OSHA’s standards for general industry and the construction industry on hazardous waste operations and emergency response (29 CFR 1910.120 or 29 CFR 1926.65) cover all employees involved in:
• Clean-up operations of hazardous substances at uncontrolled hazardous waste sites required by Federal, state, local or other governments;
• Corrective actions involving clean-up procedures at sites covered by the Resource Conservation and Recovery Act (RCRA);
• Voluntary clean-up operations at sites recognized as uncontrolled hazardous waste sites by Federal, state, local or other governments;
• Operations involving hazardous waste that are conducted at treatment, storage and disposal facilities licensed under RCRA;
• Emergency response operations for hazardous substance releases or substantial threats of releases.
Exceptions are permitted if the employer can demonstrate that the operation does not involve employee exposure or a reasonable possibility of such exposure to hazards. State and local government employees are covered by equivalent standards in the 26 states with OSHA-approved state plans and by the Environment Protection Agency’s hazardous waste standard in states without plans.
Hazardous Waste Operations
Each employer must have:
• A written, readily-accessible safety and health program that identifies, evaluates and controls safety and health hazards and provides for emergency response.
• A preliminary site evaluation conducted by a qualified person to identify potential site hazards and to aid in the selection of appropriate employee protection methods.
• A site control program to protect employees against hazardous contamination. At a minimum it must have a site map, site work zones,site communications, safe work practices, the use of a “buddy system,” and identification of the nearest medical aid.
• Employee training for everyone working on a hazardous waste site.
• Medical surveillance of workers exposed at or above permissible exposure limits for hazardous substances, conducted (1) at least annually, (2) when a worker moves to a new worksite, (3) when a worker experiences exposure from unexpected or emergency releases and (4) at the end of employment.
Other requirements include controls to reduce and monitor exposure levels of hazardous materials,
an informational program describing any exposure during operations and the inspection of drums and containers prior to removal or opening. Decontamination procedures and emergency response plans (described under Emergency Response) must be in place before employees begin working in hazardous waste operations. Employers must also create safer environments by developing and implementing effective new technologies.
In addition to programs for safety and health, training, medical surveillance, decontamination, new technology and emergency response, employers at RCRA sites also need the following:
• A written hazard communication program meeting the requirements of 29 CFR 1910.1200.
• Procedures to effectively control and handle drums and containers.
Employers must develop an emergency response plan to handle possible on-site emergencies and coordinate off-site response. Rehearsed regularly and reviewed/amended periodically, the plan must address: personnel roles; lines of authority, training and communications; emergency recognition and prevention; site security; evacuation routes and procedures; decontamination procedures; emergency medical treatment; and emergency alerting procedures. Training is required before employees engage in hazardous waste operations and emergency response.
Uncontrolled hazardous waste operations
• 40 hours of initial training; 3 days of actual field experience for regular employees to be certified.
• 24 hours of initial training; 1 day of supervised field experience for employees visiting the site occasionally.
• 8 hours of additional waste management training for supervisors and managers.
• 8 hours of annual refresher training.
Treatment, storage and disposal facilities licensed under RCRA
• 24 hours of training.
• 8 hours of annual refresher training.
Emergency response operations at sites not RCRA licensed or at uncontrolled hazardous waste site clean-ups
1) First responders at the “awareness level” (witness or discover a hazardous substance release
and initiate the emergency response) must demonstrate competency in areas such as recognizing the presence of hazardous materials in an emergency, the risks involved and the role they play in their employer’s plan.
2) First responders at the “operations level” (respond to prevent the spread, exposures to and the further release of hazardous materials) must have 8 hours of training plus “awareness level” competency.
3) Hazardous materials technicians (respond to stop the release) must have 24 hours of training equal to the “operations level” and know how to implement the employer’s plan and carry out decontamination.
4) Hazardous materials specialists (require specific knowledge of the substances to be contained) must have 24 hours of training equal to the “technical level” and act as liaison with all government
5) On-scene incident commanders (assume control of the scene) must have 24 hours of training equal to the “operations level” and demonstrate competence in implementing the incident command system, the employer’s plan and the state and local emergency response plans.
Annual refresher training is required for each level of response.
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