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Requirements You Need to Make Sure Are In Your Hazardous Waste Operations and Emergency Response (HAZWOPER) Plan

hazwoperThe Hazardous Waste Operations and Emergency Response (HAZWOPER) Health and Safety Plan (HASP) applies to cleanup operations required by government agencies at uncontrolled hazardous waste sites, corrective actions involving cleanup at Resource Conservation and Recovery Act (RCRA)-regulated sites, and voluntary cleanup at uncontrolled hazardous waste sites. HASP is limited to the Occupational Safety and Health Administration’s (OSHA) HAZWOPER requirements at 29 CFR 1910.120(b)-(o) and, therefore, does not apply to treatment, storage, and disposal facilities (TSDFs) licensed under RCRA that are not subject to corrective actions, nor to the emergency responder requirements under Section (q) of the standard.

Below are some basic elements that you should make sure  are in your  your facility’s Health and Safety Plan (HASP)…

  1. Site Characterization and Analysis (29 CFR 1910.120(c)) – Initial site characterization and analysis must be performed by a qualified person in order to choose and justify engineering controls, work practices, and personal protective equipment (PPE). They should checkout the historical data and then work a plan to anticipate site conditions to then identify appropriate procedures. At a bare minimum take into consideration  conditions that….
    • Can become Immediately dangerous to life or health (IDLH).
    • Could exceed published exposure levels (e.g., OSHA permissible exposure limits (PELs), ACGIH TLVs®, National Institute for Occupational Safety and Health (NIOSH) RELs).
    • Could indicate exposure over radioactive dose limits (see 10 CFR 20).
    • Are otherwise dangerous conditions, including but not limited to the presence of flammable or oxygen-deficient atmospheres.
  2. Site Control (29 CFR 1910.120(d)) – These procedures should identify contaminated areas and appropriate work practices, address preventing unauthorized or unprotected workers from entering contaminated areas, and define controlling the migration of site contaminants. Make sure your plan sections off work zones and establishes safe work and communication procedures for each of these zones. The plan will  need a site map and shows the zones and explains how they will be made physically visible. The plan must explain your method for controlling entry into contaminated areas, to make sure to restrict it to only authorized employees with sufficient training. Medial information, along with the route to the nearest medical facility must be posted in the contamination or support zone(s), Emergency communication procedures must be written and explained to employees.
  3. Training (29 CFR 1910.120(e)) and Information Programs (29 CFR 1910.120 (i)) – Employees must be safety trained before work begins. Required training is described in 29 CFR 1910.120(e) and is a combination of classroom instruction, site-specific information, and supervised fieldwork. Initial training must be updated with 8 hours of refresher training annually. You are also required to inform employees and contractors of the types and level of hazards associated with operations. Nonmandatory Appendix E provides training criteria and content guidance. Your plan must identify which jobs require training what is need to be fulfilled before beginning work.  
  4. Medical Surveillance (29 CFR 1910.120(f)) – If you have employees who meet any of following criteria, you need to establish a medical surveillance program. A licensed physician needs determine the content of the medical exams to be provided to your employees and baseline, periodic, and exit exams are required. A physician’s written opinion must be provided after each employee’s medical exam and in almost all cases you must keep both employees’ medical and exposure records for the duration of their employment, plus 30 years. Employees and their representatives have the right to access these records. Employees must be included in the medical surveillance program if they…
    • Are or may be exposed to hazardous substances above permissible limits for at least 30 days per year.
    • Wear a respirator for at least 30 days per year.
    • Become ill or show signs or symptoms of job-related overexposure to hazardous substances.
    • Are members of a hazardous materials (hazmat) team.
  5. Engineering Controls, Work Practices, and PPE for Employee Protection (29 CFR 1910.120(g)) – Controls and work practices must be in your plan and if they require PPE, you must include a written PPE program that describes how you select and use PPE based on the tasks and the amounts of site contaminants. The PPE program must explain how to use PPE and what their limitations are along with keeping them viable and training to use them and such. The PPE program must them be evaluated.

Need someone to help your business to stay compliant or advise you on your HAZWOPER or HASP plans? We work with these regulations everyday and know how to handle it for you, so you can focus on your core business.  

Contact Us (859-689-9222 – KY, 513-367-4100 – OH) to get more information about how we can help your business.

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