage of site characterization is initial site entry. The purpose of this stage is to:

  • Verify the information gathered in the preliminary evaluation, and
  • Gather additional information.

No matter how thorough the preliminary evaluation is, there are always potential unknowns during an initial site entry. For that reason, a minimum of a Level B ensemble for protective clothing and equipment is highly recommended. A Level A ensemble must be worn for certain activities or if immediately dangerous to life or health (IDLH) conditions are expected.

The level of protective equipment and clothing worn during an initial site entry must be decided based on the results of the preliminary site evaluation. It must provide enough protection to keep exposure below permissible exposure limits (PELs) or published exposure levels.

If a positive-pressure self-contained breathing apparatus (SCBA) is not part of the entry ensemble but respiratory protection is necessary, then site entry personnel must carry escape SCBAs with at least five minutes of air.

If the preliminary site evaluation does not produce enough information to identify the hazards that may be present, then the team must wear at least a Level B ensemble for the initial site entry.

An initial site entry team should consist of a minimum of four personnel, and the buddy system must always be used — at least two employees enter the site, and at least two more employees wear the same (or higher) ensemble level as the entry employees but remain outside the site, ready to provide support in case of an emergency.

If the preliminary evaluation is insufficient or indicates the potential for ionizing radiation or IDLH conditions, one of the tasks of initial entry employees is to monitor the air and make visual observations to confirm site conditions. In this situation, the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires the use of direct-reading instruments, such as combustible gas meters and detector tubes, to check for:

  • Hazardous levels of ionizing radiation,
  • Any IDLH conditions, and
  • Other conditions that may cause death or serious harm (such as combustible, explosive, or oxygen-deficient atmospheres or toxic substances).

The standard also calls for visual observations for actual or potential IDLH or other dangerous conditions like enclosed spaces that must be entered, bulging drums, or open patches with dead vegetation.

If deadly or serious hazards are indicated, initial entry employees should proceed with extreme caution. It may be necessary to regroup and take extra precautions before continuing.

The other main task of initial entry employees is to gather additional information, such as:

  • The types of containers and storage systems;
  • Any containers in damaged, corroded, leaking, or unsound condition;
  • The quantities and physical states of materials (such as gases, liquids, or solids);
  • Potential exposure indicators, such as dead fish, an oily sheen on water surfaces, dust in the air, and pools of liquid;
  • Any safety hazards like unstable terrain and deteriorating structures;
  • Land features and natural wind barriers;
  • The presence of poisonous plants; and
  • Any signs, labels, tags, or other identifying markings.

Finally, when gathering additional information, workers will:

Collect samples from the air, soil, pools of liquids, storage containers, ditches, streams, and groundwater; and

Use non-invasive methods like metal detection or radar to locate buried wastes.

After the initial site entry is completed, all the new information must be analyzed by a qualified person prior to starting operations onsite. This analysis will ensure employees are aware of:

  • Specific hazardous substances onsite and their concentration levels,
  • Any other health hazards that are present at the site, and
  • Any other physical hazards that are present at the site.

Once the presence and concentrations of specific hazardous substances and health hazards have been established, the risks associated with these substances must be identified. Some risks that must be considered include:

  • Exposures exceeding the PELs and published exposure levels,
  • IDLH concentrations,
  • Potential skin absorption and irritation sources,
  • Potential eye irritation sources,
  • Explosion sensitivity and flammability ranges, and
  • Oxygen deficiency.

Before work begins onsite, the employer must make available to employees information concerning any identified risks and the properties of each hazardous substance present or anticipated at the site, if those substances are relevant to the duties workers are expected to perform. The employer may use the Hazard Communication (HazCom) Program for this purpose.

Ongoing evaluation

  • During the ongoing evaluation phase of the site characterization process, air monitoring and workers’ observations keep track of any changes in conditions.

Once the initial site entry has been made and conditions analyzed, and it is determined the site is safe to start cleanup operations, appropriate engineering controls and personal protective equipment (PPE) must be selected and used for the tasks to be performed.

However, site characterization and analysis does not end there. Ongoing air monitoring must be implemented to provide information about any changes in conditions. Also, employees should be instructed to note any changes or new information and to immediately report to their supervisor anything different or unusual.

Site control

  • A site control program must be established before work begins in order to minimize worker contamination, protect the environment and the public, and prevent unauthorized access and vandalism.

Maintaining site control is essential, especially in hazardous and emergency situations. The site control program is addressed in paragraph (d) of 29 CFR 1910.120 and 1926.65. The purpose of the program is threefold:

  • To help minimize the potential of worker contamination,
  • To protect the environment and the public, and
  • To prevent unauthorized access and vandalism.

Some of the elements in the site control program include a site map, work zones, communications, and site security.

The employer must establish the site control program early in the planning stages. Site control procedures should be implemented before hazardous waste cleanup begins in order to control employees’ exposure to hazardous substances.

The site control program must be modified as necessary whenever new information about site conditions or hazards becomes available.

Site control program elements

  • The site control program must establish a site map, work zones, a buddy system, communications methods, safe work practices, and medical assistance procedures.

The elements of the site control program are as follows:

  • Site map
  • Site work zones
  • Buddy system
  • Communications
  • Safe work practices
  • Medical assistance

Site map

Site maps are created to show topographic features; prevailing wind direction; drainage patterns; hazards present; and locations of buildings, containers, pits, ponds, and tanks. Activities in which a site map can be helpful include:

  • Planning projects and work activities;
  • Assigning personnel;
  • Establishing access routes, evacuation routes, and problem areas;
  • Determining areas that require the use of personal protective equipment (PPE); and
  • Supplementing daily safety meetings.

An initial site map should be prepared before site entry and updated regularly to show:

  • Changes in site activities and operations,
  • Any onsite accidents or emergencies,
  • New hazards that are discovered,
  • New materials that are introduced,
  • Unauthorized entry or incidents of vandalism, and
  • Changes to weather patterns.

To show information without cluttering the map, overlays may be useful.

Site work zones

Refer to the More about site work zones section found elsewhere in this subject to learn about the three typical work zones at a site.

Buddy system

Workers in the Exclusion Zone (EZ) or any other hazardous areas must use the buddy system. When using the buddy system, employees are expected to:

  • Provide each other with assistance,
  • Observe each other for signs or symptoms of illness or injury,
  • Verify the integrity of one another’s PPE, and
  • Notify the Command Post Supervisor or others if an emergency develops.

Buddies enter the EZ through the access control point and must stay near to and in line of sight of each other, while in the EZ.

Communications

Two types of communications are needed for site control:

  • For internal communication between onsite employees, and
  • For external communication between onsite employees and offsite personnel.

Site personnel should be aware of the expectations for both internal and external communications.

Internal communication is used to inform workers of an emergency, to update personnel on safety information or changes in the work scope, and to help maintain control of the site. Both a primary and a backup means of internal communication should be set up and understood by all employees. It’s a good idea to establish a set of signals to be used only in emergencies.

Note that any communications used in potentially explosive atmospheres must be intrinsically safe.

Audible internal communications might include two-way radios, bells, whistles, sirens, megaphones, or an air horn. These communication methods could be impeded by background noise, respirators, and hoods. Therefore, when audible communication is difficult or impossible, visual communications might be preferred, such as hand signals, whole-body movements, lights, flares, or flags. In fact, flags also work great at providing visual awareness of workers in areas of poor visibility.

To allow them to identify each other, employees should mark their names on their protective clothing. Color-coding, numbers, or symbols can be added for long-distance identification.

Communication devices should be checked daily to ensure they are working properly.

Telephones (including landlines and cellphones) and radios are the primary means of external communication. A list of important phone numbers should be kept readily available. Site personnel may need to communicate externally to:

  • Coordinate emergency response efforts,
  • Report to management, and
  • Maintain contact with essential offsite personnel.

Medical assistance

The site manager should maintain and post the identification and location of the nearest medical facilities. This critical information should be posted near phones or other external communication devices.

Posted information may include names; addresses; phone numbers; maps; directions; and procedures for contacting the nearest area hospitals/clinics and emergency ambulance, fire, and police.

Before work commences at the site, staff at nearby medical facilities should be made aware of the types of activities that take place onsite and the hazards that are present.

Other recommended program elements

  • Site preparation and site security are useful to include in a site control program to ensure the safety of the site and those around it.

The site control program is not required to contain these elements, but they are recommended:

  • Site preparation
  • Site security

Site preparation

A lot of work goes into getting a site ready for daily cleanup activities. Dangers can be present during these preparations, so safety and protective measures are important.

During site preparation, roadways may need to be constructed. Whether sufficient roadways exist or not, traffic signs are installed to safely direct the flow of heavy equipment and vehicle traffic.

Efforts should then be made to remove as many hazards as possible. Steps that can be taken to eliminate hazards include:

  • Ensuring no ignition sources exist in flammable areas.
  • Working with the Site Safety Officer and local utility company to remove or fix any exposed, ungrounded, or low-hanging power lines or electrical wires. Only properly trained and qualified persons may handle electrical hazards.
  • Removing or guarding any sharp or protruding objects.
  • Addressing any slip, trip, or fall hazards, such as loose stair treads, unsecured railings, debris, and holes.
  • Securing or removing objects on elevated surfaces, such as catwalks, rooftops, and scaffolding.
  • Removing any debris that obstructs visibility.
  • Installing skid-resistant strips or devices on slippery surface areas.

Other site preparations may include:

  • Constructing foundations for temporary structures, mobile facilities, and decontamination areas.
  • Constructing loading docks, processing areas, and staging areas.
  • Installing any wiring or electrical equipment required according to code.
  • Installing adequate lighting for performing work activities effectively and safely in all work areas.

If temporary lighting is installed, protective guarding around the lighting should be put in place to prevent breakage from accidental contact with it.

Site security

Site security is a site control plan element because it helps to:

  • Prevent unauthorized and unprotected people from exposure to hazards onsite;
  • Avoid vandalism, theft, and abandoned wastes; and
  • Avoid interference with safe work procedures.

In addition to manned access control points, a hazardous waste cleanup site may implement several different controls for maintaining site security. Other security measures that can be taken include:

  • Erecting fencing or other physical barriers and warning signs around the perimeter of the site.
  • Using security guards to patrol the perimeter.
  • Establishing an identification system including log-in procedures to quickly distinguish between authorized and unauthorized persons.
  • Adopting a policy requiring visitors to have a valid reason to be onsite, approval for their visit, and a trained site employee to escort them.
  • Assigning trained site employees for site surveillance.
  • Enlisting help from local police departments if there is a threat to the surrounding community.
  • Securing all equipment.

More about site work zones

  • The three work zones, from most to least dangerous, are the Exclusion Zone (or hot zone), the Contamination Reduction Zone, and the Support Zone (or cold zone).
  • The Support Zone should have no danger of contamination.

Setting up work zones onsite, another element of the site control program, is important because it reduces the spread of contamination, helps ensure proper personal protective equipment (PPE) is worn when working with hazardous substances, confines work activities to appropriate locations, and facilitates the location of personnel in emergency situations.

The boundaries of site work zones are decided based on the data collected during site characterization, including monitoring and sampling results. Access control points should be used to restrict the movement of personnel between the zones. This approach will also minimize the spread of contamination to clean areas.

Hazardous waste cleanup sites can have as many work zones as needed to operate safely. Most often, however, there are three work zones:

  1. The Exclusion Zone (EZ)
  2. The Contamination Reduction Zone (CRZ)
  3. The Support Zone

Exclusion Zone

The innermost work zone where contamination is present is the EZ. This area is also referred to as the “hot zone.” The EZ extends outward far enough to prevent adverse effects to personnel outside the zone. Its outside perimeter is marked with ropes, barricade tape, stanchions, cones, chains, fencing, walls of existing buildings, or other markers. This boundary is called the “hotline.”

When establishing how far the EZ should extend and where to place the hotline, the employer will consider, among other things: the results of sampling and monitoring during the initial site entry, the safe distance in the event of a fire or explosion, the area needed to perform work activities, and typical wind and weather patterns.

Only employees with proper training, PPE, and chemical protective clothing (CPC) are allowed to enter the EZ through the access control point. Entering and exiting only through the access control point helps regulate the flow of personnel and equipment and verify that proper procedures are used. Personnel that typically work in the EZ include the Field Team Leader, work parties, and heavy equipment operators or other specialized workers. Emergency responders may also be found in the EZ in an emergency situation.

Work activities performed in the EZ might include:

  • Monitoring and sampling,
  • Installation of wells for groundwater monitoring, and
  • Handling and processing hazardous waste, such as drum opening, drum staging, and other cleanup activities.

The EZ may be further subdivided into zones with varying degrees of hazards, incompatibilities, and PPE requirements. Each subdivision should be clearly marked, and protection requirements for each should be defined.

Contamination Reduction Zone

The CRZ is a buffer or transition area between the EZ and the Support Zone. The outer boundary of the CRZ, called the contamination control line, must be clearly marked.

Just like the EZ, no one is allowed to enter the CRZ unless they have had the proper training and are wearing the required PPE and CPC. Access is obtained through an access control point, which may even be staffed to make sure no unauthorized personnel enter the area.

A Contamination Reduction Corridor (or CRC), also known as the “decon line,” is set up inside the CRZ. It’s in this corridor that all the decon activities take place. This includes the decontamination and removal of PPE and protective clothing.

The CRC limits decon activities to a confined area and helps to minimize the spread of contamination. There may be more than one decon line in the corridor because a separate line is often used to accommodate the decontamination of heavy equipment and vehicles.

All entry and exit from the EZ is made through the access control points on the edges of the CRC. Each person or item in the CRC must be thoroughly decontaminated before entering the Support Zone.

Personnel working in the CRZ include the Site Safety Officer, a Personnel Decontamination Station (PDS) Operator, and decontamination crews. Emergency responders may enter the CRZ during an emergency.

People working in the CRZ may be there to:

  • Decontaminate personnel, tools, vehicles, and heavy equipment;
  • Maintain communication with work parties in the EZ;
  • Monitor work parties for signs and symptoms; and
  • Maintain site security.

Support Zone

The outermost zone is the Support Zone. This is also known as the “clean area” or “cold zone” and consists of all areas outside the contamination control line.

No one should be exposed to hazardous substances in the Support Zone. That means there is no need to wear protective equipment and clothing in this zone in relation to hazardous substances.

The command post, first aid station, emergency transport vehicles, equipment and supply center, field laboratory, lockers, and showering or changing facilities are all located in the Support Zone.

Factors that should be considered when making decisions about where to locate support facilities include:

  • Locations of roads, highways, and railroad tracks and ease of access for emergency vehicles;
  • Available resources like water, shelter, power lines, and telephone service;
  • The line of sight to activities in the EZ;
  • The prevailing wind direction (support facilities should be upwind of the EZ); and
  • The distance from the EZ (support facilities should as far from the EZ as practicable).

All support activities are managed and handled from the Support Zone. The Command Post Supervisor runs daily and emergency activities from the command post in this area. Other employees who may be in the Support Zone include the project team leader, field team members who are preparing for entry or have returned from entry, medical personnel, and administrative personnel.

Other support work performed in the Support Zone might include:

  • Maintaining communication;
  • Recordkeeping;
  • Monitoring work schedules;
  • Maintaining site security;
  • Performing medical activities;
  • Inspecting, maintaining, and repairing equipment and supplies;
  • Performing administrative duties; and
  • Handling and processing field samples.

Hierarchy of controls

  • Effective hazard control measures range from eliminating the hazard (most effective) to wearing PPE (least effective).

The functions of effective control measures include:

  • Protecting employees from workplace hazards;
  • Helping avoid injuries, illnesses, and incidents;
  • Minimizing or eliminating safety and health risks; and
  • Helping employers provide safe and healthful working conditions.

The employer will select the controls that are the most feasible, effective, and permanent for the site. The “hierarchy of controls,” from most effective to least effective, is as follows:

  1. Eliminate or remove the hazard;
  2. Substitute or replace the hazard;
  3. Use engineering controls to isolate people from the hazard;
  4. Use administrative controls to reduce the duration, frequency, and severity of exposure to hazards;
  5. Use safe work practices; and
  6. Wear personal protective equipment (PPE) around the hazard.

Eliminating a hazard could be as simple as noticing a sharp object and safely removing it or seeing a cord stretched across a pathway and putting this tripping hazard away. Both of these scenarios involve identifying and removing a hazard. An employer could also replace a safer chemical for a more hazardous one, thereby controlling the hazard by substitution.

Engineering controls are physical changes at the site to isolate people from the hazard or otherwise eliminate or reduce the hazard on the job or during the task. Examples include changing a process to minimize contact with hazardous substances, isolating or enclosing a process, using wet methods to reduce generation of dusts or other particulates, ventilating to dilute the air, using fume hoods, or using remotely operated equipment.

Administrative controls are policies and practices that reduce the duration, frequency, and severity of exposure to hazards. This control measure includes, but is not limited to: job rotation, shortened shift lengths, limiting overtime, taking frequent breaks, decreasing production rates, and increasing the number of employees assigned to a task.

Safe work practices are sometimes called “standing orders.” They are an element of the Site Control Plan and contribute to safety awareness. Anyone entering the site should be made aware of the expected safe work practices. A list may be maintained at the command post and access control points.

Some common safe work practices at a hazardous waste cleanup site are offered in the Engineering, administrative, and work practice controls section.

Employees could be reminded of safe work practices during daily job briefs. Whenever there is a new employee or a new project, a briefing should be provided about hazardous substances that might be encountered.

Standard Operating Procedures (or SOPs) are detailed documents that have steps for safety built into them and ensure each employee performs the task consistently. Of course, SOPs are only effective if they’re followed. They are used for many tasks, such as decontamination, selecting and inspecting PPE, entering confined spaces, handling drums, and locking out equipment.

The process of eliminating or substituting hazards and putting engineering, administrative, and work practice controls in place will help to mitigate many hazards. However, when hazards remain, there’s one more control method that employers may be required to provide to protect their workers — PPE.

PPE can help employees perform tasks within or alongside hazards, such as hazardous substances, noise, elevated surfaces, or electrical hazards. But, as important as PPE is, it has its limitations. PPE does not control the hazard; it merely controls exposure to the hazard by setting a barrier between the employee and the hazard. PPE is not suitable for all situations. For example, no single type of glove can protect against all solvents.

Fire control and sanitary measures

  • Fire control measures include firefighting personnel and equipment, as well as detection and alarm systems.
  • Sanitary measures have to do with food, water, hygiene, and living conditions.

Fire is among the deadliest of work hazards. Due to the nature of many hazardous substances at hazardous waste cleanup sites, fire is a real threat. Control measures must be in place to help protect against fire once it starts.

The different forms of fire protection that might be found at a site include:

  • A fire brigade;
  • Portable fire extinguishers;
  • Standpipe and hose systems;
  • Fixed fire suppression equipment, like automatic sprinkler systems;
  • Fire detection systems; and
  • Employee alarm systems.

Sanitation is yet another control measure. Sanitary measures are used to maintain an acceptable level of personal hygiene and to reduce the likelihood of exposure to hazardous substances through ingestion or dermal contact. Sanitary measures that must be taken at a hazardous waste cleanup site include the following:

  • Adequate washing facilities must be provided for those engaged in operations involving hazardous substances. These facilities must be provided in areas where exposures are below permissible exposure limits (PELs) or published exposure levels.
  • Adequate numbers of toilets must be provided.
  • If the site is operating for six months or longer, showers and changing rooms must also be provided.
  • If sleeping quarters are provided, they must be heated, ventilated, and lighted.
  • Food-handling measures must meet local codes.
  • Potable and non-potable water systems must be kept separate.
  • Non-potable water systems must be clearly marked, indicating that the water is unsafe for drinking, washing, or cooking.
  • Portable containers used for drinking water must be designed to prevent contamination of the water, be clearly marked as drinking water, and be equipped with a tap. Employees must not be allowed to dip water from the container.

Training

  • Employees aren’t allowed to perform any hazardous waste operations until they have either been trained and certified or shown documentation of equivalent knowledge acquired elsewhere.
  • Trainers must either be trained in how to train others in the subject, or they must have acquired the necessary subject matter and instructional expertise.

Paragraph (e) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard lists all the employee training requirements. Training is critical for recognizing, understanding, and handling the many safety and health hazards that are present at a hazardous waste site.

A training program is required under the safety and health program and is also part of the site-specific safety and health plan. This training must be provided to all employees who will work on the site, such as equipment operators, general laborers, and supervisors or managers who may have exposure to hazardous substances.

Employees at all sites must not perform any hazardous waste operations unless they have been:

  • Trained to the level necessary for their job function and responsibility and certified by a qualified trainer as having completed the required training; or
  • Shown by documentation or certification that their work experience and/or training has resulted in training equivalent to the training required, in accordance with subparagraph (e)(9) of 29 CFR 1910.120 and 1926.65.

Trainer qualifications

Trainers must be qualified to instruct employees about the subject matter that is being presented in training. Such trainers shall have either:

  • Satisfactorily completed a training program for teaching the subjects they are expected to teach, or
  • Acquired the academic credentials and instructional experience necessary for teaching the subjects.

Instructors must have competent instructional skills and knowledge of the applicable subject matter.

Initial and refresher training and certification

  • The amount of initial training required depends on an employee’s job role, but almost everyone is required to have eight hours of annual refresher training.

Before any work on a hazardous waste cleanup site, the employer must provide employees with initial training based on their tasks and operations and the anticipated exposures (see the table below).

Employees who have equivalent experience and skills from previous work experience and/or training do not have to receive the initial training, provided that the employer can verify it through documentation or certification. However, equivalently trained employees who are new to a site must receive site-specific training before site entry.

Trainee typeRequired initial and refresher trainingRegulation
General waste site employees (e.g., equipment operators or general laborers)
  • 40 hours initial training
  • 24 hours supervised field experience
  • 8 hours annual refresher
Subparagraph (e)(3)(i) of 29 CFR 1910.120 or 1926.65
Employees occasionally onsite for a limited task (e.g., groundwater monitoring or land surveying) with minimal exposure (also called non- routine site workers)
  • 24 hours initial training
  • 8 hours supervised field experience
  • 8 hours annual refresher
Subparagraph (e)(3)(ii) of 1910.120 or 1926.65
Employees regularly onsite who are not exposed to health hazards (also called routine site workers)
  • 24 hours initial training
  • 8 hours supervised field experience
  • 8 hours annual refresher
Subparagraph (e)(3)(iii) of 1910.120 or 1926.65
Employees under (e)(3)(ii) or (iii) who become general site workers under (e)(3)(i)
  • 16 hours of additional training
  • 16 hours of additional supervised
  • field experience
Subparagraph (e)(3)(iv) of 1910.120 or 1926.65
Supervisors of general site employees (e.g., equipment operators or general laborers)
  • 40 hours initial training
  • 24 hours supervised field experience
  • 8 hours of specialized training in employer’s safety and health-related programs
  • 8 hours annual refresher
Subparagraph (e)(4) of 1910.120 or 1926.65
Supervisors of non-routine site worker
  • 24 hours initial training
  • 8 hours supervised field experience
  • 8 hours specialized training in employer’s safety and health-related programs
  • 8 hours annual refresher
Subparagraph (e)(4) of 1910.120 or 1926.65
Supervisors of routine site workers
  • 24 hours initial training
  • 8 hours supervised field experience
  • 8 hours specialized training in employer’s safety and health-related programs
  • 8 hours annual refresher
Subparagraph (e)(4) of 1910.120 or 1926.65

Employees who receive the specified training must receive a written certificate from their instructor (or the head instructor) and trained supervisor upon successful completion of that training. A written certificate shall be given to each person so certified.

If the employee goes to work at a new site, the training does not need to be repeated; however, the employee must receive the necessary additional site-specific training needed to work safely at the new site.

All employees must receive eight hours of annual refresher training as indicated in the table above. This training may include any critique of incidents that have occurred in the past year, examples of related work, and other relevant topics.

Notes:

  • Subparagraph (e)(7) of 1910.120 and 1926.65 also calls for the training of employees who are engaged in responding to hazardous emergency situations at hazardous waste cleanup sites that may expose them to hazardous substances. That training must cover how to respond to such expected emergencies. No training duration is specified. Please refer to the Emergency response for uncontrolled hazardous waste sites section found elsewhere in this subject for further discussion.
  • Non-mandatory Appendices C and E to the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 1910.120 and 1926.65 provide useful compliance guidelines and assistance in developing a site-specific training curriculum used to meet the training requirements in paragraph (e) of 1910.120 and 1926.65.

Training elements

  • Supervisors and employees must be trained to understand and follow policies and procedures and to use and care for equipment.

Training makes employees aware of the potential hazards they may encounter and provides the necessary knowledge and skills to perform their work with minimal risk to their own and others’ safety and health. Both supervisors and employees must be trained to:

  • Recognize hazards and prevent them;
  • Select, care for, and use respirators properly, as well as other types of personal protective equipment (PPE);
  • Understand engineering controls and their use;
  • Use proper decontamination procedures; and
  • Understand:
    • The emergency response plan,
    • Medical surveillance requirements,
    • Confined space entry procedures,
    • The spill containment program, and
    • Any appropriate work practices.

Employees also must know the names of personnel and their alternates responsible for site safety and health. Site personnel who are expected to respond to emergency situations at the site must receive additional training in how to respond to anticipated emergencies (e.g., fires, explosions, hazardous spills).

Training format

  • HAZWOPER training can include a computer-based component, as long as the overall training program provides employees with hands-on experience and the ability to ask questions of a trainer.

According to the Occupational Safety and Health Administration (OSHA), use of computer-based (or online) training by itself is not sufficient to meet the intent of most of OSHA’s training requirements, in particular those of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. However, self-paced, interactive computer-based training can serve as a valuable training tool in the context of an overall training program. OSHA’s position on this matter is essentially the same as the agency’s policy on the use of training videos, since the two approaches have similar shortcomings.

OSHA urges employers to be wary of relying solely on generic, “packaged” training programs in meeting the agency’s training requirements. For example, training under HAZWOPER requires site-specific elements and should also, to some degree, be tailored to employees’ assigned duties.

In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them. In a computer-based program, HAZWOPER training requirements may be met by providing a telephone hotline so that trainees will have direct access to a qualified trainer.

Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting. Many industrial operations, and in particular hazardous waste operations, can involve complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely.

Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks. The purpose of hands-on training, for example in putting on and removing personal protective equipment (PPE), is twofold:

  1. To ensure that employees have an opportunity to learn by experience, and
  2. To assess whether employees have mastered the necessary skills.

Sole reliance on a computer-based training program is unlikely to achieve these objectives.

Thus, OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer and provides trainees with sufficient hands-on experience.

Medical surveillance

  • HAZWOPER requires employers to provide medical exams and consultations for employees who work with hazardous waste.
  • There are five main types of medical exams: pre-assignment, periodic, termination, post-illness or -injury, and follow-up.

Employees who work with hazardous waste during cleanup operations or respond to emergency response situations face health hazards and may be at high risk of illness. Therefore, it is essential that they get initial and regular medical exams in addition to any needed medical attention.

Paragraph (f) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard addresses the provisions for medical surveillance, which means that employers are required to provide their employees with medical exams and consultations and keep records of the physicians’ written opinions.

All examinations pertaining to the medical surveillance program must be performed by or under the supervision of a licensed physician, preferably one knowledgeable in occupational medicine. These exams must be provided at no cost, without loss of pay, and at a reasonable time and place.

According to the HAZWOPER Standard, five main types of exams are available:

  • Pre-assignment exam
  • Periodic exam
  • Termination exam
  • Post-illness or -injury exam
  • Follow-up exam

Introduction

  • Besides hazardous substance exposure, potential health hazards at a worksite include heat and cold, radiation, and noise.

While much attention is focused on safety hazards, health hazards are a real concern as well. Employees who work at hazardous waste cleanup sites or respond to emergency releases of hazardous substances may be exposed to health hazards.

One health hazard found in these two operations (hazardous waste cleanup and emergency response) is exposure to hazardous substances. It’s possible to be exposed to a hazardous substance and not even be aware of it because some substances are odorless and colorless. The first indication of the presence of these substances might be the employee feeling the effects of exposure. The trouble is the effects from some substances might not show up right away.

Besides exposure to hazardous substances, other potential health hazards include, but are not limited to:

  • Heat stress
  • Cold exposure
  • Biologic hazards
  • Ionizing radiation
  • Oxygen deficiency
  • Noise

With so many health hazards, the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires covered employers to perform medical surveillance and, for cleanup operations, have a written medical surveillance program in place.

Besides being required, medical surveillance is performed for many reasons, including:

  • To diagnose and treat injuries or illnesses early;
  • To establish an employee’s baseline medical condition;
  • To assess an employee’s fitness for duty, including the ability to wear personal protective equipment (PPE) and chemical protective clothing (CPC);
  • To document exposures and medical conditions;
  • To detect and eliminate hazards and exposures contributing to health problems; and
  • To ensure emergency and non-emergency treatment is provided.

Who needs medical surveillance?

  • Under HAZWOPER, employers are required to provide medical surveillance, but employees can opt out of it.

For hazardous waste cleanup operations, medical surveillance must be made available to employees if:

  • They are or may be exposed for 30 or more days a year to hazardous substances or health hazards at or above the permissible exposure limits (or PELs), or, if no PEL is available, then over the published exposure levels for these substances.
  • They wear a respirator for 30 days or more a year.
  • They are injured, become ill, or develop signs or symptoms due to possible overexposure involving hazardous substances or health hazards.
  • They belong to a HAZMAT team, whose members are expected to control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance.

Employees who fit any of the criteria listed above are considered “covered employees.”

Under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, employers are obligated to make medical surveillance available without cost to employees, but the Occupational Safety and Health Administration (OSHA) does not require employees to participate. If an employee chooses not to take part in the medical surveillance program, this should be documented with a signed record in the employee’s personnel file.

HAZWOPER training should incorporate the purpose and content of the medical surveillance program required by the standard so employees understand that it is for their protection.

OSHA does not require employees to take a medical exam. However, employees who refuse to be medically evaluated cannot be assigned to work in areas where they are required to wear a respirator.

Signs and symptoms of overexposure

  • There are two types of chemical exposure — acute (high concentration over a short time) and chronic (lower concentrations over a longer time).

There are many different hazardous substances, and the effects they can have on humans range from mild to deadly. Employees should be trained to seek medical attention immediately if they detect signs or symptoms in themselves or coworkers.

Some signs and symptoms that could indicate an exposure to hazardous substances include:

  • Weakness;
  • Headache;
  • Cramps, diarrhea, or nausea;
  • Decreased mental ability, confusion, or unconsciousness;
  • Arm or leg numbness;
  • Irritability, dizziness, poor balance, tremors, or convulsions; and
  • Fatigue.

It should be noted that chemical exposure may not be noticeable right away. Chemical exposures are generally divided into two categories:

  • Acute exposure. Exposure to a substance over a short period of time, typically in an isolated incident. Symptoms usually occur during or shortly after exposure to a sufficiently high concentration of the substance. Generally, medical attention and treatment are sought once symptoms are detected.
  • Chronic exposure. Exposure to low concentrations of a chemical over a long period of time. It can take years for the effects or symptoms to show up. However, this is part of the reason for medical surveillance, which can help detect exposures earlier than people might detect them on their own.

Types of medical exams

  • Under HAZWOPER, covered employees should receive medical exams and consultations to determine their fitness for duty and establish a baseline, compare to that baseline, evaluate illness and injuries, and keep their records up to date.

The medical surveillance program includes five types of medical exams, which are conducted at different points in employees’ job tenures to gather data about their health, both as a baseline and in relation to time and chemical exposure.

Pre-assignment exam

Employees must be offered a medical exam and consultation before performing any work that makes them a “covered employee” (see the Who needs medical surveillance? section). The pre-assignment exam, also called the initial exam, serves two purposes:

  • To determine fitness for duty, and
  • To acquire baseline data for comparison with future medical exams.

The physician will assess an employee’s ability to perform the physically demanding tasks their job may require in order to determine fitness for duty. The physician must assess the occupational and medical history but may also consider a physical exam of the organs, with emphasis on the heart, lungs, and musculoskeletal systems, and an assessment of the employee’s ability to work while wearing personal protective equipment (PPE) and/or chemical protective clothing (CPC).

The employee will be asked to fill out a medical questionnaire with a very detailed occupational and medical history. The physician will use this to:

  • Review prior occupational exposures to chemical and physical hazards;
  • Review past illnesses and chronic diseases, such as asthma and lung or heart disease;
  • Review symptoms, past or present, such as shortness of breath, respiratory symptoms, cardiovascular issues, or heat intolerance;
  • Assess any sensitivity to specific substances; and
  • Assess any relevant hobbies and lifestyle habits, like smoking, drinking alcohol, and drug use.

Next, the physician performs a comprehensive physical examination including the following:

  • Height, weight, temperature, pulse, respiration, blood pressure, head, nose, throat, vision, and hearing;
  • The condition of the organs, with particular attention to the pulmonary, cardiovascular, and musculoskeletal systems;
  • Blood chemistry, urinalysis, and chest x-ray;
  • Any conditions that heighten vulnerability to heat stroke, such as obesity or poor physical condition;
  • Any conditions that may interfere with respirator use, such as facial scars, dentures, or poor eyesight; and
  • Any other limitations concerning the ability to use PPE and/or CPC.

A pulmonary function test, stress test, and/or electrocardiogram (EKG) may also be administered. Employees can be assigned to tasks that require respirators only if they have been determined to be physically able to perform under such conditions.

The physician uses all the information gathered to determine whether the employee is fit for duty as a covered employee. However, the pre-assignment exam will also acquire baseline data, which:

  • Provides a measure for determining if subsequent exposures have adversely affected the employee’s health, and
  • Creates a data set for the employer to verify the effectiveness of control measures.

Based on what substances employees may be exposed to, tasks they will be expected to perform, and their medical and work history, the physician will determine what other tests to administer to obtain baseline data. Some of the following will likely be part of the exam:

  • EKG
  • Pulmonary function test
  • Hernia exam
  • Skin exam
  • Heavy metal screen
  • Blood tests for other toxicants likely to be onsite
  • Radiological bioassay
  • Any other tests the physician deems necessary

Periodic exam

Periodic exams are essential to medical surveillance. By comparing baseline data from the pre-assignment exam to the data collected in periodic exams, the physician can identify trends that indicate the onset of negative health effects.

An annual periodic exam and consultation are recommended; however, the physician will determine the frequency (at least once every two years) based on the employee’s information. More frequent exams may be needed, depending on:

  • The extent of potential or actual exposure;
  • The type of substances involved in job duties;
  • The duration of the assignment; and
  • The employee’s profile, including things like age, medical history, previous exams, and previous exposures.

A periodic exam will include:

  • An updated medical and work history focused on changes in health, any illnesses, and any possible work-related symptoms;
  • A physical exam;
  • Additional tests, which may include pulmonary function, EKG, hearing, vision, blood chemistry, and urinalysis; and
  • Any other tests the physician deems necessary.

Termination exam

When an employee’s employment ends, or upon reassignment to a position that does not require medical surveillance, a full termination exam and consultation will be given if one of the following applies:

  • The last periodic exam was conducted six or more months ago,
  • Exposure has occurred since the last exam,
  • Symptoms of exposure have arisen since the last exam, or
  • The physician deems it necessary.

If a full exam and consultation is required, it will consist of:

  • Updating the employee’s occupational and medical history,
  • A physical exam,
  • Laboratory tests, and
  • Any other test the physician deems necessary.

If a full termination exam is not needed, a termination exam and consultation will be conducted to simply update the employee’s most recent occupational and medical history.

Post-illness or -injury exam

Medical examinations and consultations must also be offered as soon as possible when an employee develops signs or symptoms of overexposure to health hazards, or is injured or exposed above certain limits in an emergency. Depending on the situation, the physician will decide the extent of the exam.

While not required, the employer may offer additional exams or consultations for other situations, such as:

  • Any recordable injury onsite,
  • Any lost time illness of a certain number of days, and
  • A contamination incident.

Emergency responders who are not “covered employees” (as listed in the Who needs medical surveillance? section) have no medical surveillance protections from OSHA. However, they’re entitled to medical consultation if they become injured or ill or develop signs or symptoms due to exposure to hazardous substances from an emergency response.

Follow-up exam

The physician will determine if any follow-up exams or consultations are medically necessary based on the employee’s information and situation after an exam involving an injury, illness, or possible overexposure.

Information exchanged with physician

  • The employer must provide the physician who examines an employee with information about HAZWOPER and the employee’s work conditions, including duties, accompanying hazards, and PPE.
  • After the exam, the examining physician must provide the employer with information about the employee’s medical risks and conditions that are related to the work, along with recommendations for work limitations.

Prior to an employee’s examination, the employer must furnish the physician with specific information, including:

  • A copy of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard and its appendices;
  • A description of the employee’s duties as they relate to hazardous substance exposure;
  • The employee’s expected physical work effort;
  • The employee’s anticipated or real chemical exposure levels;
  • Temperature and humidity extremes that may be encountered;
  • A description of any personal protective equipment (PPE) the employee has used or will be required to use, including the respirator type and weight, the duration and frequency of respirator use, and protective clothing and equipment to be worn; and
  • Information from previous medical exams, if that information is not readily available to the physician.

Going the other direction, the examining physician will furnish the employer with a written opinion that includes:

  • Whether the employee has any detected medical conditions that would cause increased risk on the job or with respirator use,
  • The physician’s recommended limitations for the employee,
  • The results of any medical exams and tests requested by the employee, and
  • A statement that the employee has been informed of the medical exam results and any medical conditions which require further examination or treatment.

Any conditions discovered during a medical exam that are not related to the employee’s work must remain confidential and not be revealed to the employer.

Medical surveillance program

  • Medical surveillance programs must be site-specific and may be tailored to an employee’s varying needs and potential exposures.
  • Each year, the medical surveillance program must be reviewed by the site safety and health supervisor.

Employers at hazardous waste cleanup sites are required to have a medical surveillance program and to put it in writing.

In contrast, for emergency response operations, the employer is required to provide medical surveillance but is not required to put the details about medical surveillance in writing. However, emergency first aid and treatment information must be included in the emergency response plan (ERP), if applicable.

A medical surveillance program for cleanup site workers describes how worker health status is monitored and should include elements for:

  • Medical exams, including pre-assignment, periodic, post-injury or -illness, follow-up, and termination exams;
  • Emergency medical treatment and first aid;
  • Recordkeeping; and
  • Review of the program’s effectiveness.

The medical surveillance program must be site-specific, based on the specific needs, location, and potential exposures of employees at the site.

The surveillance needs of employees at a site under the program may vary slightly. That’s because exposure, medical and work history, age, sex, weight, stress level, diet, allergies, medications, and hobbies differ from person to person. The employer may attempt to tailor the medical exams and tests to fit individual employees and better protect their health.

Covered employees (as listed in the Who needs medical surveillance? section) should be encouraged to:

  • Give complete, accurate, and detailed information on occupational and medical history questionnaires;
  • Report any suspected exposures and watch for signs and symptoms of exposure in both themselves and their coworkers;
  • Report all injuries;
  • Wear their personal protective equipment (PPE) and chemical protective clothing (CPC) properly;
  • Keep all medical exam appointments; and
  • Live a healthy lifestyle, including plenty of sleep, balanced nutrition, and regular exercise.

Program review

When the medical surveillance program is required, it should be reviewed each year by the site safety and health supervisor or a management representative knowledgeable in occupational safety and health. Performing a thorough review helps ensure the effectiveness of the medical surveillance program.

The items that should be addressed during a medical surveillance program review include:

  • Verifying that each incident or illness was investigated, the cause was determined, and any necessary changes to procedures were updated;
  • Ensuring the proper tests are being provided to workers based on the potential exposures;
  • Adding or deleting medical tests based on current data;
  • Reviewing procedures for emergency medical treatment; and
  • Updating emergency contact lists.

Other records

  • Employers must keep employee medical records and exposure records and make them available to the employee and to OSHA.
  • Each year, employers must post a yearly summary report of recordable work injuries and illnesses.

Employers are required to keep accurate and thorough records of medical surveillance. These records include:

  • Employees’ names;
  • The physicians’ written opinions, recommended limitations, and results of exams and tests;
  • Any medical complaints that may be related to employees’ exposure to hazardous substances; and
  • A copy of the information the employer provided to the physician.

Employee medical records

The Occupational Safety and Health Administration (OSHA) defines an “employee medical record” as a record concerning an employee’s health status, which is made or maintained by a healthcare professional and includes:

  • Any medical and employment questionnaires or history;
  • Results of medical exams and tests;
  • Medical opinions, diagnoses, progress notes, and recommendations;
  • First aid records;
  • Descriptions of treatments and prescriptions; and
  • Employee medical complaints.

All medical records from medical surveillance must be available to the employee upon request while employed with the employer and for an additional 30 years after the end of employment.

Employee exposure records

OSHA defines an “employee exposure record” as a record containing any of the following kinds of information:

  • Environmental monitoring or measuring of a toxic substance or harmful physical agent,
  • Biological monitoring results that directly assess the absorption of a toxic substance or harmful physical agent by body systems,
  • Safety data sheets indicating the material may pose a hazard to human health, or
  • In the absence of safety data sheets, a chemical inventory or other record that reveals the identity of the substance or agent and where and when it was used.

Exposure records must be available to the employee upon request for 30 years after exposure.

Availability of records

Medical and exposure records are kept confidential. However, employees or their authorized representatives can request copies of their medical and exposure records including test results and written opinions.

An authorized OSHA representative is also allowed access to medical records upon request, in accordance with the regulations.

Finally, each year the employer must post a yearly summary report of all “recordable” work injuries and illnesses. This annual summary report is posted in the workplace in a conspicuous place or places where notices to employees are customarily posted. The summary must be posted from February 1 to April 30 each year.

Engineering, administrative, and work practice controls

  • Engineering controls are physical changes at the worksite to isolate or reduce hazards.
  • Administrative controls are policies, such as scheduling, that reduce employee exposure to hazards.
  • Work practice controls are best practices for performing job duties so as to minimize risk.

Control measures are essential to eliminating or reducing the hazards that are present at a hazardous waste site. The requirements for control measures are described in paragraph (g) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard.

Engineering controls

Engineering controls are physical changes at the site to isolate people from the hazard or otherwise eliminate or reduce the hazard on the job or during the task. Examples include:

  • Changing a process to minimize contact with hazardous chemicals,
  • Isolating or enclosing the process,
  • Using wet methods to reduce generation of dusts or other particulates,
  • Ventilating to dilute the air,
  • Using fume hoods,
  • Using remotely operated equipment, and
  • Using pressurized cabs or control booths on equipment to isolate the employee.

Administrative controls

Administrative controls reduce the duration, frequency, and severity of exposure to hazards. These can include:

  • Instituting job rotation,
  • Shortening shift lengths,
  • Limiting overtime,
  • Requiring frequent breaks,
  • Decreasing production rates,
  • Increasing the number of employees assigned to a task, and
  • Removing all non-essential employees from potential exposure during the opening of drums.

However, employee rotation should be a last resort in regard to radiation exposure or dose limits. The employer should only use this control if there is no other feasible way of complying with the airborne or dermal dose limits for ionizing radiation.

Safe work practices

Some common safe work practices at a hazardous waste cleanup site include:

  • Not smoking, eating, drinking, chewing gum or tobacco, or applying cosmetics in contaminated areas;
  • Not using matches or lighters in contaminated areas;
  • Wetting down dusty operations;
  • Exiting contaminated areas if conditions change or become unsafe;
  • Allowing only essential personnel to enter an area during certain activities like drum opening;
  • Staying upwind of hazards if possible;
  • Sticking closely to the buddy system;
  • Checking in and out of work zones through access control points; and
  • Using only intrinsically safe equipment in potentially explosive atmospheres.

Some other general safe work practices include keeping work areas clean, putting away tools or equipment, using safe lifting techniques, and wearing personal protective equipment (PPE) properly.

What about PPE?

The process of eliminating or substituting hazards and putting engineering, administrative, and work practice controls in place will help to mitigate many hazards; however, when hazards remain, there’s one more control method to turn to — PPE.

According to paragraph (g)(1) and (2) of 29 CFR 1910.120 and 1926.65,to the extent feasible, employers must institute engineering controls and work practices to help reduce and maintain employee exposure at or below permissible exposure limits. When this is not feasible, engineering and work practice controls may be supplemented with PPE to keep employee exposures at or below permissible exposure limits or dose limits.

Further requirements

In addition, the provisions of 29 CFR 1910 Subpart G or 29 CFR 1926 Subpart D must be followed. These subparts regulate occupational health and environmental controls for general industry and construction, respectively.

Personal protective equipment and clothing

  • PPE and CPC are an important defense for employees working with hazardous substances, but they have limitations and can pose their own hazards as well.

An important defense for employees working with a hazardous substance is the personal protective equipment (PPE) and chemical protective clothing (CPC) they wear. Being overexposed to chemicals may cause severe illness and injury including death. PPE and CPC are designed to help shield, isolate, or otherwise protect employees from chemical, physical, and biological hazards when engineering and work practice controls alone are not protective enough.

Whenever engineering controls and work practices are not feasible or not required, paragraph (g) of 1910.120 and 1926.65 says that any reasonable combination of engineering controls, work practices, and PPE shall be used to reduce and maintain employee exposures to or below the permissible exposure limits or dose limits.

However, protective equipment and clothing have their limits. They can also pose hazards such as heat stress and impaired vision. That’s why it’s extremely important for employees to be well informed and able to analyze which PPE and CPC would be best in a situation.

Program elements

  • The PPE program required of employers covered under 29 CFR 1910.120 or 1926.65 must address topics including selection, use, and maintenance of PPE and CPC.

Employers whose employees will be exposed or have the potential to be exposed to hazardous substances are required to have a personal protective equipment (PPE) program. The purpose of the program is twofold:

  • To provide protection from any chemical, physical, or biological hazards; and
  • To ensure workers know how to wear their protective equipment and clothing properly so they are not harmed from improper use or malfunction.

The PPE program should be in writing and be available to all employees. Some topics that must be addressed in the PPE program include:

  • Identification of hazards;
  • Uses and limitations of the PPE and chemical protective clothing (CPC) provided;
  • Proper selection of equipment and clothing;
  • Medical monitoring of personnel;
  • Environmental surveillance;
  • Proper use, inspection, and maintenance of equipment and clothing;
  • Decontamination methods for PPE and CPC;
  • Training for employees, including hands-on training; and
  • Proper donning and doffing procedures.

Another requirement of a PPE program is for the employer to review the program annually to evaluate its effectiveness. The review should be comprehensive and analyze aspects including:

  • Compliance with regulations;
  • Time workers spent wearing PPE;
  • Accidents or illnesses;
  • Adequacy of programs for:
    • Equipment selection,
    • Use,
    • Inspection,
    • Maintenance,
    • Decontamination, and
    • Storage; and
  • Effectiveness of employee training.

The review of the PPE program should also be made available to all employees and should be used to assess if any changes are needed to improve upon the effectiveness of the program.

Types of PPE and CPC

  • Chemicals, radiation, heat, explosions, immersion, and other hazards can all be addressed with the proper type of CPC.

There are many different types of personal protective equipment (PPE) and chemical protective clothing (CPC) that protect many different parts of the body from many different hazards.

Types of PPE

PPE can provide protection from the following:

  • Chemical hazards such as spills, splashes, vapor clouds, and contaminated dusts;
  • Physical hazards such as falls, flying objects, and sources of electricity; and
  • Biological hazards such as bloodborne pathogens and other infectious agents.

Types of CPC

The CPC that workers should wear varies depending on the situation and the chemicals involved. Any article of clothing that offers protection for a person’s skin or body from chemical hazards is considered CPC. Some types of CPC include:

  • Fully encapsulating suits
  • Non-encapsulating suits
  • Aprons, leggings, and sleeve protectors
  • Firefighters’ protective clothing
  • Proximity garments or approach suits
  • Blast and fragmentation suits
  • Radiation contamination suits
  • Flotation gear
  • Cooling garments
  • Hoods or hair coverings
  • Sweatbands
  • Disposable shoe or boot covers

A fully encapsulating suit offers whole-body protection from splashes, dust, gases, and vapors through its one-piece design. The boots and gloves can be either part of the suit, attached so they can be replaced, or separate.

This type of suit requires an atmosphere-supplying respirator. Employees wearing fully encapsulating suits should be monitored for heat stress, especially if they are also wearing self-contained breathing apparatus (SCBA).

A non-encapsulating suit protects most of the body, but parts of the head or neck are not protected. It consists of separate pieces of clothing that are worn together, such as a jacket, a hood, pants or bib overalls, and/or one-piece coveralls.

This type of clothing can also cause heat stress. Tape should be used to seal the connections between pants and boots, and between gloves and sleeves.

Arm sleeves can be used to add protection to the arms. Arm sleeves typically go all the way up to the shoulder. For additional protection, workers can use tape to seal their arm sleeves to their gloves, preventing splashes from getting down inside the gloves.

Aprons and leggings can provide additional protection to the chest and legs. These, along with the arm sleeves, should only be used alone when the chances of hazardous substances splashing the whole body are extremely low.

Firefighters’ protective clothing consists of a helmet, fire-resistant coat, fire-resistant pants, and boots. The main purpose of this clothing is to protect against heat and hot water. It will add protection against some particles as well, but it is very hard to decontaminate and can be permeated and degraded by chemicals.

Firefighters’ protective clothing should never be used as protection against chemical splashes, gaseous atmospheres, or vapors.

A proximity garment, sometimes called an approach suit, consists of a one- or two-piece overgarment with boot covers, gloves, and a hood made of aluminized nylon or cotton. These items are worn over other protective clothing to provide brief protection from radiant heat.

If employees will be exposed to a toxic atmosphere or need more than a couple minutes of protection, they would need to wear some type of cooling aid and an SCBA.

A blast and fragmentation suit consists of special blast and fragmentation vests and clothing, bomb blankets, and bomb carriers. These items can be used to provide some protection when small detonations are expected. Bomb blankets and baskets can be used to help redirect a blast.

When wearing this clothing, employees must also use some type of hearing protection.

For protection against radioactive alpha and beta particles, employees would wear a radiation-contamination protective suit, which consists of coveralls, gloves, shoe or boot covers, and a hood. This protective clothing is designed to protect the skin from contamination; it will not provide protection from gamma radiation.

If radiation may be present, a radiation expert should be consulted, and personnel should be evacuated from the area until conditions have been evaluated.

Life jackets or vests can be used as flotation gear when working in or around water. A life jacket or vest should be worn underneath other protective clothing to prevent degradation of the material from exposure to chemicals.

When heat stress is a concern due to either temperatures or the type of protective clothing worn, cooling garments can be used. Methods used for cooling include:

  • A pump that circulates cool, dry air to portions of the suit or throughout the suit using an air line;
  • A vest or jacket worn under other protective clothing that has pockets for carrying ice packs; and
  • A pump that circulates ice water from a reservoir through tubes that cover the upper torso.

To protect the head area:

  • Hoods can be used to protect the hair and neck from contamination.
  • Hair nets can be used to keep workers’ hair from impairing their vision, particularly long hair. These can be worn under hard hats, liners, or hoods.
  • Sweatbands can help prevent sweat from dripping into the eyes, causing irritation or impaired vision. These don’t provide any protection from chemicals, but they may make it more comfortable to work in warm environments or wear full body protection.

Boot covers or shoe covers give the feet an added layer of protection from chemicals. These covers slip over boots or shoes and are typically single use.

Hazard assessment

  • PPE and CPC are selected based on hazards identified during the site characterization and analysis.
  • For general industry, HAZWOPER also requires a certified hazard assessment that documents which hazards are or may be present in a workplace.

Employees must be protected from actual and potential hazards with appropriate personal protective equipment (PPE) and chemical protective clothing (CPC). Under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, PPE and CPC must be “selected and used which will protect employees from the hazards and potential hazards they are likely to encounter as identified during the site characterization and analysis.” Site characterization and analysis is covered by paragraph (c) of 29 CFR 1910.120 and 1926.65. See the Site characterization and analysis section for details.

In addition, PPE and CPC must meet the requirements of paragraph (g) of 1910.120 and 1926.65, and this paragraph references 29 CFR 1910 Subpart I for general industry or 29 CFR 1926 Subpart E for construction.

In referencing Subpart I, the HAZWOPER Standard also references a hazard assessment certification requirement at 1910.132. Specifically, the employer must assess the workplace to determine if hazards are present, or are likely to be present, that necessitate the use of PPE or CPC. If such hazards are present, or likely to be present, the employer must:

  • Select, and have each affected employee use, the types of PPE and CPC that will protect the employee from the hazards identified in the hazard assessment;
  • Communicate selection decisions to each affected employee; and
  • Select PPE and CPC that properly fits each affected employee.

Under 1910.132, the employer must also verify that the required workplace hazard assessment has been performed. This verification happens via a written certification that identifies:

  • The workplace evaluated;
  • The person certifying that the evaluation has been performed;
  • The date(s) of the hazard assessment; and
  • That the document is a certification of hazard assessment.

The non-mandatory Appendix B to 29 CFR 1910 Subpart I contains an example of procedures that would comply with the requirement for a hazard assessment.

The construction regulations at 29 CFR 1926 Subpart E do not carry a hazard assessment certification provision. However, 1926.95 calls for protective equipment and protective clothing “whenever it is necessary by reason of hazards of processes or environment, chemical hazards, radiological hazards, or mechanical irritants encountered in a manner capable of causing injury or impairment in the function of any part of the body through absorption, inhalation or physical contact.”

Moreover, 1926.65 mandates that PPE and CPC be selected in accordance with the site characterization and analysis at 1926.65(c).

Selecting PPE and CPC

  • Selection criteria for PPE and CPC should include not only the level and nature of protection they provide but their fit, compatibility, and ease of decontamination.

Before selecting any personal protective equipment (PPE) or chemical protective clothing (CPC), employees should be well informed about the conditions. What hazardous substances are present, what form they are in (such as a vapor cloud or a liquid spill), the concentration levels, the hazards involved, the exposure routes, and any expectations for possible changing conditions are all vital pieces of information.

Selecting PPE

One thing to take into consideration is whether all pieces of PPE needed are compatible and do not interfere with each other. For instance, an employee wearing a hard hat, goggles, and hearing protection should make sure the goggles don’t interfere with the fit of the hard hat. An employee preferring earmuffs as hearing protection may need a hard hat that has special grooves in it to accommodate them.

Another consideration is proper fit. PPE must be comfortable to wear; if it’s too tight and causing pinch points, it will be distracting. If it’s too large and falling off or moving around and the employee needs to adjust it regularly, that will be equally distracting.

Considerations when selecting PPE may include:

  • Specific hazards such as elevated heights, projectiles, falling objects, loud noises, or splashing liquids;
  • Unrestricted vision and movement;
  • Electrical hazards;
  • Explosive or combustible environments;
  • Wet surfaces or slippery conditions;
  • Possible changing conditions;
  • Thermal protection;
  • Duration of work;
  • Grip requirements; and
  • Shock absorbency.

Selecting CPC

When selecting CPC, one thing to consider is permeation. Even chemically resistant clothing is not immune to permeation. And in most cases, there won’t be any visible evidence that chemicals are permeating the material.

Chemical mixtures make permeation especially unpredictable, as even small concentrations of certain chemicals can enable the more rapid permeation of others.

Some factors that can affect the degree of permeation and how quickly it breaks through materials include:

  • Material type and thickness;
  • How the material was manufactured;
  • The concentration of the hazardous substance; and
  • Temperature, pressure, and humidity.

When selecting CPC, employees should also consider penetration and degradation. Penetration is the ability of chemicals to move through zippers, seams, or imperfections in material. Degradation involves physical changes in a material due to chemical exposure, use over time, or exposure to ambient conditions like sunlight. Signs of degradation include fading, swelling, loss of strength, and deterioration.

Another consideration is heat transfer. This refers to the clothing’s ability to dissipate heat. During work that occurs in a hot environment or requires rapid movement, heat can build up quickly inside CPC, which creates a concern for heat stress. The level of protection should never be downgraded due to heat stress, but adding some type of cooling garments may be necessary.

More factors to consider when selecting CPC include:

  • Durability. Does the material have the strength to stand up to the physical stresses of the tasks the wearer needs to perform? Can the material resist tears, punctures, and abrasions?
  • Flexibility. Will the material allow the wearer the flexibility required to perform necessary tasks?
  • Temperature. What effects will hot or cold temperatures have on the protective clothing? Will the clothing remain flexible in extreme temperatures?
  • Decontamination. How difficult is the clothing to decontaminate? Employees may decide to wear disposable or reusable clothing or a combination of both, depending on the conditions.
  • Compatibility. Is the clothing compatible with other needed clothing and PPE? For instance, some fully encapsulating suits may not be compatible with a hard hat.
  • Duration. How long will the required tasks take? Can the tasks be done before degradation or permeation becomes an issue?
  • Special conditions. Are there any special conditions that are present or could potentially happen, such as fires, explosions, heat, and radiation? The employee could need protection from those conditions in addition to chemical protection.

Selecting ensembles

  • When PPE and CPC are worn together, this is known as an ensemble.
  • Ensembles range from more protective (level A) to less protective (level D), depending on their components.

Personal protective equipment (PPE) and chemical protective clothing (CPC) are typically worn together in what is called an ensemble. There are four different ensemble categories based on the degree of protection needed — levels A, B, C, and D.

Level A

Level A provides the highest degree of respiratory, skin, and eye protection from solids, liquids, vapors, and gaseous chemicals. Level A protection requires the following:

  • A positive pressure full-facepiece self-contained breathing apparatus (SCBA) or a positive pressure supplied-air respirator with an escape SCBA,
  • A fully encapsulating chemical protective suit,
  • Inner and outer chemical-resistant gloves, and
  • Chemical-resistant safety boots.

There are optional items that can be worn along with level A protection, such as:

  • Cooling unit;
  • Coveralls;
  • Long underwear;
  • Hard hat;
  • Disposable suit, gloves, and boots worn over the top of the fully encapsulating suit.

Level A protection is needed for:

  • Entering areas with high concentrations of an identified airborne hazardous substance that requires the highest level of protection for the skin, eyes, and respiratory system;
  • Working where substances with a high degree of hazard to the skin are known or suspected to be present; and
  • Performing operations in confined or poorly ventilated areas.

Level B

Level B provides the same level of respiratory protection as level A, but a lesser level of skin protection. Level B protection requires the following:

  • A positive-pressure full-facepiece SCBA or a positive-pressure supplied-air respirator with an escape SCBA,
  • A hooded chemical-resistant suit,
  • Inner and outer chemical-resistant gloves, and
  • Chemical-resistant safety boots.

There are also optional items that can be worn along with level B protection, such as:

  • Coveralls
  • Chemical-resistant disposable outer shoe covers
  • Face shield
  • Hard hat

Level B should be used when:

  • There are high concentrations of identified airborne hazardous substances that require a high level of respiratory protection but a lesser level of skin protection;
  • The atmosphere contains less than 19.5 percent oxygen; or
  • There are unknown hazardous substances, but they are not suspected to contain high levels of substances harmful to skin or capable of being absorbed through the skin.

Level C

Level C protection provides the same level of skin protection as level B, but a lower level of respiratory protection. Level C protection requires the following:

  • A full-face or half-mask air-purifying respirator,
  • Hooded chemical-resistant clothing, and
  • Inner and outer chemical-resistant gloves.

There are optional items which can be worn along with level C protection, such as:

  • Coveralls
  • Chemical-resistant safety boots
  • Chemical-resistant disposable outer shoe covers
  • Hard hat
  • Escape mask
  • Face shield

Level C protection should be used if:

  • There are no hazardous substances present onsite that will negatively affect the skin,
  • All airborne hazardous substances have been identified,
  • An air-purifying respirator is available that can remove the contaminants, and
  • All criteria for the use of air-purifying respirators are met.

Level D

Level D protection provides no respiratory protection and only minimal skin protection. Level D protection requires the following:

  • Coveralls
  • Safety shoes

There are optional items that can be worn along with level D protection, such as:

  • Gloves
  • Chemical-resistant safety boots
  • Chemical-resistant disposable outer shoe covers
  • Safety glasses or goggles
  • Escape mask
  • Face shield

Level D protection should be used if:

  • The air contains no known hazards; and
  • The work being performed precludes splashes, immersion, the potential for unexpected inhalation, or contact with hazardous levels of any substances.

Ensemble selection

Some things to consider when selecting ensembles include:

  • An adequate level of protection,
  • Each item’s compatibility with all other items,
  • Time required to put on all clothing and equipment,
  • Chemical hazards that are present,
  • Physical environment and any physical hazards,
  • Duration of exposure,
  • Communication requirements, and
  • The components available.

If hazards are unidentified, a minimum of a level B ensemble is appropriate, and employees must carry instruments that can identify IDLH (immediately dangerous to life or health) conditions.

If an SCBA is not part of the ensemble for initial entry, employees will need to bring an escape SCBA with at least five minutes of air.

Each ensemble level is a starting point and should be tailored to the specific situation. Conditions should be monitored continuously for any changes, so PPE and CPC can be re-evaluated as new information is known. Reasons why PPE and CPC could be upgraded or downgraded include:

  • Upgrading — PPE and CPC might be upgraded because:
    • New information indicates that substances could affect the dermal layer of the skin or that gas or vapor emissions are likely,
    • A change in work tasks increases the employee’s contact with hazardous substances, or
    • The worker requests an upgrade.
  • Downgrading — PPE and CPC might be downgraded because:
    • New information indicates that the situation is less hazardous than originally thought,
    • The hazardous conditions have decreased, or
    • A change in work tasks will decrease the employee’s contact with hazardous substances.

Donning and doffing an ensemble

  • A worker should always have an assistant help with putting on and taking off an ensemble.
  • The procedure for taking off an ensemble depends on how much air is left in the wearer’s SCBA tank.

Putting on and taking off (technically called donning and doffing) an ensemble is not as simple as it sounds. It’s a good idea to practice donning and doffing protective equipment and clothing. This creates an opportunity for the wearer to:

  • Address any personal use issues,
  • Know what sizes of items fit best,
  • Get comfortable with the procedures of donning and doffing, and
  • Gain facility with wearing and operating the individual pieces.

Donning an ensemble

The job of donning a protective ensemble can seem like a huge task, but employees always help each other. An assistant should always help an employee don the ensemble. Assistants can help tape seals, pull on boots, strap on a self-contained breathing apparatus (SCBA), and check to make sure none of the protective gear is missing and everything looks proper.

Prior to donning any personal protective equipment (PPE) or chemical protective clothing (CPC), the wearer should inspect each piece.

The following steps are for donning a level A ensemble.

  1. If the fully encapsulating suit has a back closure for changing out air tanks, the wearer makes sure that closure is opened.
  2. Then, from a standing or sitting position, the wearer steps into the suit, placing feet properly inside the suit. The wearer pulls the suit up and gathers it around the waist.
  3. Next, the wearer puts on chemically resistant safety boots over the feet of the suit. Next, the leg cuff is brought over the top of the boots, and tape is used to seal the suit to the boots. If any additional foot protection like disposable boot or shoe covers will be worn, this would be put on now over the safety boots.
  4. The wearer puts on the SCBA and adjusts the harness, then dons the facepiece and adjusts it so it’s secure and comfortable. The breathing hose isn’t connected yet, but the valve on the air tank should be open.
  5. Next both negative- and positive-pressure tests on the facepiece are conducted:
    1. To perform a negative-pressure test, the palm of the hand is placed firmly over the inlet valve to block flow while the wearer gently inhales for 10 seconds. If any air rushes inside the facepiece, it indicates an improper fit. The facepiece must be adjusted and the test performed again.
    2. To perform a positive-pressure test, the wearer gently exhales while placing a hand over the exhalation valve. If air escapes from the mask and positive pressure cannot build up, this would also indicate an improper fit. The facepiece must be adjusted and the test performed again.
  6. Next, the wearer puts on the inner gloves and tapes them to the sleeves. Arms go into the sleeves of the suit while the assistant helps pull the suit up and over the wearer’s SCBA. The assistant helps adjust the suit around the SCBA and the wearer’s shoulders to make sure the suit allows unrestricted movement.
  7. Now the wearer puts on a hard hat and puts up the hood of the suit—carefully, so as not to break the seal on the facepiece.
  8. The wearer makes sure the suit is adjusted comfortably and starts securing the suit by closing any fasteners, leaving just enough room to attach the breathing hose and open the main valve.
  9. The assistant verifies the wearer is breathing properly and finishes closing the fasteners on the suit. The assistant then helps the wearer don outer gloves if needed and tapes them to the suit sleeves; checks all closures; and makes sure the wearer is comfortable and psychologically stable and that all equipment is operating properly before the wearer starts work.

Doffing an ensemble

Upon leaving a contaminated area, all the outside surfaces of the ensemble will be thoroughly decontaminated, with the employee still in the ensemble. Employers must have exact procedures for doffing that are written prior to the need for doffing.

When doffing (or removing) an ensemble, the wearer needs to be very careful not to touch any exposed surfaces of the equipment and clothing because there could still be residual contamination. There should also be an assistant for the doffing process, and this assistant must be dressed properly to prevent getting contaminated.

The start of the doffing process depends on how much air is left in the SCBA tank.

  • More than five minutes — If more than five minutes of air are left in the SCBA air tank, the process of doffing begins with a thorough decontamination. The decontamination process could vary depending on what hazardous substances the wearer has been in contact with. The steps for doffing the ensemble are as follows:
    1. The wearer removes outer disposable clothing like shoe covers, outer gloves, and tape.
    2. The assistant helps remove the safety boots.
    3. The assistant opens the suit and carefully lifts the hood off the wearer’s head, letting the hood rest on the SCBA tank.
    4. The wearer’s arms are removed from the suit one at a time as the assistant pulls the suit back and away from the wearer.
    5. The wearer removes one leg at a time from the suit. If possible, this step is performed in a sitting position — it’s easier that way.
    6. The wearer follows the employer’s written procedure for doffing an SCBA.
    7. The wearer removes the internal gloves by pulling them down and inside out while taking them off. 8. If contamination is suspected, the wearer removes personal clothing and takes a shower.
  • Five minutes or less — If the remaining air in the tank is five minutes or less, the wearer starts the process of doffing by skipping the thorough decontamination process. The goal is still the same, which is to remove protective equipment and clothing without the wearer or the assistant becoming contaminated. However, in this situation, getting the wearer air becomes the priority. Here are the steps:
    1. The wearer goes straight to removing any disposable clothing such as boot covers or shoe covers, outer gloves, and tape.
    2. Next, the wearer quickly scrubs and hoses off the suit, paying special attention to the zipper area. This is a quicker decontamination process, so extra caution is needed.
    3. The wearer opens the zipper just enough to reach the regulator and breathing hose. Immediately, another tank is attached to the breathing hose. Note: This procedure does help prevent contamination spreading to the wearer and the assistant, but they both need to proceed with caution, knowing there may be residual contamination on the wearer’s PPE and CPC.
    4. Once the wearer has air, the rest of the procedure is the same. In this case, the wearer has already removed the outer disposable clothing, so next, the assistant helps loosen and remove the wearer’s safety shoes or boots and continues with the normal doffing procedure.

Using PPE and CPC

  • Employees using PPE and CPC need to take special precautions if they have long hair, tend to grow facial hair, or wear prescription glasses.
  • When working in a contaminated area, employees should monitor themselves and their buddies for signs of exposure or PPE/CPC damage.

When it comes to using personal protective equipment (PPE) and chemical protective clothing (CPC), there are individual factors that must be taken into consideration. Because people are all different sizes and shapes, protective equipment and clothing should be provided in many different sizes to accommodate all employees.

Those employees with long hair need to tie it back and wear a protective hair covering to prevent hair from interfering with vision or the seal of the respirator.

No facial hair is allowed when wearing respirators with a tight-fitting facepiece. Even a day or two of growth can break the seal between the face and the respirator, allowing contaminants inside. Employees wearing a respirator must be clean shaven where the facepiece seals to the skin.

For employees with prescription glasses, there are special considerations when wearing a respirator. Regular glasses interfere with the seal of a worn together. Any employee who has prescription glasses and will be wearing a respirator must either have the respirator facepiece equipped with prescription lenses or wear contact lenses.

Chewing gum or tobacco is never allowed in contaminated areas. Employees should never attempt to chew gum or tobacco when wearing a respirator. In addition to providing a route for ingestion, chewing movements can break the seal between the respirator and the employee’s face.

In-use monitoring

When employees are in a contaminated area performing work tasks, they should monitor both themselves and their buddies for:

  • Degradation of PPE or CPC
  • Unexpected odors
  • Skin becoming itchy or irritated
  • Unusual residue on equipment or clothing
  • Pain or discomfort
  • Breathing problems
  • Fatigue
  • Vision or communication problems
  • Movement being restricted
  • Any medical issues
  • A restricted breathing air line (if using)

Storage, inspection, and maintenance

  • PPE and CPC should be stored according to manufacturer instructions, with potentially contaminated materials well separated from uncontaminated materials.
  • Maintenance of PPE and CPC should only be attempted by qualified personnel.

Personal protective equipment (PPE) and chemical protective clothing (CPC) can literally mean the difference between life and death for their wearers, so it’s crucial to take care of them properly and make sure they are in excellent condition for each use.

Storage

PPE and CPC should be stored according to the manufacturer’s directions to prevent damage. If stored improperly, they could be exposed to dust, moisture, sunlight, chemicals, extreme temperatures, or impacts, which could cause them to fail when used.

To store PPE and CPC properly:

  • Respirators should be taken apart, washed thoroughly, and disinfected prior to storage. They can be stored in their original cases, heat-sealed plastic bags, or resealable plastic bags.
  • Clothing that is potentially contaminated should be stored in a separate area that is well-ventilated where it will not come into contact with street clothing.
  • To prevent issuing the wrong items, clothing of different types and materials should be stored separately.

Inspection

Protective equipment and clothing should be inspected regularly. In fact, the first inspection happens when the items are received from the manufacturer or supply store, prior to being put into service.

Records should be kept each time an inspection occurs, documenting the item’s identification number if applicable, the date of inspection, the inspector’s name, and the condition of the item.

Other inspection times include when the equipment and clothing is issued for use, after use (even if only used for training), any time a problem or concern arises, and periodically while in storage.

Conditions to watch for when performing an inspection on PPE or CPC items include:

  • Imperfect seams;
  • Non-uniform coatings;
  • Tears, cracks, punctures, or pinholes;
  • Malfunctioning closures;
  • Discoloration;
  • Swelling or stiffness of material;
  • Non-operational pressure relief valves in fully encapsulating suits;
  • Loosened material around wrists, ankles, and neck; and
  • Cracks, crazing, or fogginess on facepieces, goggles, or face shields.

If permeation of chemicals is suspected, CPC should be checked thoroughly inside and out for any signs of discoloration or degradation. With permeation, decontamination cannot remove the chemicals that have seeped into the fabric. These chemicals can continue to seep through and reach the inside of the clothing, where they will contaminate the next person who wears the CPC.

If any issues or concerns arise during inspection of PPE or CPC, the items of concern should be removed from service and either repaired if possible or discarded appropriately.

Care and maintenance

PPE and CPC should be handled with care to preserve their integrity. They should never be set down in dusty, dirty areas or left where they are exposed to elements like rain, direct sunlight, or extreme temperatures.

Employers’ PPE programs must cover the maintenance of PPE and CPC. Many manufacturers will only allow persons who are specifically trained and authorized to perform maintenance on their products.

There may be a specific person or department at a workplace with the knowledge, training, and authorization to perform maintenance, or items requiring maintenance may need to be sent to an authorized person or place offsite.

No one should attempt to perform maintenance on any PPE or CPC without the proper qualifications to do so.

Temperature extremes

  • PPE and CPC can combine with heat or cold to make work conditions extra dangerous, but this hazard can be mitigated by choosing gear carefully for the situation.

The selection of PPE and CPC can be a complex process, especially when chemical exposures and extreme temperatures are combined. Employers should provide clear guidance to employees so that they can make informed choices about how to dress during extreme hot or cold conditions.

Hot environments

Many of the tasks performed at a hazardous waste cleanup site require the use of personal protective equipment (PPE) and chemical protective equipment (CPC), which protect workers from physical, chemical, and biological hazards. However, these present additional risks when it comes to working in hot environments.

The good news is that there are devices employees can wear to help keep their body temperature from rising while wearing PPE and CPC, including:

  • Cooling vests or ice vests,
  • Water-cooled garments, and
  • A personal cooling system with circulating cool air that blows into the suit.

When wearing a respirator, employees should choose either a powered air-purifying respirator (PAPR) or a supplied-air respirator (SAR) if possible. These types of respirators can have a cooling effect because of the airflow they provide.

Cold environments

Where chemical exposures exist, choosing protective gear requires a balance to be struck between dressing for chemical and cold hazards. For instance, a totally encapsulating suit does not provide an outer layer that has ventilation; therefore, it could cause the wearer to overheat, even when working in the cold.

That doesn’t mean employees should avoid wear encapsulating suits, but they should pay special attention to their condition when they do. Should suits cause employees to sweat in a cold environment, they may even need to exit the Exclusion Zone to change their PPE ensemble more often during a job.

If an employee must wear a tight-fitting respirator, then a knit mask would not be allowed because it would break the seal of the facepiece. In this case, a hat or hood could be worn over any respirator straps.

Monitoring and sampling

  • OSHA requires monitoring and sampling of the environment to identify and protect employees from airborne contaminants.

Airborne contaminants can present a significant threat to worker health and safety. Exposure monitoring and sampling identifies potentially dangerous situations, like environments that are radioactive, toxic, flammable, or oxygen deficient. It also identifies concentrations of airborne contaminants for use in tracking employee exposures and preventing overexposures.

Knowing the concentration levels of contaminants helps prevent serious injury or illness by allowing for the selection of appropriate engineering controls, work practices, and personal protective equipment (PPE).

Purpose

Because airborne contaminants can adversely affect the health of employees, the main purpose of monitoring and sampling is to protect employees who may be exposed to hazardous substances.

For emergency responders and employees at hazardous waste cleanup sites, the potential exists for exposure to airborne contaminants such as particulates, dusts, vapors, fumes, mists, and/or gases.

In fact, hazardous atmospheres can present more than one hazard at a time. And exposed employees may not even know it, because some hazardous substances cannot be detected by sight or smell. Therefore, human senses alone cannot be relied upon to detect airborne substances.

The Occupational Safety and Health Administration (OSHA) requires monitoring and sampling to ensure that employees’ exposure to hazardous substances does not exceed the permissible exposure limits (or PELs), or the published exposure levels for substances that do not have a PEL.

As stated, monitoring and sampling are meant to protect the employee. To ensure that protection, the information gathered in the monitoring and sampling process can be used in several ways, including to:

  • Assess the dangers that are present,
  • Determine the appropriate level of PPE and chemical protective clothing (CPC),
  • Determine any engineering controls or safe work practices to be put in place,
  • Create work zones,
  • Meet OSHA regulations, and
  • Determine employee exposures.

Detectable hazards

While atmospheres can be hazardous, the good news is monitoring and sampling can detect many of these hazards. The following hazards are detectable through monitoring and sampling:

  • Radioactivity
  • Oxygen deficiency
  • Oxygen-rich atmospheres
  • Flammability
  • Toxicity
  • Reactivity
  • Corrosives
  • Pathogenicity

Monitoring versus sampling

  • Monitoring produces instantaneous data, but these data can be incomplete due to the limitations of the direct-reading instruments.
  • Sampling produces more complete data but requires more equipment and more time because results must be obtained from a lab.

The terms “monitoring” and “sampling” may seem synonymous, but they’re not. Here’s the difference:

  • Monitoring uses direct-reading instruments to produce instantaneous data, and
  • Sampling uses a pump or other collection device to produce samples that must be sent to a laboratory for analysis.

Monitoring

To monitor conditions, direct-reading instruments are used to produce instantaneous data. Because the data are instantaneous, employees are alerted to changing conditions quickly.

Using direct-reading instruments to monitor conditions has its advantages and disadvantages. Direct-reading instruments have an advantage because they:

  • Provide a rapid (real-time) response,
  • Can identify certain conditions such as IDLH (immediately dangerous to life or health) and oxygen deficiency, and
  • Allow protective measures to be implemented quickly.

The disadvantages of direct-reading instruments are that:

  • They usually cannot detect airborne contaminants at extremely low concentration levels;
  • They are generally limited to detecting or measuring a specific class of chemicals;
  • They may not detect certain classes of compounds; and
  • Other chemicals can potentially cause interference, which may result in false readings.

Because of the limitations of direct-reading instruments, their results should be interpreted conservatively. Anyone using an instrument for monitoring must first be qualified to use it and familiar with its limitations.

When hazardous substances are unknown but the direct-reading instrument is giving a response, these contaminants should be reported as “needle deflection” or “positive instrument response” instead of a specific concentration.

Also, if there is no response or the instrument gives a reading of zero, this should be reported as “no instrument response” rather than “clean,” due to the possibility that substances were just not detected by the instrument.

Sampling

Sampling uses a device and some type of sampling medium to take samples that must be sent to a lab for analysis. Often this approach involves a pump that draws air through either a filter or sorbent.

Note: Only labs that are accredited by the American Industrial Hygiene Association (AIHA) should be used for analyzing samples. Labs have more sophisticated instruments for detecting hazardous substances. Therefore, the advantages of using a lab are that it:

  • Can detect low-level concentrations,
  • Has greater accuracy, and
  • Can detect compound or class-specific substances.

On the other hand, because sending samples to a lab requires more time, some of the disadvantages are that:

  • Results are not immediate;
  • Conditions may change by the time results are received; and
  • Sampling requires additional pumps, media, and analytical support.

To help remedy the disadvantages, sometimes onsite labs or mobile labs are used. Mobile labs tend to be located inside a mobile trailer and feature a few analytical instruments that can quickly identify and quantify contaminants.

Monitoring and sampling combined

There is no single instrument that can detect all hazardous contaminants. Generally, neither monitoring nor sampling alone can provide all the information each worker needs. Likewise, when determining the atmospheric hazards that may be present, it’s a good idea not to rely on just one device.

Instead, performing a combination of monitoring and sampling may provide enough information to ensure sufficient precautions are taken to keep exposure to hazardous substances under the limits. Together, monitoring and sampling support each other.

Air monitoring and sampling

  • Air monitoring and sampling should be conducted to identify IDLH conditions, monitor the site overall, assess the perimeter of the site, and check offsite areas that might be at risk from the site.

Breathing in contaminants is a major concern when working at hazardous waste cleanup sites or responding to an emergency release. To protect workers against airborne hazards, air monitoring and sampling are critical.

Paragraph (h) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard lists the requirements for monitoring and sampling. Air monitoring and sampling have four main areas of concern:

  • IDLH (immediately dangerous to life or health),
  • General onsite,
  • Perimeter, and
  • Off-site.

IDLH

Checking for IDLH and other dangerous conditions should be the first step in any air monitoring program due to the deadly nature of these conditions. The process requires a variety of instruments that can detect flammable, explosive, oxygen-deficient, radioactive, and highly toxic atmospheres.

Of course, it’s necessary to test any areas where a spill has occurred, and it’s a good idea to monitor hollows, trenches, tanks, buildings, sumps, or other areas where concentrations may build up.

If substances are lighter than air, monitoring may be important on any elevated terrain on which people are working or under canopies where employees might congregate. Substances tend to disperse in open spaces, but if a release is very large, monitoring open spaces might also be necessary.

General onsite

A variety of instruments should be used when conducting general onsite monitoring. However, the first thing to do is identify the source of airborne contaminants, then begin monitoring downwind from that source, gradually working upwind.

Crosswind sections and areas upwind from the source should also be monitored to ensure there is no background interference and that contaminants are originating from the identified source.

Perimeter

Perimeter monitoring means using fixed locations along the site’s fence line and at work zone borders. This helps to verify conditions and the legitimacy of work zones and clean areas. It also helps ensure the safety of the surrounding community.

Off-site

Offsite monitoring is used to verify that airborne contaminants are not traveling to surrounding communities or affecting the environment. Considerations for where to monitor offsite include:

  • Wind direction
  • Wind speed
  • Humidity
  • Other environmental factors

If through monitoring, it’s found that multiple contaminants are present, it may be effective to monitor for just one of the contaminants, which is referred to as the “sentinel” or “indicator substance.”

However, this only works if the “indicator substance” is representative of the other contaminants. And the contaminant chosen should usually be the one with the lowest permissible exposure limit (PEL).

All work zones should be monitored and sampled for airborne contaminants, including the Exclusion Zone (EZ), the Contamination Reduction Zone (CRZ), and the Support Zone.

Personal sampling

  • Employees may participate in personal sampling by wearing a sampling device such as a passive dosimeter clipped to their clothing or having their skin, breath, body fluids, and so forth tested for contaminants.

Employees may be asked to wear a personal sampler while conducting work activities. Selecting who will wear personal samplers is based on which employees will be closest to the source.

Personal samplers usually consist of:

  • A pump unit, which is worn on a belt around the waist;
  • A tube for drawing air through; and
  • Some type of collection media, like a filter or canister of sorbent material.

It’s important to target the breathing zone when wearing sampling equipment. To stay in the breathing zone, the collection media should be fastened outside the facepiece of the respirator close to the employee’s face. That means it’s often secured to the employee’s shoulder or chest.

This type of sampling indicates what the actual inhalation exposure of an employee would be without a respirator. This information is used to help keep an employee’s exposure to airborne contaminants below permissible exposure limit (PEL) values.

Because there can be several different contaminants present, one employee may be asked to change sampling devices several times or each member of a team may be assigned to wear a different sampling device so exposure records can be recorded for each contaminant.

One personal sampling device that’s used is the passive dosimeter. Passive dosimeters are small badges worn clipped to clothing, usually on the collar or a shirt pocket. Hazardous substances are collected on the dosimeter as air passes over it. The dosimeter is then sent to a lab to be analyzed.

A less common type of sampling is dermal sampling, which tries to measure exposure through absorption to the dermal layer of skin using skin washes or wipes, dosimeter patches, or whole-body suits.

Another less common type of personal sampling is biological sampling, where samples of an employee’s blood, urine, and exhaled breath are used to measure contaminants that have made their way into the body.

Personal monitoring can also be performed during work tasks. An employee can monitor for oxygen deficiency, flammability, and radiation by either wearing or holding monitoring equipment that is set to alarm if the readings are too high.

Some monitoring instruments also allow an employee to take a quick sample while working to verify conditions.

Environmental sampling

  • Environmental sampling fills in the gaps left by air monitoring, including testing water, soil, surfaces, and drum contents.
  • Compatibility testing is a form of environmental sampling that tests whether substances can be mixed safely.

While air monitoring and sampling are critical to employee safety and health, environmental sampling is also important because it helps to identify and assess substances and exposures in the work environment.

Certain substances may only be present in solid or liquid forms that cannot be picked up in air monitoring or sampling. Environmental sampling fills in the gaps.

One type of environmental sampling is water sampling. Water samples can be collected from onsite and local wells, rivers, streams, ponds, lakes, or other bodies of water.

Soil samples can also help determine the spread of contaminants. Leaky drums can leach contaminants into the soil, and airborne contaminants may settle on top of soil and then seep down when it rains. Storage areas and prevailing winds in the area should be considered by anyone collecting soil samples.

Wipe testing, otherwise known as swipe testing, is done by wiping a piece of collection media (like cloth or special paper) over surfaces. These wipe tests are then analyzed for contaminants and can help determine the risk of skin exposures. Wipe tests are used on the inside and outside of personal protective equipment (PPE) and chemical protective clothing (CPC) to verify that they are free of contamination.

To verify or identify the substances in drums, drum sampling may be performed. There are several instruments to choose from when taking a drum sample. The most common is a glass rod called a “thief.” Drum sampling should be done with caution, however, and the employer should have specific safety procedures to follow while performing this task.

Another form of environmental sampling, compatibility testing, is used to determine if different hazardous substances can be mixed together safely. Samples of each substance are sent to a lab for compatibility testing. If the tests come back as compatible, it should be safe to mix them, but if they come back as incompatible, mixing them could be very dangerous.

All the water and soil samples, swipe tests, and drum samples collected can also be tested at a lab that has instruments capable of detecting even small amounts of hazardous substances.

Timing of monitoring and sampling

  • Monitoring and sampling should be performed upon first entering a contaminated area, periodically to check for changes, when hazardous waste cleanup begins, and before and during confined space entry.

The Occupational Safety and Health Administration (OSHA) requires hazardous waste site employers to address monitoring and sampling frequency in the site safety and health plan. The plan should address monitoring and sampling performed:

  • At initial entry,
  • Periodically,
  • After commencing hazardous waste cleanup, and
  • Before and during confined space entry.

Initial entry monitoring

Upon first entering a contaminated area, initial entry monitoring is used to assess what hazardous substances are present, their concentration levels, and any other hazards. Monitoring during an initial entry must look for:

  • Oxygen-deficient atmospheres,
  • Any exposure to radioactive materials that exceed dose limits,
  • Other IDLH (immediately dangerous to life or health) atmospheres,
  • The presence of flammable or other dangerous atmospheres, and
  • Any exposure over the permissible exposure limit (PEL) or published exposure level.

Typically, visual observations and direct-reading instruments are used during an initial entry because the employees need to be aware of the conditions quickly and there could be changing conditions that they must to be alerted to immediately.

Sampling is not always performed during initial entry; however, the employer may call for sampling to confirm monitoring results, detect low-level concentrations, or detect certain compounds or class-specific substances that monitoring devices are unable to detect.

Periodic monitoring and sampling

Conditions can change at any time during hazardous waste cleanup; in fact, the work activities themselves can cause conditions to change. Therefore, periodic monitoring and sampling must also be performed during these cleanup operations either to verify conditions haven’t changed or to document the change.

Certain events must prompt periodic monitoring, such as:

  • Work begins in a new area,
  • New work tasks and activities are initiated at the site,
  • Newly identified hazardous substances are handled,
  • Work is conducted in areas with liquid contamination like a spill or lagoon, and
  • Leaking drums are handled.

Periodic sampling should be done as appropriate, and certainly if conditions are suspected to have changed. The data collected from periodic monitoring may actually help to determine when periodic sampling is needed.

After commencing hazardous waste cleanup

During hazardous waste cleanup activities, personal sampling must be done after the actual cleanup phase of any hazardous waste operation starts. For example, when soil, surface water, or containers are moved or disturbed, personal sampling must begin.

The employer must take personal samples of those employees who are likely to have the highest exposure to hazardous substances. When selecting the employees for personal sampling, the employer must consider what tasks employees are performing and their proximity to contaminants.

If the highest exposure from initial personal sampling during cleanup activities is above the PEL, then all employees at risk must undergo personal sampling.

Before and during confined space entry

Before anyone enters a confined space, the air must be monitored for hazardous conditions. Calibrated, direct-reading instruments must be used to test for:

  • Oxygen content
  • Flammable gases and vapors
  • Potential toxic air contaminants

While inside the space, periodic or continuous monitoring of atmospheric hazards is required.

If atmospheric testing reveals a hazard, special safeguards — like forced air ventilation and continuous monitoring — must be used to make entry, and work, safe.

Analyzing results

  • Factors that can influence monitoring and sampling results include temperature, wind speed, rainfall, moisture, vapor emissions, and work activities that may disturb hazardous substances.

Reading the output of instruments varies from easy to difficult. Employees must have hands-on training on each type of instrument they will be using. Only qualified personnel should analyze results.

Concentrations of solids are measured as milligrams per cubic meter of air (mg/m3), and air contaminants are measured in parts per million (ppm) of air.

It’s a good idea to verify sets of data against each other — for instance, by checking personal sampling information from the lab against the results from direct-reading instruments, or by using one instrument to confirm another instrument’s result.

Analyzing results helps ensure proper control measures and proper selection of personal protective equipment (PPE) and chemical protective clothing (CPC). Also, it helps assess if any changes are needed in the monitoring and sampling program.

If an instrument doesn’t show a reading, this doesn’t necessarily mean there is no hazard. It’s possible the instrument isn’t the right one for detecting the contaminant present.

Factors affecting results

Certain factors should be considered during analysis of any monitoring instrument readings or data collected from samples. That’s because these factors can influence monitoring and sampling results. These influencing factors include:

  • Temperature — The vapor pressure of most chemicals increases in higher temperatures.
  • Wind speed — Higher wind speeds can affect dusts, particulates, and vapor concentration levels.
  • Rainfall — Rain can reduce airborne dusts, particulates, and vapor concentration levels.
  • Moisture — Moisture can affect sampling results’ accuracy. Dusts are especially sensitive to moisture.
  • Vapor emissions — Evaporation can cause vapor emissions and produce high concentrations.
  • Work activities — Work activities can disturb hazardous substances, causing them to become airborne and creating higher concentrations.

Records

  • Records of monitoring and sampling activities must be kept for at least 30 years.

The results of monitoring and sampling activities are considered exposure records, which employers are required to keep for at least 30 years. Therefore, it’s extremely important to maintain accurate records.

Specific information must be documented when samples are collected. The type of sample will determine which of the items listed below are pertinent:

  • Name of employee sampled and person collecting the sample;
  • Task being performed during sampling;
  • Suspected contaminants;
  • Level of personal protective equipment (PPE) worn by employee;
  • Pump flow rate at beginning and end;
  • Start and end times of sample;
  • Date;
  • Location, which may include a map;
  • Sample number or identification;
  • Environmental conditions like temperature, humidity, and wind speed; and
  • Total volume of sample.

It’s also important to keep records of any readings taken out in the field using direct-reading instruments. These readings are usually entered in a logbook that includes all the pertinent information listed above.

The chain-of-custody forms and any documentation received from the lab are also important for recordkeeping. The lab will send back a report with its findings, including what contaminants were detected and the concentration levels of each contaminant.

Information program

  • The HAZWOPER Standard requires employers to provide personnel covered by the standard with an information program, often addressed through initial and refresher training, as part of the comprehensive safety and health program.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires every covered employer to develop and implement an informational program as part of its comprehensive safety and health program.

That’s because it is important for the employer to share information with employees, contractors, and subcontractors (or their representatives) about the nature, level, and degree of exposure to hazardous substances that are likely as a result of performing work at hazardous waste operations.

This requirement, found at paragraph (i) of 1910.120 and 1926.65, is typically addressed through initial and refresher training under paragraph (e) of the regulations.

Employees who are working outside of the cleanup operations (e.g., clerical staff who work on the periphery of the site) with no reasonable possibility for exposure to safety or health hazards are not covered by either the HAZWOPER Standard or the information program

Handling drums and containers

  • The 55-gallon drum is the most common hazardous waste container, but dozens of other types of containers are used as well.

When picturing a hazardous waste cleanup operation, most people think of drums of hazardous waste. That’s not surprising because according to the Environmental Protection Agency (EPA), “The most common hazardous waste container is the 55-gallon drum.” However, hazardous waste can be stored in many other types of containers as well.

Handling drums and other containers can be a very dangerous job. Detonations, fires, explosions, vapor generation, and physical injury are all potential hazards employees face when handling drums and containers of hazardous waste or other hazardous substances. The good news is that proper work practices can minimize the risk.

Paragraph (j) of 1910.120 and 1926.65 discusses the requirements for safely performing tasks associated with drum and container handling, such as:

  • Opening drums and containers,
  • Sampling and characterizing the contents, and
  • Shipping and transporting drums and containers.

Container types

Containers of hazardous substances come in all types, shapes, and sizes. A large variety are likely to be present at a hazardous waste cleanup operation. Container types include, but are not limited to:

  • Drums
  • Barrels
  • Jerricans
  • Carboys
  • Jars
  • Bottles
  • Cans
  • Boxes
  • Buckets
  • Pails
  • Crates
  • Bags
  • Cylinders
  • Flasks
  • Test tubes
  • Petri dishes
  • Envelopes
  • Shipping tubes
  • Overpacks
  • Portable tanks
  • Intermediate or flexible bulk containers
  • Cargo tanks and trailers
  • Tank cars
  • Vessels
  • Piping
  • Pipelines
  • Vaults
  • Underground and aboveground storage tanks
  • Pressure vessels
  • A combination of container types

Some containers fall into the category of bulk containers, like cargo tanks, while others are considered non-bulk containers, like boxes, drums, and barrels. Even within these categories, there may be many different shapes and sizes.

The materials used in the construction of containers vary widely too. It’s common to see containers made of fiberboard, plastic, steel, aluminum, nickel, or other metals. But containers may also be constructed of wood, textile, cardboard, paper, glass, porcelain, or stoneware. What’s more, containers may be lined or coated.

Methods for accessing the contents of a container can vary widely. Some large containers may have hatches or doors that open. Others may have covers, lids, stoppers, spigots, valves, or pumps.

Drums may be sealed or have covers fastened with a seal. A “drum bung” is used for accessing drum contents.

Drum handling

  • Handling drums has many dangers, both chemical and physical, and drum handling should be done as little as possible.

Handling drums of hazardous substances is extremely dangerous and should be kept to a minimum. Whether drums should be handled or whether they should be staged in specific areas are decisions that need to be made prior to certain activities.

Employers and their employees must always keep the dangers in mind and ensure drums are not handled more than absolutely necessary.

Typical steps involved in handling and shipping drums include:

  • Inspecting drums;
  • Creating a plan for handling drums;
  • Handling drums to orient them for opening and sampling;
  • Opening drums;
  • Sampling drum contents;
  • Characterizing drum contents;
  • Bulking (transferring drums into bulk containers);
  • Staging (in the above steps) in order to organize drums for opening, sampling, characterizing, and bulking activities; and
  • Shipping drums or bulk containers offsite for treatment, storage, or disposal.

Hazard awareness

It’s the contents of the drums that make handling them so dangerous. The hazardous substances within drums could potentially cause:

  • Detonations
  • Fires
  • Explosions
  • Vapor generation

Handling drums also comes with the risk of physical injuries like cuts and scrapes, musculoskeletal disorders (MSDs), or struck-by incidents.

With so many risks involved, employers are required to ensure there are procedures in place that incorporate all the applicable regulations under the Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT).

Inspecting drums

  • Inspection of a drum should look for signs of deterioration or pressure as well as symbols, labels, and the construction of the drum, which provide information about the drum’s contents.
  • Drums buried underground can be located using a variety of ground-penetrating systems.

Before drums and containers are handled and moved, they should be inspected to gather information about their contents and integrity.

Sometimes drums and containers are stored in a manner that makes it difficult or impossible to inspect them prior to moving, as when they’re buried or stacked. In this case, they should be moved just enough to allow for an inspection before they are moved any further.

What to watch for when inspecting a drum includes:

  • Symbols, words, labels, or other markings that indicate the contents;
  • Signs of deterioration, like corrosion, rust, punctures, or leaks;
  • Signs of bulging or swelling, indicating the drum is under pressure;
  • The material the container is made of; and
  • The configuration of the drumhead:
    • If the drum lid is removable, the drum was designed for solids; and
    • If the drum lid has a bung hole, the drum was designed for liquids.

The material a drum is made of can be a clue to what type of hazardous waste might be inside. For instance:

  • Polyethylene drums or drums lined with polyvinyl chloride (PVC) often contain strong acids or bases;
  • Exotic metal drums like nickel, aluminum, and stainless steel might contain extremely dangerous material;
  • Single-walled drums used as pressure vessels often contain reactive, flammable, or explosive materials; and
  • Laboratory packs might contain incompatible materials; shock-sensitive materials; or highly volatile, corrosive, or toxic materials.

Before approaching drums or other containers for an inspection, the area should be monitored for radiation, organic vapors, and combustible gases to help classify any potential hazards. If there are any extremely swollen or bulging drums, they should not be approached until safety precautions can be put in place.

Drums with no labels or markings should be assumed to contain hazardous substances and handled accordingly. In addition, labels are not always accurate. Sometimes drums are mislabeled, especially if they have been reused.

If drums are buried underground, ground-penetrating systems must be used to help locate them and estimate the depth. One or more of the following systems may be considered:

  • Electromagnetic wave
  • Electrical resistivity
  • Ground-penetrating radar
  • Magnetometry
  • Metal detection

Planning to handle drums

Each step of a drum-handling operation must be carefully planned to minimize the movement of drums. The information from drum inspections should be reviewed to determine:

  • What hazards are present,
  • Which drums need to be moved in order to open and sample them,
  • The extent of handling necessary for the operation,
  • Which personnel will perform handling operations, and
  • Procedures for handling.

Once handling operations begin, new information about the contents or hazards may make it necessary to stop and revise the plan. Employees should always be on alert for new information.

Handling drums

  • Drums of hazardous waste must be handled carefully.
  • Safe practices include safeguards against electrical, fire, and chemical hazards.

The purpose of drum handling is to respond to obvious problems, stage drums for sampling activities, and organize drums for characterization.

Before anyone handles drums, employees must be aware of the hazards involved. Drums should only be handled if necessary. Other precautions to take during drum handling activities include:

  • Warning personnel (prior to moving drums) that movement will be starting;
  • Keeping overpack drums and sorbents nearby;
  • Having a containment program in place in case of major spills; and
  • Having trained spill responders on standby.

Heavy equipment like front-end loaders and rough terrain forklifts is often used for excavating around buried drums, removing drums from pits and trenches, and loading and transporting drums to storage or staging areas. Precautions to take when using heavy equipment include:

  • Staying within the load capacity of equipment used;
  • Providing air conditioning in equipment cabs;
  • Protecting the equipment operator with splash shields;
  • Ensuring operators of heavy equipment have a clear view or a signal person; and
  • Using bars over excavator bucket teeth to prevent punctures when using an excavator.

A drum grappler is a great piece of equipment to use because it adds a degree of safety by putting distance between the operator and the drum. That way, if the drum detonates or ruptures, chances of the operator getting injured are lessened. Plus, the grappler claws partially deflect the energy from any detonation.

Other equipment used for handling drums may include:

  • A roller conveyor with solid rollers,
  • Drum carts, and
  • Spark-proof tools used for opening and closing drums.

Safe practices

Safe practices must always be followed during work with drums of hazardous waste. Examples include:

  • Using proper lifting techniques;
  • Using extreme caution with drums that are not intact or not tightly sealed;
  • Never pushing, rolling, or dragging drums;
  • Allowing enough space between drums for people to move around and retreat quickly if needed;
  • Grounding any equipment used to transfer waste to new drums;
  • Always using respiratory protection, other personal protective equipment (PPE), and chemical protective equipment (CPC) that’s required;
  • Abiding by any “no smoking” signs;
  • Following the site’s emergency procedures if there is an actual or imminent release, fire, explosion, or other emergency; and
  • Ensuring drums and containers meet appropriate Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations.

Environmental practices

Some key EPA hazardous waste container management provisions to keep in mind, if applicable, include the following:

  • Use containers made of or lined with materials that will not react with, or are otherwise compatible with, the waste to be stored;
  • Always keep hazardous waste containers closed during storage, except when it is necessary to add or remove waste;
  • Keep containers of ignitable or reactive waste at least 50 feet from the facility’s property line;
  • Separate or protect ignitable or reactive waste from sources of ignition, such as open flames, welding, sparks, or smoking;
  • Do not place incompatible wastes (or incompatible wastes and other materials) in the same container;
  • Do not place hazardous waste in an unwashed container that previously held an incompatible waste or material; and
  • Provide a label (also known as an accumulation label) on the hazardous waste container during storage.

Special precautions with certain drums

  • Drums that may be shock-sensitive or explosive should be handled with particular care, including movement-signaling alarms and continuous communication among site personnel.
  • Leaking, open, or deteriorated drums should be moved to an overpack using a drum grappler.

Some drums require special precautions. For instance, any drums that have levels of radiation above background radiation should not be handled until an expert such as a health physicist has been consulted. Other special precautions to take with certain drums relate to the following:

  • Shock-sensitive or explosive drums — Employees should seek special assistance before handling drums containing explosive or shock-sensitive waste and use the following precautions:
    • Handle with extreme caution,
    • Ensure non-essential personnel are at a safe distance,
    • Use a drum grappler constructed for explosive containment,
    • Use an audible alarm to signal the start and end of handling activities,
    • Maintain continuous communication with the site safety officer or command post while handling, and
    • Palletize and secure drums prior to transport.
  • Bulging drums — If possible, bulging or swelling drums should not be moved. Instead, the cause of the swelling should be determined (if possible) and containment procedures should be implemented to protect people from eruption of the drums. If a bulging drum must be moved, a drum grappler should be used, and the drum should be moved only as far as necessary to firm ground or placed in an overpack.
  • Lab packs — Lab packs usually contain several different individual containers that are typically surrounded by absorbent cushioning material. The waste in lab packs should be considered explosive and shock-sensitive until proven otherwise through characterization. Not just anyone can open a lab pack. Lab packs can only be opened by personnel specially trained in the inspection, classification, and segregation of the containers within the pack. Hazards that may be encountered in lab packs include:
    • Incompatible materials
    • Radioisotopes
    • Shock-sensitive materials
    • Highly volatile materials
    • Highly corrosive materials
    • Very toxic chemicals
    Precautions to take when working with lab packs include:
    • Making sure non-essential personnel are at a safe distance;
    • Using a drum grappler for explosive containment;
    • Maintaining continuous communication with the Site Safety Officer or the command post while handling;
    • Having a chemist inspect, classify, and segregate the waste containers within the pack without opening them;
    • Packing the unopened smaller containers in drums with sufficient absorbent and cushioning material;
    • Treating the material as shock-sensitive if crystalline material is noted, and getting expert advice; and
    • Palletizing and securing repackaged drums prior to transport.
  • Leaking, open, or deteriorated drums — A drum grappler should be used to place the following drums in overpacks:
    • Leaky drums containing sludge or semi-solid material,
    • Open drums containing liquid or solid waste, and
    • Deteriorated drums that can be moved without rupturing.
    If any of these leaky, open, or deteriorated drums contain liquids and cannot be moved, the contents should be pumped to a different drum using grounded equipment. In fact, the Environmental Protection Agency (EPA) may require a site to transfer hazardous waste from a drum in poor condition to a sound container or otherwise manage the waste in some other way that complies with requirements.
  • Buried drums — With ground-penetrating systems, once buried drums are located and their depth is known, the following precautions should be used:
    • Use a drum grappler, if possible;
    • Remove the soil with extreme caution; and
    • Have a dry chemical fire extinguisher on hand.

Opening drums

  • Opening drums safely requires appropriate PPE/CPC; atmosphere-monitoring equipment; and precautions against chemical, fire, and physical hazards.

Whether drums are opened in place or moved to a staging area for opening, the procedures remain the same. Employers must have specific procedures for drum opening. Employees need to become familiar with these procedures prior to opening any drums.

Because several types of atmospheres might develop during drum opening, respiratory protection is required. Anyone opening a drum must wear an atmosphere-supplying respirator (ASR), either:

  • A self-contained breathing apparatus (SCBA), or
  • A supplied-air respirator (SAR).

Anyone using an SAR should make sure the air supply is in a clean area, protect the hose from damage, and carry an escape SCBA.

To monitor conditions during drum-opening activities, the sensors of direct-reading instruments should be placed as close to the source as possible. Monitoring for different types of atmospheres can be done using:

  • Colorimetric tubes
  • Dosimeters
  • Radiation survey instruments
  • Explosion meters
  • Organic vapor analyzers
  • Oxygen meters

During the opening process, employees should stand back as far as possible. If it’s necessary to be closer, explosion-resistant plastic shields should be placed between any persons and the drum. The controls for drum-opening equipment, monitoring instruments, and fire-suppression equipment should be located on the person side of the shield.

Using remote-controlled equipment adds another layer of protection. The following devices can be used for opening drums:

  • A pneumatically operated impact wrench to remove drum bungs,
  • Hydraulically or pneumatically operated drum piercers, and
  • Backhoes equipped with bronze spikes for piercing drum tops.

Other precautions to take when opening drums include:

  • Only using non-spark tools and equipment when flammable or explosive atmospheres are present.
  • Never standing on drums or working from them.
  • Never using picks, chisels, firearms, or other means to open a drum in a manner that may rupture the container or cause it to leak.
  • Hanging tools to minimize employee exertion.
  • Performing all steps slowly and relieve excess pressure on bulging or swelling drums.
  • Opening exotic PVC-lined drums by the bung, using extreme caution.
  • Not opening or sampling individual containers in lab packs.
  • Resealing open bungs as quickly as possible, and, if bungs cannot be resealed, placing the drum in an overpack.
  • Decontaminating drum-opening equipment after opening each drum to avoid mixing incompatible wastes.

Drum sampling

  • Performing drum sampling safely requires appropriate PPE/CPC and maintaining physical distance from the contents of the drum.

During drum sampling, the potential exists to come into direct contact with the hazardous waste in the drum. That potential makes this task a threat to worker health and safety. Drum sampling should be carefully and thoughtfully planned prior to sampling any drums.

A drum sampling plan should include a description of:

  • Expected or potential hazardous waste,
  • Which drums will be sampled,
  • Sampling devices and containers to be used, and
  • The number, volume, and location of samples to obtain.

The plan should also list sampling procedures.

The personal protective equipment (PPE) and chemical protective clothing (CPC) worn during drum sampling should be selected by a professional trained in health and safety.

Proper drum sampling techniques include:

  • Staying at a safe distance until drum opening is complete before performing sampling;
  • Not leaning over a drum while sampling unless absolutely necessary;
  • Covering drum tops with plastic sheeting to prevent the spread of contamination;
  • Not standing on drums, but instead using a platform or mobile steps when gaining height is necessary;
  • Using glass rods or vacuum pumps to obtain samples;
  • Preventing cross-contamination and mixing incompatible wastes by not using contaminated items for sampling; and
  • Removing glass rods prior to pumping.

Drum characterization and compatibility testing

  • Drum characterization collects information on the contents of the drum so that it can be handled safely.
  • Compatibility testing observes the behavior of different types of wastes when mixed together.

After sampling, the next step in the drum-handling process is to characterize the contents so wastes can be packaged and transported safely. Each drum is scanned for radioactivity as it is opened. If the scan is negative, a sample is taken.

Compatibility testing is performed on the collected samples, and the wastes are classified into general categories:

  • Auto-reactives
  • Water reactives
  • Organic acids
  • Inorganic acids
  • Bases
  • Heavy metals
  • Pesticides
  • Cyanides
  • Organic oxidizers
  • Inorganic oxidizers

Classifying wastes into general categories helps determine which wastes can safely be bulked together in a larger container without the risk of fire or explosion. If drums will be stored or staged for transport, this classification helps determine which drums can safely be stored or staged together.

It’s a good idea to fill out a form for each characterized drum, including information such as:

  • The physical state of the waste;
  • Any instrument readings;
  • Drum type, color, size, condition, markings, and opening type; and
  • Quantity and color of the drum contents.

Characterization of wastes should be performed by trained and experienced personnel.

For drum characterization, an onsite lab should be used if available. This will provide quicker results and reduce the risks of transporting samples. If samples do have to be shipped for testing, any hazardous waste shipments including samples must be shipped in accordance with Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations.

Compatibility tests are often performed on wastes in a controlled environment. Small amounts of different wastes are added together and then observed for vapor generation, heat generation, or any other reactions.

Staging drums

  • Drum staging involves moving drums in an organized manner to predesignated areas.
  • There are five types of staging areas — initial staging, opening, sampling, holding, and bulking.

Although every attempt should be made to minimize drum handling, drums must sometimes be staged (or moved in an organized manner to predesignated areas). Staging may facilitate drum opening, sampling, characterization, and bulking. It may also be used to protect drums from heavy equipment and high temperatures that may cause explosion, ignition, or pressure buildup.

The number of staging areas needed is specific to the site and dependent on the scope of operation, accessibility, and potential hazards of drum contents. However, the number of staging areas should be kept to a minimum. Staging drums is a trade-off between increased hazards from drum movement and decreased hazards from organizing and accessing wastes.

Each staging area should be set up with enough space that heavy equipment and other vehicles can access the area and move around easily. Separation between areas is also helpful in maintaining safe operations. In the event of a fire or explosion, it may prevent a chain reaction.

Some sites use up to five staging areas, including:

  • Initial staging — This is where drums are stored prior to opening and sampling. In this area, drums get organized by suspected hazards and drum type and size.
  • Opening area — Drum opening, sampling, and resealing occurs here. This area should be located a safe distance from all other areas.
  • Sampling area — A separate sampling area may be set up during emergencies or large-scale operations. This reduces the number of personnel in the opening area in case of an explosion.
  • Holding area — Drums can be stored in a holding area to be characterized. If any drums with unknown contents are in this area, they must be sealed to prevent incompatibility hazards.
  • Bulking area — After wastes are characterized, the drums are placed in the final staging area or bulking area, where they are bulked for transport to a treatment, storage, or disposal facility.

The bulking area should be located as close to the site exit as possible. The area should be graded, covered with plastic sheeting, and surrounded by a dike to prevent the spread of contamination if a spill occurs.

The drums in the bulking area should be further separated by the hazards determined during characterization. Dikes, berms, walls, or other structures should be installed around each segregated area. This approach contains spills and keeps incompatible wastes from mixing should containers break or leak.

Between drums, there must be enough aisle space to allow quick escape from the area and to make room for equipment for drum handling, fire protection, spill control, and decontamination.

Staging areas must be equipped with firefighting equipment, an internal communications or alarm system, and a telephone or other device to summon emergency assistance.

All drum staging areas must be inspected weekly to look for leaking and deteriorating drums. If unsound drums are found, waste must be transferred from them to containers in good condition. Any leaks that occur should be cleaned up immediately.

Bulking materials

  • Bulking means combining wastes (with careful attention to their properties and compatibility) in bulk containers for transport.

Bulking means to combine wastes in bulk containers like tanks, vacuum trucks, or trailers for shipment offsite to a treatment, storage, and disposal (TSD) facility. Before any wastes can safely be combined, they must go through a thorough characterization.

Before any wastes are bulked, the larger container must be clean and free of any residual contaminants, which could be incompatible with the wastes being transferred.

It’s important to understand the physical properties of the wastes being bulked. Some may require room for expansion, while others may need to completely fill the container, with zero headspace.

Extra precautions to take when bulking liquids include:

  • Only using pumps rated by the National Fire Protection Association (NFPA);
  • Ensuring pumps have a safety relief valve and a splash shield;
  • Ensuring hoses, casings, fittings, and gaskets are compatible with the wastes being transferred;
  • Inspecting hose lines, fittings, and valves for weak spots and ensuring everything is assembled properly;
  • Using caution when handling hoses;
  • Staying protected from splashing;
  • Protecting the hose lines from any traffic in the area; and
  • Using only approved containers to bulk flammable liquids.

Shipment of materials

  • When drums must be shipped, they can’t be overfilled and must be secured and covered in the transport vehicle.
  • Hazardous waste shipments must comply with OSHA, EPA, and DOT regulations.

Some important safety measures apply to preparing or shipping materials. For example, the bulking area should be as close to the site exit as possible. The flow of traffic may require careful planning to minimize conflict. Hauling vehicles must have ample space to move around, and roads must be kept in good condition. Also, vehicle operators must always obey any traffic lights or signs.

When vehicles arrive, operators should be directed to park in a safe area and stay in the cab until it’s time to start loading. Before loading begins, the vehicle operator must have any personal protective equipment (PPE) or chemical protective clothing (CPC) needed in the loading area.

Vehicle loads of bulked solids should go no higher than a couple inches below the container rim. To prevent the release of contaminants during transport, waste solids should be covered with a layer of soil, foam, and/or a tarp. Lastly, the load must be secured to prevent any shifting during transportation.

Bulking is not always an option, so sometimes it’s necessary to ship drums. Safety measures to adhere to when loading drums include:

  • Ensuring each drum is closed in accordance with the drum manufacturer’s closure instructions. If the manufacturer is unknown and no closure instructions are available, repackage the waste (or use an overpack) and follow the packaging manufacturer’s closure instructions.
  • Ensuring truck brakes are set and wheels chocked.
  • Using an overpack for any leaking or deteriorated drums.
  • Inspecting the truck bed to ensure it’s both clean and flat for the safe transport of drums.
  • Not double stacking drums.
  • Securing the load to prevent drums from moving or shifting.

Both trucks and roads have weight limitations. It’s a good idea to occasionally stop loading and weigh the transport vehicle to make sure those limitations will not be exceeded.

Transport vehicle tires should be decontaminated prior to leaving the site so public roadways are not contaminated. The truck operator should check the load occasionally to ensure no dust, liquids, or vapors are being released while in transport.

Regulations

All shipments of hazardous waste must comply with Occupational Safety and Health Administration (OSHA), Environmental Protection Agency (EPA), and Department of Transportation (DOT) regulations:

  • OSHA — OSHA regulates the shipment of hazardous waste under the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. This regulation’s shipping provisions call for classifying containers, keeping staging to a minimum, providing adequate access and egress routes in staging areas, and bulking only after characterization.
  • EPA — This is the agency that enforces the Resource Conservation and Recovery Act (RCRA), a law that gives EPA authority to control hazardous waste from the time the waste is generated until it’s disposed. This time span is called “cradle to grave,” and this duration includes transportation.
  • DOT — The DOT regulates hazardous materials (hazmat) under the Hazardous Materials Regulations (HMR). These regulations ensure that hazmat is packaged, handled, and transported in a safe manner.

Special precautions with specific containers

  • Tanks, vaults, vacuum trucks, elevated tanks, compressed gas cylinders, and ponds and lagoons all require special precautions to handle them and their contents safely.
  • A confined space permit might be required before entering a tank or vault.

Sometimes containers present additional hazards due to their size, shape, location, or pressure. The container types covered below require extra precautions in addition to the general procedures for handling containers.

Tanks and vaults

It’s common to see tanks and vaults at hazardous waste cleanup sites. Note that excess pressure can build up inside a tank or vault. For protection from contaminants that may release when a container is opened, a deflecting shield should be placed between the employee opening the container and the opening.

Once the tank or vault is opened, manholes or access points should always be guarded to ensure no personnel inadvertently fall into the container. The contents should be identified using analysis of sample results, and the container should be characterized. If these results show the contents are safe to move, it may be possible to vacuum the waste into a vacuum truck and have it transported to a treatment, storage, and disposal (TSD) facility.

The tank or vault should be emptied and decontaminated before disposal.

It’s important to know that tanks and vaults are typical examples of confined spaces because they are often large enough to enter, have limited means of entry or exit, and are not designed for continuous occupancy.

Because tanks and vaults have the potential for dangerous atmospheres, a confined space permit may be required just to enter a tank or vault at a site. If a permit is required, the tank or vault is considered a “permit-required confined space.”

If at any time it becomes necessary to enter the tank, employees must adhere to the confined space entry procedures on the permit, along with the requirements of their employer’s written permit-required confined space program. Extra precautions needed for entering a tank or vault include:

  • Disconnecting pipelines from the container;
  • Obtaining air samples to verify oxygen levels and to check for flammable gases or toxic gases and vapors in the interior container atmosphere;
  • Thoroughly purging, inerting, flushing, or ventilating the container to control atmospheric hazards;
  • Making sure all entry workers are equipped with respiratory protection, protective clothing, a safety harness and retrieval line, and any other personal protective equipment (PPE), as needed;
  • Having a trained attendant in place prior to entry;
  • Establishing lifeline signals for communication between entry workers and the attendant;
  • Stationing an additional employee in the area to assist the attendant if needed;
  • Having the entry supervisor confirm that conditions are acceptable for entry; and
  • Ensuring the attendant knows not to enter the area until additional personnel arrive.

Vacuum trucks

A vacuum truck is a tanker truck equipped with a powerful vacuum strong enough to suck sludges, slurries, and liquids into the tank on the truck. It works perfectly for emptying tanks and vaults of hazardous wastes.

Extra measures to take when working with vacuum trucks include:

  • Wearing appropriate PPE and chemical protective clothing (CPC) when opening the hatch;
  • Using mobile steps or suitable scaffolding if available;
  • Avoiding climbing the ladder and catwalk on the vacuum tank;
  • Using both hands to grip the side rails of the truck ladder while ascending or descending;
  • Hoisting tools or sampling equipment only after reaching the top of the ladder;
  • Sampling from the top of the vehicle if possible; and
  • Standing off to the side and keeping absorbent materials close by if sampling from the drain spigot.

Elevated tanks

Elevated stationary tanks require the same precautions as vacuum trucks. However, these stationary tanks may also require fall protection, such as guardrails, safety net systems, or personal fall protection. Ladders and railings must also be maintained in a safe condition.

Compressed gas cylinders

Compressed gas cylinders can quickly become an explosion or projectile hazard if they’re damaged. When working with compressed gas cylinders, employees must:

  • Handle them with extreme caution;
  • Never roll, push, or pull cylinders;
  • Use a cylinder cart when moving cylinders;
  • Stage cylinders in cool, shaded areas;
  • Keep cylinders away from any flames or sparks;
  • Record identification numbers to aid in characterization; and
  • Ensure cylinders are secured when moving or storing them.

Refer to the Compressed gases subject for further information.

Ponds and lagoons

Wearing PPE and CPC may make it difficult to swim, float, or tread water, creating a drowning hazard for employees near ponds and lagoons. When working around water, employees should take the following precautions:

  • Work from shore if possible;
  • Use lifeboats, flotation gear, or other necessary safety gear; and
  • Be cautious along shorelines, keeping an eye out for solids that may float and give the appearance of a stable surface.

Spill containment program

  • Employers covered under HAZWOPER must develop and implement a written spill containment program.
  • The spill containment program needs to address hazardous materials onsite and detail potential control and response measures for them.

Although the Occupational Safety and Health Administration (OSHA) does not define exactly what a “major spill” is, the agency does require any employers that have the potential for a major spill to develop and implement a written spill containment program. Elements of a spill containment program are covered below.

Potential spills and available controls

To develop an effective spill containment program, the employer must conduct an assessment of the hazardous substances onsite; operations; and how containers are stored, handled, and transported.

After a careful assessment of all substances and operations at the site, the employer should document all hazardous substances onsite; any activities with spill potential, with their spill types and locations; and what control measures are available in the event of a spill.

Possible control measures include, but are not limited to:

  • Absorbent materials;
  • Overpack drums;
  • Dikes and berms;
  • Inflatable containment (like “kiddie pools”); and
  • Pumps, hoses, shovels, and other equipment.

When selecting control measures, the employer must consider the largest possible spill that could occur. It should be noted that the site may be required to provide secondary containment in line with Environmental Protection Agency (EPA) regulations. These structures may require containment systems that:

  • Have a “sufficiently impervious” base to contain leaks, spills, and accumulated precipitation until the material is detected and removed;
  • Have a base that slopes or drains unless containers are elevated or protected from contact with accumulated liquids;
  • Have sufficient capacity for 10 percent of the total volume of all containers in a containment system, or 100 percent of the volume of the largest container, whichever is greater;
  • Have sufficient excess capacity to contain any run-on (such as rainwater, leachate, or other liquid that drains over the land), or otherwise prevent run-on from running into the containment system; and
  • Remove any spilled or leaked waste or accumulated precipitation from the containment area in a timely manner to prevent overflow of the system.

Federal, state, and local secondary containment provisions that apply to a cleanup site may be more stringent.

Initial spill notification and response

The second element of the spill containment program must address who to call if a spill should occur, what information to provide during notification, and what response is expected, including when to activate the emergency response plan (ERP).

Site personnel should become familiar with their site’s spill containment program for specifics. However, upon discovery of a spill, this element of the program can provide instructions for:

  • Summoning help;
  • Alerting nearby personnel;
  • Moving to a safe location;
  • Contacting emergency medical services, if needed; and
  • Keeping unauthorized personnel away from the spill.

Different employees may have different roles in the event of an emergency, depending on their level of training. All employees should know what their role is and what is expected of them should a spill occur.

Spill evaluation and response

The directives in the third spill containment program element include evaluating the spill and determining what type of response is needed to handle it. An authorized individual should identify the hazards associated with the hazardous substance involved and the spill volume and conditions. This individual will then determine whether the spill is:

  • Incidental, and can be handled safely by site employees;
  • More than incidental, and the ERP must be activated; or
  • More than incidental, and external response organizations are needed.

If the spill is determined to be incidental, response personnel will rely on their training under the Personal Protective Equipment (PPE) and Hazard Communication standards to handle the spill. They may also be briefed as to spill conditions, response activities, decontamination, and waste handling.

If the spill is determined to be more than incidental, but response can be handled without outside help, the ERP will be activated, and each employee involved in the emergency response operation should be briefed on:

  • The level of PPE and chemical protective clothing (CPC) required,
  • Safety procedures,
  • Isolating the spill and creating work zones,
  • Tasks involved,
  • Leak or spill control,
  • Any medical care required, and
  • Decontamination procedures.

Once the emergency is under control, post-emergency response procedures can be implemented. These will address cleaning up the area, decontaminating personnel and equipment, and properly disposing of the waste.

Post-spill-response evaluation

The spill response effort doesn’t end after control and cleanup activities are completed. Some common expectations and procedures for a post-spill-response evaluation — the last element of a spill containment program — include:

  • Ensuring the incident is documented;
  • Examining the root cause(s) of the incident;
  • Examining response efforts;
  • Implementing corrective actions;
  • Replenishing supplies and equipment; and
  • Ensuring medical, exposure, and monitoring records are completed and maintained.

Spill control measures

  • The three methods to address a spill are containing it (e.g., plugging a leak), confining it (e.g., building a dam around it), and controlling it (e.g. neutralizing the substance).

When addressing the hazards of a spill, there are three methods that can be used:

  • Contain it — Containing a release is keeping the remainder of the hazardous substance in its container. Examples of containing methods include plugging or patching leaks.
  • Confine it — Actions to take to confine a hazardous release and keep it from flowing any further could include using absorbents, diverting a spill, building a dam, or digging a trench.
  • Control it — Actions to otherwise control a spill and limit exposure and damages could include improving ventilation or neutralizing the substance, for example.

Everyone who is tasked with containing, confining, and/or controlling a hazardous substance release must be aware of their surroundings and watch for any indication that conditions are changing. Also, they must pay attention to how they are feeling and keep an eye on their “buddies.”

If any signs or symptoms of chemical exposure are present, employees should leave the area immediately. They can then regroup, discuss the new information, and make changes to the action plan.

The personnel authorized to address the release should consider the following factors when deciding what spill control measures to use:

  • What the release substance is and its hazards;
  • The chemical properties of the substance, including whether it is in solid, liquid, or gaseous form;
  • Whether the substance is under pressure;
  • Whether the release is on land, in the air, or in water;
  • What natural or man-made barriers are already in place; and
  • Weather conditions, such as extreme heat and cold, wind speed and direction, and rain.

Containing a spill might include measures such as:

  • Plugging and patching,
  • Overpacking,
  • Shutting off a valve, or
  • Rolling and tipping a leaking container so the hole is at the top.

Confining a spill might include the following measures:

  • Sorbents
  • Drip pans
  • Diversion and retention ponds
  • Damming, diking, or curbing
  • Booming
  • Drainage systems
  • Vapor dispersion
  • Vapor suppression
  • Covering the spill

Some measures that can be used to control a spill emergency and limit exposure and damages include:

  • Transferring the substance to a new container
  • Vacuuming the spill
  • Venting gases
  • Using dispersants
  • Dilution
  • Ventilation
  • Burning or flaring the substance
  • Converting the spill to a gel or solid
  • Neutralizing the spill
  • Using a chemical to react with the substance

Decontamination

  • Decontamination (also called decon) is a process that removes or deactivates contaminants or otherwise prevents them from spreading.
  • When working with hazardous waste or other hazardous substances, the goal is to keep contamination levels as low as possible to minimize employee exposure to contaminants.
  • HAZWOPER requires decontamination procedures to be in place before any personnel or equipment enter areas with the potential for contamination.

Even when general safety measures are taken, it might not be possible to eliminate exposure to contamination. Therefore, decontamination is critical to health and safety. Decontamination (also called decon) is a process that removes or deactivates contaminants or otherwise prevents them from spreading.

The Occupational Safety and Health Administration’s (OSHA) decon requirements are listed in paragraph (k) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. The requirements for decontamination address things like:

  • The location of decontamination activities,
  • Equipment and solvents used,
  • Personal protective equipment (PPE) and chemical protective clothing (CPC) for decon-line workers, and
  • The use of commercial laundries or cleaning establishments.

Decon procedures must be in place before any personnel or equipment may enter areas where potential for exposure to hazardous substances exists.

Contamination basics

Properly contained hazardous substances do not pose a contamination threat. Contamination occurs when they spread outside of the container and reach skin, clothing, tools, protective equipment, instruments, vehicles, or any other surface. Soil may also be contaminated. Contaminants could take these forms:

  • Vapors
  • Dusts
  • Mists
  • Liquids
  • Radioactive particles
  • Biological materials

When hazardous substances collect on surfaces, it is considered “surface contamination.” However, sometimes contaminants can permeate materials, which is considered “permeated contamination.” Both types of contamination can cause exposure if they are not detected and removed.

Because permeated contaminants are harder to detect and remove than surface contaminants, they can cause unexpected exposures. Factors that can affect the degree or rate of permeation include:

  • Concentration level of the hazardous substance;
  • Contact time between the contaminant and surface material;
  • Temperature, pressure, and humidity;
  • Size of the contaminant molecules (smaller molecules can permeate materials more easily);
  • Physical state of the contaminant (gases and vapors tend to permeate more easily); and
  • Condition of the surface material.

Contamination can be transferred from one item to another, protective clothing to wearer, equipment to personnel, or from one area to another. This is known as cross-contamination.

Preventing or reducing contamination

When working with hazardous waste or other hazardous substances, the goal is to keep contamination levels as low as possible to minimize employee exposure to contaminants.

To prevent contaminants from reaching the body, all PPE and CPC must fit properly, and all the fasteners on clothing must be fully closed. More ways to help prevent contaminants from reaching the body include:

  • Tucking boots and gloves under pant leg and sleeve cuffs (if outer clothing includes these);
  • Wearing hoods outside the collar;
  • Using tape to seal the area where the sleeves meet the gloves and the pant legs meet the boots;
  • Inspecting PPE and CPC for any punctures, holes, cuts, or degradation prior to donning;
  • Avoiding or minimizing contact with contaminants; and
  • Wearing outer garments that are disposable.

If an employee has any cuts, sores, or wounds, even proper PPE and CPC may not be enough protection. This is because if an open wound is present and the employee’s PPE or CPC experiences permeation, the contaminant has a direct path to enter the body. Any employee with a wound should wear a bandage to prevent contaminant entry and seriously consider not entering any contaminated areas until the wound is healed.

Other control measures

Other preventative strategies include collecting samples remotely and limiting contact with contaminants, such as by:

  • Using a tool to open containers (rather than by hand),
  • Not splashing substances when sampling or opening containers,
  • Using drum grapplers,
  • Not touching potentially hazardous substances (if possible),
  • Not using contaminated instruments or equipment,
  • Watering down dusty areas,
  • Not walking through (or kneeling in) puddles of hazardous substances, and
  • Not sitting on contaminated soil.

Contamination of tools and equipment can be minimized by covering them in plastic, bagging them, or coating them with a substance that is easily removed later. Leaky containers can be placed in overpacks, or oversized containers, to keep the contents from spreading further. Contaminated surfaces could also be encased in plastic to prevent any spread.

Decontamination basics

  • Decontamination is intended to protect employees, contain contaminants, and prevent the mixing of incompatible wastes.

Unfortunately, no matter how well a workplace is safeguarded against contamination, contaminants may still reach employees. Once a person is contaminated, exposure can occur and health effects may result. That means decontamination is critical to:

  • Reducing employee exposure to hazardous substances, and
  • Protecting employee health.

The Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard states that decontamination is the removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects.

Contaminants can be removed:

  • Physically,
  • Using chemicals to deactivate or neutralize the contaminants, or
  • Using a combination of both physical and chemical removal methods.

One way of physically removing contaminants is by washing them off the surface, just as people wash their hands to prevent the spread of germs.

There are many different methods of decontamination that can be applied to employees, tools, equipment (including personal protective equipment, or PPE), instruments, samples, buildings, vehicles, roadways, soil, and even water supplies.

The process of decontamination is sometimes referred to as decon, decontaminating, or deconning. Its purpose is to:

  • Protect employees as they remove contaminated PPE and chemical protective clothing (CPC),
  • Prevent the mixing of incompatible wastes,
  • Prevent others from being contaminated by minimizing the transfer of contaminants and contaminated equipment to clean areas of the site, and
  • Protect the community by preventing the migration of contaminants from the site.

Decontamination procedures

Because decon is so critical to employee health, OSHA requires employers to have decon procedures in place. The agency requires all personnel to be appropriately decontaminated when leaving a contaminated area.

The decontamination process includes appropriately disposing of or decontaminating all contaminated clothing and equipment before leaving a contaminated area. The outside of sample containers too should be decontaminated.

Decontaminating PPE is an important part of maintaining its usefulness and effectiveness, along with cleaning, laundering, maintaining, and replacing it as needed.

At a hazardous waste cleanup site, the decon procedures will be part of the site-specific safety and health plan. For emergency response operations, the decon procedures will be part of the emergency response plan (ERP).

Decontamination procedures establish a standard way of performing decon activities. Employers must develop procedures that address:

  • The number and placement of decon stations,
  • The necessary decon equipment and methods,
  • Procedures to prevent contamination of clean areas,
  • Procedures to minimize contamination during the removal of PPE and CPC, and
  • How to handle clothing and equipment that may not be able to be completely decontaminated.

Employees should read through all decontamination procedures before entering any areas with the potential for exposure to hazardous substances.

It’s also a good idea to run practice drills of decon procedures in non-contaminated areas, especially for the decon of personnel dressed out in their PPE and CPC. These drills may be slow going at first, but with practice, they can help employees perform actual decon activities quickly and efficiently, which may be necessary when an entry worker in a self-contained breathing apparatus (SCBA) is running out of air.

According to the HAZWOPER Standard, decontamination procedures must be monitored to determine their effectiveness. If any deficiencies are discovered in the procedures, steps must be taken to correct them.

Decon methods

  • Contaminants can be removed using physical or chemical methods or a combination of the two.

Decon methods include physical and chemical methods or a combination of these methods. If multiple contaminants are present, a combination of both physical and chemical methods may be needed to remove them.

Physical methods

Physical methods are typically used to remove gross contamination. These physical methods of decon often involve one or more of the following:

  • Dislodging
  • Displacement
  • Rinsing with water or a liquid rinse solution
  • Wiping off
  • Evaporation

Sometimes it may be necessary to use high pressure or heat to help physically remove contaminants. However, these two methods should be used with caution, as they may cause the spread of contamination or burn an employee or equipment.

Contaminants that can be removed by physical means typically fall into three categories:

  • Loose contaminants — Dusts, soils, vapors, and particulates are examples of loose contaminants. Most often, loose contaminants can be rinsed off successfully with water alone, soap and water, or a liquid rinse. If they cling statically, anti-static solutions and sprays may help remove them.
  • Adhering contaminants — Contaminated glues, cements, resins, and muds adhere and may be harder to remove. Some physical methods of removing adhering contaminants include scraping, brushing, wiping, and melting.
  • Volatile liquids — Volatile-liquid-type contaminants are usually allowed to evaporate and then followed up with a water rinse. Using steam jets may help with the evaporation phase, but caution should be taken to prevent inhalation of the vaporized chemicals during this approach.

Other physical methods to consider for removing contaminants include:

  • Pressure washing
  • Sponge wiping
  • Absorbing
  • Vacuuming
  • Pressurized air jets
  • Removal by disposal

Chemical methods

Using chemicals may also take care of contaminants. A common chemical method is to dissolve contaminants in a solvent. There are three types of solvents: dilute acids, dilute bases, and organic solvents. Issues to consider when using solvents include the following:

  • The solvent being used must be compatible with the equipment or clothing that is being decontaminated.
  • Residues might be left behind on equipment or material.
  • Using organic solvents on protective clothing could cause damage to the material or permeation.
  • Halogenated solvents are toxic and could cause damage to materials — they should be used only as a last resort if recommended by an industrial hygienist.
  • Used solvents must be collected and disposed of properly. Surfactants, such as common household detergents, are also used as a chemical method of contamination removal.

Surfactants reduce adhesive forces between the contaminant and the surface being cleaned. They also prevent the contaminant from redepositing on the surface.

Contaminants can be solidified by:

  • Freezing them with ice or ice water,
  • Using chemical reactions, or
  • Removing the moisture from them with an absorbent material.

Rinsing the surface also helps remove contaminants through dilution, physical attraction, and increased solubility. Continuous rinsing or rinsing multiple times may be required for this method.

Yet another option uses chemical disinfectants, which can inactivate some infectious agents. However, this chemical method does not work well on personal protective equipment (PPE), so disposable PPE is often used when infectious agents are involved.

Other chemical methods that can be used for removal of contaminants include:

  • Adsorption
  • Neutralization
  • Oxidation or reduction
  • Irradiation

Decon extent, limits, and effectiveness

  • The extent of decon required for an entry worker depends on the type, amount, and location of contaminant; the worker’s job tasks and reason for leaving the area; and the protection in use.

To decide the extent of decon needed for an entry worker, these factors should be considered:

  • Type of contaminant,
  • Amount of contaminant,
  • Level of protection entry workers will use,
  • Work function of entry workers,
  • Location of contamination, and
  • Reason for leaving the contaminated area.

For personnel decon, the type of contaminant plays a big role in the extent of decon required. If the hazardous substance is known to be highly toxic or destructive to the skin, a full decon should be performed. The procedure can be downgraded if the substance is less hazardous.

It’s sometimes possible to determine visually the amount of contamination deposited on protective clothing or equipment. If gross contamination exists, a thorough decon should be performed. High amounts or concentrations of contamination increase the probability of permeation. Contaminants remaining on protective clothing for an extended period may degrade it.

The level of protection can also affect the extent of decon required. Some pieces of equipment or clothing are more difficult to decontaminate. For example, a smooth material like a plastic apron may need only a water rinse, but the straps on a self-contained breathing apparatus (SCBA) may require much more effort.

The employee’s work function or tasks performed can contribute to the extent of decon required. For example, an employee shutting off a valve at the source of a leak will have a different level of contamination than an employee performing monitoring activities along the edge of the leak. The extent of decon required will be different.

The location of contamination also makes a difference. Contamination that has settled on the outer pant leg of an employee’s protective clothing poses less of a risk than contamination around the upper chest and shoulders near the employee’s breathing zone. In other words, the closer the contamination is to the breathing zone, the higher the risk.

Finally, the reason the employee is leaving the contaminated area can impact the extent of decon required. An employee who is leaving the area to drop off or pick up a tool may not require any decon or merely require a partial decon. However, an employee changing a respirator may require some degree of decon. Moreover, an employee who is leaving the contaminated area to go to a different area will require a full decon.

Decon limitations

Of course, decon has its limits. It can even pose hazards to employee health and safety. Limitations include:

  • The method used could be incompatible with the contaminant being removed, causing an explosion, heat, or a toxic release.
  • Some methods, especially those using organic solvents, can cause permeation or degradation of clothing, equipment, or other surface materials.
  • Hazardous vapors used for some chemical decon methods may pose an inhalation hazard and/or be flammable.

The chemical and physical compatibility of the decon method must be determined before it is used. Any method that permeates, degrades, damages, or otherwise impairs the safe functioning of PPE should not be used.

Employers must take measures to adequately protect employees from any decontamination method that poses a direct health threat.

Decon effectiveness

Unfortunately, decontamination efforts are not always effective. The method chosen for decon may work great with one hazardous substance but not at all with another. The good news is that several methods can be used to test the effectiveness of decon, including:

  • Visual observation
  • Wipe sampling
  • Cleaning solution analysis
  • Testing for permeation

Effectiveness can be tested for by simply observing the surface material. Things to watch for include:

  • Discolorations
  • Stains
  • Visible dirt
  • Alterations
  • Degraded materials

Substances adhering to objects may indicate contaminants have not been removed. Some contaminants can be detected with ultraviolet light. However, passing a visual observation test does not necessarily mean the material is free of contaminants. Many contaminants are not easily observed.

One way to assess decon in more depth than visual observation is to perform wipe sampling, in which a wet or dry cloth, glass fiber filter paper, or swab is wiped over the surface of the material or object after it has been decontaminated. This sample is then analyzed in a lab to verify whether the decon method was effective.

Yet another way to measure decon effectiveness is with cleaning solution analysis. If the final rinse solution used in the decon line still has elevated levels of contaminants, additional decontamination may be required.

And last, if visual observation suggests (or the employee otherwise suspects) that a material has been permeated, pieces of the material can be sent to a lab to be tested for permeation.

When decon measures are found to be ineffective, appropriate steps shall be taken to correct any deficiencies.

Decon equipment

  • Necessary decon equipment includes supplies for marking and separating contaminated items and areas, supplies for washing, various containers, and general cleaning supplies.

Being prepared to decontaminate personnel and their protective equipment and clothing includes having all the decon equipment and supplies ready and available. It may be helpful to use a checklist to ensure there are enough supplies.

Some of the supplies and equipment needed to decontaminate personnel and their protective equipment and clothing include:

  • Drop cloths or sheets of plastic to set heavily contaminated equipment and clothing on;
  • Lined collection containers for items to be discarded;
  • Tubs, tanks, or wading pools to hold wash and rinse solutions;
  • Wash and rinse solutions;
  • Long-handled, soft-bristled brushes;
  • Paper or cloth towels;
  • Folding chairs to sit on when removing boots;
  • Lockers or cabinets for storing decontaminated items;
  • Plastic sheeting or sealed pads with drains to collect wash and rinse solutions;
  • Metal or plastic drums to collect wash and rinse solutions; and
  • Shower facilities or wash sinks with soap, washcloths, and towels.

Other supplies and equipment needed for personnel decon include:

  • Barricade tape (like caution tape),
  • Tables to hold smaller containers and equipment,
  • Masking and duct tape,
  • Pens and permanent markers,
  • Labels and tags,
  • Sanitizing wipes,
  • Spray bottles,
  • Wire brush for hard-to-remove contaminants,
  • Buckets,
  • Stepladder, and
  • HEPA vacuum with filters.

Vehicle and equipment decon

Large items like vehicles and heavy equipment can be challenging to decontaminate. Some of the supplies needed overlap with those for deconning personnel. Equipment and supplies that may be needed when decontaminating vehicles and heavy equipment include:

  • Storage tanks for temporary storage and possibly treatment of contaminated wash and rinse solutions;
  • Drains or pumps for collecting solutions;
  • Long-handled brushes to help scrub exteriors;
  • Long-handled rods or shovels to dislodge contaminants from tires and undersides of vehicles and heavy equipment;
  • Wash and rinse solutions;
  • Pressurized sprayers;
  • Curtains, tarps, or enclosure booths to contain spray;
  • Buckets or other containers to hold materials like soil that dislodge from the vehicle or heavy equipment;
  • Wash and rinse buckets for interiors; and
  • Brooms and brushes for interiors.

Equipment selection factors

The selection of equipment to use during decon should take into account the contaminants involved. How effective would the equipment be in removing those particular contaminants? Are there chemicals or biological agents that may require special attention?

Consider, too, the functionality and capacity of the equipment. In what areas could this be used? How many personnel, vehicles, or pieces of equipment could be decontaminated before it loses its capacity or is used up?

Other factors to consider when selecting equipment for decon include:

  • Time required to set up the equipment,
  • Type of power required to run the equipment,
  • The operational environment (like extreme temperatures, rain, snow, or ice) and its impact on equipment,
  • Whether the equipment is durable and rugged,
  • Employees available to operate the equipment and their skill level and familiarity with it, and
  • Whether training would be required to proficiently operate the equipment.

Location of decon operations

  • Decontamination is conducted in the Contamination Reduction Zone, between the contaminated Exclusion Zone and the clear Support Zone.

Whenever there is a contaminated area or an emergency release of a hazardous substance, zones are set up around the area. The contaminated area is called the Exclusion Zone (EZ), also known as the “hot zone.” The EZ extends outward far enough to prevent adverse effects to personnel outside the area.

The outside perimeter of the EZ is marked by a boundary of ropes, barricade tape, stanchions, cones, or other markers. This boundary is called the “hotline.” Only employees with proper training, personal protective equipment (PPE), and chemical protective clothing are allowed to enter the EZ.

The Contamination Reduction Zone (or CRZ) is a buffer or transition area between the EZ and the clean area. The outer boundary of the CRZ, called the contamination control line, is marked. Decontamination occurs in the CRZ.

Note: Anyone who is working in the EZ with a self-contained breathing apparatus (SCBA) will need to leave the area with enough air to proceed through the decontamination process in the CRZ.

A Contamination Reduction Corridor (CRC), also known as the decon line, is set up inside the CRZ. It’s in this corridor that all the decon activities take place. This includes the decontamination and removal of PPE and protective clothing.

The corridor limits decon activities to a smaller area that minimizes the exposure of uncontaminated employees or equipment, including exposure from runoff or overspray.

Rest stations are often set up in the corridor. Depending on the weather conditions, the rest stations may offer warming or cooling while employees take a break.

There may be more than one decon line in the corridor. If entry workers may be exposed to incompatible components, they should have separate decon lines to allow them to avoid mixing. Also, a separate line can be used to accommodate the decontamination of heavy equipment and vehicles.

Because the CRZ and the EZ have the potential to be dangerous to life and health, no one is allowed in these areas without proper training, PPE, and protective clothing. The contamination control line has an entry point and is usually staffed to make sure no unauthorized personnel enter. If warranted, there may even be security personnel making sure the area is secure.

All entry and exit from the EZ is made through the CRC. Each person or item in the CRC must be thoroughly decontaminated before entering the clean area.

The outermost zone is the Support Zone. This is also known as the “clean area” or “cold zone” and consists of all areas outside the contamination control line. There should be no possibility of exposure to hazardous substances in the Support Zone, and thus no need to wear PPE and protective clothing in relation to hazardous substances.

The command post, first aid station, emergency transport vehicles, lockers, and showering or changing facilities are all located in the Support Zone.

Decon line basics

  • A decon line is a row of stations for different decontamination tasks, arranged from most to least contaminated gear.

The decon line consists of different stations set up in a row, each with a specific purpose, such as washing boots or removing outer gloves. The stations should be separated physically. If they are too close, cross-contamination may occur.

The sequence of the stations will address the outermost protective equipment and clothing first because those will be the most contaminated. As workers continue through the line, the levels of contamination should decrease.

During decon activities on the decon line, entry workers will be decontaminated and helped by decon station workers to remove personal protective equipment (PPE) and chemical protective clothing (CPC). Caution is required so that residual contaminants do not contact decon station workers’ skin or splash or drift toward them during the removal process.

Anyone assigned to decontaminate entry workers must wear the same level of PPE and CPC as the workers being decontaminated. In some instances, they may wear one level below what the entry workers are wearing. In other words, someone decontaminating a worker wearing a Level A ensemble will need to wear either a Level A ensemble or, if deemed appropriate, no less than a Level B ensemble.

However, those performing decon at one of the last stations, where levels of contaminants are much lower, may be able to downgrade their ensemble level.

The level of protection for decon-line workers depends on:

  • Expected or visible contamination on entry workers,
  • Type of contaminant and associated respiratory and skin hazards,
  • Total vapor or gas concentrations in the CRC,
  • Particulates and specific inorganic or organic vapors in the corridor, and
  • Results of any swipe tests.

Employers must have specific procedures for the decontamination process and the order of stations in the decon line. Workers must be familiar with the procedures and have a chance to practice them before being stationed to help decontaminate coworkers or going through the decon line.

Equipment disposal or decon

All equipment used in the EZ or in the CRZ for decon procedures must also be decontaminated before it can enter the Support Zone. Any equipment, supplies, or protective equipment and clothing that cannot be decontaminated must be disposed of properly. These items may now be considered hazardous waste or hazardous materials and must be tagged or labeled as such.

Wash solutions, solvents, and rinse water should be collected and placed in appropriate containers with proper markings, labels, or tags for either disposal or treatment.

Any items that will undergo further decon later should be bagged in plastic and labeled as contaminated items.

If permeable clothing gets splashed by any hazardous substance, that clothing should immediately be removed and either discarded or decontaminated. The wearer should then proceed to the shower.

If commercial laundering facilities are used for PPE or clothing, the laundering facility must be made aware of the potential harmful effects of the hazardous substances. These items should be properly bagged and labeled for transport to the facility.

No one should remove PPE or CPC from the changing rooms without authorization.

Emergency and mass decon

  • If a person’s life is in danger, decon should be delayed until the person is stabilized.
  • The purpose of mass decon is to quickly remove contaminants from large populations of people, as after a widespread emergency release or a terrorist attack.

Emergency decon

What if a contaminated worker has a life-threatening illness or injury? That’s when emergency decon procedures kick in. If a person’s life is in danger, decontamination should be delayed until the person is stabilized. However, there are two exceptions to delaying decontamination:

  • If, based on the condition of the victim, decon can be performed without interfering with life-saving techniques or first aid services; or
  • If the injured or ill worker is contaminated with a highly toxic or corrosive substance that can cause severe injury or loss of life.

In other words, decon should be performed immediately if it will not interfere with saving a life or if it will prevent further severe injury or loss of life from extremely toxic or corrosive materials.

Some recommendations on dealing with contaminated personnel suffering from life-threatening injury or illness include:

  • Always remove respirators and backpacks.
  • Do not attempt to wash or rinse the victim onsite.
  • Cut open and remove outer chemical protective clothing (CPC) if this can be done safely.
  • If outer CPC cannot be safely removed, wrap the worker in plastic, rubber, or blankets to prevent the spread of contamination to medical personnel and transport vehicles.
  • If the emergency is due to heat stress, cut off and remove CPC as quickly as possible. Heat stress can elevate to heatstroke, which can be deadly.
  • Site personnel who are familiar with the incident should accompany the ambulance to the medical facility and bring information about the contaminant along for the physician.
  • Consider the stretcher, transport vehicle, and emergency room to be contaminated areas.
  • Once the victim is stabilized, decon the victim and any contaminated areas.
  • Contain and properly tag or label all waste generated from the decon process.

Mass decon

The purpose of mass decon is to quickly remove contaminants from large populations of people, including the public, who have been exposed to an emergency release of a hazardous substance. Mass decon could also be applied after a terrorist attack using weapons of mass destruction (WMD).

Due to time constraints, initial mass decon may not be set up as fully as it would at an established hazardous waste cleanup operation. Water hoses are typically used for mass decon if the contaminant is not water reactive.

The most important thing is to address the potentially life-threatening needs of the people who have been exposed, but mass decon efforts also include decon of tools, equipment, buildings, roads, and anything else exposed during the incident.

A more formal decon setup may be installed while initial mass decon is going on. This greater level of decontamination may be needed if initial mass decon methods are proved ineffective.

If there is a need for mass decon, then local, state, and federal agencies will likely be involved. Decisions on how to handle the incident will be based on the size and severity of the incident.

Tents may be set up for medical attention and decon stations. Mass decon needs to be executed as soon as possible to limit exposures and the spread of contaminants. Extra help and supplies would likely be coming from surrounding areas.

Emergency response for uncontrolled hazardous waste sites

  • HAZWOPER requires an emergency response plan from employers whose workers are expected to handle hazardous waste releases, and an emergency action plan if workers are expected to evacuate in the event of a release.

Because hazardous waste cleanup sites have the potential for chemical emergency situations, it’s important to plan and have procedures in place. Paragraph (l) of 29 CFR 1910.120 and 1926.65 goes over the requirements for emergency response involving the uncontrollable release of hazardous waste and other hazardous substances.

Proper emergency planning and response are important elements of the site-specific safety and health plan that help minimize employee exposure, illness, and injury. The employer must provide either an emergency response plan (ERP) or an emergency action plan (EAP) for the site, depending on what action employees are expected to take in an emergency.

Emergency response plan

The ERP provides guidance to employees so that quick, decisive action can be taken in the event of an emergency release. An emergency release is when the release of a hazardous substance cannot be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. Employees from outside the immediate release area or other designated responders are needed to handle the release.

This type of release is uncontrolled or likely to result in an uncontrolled release, and it poses a threat to site personnel, the environment, and possibly even the public, depending on the size and nature of the release.

When it comes to emergency situations involving hazardous substances, it is extremely important to have a plan. It’s also important that everyone involved be familiar with the plan and know exactly what their role is in the event of an emergency release. Seconds could make a huge difference in the outcome.

The Occupational Safety and Health Administration (OSHA) requires employers to put together an ERP if their own personnel will be handling the release. The plan must be in writing and include pre-planning for each of the following elements:

  • Pre-emergency planning;
  • Personnel roles, including lines of authority and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination procedures;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up;
  • Personal protective equipment (PPE) and emergency equipment;
  • Site topography, layout, and prevailing weather conditions; and
  • Procedures for reporting incidents to governmental agencies.

The ERP must be a separate section of the site safety and health plan. Hazardous waste cleanup sites are also required to ensure the ERP is compatible and integrated with local, state, and federal emergency and disaster plans; rehearsed regularly; reviewed periodically; and updated as necessary.

Emergency action plan

If an employer is not required to have responders onsite and wants to simply evacuate all personnel from the danger area during an emergency release situation, then an ERP is not required. Instead, an EAP is mandated. An EAP is initiated when:

All employees must evacuate from the danger area if an emergency release occurs, and

No site employees are permitted to assist in handling the release itself.

In this case, an outside contractor or local emergency personnel, such as the fire department, will handle the emergency release. Coordination with the outside entity is arranged prior to any emergency release.

If there are only 10 or fewer workers onsite, the employer may communicate the EAP with them orally. Otherwise, the plan must be in writing. The employer is required to review it with employees when they are initially hired and again if any changes are made to the plan or their responsibilities under the plan change.

Employers might think of the EAP as an evacuation plan. The elements of an EAP must include:

  • Procedures for reporting a fire or other emergency, Evacuation routes and procedures,
  • Procedures for critical operations,
  • Procedures to account for all personnel after evacuation,
  • Procedures for workers performing rescue or medical duties, and
  • The name or job title of a person to contact for more information about the plan.

For more details about the EAP requirements, please refer to the Emergency planning subject.

Training

  • Any employee expected to respond to an emergency situation must be trained on how to do so safely and effectively.

Emergency response personnel include any employees who are expected to respond to an emergency situation at a hazardous waste cleanup site. These employees need training in how to respond safely in a hazardous emergency situation that may expose them to hazardous substances.

Employers must train these employees in accordance with subparagraph (e)(7) of 29 CFR 1910.120 and 1926.65. Training must occur during times when the employees are being compensated.

An effective training program significantly reduces the number and severity of incidents from overexposure to health hazards.

Note: The Occupational Safety and Health Administration (OSHA) has stated in CPL 02-02-071 that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements. Computer-based training alone would not be sufficient. To provide all required training components, any computer-based training program must be supplemented by the opportunity for trainees to ask questions of a qualified trainer and must provide trainees with sufficient hands-on experience. Site- and task-specific training are also important.

Procedures for emergency response at hazardous waste cleanup sites

  • Emergency response operations have four basic steps — notification, preparation, response, and termination.

Subparagraph (l)(3) of 29 CFR 1910.12 and 1926.65 does not specify much in the way of emergency response procedures. However, according to the Occupational Safety and Health Administration (OSHA), the employer must evaluate the incident and the site response capabilities and, based upon the information available at the time of the emergency, proceed with the “appropriate steps” to implement the site emergency response plan (ERP).

Most emergency response operations follow some basic steps. OSHA makes it clear that no one should rush into a situation where there has been an emergency release of hazardous substances. It is always important to stay clear of vapors, fumes, smoke, and spills to minimize any health and safety risks.

If a hazardous substance is released, an employee who is unauthorized to confine, contain, control, or clean up a release must leave the affected area immediately. The employee should pay attention to as many details as possible on the way out and, once in a safe area, follow the employer’s procedures for notifying appropriate personnel.

For employees who are authorized to respond to an emergency release, there are four basic steps in an emergency response operation:

  1. Notification — Notify all onsite personnel of the emergency.
  2. Preparation — Size up the situation by quickly evaluating casualties, hazards, and response capabilities and allocating personnel and equipment for response.
  3. Response — Respond per appropriate steps in the ERP. This may include:
    • Taking rescue actions to stabilize, extricate, decontaminate, and transport victims;
    • Evacuating personnel and/or the public; and
    • Controlling the hazard itself.
  4. Termination — Follow up with termination procedures by restocking all equipment and supplies, debriefing responders, critiquing the incident, and updating the ERP.

For more on procedures for emergency response, please refer to the Emergency response operations for hazardous substance releases section of this subject.

Alarms

According to subparagraph (l)(3)(vi) of 29 CFR 1910.120 and 1926.65, an employee alarm system must be installed at hazardous waste cleanup sites to:

  • Notify employees of an emergency situation,
  • Stop work activities if necessary,
  • Lower background noise in order to speed communication, and
  • Begin emergency procedures.

Check out 29 CFR 1910.165, the Employee Alarm System Standard, along with the Emergency response operations for hazardous substance releases section of this subject for more on internal communication.

Illumination

  • Places onsite where hazardous waste cleanup work is being performed must meet minimum lighting requirements based on the type of area or operation.

Paragraph (m) of 29 CFR 1910.120 and 1926.65 details the minimum lighting requirements for any areas onsite where hazardous waste cleanup work is being performed.

Areas accessible to employees must be lighted to not less than the minimum illumination intensities listed in the following table while any work is in progress:

Minimum illumination intensity in foot-candlesArea or operations
3Excavation and waste areas, accessways, active storage areas, loading platforms, refueling areas, and field maintenance areas
5General site areas
5Indoors, i.e., warehouses, corridors, hallways, and exit ways
5Tunnels, shafts, and general underground work areas
Exception: Minimum of 10 foot-candles is required at tunnel and shaft heading during drilling, mucking, and scaling. Mine Safety and Health Administration-approved cap lights are acceptable for use in the tunnel heading.
10General shops, e.g., mechanical and electrical equipment rooms, active storerooms, barracks or living quarters, locker or dressing rooms, dining areas, and indoor toilets and workrooms
30First aid stations, infirmaries, and offices

The illumination requirements are designed to ensure that site areas accessible to employees are adequately lighted. Where night shifts are used, these requirements are particularly important.

Employers should ensure that illumination is adequate during all work shifts. Employers should also consider appropriateness of lighting equipment for the location, especially hazardous locations classified at 29 CFR 1910.307, 1910.399, 1926.407, and 1926.449.

Sanitation at temporary workplaces

  • Temporary workplaces must provide sanitary measures including toilets, washing facilities, water, and food-handling areas in accordance with requirements.

Sanitation is covered in paragraph (n) of 29 CFR 1910.120 and 1926.65. Sanitation refers to water supply, toilet and washing facilities, food-handling areas, and similar facilities. Sanitary measures are used to maintain an acceptable level of personal hygiene and to reduce the likelihood of exposure to hazardous substances through ingestion or dermal contact.

Sanitary measures that must be taken at a hazardous waste cleanup site include:

  • Washing facilities — Adequate washing facilities must be provided for those engaged in operations involving hazardous substances. These facilities must be provided in areas where exposures are below permissible exposure limits (PELs) or published exposure levels.
  • Toilets — Adequate numbers of toilets must be provided, in accordance with the table below. However, under temporary field conditions, provisions shall be made to have at least one toilet facility available.
    • The toilet number provision does not apply to mobile crews who have transportation readily available to nearby toilet facilities
    • Doors entering toilet facilities must be provided with entrance locks controlled from inside the facility.
    • If a sanitary sewer is not provided, chemical toilets, recirculating toilets, combustion toilets, or flush toilets must be provided, unless a toilet type is prohibited by local codes.

Number of employeesMinimum number of facilities
20 or fewerOne
More than 20, fewer than 200One toilet seat and one urinal per 40 employees
More than 200One toilet seat and one urinal per 50 employees
  • Showers and changing rooms — If the cleanup or removal operation will require six months or longer to complete, showers and changing rooms must also be provided.
    • Showers must meet the requirements of 29 CFR 1910.141(d)(3) or 1926.51(f)(4). Showers and changing rooms must be located in areas where exposures are below the PELs and published exposure levels. If this is not possible, then a ventilation system must be provided to supply air that is below the PELs and published exposure levels. Employers must have employees shower at the end of their work shift and when leaving the hazardous waste site.
    • Changing rooms must meet 1910.141(e) or 1926.51(i). Changing rooms shall consist of two separate change areas separated by the shower area. One change area, with an exit leading off the worksite, must provide employees with a clean area where they can remove, store, and put on street clothing. The second area, with an exit to the worksite, must provide employees with an area where they can put on, remove, and store work clothing and personal protective equipment (PPE).
  • Sleeping quarters — If sleeping quarters are provided, they must be heated, ventilated, and lighted.
  • Food — Food-handling measures must meet local codes.
  • Water — An adequate supply of potable water must be provided on the site.
    • Portable containers used for drinking water must be designed to prevent contamination, clearly marked as drinking water, and equipped with a tap. Employees must not be allowed to dip water from the container.
    • Where single-use cups are supplied, both a sanitary container for the unused cups and a receptacle for disposing of the used cups must be provided.
    • Potable and non-potable water systems must be kept separate.
    • Non-potable water systems must be clearly marked, indicating that the water is unsafe for drinking, washing, or cooking.

New technology program

  • As part of the site safety and health plan, employers must have procedures for reviewing and introducing new technologies, equipment, and control measures.

Paragraph (o) of 29 CFR 1910.120 and 1926.65 requires hazardous waste sites to evaluate new technology and consider implementing any available and effective new technologies that could improve the way the site controls hazards. Some examples are new foams, absorbents, and neutralizers that can be used to decrease the level of exposures to hazardous substances.

It is important that new technologies, equipment, and control measures be evaluated by the employer to determine the effectiveness of employee protection before they are implemented onsite. As part of the evaluation, the employer should review information from the manufacturer and supplier.

To ensure ongoing employee protection, employers are required to develop and implement procedures for new technology review and introduction. The site safety and health plan must include these procedures.

Hazardous waste treatment, storage, or disposal (TSD)

  • TSD facilities are fixed ongoing operations for handling substances from outside sources, and thus regulated differently from hazardous waste cleanup sites.

Hazardous waste treatment, storage, or disposal (TSD) facilities generally operate differently than hazardous waste cleanup sites. For example, TSD facilities tend for the most part to be fixed ongoing operations that handle the following for hazardous wastes or hazardous substances from outside sources:

  • Receiving
  • Processing
  • Storage
  • Treatment
  • Disposal

In contrast, cleanup operations are temporary emergency operations involving often undefined and substantial quantities of hazardous waste. Consequently, hazards at TSDs tend to be better controlled and more routine and stable. Therefore, less extensive requirements are appropriate.

The Occupational Safety and Health Administration (OSHA) has a separate paragraph (p) in 29 CFR 1910.120 and 1926.65 to cover TSD operations. Specifically, this paragraph applies to operations involving hazardous wastes that are conducted at TSD facilities regulated by 40 CFR 264 or 265 or by agencies under agreement with the Environmental Protection Agency (EPA) to implement Resource Conservation and Recovery Act (RCRA) regulations.

Exceptions for certain hazardous waste generators

  • Hazardous waste generators that are not required to have a permit or interim status are also not required to comply with subparagraphs (p)(1) to (p)(7) of 1910.120 and 1926.65, but they must consider whether they fall under the emergency response provisions at (p)(8).
  • Compliance with the requirements of paragraph (q) is considered to be in compliance with the requirements of paragraph (p)(8) for emergency response operations conducted in hazardous waste treatment, storage, or disposal areas.

All provisions of paragraph (p) of 29 CFR 1910.120 and 1926.65, including subparagraphs (p)(1) to (p)(8) cover any treatment, storage, or disposal (TSD) operation:

However, some employers are not required to have a permit or interim status. These include employers who are considered:

  • Very small quantity generators (VSQGs) of hazardous waste, and
  • Small quantity hazardous waste generators (SQGs) and large quantity hazardous waste generators (LQGs) that quality for exemptions from regulation under 40 CFR 264, 265, and 270.

OSHA explains that hazardous waste generators that are not required to have a permit or interim status are also not required to comply with subparagraphs (p)(1) to (p)(7) of 1910.120 and 1926.65, but they must consider whether they fall under the emergency response provisions at (p)(8).

Subparagraph (p)(8) offers a loophole. Employers who will evacuate their employees from the worksite location when an emergency occurs and who do not permit any of their employees to assist in handling the emergency are exempt from the requirements of subparagraph (p)(8) if they provide an emergency action plan complying with 29 CFR 1910.38 or 1926.35.

Currently, SQGs and LQGs are required to provide an emergency coordinator and perform emergency response. That means these two generator types cannot qualify to take the (p)(8) loophole and must meet all of subparagraph (p)(8).

Federal EPA does not require VSQGs to provide an emergency coordinator or perform emergency response, so VSQGs should check their state and local laws and regulations to determine if they are required to have employees take on emergency response duties.

VSQGs are exempt from subparagraph (p)(8) of 1910.120 and 1926.65 if they:

  • Are not required by a state or local agency to have employees engage in emergency response,
  • Direct their employees to evacuate in the case of such emergencies, and
  • Meet the requirements of subparagraph (p)(8)(i), including providing an emergency action plan.

Note: According to subparagraph (a)(2)(iii)(C) of 1910.120 and 1926.65, if an area is used primarily for hazardous waste treatment, storage, or disposal, any emergency response operations conducted in that area shall comply with paragraph (p)(8). In other areas not used primarily for hazardous waste treatment, storage, or disposal, any emergency response operations shall comply with paragraph (q) of 1910.120 or 1926.65.

However, subparagraph (a)(2)(iii)(C) also says compliance with the requirements of paragraph (q) is considered to be in compliance with the requirements of paragraph (p)(8). Therefore, the employer who does not or cannot take the (p)(8) loophole has the option to comply with either (p)(8) or (q) for any emergency response operations conducted in the hazardous waste treatment, storage, or disposal area.

Programs

  • OSHA requires TSD facilities to provide programs including safety and health, hazard communication, medical surveillance, and others.

Employers conducting operations at treatment, storage, and disposal (TSD) facilities specified in paragraph (a)(1)(iv) of 1910.120 and 1926.65 must provide and implement the programs listed in paragraph (p).

Safety and health program

Employers are required to develop and implement a written safety and health program for employees involved in hazardous waste operations. This program needs to be available for inspection by employees, their representatives, and Occupational Safety and Health Administration (OSHA) personnel.

The safety and health program shall be designed to identify, evaluate, and control safety and health hazards in the employers’ facilities for the following purposes:

  • To protect employees;
  • To provide for emergency response operations that meet the requirements of paragraph (p)(8); and
  • To address issues including:
    • Site analysis,
    • Engineering controls,
    • Maximum exposure limits,
    • Hazardous waste handling procedures, and
    • Uses of new technologies.

Hazard communication program

The employer must implement a hazard communication program meeting the requirements of 29 CFR 1910.1200 as part of the employer’s safety and health program. The exemption for hazardous waste provided in 1910.1200 is applicable to paragraph (p) of 1910.120 and 1926.65.

Medical surveillance program

The employer must develop and implement a medical surveillance program meeting the requirements of paragraph (f) of 1910.120 or 1926.65. See the Medical surveillance section for details.

Decontamination program

The employer must develop and implement a decontamination procedure meeting the requirements of paragraph (k) of 1910.120 or 1926.65.

New technology program

The employer must develop and implement procedures meeting the requirements of paragraph (o) of 1910.120 or 1926.65 for introducing new and innovative equipment into the workplace. See the New technology program section for details.

Material handling program

Where employees will be handling drums or containers, the employer must develop and implement procedures meeting the requirements of subparagraphs (j)(1)(ii) through (viii) and (xi) of 1910.120 or 1926.65, as well as subparagraphs (j)(3) and (j)(8), prior to starting such work.

Training program

The employer must develop and implement a training program for employees exposed to health hazards or hazardous substances at TSD operations. This program is part of the employer’s safety and health program, with a goal of enabling employees to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees.

Emergency response program

All employers must develop and implement an emergency response plan (ERP). This plan doesn’t need to duplicate any subjects that are fully addressed in the employer’s contingency planning required by permits, such as those issued by the Environmental Protection Agency (EPA), provided that the contingency plan is made part of the ERP.

The ERP must be a written portion of the employer’s required safety and health program. Employers who will evacuate their employees from the worksite location when an emergency occurs and who do not permit any of their employees to assist in handling the emergency are exempt from the requirements of paragraph (p)(8) if they provide an emergency action plan complying with 29 CFR 1910.38 or 1926.35.

Training

  • Employers at TSD operations must provide a training program that includes overall safety training, as well as emergency response training for employees as appropriate.

All the training requirements for hazardous waste treatment, storage, and disposal (TSD) operations are found in subparagraph (p)(7) and (p)(8)(iii) of 29 CFR 1910.120 and 1926.65.

Employers must develop a training program as part of the overall safety and health program for employees who are exposed to health hazards or hazardous substances at TSD operations. This program must ensure that employees are properly trained to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees.

Initial and refresher training and certification for personnel

Subparagraph (p)(7) distinguishes between new employees and current employees with respect to required training, as indicated in the table below.

Trainee typeRequired initial and refresher trainingRegulation
New employees24 hours initial training
8 hours annual refresher
Subparagraph (p)(7)(i) of 1910.120 or 1926.65
Current employeesProven previous equivalent training or experience or 24 hours initial training
8 hours annual refresher
Subparagraph (p)(7)(ii) of 1910.120 or 1926.65

Employees must not perform any operations involving exposure to health hazards or hazardous substances at a TSD facility unless they have been trained by a competent trainer to the level required by their job function and responsibility. New employees must also receive a certificate showing that they have completed the necessary training.

Emergency responder training

Employees who work in hazardous waste treatment, storage, and/or disposal areas and who are expected to perform emergency response must be properly trained prior to responding to emergencies, in accordance with subparagraph (p)(8)(iii). However, the Occupational Safety and Health Administration (OSHA) offers two exceptions:

  1. An employer need not train all employees to the degree specified if the employer divides the workforce such that:
    • A sufficient number of employees who have responsibility to control emergencies have the training specified, and
    • All other employees who may first respond to an emergency incident have sufficient awareness training to recognize that an emergency response situation exists, summon the fully trained employees, and avoid attempting control activities for which they are not trained.
  2. An employer need not train all employees to the degree specified if:
    • Arrangements have been made in advance for an outside fully trained emergency response team to respond in a reasonable period, and
    • All employees who may come to the incident first have sufficient awareness training to recognize that an emergency response situation exists and call the designated outside fully trained emergency response team for assistance.

Required training must cover the employer’s emergency response plan (ERP), standard operating procedures, appropriate personal protective equipment (PPE), and procedures for handling an emergency response.

Employee members of TSD facility emergency response organizations must be trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees. This includes training in the:

  • Methods used to minimize risk from safety and health hazards;
  • Safe use of control equipment;
  • Selection and use of appropriate PPE;
  • Safe operating procedures to be used at the incident scene;
  • Techniques of coordination with other employees to minimize risks;
  • Appropriate response to overexposure from health hazards or injury to themselves and other employees; and
  • Recognition of subsequent symptoms that may result from overexposures.

Initially and at least annually, the employer must either document each employee’s attendance and successful completion of required training or certify each employee’s competency. The method used to demonstrate competency for certification of training must be recorded and maintained by the employer.

Trainer qualifications

Trainers who teach initial training must have either:

  • Satisfactorily completed a training course for teaching the subjects they are expected to teach, or
  • Acquired the academic credentials and instruction experience necessary to demonstrate a good command of the subject matter of the courses and competent instructional skills.

Training format

Please refer to Training format subsection under Hazardous waste cleanup operations section.

Emergency response for hazardous waste treatment, storage, and/or disposal areas

  • Subparagraph (p)(8) calls for implementation of a written ERP and responder training, unless otherwise exempted.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard requires that a treatment, storage, and disposal (TSD) facility develop and implement a written emergency response plan (ERP) in accordance with subparagraph (p)(8) as part of its safety and health program to handle possible emergencies at the facility.

According to subparagraph (a)(2)(iii)(C) of 1910.120 and 1926.65, if an area is used primarily for hazardous waste treatment, storage, or disposal, any emergency response operations in that area must comply with subparagraph (p)(8). In other areas not used primarily for hazardous waste treatment, storage, or disposal, any emergency response operations must comply with paragraph (q). However, compliance with the requirements of paragraph (q) is in compliance with the requirements of subparagraph (p)(8) for hazardous waste treatment, storage, or disposal areas.

Employers with a hazardous waste treatment, storage, or disposal area or facility who will evacuate their employees from the area or facility, respectively, according to (p)(8)(i) when an emergency occurs and who do not permit any of their employees to assist in handling the emergency are exempt from developing an ERP and from the training requirements of subparagraph (p)(8). However, employers who take this loophole must then develop an emergency action plan (EAP) and ensure that the training of site personnel is consistent with 29 CFR 1910.38 or 1926.65.

According to subparagraph (p)(8), employers that require their employees to respond to site emergencies must develop a written ERP that includes the following elements:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles;
  • Lines of authority;
  • Training and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination procedures;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up;
  • Personal protective equipment (PPE) and emergency equipment;
  • Site topography, layout, and prevailing weather conditions; and
  • Procedures for reporting incidents to local, state, and federal governmental agencies.

If a TSD facility has an ERP required by 40 CFR 264 or 265, containing all the elements above, a separate written plan will not be required. The employer must periodically review the facility’s ERP and update it as necessary to reflect new or changing site conditions or information.

Employees of TSD facilities or areas who are expected to perform emergency response must be properly trained and certified prior to responding to emergencies. The training must cover:

  • The ERP,
  • Standard operating procedures,
  • Appropriate PPE, and
  • Procedures for handling an emergency response.

The employer must also document the employee’s completion of training or certify the employee’s competency. At least yearly, the employer must also certify that each covered employee has attended and successfully completed the training or recertify the employee’s competency.

Emergency response operations for hazardous substance releases

  • The requirements for emergency response operations for hazardous substances releases depend on whether the release is an emergency or simply incidental.

Emergency response operations for releases of, or substantial threats of releases of, hazardous substances that are not otherwise covered by subparagraphs (a)(1)(i) through (a)(1)(iv) of 1910.120 and 1926.65 must only comply with the requirements of paragraph (q). Paragraph (q) is about hazardous substances, not just hazardous waste. Also, the term “emergency response or responding to emergencies” is defined at paragraph (a)(3).

To comply effectively with paragraph (q) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, it’s necessary to have a clear understanding of the distinction between an incidental release of a hazardous substance and a release that requires an emergency response. Please see the following sections:

Releases that are clearly incidental

  • Releases involving limited quantities of hazardous substance and posing no immediate threat to health or safety are considered “incidental.”
  • Incidental releases are not covered by HAZWOPER.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard does not cover the foreseeable release of a hazardous substance that is limited in quantity and poses no emergency or significant threat to the safety and health of employees in the immediate vicinity. This type of release is referred to as an “incidental release.”

An incidental release doesn’t pose a significant safety or health hazard to employees who are cleaning it up, nor does it have the potential to quickly become an emergency. As stated, incidental releases are limited in quantity, exposure potential, or toxicity and present only minor safety or health hazards.

If the hazardous substances in the work area are always stored in very small quantities, such as at a laboratory that handles amounts from test tubes to pints, and the hazardous substances do not pose a significant safety and health threat at that volume, then the risks of having a release that escalates into an emergency are minimal. In this setting, incidental releases will generally be the norm, and employees will be trained to protect themselves as per the training requirements of 29 CFR 1910.1200 and 29 CFR 1910 Subpart I.

Another example is a tanker truck receiving a load of hazardous materials at a tanker truck loading station. At the time of an accidental spill, the product can be contained by employees in the immediate vicinity and cleaned up utilizing absorbent without posing a threat to employee safety or health. As such, the employer may respond to certain incidental releases.

A third example of an incidental release is maintenance personnel who are repairing a small leak that resulted from a routine maintenance activity and can be readily repaired or does not need to be taken care of immediately, i.e., the safety and health of the employees are not threatened if an immediate response is not initiated.

Releases that may be incidental or an emergency depending on circumstances

  • Some releases are incidental in some cases and emergencies in others, depending on factors like the surroundings of the release and the equipment and personnel available to address it.

The properties of hazardous substances (such as toxicity, volatility, flammability, explosiveness, corrosiveness, etc.), as well as the circumstances of the release itself (such as quantity, confined space considerations, ventilation, etc.), have an impact on what employees can handle safely and what procedures should be followed.

Other factors may mitigate the hazards associated with a release and its remediation, such as:

  • The training or experience of the employees in the immediate work area,
  • The response and personal protective equipment (PPE) at hand, and
  • The pre-established standard operating procedures for response.

Some engineering control measures can also be activated to assist in controlling and stopping the release.

These considerations combine to define the distinction between incidental releases and releases that require an emergency response. The distinction is site-specific, and its impact is a function of the emergency response plan (ERP).

For example, a spill of the solvent toluene in a facility that manufactures toluene may not require an emergency response because of the advanced knowledge of the nearby personnel and the equipment available to absorb and clean up the spill. However, the same spill inside a furniture refinishing shop whose personnel have had only basic hazard communication training on toluene may require an emergency response by more highly trained personnel. The furniture shop’s ERP would call for evacuation for all but the most minor spills, but at the chemical facility, evacuation and emergency response would be necessary only for much larger spills.

A fuel spill from an overturned aircraft would likely be emergency response due to the significant and uncontrolled hazards posed by the aircraft and jet fuel. Personnel would be conducting operations such as firefighting, passenger rescue, and working to stop the release of jet fuel. However, a fuel spill from a tanker truck that can be absorbed, neutralized, or otherwise controlled by employees in the immediate release area using absorbent pads may qualify as an incidental release if there are no significant health or safety hazards. (Note: If the release of jet fuel is covered by 40 CFR 300, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP), an employer may be required by the Environmental Protection Agency (EPA) to follow the Hazardous Waste Operations and Emergency Response Standard.)

Releases that require emergency response regardless of circumstances

  • Some releases pose a large enough threat to health and safety that they automatically require an emergency response.
  • When planning emergency response, employers should use a reasonably predictable worst-case scenario.

Some releases of hazardous substances pose a sufficient threat to health and safety that they require an emergency response no matter what. An employer must determine the potential for an emergency in a reasonably predictable worst-case scenario and plan response procedures accordingly. These are “anticipated emergencies” as mentioned in the emergency response plan provision at subparagraph (q)(1) of 29 CFR 1910.120 and 1926.65.

Example situation: Motor carrier spill

A motor carrier transporting hazardous materials has an accidental release. The product cannot be contained by employees in the immediate vicinity or be cleaned up with absorbent. The motor carrier’s employees evacuate the area and call for outside help, as instructed by the employer. In this instance, if a spill of a hazardous substance occurs and an employer instructs all employees to evacuate the danger area, then the employer may not be required to train those employees under 1910.120.

However, the ability to decide whether a spill is an incidental spill or one requiring an emergency response requires training. Also, any employees who are expected to become actively involved in an emergency response due to a release of a hazardous substance are covered by 1910.120 and must be trained accordingly.

Note: The Occupational Safety and Health Administration (OSHA) has limited jurisdiction for over-the-road vehicle operation. The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard may not cover the vehicle operator in all circumstances involving spills while the material is on the vehicle or otherwise “in transportation.” An operator or any other employee who becomes actively involved in an emergency response then becomes an emergency responder and is covered by 1910.120(q).

Example situation: Ammonia release

OSHA says another example of a situation that would generally necessitate an emergency response is the release of anhydrous ammonia from a refrigeration unit. Employers must determine if there is a potential for release of ammonia in their facility that could result in an emergency situation. Anhydrous ammonia can produce severe health effects, depending upon the degree of exposure.

Example situation: Fire department call

Another situation that would likely require an emergency response is an emergency call to the fire department reporting a suspected release of a hazardous substance. The fire department should not knowingly dispatch a firefighter trained only under the Hazard Communication Standard or only to the “awareness level” to respond to a hazardous substance emergency.

For example, an emergency call involving the discovery of three 55-gallon drums on the side of a road that may be connected to a nearby methamphetamine laboratory would classify the situation as a potential emergency response requiring appropriately trained personnel.

Other emergency response examples

An emergency response includes, but is not limited to, the following situations:

  • The response comes from outside the immediate release area.
  • The release requires evacuation of employees in the area.
  • The release poses, or has the potential to pose, conditions that are immediately dangerous to life or health (IDLH).
  • The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit).
  • The release requires immediate attention because of imminent danger.
  • The release may cause high levels of exposure to toxic substances.
  • There is uncertainty about whether the employees in the work area can handle the severity of the hazard with the PPE and equipment that has been provided, and the exposure limit could easily be exceeded.
  • The situation is unclear, or data are lacking on important factors.

Procedures for emergency response

  • Spill prevention and planning can help keep spills and their impact to a minimum.
  • Best practices in preparing for an emergency release include establishing appropriate procedures, training workers, and assembling equipment such as PPE and spill kits.

Procedures help with consistency. They let employees know exactly what is expected of them so that each task is done the same way every time. Responding to an emergency release of hazardous substances is an intense operation, but procedures help to take the guesswork out of it.

Prevention and planning

Being conscientious and diligent about spill prevention can help keep spills to a minimum. In fact, the Occupational Safety and Health Administration (OSHA) considers prevention to be the most effective action employers and employees can take.

Best practices for preventing spills include:

  • Using appropriate containers to store hazardous substances;
  • Pre-deploying drain covers before loading or unloading hazardous substances located near drainage structures;
  • Providing overfill prevention for containers that store hazardous substances;
  • Keeping machinery and equipment that use hazardous substances in good working order;
  • Visually inspecting pipes and containers;
  • Avoiding storage of hazardous substances near wells or drains or where flooding is possible;
  • Providing dikes or other secondary containment;
  • Knowing the maximum capacity of containers to avoid overfilling them; and
  • Following manufacturers’ instructions for safe handling and storage.

Unfortunately, despite preventive measures, sometimes an emergency release does happen. Planning for an emergency release helps employees to prepare so they can take action with confidence, knowing what needs to be done.

Planning is exactly what the emergency response plan (ERP) is all about. The ERP must be kept up to date and must be written before anyone may take part in potential emergency response operations.

Another way to plan for an emergency release is to make sure all personal protective equipment (PPE) and clothing is clean, in good working condition, stored properly, and ready for use.

Having spill kits ready and stored close to areas where there is the most potential for an emergency release also helps with spill preparation. Spill kits contain equipment and supplies for use in the event of a release. These might include:

  • Acid and base neutralizers;
  • Signs, tags, labels, barricade tape, and writing equipment;
  • Environmental monitoring equipment;
  • Tools such as brooms, mops, shovels, scoops, scrapers, squeegees, flashlights, and wrenches;
  • Two-way radios, cell phone, phone numbers, or other communication equipment;
  • Absorbent towels, pads, or mats;
  • Loose sorbent materials like sand, vermiculite, or kitty litter; and
  • Patch and plug kits to stop leaks.

Employees can personally be prepared by:

  • Keeping all medical appointments for initial and annual exams (which are required as a responder on a hazardous materials response (HAZMAT) team);
  • Completing all required initial and refresher training; and
  • Getting their initial and annual respirator fit tests done, as scheduled by their employer.

Recognition, identification, and notification

  • The first step after a release is to determine whether it’s incidental (able to be addressed by workers in the area without significant health or safety risk) or emergency (requiring more dramatic measures).
  • Other steps include identifying the substance, notifying personnel in the area, and informing emergency response services and federal and state agencies as necessary.

If a release occurs, no one should rush in even if other personnel in the area appear to be injured or ill. Instead, it’s vital to take the time to identify what hazardous substance is involved (if possible) and make proper notifications that a release has happened, all the while staying clear of any vapors, fumes, smoke, and spills.

First, it must be identified whether the release is incidental or requires an emergency response:

  • Incidental release — An incidental release has occurred when the release of a hazardous substance can be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. It does not pose a significant threat to health and safety of employees in the area or to those cleaning it up and does not have the potential to become an emergency within a short period.
  • Emergency release — An emergency release has occurred when the release of a hazardous substance cannot be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. An emergency release does pose a significant threat to the health and safety of employees.

The following tools can be used to help figure out if any hazardous substances are involved in the release:

  • The location of the release,
  • The shapes and colors of containers,
  • Any markings and color codes, and
  • Human senses.

If it’s determined that an emergency release of a hazardous substance has occurred, the next step is to try to quickly identify, if possible, the hazardous substance or substances involved in the release. Tools available for identifying hazardous substances include:

  • Labels and markings,
  • Shipping papers,
  • Safety data sheets (SDSs),
  • Emergency Response Guidebook (ERG), and
  • Air monitoring and field survey instruments.

Whether or not the substance can be identified, the next step is to make notifications.

All personnel in the immediate vicinity must be made aware of the situation. Work activities should be stopped, and everyone should head for a safe location to hear the notification.

When emergency response personnel are notified about the emergency, the ERP is activated. At this time, specific information will need to be provided, including:

  • Location of the incident;
  • Time of occurrence;
  • A description of what happened;
  • Any injuries or fatalities;
  • Extent of the damage;
  • Actions taken; and
  • What response is needed from outside parties, such as fire department, ambulance, etc.

Both onsite and offsite personnel need to be notified. Directions for doing this should be included in the ERP.

For onsite notification, there may be an installed alarm system, sirens, bells, whistles, megaphones, dedicated radio frequencies, or a public address system.

Offsite notification will most often mean using a phone. All employees should be aware of how to contact local fire departments, police departments, ambulance services, and hospitals. Typically, this means dialing 911.

However, there may also be state and federal agencies that must be contacted. Information about who to call and where to find their phone numbers should be in the ERP.

Although notification activates the ERP, the release is not considered an emergency response operation until a trained emergency responder (who might be the employee handling the notification) gets involved or arrives at the scene.

Isolation and size up

  • An emergency release must be isolated and sized up, which includes assessing the event, casualties, possible further events, and available resources.

The area of the release needs to be isolated, which means to make sure everyone is a safe distance away from the release and out of harm’s way.

If the substance has been identified, the safety data sheet (SDS) or Emergency Response Guide (ERG) can be used to help figure out how far away from the release people should be. It’s necessary to stay upwind, uphill, and upstream from the release.

What happened?

The situation should be sized up by gathering and assessing all the information available, which will help in making well-informed decisions about how to handle the situation. Determining what happened is part of sizing up the situation. In addition, it’s necessary to assess whether there are any casualties, what could still happen, and what resources are available.

Questions to ask when trying to assess what happened include:

  • What was spilled?
  • What type of spill occurred?
  • What caused the spill?
  • What’s the extent of the spill and the damage?

Are there any casualties?

Casualties must be assessed to determine what type of medical help and how many medical resources will be needed. Questions to ask when assessing casualties include:

  • How many victims are there?
  • Where are they located?
  • What’s their condition?
  • What treatment is required?
  • Is anyone missing?

What could still happen?

A full assessment includes considering what could still happen. Questions to ask include:

  • What types of substances are nearby?
  • Could these substances react with the substance that was released?
  • What’s the potential for fire, explosion, or more spills?
  • Where are personnel relative to hazardous areas?
  • Is there any potential danger to the public or the environment?

What resources are available?

Finally, the available resources should be assessed. Questions to ask when considering resources include:

  • What medical resources are available for victim rescue, stabilization, and transport?
  • What resources are available for hazard mitigation, such as personal protective equipment (PPE), chemical protective clothing (CPC), field survey equipment, communication equipment, and other supplies and equipment?
  • How many trained responders are available?
  • What will be needed from offsite sources?
  • How long will it take for offsite resources to arrive?

Preparation for emergency response

  • Steps to prepare for emergency response include determining what hazards exist, allocating personnel and equipment, securing the scene, and making an action plan before moving forward.

Determine hazards

Now that notifications have been made, the area has been isolated, and the situation has been sized up, it’s time to determine what hazards and risk would be involved in rescue and response.

  • Are there IDLH (immediately dangerous to life or health) conditions?
  • How long would it take to perform control measures?
  • Would a self-contained breathing apparatus (SCBA) run out of air before the task can be accomplished?
  • Should responders rotate?
  • Is there enough lighting in the area?
  • Is there a lot of smoke?
  • Should responders use lifelines?

A crucial task here is to consider what could go wrong. The goal is to both get the release under control and rescue victims without causing injury or illness to the responders performing these tasks.

Allocate personnel and equipment

Personnel and equipment need to be assigned. All responders should know exactly which tasks they will be performing and verify all equipment and supplies needed are available, in good condition, and ready to go.

Secure the scene

To control access to the release area, three zones should be set up:

  • Exclusion Zone — The Exclusion Zone (EZ) is an area surrounding the release that is contaminated from the hazardous substance. This is also referred to as the “hot zone.”
  • Contamination Reduction Zone — The Contamination Reduction Zone (CRZ) is where decontamination occurs. It’s a transition area between the EZ and the clean area. A “hotline” separates the EZ from the CRZ.
  • Support Zone — The Support Zone is the clean area. No one should be exposed to any hazardous substances in this area. The command post is always located in the Support Zone. A contamination control line separates the CRZ from the Support Zone.

The zones would be decided quickly based on information such as the hazardous substance, size of the release, isolation distance, and weather conditions like wind speed and direction. An employee trained as an operations-level first responder or higher may set up the EZ.

Each zone is marked with a barrier and/or signs. Barriers could be structures already in place, like the walls of a building, or temporary barriers could be quickly constructed, like fences or stanchions and ropes.

Signs are posted around the perimeter of the zones, and guards can be used to patrol the perimeter.

Access to the EZ and CRZ is controlled using a checkpoint. Only authorized personnel — responders who have proper training and are dressed and equipped to handle the conditions — are allowed to enter areas through the checkpoint.

Records should be kept on everyone who passes through the checkpoint. Information to record includes:

  • Name,
  • Time of entry,
  • Anticipated exit time,
  • Zones being entered,
  • Name of team or “buddy,”
  • The task being performed and its location, and
  • Rescue and response equipment taken into the area.

Having security at access points to the EZ and CRZ will minimize potential contamination of workers, protect the public from a release, and prevent vandalism and theft. Unauthorized people will be prohibited from entering.

Note: Entry and exit from the EZ must be controlled by a first responder at the operations level or higher. An employee trained as an awareness-level first responder could assist in preventing unauthorized entry at the scene, as long as these activities are done at a safe remote location.

Make an action plan

Though it seems like many steps, all these tasks would be happening quickly. The last thing to do before actually taking action is to make an action plan. The response team should take a few minutes to assess all the information that has been gathered and make decisions about what actions to take.

As the response efforts unfold, this action plan should be checked. It may need to be revised based on new information.

Ground rules for emergency response

  • Emergency response relies on a chain of command, in which the most senior official onsite is responsible for controlling and directing all response activities, and the responsibility is passed to any official with a higher rank who arrives.
  • Steps for response are often done concurrently rather than consecutively.

Every emergency response to a hazardous substance release is unique, but certain ground rules will always be the same. These rules are required by the Occupational Safety and Health Administration’s (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard. They provide consistency and are in place to help keep employees, the public, and the environment safe.

Emergency response always uses the chain of command. The most senior official onsite is responsible for controlling and directing all response activities. As more response personnel arrive, the position is passed up to any new official with a higher rank.

Steps for response can be and usually are done simultaneously. They do not have to be completed one after another. What this means is some responders may be rescuing victims while other responders are trying to get the release under control.

Some more ground rules may include:

  • All responders must be wearing appropriate personal protective equipment (PPE) and chemical protective clothing (CPC) unless they are in the Support Zone.
  • All responders exposed to air contaminants at an unknown concentration or at a concentration that is IDLH (immediately dangerous to life or health) must wear a positive pressure self-contained breathing apparatus (SCBA) until air monitoring data indicate that exposure levels are safe enough for other types of respirators to be used.
  • The number of responders entering the Exclusion Zone (EZ) must be limited to only those who are performing tasks related to the emergency release.
  • The “buddy system” must always be used for any responders entering the EZ.
  • Backup and advanced first aid support personnel must be on standby with equipment and proper PPE and CPC.
  • The type of communication to be used must be established.
  • The conditions must be monitored continuously for any changes.
  • The action plan must be updated as conditions change.

In addition, a Safety Official must be designated. This official can alter, suspend, or terminate activities if imminent danger exists, such as IDLH conditions. The Safety Official must be knowledgeable in emergency response and is responsible for identifying and evaluating any hazards that are present.

Helping victims

  • Victims of emergency releases should be stabilized and removed from the area, and should be decontaminated before receiving medical treatment unless their condition is life-threatening.
  • It may be necessary to delay rescue until conditions pose less risk to the rescuers.

Emergency releases may cause fatalities, injuries, and illnesses. That means medical treatment of injured or ill victims may be required during an emergency response effort. It may also be necessary to locate victims who are missing and assess their condition.

All victims should be stabilized and removed from the area. Stabilizing a victim may require first aid measures. Whether victims are decontaminated before leaving the Contamination Reduction Zone (CRZ) will depend on their medical condition.

When medical conditions are life-threatening, medical treatment takes precedence over decontamination. Measures can be taken to minimize the spread of contamination that include ensuring medical personnel have personal protective equipment (PPE) and placing sheeting over the victim and in transport vehicles.

Rescue attempts should always be weighed against putting the rescuers in harm’s way. The harsh reality is that there may be times when conditions dictate that rescue has to wait until the threat of danger to rescuers has subsided.

Evacuating or sheltering in place

  • Conditions during emergency response may call for evacuating (moving people to a safe area) or sheltering in place (staying inside a building until the danger passes).

Depending on the conditions, it may be necessary to either evacuate personnel or have them shelter in place.

  • Evacuate — To move people from a place of danger to a safe area in an organized manner.
  • Shelter in place — To seek shelter inside a building and remain inside until the danger passes.

Employers should have two distinct signals in place, and personnel should be trained on both signals so they know what is expected of them when they notice a particular signal. Also, evacuation routes should be predetermined and addressed in the emergency response plan (ERP). All employees should be trained on where to go and the route to get there.

Sometimes it’s safer to shelter in place. An example would be if there are airborne contaminants that employees would have to travel through to evacuate. When sheltering in place, it may be necessary to close all windows and doors and turn off any ventilation, heating, or cooling systems to keep out contaminants.

Whether the situation calls for an evacuation or sheltering in place, there must be predetermined locations for each and a way to account for all personnel. This helps in identifying any personnel who did not get out to safety so a rescue can be planned.

If there is a safety threat to the public and a decision is made to either evacuate the public or have them stay inside and shelter in place, these activities are handled by government agencies like local fire and police departments. Communities may have public siren systems for alerting the public and use local television and radio stations to communicate the threat and what actions should be taken for safety.

Controlling the hazard

  • The three primary methods for addressing an emergency release are to control, contain, and confine it.
  • Control measures can be physical (such as patching a leak or diverting a flow) or chemical (such as burning, neutralizing, or converting a substance).

When addressing the hazards of an emergency release, an emergency responder has three potential methods:

  • Control it — Actions to control the emergency and limit exposure and damages include:
    • Shutting off a valve,
    • Diking a spill,
    • Covering floor drains and sewers, and
    • Improving ventilation.
  • Contain it — Containing a release might involve plugging or patching a leak to keep the remainder of the hazardous substance in its container.
  • Confine it — Actions to confine a hazardous release and keep it from flowing any further could include:
    • Using absorbents,
    • Diverting a spill,
    • Building a dam, or
    • Digging a trench.

Anyone tasked with controlling, containing, and/or confining a hazardous substance release should be very alert and cautious. It’s important for employees to be aware of:

  • The surroundings and any indication that conditions are changing;
  • How they’re feeling; and
  • How their work buddies are doing.

If any signs or symptoms of chemical exposure arise, it’s time to leave the area immediately. Once in a safe location, the next steps are to regroup, discuss the new information, and make changes to the action plan.

Advanced control measures

When taking control of an emergency release, responders typically use either physical or chemical approaches. A combination of physical and chemical approaches may be needed, depending on the situation. Factors to consider when deciding which approach(es) to use:

  • What the release substance is and its hazards;
  • The chemical properties of the substance, including whether it is in solid, liquid, or gaseous form;
  • Whether the substance is under pressure;
  • Whether the release is on land, in the air, or in water;
  • What natural or man-made barriers are already in place; and
  • Weather conditions, such as extreme heat and cold, wind speed and direction, and rain.

Before any approach is applied, it must be approved by the On-scene Incident Commander. No one should apply an approach unless trained to do so properly.

Some common physical approaches to taking control of a release include:

  • Plug and patch — Using plugs and patching material on leaks from containers due to small holes, rips, or cracks. If the bung (or stopper) of a drum is loose, simply tightening it with a non-sparking bung wrench may also seal the leak.
  • Damming or diking — Creating barriers to stop the flow of a spill. Some common materials to use are soil, sandbags, and concrete barricades.
  • Booming — Using a flexible, floating barrier on a water surface, where it can soak up floating contaminants. Booms are often used on oil spills in bodies of water.
  • Diversion — Placing an obstacle in the direct path of a flowing spill to divert it to a specific area where it is collected. Digging trenches or placing a boom to direct flow are two examples. Covering a drain diverts a spill too.
  • Sorbents — Placing sorbent materials (such as towels, kitty litter, sawdust, clay, or phenolic granules) either directly on a spill or in its pathway to absorb the spill. Sorbents are not recommended for volatile liquids, however. After use, sorbent materials must be disposed of properly.
  • Vapor dispersion — Spraying water at vapors to pull them from the air to the water. The contaminated water must then be collected and disposed of properly.
  • Vapor suppression — Applying a foam blanket or other agent over a substance to suppress the vapors.
  • Dilution — Diluting a substance with water to lower its concentration. This only works if the substance is water soluble and not water reactive.

Other physical approaches include, but are not limited to:

  • Shutting off a valve;
  • Rolling or tipping a leaking container so the hole is at the top;
  • Covering the release;
  • Rolling a leaking container into (or otherwise putting the container inside) a compatible overpack (oversized) container;
  • Transferring the substance to a different container that is compatible, bonded, and grounded;
  • Vacuuming the spill; and
  • Venting gas from a container to alleviate pressure.

The most common chemical approach to take control of a release is to disperse the contaminant, rather than removing it. Let’s say the insoluble part of an oil spill has been removed from a water body. The next step might be to apply emulsifiers to the spill area to help break up (or disperse) any remaining oil.

Other chemical approaches include, but are not limited to:

  • Burning or flaring the substance in a controlled manner;
  • Converting the release to a gel;
  • Converting the release to a solid;
  • Neutralizing the release; and
  • Using another chemical to react with the substance, changing it to a less hazardous substance.

Terminating the emergency response operation

Once the release is controlled, contained, and/or confined through physical and/or chemical approaches, as necessary, the senior official in charge of the emergency response operation will decide when to terminate the emergency response and move into post-emergency response efforts.

Procedures for post-emergency response

  • Post-emergency response, which happens after the immediate threat is stabilized, includes site cleanup, decontamination, and debriefing.

Post-emergency response means the portion of an emergency response that is performed after the immediate threat of a release has been stabilized or eliminated and cleanup of the site has begun. Post-emergency response procedures include cleanup of the area, decontaminating personnel and equipment, and other tasks.

Cleanup of the area

After the immediate threat is stabilized, the spill area needs to be cleaned up. Everyone who enters the spill area to perform cleanup activities must have proper training, such as emergency evacuation, respiratory protection, hazard communication (HazCom), and other appropriate safety and health training made necessary by the tasks they are expected to perform.

For instance, if contaminants were released outside, it’s possible the soil could be contaminated. Anyone entering the area to help extricate the soil would need proper training and personal protective equipment (PPE) to do so. Any equipment used in cleanup activities must be inspected prior to use and be in good working condition.

All contaminated sorbents or waste solids must be transferred to compatible waste containers and labeled appropriately. Hazardous waste labels may be required if the waste is considered hazardous.

Once all the sorbents or waste solids are cleaned up, the spill area can be decontaminated. The wash and rinse solutions used for this process should then be transferred to compatible waste containers and labeled appropriately. Again, hazardous waste labels may be required.

Decontaminating personnel and equipment

As personnel exit the spill area to the Contamination Reduction Zone (CRZ), they will have to be decontaminated along with any equipment, tools, and supplies they may have with them.

Anyone involved in the decontamination process must be dressed in PPE and chemical protective clothing (CPC) to a level that’s adequate to protect them from becoming contaminated. Decontamination workers must wear PPE at the same level or one level below that worn by the emergency responders they are supporting, as appropriate to the hazards.

Note: All decontamination station workers must themselves be decontaminated before entering the Support Zone.

A variety of decontamination methods can be used to remove or neutralize contaminants from each individual or item coming from the spill area. Items that cannot be decontaminated should be properly disposed of. Anyone decontaminating CPC should watch for items of clothing that may be showing signs of permeation. These items need to be checked more closely and possibly disposed of.

As a final step, the solvents and equipment used for decontamination will themselves be decontaminated or disposed of. All waste items including wastewater and solvents used in the decontamination process must be packaged, properly labeled, and removed from the area for disposal.

The employer must address specific procedures for decontamination in the emergency response plan (ERP), and different facilities’ procedures may vary, so any questions should be addressed by consulting the procedures for the organization.

Other post-emergency tasks

An emergency response effort does not end when the release is controlled, the area is cleaned up, and personnel and equipment are decontaminated. Other post-emergency procedures must be addressed.

Within 24 to 72 hours, the employer should hold a debriefing. This is when all responders gather to discuss the details of what happened. The information gathered during the debriefing is used to help write an incident report. Nothing said during a debriefing should be debated or argued, as the process is merely about sharing and gathering information.

Employers will also have a critique of the event. This is when the team tries to evaluate how the emergency response was handled. During a critique, everyone present should share their comments and suggestions. Some key questions that are helpful during a critique include:

  • What caused the emergency?
  • Was the situation preventable? If so, how?
  • Were procedures for prevention of the emergency adequate? If not, how can they be improved?
  • Were all phases of the response adequate? If not, how could it have been improved?
  • How did the incident affect the site?
  • Was public safety protected?

Based on the information from the critique, procedures and written plans (like the ERP) should be updated with any necessary improvements.

Documenting everything that happened during the response is very important. Other documentation from the incident might include incident logs, medical records, exposure records, and monitoring records.

Before normal activities may be resumed, the site must be fully equipped to handle another emergency. Any equipment that was damaged during the incident should be removed from service and either repaired or disposed of properly. Also, the employer must replenish any supplies that were depleted.

All waste generated during the emergency response must be disposed of properly. Some wastes may be considered “hazardous waste,” which is regulated by the Environmental Protection Agency (or EPA) or state environmental agency, requiring special disposal. That means someone at the organization will need to determine whether the waste from the spill is hazardous waste or not so it can be disposed of in the proper way.

Emergency action plan

  • An emergency action plan (required for sites at which employees evacuate rather than handle an emergency release) contains procedures for reporting the issue, evacuating the area, accounting for personnel after evacuation, and performing rescue or medical duties.

Any time a release is considered an emergency release, an emergency plan must be initiated. Any employer that has the potential for an emergency release must have either an emergency action plan (EAP) or an emergency response plan (ERP), depending on whether or not employees will handle the release.

An EAP is initiated when all employees must evacuate from the danger area if an emergency release occurs and no site employees are permitted to assist in handling the release itself. In this case, some outside contractor or local emergency personnel such as the fire department will handle the emergency release. The employer must coordinate with these outside entities prior to any emergency release.

If there are 10 or fewer employees onsite, an EAP can be communicated orally. Otherwise, the plan must be in writing and available for employees to review.

Employers with an EAP (whether written or not) are required to review it with each employee at initial hire and again if any changes are made to the plan or the employee’s responsibilities under the plan change.

An EAP must cover several elements:

  • Procedures for reporting a fire or other emergency,
  • Procedures for emergency evacuation including exit routes assigned,
  • Procedures for any employees who stay to operate critical operations prior to evacuating;
    • Note: Staying behind to operate critical operations prior to evacuating is an element of the EAP for emergencies in general, but when you take the EAP loophole under HAZWOPER, employees are not allowed to stay behind and perform critical operations in an “emergency release” situation. While employees may, for example, flip a switch on their way out, they must evacuate immediately during an emergency release event.
  • Procedures to account for all personnel after evacuation,
  • Procedures for employees performing rescue or medical duties, and
  • The name of a person employees can contact for more information about the plan.

Emergency response plan

  • The purpose of an emergency response plan is to allow everyone who will be involved in an emergency response to know their roles, tasks, and limitations before any emergencies occur.

An emergency response plan (ERP) is initiated when the employer has designated and trained one or more site employees to assist in handling an emergency release if one should occur. This written plan must be made available to all employees for inspection and copying.

An ERP is not required by the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard if employers elect to develop an emergency action plan (EAP) in accordance with 29 CFR 1910.38 and evacuate all employees in the case of an emergency release.

Further, if an employer has developed an Integrated Contingency Plan (ICP) according to the National Response Team’s (NRT) Integrated Contingency Plan Guidance, the Occupational Safety and Health Administration (OSHA) recognizes this type of document as demonstrating compliance with the requirements of 29 CFR 1910.120(q)(1), 1926.65(q)(1), 1910.38, and 1926.35. The ICP must still be carefully reviewed against HAZWOPER requirements, in the same manner as an ERP.

Purpose of the ERP

Those involved in an emergency response operation should know exactly what their role is, what tasks they are expected to perform, and what limitations need to be adhered to. Planning for such an unfortunate event can have a huge impact on controlling releases as quickly as possible, minimizing damage, lessening the risk of illness and injuries, and saving lives.

A written ERP must be developed and implemented before any employees are involved in responding to a hazardous substance release. The plan must cover reasonably anticipated worst-case scenarios. Employers that require employees to respond to emergencies must develop a written ERP that includes the following elements:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles, lines of authority, training, and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up; and
  • Personal protective equipment (PPE) and emergency equipment.

Employers may use the local or state ERP (including items addressed by Title III of the Superfund Amendments and Reauthorization Act of 1986, or SARA) as part of their site ERP if the required elements are covered.

Elements of the emergency response plan

  • Examples of information in the ERP include evacuation routes, decontamination procedures, personnel roles and training, safe distances, and emergency medical treatment and first aid.

The emergency response plan (ERP) is required to include several elements in order to provide a complete picture of the structure and function of the facility’s emergency response process.

Pre-emergency planning and coordination

When an emergency release occurs, any delays in action can cause life-threatening situations. Coordination with any outside parties listed in the plan must be pre-arranged. Employers can be cited if their ERP does not:

  • Reflect pre-emergency planning and coordination with outside parties;
  • Describe procedures or existing agreements addressing how outside parties will be notified of a potential emergency situation;
  • Address expected roles of outside parties in providing emergency response; or
  • Address existing factors, if any, that could delay or prevent outside parties from responding.

Personnel roles, lines of authority, training, and communication

Personnel roles must be clearly defined in the ERP. The ERP also lists the chain of command and lines of authority, including titles of key personnel and outside responders.

All personnel must know their roles for an emergency and have the required training. The employer must incorporate the provisions for employee training into the ERP. This might include a general outline of the training for each level of emergency responder, or just a reference to the location of the training manual. The plan should also address a schedule for required annual refresher training.

The ERP must clearly define the lines of communication so that employees encountering a release know who to report it to. The means of communication in an emergency must also be addressed. This might include radio frequencies, hand signals, siren blasts, light indicators, or any other system to alert personnel that an emergency response operation has begun.

Emergency recognition and prevention

The emergency recognition and prevention section of the ERP should include:

  • An inventory of the hazardous substances onsite,
  • How they are stored,
  • The consequences of an uncontrolled release, and
  • Scenarios or circumstances that would trigger emergency response for hazardous substances stored onsite.

Safe distances and places of refuge

This plan element should contain a map identifying safe places of refuge in each area where hazardous substance emergencies could occur. All employees would be accounted for in these areas, which is critical for identifying individuals who may need rescue.

Sometimes it’s safer to remain indoors than to evacuate. If an employer intends to use places of refuge as shelter-in-place areas, the ERP must include a shelter-in-place option, with a signal that is easily distinguishable from an evacuation signal, and personnel must be trained in the relevant procedures.

Site security and control

In an emergency release situation, the employer must control areas surrounding the danger area by prohibiting unauthorized personnel from entering. Methods for defining controlled areas are addressed in this ERP element. Emergency responses are coordinated from a command post a safe distance away from the emergency release area. The ERP addresses the setup and functions of this command post.

Personnel expected to set up boundaries designating safe and unsafe areas must be trained to the first responder operations level. (The first responder awareness level is not a sufficient level of training to set up safe distances because this level lacks knowledge on the potential for exposure, explosion, or radiation.)

Once these areas have been established, operations-level personnel must control entry and exit from the area of the release. Awareness-level personnel may assist in preventing unauthorized entry into the release area if they do so from a safe remote location.

Evacuation routes and procedures

This element of the ERP should identify how employees who are not part of the response operation will be notified to start evacuating, their evacuation routes, and where they should assemble so all personnel can be accounted for.

Decontamination

Decontamination procedures are also included in the ERP. These procedures must address decontaminating emergency responders leaving the Exclusion Zone (EZ). Personnel who assist in the decontamination process must wear personal protective equipment (PPE) at the same level or one level below the responders they are assisting.

If emergency responders are expected to decontaminate their own equipment or the EZ, then the ERP must include these procedures. Decontamination of response equipment left in the EZ and the contaminated area may be handled in the post-emergency response phase. Therefore, decontamination procedures for these areas and equipment do not necessarily need to be part of the ERP.

Emergency medical treatment and first aid

This element should identify all personnel with specialized training in Basic Life Support (BLS), their certifications, and the best way to contact them. These personnel must be no more than 3 to 4 minutes away. BLS refers to a unique group of trained individuals (e.g., emergency medical technicians, or EMTs) who have received an established level of specialized training that exceeds basic first aid skills. These personnel must be on standby, as per 29 CFR 1910.120(q)(3)(vi) or 1926.65(q)(3)(vi).

Emergency alerting and response procedures

This element of the plan should address procedures about how personnel will be informed of an emergency, including its type; how personnel should respond; and how they will be made aware of specific instructions, if necessary. The following information should be included, as applicable:

  • Notification — Making the existence of the emergency situation known;
  • Level and type of response — The required response based on the extent/type of emergency;
  • Nature of the response — The type of emergency condition (explosion, chemical spill, medical);
  • Location — The part of the facility affected (critically important in large facilities); and
  • Ambient conditions — Environmental factors, such as wind speed and direction, that may influence evacuation or response procedures.

If the emergency situation calls for special instructions, determine if the emergency alerting system indicates the location of the hazard, the direction employees should evacuate, what the hazard is, and any special PPE employees must don.

Critique of response and follow-up

The goal of this plan element is to improve the ERP after an incident. It sets procedures to analyze and evaluate how the incident was handled. Any new information and experiences from the emergency response operation are shared and used to update the ERP. This plan element also contains procedures for follow-up activities, such as restocking supplies and PPE.

PPE and emergency equipment

This element of the ERP includes a listing of PPE and emergency response equipment and materials, including their locations, their instructions for use, their limitations, and in what situations emergency responders will use them.

Local and state emergency response plans

Community emergency response agencies should be integral components of the community ERP. This ERP element should spell out specific roles and responsibilities for various organizations or agencies and indicate which function each will play in an emergency. The employer’s ERP may reference or include all or applicable sections of a local ERP or state ERP.

Incident Command System and the On-scene Incident Commander

  • An Incident Command System (ICS) designates one person as a central point of command to streamline communication and coordination.

During an emergency release, an Incident Command System (ICS) is used. An ICS is an organized approach required by the Occupational Safety and Health Administration (OSHA) to effectively control and manage operations at an emergency incident.

Regardless of the size or complexity of an incident, implementing an ICS designates one individual in charge who makes the decisions and gives directions. All actions and communications are coordinated through one central point of command. This system is intended to:

  • Reduce confusion,
  • Improve safety,
  • Organize and coordinate actions, and
  • Facilitate effective management of the incident.

The individual in charge of the ICS, known as the on-scene incident commander (IC), will be the senior official responding to the incident. This person is well trained in managing emergencies and is responsible for all aspects of the response.

The on-scene IC must demonstrate competence in a broad range of areas, including, but not limited to:

  • Making appropriate notifications,
  • Implementing the employer’s ICS,
  • Implementing the employer’s emergency response plan (ERP),
  • Selecting and using proper personal protective equipment (PPE),
  • Understanding the hazards and risks associated with chemical protective clothing (CPC),
  • Understanding the importance of decontamination procedures,
  • Implementing basic decontamination procedures,
  • Knowing how to implement the local ERP, and
  • Knowing about the state’s ERP.

During an emergency response effort, a typical command staff would include the following roles and responsibilities:

  • Information officer, whose role is to develop and release information about the incident to news media, incident personnel, and others;
  • Liaison officer, whose role is to assist in communicating and coordinating with other agencies;
  • Safety officer, whose role is to assess and mitigate health and safety hazards; and
  • General staff, who are designated for operations, planning, logistics, finance, and administrative aspects.

The organizational structure within the ICS uses the chain of command, which establishes lines of authority, responsibility, and communication.

Other emergency response personnel

  • Emergency response personnel, in ascending order of responsibility, include awareness-level first responders, operations-level first responders, hazardous materials technicians, and hazardous materials specialists.
  • Other personnel from the facility and from outside organizations and agencies (such as government and emergency services) may also be involved in emergency response.

Besides the on-scene incident commander and command staff, other people are needed to take care of an incident. That’s where emergency response personnel come in.

Roles and responsibilities in an emergency response effort can vary greatly depending on the amount of training each employee has received. All employees must know the requirements and limits of their duties in any emergency response effort. Anyone who takes actions beyond the limits of their work role may put people in harm’s way.

In addition to the incident commander, there are four additional main roles:

  • Awareness-level first responder
  • Operations-level first responder
  • Hazardous materials technician
  • Hazardous materials specialist

Awareness-level first responder

First responders at the awareness level are the individuals who witness or discover a hazardous substance release and initiate the emergency response by notifying the proper authorities. As the title indicates, their role is awareness rather than action — they do not do anything to stop or control the release.

An awareness-level first responder must be able to:

  • Recognize the presence of a hazardous substance in an emergency,
  • Know how to identify the substance,
  • Understand the risks associated with each incident,
  • Realize the need for additional resources, and
  • Make appropriate notifications.

Operations-level first responder

First responders at the operations level respond to protect nearby people, property, and the environment without trying to stop the release. Working from a safe distance, these responders take defensive action to keep the release from spreading and prevent exposures.

An operations-level first responder must be able to do what a first responder at the awareness level can do, and also:

  • Use basic techniques to assess hazards and risks;
  • Select and use proper personal protective equipment (PPE);
  • Perform basic control, confinement, and containment operations;
  • Implement basic decontamination procedures; and
  • Understand standard operating procedures and procedures to terminate a response effort.

Hazardous materials technician

Hazardous materials (hazmat) technicians are the individuals who work to stop the release. These responders take an aggressive role and approach the point of release.

A hazmat technician must be able to do what a first responder at the operations level can do, and also:

  • Implement the employer’s emergency response plan (ERP);
  • Classify and identify unknown materials using field survey equipment;
  • Understand basic chemical behavior;
  • Perform advanced control, containment, and confinement operations; and
  • Implement advanced decontamination procedures.

Hazardous materials specialist

Hazardous materials (hazmat) specialists are the individuals who support the technicians and demonstrate more specific knowledge of the substances to be contained.

A hazmat specialist must be able to do what a hazmat technician can do, and also:

  • Implement the local emergency response plan,
  • Classify and identify unknown materials using advanced survey equipment,
  • Know the state ERP,
  • Understand in-depth hazard and risk techniques, and
  • Develop a site safety and control plan.

Other personnel

In addition, there may be other roles involved in emergency response:

  • Backup personnel standing by with equipment ready to provide aid or rescue,
  • Advanced first aid support standing by with medical equipment and transportation,
  • Skilled support personnel like heavy equipment operators,
  • Specialist employees to provide technical advice regarding specific substances, and
  • Offsite personnel to provide further expertise and support.

An emergency release effort may involve working together with other organizations and agencies. These could include state and federal organizations along with fire, rescue, and police departments, to name a few.

HAZMAT team

  • A HAZMAT team consists, at a minimum, of two responders, a backup person wearing the same level of protection, and an on-scene incident commander.

The Occupational Safety and Health Administration (OSHA) uses the term “hazardous materials response (HAZMAT) team” to refer to an emergency response team. A HAZMAT team is:

  • An organized group of employees,
  • Designated by their employer,
  • Expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance, and
  • Tasked with responding for the purpose of controlling or stabilizing the incident.

A HAZMAT team is not a fire brigade, nor is a typical fire brigade a HAZMAT team. However, a HAZMAT team may be a separate component of a fire brigade or fire department.

One of the responsibilities of the incident commander is to limit the number of emergency responders who enter areas of exposure or potential exposure.

For a small incident, the minimum number of responders in a HAZMAT team is four. It consists of at least:

  • Two responders who enter the Exclusion Zone (EZ) using the buddy system,
  • One designated backup person standing by in a safe area and fully dressed in the same (or higher) level of personal protective equipment (PPE) and clothing as the responders who enter, and
  • An on-scene incident commander who is also the safety officer posted in the safe area.

However, OSHA recommends that at least two employees be designated as backup personnel, since the assistance needed may include rescue. That would mean a minimum of five HAZMAT team members.

Due to the nature of the hazards in an emergency release response, no one should enter an EZ without a buddy. Put another way, operations in hazardous areas must be performed in groups of two or more, using the buddy system.

Under the buddy system, all employees must be able to:

  • Provide their buddy with assistance;
  • Observe their buddy for signs of chemical, heat, or other exposure;
  • Periodically check the integrity of their buddy’s PPE and clothing; and
  • Notify others if help is needed.

Emergency response training

  • Employees who are expected to assist in an emergency response must receive appropriate and sufficient training in these duties, documented by the employer.
  • Training can’t occur only on video or via a computer program – interaction with a qualified trainer and site-specific procedures must be included.

The minutes immediately following a hazardous substance release are critical to ensuring everyone’s safety. That’s why the Occupational Safety and Health Administration (OSHA) requires emergency response training if employees are expected to assist in the handling of an actual or potentially uncontrolled release of a hazardous substance. The training level provided must be based on the functions and duties that responders will be expected to perform.

Trainer qualifications

Trainers who teach any of the above training subjects must either:

  • Have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy; or
  • Have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach.

Training format

According to OSHA, a video-only approach to train employees is not sufficient. However, videos can be used for part of the training if the employer can demonstrate that the employee has achieved sufficient knowledge and skills. For example, the employee would provide an instructor to respond to the employees’ questions after the video presentations and evaluate employee understanding of the material.

Similarly, computer-based training can serve as a valuable training tool in the context of an overall training program, but by itself, it is not sufficient to meet the training requirements.

Training under Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard includes site-specific elements and must be tailored to employees’ assigned duties, including hands-on training involving personal protective equipment (PPE) and other gear.

In fact, training for operations-level first responders (under paragraph (q)(6)(ii) of 29 CFR 1910.120 or 1926.65) and higher responder levels would require hands-on training and more interaction with the instructor.

Training certification

Under paragraph (q) of 29 CFR 1910.120 and 1926.65, employees need not necessarily receive a certificate, but the employer must certify training with some form of documentation. Note: The HAZWOPER Standard does not contain a specific certification requirement for awareness-level training.

It is considered good practice to provide employees with a training certificate as well as to document the training in the employer’s records. The employer also must document in its emergency response plan (ERP) its training plan for personnel who respond to hazardous substance incidents.

Initial and refresher training

  • Emergency responders must be trained in their roles and tasks, including yearly refresher training.
  • “Specialist employees” refers to employees from offsite who assist or counsel the HAZMAT team personnel, such as technical, medical, and environmental experts.

Emergency responders must be trained prior to their participation in emergency response operations, and their training must be based on the functions and duties they will be expected to perform. Consequently, employers must evaluate the roles and tasks that employees will perform and train them appropriately. For example:

  • If an employee is simply expected to notify the emergency response team upon discovery of an emergency release and evacuate from the area, the employee would be trained to the first responder awareness level.
  • If an employee is responding initially in a defensive manner for the purpose of protecting nearby persons, property, or the environment from the effects of the release, but does not approach the point of release, that employee would be trained to the first responder operations level.
  • If, however, the employee is expected to approach the point of release for the purpose of stopping the release, the employee would minimally need to be trained to the hazardous materials (hazmat) technician level.
  • If an employee is expected to have more direct and specific knowledge of the various hazardous substances and to assist the hazmat technician in the response, the employee would minimally need to be trained to the hazmat specialist level.
  • If the employee is expected to assume control of the incident scene, the employee would need training at the on-scene incident commander level.

In addition to the training levels established in the standard for emergency responders, two additional personnel classifications are provided:

  • Skilled support personnel (SSP) — These are employees who are needed to temporarily perform immediate emergency support work (e.g., excavator, crane, or tow truck operators). SSP must be provided with an initial site briefing that covers personal protective equipment (PPE) use, the chemical hazards involved, and the tasks to be performed.
  • Specialist employees — These are employees who, in the course of their regular job duties, work with and are trained in the hazards of specific hazardous substances. They may be called upon to provide technical advice or assistance at a hazardous substance release incident. This classification applies to employees from offsite who assist, counsel, or advise the on-scene incident commander or HAZMAT team. They provide technical assistance in operations such as servicing specific valves on a storage tank or a tank car, or in similarly skilled areas, in addition to offering advice. They could also include medical or environmental experts. Specialist employees may not enter the danger area unless they are fully trained in the use of the required PPE and are accompanied by a hazmat technician or hazmat specialist.

HAZWOPER emergency response training provisions

Emergency response training provisions under paragraph (q) of 29 CFR 1910.120 or 1926.65 are summarized in the table:

Trainee typeBrief descriptionRequired initial and refresher trainingRegulation
First responder awareness levelWitnesses or discovers a release of hazardous substances and is trained to notify the proper authorities
  • Sufficient initial training and competencies
  • Annual refresher
Subparagraphs (q)(6)(i) and (q)(8) of 1910.120 or 1926.65
First responder operations levelResponds to releases of hazardous substances in a defensive manner, without trying to stop the release
  • 8 hours initial training and competencies
  • Annual refresher
Subparagraphs (q)(6)(ii) and (q)(8) of 1910.120 or 1926.65
Hazardous materials technicianResponds aggressively to stop a release of hazardous substances
  • 24 hours initial training and competencies
  • Annual refresher
Subparagraphs (q)(6)(iii) and (q)(8) of 1910.120 or 1926.65
Hazardous materials specialistResponds with and in support of hazmat technicians, but who have specific knowledge of various hazardous substances
  • 24 hours initial training and competencies
  • Annual refresher
Subparagraphs (q)(6)(iv) and (q)(8) of 1910.120 or 1926.65
On-scene incident commanderAssumes control of the incident scene beyond the first responder awareness level
  • 24 hours initial training and competencies
  • Annual refresher
Subparagraphs (q)(6)(v) and (q)(8) of 1910.120 or 1926.65
Skilled support personnelTemporarily performs immediate emergency support work
  • Safety and health briefing at response site
Subparagraph (q)(4) of 1910.120 or 1926.65
Specialist employeesProvides technical advice/assistance on specific hazardous substances
  • Annual demonstration of specialized competencies
Subparagraph (q)(5) of 1910.120 or 1926.65

Table note: The training hours in the standard are minimums. HAZWOPER training programs often will exceed the 8- or 24-hour minimums in order to include all of the required subjects.

Employees who must receive training as required by subparagraph (q)(6) of 1910.120 or 1926.65 must also receive refresher training or demonstrate competency at least annually. Refresher training is required because employees must stay up to date in their skills and knowledge.

The Occupational Safety and Health Administration’s (OSHA) intent is that employees should complete their refresher training within 12 months of their initial training. However, sometimes courses are missed due to unavoidable circumstances. In such an event, employees should take the next available refresher training course, with a record added to their personnel files indicating why the training has been delayed and when the training will be completed.

If an employee has gone without refresher training for more than 12 months, the employer must evaluate whether the initial comprehensive training needs to be repeated. The need to repeat initial training must be determined based on the employee’s familiarity with safety and health procedures and potential hazards.

Refresher training may be given in segments throughout the year as long as the required training is completed by the employee’s anniversary date. Time spent by emergency response employees reviewing incidents can also be credited toward their refresher training requirements.

Finally, the employer must have a “statement of training” or “statement of competency” for annual refresher training or competency for all employees trained in emergency response.

For more in-depth information on emergency response training, see section XI.E. to XI.I. in OSHA’s directive CPL 02-02-073, Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases.

Post-emergency response training

  • Personnel involved in post-emergency response training must be trained in the procedures for doing so.
  • Post-emergency response can happen concurrently with emergency response if the site is large enough or if an additional release occurs after emergency response is completed.

Upon completion of the emergency response, if it is determined that it is necessary to remove hazardous substances, health hazards, and materials contaminated with them (such as contaminated soil or other elements of the natural environment) from the site of the incident, the employer conducting the cleanup must comply with one of the following:

  • All of the requirements of paragraphs (b) through (o) of 29 CFR 1910.120 or 1926.65; or
  • If the cleanup is done on plant property using plant or workplace employees, the employees must have completed the training requirements of 29 CFR 1910.38, 1910.134, and 1910.1200, as well as other safety and health training made necessary by their assigned tasks.

All equipment used in cleanup work must be in serviceable condition and inspected prior to use.

Post-emergency response begins when the individual in charge of the initial emergency response declares the site to be under control and ready for cleanup. As long as an emergency response team is still in control of the site and a significant safety or health hazard exists, an emergency classification continues to be in effect.

For example, if a vacuum truck arrives to remove spilled gasoline while an emergency response team is managing the activity, the vacuum truck operator’s activity is part of the emergency response operations. Once the incident commander has declared the response activity over or finished, and the immediate threat has been stabilized, any remaining cleanup is considered a post-emergency operation.

It is worth noting that:

  • In a large release, emergency response and post-emergency response activities may occur simultaneously, as in a marine oil spill. The on-scene incident commander (IC) must be careful to define the boundaries between the emergency response area and the post-emergency response cleanup area in this scenario. (See Inspection Guidelines for Post-Emergency Response Operations Under 1910.120, CPL 02-02-051.)
  • The IC must convey information on all remaining site hazards to employees who are involved in the cleanup operations for post-emergency response. The individuals who will take control of the site to perform the post-emergency response cleanup must in turn contact the IC to determine if there are any remaining hazards or any special conditions on the site.
  • If the IC feels that the post-emergency response cleanup crews are not sufficiently trained or prepared to perform their duties, the IC may notify the employer or the Occupational Safety and Health Administration (OSHA).

Contract personnel assigned full-time at a plant facility are considered “plant or workplace employees” for the purposes of subparagraph (q)(11)(ii) of 1910.120 or 1926.65 when they are conducting cleanup in areas where they routinely work. However, contractors brought in specifically for cleanup operations are covered by subparagraph (q)(11)(i) of 1910.120 or 1926.65.

What about emergency response during a post-emergency response?

If an additional emergency release of a hazardous substance occurs during a post-emergency response cleanup, the Hazardous Waste Operations and Emergency Response (HAZWOPER) emergency response provision that applies would depend upon who is handling the cleanup, who will be responding, and whether the cleanup is done on plant property:

  • If the emergency is responded to by an outside response team or responders, paragraph (q) of 1910.120 or 1926.65 would apply.
  • Employees who work at a hazardous waste cleanup site or a Resource Conservation and Recovery Act of 1976 (RCRA) corrective action and are trained in accordance with subparagraph (e)(7) of 1910.120 or 1926.65 may respond to emergencies at that site.
  • The contractor hired for the cleanup procedure may respond to emergencies during the cleanup if the contractor’s employees who are involved in the cleanup are trained in accordance with subparagraph (e)(7) and paragraph (l) of 1910.120 and 1926.65.

Note that if the site is inspected by OSHA, the agency inspector conducting an inspection will:

  • Use observation and information from the IC to determine the status of operations and whether the IC is continuing emergency response operations or if the IC has declared emergency response activities completed and shifted to post-emergency response cleanup.
  • Determine whether there are areas of the site still under emergency response operations.
  • Determine whether post-emergency response operations are being performed by site employees consistent with subparagraph (q)(11)(ii) or by offsite or outside personnel consistent with subparagraph (q)(11)(i).

Communication during emergencies

  • Both internal and external communication are crucial in an emergency response.
  • A public information officer should be designated to be the sole point of contact with the media.

Effective communication is another important aspect of an emergency response effort. Onsite and offsite personnel must be able to quickly and accurately pass along information, such as the location of an injured person, evacuation orders, or notice of a blocked evacuation route. In an emergency, both internal and external communication are extremely important.

Internal communication

Internal emergency communication systems are used to:

  • Alert team members about emergencies,
  • Convey safety information,
  • Communicate changes in work tasks, and
  • Maintain site control.

The employer must have some means of notifying all personnel when the Emergency Response Plan (ERP) is activated. This could be an installed alarm system, sirens, bells, whistles, megaphones, dedicated radio frequencies, or a public address system.

Prior to an emergency, all personnel need to be made aware of what the signal or announcement will be and how they are expected to respond to it. This information will be found in the written ERP.

Telephones, cell phones, handheld radios, and walkie-talkies are often used for communication between employees.

Communication devices used in a potentially explosive atmosphere must be intrinsically safe and not capable of sparking. They should be checked daily to ensure they are operating correctly. All personnel should know where to locate any communication devices or phone numbers they may need to use during an emergency.

Several nonverbal or non-auditory forms of communication can be used to initiate a response as well as to communicate during a response effort. These include flares, flags, lights, signal boards, smoke signals, and other forms of visual communication.

In addition, responders who enter the hazardous area can wear different colors of protective clothing or have their names written on their outer clothing as a means of identification from a distance.

While wearing personal protective equipment (PPE), communication can be very difficult, so hand and body signals may help to communicate effectively. It’s important the signals be agreed upon in advance and communicated to all involved. Some common examples of hand and body signals are:

  • Clutching hands to the throat to mean “I’m out of air” or “I can’t breathe,”
  • Placing hands on top of the head to mean “I need assistance,”
  • Thumbs up to mean “Everything is all right,” and
  • Gripping one’s buddy by both hands or around the waist to mean “Let’s leave the area immediately.”

External communication

External communication systems keep onsite and offsite personnel connected. Procedures for external communications should be clear and accessible always. This type of communication is used to:

  • Coordinate emergency responses,
  • Report updates to management, and
  • Maintain contact with offsite personnel.

The telephone or cell phone is the most common way of communicating with state and federal officials and agencies. Anyone who is expected to contact any officials or agencies should be aware of where the phone numbers are listed so they can make contact quickly and efficiently.

All employees should know how to contact local fire departments, police departments, ambulance services, and hospitals. Typically, this means dialing 911.

In the event an emergency release could (or will) affect the public, typically offsite sources must be contacted to get assistance to inform the public about the emergency situation. The facility and the community may also use public siren systems, local television and radio stations, or mobile apps to communicate with the public.

As with any emergency event, an emergency release may draw the attention of news media. When communicating with the media, typically, there should be just one point of contact, the employer’s public information officer, who relays information to the news media and the public concerning site activities as necessary. This person, who is a part of the command staff, is expected to provide factual information, not opinions or predictions.

The designated public information officer should be sure to review the employer’s procedures on acceptable forms of communication. The incident commander should approve any media releases prior to their posting.

As a best practice, no one except the public information officer should give out any information about an emergency release response or post information on social media.

Medical surveillance and consultation

  • Due to the number and severity of health hazards at an emergency response operation, employers are required to offer medical surveillance and consultation to certain employees.

Exposure to hazardous substances may pose health hazards. It’s possible to be exposed to a hazardous substance and not even be aware of it because some substances are odorless and colorless. There could be no indication of their presence until the effects of exposure begin. In addition, the effects from some substances might not show up right away.

Exposures to hazardous substances are not the only health hazard risk at an emergency response operation. Other potential health hazards include, but are not limited to:

  • Heat stress
  • Cold exposure
  • Biological hazards
  • Ionizing radiation
  • Oxygen deficiency
  • Noise

With so many health hazards, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 1910.120(q)(9) and 1926.65(q)(9) requires employers to offer medical surveillance and consultation to certain emergency responders. It’s important to look at the medical surveillance and consultation provisions separately.

Medical surveillance

Medical surveillance is the analysis of health information to look for problems that may be occurring at work that require targeted prevention. Thus, surveillance serves as a feedback loop to the employer. The purpose is to detect and eliminate the underlying causes, such as hazards or exposures, of any discovered trends.

Surveillance may be based on a single case or sentinel event, but more typically surveillance uses screening results from the group of employees being evaluated to look for abnormal trends in health status. Surveillance can also be conducted on a single employee over time.

Subparagraph (q)(9)(i) of 1910.120 and 1926.65 requires that members of an organized and designated hazardous materials response (HAZMAT) team and hazardous materials (hazmat) specialists receive a baseline physical examination and medical surveillance in accordance with paragraph (f) of those regulations. A HAZMAT team refers to a group of individuals who are expected to control actual or potential leaks or spills of hazardous substances requiring close approach to the substance.

Employers are obligated to make medical surveillance available to HAZMAT team members and hazmat specialists at no cost. Examinations must be provided prior to initial assignment, at least yearly thereafter, and at termination of employment. Medical examinations must also be provided in cases where employees are injured or develop signs or symptoms of overexposure to health hazards.

The actual content of these medical examinations (e.g., laboratory tests, chest x-rays, spirometry, etc.) is determined by the attending physician. Chapter 5 of the publication Occupational Safety and Health Guidance Manual for Hazardous Waste Sites provides guidelines for designing a medical program.

The medical examination must include a medical and work history (or updated history if one is in the employee’s file) with an emphasis on the following:

  • Symptoms related to the handling of hazardous substances and health hazards.
  • Fitness for duty and the ability of the employee to wear any required personal protective equipment (PPE) including respiratory protection under the expected conditions at the worksite (e.g., temperature extremes).

While subparagraph (f)(3) of 1910.120 and 1926.65 requires the employer to “make medical examinations available” at no cost, the standard does not require the employee to take the medical examination.

However, subparagraph (q)(9)(i) of 1910.120 and 1926.65 provides that members of an organized and designated HAZMAT team and HAZMAT specialists “shall receive” a baseline examination and be provided with medical surveillance as set forth in 1910.120(f). As a result, in order for an individual to qualify as a member of an organized HAZMAT team or a hazmat specialist, the individual must undergo medical examination as set forth in paragraph (f).

Also, if an individual chooses not to have a medical exam or participate in a medical surveillance program, the employer should note this refusal in the employee’s personnel file.

Consultation

The employer must also provide medical consultation to any emergency responder (not limited to HAZMAT team members and hazmat specialists) who becomes injured or ill or develops signs or symptoms due to exposure to hazardous substances from an emergency response. Consultations must be provided as soon as possible following the incident and also at additional times if the physician determines it’s necessary. Similar to examinations, the content of consultations is determined by the attending physician.

Personal protective equipment and chemical protective clothing

  • PPE and CPC must be selected to be appropriate for the nature, degree, and extent of the hazards wearers may encounter.

Personal protective equipment (PPE) must be selected and used with the intent to protect employees from hazards and potential hazards. In addition, chemical protective clothing (CPC) and chemical protective equipment (such as PPE) used by hazardous materials response (HAZMAT) team members and hazardous materials specialists must meet the requirements contained in subparagraphs (g)(3) to (g)(5) of 1910.120 and 1926.65, which cover PPE selection criteria, protocols for testing totally encapsulating chemical protective suits, and PPE programs.

Refer to the Personal protective equipment and clothing section for more about subparagraphs (g)(3) and (g)(5).

Notes:

  • Personnel engaged in emergency response and exposed to hazardous substances that present an inhalation or potential inhalation hazard must comply with paragraph (q)(3)(iv) for respirator selection criteria. Whereas, subparagraphs (g)(3) to (g)(5) refer to other types of PPE and CPC.
  • In situations where the type of hazard is fire beyond the incipient stage, or thermal energy, then subparagraph (q)(3)(iii) of 1910.120 or 1926.65 must be followed. When the type of chemical and its concentration are “totally unknown” or “somewhat known,” the appropriate protective clothing and other equipment selected must be based on experience, judgment, and professional knowledge.
  • Determining the nature, degree, and extent of the hazards may be done by taking air measurements with monitoring equipment for toxic concentrations of vapors, particulates, explosive potential, and the possibility of radiation exposure. Also, visual observation, existing data (including safety data sheets, or SDSs), and past experience can help determine the potential risks of exposure.

Related records

  • Records related to HAZWOPER that must be kept include training records, medical and medical-related records, and an emergency response plan or emergency action plan.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard is intended to provide a framework for employers to implement so that they can protect their employees from hazards during hazardous waste cleanup, treatment, storage, and disposal, as well as hazardous substance emergency response operations.

Training records

As part of that protection, initial and annual refresher training must be certified. The Occupational Safety and Health Administration (OSHA) advises employers to keep training certification records for a minimum of five years after the date of training. In the case of hazardous waste cleanup sites, if the employer can show by documentation or certification that an employee's work experience and/or training has resulted in training equivalent to what’s required, then initial training is waived.

Medical and medical-related records

Certain employees must receive medical exams based on the criteria in the HAZWOPER Standard’s medical surveillance program. Under 29 CFR 1910.120(f)(8), 1926.65(f)(8), and 1910.1020, the following must be retained for at least the duration of employment plus 30 years:

  • Employee medical complaints,
  • Physician’s opinions,
  • Recommended limitations,
  • Medical test results, and
  • Copies of any information sent to the physician.

Written plans

Depending on site operations, the employer may need a HAZWOPER safety and health program and/or one of the following two plans — an emergency response plan or emergency action plan. An employer may use an emergency action plan in lieu of an emergency response plan only if all employees will be evacuated during an emergency release incident rather than responding to it.

Site characterization records

While the HAZWOPER Standard does not specifically mention documenting the site characterization and analysis under paragraph (c), the variety of required information that must be gathered lends itself to keeping a record of it. Moreover, OSHA directive CPL 02-02-071 states that OSHA inspectors should review documentation of the site characterization and analysis, implying that this documentation should exist.

Other records

Beyond the HAZWOPER Standard, the employer may be required to keep records under other related federal, state, or local laws and regulations. Examples include:

  • Permits, written plans and procedures, policies, and operating procedures;
  • Inspection, maintenance, testing, and repair records;
  • Hazard assessments and analyses/certifications;
  • Monitoring and sampling records;
  • Respiratory protection records and fit test results;
  • Medical records, exposure records, and injury/illness logs;
  • Incident reports and other agency-required reports and notifications;
  • Chemical inventories and safety data sheets;
  • Fire brigade organizational statements and written procedures;
  • Laboratory-related records;
  • Hazardous waste records and reports;
  • Shipping papers and manifests; and
  • Training records.

Examples of written programs include those for benzene, lead, asbestos, heat stress, process safety management (PSM), permit-required confined space, and lockout/tagout.

Note that 29 CFR 1910.1020 requires that exposure records be preserved and maintained for at least 30 years.

Related laws and regulations

  • When HAZWOPER and another OSHA standard both apply, the more protective standard dominates.
  • Many other OSHA regulations, as well as regulations and standards from other agencies, may pertain to hazardous waste cleanup, hazardous waste treatment/storage/disposal, or emergency response operations.

Paragraphs 29 CFR 1910.120(a)(2)(i) and 1926.65(a)(2)(i) state, “All requirements of part 1910 and part 1926 of title 29 of the Code of Federal Regulations apply pursuant to their terms to hazardous waste and emergency response operations whether covered by this section or not. If there is a conflict or overlap, the provision more protective of employee safety and health shall apply without regard to 29 CFR 1910.5(c)(1) [and 29 CFR 1926.20(e)].”

Put another way, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard does not completely supersede any other Occupational Safety and Health Administration (OSHA) standard. HAZWOPER supersedes provisions of another standard only where HAZWOPER is more protective.

For example, OSHA can cite the provisions of one of two standards, the Benzene Standard and the HAZWOPER Standard, depending on which provision offers more protection. The Benzene Standard provides specific requirements for exposure monitoring and medical surveillance that are more protective than those in HAZWOPER. In situations where an employer's monitoring or medical surveillance program is inadequate on a hazardous waste site where benzene is present, the Benzene Standard applies over HAZWOPER.

Other OSHA regulations that may pertain to hazardous waste cleanup operations; hazardous waste treatment, storage, and disposal operations; or emergency response operations include, but are not limited to, the:

  • Walking-Working Surfaces Standards,
  • Emergency Action Plans and Fire Prevention Plans Standards,
  • Occupational Noise Exposure Standards,
  • Flammable Liquids Standards,
  • Process Safety Management Standard,
  • Personal Protective Equipment (PPE) Standards,
  • Permit-Required Confined Spaces Standards,
  • Fire Protection Standards,
  • Control of Hazardous Energy Standards,
  • Hand and Portable Powered Tools Standards,
  • Electrical Standards,
  • Employee Exposure and Medical Record Standard,
  • Bloodborne Pathogens Standard,
  • Ionizing Radiation Standard,
  • Hazard Communication Standard,
  • Toxic and Hazardous Substances Standards,
  • Laboratory Standard,
  • Excavation Standard, and
  • Demolition Standards.

Where an OSHA regulation does not exist to protect employees from a hazard, such as heat stress or heavy lifting, the General Duty Clause may apply. This provision is found in section 5(a)(1) of the Occupational Safety and Health Act (or OSH Act). It says: “Each employer shall furnish to each of his employees employment and a place of employment which is free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”

That means an employer is obligated to protect employees from recognized hazards, even if there’s not an OSHA regulation that applies to the situation.

In addition to OSHA protections, regulations established by other agencies may also pertain to hazardous waste cleanup operations; hazardous waste treatment, storage, and disposal operations; or emergency response operations, including, but not limited to, those from:

  • The Environmental Protection Agency (EPA),
  • The Department of Transportation (DOT),
  • The Department of Energy (DOE),
  • The Nuclear Regulatory Commission (NRC),
  • The U.S. Coast Guard, and
  • State- and local-level agencies.

While not regulations, it should be noted that the National Fire Protection Association (NFPA) has developed and published hundreds of consensus standards on protection from fire and other risks, including hazardous materials incidents/emergencies and chemical/biological terrorism incidents. Some of these consensus standards may be adopted by current state and local laws and codes.

State requirements and important references

  • Other resources for HAZWOPER compliance include state requirements and additional OSHA and EPA regulations.
  • Additional references to consult for further information are listed below.

State requirements

While the core federal regulation is found at 29 CFR 1910.120, each state may manage Hazardous Waste Operations and Emergency Response (HAZWOPER) protections differently. Employers should check the information for their state to determine if additional requirements apply to their operations. Click the following link for state information.

Notes

Covered employers should note that:

  • There are many other Occupational Safety and Health Administration (OSHA) regulations that can be interrelated with HAZWOPER.
  • The Environmental Protection Agency’s (EPA) Worker Protection Standard at 40 CFR 311 adopts 1910.120 for state and local government employees engaged in hazardous waste operations. (A hazardous waste operation means any operation conducted within the scope of 29 CFR 1910.120.)
  • Construction follows the HAZWOPER Standard at 29 CFR 1926.65, which is identical to 1910.120, except for its references to other regulations. (OSHA 1910.120 typically references Part 1910 standards; whereas, 1926.65 typically references Part 1926 standards.)

Important references

The following references may be consulted for further information on HAZWOPER:

  • “Compliance guidelines,” Appendix C to 1910.120.
  • EM Health and Safety Plan Guidelines, Department of Energy (DOE) Standard DOE-STD-5503-94 – 12/1994.
  • Emergency Response Guidebook, U.S. Department of Transportation (DOT) publication every four years.
  • “General description and discussion of the levels of protection and protective gear,” Appendix B to 1910.120.
  • Hazardous Waste Operations and Emergency Response, Occupational Safety and Health Administration (OSHA) publication OSHA 3114-07R 2008 – 7/2008.
  • “Hazardous Waste Operations and Emergency Response (HAZWOPER),” OSHA webpage topic.
  • Hazardous Waste Sites and Hazardous Substance Emergencies, National Institute for Occupational Safety and Health (NIOSH) Worker Bulletin, NIOSH publication no. 83-100 – 12/1982.
  • “Inspection Guidelines for Post-Emergency Response Operations Under 1910.120,” OSHA directive CPL 02-02-051 – 11/5/1990.
  • “Inspection Procedures for 29 CFR 1910.120 and 1926.65, Paragraph (q): Emergency Response to Hazardous Substance Releases,” OSHA directive CPL 02-02-073 – 8/27/2007.
  • Hazardous Materials/Weapons of Mass Destruction Response Personnel Handbook, Seventh Edition, National Fire Protection Association (NFPA) publication (copyright 2017).
  • Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, NIOSH/OSHA/U.S. Coast Guard (USCG)/Environmental Protection Agency (EPA) publication 85-115 – 10/1985.
  • Best Practices for Protecting EMS Responders during Treatment and Transport of Victims of Hazardous Substance Releases, OSHA publication OSHA 3370-11 2009 – 11/2009.
  • Recommended Practice for Responding to Hazardous Materials Incidents, NFPA 471.
  • “References,” Appendix D to 1910.120.
  • Safety and Health Awareness for Oil Spill Cleanup Workers, National Institute of Environmental Health Sciences (NIEHS) and OSHA publication OSHA 3388-062010 – 6/2010.
  • Standard for Competencies for EMS Personnel Responding to Hazardous Materials Incidents, NFPA 473.
  • Standard for Professional Competence of Responders to Hazardous Materials Incidents, NFPA 472.
  • Standard Operating Safety Guides, EPA Office of Emergency and Remedial Response publication 9285.1-03 – 6/1992.
  • “Technical Enforcement and Assistance Guidelines for Hazardous Waste Site and RCRA Corrective Action Clean-up Operations,” OSHA directive CPL 02-02-071 – 11/5/2003.
  • “Training curriculum guidelines,” non-mandatory Appendix E to 1910.120.

Key definitions

  • Several key definitions are relevant to understanding and complying with the HAZWOPER Standard.

Although the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard has been around for several decades, it continues to confuse employers. The standard defines 20 terms in its definitions section at paragraph (a)(3) of 29 CFR 1910.120 for general industry and 29 CFR 1926.65 for construction. In addition, Occupational Safety and Health Administration (OSHA) directives CPL 02-02-071 and 02-02-073 define 75 related terms.

The use of these words and phrases may make the regulation a challenge for employers to understand. Some definitions and clarification are provided below.

Buddy system: A system of organizing employees into work groups so that each employee of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy system is to provide rapid assistance to employees in the event of an emergency.

Cleanup operation: An operation in which hazardous substances are removed, contained, incinerated, neutralized, stabilized, cleared up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or the environment.

Decontamination: The removal of hazardous substances from employees and their equipment to the extent necessary to preclude the occurrence of foreseeable adverse health effects.

Emergency response or responding to emergencies: A response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.) to an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area or by maintenance personnel are not considered to be emergency responses within the scope of this standard. 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.

Appendix A to 29 CFR 1910.120 and 1926.65 provides further guidance on this term.

Facility: This term is divided into two types:

(A) Any building, structure, installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly owned treatment works), well, pit, pond, lagoon, impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft; or

(B) Any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise comes to be located. This definition does not include any consumer product in consumer use or any water-borne vessel.

Hazardous materials response (HAZMAT) team: An organized group of employees, designated by the employer, who are expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close approach to the substance. The team members perform responses to releases or potential releases of hazardous substances for the purpose of controlling or stabilizing the incident. A HAZMAT team is not a fire brigade, nor is a typical fire brigade a HAZMAT team. A HAZMAT team, however, may be a separate component of a fire brigade or fire department.

Hazardous substance: Any substance designated or listed under paragraphs (A) through (D) of this definition, exposure to which results or may result in adverse effects on the health or safety of employees:

(A) Any substance defined under section 103(14) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (see 42 U.S.C. 9601(14)).

(B) Any biological agent or other disease-causing agent that, after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction), or physical deformations in such persons or their offspring;

(C) Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR 172.101 and appendices; and

(D) Hazardous waste as defined below.

The term “hazardous substance” as defined by 1910.120 and 1926.65 should not be confused with the definition of “hazardous chemical” in 29 CFR 1910.1200, Hazard Communication.

Hazardous waste: This term is divided into two types:

(A) A waste or combination of wastes as defined in 40 CFR 261.3, or

(B) Those substances defined as hazardous wastes in 49 CFR 171.8. Hazardous waste operation. Any operation conducted within the scope 1910.120 or 1926.65.

Hazardous waste site: Any facility or location within the scope of 1910.120 or 1926.65 at which hazardous waste operations take place.

Health hazard: This term includes two types:

(A) A chemical or a pathogen where acute or chronic health effects may occur in exposed employees, or

(B) Stress due to temperature extremes.

The term “health hazard” includes chemicals that are classified in accordance with the Hazard Communication Standard, 1910.1200, as posing one of the following hazardous effects: acute toxicity (any route of exposure), skin corrosion or irritation, serious eye damage or eye irritation, respiratory or skin sensitization, germ cell mutagenicity, carcinogenicity, reproductive toxicity, specific target organ toxicity (single or repeated exposure), aspiration toxicity, or asphyxiation.

See 1910.1200 Appendix A — Health Hazard Criteria (Mandatory) — for the criteria for determining whether a chemical is classified as a health hazard.

IDLH or Immediately dangerous to life or health: An atmospheric concentration of any toxic, corrosive, or asphyxiant substance that:

(A) Poses an immediate threat to life,

(B) Would cause irreversible or delayed adverse health effects, or

(C) Would interfere with an individual’s ability to escape from a dangerous atmosphere.

Post-emergency response: That portion of an emergency response performed after the immediate threat of a release has been stabilized or eliminated and cleanup of the site has begun. If response is performed by an employer’s own employees who were part of the initial emergency response, it is considered to be part of the initial response and not post-emergency response. However, if a group of an employer’s own employees, separate from the group providing initial response, performs the cleanup operation, then the separate group of employees would be considered to be performing post-emergency response and subject to 1910.120(q)(11) for general industry or 29 CFR 1926.65(q)(11) for construction.

Small quantity generator: This term must meet two criteria:

(A) Any person, by site, whose act or process produces hazardous waste identified or listed in 40 CFR 261 or whose act first causes a hazardous waste to become subject to EPA regulation; and

(B) This person, by site, generates in any calendar month no more than 1,000 kilograms (2,205 pounds) of hazardous waste in that month.

Uncontrolled hazardous waste site: An area identified as an uncontrolled hazardous waste site by a governmental body, whether federal, state, local, or other, where an accumulation of hazardous substances creates a threat to the health and safety of individuals or the environment or both.

Some sites are found on public lands, such as those created by former municipal, county, or state landfills, where illegal or poorly managed waste disposal has taken place. Other sites are found on private property, often belonging to generators or former generators of hazardous substance wastes. Examples of such sites include, but are not limited to, surface impoundments, landfills, dumps, and tank or drum farms.

Normal operations at hazardous waste treatment, storage, and disposal (TSD) sites are not covered by this definition

Historical background

  • Love Canal and Valley of the Drums disasters led to a series of laws, one of which required OSHA to promulgate regulations to protect employees in hazardous waste operations. Those regulations became the HAZWOPER Standard we know today.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard was not the Occupational Safety and Health Administration’s (OSHA) idea. The regulation itself was actually mandated by a law signed by President Reagan in 1986. To understand the HAZWOPER Standard, it may help to know the history behind the regulation and how the regulation came about.

In the past, massive quantities of hazardous waste were stored or disposed of in poor conditions at unsafe locations. Many of these “dump sites” were abandoned and presented potential danger to human health and/or the environment. In the 1970s, lawmakers and the public started to realize that improperly treated, stored, or discarded hazardous waste was a serious problem.

Two environmental disasters got the public’s attention:

  • Love Canal in Niagara Falls, New York — Large amounts of abandoned, buried hazardous waste caused extensive contamination of the area, declaration of the area as a disaster by the federal government, and eventual relocation of most area residents. While the disaster came to a head in the 1970s, its history started in the late 1800s. For further information, see the Love Canal information in the CERCLA, SARA, EPCRA topic.
  • Valley of the Drums in Louisville, Kentucky — Once investigations and cleanup began, over 100,000 drums were discovered on the property. Many of the drums were in poor condition and leaking into the soil and the waters of Wilson Creek, a tributary of the Ohio River. Around 140 different chemical compounds were found on the land, and it took years to clean up the site. For further information, see the Valley of the Drums information in the CERCLA, SARA, EPCRA topic.

Because of the seriousness of the problem, Congress enacted legislation to control it:

  • Resource Conservation and Recovery Act of 1976 (RCRA) — This law established a regulatory system to manage hazardous wastes from the time they are generated to their final disposal.
  • Comprehensive Environmental Resource, Compensation, and Liability Act of 1980 (CERCLA) —This law gave the government authority to deal with threats from hazardous waste sites to human health and the environment. It forced responsible parties to pay for the cleanup of abandoned hazardous waste sites and take action to respond to emergencies involving uncontrolled releases of hazardous substances.
  • Superfund Amendments and Reauthorization Act of 1986 (SARA) — This law made several changes to CERCLA, increased communities’ awareness of extremely hazardous chemicals located near them, and helped communities develop emergency response plans.

It turns out that the treatment and disposal of hazardous wastes under RCRA and CERCLA created a significant risk to the safety and health of employees who worked in cleanup, treatment, storage, disposal, and emergency response operations. This risk was addressed by SARA, which specifically required OSHA to issue a regulation for the health and safety of employees engaged in hazardous waste operations. This regulation became the HAZWOPER Standard, found at:

  • OSHA 29 CFR 1910.120, HAZWOPER Standard for general industry;
  • OSHA 29 CFR 1926.65, HAZWOPER Standard for construction; and
  • EPA 40 CFR 311, Worker Protection Standard for state and municipal workers not protected by OSHA or an OSHA-approved state agency.

Note that a “hazardous waste operation” means any operation conducted within the scope of the HAZWOPER Standard.

Scope and applicability

  • The HAZWOPER Standard covers hazardous waste cleanup operations; operations involving hazardous wastes at treatment, storage, and disposal facilities; and emergency responses involving release or threatened release of hazardous substances.

The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 29 CFR 1910.120 and 1926.65 covers three primary categories of work operations, any one or more of which may apply to a single employer.

General scope and applicability criteria

According to 1910.120(a)(1) for general industry and 1926.65(a)(1) for construction, the HAZWOPER regulations cover the following operations, unless the employer can demonstrate that the operation does not involve employee exposure or a reasonable possibility of employee exposure to safety or health hazards:

  • Hazardous waste cleanup operations;
  • Operations involving hazardous wastes that are conducted at treatment, storage, and disposal (TSD) facilities; and
  • Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.

In addition, 40 CFR 311 says, “The substantive provisions found at 29 CFR 1910.120 ... apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” Because the term “hazardous waste operation” means any operation conducted within the scope of 1910.120, state and local government employers must protect their employees who are engaged in any of the bulleted operations above if those employers are not covered by a state-plan state approved by the Occupational Safety and Health Administration (OSHA).

Covered hazardous waste cleanup operations

  • The HAZWOPER Standard applies to three types of hazardous waste cleanup operations.

The general category of hazardous waste cleanup operations is divided into three very specific groups in the scope of 29 CFR 1910.120(a)(1) and 1926.65(a)(1):

  • Cleanup operations required by a federal, state, local, or other governmental body involving hazardous substances that are conducted at uncontrolled hazardous waste sites. These sites include, but are not limited to:
    • The Environmental Protection Agency’s (EPA) National Priority Site List (NPL),
    • State priority site lists,
    • Sites recommended for the EPA NPL, and
    • Initial investigations of government-identified sites that are conducted before the presence or absence of hazardous substances has been ascertained.
  • Corrective actions involving cleanup operations at sites covered by the Resource Conservation and Recovery Act (RCRA) of 1976 as amended (42 U.S.C. 6901 et seq.).
  • Voluntary cleanup operations at sites recognized by federal, state, local, or other governmental bodies as uncontrolled hazardous waste sites.

All of these operations must comply with paragraphs (b) through (o) of 1910.120 and/or 1926.65.

Refer to the Definitions section to learn the meanings of the terms cleanup operation, hazardous waste site, and uncontrolled hazardous waste site.

Covered hazardous waste treatment, storage, and disposal operations

Hazardous waste treatment, storage, and disposal (TSD) facilities are those facilities regulated by 40 CFR 264, 40 CFR 265, or agencies under agreement with EPA to implement the Resource Conservation and Recovery Act (RCRA) regulations. Operations involving hazardous wastes conducted at these RCRA-permitted TSD facilities must also comply with paragraph (p) of 29 CFR 1910.120 and/or 1926.65.

What about hazardous waste generators?

In addition, the HAZWOPER Standard covers small and large quantity hazardous waste generators with the following characteristics:

  • They qualify for permitting exemptions under 40 CFR 264, 265, and 270, and
  • They are required by EPA or a state agency to have their employees engage in emergency response for hazardous waste storage areas, or they otherwise direct their employees to do so.

Instead of falling under the balance of paragraph (p), these operations are only required to meet paragraph (p)(8) of 1910.120 and/or 1926.65. As another option, compliance with the requirements of paragraph (q) of 1910.120 and/or 1926.65 is considered to be in compliance with the requirements of paragraph (p)(8).

EPA does not require very small quantity hazardous waste generators to have their employees engage in emergency response. Therefore, unless the state agency requires emergency response from the employees, this generator type does not need to worry about paragraph (p)(8).

The Notes and Exceptions in subparagraph (a)(2)(iii) of 1910.120 and/or 1926.65 provide further information regarding hazardous waste generators.

Covered emergency response operations

  • Under HAZWOPER, emergency response primarily involves employees or other responders from outside the immediate area of the hazardous substance release.
  • Incidental hazardous substance releases that are controlled or neutralized by employees in the area or that don’t pose any hazards do not count as emergency response operations.

Emergency response operations for releases of, or substantial threats of releases of, hazardous substances must comply with paragraph (q) of 29 CFR 1910.120 and/or 1926.65. The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard defines the term “emergency response or responding to emergencies” as follows: “A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance ...”

Responders from outside the immediate release area

The HAZWOPER Standard, at 1910.120(q) and 1926.65(q), uses the term “responders” generally to refer to employees who respond to emergencies.

The standard covers responses “by other designated responders.” Under the language of the standard, responders are a separate group, different from employees outside the immediate release area who are directed to respond to the emergency by the employer.

Emergency responders include employees who are working in the immediate release area (not just outsiders) if the employer designates them as such. For example, a release of chlorine gas above the “immediately dangerous to life and health” (IDLH) level, obscuring visibility and moving through a facility, is an emergency situation even if the initial responders are from the immediate release area. Employees who would respond to this situation, whether they work in the immediate area or come from outside, would need to act in accordance with 1910.120(q).

Employees are not barred from responding to releases in the immediate release area that would otherwise require outside assistance from a trained HAZMAT team, even though the definition of an emergency response states that an emergency response is “a response effort by employees from outside the immediate release area.”

Conversely, incidental releases of hazardous substances that are routinely cleaned up by employees from outside the immediate release area need not be considered emergency responses solely because those responsible for cleanup come from outside the immediate release area.

For example, paint thinner is spilled in an art studio, and the janitor is called from outside the immediate release area to mop it up. The janitor does not have to respond in accordance with 1910.120 and 1926.65. (The janitor would, however, be expected to understand the hazards associated with paint thinner through training under 29 CFR 1910.1200, Hazard Communication.)

What the term “emergency response” does not include

To clarify the definition of the term, the Occupational Safety and Health Administration (OSHA) explains that an “emergency response” does not include responses to:

  • Incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel.
  • Releases of hazardous substances where there is no potential safety or health hazard such as fire, explosion, or chemical exposure.

Exemption for no employee exposure to hazards

  • Employers can claim exemption from HAZWOPER if they can demonstrate that their employees won’t be exposed to hazards.

When determining applicability, employers should consider if they have an exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard.

The HAZWOPER Standard at 29 CFR 1910.120 and 1926.65 covers several listed operations unless the employer can demonstrate that the operation does not involve “employee exposure or the reasonable possibility for employee exposure to safety or health hazards.” Therefore, it is important to understand how to determine whether an exemption from the standard is met.

Employers must consider all routes of entry (inhalation, ingestion, and skin absorption) without regard to the use of personal protective equipment (PPE) when evaluating employee exposure or the reasonable possibility of employee exposure to safety or health hazards. The exposure or potential exposure must also be associated with a hazardous substance from the listed operations.

Safety hazards from a hazardous substance could include fire, explosion, corrosive action, etc., from flammable, corrosive, or otherwise hazardous substances associated with the site. Health hazards from a hazardous substance could include cancer or organ function impairment from toxic, carcinogenic, or infectious material associated with the site. The term “health hazard” is further defined at 1910.120(a)(3) and 1926.65(a)(3).

Safety hazards from sources not specifically associated with the hazardous substances at the site (e.g., trenching; moving machinery; and slips, trips, and falls) do not by themselves require coverage under HAZWOPER. Employees are considered “exposed” when they encounter any amount of a hazardous substance in the work environment that could cause them harm.

Exemptions related to releases

  • If all employees would be evacuated rather than help respond to an emergency release, employers may create an emergency action plan that includes the evacuation procedure in lieu of complying with the emergency response provisions.
  • Incidental releases are those that don’t pose a significant danger to the employees working in the area or cleaning up the substance. Incidental releases are not covered by the HAZWOPER Standard.

When determining applicability, employers should consider if they have a partial exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, as it relates to releases.

Emergency action plan exemption

Employers who will evacuate all employees from the danger area, and who will not permit any employees to assist in handling the emergency, have the option of creating a written emergency action plan (EAP) in accordance with 29 CFR 1910.38 or 1926.35 in lieu of an emergency response plan (ERP) and the other provisions of paragraph (q) of 1910.120 or 1926.65. Employers with 10 or fewer employees can communicate the EAP orally rather than maintaining a written plan.

When used to meet the requirements of HAZWOPER, 29 CFR 1910.38 and 1926.35 require employers to also have an effective alarm system to alert employees to an emergency, evacuate all employees, and notify an emergency response team, such as a fire department that is trained in accordance with HAZWOPER.

Employers who will train some of their employees to respond to an emergency release must create an ERP. The ERP must include an EAP for the evacuation of all employees in the area who are not essential for emergency response.

Incidental release exemption

One of the operations that falls under the HAZWOPER Standard is the emergency response operation for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. However, responding to incidental spills and releases is not considered an “emergency response.”

An understanding of the distinction between an incidental release of a hazardous substance and a release that requires an emergency response is fundamental to proper compliance with the provisions of the standard.

The definition of the term “incidental release” is found at 1910.120(a)(3) and 1926.65(a)(3) within the definition of “emergency response or responding to emergencies,” where it says, “Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.”

An incidental release is a release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employees cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up. An incidental spill poses an insignificant threat to health or safety and may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.

On the flip side, an emergency release is defined as an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance that requires a response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.). Emergency releases of hazardous substances pose a sufficient threat to health and safety that, by their very nature, require an emergency response regardless of the circumstances surrounding the release or the mitigating factors.

An emergency response includes, but is not limited to, the following situations:

  • The response comes from outside the immediate release area.
  • The release requires evacuation of employees in the area.
  • The release poses, or has the potential to pose, conditions that are immediately dangerous to life or health (IDLH).
  • The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit).
  • The release requires immediate attention because of imminent danger.
  • The release may cause high levels of exposure to toxic substances.
  • There is uncertainty about whether the employees in the work area can handle the severity of the hazard with the personal protective equipment (PPE) and other equipment that has been provided, and the exposure limit could easily be exceeded.
  • The situation is unclear, or data are lacking on important factors.

The quantity of a substance spilled does not by itself determine if an incidental spill or emergency release has occurred. The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, and corrosiveness, as well as the circumstances of the release itself, such as quantity, confined space considerations, and ventilation, will have an impact on what employees can handle safely and what procedures should be followed.

Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and PPE at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.

These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental spills and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.

Covered hazardous waste cleanup operations

  • The HAZWOPER Standard applies to three types of hazardous waste cleanup operations.

The general category of hazardous waste cleanup operations is divided into three very specific groups in the scope of 29 CFR 1910.120(a)(1) and 1926.65(a)(1):

  • Cleanup operations required by a federal, state, local, or other governmental body involving hazardous substances that are conducted at uncontrolled hazardous waste sites. These sites include, but are not limited to:
    • The Environmental Protection Agency’s (EPA) National Priority Site List (NPL),
    • State priority site lists,
    • Sites recommended for the EPA NPL, and
    • Initial investigations of government-identified sites that are conducted before the presence or absence of hazardous substances has been ascertained.
  • Corrective actions involving cleanup operations at sites covered by the Resource Conservation and Recovery Act (RCRA) of 1976 as amended (42 U.S.C. 6901 et seq.).
  • Voluntary cleanup operations at sites recognized by federal, state, local, or other governmental bodies as uncontrolled hazardous waste sites.

All of these operations must comply with paragraphs (b) through (o) of 1910.120 and/or 1926.65.

Refer to the Definitions section to learn the meanings of the terms cleanup operation, hazardous waste site, and uncontrolled hazardous waste site.

Covered hazardous waste treatment, storage, and disposal operations

Hazardous waste treatment, storage, and disposal (TSD) facilities are those facilities regulated by 40 CFR 264, 40 CFR 265, or agencies under agreement with EPA to implement the Resource Conservation and Recovery Act (RCRA) regulations. Operations involving hazardous wastes conducted at these RCRA-permitted TSD facilities must also comply with paragraph (p) of 29 CFR 1910.120 and/or 1926.65.

What about hazardous waste generators?

In addition, the HAZWOPER Standard covers small and large quantity hazardous waste generators with the following characteristics:

  • They qualify for permitting exemptions under 40 CFR 264, 265, and 270, and
  • They are required by EPA or a state agency to have their employees engage in emergency response for hazardous waste storage areas, or they otherwise direct their employees to do so.

Instead of falling under the balance of paragraph (p), these operations are only required to meet paragraph (p)(8) of 1910.120 and/or 1926.65. As another option, compliance with the requirements of paragraph (q) of 1910.120 and/or 1926.65 is considered to be in compliance with the requirements of paragraph (p)(8).

EPA does not require very small quantity hazardous waste generators to have their employees engage in emergency response. Therefore, unless the state agency requires emergency response from the employees, this generator type does not need to worry about paragraph (p)(8).

The Notes and Exceptions in subparagraph (a)(2)(iii) of 1910.120 and/or 1926.65 provide further information regarding hazardous waste generators.

Covered emergency response operations

  • Under HAZWOPER, emergency response primarily involves employees or other responders from outside the immediate area of the hazardous substance release.
  • Incidental hazardous substance releases that are controlled or neutralized by employees in the area or that don’t pose any hazards do not count as emergency response operations.

Emergency response operations for releases of, or substantial threats of releases of, hazardous substances must comply with paragraph (q) of 29 CFR 1910.120 and/or 1926.65. The Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard defines the term “emergency response or responding to emergencies” as follows: “A response effort by employees from outside the immediate release area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release of a hazardous substance ...”

Responders from outside the immediate release area

The HAZWOPER Standard, at 1910.120(q) and 1926.65(q), uses the term “responders” generally to refer to employees who respond to emergencies.

The standard covers responses “by other designated responders.” Under the language of the standard, responders are a separate group, different from employees outside the immediate release area who are directed to respond to the emergency by the employer.

Emergency responders include employees who are working in the immediate release area (not just outsiders) if the employer designates them as such. For example, a release of chlorine gas above the “immediately dangerous to life and health” (IDLH) level, obscuring visibility and moving through a facility, is an emergency situation even if the initial responders are from the immediate release area. Employees who would respond to this situation, whether they work in the immediate area or come from outside, would need to act in accordance with 1910.120(q).

Employees are not barred from responding to releases in the immediate release area that would otherwise require outside assistance from a trained HAZMAT team, even though the definition of an emergency response states that an emergency response is “a response effort by employees from outside the immediate release area.”

Conversely, incidental releases of hazardous substances that are routinely cleaned up by employees from outside the immediate release area need not be considered emergency responses solely because those responsible for cleanup come from outside the immediate release area.

For example, paint thinner is spilled in an art studio, and the janitor is called from outside the immediate release area to mop it up. The janitor does not have to respond in accordance with 1910.120 and 1926.65. (The janitor would, however, be expected to understand the hazards associated with paint thinner through training under 29 CFR 1910.1200, Hazard Communication.)

What the term “emergency response” does not include

To clarify the definition of the term, the Occupational Safety and Health Administration (OSHA) explains that an “emergency response” does not include responses to:

  • Incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel.
  • Releases of hazardous substances where there is no potential safety or health hazard such as fire, explosion, or chemical exposure.

Exemption for no employee exposure to hazards

  • Employers can claim exemption from HAZWOPER if they can demonstrate that their employees won’t be exposed to hazards.

When determining applicability, employers should consider if they have an exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard.

The HAZWOPER Standard at 29 CFR 1910.120 and 1926.65 covers several listed operations unless the employer can demonstrate that the operation does not involve “employee exposure or the reasonable possibility for employee exposure to safety or health hazards.” Therefore, it is important to understand how to determine whether an exemption from the standard is met.

Employers must consider all routes of entry (inhalation, ingestion, and skin absorption) without regard to the use of personal protective equipment (PPE) when evaluating employee exposure or the reasonable possibility of employee exposure to safety or health hazards. The exposure or potential exposure must also be associated with a hazardous substance from the listed operations.

Safety hazards from a hazardous substance could include fire, explosion, corrosive action, etc., from flammable, corrosive, or otherwise hazardous substances associated with the site. Health hazards from a hazardous substance could include cancer or organ function impairment from toxic, carcinogenic, or infectious material associated with the site. The term “health hazard” is further defined at 1910.120(a)(3) and 1926.65(a)(3).

Safety hazards from sources not specifically associated with the hazardous substances at the site (e.g., trenching; moving machinery; and slips, trips, and falls) do not by themselves require coverage under HAZWOPER. Employees are considered “exposed” when they encounter any amount of a hazardous substance in the work environment that could cause them harm.

Exemptions related to releases

  • If all employees would be evacuated rather than help respond to an emergency release, employers may create an emergency action plan that includes the evacuation procedure in lieu of complying with the emergency response provisions.
  • Incidental releases are those that don’t pose a significant danger to the employees working in the area or cleaning up the substance. Incidental releases are not covered by the HAZWOPER Standard.

When determining applicability, employers should consider if they have a partial exemption from the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, as it relates to releases.

Emergency action plan exemption

Employers who will evacuate all employees from the danger area, and who will not permit any employees to assist in handling the emergency, have the option of creating a written emergency action plan (EAP) in accordance with 29 CFR 1910.38 or 1926.35 in lieu of an emergency response plan (ERP) and the other provisions of paragraph (q) of 1910.120 or 1926.65. Employers with 10 or fewer employees can communicate the EAP orally rather than maintaining a written plan.

When used to meet the requirements of HAZWOPER, 29 CFR 1910.38 and 1926.35 require employers to also have an effective alarm system to alert employees to an emergency, evacuate all employees, and notify an emergency response team, such as a fire department that is trained in accordance with HAZWOPER.

Employers who will train some of their employees to respond to an emergency release must create an ERP. The ERP must include an EAP for the evacuation of all employees in the area who are not essential for emergency response.

Incidental release exemption

One of the operations that falls under the HAZWOPER Standard is the emergency response operation for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard. However, responding to incidental spills and releases is not considered an “emergency response.”

An understanding of the distinction between an incidental release of a hazardous substance and a release that requires an emergency response is fundamental to proper compliance with the provisions of the standard.

The definition of the term “incidental release” is found at 1910.120(a)(3) and 1926.65(a)(3) within the definition of “emergency response or responding to emergencies,” where it says, “Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.”

An incidental release is a release of a hazardous substance that does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employees cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up. An incidental spill poses an insignificant threat to health or safety and may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.

On the flip side, an emergency release is defined as an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance that requires a response effort by employees from outside the immediate release area or by other designated responders (e.g., mutual-aid groups, local fire departments, etc.). Emergency releases of hazardous substances pose a sufficient threat to health and safety that, by their very nature, require an emergency response regardless of the circumstances surrounding the release or the mitigating factors.

An emergency response includes, but is not limited to, the following situations:

  • The response comes from outside the immediate release area.
  • The release requires evacuation of employees in the area.
  • The release poses, or has the potential to pose, conditions that are immediately dangerous to life or health (IDLH).
  • The release poses a serious threat of fire or explosion (exceeds or has the potential to exceed the lower explosive limit or lower flammable limit).
  • The release requires immediate attention because of imminent danger.
  • The release may cause high levels of exposure to toxic substances.
  • There is uncertainty about whether the employees in the work area can handle the severity of the hazard with the personal protective equipment (PPE) and other equipment that has been provided, and the exposure limit could easily be exceeded.
  • The situation is unclear, or data are lacking on important factors.

The quantity of a substance spilled does not by itself determine if an incidental spill or emergency release has occurred. The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, and corrosiveness, as well as the circumstances of the release itself, such as quantity, confined space considerations, and ventilation, will have an impact on what employees can handle safely and what procedures should be followed.

Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and PPE at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.

These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental spills and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.

Special issues

A few issues relating to the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard need particular attention. Knowledge of these special issues is essential to fully understanding HAZWOPER.

Certain industry or employer types

  • Whether an employer is in the construction, shipyard, marine terminal, longshoring, or healthcare industry poses special issues relating to HAZWOPER.
  • EPA adopted 1910.120 in 40 CFR 311 for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan.

Construction

Hazardous waste operations and emergency response for construction sites are covered by 29 CFR 1926.65 (a standard identical to 29 CFR 1910.120, except for its references to other Occupational Safety and Health Administration, or OSHA, regulations). Work for construction, alteration, and/or repair, including painting and decorating, is considered “construction work” according to 29 CFR 1910.12 and must comply with the Construction Safety and Health Regulations within 29 CFR 1926.

For construction, all requirements of Part 1926 apply pursuant to their terms to hazardous waste and emergency response operations, whether covered by 1926.65 or not. If there is a conflict or overlap between 1926.65 and another Part 1926 regulation, the provision more protective of employee safety and health applies.

Shipyards, marine terminals, and longshoring

OSHA directive CPL 02-02-073 states, “HAZWOPER is also applicable to shipyard work under [Part] 1915.”

Employers are required under 29 CFR 1917.30 and 1918.100 to develop and implement emergency action plans to ensure employee safety from fires and other emergencies. However, if employees are directed by their employer to respond to an emergency beyond the scope of an emergency action plan, then paragraph (q) of 1910.120 applies (see footnotes at bottom of 1917.30 and 1918.100).

Healthcare

First receivers include hospital-based staff (e.g., triage, decontamination, medical treatment, and security) that receive and treat contaminated victims from mass casualty incidents. These personnel are removed from the site of the emergency and the point of release and do not need to be trained — or equipped — for control, containment, or confinement operations, as is required for a HAZMAT team.

First receivers are still considered to be part of an emergency response and are required to wear appropriate personal protective equipment (PPE) and be provided effective training based on the duties and functions to be performed.

State and local government employees

The Environmental Protection Agency (EPA) adopted 1910.120 in 40 CFR 311 (Federal Register June 23, 1989) for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan is in place, and, therefore, there is no OSHA coverage for state and local government employees.

Part 311 says, “The substantive provisions found at 29 CFR 1910.120 … apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” The term “hazardous waste operation” means any operation conducted within the scope of 1910.120.

EPA specifically includes “non-compensated workers” (i.e., volunteer workers) who work for governmental agencies engaged in emergency response, such as volunteer firefighters. Therefore, volunteers who will take part in operations involving hazardous substances must be trained in accordance with the applicable sections of 1910.120.

Radioactive or infectious materials

  • Radioactive waste and infectious materials can both fall under the HAZWOPER Standard, depending on the circumstances.

Radioactive waste

The term “hazardous substance” as defined by 29 CFR 1910.120 includes radioactive waste in addition to hazardous waste. It should not be confused with the definition of “hazardous chemical” in 29 CFR 1910.1200, Hazard Communication, which specifically excludes any radioactive chemicals.

The U.S. Nuclear Regulatory Commission (NRC) has jurisdiction “inside the fence” at NRC-licensed nuclear facilities for the risks involved with licensed radioactive materials, including emergency response procedures. The Occupational Safety and Health Administration (OSHA) has jurisdiction “inside the fence” for non-licensed radioactive materials, such as x-ray equipment, accelerators, some electron microscopes, and some naturally occurring radioactive materials (see the memo of understanding between OSHA and the NRC that delineates employee protection responsibilities for each agency at facilities licensed by the NRC, effective October 21, 1988).

There may be both NRC and OSHA jurisdiction when there is an emergency involving mixed wastes (licensed radioactive materials and other hazardous substances) “inside the fence.” HAZWOPER may also be applicable “outside the fence” to emergency response and cleanup activities involving hazardous substances, including licensed radioactive wastes.

Infectious materials

Employers must include infectious materials in their effort to comply with 1910.120(q) if there is a possibility that a release could cause an emergency. Employers with employees engaged in emergency response activities involving infectious materials must comply with the requirements in 1910.120(q) and may also have to comply with the Bloodborne Pathogens Standard, 29 CFR 1910.1030. If there is a conflict or overlap between the standards, the provision that is more protective of employee safety and health applies.

Terrorist events and acts of nature

  • Terrorist events themselves are not covered under the HAZWOPER Standard because they are not considered foreseeable workplace emergencies, but any emergency response to a hazardous substance release does fall under the standard.
  • Acts of nature fall under HAZWOPER if they can be reasonably expected to occur in the area and may cause the release of hazardous substances.

Although terrorist events and dangerous weather phenomena can present serious workplace hazards, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard only applies to them under certain conditions.

Terrorist events

The Occupational Safety and Health Administration (OSHA) does not consider terrorist events to be foreseeable workplace emergencies for purposes of standards requiring employers to anticipate and prepare for such emergencies. The release of chemicals or hazardous substances into a workplace, whether caused by an accidental release or by a terrorist event, would, however, be considered a hazardous materials (HAZMAT) incident. All emergency responders and employees performing emergency response efforts for such releases would, therefore, fall under 29 CFR 1910.120(q).

The level of emergency responder training must be based on the duties and functions to be performed by each responder. Although under 1910.120(q), employers would not be required specifically to prepare for a potential terrorist event and to develop an emergency response plan (ERP) for such an event, using the elements of the standard may be of assistance to employers in developing a useful plan of action to respond to any emergency situation.

Acts of nature

Workplaces located in areas prone to natural phenomena, such as earthquakes, floods, tornadoes, and hurricanes, and potentially subject to a “substantial threat of release of hazardous substances” are covered by 1910.120. The ERP required in 1910.120(q)(1) must include responses to emergencies caused by such natural phenomena.

According to subparagraph (q)(1), the ERP “shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations.” This means that employers in areas prone to natural phenomena should anticipate whether such natural phenomena are likely to cause releases of hazardous substances and, if so, incorporate appropriate emergency response procedures into their ERP.

Certain industry or employer types

  • Whether an employer is in the construction, shipyard, marine terminal, longshoring, or healthcare industry poses special issues relating to HAZWOPER.
  • EPA adopted 1910.120 in 40 CFR 311 for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan.

Construction

Hazardous waste operations and emergency response for construction sites are covered by 29 CFR 1926.65 (a standard identical to 29 CFR 1910.120, except for its references to other Occupational Safety and Health Administration, or OSHA, regulations). Work for construction, alteration, and/or repair, including painting and decorating, is considered “construction work” according to 29 CFR 1910.12 and must comply with the Construction Safety and Health Regulations within 29 CFR 1926.

For construction, all requirements of Part 1926 apply pursuant to their terms to hazardous waste and emergency response operations, whether covered by 1926.65 or not. If there is a conflict or overlap between 1926.65 and another Part 1926 regulation, the provision more protective of employee safety and health applies.

Shipyards, marine terminals, and longshoring

OSHA directive CPL 02-02-073 states, “HAZWOPER is also applicable to shipyard work under [Part] 1915.”

Employers are required under 29 CFR 1917.30 and 1918.100 to develop and implement emergency action plans to ensure employee safety from fires and other emergencies. However, if employees are directed by their employer to respond to an emergency beyond the scope of an emergency action plan, then paragraph (q) of 1910.120 applies (see footnotes at bottom of 1917.30 and 1918.100).

Healthcare

First receivers include hospital-based staff (e.g., triage, decontamination, medical treatment, and security) that receive and treat contaminated victims from mass casualty incidents. These personnel are removed from the site of the emergency and the point of release and do not need to be trained — or equipped — for control, containment, or confinement operations, as is required for a HAZMAT team.

First receivers are still considered to be part of an emergency response and are required to wear appropriate personal protective equipment (PPE) and be provided effective training based on the duties and functions to be performed.

State and local government employees

The Environmental Protection Agency (EPA) adopted 1910.120 in 40 CFR 311 (Federal Register June 23, 1989) for public employees who are both compensated and non-compensated (volunteers) in states where no OSHA-approved State Plan is in place, and, therefore, there is no OSHA coverage for state and local government employees.

Part 311 says, “The substantive provisions found at 29 CFR 1910.120 … apply to State and local government employees engaged in hazardous waste operations, as defined in 29 CFR 1910.120(a), in States that do not have a State plan approved under section 18 of the Occupational Safety and Health Act of 1970.” The term “hazardous waste operation” means any operation conducted within the scope of 1910.120.

EPA specifically includes “non-compensated workers” (i.e., volunteer workers) who work for governmental agencies engaged in emergency response, such as volunteer firefighters. Therefore, volunteers who will take part in operations involving hazardous substances must be trained in accordance with the applicable sections of 1910.120.

Radioactive or infectious materials

  • Radioactive waste and infectious materials can both fall under the HAZWOPER Standard, depending on the circumstances.

Radioactive waste

The term “hazardous substance” as defined by 29 CFR 1910.120 includes radioactive waste in addition to hazardous waste. It should not be confused with the definition of “hazardous chemical” in 29 CFR 1910.1200, Hazard Communication, which specifically excludes any radioactive chemicals.

The U.S. Nuclear Regulatory Commission (NRC) has jurisdiction “inside the fence” at NRC-licensed nuclear facilities for the risks involved with licensed radioactive materials, including emergency response procedures. The Occupational Safety and Health Administration (OSHA) has jurisdiction “inside the fence” for non-licensed radioactive materials, such as x-ray equipment, accelerators, some electron microscopes, and some naturally occurring radioactive materials (see the memo of understanding between OSHA and the NRC that delineates employee protection responsibilities for each agency at facilities licensed by the NRC, effective October 21, 1988).

There may be both NRC and OSHA jurisdiction when there is an emergency involving mixed wastes (licensed radioactive materials and other hazardous substances) “inside the fence.” HAZWOPER may also be applicable “outside the fence” to emergency response and cleanup activities involving hazardous substances, including licensed radioactive wastes.

Infectious materials

Employers must include infectious materials in their effort to comply with 1910.120(q) if there is a possibility that a release could cause an emergency. Employers with employees engaged in emergency response activities involving infectious materials must comply with the requirements in 1910.120(q) and may also have to comply with the Bloodborne Pathogens Standard, 29 CFR 1910.1030. If there is a conflict or overlap between the standards, the provision that is more protective of employee safety and health applies.

Terrorist events and acts of nature

  • Terrorist events themselves are not covered under the HAZWOPER Standard because they are not considered foreseeable workplace emergencies, but any emergency response to a hazardous substance release does fall under the standard.
  • Acts of nature fall under HAZWOPER if they can be reasonably expected to occur in the area and may cause the release of hazardous substances.

Although terrorist events and dangerous weather phenomena can present serious workplace hazards, the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard only applies to them under certain conditions.

Terrorist events

The Occupational Safety and Health Administration (OSHA) does not consider terrorist events to be foreseeable workplace emergencies for purposes of standards requiring employers to anticipate and prepare for such emergencies. The release of chemicals or hazardous substances into a workplace, whether caused by an accidental release or by a terrorist event, would, however, be considered a hazardous materials (HAZMAT) incident. All emergency responders and employees performing emergency response efforts for such releases would, therefore, fall under 29 CFR 1910.120(q).

The level of emergency responder training must be based on the duties and functions to be performed by each responder. Although under 1910.120(q), employers would not be required specifically to prepare for a potential terrorist event and to develop an emergency response plan (ERP) for such an event, using the elements of the standard may be of assistance to employers in developing a useful plan of action to respond to any emergency situation.

Acts of nature

Workplaces located in areas prone to natural phenomena, such as earthquakes, floods, tornadoes, and hurricanes, and potentially subject to a “substantial threat of release of hazardous substances” are covered by 1910.120. The ERP required in 1910.120(q)(1) must include responses to emergencies caused by such natural phenomena.

According to subparagraph (q)(1), the ERP “shall be developed and implemented to handle anticipated emergencies prior to the commencement of emergency response operations.” This means that employers in areas prone to natural phenomena should anticipate whether such natural phenomena are likely to cause releases of hazardous substances and, if so, incorporate appropriate emergency response procedures into their ERP.

Related hazards

  • Employers must be aware of and account for both general and specific hazards of the worksite and how these may change/develop over time and as work progresses.

Knowledge of hazards, both in general and specific to the work setting, is crucial to development of a Hazardous Waste Operations and Emergency Response (HAZWOPER) program and employee training. Whether an employer has a hazardous waste cleanup site, hazardous waste treatment/storage/disposal facility, hazardous waste storage area, or emergency response operations, the work setting may pose a multitude of health and safety concerns, any one of which could result in serious injury, illness, or death. These hazards are a function of the nature of the site as well as a consequence of the work being performed.

Under HAZWOPER, worksites may pose an immediate danger to life or health that may:

  • Not be immediately obvious or identifiable,
  • Vary according to the location and task being performed, or
  • Change as site activities progress.

The employer’s written programs must provide comprehensive protection against all potential hazards and specific protection against individual known hazards, and these programs should adapt to new information and changing site conditions. The related hazards described in this section are general categories, and the employer may require more information on certain hazards that apply to its operations.

Chemical exposure

  • Chemical hazards can cause many different types of injuries or illnesses to humans, some not apparent until long after exposure.
  • Physical hazards are posed by the physical properties of a chemical, such as being combustible or reactive.
  • Health hazards are posed by properties of a chemical that are toxic to humans, such as being corrosive or carcinogenic.

Preventing exposure to toxic chemicals is a primary concern while working with hazardous waste or responding to a chemical emergency. Most facilities contain a variety of chemical substances in gaseous, liquid, or solid form. These substances can enter the unprotected body through the four routes of exposure:

  • Inhalation
  • Skin absorption
  • Ingestion
  • Injection (through a puncture wound)

A contaminant can cause damage at the point of contact or can act systemically, causing a toxic effect at a part of the body distant from the point of initial contact.

There are two main classifications of chemical hazards — physical hazards and health hazards. Physical hazards are those hazards posed by the physical properties of a chemical, such as being able to burn, corrode, or react with other chemicals. Chemicals that pose physical hazards include:

  • Explosives
  • Flammables (gases, aerosols, liquids, or solids)
  • Oxidizers (liquid, solid or gas)
  • Self-reactives
  • Pyrophorics (liquids or solids)
  • Self-heating chemicals
  • Organic peroxides
  • Chemicals corrosive to metal
  • Gases under pressure
  • Chemicals when in contact with water emit flammable gas

Health hazards mean the chemical possesses toxic properties that may poison or injure us. Obviously, the possible injury can take many forms, from a skin rash to cancer. Chemicals with health hazards pose one or more of the following health effects:

  • Acute toxicity (any route of exposure)
  • Skin corrosion or irritation
  • Serious eye damage or eye irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (single or repeated exposure)
  • Aspiration toxicity or simple asphyxiant

Hazardous chemicals also include simple asphyxiants, combustible dusts, pyrophoric gases, or hazards not otherwise classified.

Chemical exposures are generally divided into two categories: acute and chronic. Symptoms resulting from acute exposures usually occur during or shortly after exposure to a sufficiently high concentration of a contaminant. The concentration required to produce such effects varies widely from chemical to chemical.

The term “chronic exposure” generally refers to exposures to “low” concentrations of a contaminant over a long period of time. The “low” concentrations required to produce symptoms of chronic exposure depend upon the chemical, the duration of each exposure, and the number of exposures. For a given contaminant, the symptoms of an acute exposure may be completely different from those resulting from chronic exposure.

For either chronic or acute exposure, the toxic effect may be temporary and reversible, or it may be permanent (disability or death). Some chemicals may cause obvious symptoms such as burning, coughing, nausea, tearing eyes, or rashes. Other chemicals may cause health damage without any such warning signs (this is a particular concern with chronic exposures to low concentrations).

Health effects such as cancer or respiratory disease may not manifest for several years or decades after exposure. In addition, some toxic chemicals may be colorless and/or odorless, may dull the sense of smell, or may not produce any immediate or obvious physiological sensations. Thus, a worker’s senses or feelings cannot necessarily be relied upon to warn of potential toxic exposure.

The effects of exposure not only depend on the chemical, its concentration, the route of entry, and the duration of exposure, but may also be influenced by personal factors such as the individual’s smoking habits, alcohol consumption, medication use, nutrition, age, and sex.

Exposure routes

  • The most common exposure route is inhalation, but others include skin/eye contact, ingestion, and injection via puncture wounds.

Inhalation

One important exposure route is inhalation. The majority of toxic substances enter the body through breathing. That’s because the lungs are extremely vulnerable to chemical agents. Even substances that do not directly affect the lungs may pass through lung tissue into the bloodstream, where they are transported to other vulnerable areas of the body.

Some toxic chemicals present in the atmosphere may not be detected by human senses — they may be colorless and odorless, and their toxic effects may not produce any immediate symptoms. Respiratory protection is therefore extremely important if there is a possibility that the worksite atmosphere may contain such hazardous substances.

Chemicals can also enter the respiratory tract through punctured eardrums. Where this is a hazard, workers with punctured eardrums should be medically evaluated to determine if this condition would place them at unacceptable risk and preclude their working at the task in question.

Skin/Eye contact

Direct contact of the skin and eyes with hazardous substances is another important route of exposure. Some chemicals directly injure the skin. Some pass through the skin into the bloodstream, where they are transported to vulnerable organs. Skin absorption is enhanced by abrasions, cuts, heat, and moisture.

The eye is particularly vulnerable because airborne chemicals can dissolve in its moist surface and be carried to the rest of the body through the bloodstream (capillaries are very close to the surface of the eye). Wearing protective equipment, not using contact lenses in contaminated atmospheres (since they may trap chemicals against the eye surface), keeping hands away from the face, and minimizing contact with liquid and solid chemicals can help protect workers against skin and eye contact.

Ingestion

Although ingestion should be the least significant route of exposure, it is important to be aware of how this type of exposure can occur. Deliberate ingestion of chemicals is unlikely. However, personal habits such as chewing gum or tobacco, drinking, eating, smoking cigarettes, or applying cosmetics on the jobsite may provide a route of entry for chemicals.

Injection

The last primary route of chemical exposure is injection, whereby chemicals are introduced into the body through puncture wounds (for example, by stepping or tripping and falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical hazards, and taking common-sense precautions are important protective measures against injection.

Explosion and fire

  • Explosions and fires can happen spontaneously but more often come from worksite activities such as moving drums or accidentally mixing or igniting chemicals.
There are many potential causes of explosions and fires at any site where chemicals are present, like:
  • Chemical reactions that produce explosion, fire, or heat;
  • Ignition of explosive or flammable chemicals;
  • Ignition of materials due to oxygen enrichment;
  • Agitation of shock- or friction-sensitive compounds; and
  • Sudden release of materials under pressure.

Explosions and fires may arise spontaneously. However, more commonly, they result from worksite activities such as moving drums, accidentally mixing incompatible chemicals, or introducing an ignition source (such as a spark from equipment) into an explosive or flammable environment.

At chemical handling sites, explosions and fires not only pose the obvious hazards of intense heat, open flame, smoke inhalation, and flying objects but may also cause the release of toxic chemicals into the environment. Such releases can threaten both personnel onsite and members of the general public living or working nearby.

Protecting against this hazard means:

  • Having qualified personnel field monitor for explosive atmospheres and flammable vapors;
  • Keeping all potential ignition sources away from an explosive or flammable environment;
  • Using non-sparking, explosion-proof equipment; and
  • Following safe practices when performing any task that might result in the agitation or release of chemicals.

Oxygen deficiency

  • Oxygen deficiency is likeliest to occur in confined spaces, low-lying areas, and in poorly ventilated areas where another gas may displace oxygen (such as CO produced by a generator).

The oxygen content of normal air at sea level is approximately 21 percent. Physiological effects of oxygen deficiency in humans are readily apparent when the oxygen concentration in the air decreases to 16 percent. These effects include impaired attention, judgment, and coordination, as well as increased breathing and heart rate.

Oxygen concentrations lower than 16 percent can result in nausea and vomiting, brain damage, heart damage, unconsciousness, and death. To account for individual physiological responses and errors in measurement, concentrations of 19.5 percent oxygen or lower are considered to be indicative of oxygen deficiency.

Oxygen deficiency may result when oxygen is displaced by another gas or consumed by a chemical reaction. Confined spaces and low-lying areas are particularly vulnerable to oxygen deficiency and should always be monitored prior to entry. Qualified field personnel should always monitor oxygen levels and should use atmosphere-supplying respiratory equipment when oxygen concentrations drop below 19.5 percent by volume.

Asphyxiation is injury or death caused by the replacement of oxygen in the environment by another gas or vapor or by a chemical that keeps the body tissues from using oxygen. Carbon monoxide (CO) and benzene are examples of chemical asphyxiants.

CO is a poisonous, colorless, and odorless gas that is produced by the incomplete burning of fuel. Possible sources of exposure include emergency power generators used in poorly ventilated areas and gas-powered saws that need servicing.

Generators should never be used indoors or in enclosed spaces such as garages and basements. They also should not be used outdoors near doors, windows, and vents that could allow CO to enter. Opening windows and doors may not be enough to prevent CO from building up in those spaces

Radiation

  • The three types of harmful radiation, from least to most dangerous, are alpha, beta, and gamma.
  • Sunburn is caused by UV radiation from the sun and is best avoided by minimizing direct sun exposure.

Radioactive materials emit one or more of three types of harmful radiation:

  • Alpha radiation has limited penetration ability and is usually stopped by clothing and the outer layers of the skin. Alpha radiation poses little threat outside the body but can be hazardous if materials that emit alpha radiation are inhaled or ingested.
  • Beta radiation can cause harmful “beta burns” to the skin and damage the subsurface blood system. Beta radiation is also hazardous if materials that emit beta radiation are inhaled or ingested. Use of protective clothing, coupled with scrupulous personal hygiene and decontamination, affords good protection against alpha and beta radiation.
  • Gamma radiation easily passes through clothing and human tissue and can also cause serious permanent damage to the body. Chemical protective clothing affords no protection against gamma radiation itself. However, respiratory and other protective equipment can help keep radiation-emitting materials from entering the body by inhalation, ingestion, injection, or skin absorption.

If levels of radiation above natural background are discovered, a health physicist should be consulted. At levels greater than 2 mrem/hr, all site activities should cease until the site has been assessed by health physicists.

Sunburn

Prolonged exposure to ultraviolet radiation from the sun can produce sunburn. Symptoms include red, sensitive, inflamed skin and even blisters. General steps to relieve sunburn pain include:

  1. Soaking in cold water
  2. Drying the area
  3. Applying ointment
  4. Covering

For severe sunburn, medical treatment should be sought. The only way to prevent sunburn is to avoid sun exposure (by wearing a hat, long sleeves, and sunscreen).

When possible, work areas should be set up in a shaded location and tasks should be scheduled when individuals will not be exposed to direct sunlight, such as during the early morning or late afternoon.

Biological hazards

  • Biological hazards include disease-causing organisms; poisonous plants and animals; and biological agents used in bioterrorism.

Wastes from hospitals and research facilities may contain disease-causing organisms that could infect site personnel. Like chemical hazards, infectious agents may be dispersed in the environment via water and wind. Other biological hazards that may be present at a hazardous waste site include poisonous plants, insects, animals, and indigenous pathogens.

Protective clothing and respiratory equipment can help reduce the chances of exposure. Anyone who has been exposed should thoroughly wash any exposed body parts and equipment to help protect against infection.

Biological hazards can also stem from terrorist acts. Terrorism is the use of force or violence against persons or property for purposes of intimidation, coercion, or ransom. Bioterrorism is the use of biological agents to inflict casualties.

Biological agents are organisms, bacteria, viruses, or toxins that have illness-producing effects on people, livestock, and crops. Biological agents include:

AgentDisseminationTransmission (person to person)IncubationLethality
AnthraxSpores in aerosolNo (except cutaneous)1–5 daysHigh
CholeraIngestion and aerosolRare12 hours to 6 daysLow with treatment
PlagueAerosolHigh1–3 daysHigh if untreated
TularemiaAerosolNo1–10 daysModerate if untreated
Q FeverIngestion and aerosolRare14–16 daysVery low
SmallpoxAerosolHigh10–12 daysLow
VEEAerosol and infected vectorsLow1–6 daysLow
EbolaContact and aerosolModerate4–16 daysModerate to high
Botulinum ToxinIngestion and aerosolNoHours to daysHigh
T-2 MycotoxinsIngestion and aerosolNo2–4 hoursModerate
RicinIngestion and aerosoNoHours to daysHigh
Staphylococcal Enterotoxin BIngestion and aerosolNoHoursLess than 1 percent

Biological agents can be dispersed as aerosols or airborne particles. Some devices used for intentional biological terrorism may have the capacity to disseminate large quantities of biological materials in aerosols.

Terrorists may also use biological agents to contaminate food or water. Because biological agents cannot necessarily be detected and may take time to grow and cause harm, it is very difficult to determine that a biological attack has occurred until people begin showing the signs and symptoms.

Biological agents are infectious through one or more of the following mechanisms of exposure, depending upon the type of agent:

  • Inhalation, with infection through respiratory mucosa or lung tissues;
  • Ingestion;
  • Contact with the mucous membranes of the eyes or nasal tissues; or
  • Penetration of the skin through open cuts (even very small cuts and abrasions of which employees might be unaware).

Existing recommendations for protecting workers from biological hazards require the use of half-mask or full facepiece air-purifying respirators with particulate filter efficiencies ranging from N95 (for hazards such as pulmonary tuberculosis) to P100 (for hazards such as hantavirus) as a minimum level of protection.

Emergency first responders typically use self-contained breathing apparatus (SCBA) respirators with a full facepiece operated in the most protective, positive pressure (pressure demand) mode during emergency responses.

General safety hazards

  • General safety hazards include holes, steep hills, sharp objects, and bodies of water, among many other ways for workers to get hurt.

When people think of hazards during hazardous waste and emergency response operations, they might picture clouds of toxic gases being released in the workplace, or puddles of sulfuric acid eating through rubber boots. The reality is often far more mundane, but just as lethal.

Hazardous waste sites and in-plant emergency response operations may contain numerous safety hazards, such as:

  • Holes or ditches;
  • Precariously positioned structures and objects, such as drums or boards that may fall;
  • Sharp objects, such as nails, metal shards, and broken glass;
  • Slippery surfaces;
  • Steep grades;
  • Uneven terrain;
  • Unstable surfaces, such as walls that may cave in or flooring that may give way;
  • Falls from ladders and scaffolding;
  • Powered equipment with moving parts and unexpected startup;
  • Motor vehicle hazards, such as being struck or backed into by a vehicle;
  • Friction that causes blisters, rashes, and burns; and
  • Drowning.

Some safety hazards are a function of the work itself. For example, heavy equipment creates an additional hazard for workers in the vicinity of the operating equipment.

Personal protective equipment (PPE) can impair a worker’s agility, hearing, and vision, which can result in an increased risk of an accident. Stress and fatigue can play a role as well.

Accidents involving physical hazards can directly injure workers and can create additional hazards, such as increased chemical exposure due to damaged PPE or the danger of explosion caused by the mixing of chemicals. Site personnel should constantly look out for potential safety hazards and should immediately inform their supervisors of any new hazards so that mitigative action can be taken.

It is worth noting that according to a report by the Worker Education and Training Plan of the National Institute of Environmental Health Sciences, NIEHS WETP Response to the World Trade Center (WTC) Disaster, most response worker injuries at the 2001 World Trade Center disaster site were blisters and eye injuries, followed by headaches and sprains or strains. This demonstrates that general safety hazards are important and cannot be ignored at an emergency response site.

Electrical hazards

  • Employers should minimize electrical hazards to workers by identifying and deenergizing circuits workers might contact and communicating about potential dangers.
  • Power line and lightning hazards also pose risks to site employees working outdoors.

Electrical equipment

Electrical equipment used onsite may also pose a hazard to workers. To help minimize this hazard, low-voltage equipment with ground-fault circuit interrupters and watertight, corrosion-resistant connecting cables should be used onsite.

Capacitors

An additional electrical hazard involves capacitors that may retain a charge. All such items should be properly grounded before handling. OSHA standard 29 CFR 1910.137, Electrical Protective Equipment, describes clothing and equipment for protection against electrical hazards.

Power lines

Overhead power lines, downed electrical wires, and buried cables all pose a danger of shock or electrocution if workers contact or sever them during site operations.

Electrical lines should be assumed to be energized until proven otherwise. Lines and other conductors may become reenergized without warning as utilities are evaluated and restored after an emergency release or other disaster.

Employers should:

  • Identify the location of any energized electrical power circuit that employees (or their tools and equipment) could contact;
  • Deenergize and ground any such circuits; and
  • Post signs and advise individuals of the location, hazards, and protective work practices.

More information is provided in the Occupational Safety and Health Administration (OSHA) fact sheet, Working Safely Around Downed Electrical Wires, found at www.osha.gov/OshDoc/data_General_Facts/downed_electrical_wires.pdf.

Lightning

In addition, lightning is a hazard during outdoor operations, particularly for workers handling metal containers or equipment. To eliminate this work hazard, weather conditions should be monitored, and work should be suspended during electrical storms.

More information

Please refer to the Electrical safety and Personal protective equipment subjects for further information on electrical safety and electrical protective equipment.

Confined spaces

  • Confined spaces are difficult to enter, exit, and move within, and they pose a serious risk of asphyxiation.

There are safety and health hazards involved in responding to incidents in confined spaces. The openings are usually small and are difficult to move through easily, which makes the transport of protective equipment a chore.

Simply put, a confined space is any space that meets three criteria:

  • It’s large enough for a worker to enter,
  • It has limited means of entry or exit, and
  • It’s not designed for continuous occupancy.

Examples of confined spaces include tanks, vessels, silos, storage bins, hoppers, vaults, boilers, pits, sewers, and crawl spaces.

Confined space hazards

Because air may not move in or out of confined spaces freely due to the design, the atmosphere inside a confined space can be very different from the atmosphere outside. Deadly gases may be trapped inside, or there may not be enough oxygen to support life. Therefore, occasional worker entry for inspection, maintenance, repair, cleanup, or similar tasks is often difficult and dangerous due to chemical or physical hazards within the space.

In addition to oxygen deficiency and toxic air contaminants, confined spaces may contain combustible gases, electrical hazards, moving parts, and even snakes.

Permit spaces

With so many hazards, permits are often required just to perform work in a confined space. In fact, a confined space is considered a permit-required confined space (called a permit space) if it has:

  • A hazardous atmosphere;
  • The potential for engulfment or suffocation;
  • An internal layout that might trap an entrant, such as by inwardly converging walls or a sloped floor; or
  • Any other recognized serious hazard.

Please refer to the Confined spaces subject for further information.

Noise

  • Where workers are exposed to noise averaging at least 85 dBA for 8 hours, employers must administer a hearing conservation program and other administrative/engineering controls to protect workers’ hearing.

Work around large equipment often creates excessive noise. The effects of noise can include:

  • Workers being startled, annoyed, or distracted;
  • Ear damage, pain, and temporary and/or permanent hearing loss; and
  • Communication interference, which may increase potential hazards due to the inability to warn of danger and convey proper safety precautions.

In general industry, if employees are subjected to noise exceeding an 8-hour, time-weighted average sound level of 90 dBA (decibels on the A-weighted scale), feasible administrative or engineering controls must be utilized. In addition, whenever employee noise exposures equal or exceed an 8-hour, time-weighted average sound level of 85 dBA, employers must administer a continuing, effective hearing conservation program as described in Occupational Safety and Health Administration (OSHA) regulation 29 CFR 1910.95.

In construction, employers will want to reference 29 CFR 1926.52, 1926.95, and 1926.101.

Please refer to the Personal protective equipment subject for further information.

Heat stress and cold exposure

  • Heat stress can occur within 15 minutes and is exacerbated by PPE, which traps body heat and moisture.
  • Cold exposure can lead to frostbite and hypothermia and impair the ability to work.

Heat stress is a major hazard, especially for employees wearing protective clothing. The same protective materials that shield the body from chemical exposure also limit the dissipation of body heat and moisture. Personal protective equipment (PPE) and protective clothing can therefore create a hazardous condition.

Depending on the ambient conditions and the work being performed, heat stress can occur very rapidly — within as little as 15 minutes. It can pose as great a danger to employee health as chemical exposure can. In its early stages, heat stress can cause rashes, cramps, discomfort, and drowsiness, resulting in impaired functional ability that threatens the safety of both the individual employee and coworkers.

Continued heat stress can lead to heatstroke and death. Ways to protect against this hazard include:

  • Avoiding overprotection,
  • Careful training,
  • Frequent monitoring of personnel who wear PPE,
  • Judicious scheduling of work and rest periods, and
  • Frequent replacement of fluids.

Cold exposure

Cold injury (frostbite and hypothermia) and impaired ability to work are dangers at low temperatures and when the wind-chill factor is low. Factors that guard against cold-exposure hazards include:

  • Appropriate clothing;
  • Warm shelter;
  • Carefully scheduled work and rest periods; and
  • Monitoring of employees’ physical conditions.

Please refer to the Heat and cold exposure subject for further information.

Animal and plant hazards

  • Workers conducting hazardous waste and emergency response operations outdoors should be prepared to guard against, check for, and avoid animal and plant hazards.

As with any work occurring outdoors, operations involving hazardous waste and/or emergency response may pose a host of animal and plant hazards. To prevent animal and insect bites and stings, employees should take the following safety and health measures:

  • To prepare for work:
    • Wear long pants and long-sleeved shirts.
    • Inspect and shake out clothing and shoes before getting dressed.
    • Cover exposed skin (as weather permits) when working in high grass to avoid potentially Lyme-transmitting deer tick bites.
    • Use insect repellent containing DEET or Picaridin on exposed skin.
    • Wear proper foot gear, such as high-top leather boots and leather gloves when handling materials where snakes, insects, and other animals may have nesting (e.g., firewood, lumber, rocks, or construction debris).
    • Discuss hazardous wildlife (e.g., alligators or poisonous snakes) with authorities familiar with these matters (e.g., game wardens or animal control officers).
  • Where animals may be present:
    • Inspect areas for nests and stray animals.
    • Remove all nearby sources of stagnant or standing waters.
    • Place hands and feet cautiously.
    • Avoid reaching into holes or under objects (e.g., lumber, scrap metal, overturned boats) without checking to see if snakes, insects, or other animals are present.
    • Avoid sitting or lying down in areas where snakes, insects, or other animals could be present (e.g., wood piles or high vegetation).
  • Where animals are or have been present:
    • Assume that all snakes are poisonous and that all animals are rabid.
    • Be on guard for stray or wild animals, as they can exhibit unpredictable or aggressive behavior.
    • Do not attempt to take custody of animals (unless trained to do so).
    • Watch animals from a safe distance while contacting animal rescue/control personnel.
    • Report all tick bites to medical personnel.

To prevent contact with poisonous plants, employees should:

  • Be trained on hazardous plant recognition.
  • Keep rubbing alcohol accessible, as it may remove the oily resin from plants, such as poison ivy up to 30 minutes after exposure.
  • Wear gloves, long pants, and long-sleeved shirts when possibly contacting poisonous plants.
  • Use a barrier cream formulated to protect against poison ivy/oak.
  • When appropriate, safely clear vegetation from areas where personnel are working and living (e.g., construction trailers or base camps).

Other hazards

  • Victims, witnesses, responders, and their families can all experience psychological trauma after an adverse event, so companies should provide assistance, known as “managing critical incident stress.”
  • Because environmental factors are all interconnected, damage can spread widely into various aspects of the environment.

Other hazards relate to hazardous waste operations and emergency response.

Psychological hazards

Witnessing or responding to a tragic event, such as an explosion, fire, or toxic release, can adversely impact a person psychologically. Emergency responders are no exception. Feelings of hopelessness, loss, and depression may affect a person months, even years, after an incident.

To lessen psychological effects, employers should provide for the mental well-being of victims; witnesses; responders; and families of victims, witnesses, and responders to an incident. This is called managing critical incident stress. Often, employee assistance programs are involved.

Property and environmental hazards

Depending on the type of release, the emergency response efforts, and the properties and environmental factors involved, property and environmental damage caused by an incident can be minimal to severe. Explosion and fire can cause the greatest damage to property.

Releases may vaporize and travel outside the immediate area, seep into groundwater, kill vegetation and wildlife, and cause other environmental damage. Air, water, land, vegetation, and wildlife interact with one another. Affecting one may affect them all.

Chemical exposure

  • Chemical hazards can cause many different types of injuries or illnesses to humans, some not apparent until long after exposure.
  • Physical hazards are posed by the physical properties of a chemical, such as being combustible or reactive.
  • Health hazards are posed by properties of a chemical that are toxic to humans, such as being corrosive or carcinogenic.

Preventing exposure to toxic chemicals is a primary concern while working with hazardous waste or responding to a chemical emergency. Most facilities contain a variety of chemical substances in gaseous, liquid, or solid form. These substances can enter the unprotected body through the four routes of exposure:

  • Inhalation
  • Skin absorption
  • Ingestion
  • Injection (through a puncture wound)

A contaminant can cause damage at the point of contact or can act systemically, causing a toxic effect at a part of the body distant from the point of initial contact.

There are two main classifications of chemical hazards — physical hazards and health hazards. Physical hazards are those hazards posed by the physical properties of a chemical, such as being able to burn, corrode, or react with other chemicals. Chemicals that pose physical hazards include:

  • Explosives
  • Flammables (gases, aerosols, liquids, or solids)
  • Oxidizers (liquid, solid or gas)
  • Self-reactives
  • Pyrophorics (liquids or solids)
  • Self-heating chemicals
  • Organic peroxides
  • Chemicals corrosive to metal
  • Gases under pressure
  • Chemicals when in contact with water emit flammable gas

Health hazards mean the chemical possesses toxic properties that may poison or injure us. Obviously, the possible injury can take many forms, from a skin rash to cancer. Chemicals with health hazards pose one or more of the following health effects:

  • Acute toxicity (any route of exposure)
  • Skin corrosion or irritation
  • Serious eye damage or eye irritation
  • Respiratory or skin sensitization
  • Germ cell mutagenicity
  • Carcinogenicity
  • Reproductive toxicity
  • Specific target organ toxicity (single or repeated exposure)
  • Aspiration toxicity or simple asphyxiant

Hazardous chemicals also include simple asphyxiants, combustible dusts, pyrophoric gases, or hazards not otherwise classified.

Chemical exposures are generally divided into two categories: acute and chronic. Symptoms resulting from acute exposures usually occur during or shortly after exposure to a sufficiently high concentration of a contaminant. The concentration required to produce such effects varies widely from chemical to chemical.

The term “chronic exposure” generally refers to exposures to “low” concentrations of a contaminant over a long period of time. The “low” concentrations required to produce symptoms of chronic exposure depend upon the chemical, the duration of each exposure, and the number of exposures. For a given contaminant, the symptoms of an acute exposure may be completely different from those resulting from chronic exposure.

For either chronic or acute exposure, the toxic effect may be temporary and reversible, or it may be permanent (disability or death). Some chemicals may cause obvious symptoms such as burning, coughing, nausea, tearing eyes, or rashes. Other chemicals may cause health damage without any such warning signs (this is a particular concern with chronic exposures to low concentrations).

Health effects such as cancer or respiratory disease may not manifest for several years or decades after exposure. In addition, some toxic chemicals may be colorless and/or odorless, may dull the sense of smell, or may not produce any immediate or obvious physiological sensations. Thus, a worker’s senses or feelings cannot necessarily be relied upon to warn of potential toxic exposure.

The effects of exposure not only depend on the chemical, its concentration, the route of entry, and the duration of exposure, but may also be influenced by personal factors such as the individual’s smoking habits, alcohol consumption, medication use, nutrition, age, and sex.

Exposure routes

  • The most common exposure route is inhalation, but others include skin/eye contact, ingestion, and injection via puncture wounds.

Inhalation

One important exposure route is inhalation. The majority of toxic substances enter the body through breathing. That’s because the lungs are extremely vulnerable to chemical agents. Even substances that do not directly affect the lungs may pass through lung tissue into the bloodstream, where they are transported to other vulnerable areas of the body.

Some toxic chemicals present in the atmosphere may not be detected by human senses — they may be colorless and odorless, and their toxic effects may not produce any immediate symptoms. Respiratory protection is therefore extremely important if there is a possibility that the worksite atmosphere may contain such hazardous substances.

Chemicals can also enter the respiratory tract through punctured eardrums. Where this is a hazard, workers with punctured eardrums should be medically evaluated to determine if this condition would place them at unacceptable risk and preclude their working at the task in question.

Skin/Eye contact

Direct contact of the skin and eyes with hazardous substances is another important route of exposure. Some chemicals directly injure the skin. Some pass through the skin into the bloodstream, where they are transported to vulnerable organs. Skin absorption is enhanced by abrasions, cuts, heat, and moisture.

The eye is particularly vulnerable because airborne chemicals can dissolve in its moist surface and be carried to the rest of the body through the bloodstream (capillaries are very close to the surface of the eye). Wearing protective equipment, not using contact lenses in contaminated atmospheres (since they may trap chemicals against the eye surface), keeping hands away from the face, and minimizing contact with liquid and solid chemicals can help protect workers against skin and eye contact.

Ingestion

Although ingestion should be the least significant route of exposure, it is important to be aware of how this type of exposure can occur. Deliberate ingestion of chemicals is unlikely. However, personal habits such as chewing gum or tobacco, drinking, eating, smoking cigarettes, or applying cosmetics on the jobsite may provide a route of entry for chemicals.

Injection

The last primary route of chemical exposure is injection, whereby chemicals are introduced into the body through puncture wounds (for example, by stepping or tripping and falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical hazards, and taking common-sense precautions are important protective measures against injection.

Exposure routes

  • The most common exposure route is inhalation, but others include skin/eye contact, ingestion, and injection via puncture wounds.

Inhalation

One important exposure route is inhalation. The majority of toxic substances enter the body through breathing. That’s because the lungs are extremely vulnerable to chemical agents. Even substances that do not directly affect the lungs may pass through lung tissue into the bloodstream, where they are transported to other vulnerable areas of the body.

Some toxic chemicals present in the atmosphere may not be detected by human senses — they may be colorless and odorless, and their toxic effects may not produce any immediate symptoms. Respiratory protection is therefore extremely important if there is a possibility that the worksite atmosphere may contain such hazardous substances.

Chemicals can also enter the respiratory tract through punctured eardrums. Where this is a hazard, workers with punctured eardrums should be medically evaluated to determine if this condition would place them at unacceptable risk and preclude their working at the task in question.

Skin/Eye contact

Direct contact of the skin and eyes with hazardous substances is another important route of exposure. Some chemicals directly injure the skin. Some pass through the skin into the bloodstream, where they are transported to vulnerable organs. Skin absorption is enhanced by abrasions, cuts, heat, and moisture.

The eye is particularly vulnerable because airborne chemicals can dissolve in its moist surface and be carried to the rest of the body through the bloodstream (capillaries are very close to the surface of the eye). Wearing protective equipment, not using contact lenses in contaminated atmospheres (since they may trap chemicals against the eye surface), keeping hands away from the face, and minimizing contact with liquid and solid chemicals can help protect workers against skin and eye contact.

Ingestion

Although ingestion should be the least significant route of exposure, it is important to be aware of how this type of exposure can occur. Deliberate ingestion of chemicals is unlikely. However, personal habits such as chewing gum or tobacco, drinking, eating, smoking cigarettes, or applying cosmetics on the jobsite may provide a route of entry for chemicals.

Injection

The last primary route of chemical exposure is injection, whereby chemicals are introduced into the body through puncture wounds (for example, by stepping or tripping and falling onto contaminated sharp objects). Wearing safety shoes, avoiding physical hazards, and taking common-sense precautions are important protective measures against injection.

Explosion and fire

  • Explosions and fires can happen spontaneously but more often come from worksite activities such as moving drums or accidentally mixing or igniting chemicals.
There are many potential causes of explosions and fires at any site where chemicals are present, like:
  • Chemical reactions that produce explosion, fire, or heat;
  • Ignition of explosive or flammable chemicals;
  • Ignition of materials due to oxygen enrichment;
  • Agitation of shock- or friction-sensitive compounds; and
  • Sudden release of materials under pressure.

Explosions and fires may arise spontaneously. However, more commonly, they result from worksite activities such as moving drums, accidentally mixing incompatible chemicals, or introducing an ignition source (such as a spark from equipment) into an explosive or flammable environment.

At chemical handling sites, explosions and fires not only pose the obvious hazards of intense heat, open flame, smoke inhalation, and flying objects but may also cause the release of toxic chemicals into the environment. Such releases can threaten both personnel onsite and members of the general public living or working nearby.

Protecting against this hazard means:

  • Having qualified personnel field monitor for explosive atmospheres and flammable vapors;
  • Keeping all potential ignition sources away from an explosive or flammable environment;
  • Using non-sparking, explosion-proof equipment; and
  • Following safe practices when performing any task that might result in the agitation or release of chemicals.

Oxygen deficiency

  • Oxygen deficiency is likeliest to occur in confined spaces, low-lying areas, and in poorly ventilated areas where another gas may displace oxygen (such as CO produced by a generator).

The oxygen content of normal air at sea level is approximately 21 percent. Physiological effects of oxygen deficiency in humans are readily apparent when the oxygen concentration in the air decreases to 16 percent. These effects include impaired attention, judgment, and coordination, as well as increased breathing and heart rate.

Oxygen concentrations lower than 16 percent can result in nausea and vomiting, brain damage, heart damage, unconsciousness, and death. To account for individual physiological responses and errors in measurement, concentrations of 19.5 percent oxygen or lower are considered to be indicative of oxygen deficiency.

Oxygen deficiency may result when oxygen is displaced by another gas or consumed by a chemical reaction. Confined spaces and low-lying areas are particularly vulnerable to oxygen deficiency and should always be monitored prior to entry. Qualified field personnel should always monitor oxygen levels and should use atmosphere-supplying respiratory equipment when oxygen concentrations drop below 19.5 percent by volume.

Asphyxiation is injury or death caused by the replacement of oxygen in the environment by another gas or vapor or by a chemical that keeps the body tissues from using oxygen. Carbon monoxide (CO) and benzene are examples of chemical asphyxiants.

CO is a poisonous, colorless, and odorless gas that is produced by the incomplete burning of fuel. Possible sources of exposure include emergency power generators used in poorly ventilated areas and gas-powered saws that need servicing.

Generators should never be used indoors or in enclosed spaces such as garages and basements. They also should not be used outdoors near doors, windows, and vents that could allow CO to enter. Opening windows and doors may not be enough to prevent CO from building up in those spaces

Radiation

  • The three types of harmful radiation, from least to most dangerous, are alpha, beta, and gamma.
  • Sunburn is caused by UV radiation from the sun and is best avoided by minimizing direct sun exposure.

Radioactive materials emit one or more of three types of harmful radiation:

  • Alpha radiation has limited penetration ability and is usually stopped by clothing and the outer layers of the skin. Alpha radiation poses little threat outside the body but can be hazardous if materials that emit alpha radiation are inhaled or ingested.
  • Beta radiation can cause harmful “beta burns” to the skin and damage the subsurface blood system. Beta radiation is also hazardous if materials that emit beta radiation are inhaled or ingested. Use of protective clothing, coupled with scrupulous personal hygiene and decontamination, affords good protection against alpha and beta radiation.
  • Gamma radiation easily passes through clothing and human tissue and can also cause serious permanent damage to the body. Chemical protective clothing affords no protection against gamma radiation itself. However, respiratory and other protective equipment can help keep radiation-emitting materials from entering the body by inhalation, ingestion, injection, or skin absorption.

If levels of radiation above natural background are discovered, a health physicist should be consulted. At levels greater than 2 mrem/hr, all site activities should cease until the site has been assessed by health physicists.

Sunburn

Prolonged exposure to ultraviolet radiation from the sun can produce sunburn. Symptoms include red, sensitive, inflamed skin and even blisters. General steps to relieve sunburn pain include:

  1. Soaking in cold water
  2. Drying the area
  3. Applying ointment
  4. Covering

For severe sunburn, medical treatment should be sought. The only way to prevent sunburn is to avoid sun exposure (by wearing a hat, long sleeves, and sunscreen).

When possible, work areas should be set up in a shaded location and tasks should be scheduled when individuals will not be exposed to direct sunlight, such as during the early morning or late afternoon.

Biological hazards

  • Biological hazards include disease-causing organisms; poisonous plants and animals; and biological agents used in bioterrorism.

Wastes from hospitals and research facilities may contain disease-causing organisms that could infect site personnel. Like chemical hazards, infectious agents may be dispersed in the environment via water and wind. Other biological hazards that may be present at a hazardous waste site include poisonous plants, insects, animals, and indigenous pathogens.

Protective clothing and respiratory equipment can help reduce the chances of exposure. Anyone who has been exposed should thoroughly wash any exposed body parts and equipment to help protect against infection.

Biological hazards can also stem from terrorist acts. Terrorism is the use of force or violence against persons or property for purposes of intimidation, coercion, or ransom. Bioterrorism is the use of biological agents to inflict casualties.

Biological agents are organisms, bacteria, viruses, or toxins that have illness-producing effects on people, livestock, and crops. Biological agents include:

AgentDisseminationTransmission (person to person)IncubationLethality
AnthraxSpores in aerosolNo (except cutaneous)1–5 daysHigh
CholeraIngestion and aerosolRare12 hours to 6 daysLow with treatment
PlagueAerosolHigh1–3 daysHigh if untreated
TularemiaAerosolNo1–10 daysModerate if untreated
Q FeverIngestion and aerosolRare14–16 daysVery low
SmallpoxAerosolHigh10–12 daysLow
VEEAerosol and infected vectorsLow1–6 daysLow
EbolaContact and aerosolModerate4–16 daysModerate to high
Botulinum ToxinIngestion and aerosolNoHours to daysHigh
T-2 MycotoxinsIngestion and aerosolNo2–4 hoursModerate
RicinIngestion and aerosoNoHours to daysHigh
Staphylococcal Enterotoxin BIngestion and aerosolNoHoursLess than 1 percent

Biological agents can be dispersed as aerosols or airborne particles. Some devices used for intentional biological terrorism may have the capacity to disseminate large quantities of biological materials in aerosols.

Terrorists may also use biological agents to contaminate food or water. Because biological agents cannot necessarily be detected and may take time to grow and cause harm, it is very difficult to determine that a biological attack has occurred until people begin showing the signs and symptoms.

Biological agents are infectious through one or more of the following mechanisms of exposure, depending upon the type of agent:

  • Inhalation, with infection through respiratory mucosa or lung tissues;
  • Ingestion;
  • Contact with the mucous membranes of the eyes or nasal tissues; or
  • Penetration of the skin through open cuts (even very small cuts and abrasions of which employees might be unaware).

Existing recommendations for protecting workers from biological hazards require the use of half-mask or full facepiece air-purifying respirators with particulate filter efficiencies ranging from N95 (for hazards such as pulmonary tuberculosis) to P100 (for hazards such as hantavirus) as a minimum level of protection.

Emergency first responders typically use self-contained breathing apparatus (SCBA) respirators with a full facepiece operated in the most protective, positive pressure (pressure demand) mode during emergency responses.

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