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Workers, such as utility workers, who must perform duties at a hazardous waste site that has not yet been characterized but where contamination is expected, do fall under the scope of 1910.120. These workers must work under the direction of an on-site supervisor and a site-specific safety and health plan, and must be fully trained and protected pursuant to the HAZWOPER standard. When additional information becomes available through site characterization which verifies that there is minimal or no risk of employee exposure to hazardous substances, a lesser degree of PPE and worker training may be acceptable.
When site characterization shows that the area to be serviced by workers is free of potential exposure, or the proposed work assignments would not expose any of the work crew to hazardous substances, the activity can be carried out as a normal maintenance or construction operation.
The utility contractor is bound to provide at least the minimum number of training hours specified. On a hazardous waste site that has many site specific peculiarities, the employer may need to train employees beyond the 40 or 24 hour minimum set by the standard. Employees must be provided training that prepares them for their job functions and responsibilities, as stated in the general requirements in 1910.120(e).