Safety and health program

An effective and comprehensive safety and health program is essential in reducing work-related injuries and illnesses and in maintaining a safe and healthful work environment. HAZWOPER requires each covered employer to develop and implement a written safety and health program that identifies, evaluates, and controls safety and health hazards and provides emergency response procedures for each hazardous waste site or treatment, storage, and disposal facility.

This written program has to include specific and detailed information on the following topics:

• An organizational workplan,
• Site evaluation and control,
• A site-specific program,
• Information and training program,
• Personal protective equipment program,
• Monitoring,
• Medical surveillance program,
• Decontamination procedures, and
• Emergency response program.

The written program must be periodically updated and made available to all affected employees, contractors and subcontractors. The employer also must inform contractors and subcontractors of any identifiable safety and health hazards or potential fire or explosion hazards before they enter the worksite. The components of the safety and health program are discussed in the following paragraphs.

Workplan

§1910.120(b)

Planning is the key element in a hazardous waste control program. Proper planning will greatly reduce worker hazards at waste sites. A workplan should support the overall objectives of the control program and provide procedures (SOPs) for implementation and should incorporate the employer’s standard operating procedures for safety and health.

Establishing a chain of command will specify employer and employee responsibilities in carrying out the safety and health program. For example, the plan should include the following:

• Supervisor and employee responsibilities and means of communication,
• Name of person who supervises all of the hazardous waste operations, and
• The site supervisor with responsibility for an authority to develop and implement the site safety and health program and to verify compliance.

In addition to this organizational structure, the plan should define the tasks and objectives of site operation as well as the logistics and resources required to fulfill these tasks. For example, the following topics should be addressed:

• The anticipated clean-up and/or operating procedures,
• A definition of work tasks and objectives and methods of accomplishment,
• The established personnel requirements for implementing the plan, and
• Procedures for implementing training, informational programs, and medical surveillance requirements.

Necessary coordination between the general program and site-specific activities also should be included in the actual operations workplan.

Site evaluation and control

§1910.120(c) and (d)

Site evaluation, both initial and periodic, is crucial to the safety and heath of workers. Site evaluation provides employers with the information needed to identify site hazards so they can select appropriate protection methods for employees.

It is extremely important, and a requirement of the standard, that a trained person conduct a preliminary evaluation of an uncontrolled hazardous waste site before entering the site. The evaluation must include all suspected conditions that are immediately dangerous to life or health or that may cause serious harm to employees (e.g., confined space entry, potentially explosive or flammable situation, visible vapor clouds, etc.) As available, the evaluation must include the location and size of the site, site topography, site accessibility by air and roads, pathways for hazardous substances to disperse, a description of worker duties, and the time needed to perform a given task, as well as the present status and capabilities of the emergency response teams.

Periodic reevaluations should also be conducted for treatment, storage, and disposal facilities, as conditions or operations change.

Controlling the activities of workers and the movement of equipment is an important aspect of the overall safety and health program. Effective control of the site will minimize potential contamination of workers, protect the public from hazards, and prevent vandalism. The following information is useful in implementing the site control program: a site map, site work zones, site communication, safe work practices, and the name, location and phone number of the nearest medical assistance.

The use of a “buddy system” is also required as a protective measure to assist in the rescue of an employee who becomes unconscious, trapped, or seriously disabled on site. In the buddy system, two employees pair up to keep an eye on each other. Only one buddy should be in a specific dangerous area at a time, so that if that person gets in trouble, the second can call for help.

Site-specific safety and health plan

§1910.120(b)

A site-specific safety and health plan is a complementary program element that aids in eliminating or effectively controlling anticipated safety and health hazards. The site-specific plan needs to include all of the basic requirements of the overall safety and health program, but with attention to those characteristics unique to the particular site.

For example, the site-specific plan may outline procedures for confined space entry, air and personal monitoring and environmental sampling, and a spill containment program to address the particular hazards present at the site.

The site safety and health plan must identify the hazards of each phase of the specific site operation and must be kept on the worksite. Pre-entry briefings need to be conducted prior to site entry and at other times as necessary to ensure that employees are aware of the site safety and health plan and its implementation. The employer must also ensure that periodic safety and health inspections are made of the site and that all known deficiencies are corrected prior to work at the site.

Information and training program

§1910.120(e)

As part of the safety and health program, employers are required to develop and implement a program to inform workers performing hazardous waste operations of the level and degree of exposure they are likely to encounter. This includes contractors and subcontractors.

Employers also are required to develop and implement procedures for introducing effective new technologies that provide improved worker protection in hazardous waste operations. Examples include foams, absorbents, adsorbents, or neutralizers.

Training makes workers aware of the potential hazards they may encounter and provides the necessary knowledge and skills to perform their work with minimal risk to their safety and health. Develop a training program for all employees exposed to safety and health hazards during hazardous waste operations. Both supervisors and workers have to be trained to:

• Recognize hazards and to prevent them;
• Select, care for, and use respirators properly as well as other types of personal protective equipment;
• Understand engineering controls and their use;
• Use proper decontamination procedures;
• Understand the emergency response plan, medical surveillance requirements, confined space entry procedures, spill containment program, and any appropriate work practices; and
• Know the names of personnel and their alternatives responsible for site safety and health.

The amount of instruction differs with the nature of the work operations, as indicated in the following Tables 1 and 2.

Table 1: Tgrainin requirements Hazardous waste clean-up sites 

Staff
Routine site employees	40 hours initial
	24 hours field
	8 hours annual refresher
Routine site employees (minimal exposure)	24 hours initial
	8 hours field
	8 hours annual refresher
Non-routine site employees	24 hours initial
	8 hours field
	8 hours annual refresher
Supervisor/Managers of:
Routine site employees	40 hours initial
	24 hours field
	8 hours hazardous waste management
	8 hours annual refresher
Routine site employees (minimal exposure)	24 hours initial
	8 hours field
	8 hours hazardous waste management
	8 hours annual refresher
Non-routine site employees	24 hours initial
	8 hours field
	8 hours hazardous waste management
	8 hours annual refresher
Treatment, storage, and disposal sites
Staff
General site employees	24 hours initial or equivalent
	8 hours annual refresher
Emergency response personnel	Trained to a level of competency Annual refresher
Note: See 29 CFR 1910.120 (e) and (p)(7).

Table 2: Training requirements Other emergency response staff 

Level 1 -	First responder (awareness) level[1]	Sufficient training or proven experience in specific competencies Annual refresher
Level 2 -	First responder (operations level)[2]	Level 1 competency and 8 hours initial or proven experience in specific competencies Annual refresher
Level 3 -	HAZMAT technician[3]	24 hours of Level 2 and proven experience in specific competencies Annual refresher
Level 4 -	HAZMAT specialist[4]	24 hours of Level 3 and proven experience in specific competencies Annual refresher
Level 5 -	On-the-scene incident commander[5]	24 hours of Level 2 and additional competencies Annual refresher
Note: See 29 CFR 1910.120(q)(6).
[1]Witnesses or discovers a release of hazardous materials and who are trained to notify the proper authorities. [2]Responds to releases of hazardous substances in a defensive manner, without trying to stop the releases. [3]Responds aggressively to stop the release of hazardous substances. [4]Responds with and in support to HAZMAT technicians, but who have specific knowledge of various hazardous substances. [5]Assumes control of the incident scene beyond the first-responder awareness level.

Employees at all sites can not perform any hazardous waste operation unless they have been trained to the level required by their job function and responsibility and have been certified by their instructor as having completed the necessary training. All emergency responders must receive annual refresher training sufficient to maintain or demonstrate competency. Employee training requirements are further defined by the nature of the work (e.g., temporary emergency response personnel, firefighters, safety officers, HAZMAT personnel, incident commanders).

These requirements may include recognizing and knowing the hazardous materials and their risks, knowing how to select and use appropriate control, containment, or confinement procedures and how to implement them. The specific training and competency requirements for each personnel category are explained fully in the HAZWOPER standard. For a brief summary of training requirements, see Tables 1 and 2.

Employees who receive the training specified (see Table 1) must be given a written certificate upon successful completion of that training. That training need not be repeated if the employee goes to work at a new site; however, the employee must receive whatever additional training is needed to work safely at the new site. Employees who worked at hazardous waste sites before 1987 and received equivalent training need not repeat the initial training specified in Table 1, if the employer can demonstrate that in writing and certify that the employee has received such training.

Personal protective equipment program

§1910.120(g)

HAZWOPER requires the employer to develop a written personal protective program for all employees involved in hazardous waste operations. As mentioned earlier, this program is also part of the site-specific safety and health program. The personal protective equipment program has to include:

• An explanation of equipment selection and use,
• Maintenance and storage,
• Decontamination and disposal,
• Training and proper fit,
• Donning and doffing procedures,
• Inspection,
• In-use monitoring,
• Program evaluation, and
• Equipment limitations.

Provide and require the use of personal protective equipment where engineering control methods are infeasible to reduce worker exposures at or below the permissible exposure limit. Personal protective equipment has to be selected that is appropriate to the requirements and limitations of the site, the task-specific conditions and duration, and the hazards and potential hazards identified at the site.

As necessary, furnish the employee with positive-pressure self-contained breathing apparatus or positive-pressure air-line respirators equipped with an escape air supply, and with totally encapsulating chemical protective suits.

Monitoring

§1910.120(h)

Airborne contaminants can present a significant threat to employee safety and health, thus making air monitoring an important component of an effective safety and health program. Conduct monitoring before site entry at uncontrolled hazardous waste sites to identify conditions immediately dangerous to life and health, such as oxygen-deficient atmospheres and areas where toxic substance exposures are above permissible limits. Accurate information on the identification and qualification of airborne contaminants is useful for the following:

• Selecting personal protective equipment,
• Delineating areas where protection and controls are needed,
• Assessing the potential health effects of exposure, and
• Determining the need for specific medical monitoring.

After a hazardous waste clean-up operation begins, periodically monitor those employees who are likely to have higher exposures to determine if they have been exposed to hazardous substances in excess of permissible exposure limits. Also monitor for any potential condition that is immediately dangerous to life and health or for higher exposures that may occur as a result of new work operations.

Medical surveillance

§1910.120(f)

A medical surveillance program will help to assess and monitor the health and fitness of employees working with hazardous substances. Establish a medical surveillance program for the following personnel:

• All employees exposed or potentially exposed to hazardous substances or health hazards above the permissible exposure limits for more than 30 days per year;
• Workers exposed above the published exposure levels (if there is no permissible exposure limit for these substances) for 30 days or more a year;
• Workers who wear approved respirators for 30 or more days per year on site;
• Workers who are exposed to unexpected or emergency releases of hazardous wastes above exposure limits (without wearing appropriate protective equipment) or who show signs, symptoms or illness that may have resulted from exposure to hazardous substances; and
• Members of hazardous materials (HAZMAT) teams.

All examinations have to be performed under the supervision of a licensed physician, without cost to the employee, without loss of pay and at a reasonable time and place. Examinations must include a medical and work history with special emphasis on symptoms related to the handling of hazardous substances and health hazards and to fitness for duty including the ability to wear any required personal protective equipment under conditions that may be expected at the worksite. These examinations must be given as follows:

• Prior to job assignment and annually thereafter (or every two years if a physician determines that is sufficient),
• At the termination of employment,^[*]
• Before reassignment to an area where medical examinations are not required,^[*]
• If the examining physician believes that a periodic follow-up is medically necessary, and
• As soon as possible for employees injured or becoming ill from exposure to hazardous substances during an emergency, or who develop signs or symptoms of overexposure from hazardous substances.

Provide the examining physician with a copy of the standard and its appendices, a description of the employee’s duties relating to his/her exposure, the exposure level or anticipated exposure level, a description of any personal protective and respiratory equipment used or to be used, and any information from previous medical examinations.

Obtain a written opinion from the physician that contains the results of the medical examination and any detected medical conditions that would place the employee at an increased risk from exposure, any recommended limitations on the employee or upon the use of personal protective equipment, and a statement that the employee has been informed by the physician of the results of the medical examination. For employee privacy reasons, the physician is not to reveal in the written opinion given to the employer specific findings or diagnoses unrelated to employment.

Decontamination procedures

§1910.120(k)

Decontamination procedures are a component of the site-specific safety and health plan and, consequently, must be developed, communicated to employees, and implemented before workers enter a hazardous waste site. As necessary, the site safety and health officer must require and monitor decontamination of the employee or decontamination and disposal of the employee’s clothing and equipment, as well as the solvents used for decontamination, before the employee leaves the work area.

If an employee’s nonimpermeable clothing becomes grossly contaminated with hazardous substances, the employee must immediately remove that clothing and take a shower. Decontaminate impermeable protective clothing before being removed by the employee.

Protective clothing and equipment must be decontaminated, cleaned, laundered, maintained, or replaced to retain effectiveness. Inform any person who launders or cleans such clothing or equipment of the potentially harmful effects of exposure to hazardous substances.

Employees who are required to shower must be provided showers and change rooms that meet the requirements of §1910.141, General Environmental Controls. In addition, unauthorized employees must not remove their protective clothing or equipment from change rooms unless authorized to do so.

Emergency response

§1910.120(l)

Proper emergency planning and response are important elements of the safety and health program that help minimize employee exposure and injury. Develop and implement a written emergency response plan to handle possible emergencies before actively performing hazardous waste operations. At uncontrolled hazardous waste sites and at treatment, storage, and disposal facilities, the plan must include the following elements:^[**]

• Personnel roles, lines of authority, and communication procedures,
• Pre-emergency planning,
• Emergency recognition and prevention,
• Emergency medical and first-aid treatment,
• Methods or procedures for alerting onsite employees,
• Safe distances and places of refuge,
• Site security and control,
• Decontamination procedures,
• Critique of response and follow-up,
• Personal protective and emergency equipment, and
• Evacuation routes and procedures.

In addition to these requirements, the plan must include site topography, layout, and prevailing weather conditions; and procedures for reporting incidents to local, state, and federal government agencies.

The procedures have to be compatible with, and integrated into, the disaster, fire and/or emergency response plans of the site’s nearest local, state, and federal agencies. Emergency response organizations may use the local or state emergency response plans, or both, as part of their emergency response plan to avoid duplication of federal regulations.

Reherse the plan requirements regularly, review periodically, and amend as necessary to keep them current with new or changing site conditions or information. The emergency plan also must be made available for inspection and copying by employees, their representatives, OSHA personnel and other governmental agencies with relevant responsibilities.

A distinguishable and distinct alarm system must be in operation to notify employees of emergencies.

When deemed necessary, employees must wear positive-pressure self-contained breathing apparatus and approved self-contained compressed-air breathing apparatus with approved cylinders. In addition, back-up and first-aid support personnel must be available for assistance or rescue.