As already indicated, as part of an effective safety and health program, the employer must institute control methods and work practices that are appropriate to the specific characteristics of the site. Such controls are essential to successful worker protection. Some control methods are described in the following paragraphs.
Engineering controls and work practices
§1910.120(g)
To the extent feasible, institute engineering controls and work practices to help reduce and maintain employee exposure at or below permissible exposure limits. To the extent notfeasible, engineering and work practice controls may be supplemented with personal protective equipment.
Examples of suitable and feasible engineering controls include the use or pressurized cabs or control booths on equipment, and/or remotely operated materials handling equipment. Examples of safe work practices include removing all non-essential employees from potential exposure while opening drums, wetting down dusty operations, and placing employees upwind of potential hazards.
Handling and labeling drums and containers
§1910.120(j)
Prior to handling a drum or container, the employer must assure that drums or containers meet the required OSHA, EPA (40 CFR Parts 264-265 and 300), and Department of Transportation (DOT) regulations (49 CFR Parts 171-178) and are properly inspected and labeled. Damaged drums or containers must be emptied of their contents, using a device classified for the material being transferred, and properly discarded. In areas where spills, leaks or ruptures occur, furnish employees with salvage drums or containers, a suitable quantity of absorbent material, and approved fire extinguishing equipment in the event of small fires.
Inform employees of the appropriate hazard warnings of labeled drums, the removal of soil or coverings, and the dangers of handling unlabeled drums or containers without prior identification of their contents. To the extent feasible, Keep the moving of drums or containers to a minimum, and implement a program to contain and isolate hazardous substances being transferred into drums or containers. In addition, use an approved EPA ground-penetrating device to determine the location and depth of any improperly discarded drums or containers.
Ensure that safe work practices are instituted before opening a drum or container. For example, air-line respirators and approved electrical equipment must be protected from possible contamination, and all equipment kept behind any existing explosion barrier.[*] Only tools or equipment that prevent ignition may be used. Locate all employees who are not performing the operation at a safe distance and behind a suitable barrier to protect them from accidental explosions.
In addition, standing on or working from drums or containers is prohibited. Special care also must be given when an employee handles containers of shock-sensitive waste, explosive materials, or laboratory waste packs. Where an emergency exists, have procedures in place to ensure the following:
- Evacuate non-essential employees from the transfer area,
- Protect equipment operators from exploding containers by using a barrier, and
- Make available a continuous means of communication (e.g., suitable radios or telephones), and a distinguishable and distinct alarm system to signal the beginning and end of activities where explosive wastes are handled.
If drums or containers bulge or swell or show crystalline material on the outside, do not move them onto or from the site unless appropriate containment procedures have been implemented. In addition, lab packs must be opened only when necessary and only by a qualified person. Prior to shipment to a licensed disposal facility, ensure that all drums or containers are properly labeled and packaged. Staging areas also must be kept to a minimum and provided with adequate access and egress routes.
Sanitation of temporary workplaces
§1910.120(n)
Each temporary worksite must have a supply of potable water that is stored in tightly closed and clearly labeled containers and equipped with a tap. Provide disposal cups and a receptacle for their disposal. Clearly mark all water outlets that are unsafe for drinking, washing, or cooking. Equip temporary worksites with toilet facilities. If there are no sanitary sewers close to or on the hazardous waste site, provide the following toilet facilities (unless prohibited by local codes):
- Privies,
- Chemical toilets,
- Recirculating toilets, or
- Combustion toilets.
Provide heated, well-ventilated, and well-lighted sleeping quarters for workers who guard the worksite. In addition, washing facilities for all workers must be near the worksite, within controlled work zones,[**] and equipped to enable employees to remove hazardous substances. It is also the employer’s responsibility to ensure that food service facilities are licensed.
Recordkeeping
§1910.120(f)
In 1988, OSHA revised the “Access to Employee Exposure and Medical Records” standard at §1910.1020 requiring employers to provide employees with information to assist in the management of their own safety and health. This standard permits direct access to the records of employees exposed to hazardous materials by their designated representatives and by OSHA.
Keep exposure records for 30 years and medical records for at least the duration of employment plus 30 years. Records of employees who have worked for less than one year need not be retained after employment, but you must provide these records to the employee upon termination of employment. First aid records of one-time treatment are not required to be kept for any specified period.
Inform each employee of the existence, location, and availability of these records. Whenever an employer plans to stop doing business and there is no successor employer to receive and maintain these records, the employer must notify employees of their right to access to records at least three months before the employer ceases to do business. At the same time, notify the National Institute for Occupational Safety and Health.
Under the HAZWOPER standard, medical records must include, at a minimum, the following information:
- Employee’s name and social security number,
- Physicians’ written opinions,
- Employee’s medical complaints related to exposure to hazardous substances, and
- Information provided to the treating physician.
