661 hazwoper ii - oshacademy · 2021. 2. 24. · make any warranty or representation, either...

This is the second in a ten-course series comprising the 40-hour HAZWOPER for General Site Workers certificate program per OSHA Standard 29 CFR 1910.120. This course focuses on the HAZWOPER requirements for safety and health programs, planning and organization, and training.

HAZWOPER II

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OSHAcademy Course 661 Study Guide

HAZWOPER II

Copyright © 2021 Geigle Safety Group, Inc.

No portion of this text may be reprinted for other than personal use. Any commercial use of

this document is strictly forbidden.

Contact OSHAcademy to arrange for use as a training document.

This study guide is designed to be reviewed off-line as a tool for preparation to successfully

complete OSHAcademy Course 661.

Read each module, answer the quiz questions, and submit the quiz questions online through

the course webpage. You can print the post-quiz response screen which will contain the correct

answers to the questions.

The final exam will consist of questions developed from the course content and module quizzes.

We hope you enjoy the course and if you have any questions, feel free to email or call:

OSHAcademy

15220 NW Greenbrier Parkway, Suite 230 Beaverton, Oregon 97006 www.oshatrain.org [email protected]

+1 (888) 668-9079

Disclaimer

This document does not constitute legal advice. Consult with your own company counsel for advice on compliance with all applicable state and

federal regulations. Neither Geigle Safety Group, Inc., nor any of its employees, subcontractors, consultants, committees, or other assignees

make any warranty or representation, either express or implied, with respect to the accuracy, completeness, or usefulness of the information

contained herein, or assume any liability or responsibility for any use, or the results of such use, of any information or process disclosed in this

publication. GEIGLE SAFETY GROUP, INC., DISCLAIMS ALL OTHER WARRANTIES EXPRESS OR IMPLIED INCLUDING, WITHOUT LIMITATION, ANY

WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE. Taking actions suggested in this document does not guarantee

that an employer, employee, operator or contractor will be in compliance with applicable regulations. Ultimately every company is responsible

for determining the applicability of the information in this document to its own operations. Each employer’s safety management system will be

different. Mapping safety and environmental management policies, procedures, or operations using this document does not guarantee

compliance regulatory requirements.

Revised: February 15, 2021

mailto:[email protected]

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Contents

Modules and Learning Objectives .................................................................................................. 1

Module 1: HAZWOPER Safety and Health Program ................................................................... 1

Module 2: HAZWOPER Safety and Health Program (Continued) ............................................... 1

Module 3: HAZWOPER Safety and Health Program (Continued) ............................................... 1

Module 4: Planning and Organization ........................................................................................ 2

Module 5: Training ..................................................................................................................... 2

Introduction .................................................................................................................................... 3

Module 1: HAZWOPER Safety and Health Program ....................................................................... 4

Quiz Instructions ......................................................................................................................... 5

Organizational Structure ............................................................................................................. 5

Comprehensive Work Plan ......................................................................................................... 6

Site Characterization and Analysis .............................................................................................. 7

Preliminary Site Evaluation ......................................................................................................... 7

Detailed Site Evaluation .............................................................................................................. 8

Health and Safety Plan (HASP) .................................................................................................... 9

Task Hazard Analysis ............................................................................................................. 10

Exposure Monitoring ............................................................................................................ 10

Site Control ........................................................................................................................... 11

Buddy System ........................................................................................................................ 11

eHASP .................................................................................................................................... 12

Module 2: The HAZWOPER Safety and Health Program (Continued) .......................................... 13

Safety and Health Training Program ......................................................................................... 13

Initial Training ....................................................................................................................... 13

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Equivalent Training ............................................................................................................... 14

Hands-on Requirement ......................................................................................................... 17

Training Topics ...................................................................................................................... 18

Medical Surveillance ................................................................................................................. 18

Key Points About the Medical Examination: ........................................................................ 21

Module 3: HAZWOPER Safety and Health Program (Continued) ................................................. 23

Standard Operating Procedures and Practices ......................................................................... 23

Hazard Control Strategies ......................................................................................................... 23

Personal Protective Equipment ................................................................................................ 23

PPE Program .......................................................................................................................... 23

Levels of Protection .................................................................................................................. 25

Exposure Monitoring ................................................................................................................ 26

When and How to Monitor ................................................................................................... 27

Informing Employees and Contractors ..................................................................................... 28

Handling Hazardous Materials .................................................................................................. 28

Decontamination ...................................................................................................................... 30

Emergency Response ................................................................................................................ 31

Additional Emergency Response Requirements ....................................................................... 32

Lighting for Employees.............................................................................................................. 33

Sanitation .................................................................................................................................. 34

Drinking Water ...................................................................................................................... 34

Toilet Facilities ...................................................................................................................... 34

Washing Facilities .................................................................................................................. 35

Shower Facilities ................................................................................................................... 35

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Sleeping Facilities .................................................................................................................. 35

New Technology Plan ................................................................................................................ 35

Module 4: Planning and Organization .......................................................................................... 37

Introduction .............................................................................................................................. 37

Organizational Structure ........................................................................................................... 38

Leadership and Commitment ................................................................................................... 40

Roles and Responsibilities ......................................................................................................... 41

Off-site Personnel Positions .................................................................................................. 41

Essential On-site Personnel Positions ................................................................................... 42

On-site Optional Personnel Positions ................................................................................... 45

As Needed Personnel ............................................................................................................ 46

Work Plan .................................................................................................................................. 47

Site Safety Plan.......................................................................................................................... 48

Safety Meetings and Inspections .............................................................................................. 50

Module 5: Training ........................................................................................................................ 52

Introduction .............................................................................................................................. 52

Training Programs ..................................................................................................................... 53

Training for General Site Workers ............................................................................................ 56

Field Activities Requirement ..................................................................................................... 57

Emergency Responder Training ................................................................................................ 58

Emergency Response Trainer Qualifications ........................................................................ 60

Record of Training ..................................................................................................................... 61

Acronyms ...................................................................................................................................... 63

Glossary ......................................................................................................................................... 65

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Resources ...................................................................................................................................... 69


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Copyright © 2021 Geigle Safety Group, Inc. Page 1 of 69

Modules and Learning Objectives

Module 1: HAZWOPER Safety and Health Program

Learning objectives in this module include:

• Describe the elements of the organizational structure.

• List the methods used to control hazards in a preliminary site evaluation.

• Discuss what must be included in the detailed evaluation of the site.

• Discuss the importance of the Health and Safety Plan (HASP) and the elements it must address.

• Define “task hazard analysis,” and discuss why it may be the most critical component of the site HASP.

• Describe the “buddy system” and how it can assist in the rescue of employees.

Module 2: HAZWOPER Safety and Health Program (Continued)


• Discuss the requirements of employee training.

• Describe the “initial training” both supervisors and employees must receive.

• Discuss the hands-on training requirement and why it is critically important.

• Discuss medical surveillance requirements for workers performing cleanup operations.

• Discuss what the employer must give a physician that is examining an employee.

• Describe when it is necessary for an employee to receive a medical exam.



• Describe the controls and work practices an employer must use to reduce and maintain employee exposure to or below PELs.

• Discuss when it is necessary for employers to provide employees with PPE.

• Describe the four levels of respiratory protection.

• Discuss why PPE must be evaluated for each task and not for the site.

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• Describe “exposure monitoring” and the hazard it is intended to address.

• Discuss how employers must safely handle hazardous materials.

• Describe what an employee must do before leaving the work area.

Module 4: Planning and Organization


• Discuss what an organizational structure should do.

• List the steps that should be taken in formulating a comprehensive work plan.

• List the elements of a site safety plan.

• Discuss the purpose of safety meetings.

• Describe the guidelines that should be observed to ensure the effectiveness of inspections.

• List the factors that must be considered when determining the frequency of inspections.

Module 5: Training


• Define the objectives of training programs for employees involved in hazardous waste site activities.

• Discuss the training necessary for different categories of jobs.

• Discuss the training an emergency responder must receive based on the duties the responder will be expected to perform.

• Describe the necessary qualifications for an emergency response trainer.

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Introduction

Mismanagement of hazardous materials or substances, whether during daily operations or at

the time of an accidental release into the environment, can lead to adverse health effects and

even death of employees, and adverse effects on the environment. To prevent hazardous

materials incidents (i.e., a situation in which a hazardous material is or may be released into the

environment), it is important for park personnel most likely to work with hazardous materials

or substances to learn proper management and handling techniques.

HAZWOPER refers to the OSHA HAZardous Waste OPERations and Emergency Response

standard: 1910.120, Subdivision 2/H. HAZWOPER is a difficult, complex standard. The

HAZWOPER standard for the construction industry, 29 CFR 1926.65, is identical to 29 CFR

1910.120. For brevity, the HAZWOPER standard is referenced as 1910.120 throughout the

remainder of this course.

This course provides an overview of the HAZWOPER program requirements, organization and

planning, and training requirements. Understanding this information will help you to work

safely and protect the safety and health of everyone working on the hazardous waste site. The

course won’t give you all HAZWOPER requirements, but it will help you understand HAZWOPER

and determine how to protect your employees through best practices.

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Module 1: HAZWOPER Safety and Health Program

The HAZWOPER standard requires each employer to develop and implement a written safety

and health program for each of the three categories of hazardous waste sites before work

begins. Each hazardous waste site clean-up effort will require a site specific occupational safety

and health program headed by the site coordinator or the employer's representative.

The safety and health program identifies, evaluates, and controls safety and health hazards,

and provides emergency response procedures for each hazardous waste site. 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.

The program describes the work policies, practices, and procedures, and includes the following

topics:

1. an organizational structure,

2. a comprehensive workplan,

3. site characterization and evaluation,

4. a site-specific safety and health plan (HASP),

5. a safety and health training program,

6. a medical surveillance program, and

7. standard operating procedures.

The written safety and health program must be periodically updated and made available to all

affected employees, contractors, and subcontractors. Necessary coordination between the

general program and site-specific activities also should be included in the program.

The employer also must inform contractors and subcontractors, or their representatives, of any

identifiable safety and health hazards or potential fire or explosion hazards before they enter

the worksite.

One site-specific safety and health program is acceptable if it covers all tasks, operations, and

employers on the site, and if the employees are trained to use the plan. However, each

contractor or subcontractor at the site must comply with HAZWOPER requirements.

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In this module, we’ll look at the first five elements of the safety and health program, and in the

next module, we’ll cover the final three elements. Although we’ll address these elements as

they apply to cleanup operations, remember, they should also be adapted for TSD facilities and

other hazardous waste sites.

Quiz Instructions

Read the material in each section to discover the correct answer to questions. Circle the correct

answers. When you’re finished with all modules in the course, go online to take the final exam.

The exam is “open book,” so you can use this study guide while taking the exam.

1. Who must the written safety and health program be made available to?

a. Occupational Workers Program

b. Environmental Protection Agency

c. General public

d. Affected employees

Organizational Structure

The organizational structure part of the program establishes the overall chain of command as

well as the roles and responsibilities assigned to supervisors and employees. The organizational

structure must, at a minimum, include the following management positions:

• a general supervisor with the responsibility and authority to direct all hazardous waste site operations,

• a site safety and health supervisor who develops and implements the HASP and is responsible for ensuring compliance, and

• the program must also include the roles and responsibilities of all the other site personnel necessary for hazardous waste site operations.

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2. The organizational structure of the HAZWOPER program must include which of the

following management positions?

a. A regional director that directs operations for all hazardous waste sites

b. A morale and welfare supervisor with the responsibility to direct some of the

hazardous waste site operations

c. A general supervisor with the responsibility and authority to direct all hazardous

waste site operations

d. A site safety and health officer that is responsible for enhancing employee

psychosocial support.

Comprehensive Work Plan

Planning is the key element in a hazardous waste cleanup program. Proper planning will greatly

reduce employee hazards at hazardous waste sites. A work plan should support the overall

objectives of the cleanup program and provide procedures for implementation, and

incorporate the employer’s standard operating procedures for safety and health.

The plan must define the tasks and objectives of site operations as well as the logistics and

resources required to fulfill these tasks. For example, the following topics must be addressed:

• the anticipated cleanup and 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.

Chain of Command. The written program must also describe the chain of command at the site.

A chain of command links one person with overall responsibility for managing site operations to

others responsible for carrying out specific tasks. Those included in the chain of command:

• A general supervisor, who directs site operations.

• A site safety-and-health supervisor, who has authority and knowledge to develop the program and who can ensure it complies with HAZWOPER requirements.

• Those involved in cleanup operations at the site.

• Those who will respond to emergencies at the site.

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3. Why is proper planning important when working at hazardous waste sites?

a. To reduce employee hazards

b. To meet employee expectations

c. To reduce budgetary mistakes

d. To hold people accountable

Site Characterization and Analysis

Site characterization and analysis is the process of identifying specific site hazards and

determining the appropriate safety and health control procedures necessary to protect site

employees. The more accurate, detailed, and comprehensive the information available about a

site, the more the protective measures can be tailored to the actual hazards the employees

may encounter.

Preliminary Site Evaluation

Before your employees begin cleanup work at a new site, a designated qualified person must

do a preliminary evaluation to identify hazards to which they may be exposed and to determine

how to protect them with:

• engineering controls,

• work practices, and

• personal protective equipment.

Initial site characterization and analysis must be performed by a qualified person to choose and

justify engineering controls, work practices, and PPE. The qualified person should examine

historical data and the work plan to anticipate site conditions and then identify appropriate PPE

and monitoring procedures. At the outset, site evaluations may be limited to conditions that:

• are immediately dangerous to life or health (IDLH)

• exceed published exposure levels (e.g., OSHA PELs, ACGIH TLVs®, NIOSH RELs)

• 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

• historical data and known site processes should be used to identify potential chemical and physical hazards. After work begins, you must continue to evaluate conditions, update your hazard analysis, and choose appropriate controls, work practices, and PPE.

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Exposure controls and monitoring instruments must be based on an up-to-date characterization and hazard analysis.

4. At the outset, site evaluations may be limited to which condition?

a. Worker exposure below OSHA PEL limits

b. The height at which employees will be working

c. The type of soil workers will be excavating

d. Immediately dangerous to life or health (IDLH)

Detailed Site Evaluation

Soon after employees begin working at the site, the qualified person must conduct a more

detailed evaluation of the site. 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 employee duties, and the time needed to perform a given task, and

• the present status and capabilities of the emergency response teams.

Additional requirements of the site characterization involve the following:

• PPE to be used during initial site entry,

• Exposure monitoring for ionizing radiation and other IDLH conditions. (Note: An ongoing air monitoring program in accordance with paragraph (h) of HAZWOPER must be implemented after site characterization has determined it is safe to begin start-up or cleanup operations), and

• Risk identification based on the presence and concentrations of hazardous substances and communication of the risks to those employees who will be working on the site.

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5. When must a qualified person conduct a more detailed evaluation of a hazardous waste

site?

a. Soon after employees begin working at the site

b. Before the employees begin working at the site

c. After the site has been cleaned up

d. A detailed evaluation of the site is unnecessary

Health and Safety Plan (HASP)

OSHA 1910.120 requires a site-specific safety and health plan for clean-up operations

conducted under HAZWOPER. A written HASP is a critical program element that aids in

eliminating or effectively controlling anticipated safety and health hazards. The HASP must be

unique to the site and it should address all the following elements: (Click on the elements to

download chapters of a sample HASP for Anthrax)

• Organizational Structure

• Site Characterization and Job Hazard Analysis

• Site Control

• Training

• Medical Surveillance

• PPE

• Exposure Monitoring

• Heat Stress

• Spill Containment

• Decontamination

• Emergency Response

• Standard Operating Procedures (SOPs)

• Confined Space Entry Procedures

• Safety Data Sheets (SDSs)

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6. A health and safety plan (HASP) must address which element?

a. Employee training

b. Site topography

c. Employee hiring practices

d. Equipment purchasing plans

Task Hazard Analysis

Although some of the above elements are a part of the overall safety and health program,

several others are additional to these elements and are crucial in developing an effective HASP.

For example, the task hazard analysis may be the most critical component of the site HASP and

addresses the chemical, physical, and biological hazards associated with each task or operation

and the control procedures that protect employees when they perform that task.

Information obtained from the hazard analysis provides the basis for making important

decisions regarding the selection of PPE, medical monitoring, exposure monitoring, etc.

Exposure Monitoring

It is important to thoroughly address in the HASP how exposure monitoring will be performed

as this is necessary for the protection of site employees. Critical information includes:

• the frequency and types of air monitoring,

• personnel monitoring,

• environmental sampling techniques and instrumentation including calibration and maintenance methods, and

• the interpretation of monitoring results.

For example, there should be established criteria for determining when to upgrade or

downgrade PPE based on exposure monitoring results.

7. What may be the most critical component of a site health and safety plan (HASP)?

a. The preliminary site evaluation

b. A detailed site evaluation

c. Task hazard analysis

d. Employee hiring procedures

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Site Control

Another important element of the HASP is site control, which involves controlling the activities

of employees and the movement of equipment which minimizes potential contamination of

employees. Site control also protects the general public from site hazards and can prevent

trespassing and vandalism.

Site control 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.

The following information is useful in developing and implementing a site control program:

• a site map that shows work zone boundaries and identify how these boundaries will be visibly marked on the site. These boundaries may change as work operations change or if hazards migrate to clean areas.

• site work zones and site communication procedures for each work zone;

• methods for controlling entry into contaminated areas, restricting this to authorized employees who are properly trained and protected;

• safe work practices; and

• the name, location, and phone number of the nearest medical assistance.

8. What should site control procedures of a health and safety plan address?

a. Address the biological hazards associated with each task

b. Address preventing unauthorized or unprotected workers from entering

contaminated areas

c. Assess the frequency and types of air monitoring

d. Define emergency response procedures

Buddy System

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 must keep in visual contact with each other and only one employee

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should be in a specific dangerous area at any one time, so if one gets in trouble the second can

call for help.

• The written HASP must be kept at the site and must always be available for employee, contractor, or subcontractor review.

• Pre-entry briefings must be conducted before site entry and at other times as necessary to ensure employees are aware of the HASP and its implementation.

• The employer also must ensure periodic safety and health inspections are made of the site and all known deficiencies are corrected before work at the site.

eHASP

OSHA has developed an interactive software program (e-HASP2) that assists employers in

developing an appropriate HASP. This eTool integrates decision logic and a large chemical

database to assist the user in determining appropriate controls for site health and safety

hazards. After site-specific information has been entered, the program generates reports with

“model” language that is acceptable to OSHA in preparing a site-specific HASP.

9. What is required as a protective measure to assist in the rescue of an employee?

a. The use of a “buddy system”

b. The use of a “HARP system”

c. A worksite slope ratio of 2:1

d. A high-frequency whistle

https://www.osha.gov/dep/etools/ehasp/

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Module 2: The HAZWOPER Safety and Health Program (Continued)

In this module, we’ll continue discussing the final three elements of an effective HAZWOPER

safety and health program applied to cleanup operations.

Safety and Health Training Program

Training makes employees aware of the potential hazards they may encounter and provides the

necessary knowledge and skills to perform their work with minimal risk to their own, and other

employees’, safety and health.

All employees, managers, and supervisors working on-site exposed to hazardous substances,

health hazards, or safety hazards must receive training meeting the requirements of

1910.120(e)(1) before they are permitted to engage in hazardous waste operations that could

expose them to hazardous substances, safety, or health hazards. Also:

• Employees whose jobs put them at higher risk of exposure need more training than

those who do lower-risk jobs.

• Employees with 24 hours of off-site instruction who become general site workers — or

who are required to wear respirators — must have additional training that totals 40

hours of off-site instruction and three days of field experience.

• Employees who have successfully completed their training and field experience must

receive a written certificate; they can’t begin work at the site without one.

• Employees who have work experience or training that meets HAZWOPER initial training

requirements must be given appropriate site-specific training and have appropriate

supervised field experience at the new site.

1. According to OSHA standard 1910.120, which employee requires more training to

perform hazardous waste operations?

a. Employees whose jobs are lower-risk jobs

b. Employees whose jobs put them at higher risk of exposure

c. Regional managers that work off-site

d. The OSHA inspector reviewing the worksite

Initial Training

Employees must be trained to do their assigned duties safely before they begin work on-site.

The required training is a combination of instruction, site-specific information, and supervised

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9765

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fieldwork. The employer may send workers to an outside training organization for their

instruction, but the employer is ultimately responsible for ensuring employees are properly

trained.

The hours of initial training vary depending on a worker's duties and anticipated exposures.

Initial training must be updated with eight hours of refresher training annually. You are also

required to inform employees and contractors of the types and level of hazards associated with

your operations.

Both supervisors and employees must be trained to:

• recognize hazards and prevent them;

• select, care for, and use respirators properly, as well as other types of PPE;

• 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.

Employees also must know the names of personnel and their alternates responsible for site

safety and health. Site personnel who are expected to respond to emergency situations at the

site must receive additional training in how to respond to anticipated emergencies (e.g.,

fires/explosions, hazardous spills, etc.).

2. Before working on a hazardous waste site, what topic must both supervisors and

employees receive training on?

a. How to administer PPE fit testing procedures

b. Designing engineering controls to prevent exposure

c. Recognize hazards and prevent them

d. Writing and developing emergency response plans

Equivalent Training

Employers who can document or certify an employee's work experience and/or training is

equivalent to the training requirements detailed in 1910.120(e)(1) through (e)(4) are not

required to provide the initial training. A copy of the certification or documentation must be

provided to the employee upon request.

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Certified employees or employees with equivalent training new to a site must receive

appropriate, site specific training before site entry and have appropriate supervised field

experience at the new site.

Equivalent training includes any academic training or the training that existing employees might

have already received from actual hazardous waste site experience.

3. What training must a new employee with documented equivalent training receive?

a. 24-hours off-site training

b. 40-hours off-site training

c. Site specific training and supervised field experience

d. General training and supervised field experience

See the table below from the standard that summarizes training requirements for hazardous

waste cleanup operations.

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Table 2 – Training Requirements – Hazardous Waste Cleanup Operations

Workers [1910.120(e)(3)]

General site employees (e.g., equipment operators, general laborers, etc.) [1910.120(e)(3)(i)]

40 hours initial training

24 hours supervised field experience

8 hours annual refresher

Employees occasionally on-site for a limited task (e.g. groundwater monitoring, land surveying, etc.) with minimal exposure [1910.120(e)(3)(ii)]




Employees regularly on-site who are not exposed to health hazards [1910.120(e)(3)(iii)]




Employees under (e)(3)(ii) or (iii) who become general site workers under (e)(3)(i) [(e)(3)(iv)]

16 hours of additional training

16 hours of additional supervised field experience

Supervisors/Managers [1910.120(e)(4)]

Supervisors of general site employees (e.g., equipment operators, general laborers, etc.)



8 hours of specialized training in employer’s safety and health-related programs


Supervisors of employees occasionally on-site for a limited task (e.g., groundwater monitoring, land surveying, etc.) with minimal exposure

24 hours of initial training


8 hours specialized training in employer’s safety and health-related programs


Supervisors of employees regularly on-site who are not exposed to health hazards



8 hours specialized training in employer’s safety and health-related programs


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Employees at all sites must not perform any hazardous waste operations unless they have been

trained to the level required by their job function and responsibility, and have been certified by

a qualified trainer as having completed the necessary training.

Employees who receive the specified training must receive a written certificate upon successful

completion of training. Training need not be repeated if the employee goes to work at a new

site; however, the employee must receive the necessary additional site-specific training needed

to work safely at the new site. All employees must receive 8 hours of annual refresher training

as indicated in the table above.

4. General employees involved in hazardous waste cleanup operations must receive _____

hours of annual refresher training.

a. 8

b. 24

c. 32

d. 40

Hands-on Requirement

It is critically important for a portion of the training program to include hands-on experience

and exercises to provide trainees with an opportunity to become familiar with equipment and

safe practices in a non-hazardous setting. Traditional hands-on training is the preferred method

to ensure employees are prepared to perform these tasks safely.

The purpose of hands-on training, for example, in the donning and doffing of PPE, is twofold:

• to ensure employees have an opportunity to learn by experience, and second,

• to assess whether they have mastered the necessary skills.

5. Why is it important for trainees to receive hands-on training?

a. Hands-on training is not necessary

b. To ensure the trainees remain active and alert during the training

c. To provide trainees with an opportunity to become familiar with equipment and

safe practices in a non-hazardous setting

d. To allow trainees to compare their experiences working with hazardous waste

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Training Topics

Employees need to know about the site hazards to which they may be exposed, how to

recognize the hazards, and how to control their exposure. The best way for them to learn is

through a combination of instruction, site-specific information, and supervised fieldwork.

Employees who work at the site must have appropriate training before they begin their work.

The employer can send employees to off-site training but the employer is still responsible for

ensuring employees can apply their training to the conditions at the site. Employees need to

know:

• the names of those responsible for employee safety and health at the site

• the site’s hazards

• how to use personal protective equipment to control exposure

• how to minimize exposure risks

• medical surveillance requirements

• procedures for decontaminating clothing and minimizing exposure to hazardous substances

• procedures for responding to emergencies

• procedures for working in confined spaces

• procedures for containing leaks and spills of hazardous substances

6. What hazardous waste site-specific information do employees need to know?

a. Procedures for decontaminating clothing and minimizing exposure to hazardous

substances

b. The detailed site evaluation

c. The health and safety plan (HASP)

d. Established personnel requirements for implementing the work plan

Medical Surveillance

A medical surveillance program is required under the overall safety and health program and is

also part of the site HASP. This program helps to assess and monitor the health and fitness of

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employees working with hazardous substances. The employer must establish a medical

surveillance program for the following:

• all employees exposed or potentially exposed to hazardous substances or health hazards above permissible exposure limits (PELs) (or above published exposure levels if there is no PEL) for more than 30 days per year,

• employees who wear a respirator for 30 days or more per year on-site or as required by 1910.134,

• employees 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

• employees responsible for responding to on-site hazardous materials (HAZMAT) releases (i.e., on-site HAZMAT team).

7. As part of a health and safety plan (HASP), an employer must establish a medical

surveillance program for whom?

a. Employees who wear a respirator for 30 days or more per year on-site

b. Employees who wear a respirator for ten days or more per year on-site

c. All employees exposed to health hazards below the permissible exposure limits

(PELs)

d. Employees responsible for responding to on-site NORAD releases

All examinations must be performed by or 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 PPE under conditions that may be expected at the

worksite.

These examinations must be given as follows:

• before job assignment and annually after that (or every 2 years if a physician determines that interval is appropriate),

• at the termination of employment or reassignment to an area where medical examinations are not required,

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• as soon as possible for employees injured or who become ill from exposure to hazardous substances during an emergency, or who develop signs or symptoms of overexposure from hazardous substances, and

• at more frequent times if the examining physician believes an increased frequency is medically necessary.

8. Samuel is a general employee working on a hazardous waste site. In the middle of a shift,

he begins to feel dizzy and unsteady on his feet. When must he receive a medical

examination?

a. Within 3 business days

b. At the end of his shift

c. As soon as possible

d. After the symptoms continue for 24 hours

The employer must give the examining physician:

• a copy of the standard and its appendices,

• a description of the employee’s duties relating to his or her exposures,

• the exposure levels or anticipated exposure levels,

• a description of any personal protective and respiratory equipment used or to be used, and

• any information from previous medical examinations.

The employer must 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 PPE, and

• a statement that the employee has been informed by the physician of the results medical examination.

The physician is not to reveal, in the written opinion given to the employer, specific findings or

diagnoses unrelated to employment.

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9. What must an employer give an examining physician as part of a medical surveillance

program?

a. A copy of the employee’s performance appraisal

b. A description of each employee's duties relating to potential exposures

c. A copy of the company’s hiring practices

d. A description of hazards present at unrelated work-sites

The table below shows which employees must have medical surveillance.

Employee Category When a medical exam is required

Employees who may be exposed to hazardous substances at or above permissible exposure limits (PELs) or published exposure levels for those substances 30 or more days a year

Employees who wear a respirator for 30 or more days a year or who are required by 1910.134, Subdivision 2/I to wear a respirator.

Members of HAZMAT teams

Before assignment

Every 12 months unless the physician recommends a longer interval (not to exceed 24 months)

At termination of employment and reassignment

Immediately after reporting symptoms indicating overexposure

Employees who show symptoms of overexposure to hazardous substances

As soon as possible after an employee reports symptoms

When a physician determines an examination is necessary

Key Points About the Medical Examination:

• The examination must be performed under the supervision of a licensed physician.

• The physician must have information about the employee’s duties, exposure levels, and personal protective equipment.

• The employee must receive a copy of the physician’s written findings.

Employers should keep a record of the examination, including the employee’s name and the

physician’s written opinion regarding the employee’s medical fitness to do work or to wear a

respirator.

Employers should also be aware that there are medical surveillance requirements in other

OSHA substance-specific standards that may be applicable for individual sites where these

hazardous substances are present (e.g., lead, asbestos, and benzene). These substance- specific

standards are included under 29 CFR Part 1910 Subpart Z – Toxic and Hazardous Substances.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10147

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10. Kathy is scheduled to receive an examination as part of the medical surveillance

program. What information will a physician need to carry out the medical examination?

a. Kathy's educational history

b. The name of Kathy's supervisor

c. Kathy's duties, exposure levels, and personal protective equipment

d. Kathy's disciplinary records

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Standard Operating Procedures and Practices

Standard Operating Procedures (SOPs) are important to make sure everyone knows how to

perform the correct procedures. The SOPs below should be included in all safety and health

plans.

Hazard Control Strategies

How will employers control hazards and employee exposure at the site? Employers can control

hazards most effectively with elimination, substitution, engineering controls, barriers,

enclosures, administrative controls, safe-work practices and personal protective equipment to

protect employees.

If feasible, the employer must institute engineering controls and work practices to help reduce

and maintain employee exposure to or below permissible exposure limits.

• Examples of suitable and feasible engineering controls include the use of pressurized cabs or control booths on equipment and/or remotely operated material 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.

1. How can employers control hazards most effectively?

a. Eliminating the hazard

b. Use PPE to reduce exposure to the hazard

c. Analyzing the hazard

d. Expecting employees to have common sense and avoid any hazards that exist

Personal Protective Equipment

When engineering controls and work practices are not sufficient to reduce employee exposures

to or below established exposure limits or are not feasible for site operation, employers must

provide employees with and require the use of PPE.

PPE Program

The HAZWOPER standard further requires the employer to develop a written PPE program for

all employees involved in hazardous waste operations.

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The PPE program is:

• required under the overall safety and health program and

• included in the HASP for each of the site.

The PPE program must 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.

If employees will use personal protective equipment (which includes respirators) during

hazardous-waste operations, your written program must ensure the following:

• Equipment is selected to protect employees against site-specific hazards.

• Employees maintain and store the equipment properly.

• Employees understand the equipment’s limitations.

• Equipment is decontaminated and disposed of properly.

• Employees are trained to use, wear, and inspect equipment.

• Equipment fits employees who use it.

PPE typically includes respiratory protection, dermal protection (e.g., gloves and protective

clothing), eye protection (e.g., safety glasses, goggles, and face shields), and foot protection

(e.g., steel- toed boots and chemical-resistant booties). Employers must select and ensure

employees use PPE per 29 CFR Part 1910, Subpart I.

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10118

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2. When must employers provide employees with and require the use of PPE?

a. When using PPE is less expensive than engineering controls

b. When hazards can be eliminated

c. When administrative controls can sufficiently reduce hazards

d. When engineering controls and work practices are not sufficient to reduce

employee exposures

Levels of Protection

PPE at hazardous waste sites is often identified as a level of protection and frequently referred

to as level A, B, C, or D. Non-mandatory Appendix B to HAZWOPER provides guidelines for

selecting PPE and further discusses the levels of protection.

The bullets below summarize each level of protection.

• Level A provides the greatest level of skin, respiratory, and eye protection (e.g., totally-encapsulating chemical protective suit with self-contained breathing apparatus (SCBA)),

• Level B provides the greatest level of respiratory protection, but a lesser level of skin protection than Level A (e.g., chemical- resistant clothing with SCBA),

• Level C provides skin protection, but a lesser level of respiratory protection than Level B (e.g., chemical-resistant clothing with air-purifying respirator), and

• Level D provides only minimal protection for nuisance contamination only (e.g., general coveralls, hard hat, safety glasses, and boots).

The level of PPE, including the type of material the components are made from, will depend on:

• the types of hazardous substances present,

• their concentrations,

• the physical requirements of the task,

• the duration of the task,

• environmental conditions (e.g., heat stress), and

• the needs of the user (e.g., dexterity).

These factors may be different for each site task or operation, which is why HAZWOPER

requires PPE be evaluated for each task and not for the site as a whole.


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Hazardous conditions can quickly change, requiring a modification (e.g., upgrading or

downgrading) to the level and type of PPE to provide the protection needed for the new

conditions. For example, a backhoe hitting a pocket of contaminated soil can result in elevated

chemical concentrations requiring a possible upgrade to the level of PPE.

• When conditions exist that create the possibility of immediate death, immediate serious injury or illness, or impairment of escape, employees must be provided with the highest level of PPE.

• If the hazard is due to a chemical that poses an inhalation hazard, then a positive pressure SCBA or positive pressure air-line respirator must be used.

• If a chemical poses a severe skin hazard or is highly toxic and can be readily absorbed through the skin, then appropriate protective clothing (e.g., totally-encapsulating suit) must be worn.

In contrast, it is just as important to know when to downgrade the level and type of PPE

through exposure monitoring. Wearing too much PPE increases certain hazards such as heat

stress, physical and psychological stress, and can impair vision, mobility, and communication.

3. Level _____ PPE provides the greatest level skin, respiratory, and eye protection.

a. A

b. B

c. C

d. D

Exposure Monitoring

Airborne contaminants can present a significant threat to employee safety and health, thus it’s

important to make air monitoring an important component of an effective safety and health

program. The employer must conduct monitoring during the initial site entry at uncontrolled

hazardous waste sites to identify:

• conditions that are IDLH,

• exposures over PELs or other published exposure levels,

• exposures over a radioactive material’s dose limits, or

• other dangerous conditions, such as the presence of flammable atmospheres or oxygen-deficient atmospheres.

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Accurate information on the identification and quantification of airborne contaminants is useful

for the following:

• indicating work areas and identifying tasks and operations where exposure controls are needed,

• selecting PPE,

• assessing the potential health effects of exposure, and

• determining the need for specific medical monitoring.

AFTER a hazardous waste cleanup operation begins, the employer must 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.

The employer also must monitor for any potential condition that is IDLH or for exposures over

PELs or other published exposure levels since prior monitoring. Situations in which monitoring

is required include the following:

• work begins on a different portion of the site,

• new contaminants are being handled,

• different type of operation is initiated, and

• handling leaking drums or working in areas with obvious liquid contamination.

The employer should establish a monitoring policy that applies to conditions at the site. Briefly

describe what you are monitoring for, the monitoring equipment you will use, and how often

you will monitor. The policy must also specify the concentrations of airborne contaminants at

which you will reevaluate the effectiveness of the site’s engineering controls, safe work

practices, and PPE.

When and How to Monitor

At initial entry and when an employee suspects a hazardous condition or hazardous

atmosphere, monitor the air to identify any condition immediately dangerous to life and health

(ILDH) and hazardous exposure levels.

After the cleanup phase of a hazardous waste operation begins, use personal sampling to

monitor employees likely to have the highest exposures to hazardous substances.

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Informing Employees and Contractors

Your written program must ensure employees and contractors know about the chemical,

physical, and toxicologic properties of the hazardous substances to which they may be exposed

before they begin work at the site.

4. Why is air monitoring at uncontrolled hazardous waste sites during initial entry

necessary?

a. To identify contaminants which can present a significant threat to employee

safety and health

b. To identify permissible exposure limits (PELs)

c. To avoid potential legal expenses

d. To reduce scheduling conflicts

Handling Hazardous Materials

The handling of hazardous substance-containing drums and containers presents a variety of

potential health and safety hazards to employees such as fires/explosions, vapor generation,

and physical injury caused by moving heavy containers by hand. Thus, employers must ensure

appropriate methods, procedures, and equipment are in place that address at least the

following:

• drums and containers used during the cleanup must meet the required OSHA, EPA (40 CFR Parts 264-265 and 300), and Department of Transportation (DOT) regulations (49 CFR Parts 171-178), and must be properly inspected and labeled,

• damaged drums or containers that may rupture or spill when moved must be emptied of their contents using a device classified for the material being transferred, and must be properly discarded,

• in areas where spills, leaks, or ruptures may occur, the employer must furnish employees with salvage drums or containers, an adequate quantity of absorbent material, and approved fire-extinguishing equipment in the event of small fires,

• the employer must inform employees of the appropriate hazard warnings for 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, the moving of drums or containers must be kept to a minimum, and a program must be implemented to contain and isolate hazardous substances being transferred into drums or containers, and

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• ground penetrating systems or other detection devices must be used to estimate the location and depth of buried drums and containers.

The employer also must ensure 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 must be kept behind any existing explosion barrier.

• A physical barricade, natural or man-made that has been designed and constructed of sufficient thickness and density to withstand or deflect the impact loads of an adjacent explosion.

• Only tools or equipment that prevent ignition must be used.

• All employees not performing the operation must be located at a safe distance and behind a suitable barrier to protect them from accidental explosions.

• Also, standing on or working from drums or containers is prohibited.

Special care also must be taken when an employee handles containers of shock-sensitive waste,

explosive materials, or laboratory waste packs. When shock-sensitive wastes are handled, the

employer must ensure the following:

• Evacuate non-essential employees from the transfer area.

• Protect equipment operators from exploding containers by using a barrier.

• 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, they must not be moved onto or from the site unless appropriate containment procedures have been implemented.

• Lab packs must be opened only when necessary and only by a qualified person.

• Before shipment to a licensed disposal facility, all drums or containers must be properly labeled and packaged for shipment.

• Staging areas also must be kept to a minimum and provided with adequate access and exit routes.

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5. Manuel is moving a hazardous substance-containing drum by hand. What hazard should

Manuel be aware of before moving the drum?

a. Electrocution

b. Fire

c. Slips

d. Falls

Decontamination

Decontamination procedures are a component of the site HASP and, consequently, must be

developed, communicated to employees, and implemented before employees enter a

hazardous waste site.

As necessary, the site safety and health officer must require and monitor decontamination of

the employee and decontamination or disposal of the employee’s clothing and equipment, as

well as the substances used for decontamination, before the employee leaves the work area.

Other requirements the employer must follow are:

• If an employee’s non-impermeable clothing becomes grossly contaminated with hazardous substances, the employee must immediately remove that clothing and take a shower.

• Impermeable protective clothing must be decontaminated before being removed by the employee.

• Protective clothing and equipment must be decontaminated, cleaned, laundered, maintained, or replaced to retain its effectiveness.

• The employer must inform anyone who launders or cleans such clothing or equipment of the potentially harmful effects of exposure to hazardous substances.

• HAZWOPER requires showers and change rooms when hazardous waste cleanup operations take six months or longer to complete.

• Unauthorized employees must not remove their protective clothing or equipment from change rooms unless authorized to do so.

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6. _____ protective clothing must be decontaminated before being removed by the

employee.

a. Temporary

b. Permeable

c. Impermeable

d. Permanent

Emergency Response

Proper emergency planning and response are important elements of the site HASP that help

minimize employee exposure and injury. The standard requires the employer develop and

implement a written emergency response plan to handle possible emergencies before

performing hazardous waste site operations. Employers who will evacuate their employees

from the worksite location when an emergency occurs and who do not permit any of their

employees to assist in handling the emergency are exempt from developing an emergency

response plan. These employers must, however, develop an emergency action plan complying

with 29 CFR 1910.38 to ensure the safe evacuation of personnel.

Employers that require site personnel to respond to site emergencies must develop a written

emergency response plan that includes 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 on-site 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.

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7. When must an employer develop a written emergency response plan if performing

hazardous waste site operations?

a. When an employer does not permit any of their employees to assist in responding

to an emergency

b. When an employer requires employees to respond to site emergencies

c. It is not reasonable to assume an emergency will occur, so an emergency response

plan is never necessary

d. When off-site emergency personnel will respond to any and all emergencies

Additional Emergency Response Requirements

In addition to the above requirements, the plan must include site topography, layout, prevailing

weather conditions, and procedures for reporting incidents to local, state, and federal

government agencies. The procedures must be compatible with and integrated into the

disaster, fire, and/or emergency response plans of the sites nearest local, state, and federal

agencies.

The plan requirements also must be rehearsed regularly, reviewed periodically, and amended,

as necessary, to keep them current with new or changing site conditions or information. A

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

emergencies. The emergency plan also must be made available for inspection and copying by

employees, their representatives, OSHA personnel, and other government agencies with

relevant responsibilities.

When necessary, employees deemed must wear a positive-pressure self-contained breathing

apparatus or a positive pressure air-line respirator equipped with an escape air supply. Backup

and first-aid support personnel must be available for assistance or rescue.

8. Why must an emergency response plan be reviewed periodically?

a. To reduce the employer’s liability

b. To make the OSHA inspector happy

c. To create more work for the employer

d. To keep it current with new or changing site conditions or information

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Lighting for Employees

Employees must have enough light to do their work safely. The table below shows the minimum illumination intensities in foot-candles* for typical areas at hazardous waste operations.

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Foot-candles Work area

5 General work areas

3 Excavation and waste areas, access ways, active storage areas, loading

platforms, refueling, and field maintenance areas

5 Indoors

5 Tunnels, shafts, and general underground work areas

10 Shop areas

30 First-aid stations, infirmaries, and offices

* Illumination is commonly measured in foot-candles. One foot-candle is the illumination produced by one candle

at a distance of one foot. The most practical way to measure illumination is with a light meter.

9. What is the minimum level of lighting an employee must work with in a general work

area?

a. 3 foot-candles

b. 5 foot-candles

c. 10 foot-candles

d. 30 foot-candles

Sanitation

Your written program must include a policy that ensures potable water and appropriate toilets,

washing, and showering facilities are available at the site.

Drinking Water

Employees must have an adequate supply of drinking water at the site. Water must be supplied

from clearly labeled closed portable containers with taps. The containers can’t be used for any

other purpose. If you provide disposable cups, employees must take them from a sanitary

container and dispose of them in a separate container. Non-potable water outlets must clearly

state the water is not to be used for drinking, washing, or cooking.

Toilet Facilities

Toilet facilities must be available for employees at the site. Sites that don’t have sanitary sewers

must have chemical, recirculating, compostable, or flush toilets. Doors to toilets must have

locks that can be controlled from the inside.

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Washing Facilities

Handwashing facilities must be available for employees in work areas that expose them to

contaminants that could harm them.

Shower Facilities

Shower facilities and change rooms must be available at the site if employees do cleanup work

for at least six months and they may be exposed to hazardous substances. Showers and change

rooms must meet the sanitation requirements of 1910.141, General environmental controls,

and must be in areas with exposures below permissible exposure limits and published exposure

levels. Employees must shower at the end of their work shifts or before they leave the site.

Sleeping Facilities

When sleeping quarters are provided, they must be heated. Washing facilities for all employees

must be near the worksite, within controlled work zones, and equipped to enable employees to

remove hazardous substances. The employer also must ensure food service facilities are

licensed.

10. To ensure proper sanitation, what must drinking water be supplied from?

a. Re-used plastic bottles

b. Unlabeled, open stationary containers

c. Labeled, closed portable containers with taps

d. Non-potable water outlets

New Technology Plan

“New technology” in HAZWOPER refers to products and equipment introduced by

manufacturers to protect workers who do hazardous-waste cleanup operations. New

technology for improving the protection of employees on worksites must be evaluated and

implemented by employers. Examples of such equipment may include:

• new foams,

• absorbents, and

• neutralizers that can be used to decrease the level of exposures to hazardous substances.

It is important new technologies, equipment, or control measures be evaluated by the

employer to determine the effectiveness of employee protection before being implemented

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on-site. Manufacturer and supplier information should be reviewed by the employer as part of

the evaluation and included in the written safety and health program.

11. What is “New Technology” as defined in HAZWOPER?

a. The latest computer system the administration department is using to streamline

employee scheduling

b. Products and equipment the employer has used for many years but has not been

evaluated to determine the effectiveness of employee protection

c. The latest smart phone

d. Products and equipment introduced by manufacturers to protect workers who do

hazardous-waste cleanup operations.

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Module 4: Planning and Organization

Introduction

Adequate planning is the first and the most critical element of hazardous waste site activities.

By anticipating and taking steps to prevent potential hazards to health and safety, work at a

waste site can proceed with minimum risk to workers and the public.

Three aspects of planning are discussed in this module:

1. developing an overall organizational structure for site operations;

2. establishing a comprehensive Work Plan that considers each specific phase of the

operation; and

3. developing and implementing a Site Safety and Health Plan.

The organizational structure should identify the personnel needed for the overall operation,

establish the chain-of-command, and specify the overall responsibilities of each employee. The

Work Plan should establish the objectives of site operations and the logistics and resources

required to achieve the goals. The Site Safety Plan should determine the health and safety

concerns for each phase of the operation and define the requirements and procedures for

worker and public protection.

A fourth important aspect of planning is coordinating with the existing response community. A

national response organization was established by a congressionally mandated National

Contingency Plan to implement procedures for coordinating response to releases of hazardous

substances into the environment. This National Contingency Plan establishes response teams

composed of representatives of federal agencies and state and local governments. A

particularly important contact for hazardous waste site activities is the EPA-designated official

responsible for coordinating federal activities related to site cleanup.

Planning should be viewed as an ongoing process: the cleanup activities and Site Safety Plan

must be continuously adapted to new site conditions and new information.

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1. What does the National Contingency Plan establish?

a. Response teams composed of representatives of federal agencies and state and

local governments

b. Federal funding for Brownfield sites

c. Federal requirements for closing nuclear reactors

d. Congressional oversight of building projects

Organizational Structure

An organizational structure that supports the overall objectives of the project should be

developed in the first stage of planning. This structure should:

• Identify a leader who has the authority to direct all activities.

• Identify the other personnel needed for the project, and assign their general functions and responsibilities.

• Show lines of authority, responsibility, and communication. Identify the interface with the response community.

As the project progresses, it may be necessary to modify some organizational aspects of the

project, such as personnel responsibilities and authorities, so individual tasks can be performed

as efficiently and safely as possible. Any changes to the overall organizational structure must

be recorded in the appropriate parts of the Work or Site Safety Plans that are developed for

individual phases or tasks and must be communicated to all parties involved.

The figure below presents one example of an organizational framework for a hazardous waste

site response team. It shows the lines of authority for 24 categories of off-site and on-site

personnel. The on-site categories are divided into personnel that are essential for a safe and

efficient response, and optional personnel that may be desirable in a large operation where

responsibilities can be delegated to a greater number of people. As-needed personnel are

specialists that are called upon for specific tasks, either off-site or on-site.

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General Approach to Personnel Organization for Site Investigation and Response.

Regardless of the size of the effort, all response teams should include a Site Safety and Health

Officer responsible for implementing health and safety requirements. The Site Safety Officer

should have ready access to other occupational health and safety professionals, particularly an

industrial hygienist. Once an organizational system has been developed, all individuals

responsible for establishing and enforcing health and safety requirements should be identified,

and their respective authorities clearly explained to all members of the response team.

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2. What position should hazardous waste site response teams include for implementing

health and safety requirements?

a. Security officer

b. Bomb squad expert

c. Site Safety and Health Officer

d. Record-keeper

Leadership and Commitment

One of the most critical elements in worker safety is the attitude of all levels of project

management. A strong and visible commitment to worker safety must be present from the

beginning of a project. This initial attitude sets the tone for the entire operation.

The Site Safety Officer and the Project Team Leader must have the clear support of senior-level

management for establishing, implementing, and enforcing safety programs from the outset of

the project.

The importance of management's attitude toward safety throughout the project cannot be

overemphasized; site personnel are more likely to cooperate with safety programs if they sense

a genuine concern on the part of management.

Several organizational factors are indicators of successful worker safety programs. These

factors include:

• Strong management commitment to safety, as defined by various actions reflecting management's support and involvement in safety activities.

• Close contact and interaction among workers, supervisors, and management enabling open communication on safety as well as other job-related matters.

• A high level of housekeeping, orderly workplace conditions, and effective environmental quality control.

• Well-developed selection, job placement, and advancement procedures plus other employee support services.

• Training practices emphasizing early indoctrination and follow-up instruction in job safety procedures.

• Added features or variations in conventional safety practices that enhance the effectiveness of those practices.

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• Effective disciplinary plan to encourage employees to adhere to safety practices.

3. What organizational factor is an indicator of a successful worker safety program?

a. Company productivity

b. Worker retention

c. Zero injury policy

d. Strong management commitment to safety

Roles and Responsibilities

The following is a detailed description of the roles and responsibilities for the off-site and on-

site positions listed in the figure in Section 4.2. The on-site categories are divided into

personnel that are essential for a safe and efficient response, and optional personnel that may

be desirable in a large operation where responsibilities can be delegated to a greater number of

people. As-needed personnel are specialists that are called upon for specific tasks, either off-

site or on-site.

Off-site Personnel Positions

Senior-level Management defines project objectives, allocates resources, determine chain-of-

command, and evaluates program outcome. Specific responsibilities include:

• providing necessary facilities, equipment, funding, personnel, time, and resources to conduct activities safely

• supporting the efforts of on-site management and provides disciplinary action

Multi-disciplinary Advisors includes representatives from upper management, field team

member, and experts in chemistry, engineering, law, industrial hygiene, information/public

relations, medicine, pharmacology, physiology, radiation health, physics, and toxicology.

Specific responsibilities include providing advice on the design of the Work Plan and Site Safety

Plan.

Medical Support includes consulting physicians, medical personnel at local hospitals and clinics

and ambulance personnel. Specific responsibilities include:

• becoming familiar with types of materials on-site, the potential for worker exposure, and recommend the medical program for the site

• providing emergency treatment and decontamination procedures for specific exposures

• obtaining drugs, equipment, and supplies to treat exposures

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• providing emergency procedures appropriate to hazards

4. Which off-site personnel is responsible for providing the necessary equipment to

perform hazardous waste operations?

a. Senior-level management

b. Multi-disciplinary advisors

c. Medical support

d. Front-line workers

Essential On-site Personnel Positions

Project Team Leader reports to upper-level management and has the authority to direct

response operations. Project team leaders assume total control over site activities. Specific

responsibilities include:

• preparing and organizing the background review of the situation, the Work Plan, the Site Safety Plan, and the field team

• obtaining permission for site access and coordinates activities with appropriate officials

• ensuring the Work Plan is completed and on schedule

• briefing the field teams on specific assignments

• using the Site Safety and Health Officer to ensure safety and health requirements are met

• preparing the final report and support files on the response activities

• serving as the liaison with public officials

Site Safety and Health Officer (hereinafter referred to as Site Safety Officer in accordance with

common usage) advises the Project Team Leader on all aspects of health and safety on site, and

recommends stopping work if any operation threatens work or public health or safety. Specific


• selecting protective clothing and equipment

• periodically inspecting protective clothing and equipment

• ensuring protective clothing and equipment are properly stored and maintained

• controlling entry and exit at the access control points

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• coordinating safety and health program activities with the Scientific Advisor

• confirming each team member’s suitability for work based on a physician’s recommendation

• monitoring the work parties for signs of stress, such as cold exposure, heat stress, and fatigue

• monitoring on-site hazards and conditions

• participating in the preparation of and implements the Site Safety Plan

• conducting periodic inspections to determine if the Site Safety plan is being followed

• enforcing the “buddy” system

• knowing emergency procedures, evacuation routes, and the telephone numbers of the ambulance, local hospital, poison control center, fire department, and police department

• when necessary, notifying local public emergency officials

• coordinating emergency medical care

The Field Team Leader may be the same person as the Project Team Leader and may be a

member of the work party. Field team leaders are responsible for field team operations and

safety. Specific responsibilities include:

• managing field operations

• executing the Work Plan and schedule

• enforcing safety procedures

• coordinating with the Site Safety Officer in determining protection level

• enforcing site control

• documenting field activities and sample collection

• serving as liaison with public officials

The Command Post Supervisor may be the same person as the Field Team Leader. Command

Post Supervisors are responsible for communications and emergency assistance. Specific


• notifying emergency response personnel by telephone or radio in the event of an emergency

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• assisting the Site Safety Officer in rescue, if necessary

• maintaining a log of communication and site activities

• assisting other field team members in the clean areas, as needed

• maintaining line of sight and communication contact with the work parties via walkie-talkies, signal horns, or other means

Decontamination Station Officer(s) are responsible for decontamination procedures,

equipment, and supplies. Specific responsibilities include:

• setting up decontamination lines and the decontamination solutions appropriate for the type of chemical contamination on-site

• controlling the decontamination of all equipment, personnel, and samples from the contaminated areas

• assisting in the disposal of contaminated clothing and materials

• ensuring all required equipment is available

• advising medical personnel of potential exposures and consequences

Rescue Teams are primarily used on large sites with multiple work parties in the contaminated

area. Specific responsibilities include:

• standing by, partially dressed in protective gear, near hazardous work areas

• rescuing any worker whose health or safety is endangered

The Work Party should consist of at least two people. Depending on the size of the field team,

any or all the field team may be in the Work Party. Specific responsibilities include:

• safely completing the on-site tasks required to fulfill the Work Plan

• complying with the Site Safety Plan

• notifying Site Safety Officer or supervisor of unsafe conditions

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5. The ____ is responsible for safely completing on-site tasks required to fulfill the Work

Plan.

a. Site safety and health officer

b. Field team leader

c. Work party

d. Decontamination station officer

On-site Optional Personnel Positions

The Scientific Advisor guides the Project Team Leader in scientific matters. Specific

responsibilities include providing advice for:

• field monitoring

• scientific studies

• sample collection

• data interpretation

• sample analysis

• remedial plans

The Logistics Officer plans and mobilizes the facilities, materials, and personnel required for the

response.

Photographers photograph site conditions and archive photographs.

The Finance/Contracting Officer provides financial and contractual support.

The Public Information Officer releases information to the news media and the public

concerning site activities.

The Security Officer manages site security.

The Recordkeeper maintains the official records of site activities.

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6. Which optional on-site personnel is responsible for releasing information to the news

media and public concerning site activities?

a. Scientific advisor

b. Logistics officer

c. Public information officer

d. Security officer

As Needed Personnel

Bomb Squad Explosion Experts advise on methods of handling, detonating, or disposing of

explosive materials.

Communication Personnel includes civil defense organizations, local radio and television

stations, and local emergency service networks. Specific responsibilities include:

• providing communication to the public in the event of an emergency

• providing communication links of mutual aid

Environmental Scientists are consultants from industry, government, universities or other

groups. Specific responsibilities include:

• predicting the movement of released hazardous materials through the atmosphere, geologic, and hydrologic environment

• assessing the effect of this movement on air, groundwater, and surface water quality

• predicting the exposure of people and the ecosystem to the materials

Evacuation Personnel consists of federal, state, and local public safety organizations. Specific


• helping to plan for public evacuation

• mobilizing transit equipment

• assisting in public evacuation

Firefighters respond to on-site fires, stand-by for response to potential fires, and perform

rescues.

Hazard Chemical Experts are consultants from industry, government, universities, or other

groups. Specific responsibilities include:

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• advising on properties of on-site materials, contaminant control methods, and dangers of chemical mixtures

• providing immediate advice to those at the scene of a chemical-related emergency

Health Physicists evaluate radiation health hazards and recommend appropriate action.

Industrial Hygienists conduct health hazard assessments, advise on health protection, and

conduct monitoring tests to determine exposure to hazardous substances.

Meteorologists provide meteorological information.

Public Safety Personnel includes county sheriff, industrial security forces, National Guard,

police, etc. Public safety personnel controls access to the site.

Toxicologists advise on toxicological properties and health effects of substances on site.

Additionally, toxicologists provide recommendations on protection of worker health.

7. Which “as-needed” off-site personnel is responsible for providing advice on methods of

handling explosive materials?

a. Bomb squad explosion experts

b. Environmental scientists

c. Evacuation personnel

d. Hazardous chemical experts

Work Plan

Develop a work plan describing anticipated cleanup activities before beginning on-site response

actions. The Work Plan should be periodically reexamined and updated as new information

about site conditions is obtained.

The following steps should be taken in formulating a comprehensive Work Plan:

• Review available information, including:

o site records,

o waste inventories,

o generator and transporter manifests,

o previous sampling and monitoring data,

o site photos, and

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o state and local environmental and health agency records.

• Define work objectives.

• Determine methods for accomplishing the objectives (e.g., sampling plan, inventory, disposal techniques).

• Determine personnel requirements.

• Determine the need for additional training of personnel. Evaluate their current knowledge/skill level against the tasks they will perform and situations they may encounter.

• Determine equipment requirements. Evaluate the need for special equipment or services, such as drilling equipment or heavy equipment and operators.

Preparing the Work Plan requires a multidisciplinary approach including input from all levels of

on-site and off-site management. Consultants may be useful in developing sections of the

Work Plan; for example, chemists, occupational health and safety professionals, and

statisticians may be needed to develop the sampling plan.

8. How often should the Work Plan be reexamined and updated?

a. There is no requirement to update the Work Plan

b. Periodically, as information about site conditions change

c. Monthly

d. Once every six months

Site Safety Plan

A Site Safety Plan establishes policies and procedures to protect workers and the public from

the potential hazards posed by a hazardous waste site. It must be developed before site

activities proceed. Important aspects of the site safety plan include:

• The Site Safety Plan must provide measures to minimize accidents and injuries that may occur during normal daily activities or during adverse conditions such as hot or cold weather.

• The Site Safety Plan should be modified as needed for every stage of site activity.

• Because planning requires information, planning and site characterization should be coordinated.

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• An initial Site Safety Plan should be developed so the preliminary site assessment can proceed safely.

• The information from this assessment can then be used to refine the Site Safety Plan so further site activities can proceed safely.

• Plans should be revised whenever new information about site hazards is obtained.

Development of a Site Safety Plan should involve both the off-site and on-site management and

be reviewed by occupational and industrial health and safety experts, physicians, chemists, or

other appropriate personnel.

At a minimum, the plan should:

• Name key personnel and alternates responsible for site safety.

• Describe the risks associated with each operation conducted.

• Confirm personnel are adequately trained to perform their job responsibilities and to handle the specific hazardous situations they may encounter.

• Describe the protective clothing and equipment to be worn by personnel during various site operations.

• Describe any site-specific medical surveillance requirements.

• Describe the program for periodic air monitoring, personnel monitoring, and environmental sampling, if needed.

• Describe the actions to be taken to mitigate existing hazards (e.g., containment of contaminated materials) to make the work environment less hazardous.

• Define site control measures and include a site map. Establish decontamination procedures for personnel and equipment.

• Set forth the site's Standard Operating Procedures (SOPs). SOPs are those activities that can be standardized (such as decontamination and respirator fit testing), and where a checklist can be used. These procedures should be:

o prepared in advance.

o based on the best available information, operational principles, and technical guidance.

o field-tested by qualified health and safety professionals, and revised as appropriate.

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o appropriate to the types of risk at that site. Formulated to be easy to understand and practice.

o provided in writing to all site personnel, who should be briefed on their use.

o included in training programs for site personnel.

• Set forth a Contingency Plan for safe and effective response to emergencies.

9. A Site Safety Plan establishes _____ to protect workers and the public from the

potential hazards posed by a hazardous waste site.

a. corrective action plans

b. fines and penalties

c. policies and procedures

d. a minimum exposure threshold

Safety Meetings and Inspections

To ensure the Site Safety Plan is being followed, the Site Safety Officer should conduct a safety

meeting before initiating any site activity and before and after each work day. The purpose of

these safety meetings is to:

• Describe the assigned tasks and their potential hazards. Coordinate activities.

• Identify methods and precautions to prevent injuries.

• Plan for emergencies.

• Describe any changes in the Site Safety Plan.

• Get worker feedback on conditions affecting safety and health. Get worker feedback on how well the Site Safety Plan is working.

The Site Safety Officer should also conduct frequent inspections of site conditions, facilities,

equipment, and activities to determine whether the Site Safety Plan is adequate and being

followed.

At a hazardous waste site, risks to workers can change quickly and dramatically when there are

changes in:

• work and other site activities

• state of degradation of containers and containment structures. State of equipment maintenance

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• weather conditions

The following guidelines should be observed to make safety inspections effective:

• Develop a checklist for each site, listing the items that should be inspected.

• Review the results of these inspections with supervisors and workers.

• Re-inspect any identified problems to ensure they have been corrected.

• Document all inspections and subsequent follow-up actions.

• Retain records until site activities are completed and as required by regulatory agencies.

The minimum frequency at which inspections should occur varies with the characteristics of the

site and the equipment used on-site. Factors that need to be considered are:

• the severity of risk on-site

• regulatory requirements

• operation and maintenance requirements

• the expected effective lifetime of clothing, equipment, vehicles, and other items

• recommendations based on professional judgment, laboratory test results, and field experience

10. How can risks to workers of a hazardous waste site change suddenly?

a. The number of employees on the site is reduced

b. When there are changes in weather conditions

c. The number of emergency responders increases

d. When the site safety officer is conducting on-site inspections

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Module 5: Training

Introduction

Anyone who enters a hazardous waste site must recognize and understand the potential

hazards to health and safety associated with the cleanup of that site. Personnel actively

involved in cleanup must be thoroughly familiar with programs and procedures contained in the

Site Safety Plan and must be trained to work safely in contaminated areas. Visitors to a site

must receive adequate training on hazard recognition and on the site's Standard Operating

Procedures to enable them to conduct their visit safely.

The objectives of training programs for employees involved in hazardous waste site activities

are:

• To make workers aware of the potential hazards they may encounter.

• To provide the knowledge and skills necessary to perform the work with minimal risk to worker health and safety.

• To make workers aware of the purpose and limitations of safety equipment.

• To ensure workers can safely avoid or escape from emergencies.

The level of training provided should be consistent with the worker's job function and

responsibilities. The training should help employees gain adequate knowledge, skills, and

experience in their duties.

1. Knowledge. The training program should involve classroom/online instruction and on-

the-job instruction in a wide range of health and safety topics.

2. Skills. Hands-on practice to gain skills should consist of drills in the field that simulate

site activities and conditions.

3. Experience. On-site experience is gained under the direct supervision of trained,

experienced personnel.

All training information should be presented in clear, concise language. Particularly important

information, such as the Standard Operating Procedures, should be provided in writing. A

variety of teaching aids (i.e., films, tapes, slides, etc.) should be used, and lecture sessions

should be interspersed with class participation and hands-on training. All employees should

also complete refresher training, at least annually, to reemphasize the initial training and to

update workers on any new policies or procedures.

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1. An objective of a safety training program for employees involved in hazardous waste

site activities is?

a. To build up the employees’ confidence to the point they believe they don’t have

to worry about the work-site hazards

b. To supply the workers with their ID badges and acquaint them with the check-in

process

c. To provide the knowledge and skills necessary to perform the work with minimal

risk to worker health and safety

d. To ensure workers can begin working as soon as possible

Training Programs

Employees should not engage in field activities until they have been trained to a level

commensurate with their job function and responsibilities and with the degree of anticipated

hazards. Specific recommendations for the areas to be covered in training sessions are given in

the table below.

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Recommended Training by Job Category

Training Topics Emphasis of

Training

General Site

Worker

On-site

Management

&

Supervisors

Health &

Safety Staff Visitors

Biology,

Chemistry,

Physics of

Hazardous

Materials

Chemical and

physical properties;

chemical reactions;

chemical

compatibilities.

Recommended Recommended Recommended

Toxicology Dosage, routes of

exposure, toxic

effects, immediately

dangerous to life or

health (IDLH) values,

permissible

exposure limits

(PELs),

recommended

exposure limits

(RELs), threshold

limit values (TLVs)


Industrial

Hygiene

Selection and monitoring of personal protective clothing and equipment.

Calculation of doses

and exposure levels;

evaluation of

hazards; selection of

worker health and

safety protective

measures.

Recommended Recommended

OSHA Worker

Rights

Applicable provisions

of Title 29 CFR OSH

act.


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Monitoring

Equipment

Functions,

capabilities,

selection, use,

limitations, and

maintenance.


Hazard

Evaluation

Techniques of

sampling and

assessment.

Evaluation of field

and lab results. Risk

assessment.

Recommended

Optional

Recommended

Optional

Site Safety Plan Safe practices, safety

briefings and

meetings, Standard

Operating

Procedures, site

safety map.

Recommended Recommended Recommended Recommended

Standard

Operating

Procedures

(SOPs)

Hands-on practice.

Development and

compliance.


Engineering

Controls

The use of barriers,

isolation, and

distance to minimize

hazards.


Personal

Protective

Equipment (PPE)

Assignment, sizing,

fit-testing,

maintenance, use,

limitations, hands-on

practice.

Selection of PPE.

Ergonomics


Optional

Recommended

Recommended

Recommended

Recommended

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Medical Program Medical monitoring,

first aid, stress

recognition

Advanced first aid,

cardiopulmonary

resuscitation (CPR);

emergency drills

Design, planning and

implementation

Recommended

Optional

Recommended

Recommended

Recommended

Recommended

Recommended

Decontamination Hands-on training

using simulated field

conditions


Legal and

Regulatory

Aspects

Applicable safety

and health

regulations (OSHA,

EPA, etc.)

Optional Recommended Recommended

Emergencies Emergency help and

self-rescue;

emergency drills

Response to

emergencies; follow-

up investigation and

documentation


Recommended

Recommended

Recommended

2. Decontamination training is recommended for general site workers, on-site supervisors,

and health and safety staff.

a. True

b. False

Training for General Site Workers

General site workers, such as equipment operators, general laborers, technicians, and other

supervised personnel, should attend training sessions that apply to their individual jobs and

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responsibilities, as well as training sessions that provide an overview of the site hazards and the

means of controlling those hazards. Their training should include instruction in the following

subject areas, depending on their individual jobs:

• Site Safety Plan

• safe work practices

• nature of anticipated hazards

• handling emergencies and self-rescue

• rules and regulations for vehicle

• safe use of field equipment

• handling, storage, and transportation of hazardous materials

• employee rights and responsibilities

• use, care, and limitations of personal protective clothing and equipment

• safe sampling techniques

3. General site worker training should include instruction in which of the following subject

areas?

a. Techniques of sampling and assessment

b. Handling, storage, and transportation of hazardous materials

c. Evaluation of field and lab results

d. Calculation of doses and exposure levels

Field Activities Requirement

In addition to instruction, general site workers must engage in three days of actual field

activities under the direct supervision of a trained, experienced supervisor.

Some general site workers who may be exposed to unique hazards or who may occasionally

supervise others should receive additional training in the following subject areas:

• site surveillance

• Site Safety Plan development

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• use and decontamination of fully encapsulating personal protective clothing and equipment

• use of instruments to measure explosivity, radioactivity, etc. Safe use of specialized equipment

• topics specific to identified site activities

On-site management and supervisors, such as Project Team Leaders, who are responsible for

directing others, should receive the same training as the general site workers for whom they

are responsible, as well as additional training to enhance their ability to provide guidance and

make informed decisions. This additional training should include:

• management of hazardous waste site cleanup operations.

• management of the site work zones.

• how to communicate with the press and local community.

Health and safety staff with specific responsibilities for health and safety guidance on-site

should be familiar with the training provided to general site workers and their supervisors and

should receive advanced training in health and safety issues, policies, and techniques.

Visitors to the site (including elected and appointed officials, reporters, senior-level

management, and other interested parties) must also receive a briefing on safety. These

visitors should not be permitted in the Exclusion Zone unless they have been fit- tested, and

medically approved for respirator use. All other visitors should not enter the Exclusion Zone;

rather, they should observe site conditions from the clean area, e.g., using binoculars.

4. In addition to instruction, general site workers must engage in ___ days of actual field

activities under the direct supervision of a trained, experienced supervisor.

a. one

b. two

c. three

d. four

Emergency Responder Training

Emergency responders must be trained before their participation in emergency response

operations. Their training must be based on the functions and duties the responders will be

expected to perform. For example:

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• If an employee is simply expected to notify the emergency response team upon

discovery of an emergency release and evacuate from the area, the employee would be

trained to the first responder awareness level; or

• If an employee who is responding initially in a defensive manner for the purpose of

protecting nearby persons, property, or the environment from the effects of the release,

but does not approach the point of release, the employee would be trained to the first

responder operations level.

• if the employee is expected to approach the point of release to stop the release, the

employee would minimally need to be trained to the HAZMAT technician level.

• If an employee is expected to have more direct and specific knowledge of the various

hazardous substances and to assist the HAZMAT technician in the response, the

employee would minimally need to be trained to the HAZMAT specialist level.

Consequently, employers must evaluate the roles and tasks employees will perform and train

them appropriately.

In addition to the training levels established in the standard for emergency responders, two

additional personnel classifications are provided:

• Skilled support personnel (SSP). SSP are employees who are needed to temporarily

perform immediate emergency support work (e.g., excavator operators). SSP must be

provided an initial site briefing covering PPE use, the chemical hazards involved, and the

tasks to be performed.

• Specialist employees. Specialist employees are those who, during their regular job

duties, work with and are trained in the hazards of specific hazardous substances. They

may be called upon to provide technical advice or assistance at a hazardous substance

release incident.

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5. John works at a hazardous waste site as a general worker. If he discovers an emergency

release, he is expected to notify the emergency response team and evacuate the area.

What level of emergency responder training should John receive?

a. First responder awareness-level

b. First responder operations-level

c. HAZMAT technician-level

d. HAZMAT specialist-level

Emergency Response Trainer Qualifications

Trainers who teach any of the training subjects must have either:

• completed a training course on the subjects they are expected to teach, or

• they must have the training and/or academic credentials and instructional experience to demonstrate competent teaching skills.

Employees need not necessarily receive a certificate, but the employer must certify training

with some form of documentation. (Note: the HAZWOPER standard does not contain a specific

certification requirement for Awareness Level training). It is considered good practice to

provide employees with a training certificate as well as to document the training in the

employer’s records. The employer also must document in its ERP its training plan for personnel

who respond to hazardous substance incidents.

6. What qualifies an emergency response trainer to teach any of the training subjects?

a. Completed 8 hours of GHS training

b. Received 6 hours of HAZCOM training

c. Watched a response to an emergency once

d. Completed a training course on the subjects they are expected to teach

Minimum training for emergency responders is summarized below:

Responder Category Responder Tasks Minimum Training

Skilled support personnel Skilled equipment operators needed to perform emergency-support work.

Initial briefing covering hazards, PPE, and duties at the scene

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Specialist employees Provide technical assistance or advice on specific hazardous substances

Annual refresher training, or ability to demonstrate competency in their specialty

LEVEL 1: first responder, awareness level

Likely to witness or discover a hazardous substance release and initiate the emergency-response notification process

Training to identify emergencies and initiate the response process

Additional LEVEL 1 competencies, [See 1910.120(q)(6)(i)]

Annual refresher training

LEVEL 2: first responder, operations level

Responds to releases of hazardous substances; contains the release from a safe distance but is not involved in stopping the release; protects nearby persons, property, or the environment from the effects of the release

Eight hours of training that includes LEVEL 1 awareness training or the equivalent relevant experience

Additional LEVEL 2 competencies, [See 1910.120(q)(6)(ii)]


LEVEL 3: HAZMAT technician Responds to releases of hazardous substances; attempts to stop the release

Twenty-four hours of LEVEL 2 training

Additional LEVEL 3 competencies [See 1910.120(q)(6)(iii)]


LEVEL 4: HAZMAT specialist Supports the HAZMAT technician; acts as a government liaison during an emergency


Additional LEVEL 4 competencies [See 1910.120(q)(6)(iv)]


On-scene incident commander Implements the incident command system and the emergency-response plan


Additional on-scene incident commander competencies [See 1910.120(q)(6)(v)]


Trainers Instructs any of the above employees

Satisfactory completion of courses in the subjects they will teach

Record of Training

A record of training should be maintained in each employees personnel file to confirm every

person assigned to a task has had adequate training for that task, and every employee's training

is up-to-date.

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7. What should be maintained in each employee's personnel file to confirm they received

adequate training?

a. Disciplinary actions

b. A record of training

c. The employee’s pay history

d. The employee’s honor code agreement

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Acronyms

BBP Bloodborne Pathogens

CERCLA Comprehensive Environmental Response, Compensation, and Liability Act of 1980

CESQGs Conditionally Exempt Small Quantity Generators

CFR Code of Federal Regulations

DHS Department of Homeland Security

DOT Department of Transportation

EPA Environmental Protection Agency

ERP Emergency Response Plan

HASP Health and Safety Plan

HAZMAT Hazardous Materials

HAZWOPER Hazardous Waste Operations and Emergency Response

HCS Hazard Communication Standard

ICS Incident Command System

IDLH Immediately Dangerous to Life or Health

MSDS Material Safety Data Sheet

NIMS National Incident Management System

NPL National Priority List

OSHA Occupational Safety and Health Administration

PEL Permissible Exposure Limit

PPE Personal Protective Equipment

RCRA Resource Conservation and Recovery Act of 1976

SARA Superfund Amendments and Reauthorization Act of 1986

SCBA Self-contained breathing apparatus

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SHARP Safety and Health Achievement Recognition Program

SSP Skilled Support Personnel

TSD Treatment, Storage, and Disposal

TRI Toxic Release Inventory

UST Underground storage tank

VPP Voluntary Protection Programs

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Glossary

Brownfield real property where expansion or redevelopment is complicated by actual or

perceived environmental contamination. A brownfield cannot be the subject of planned or on-

going removal actions, posted or proposed for listing on the National Priority List, the subject of

an administrative court order under solid and hazardous waste laws, the subject of corrective

actions or closure requirements, or a federal facility.

Buddy system a system of organizing employees into work groups so each employee of the

work group is observed by at least one other employee in the work group. The purpose of the

buddy system is to ensure immediate assistance to employees in an emergency.

CERCLA see Comprehensive Environmental Response, Compensation, and Liability Act

Chain of command links one person with overall responsibility for managing an emergency to

others responsible for carrying out specific emergency-response tasks.

Clean-up operation hazardous substances are removed, contained, incinerated, neutralized,

stabilized, cleaned-up to make a site safer for people or the environment.

Comprehensive Environmental Response, Compensation, and Liability Act (also Superfund)

Federal legislation provided broad federal authority to respond directly to releases or

threatened releases of hazardous substances that may endanger public health or the

environment. CERCLA was amended by the Superfund Amendments and Reauthorization Act

(SARA).

Conditionally exempt small-quantity generator is a generator of 220 pounds or less of

hazardous waste per month; has less burdensome record keeping and reporting requirements

than small quantity generators or large quantity generators.

Decontamination removal of hazardous substances from employees and equipment.

Emergency action plan Oregon OSHA requirement Subdivision 2/E, 437-002-0042, for

responding to emergencies such as fires, toxic substance releases, severe weather, and

flooding.

Emergency response is a response by employees from outside an immediate release area or by

other designated responders to an uncontrolled release of a hazardous substance. Responses

to incidental releases of hazardous substances in which the substance can be absorbed,

neutralized, or otherwise controlled at the time of release by employees in the immediate

release area or by maintenance personnel, are not considered emergency responses within the

scope of HAZWOPER.

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Emergency response operation response to a hazardous waste spill or leak.

Environmental Protection Agency (EPA) federal agency whose mission is to protect human

health and the environment.

EPA Title 40, Code of Federal Regulations (CFR), 261.3 definition of hazardous waste.

EPA Title 40, Code of Federal Regulations (CFR), 261.5 special requirements for hazardous

waste generated by conditionally exempt small quantity generators.

EPA Title 40, Code of Federal Regulations (CFR), 262.34 standards applicable to generators of

hazardous waste, accumulation time.

Facility a building or a site where a hazardous substance has been deposited; facility refers to

hazardous waste generators, TSD facilities, and designated recycling facilities.

Generator an owner, manager, or controller of a facility that creates hazardous waste.

Hazardous materials response team (HAZMAT) an organized group of employees, designated

by their employer, that controls hazardous substance leaks or spills. A HAZMAT team is not a

fire brigade nor is a fire brigade, necessarily a HAZMAT team. A HAZMAT team may be a

separate component of a fire brigade or fire department.

Hazardous substance a substance defined under HAZWOPER 1910.120(a)(3)(A)-(D); a

substance defined under section 9601(14) of CERCLA; an agent that can cause death, disease,

or other adverse health effects in humans; a substance listed by the U.S. Department of

Transportation as a hazardous material under 49 CFR 172.101.

Hazardous waste is waste or combination of wastes as defined in Title 40, CFR 261.3;

substances defined as hazardous wastes in Title 49 CFR 171.8.

Hazardous waste generator see Generator.

Hazardous waste operation any operation conducted within the scope of HAZWOPER

1910.120.

Hazardous Waste Operations and Emergency Response standard (HAZWOPER) 29 CFR

1910.120 Rules.

Hazardous waste site an area contaminated by hazardous waste that poses a risk to human

health or the environment.

HAZMAT see Hazardous materials response team

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HAZWOPER see Hazardous Waste Operations and Emergency Response standard

Health hazard means a chemical or a pathogen where acute or chronic health effects may

occur in exposed employees. It also includes stress due to temperature extremes. The term

health hazard includes chemicals that are classified in accordance with the Hazard

Communication Standard, 29 CFR 1910.1200, as posing one of the following hazardous effects:

idirritation; respiratory or skin sensitization; germ cell mutagenicity; carcinogenicity;

reproductive toxicity; specific target organ toxicity (single or repeated exposure); aspiration

toxicity or simple asphyxiant. (See Appendix A to § 1910.1200—Health Hazard Criteria

(Mandatory) for the criteria for determining whether a chemical is classified as a health hazard.)

Immediately dangerous to life or health (IDLH) an atmospheric concentration of any toxic,

corrosive, or asphyxiant substance that poses an immediate threat to life, would cause

irreversible or delayed adverse health effects, or would interfere with an individual’s ability to

escape from a dangerous atmosphere.

Interim status authorization granted by the EPA that allows a TSD facility to continue operating

pending review and decision of the facility’s permit application.

Large-quantity generator is a generator of more than 2,200 pounds of hazardous waste in one

month, more than 2.2 pounds of acutely hazardous waste in one month, or more than 220

pounds of debris containing acutely hazardous waste in one month.

Oxygen deficiency the concentration of oxygen by volume below which atmosphere supplying

respiratory protection must be provided. The percentage of oxygen by volume is less than 19.5

percent oxygen.

Permissible exposure limit (PEL) the exposure, inhalation, or dermal exposure limits specified

in 1910 Subdivision 2/G (Occupational Health and Environmental Controls) and 1910

Subdivision 2/Z (Toxic and Hazardous Substances).

Post-emergency response means that portion of an emergency response performed after the

immediate threat of a hazardous substance release has been stabilized or eliminated and

cleanup of the site has begun.

Published exposure level the exposure limits published in “NIOSH Recommendations for

Occupational Health Standards” or, exposure limits specified by the American Conference of

Governmental Industrial Hygienists.

Qualified person means a person with specific training, knowledge, and experience in the area

for which the person has the responsibility and the authority to control.

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Radioactive dose limits under CERCLA, remedial actions should generally attain dose levels of

no more than 15 mrem/yr. effective dose equivalent for sites at which a dose assessment is

conducted. Dose is the amount of energy deposited in body tissue due to radiation.

RCRA permit is a permit required for a hazardous waste treatment, storage, or disposal facility.

RCRA see Resource Conservation and Recovery Act.

Resource Conservation and Recovery Act (RCRA) Federal law that regulates hazardous waste.

SARA see Superfund Amendments and Reauthorization Act.

SARA, title I required OSHA to issue regulations protecting workers engaged in hazardous

waste operations.

Site safety and health supervisor the person at a hazardous waste site who has the authority

and knowledge necessary to implement a site safety-and-health plan and verify compliance

with safety and health requirements.

Small-quantity generator is a generator of no more than 2,200 pounds of hazardous waste in

any calendar month.

Superfund Amendments and Reauthorization Act (SARA) amendments to the Comprehensive

Environmental Response, Compensation, and Liability Act (CERCLA).

TSD facility see Treatment, storage, and disposal facility.

Treatment, storage, and disposal facility (TSD) A facility that treats, stores, or disposes of

hazardous waste and is subject to RCRA permit requirements.

Uncontrolled hazardous waste site an uncontrolled hazardous waste site, as designated by a

governmental agency, at which an accumulation of hazardous substances creates a threat to

the health and safety of people or the environment.

Written safety-and-health program comprehensive workplace-safety-and-health requirements

for cleanup operations and TSD facilities required in HAZWOPER 1910.120(b)(1)(i) and

1910.120(p)(1).

Course 661


Resources

1. Occupational Safety and Health Administration. 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response.

2. Environmental Protection Agency. EPA Hazardous Waste Webpage

3. Occupational Safety and Health Administration. OSHA Incident Command System (ICS)

eTool.

4. Occupational Safety and Health Administration. Brownfield Site Cleanup and

Redevelopment.

5. Occupational Safety and Health Administration. Publication 3114. Hazardous Waste

Operations and Emergency Response.

6. National Institute for Occupational Safety and Health (NIOSH), U.S. Coast Guard (USCG),

U.S. Environmental Protection Agency (EPA) publication. Occupational Safety and Health

Guidance Manual for Hazardous Waste Site Activities

7. Occupational Safety and Health Administration. Oil Spill Response: Training Oil Spill

Response Workers under OSHA’s Hazardous Waste Operations and Emergency

Response Standard.

8. Oregon Occupational Safety and Health Division (OR-OSHA), HAZWOPER – A planning

guide for the perplexed.



https://www.epa.gov/hw

https://www.osha.gov/SLTC/etools/ics/nrs.html

https://www.osha.gov/SLTC/etools/ics/nrs.html

https://www.osha.gov/Publications/complinks/OSHG-HazWaste/4agency.html

https://www.osha.gov/Publications/complinks/OSHG-HazWaste/4agency.html

https://www.osha.gov/Publications/3172/3172.html



http://osha.oregon.gov/OSHAPubs/2117.pdf

http://osha.oregon.gov/OSHAPubs/2117.pdf

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