Hazardous Waste Operations & Emergency Response 8-Hour Annual Refresher

MODULE 1

Overview of Pertinent Environmental Regulations

HAZWOPER Standard

The Hazardous Waste Operations and Emergency Response (HAZWOPER) section of the OSHA regulations is the centerpiece of worker protection standards for handling hazardous materials on abandoned waste sites and emergency response scenarios. The major requirements are training for personnel engaged in the handling or use of hazardous substances, a written site-specific health and safety plan, use of personnel protective equipment (PPE) when needed, and development of an emergency response plan. Depending on the job classification, a 40-hour (worker) or at least 24 -hour (supervisor) initial HAZWOPER training must be taken prior to working with hazardous substances. Also, an annual 8-hour HAZWOPER refresher training is required to maintain the initial training certification. The training must train workers and supervisors on a) personnel responsible for safety, b) health and other hazards at the worksite, c) use of PPE, d) minimization of risks to work hazards, e) safe use of engineering controls and equipment at the site, f) medical surveillance requirements, and g) the contents of the site specific health and safety plan. These are the requirements as listed in the OSHA regulations.

HAZWOPER applies to five distinct groups of employers and their employees. This includes any employees who are exposed or potentially exposed to hazardous substances - including hazardous waste - and who are engaged in one of the following operations:

• Mandatory Clean-up Operations - required by a governmental body, whether federal, state, local, or other involving hazardous substances - that are conducted at uncontrolled hazardous waste sites; corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.).
• Voluntary Clean-up Operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites.
• Operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations.
• Emergency response operations for releases of, or substantial threats of release of, hazardous substances regardless of the location of the hazard.
• Routine hazardous waste operations at RCRA TSD facilities.

Hazard Communication Standard

Congress passed the hazard communication standard largely because of accidents involving hazardous substances. Specifically, the 1983 Bhopal, India tank accident, which released large amounts of methyl isocyanate to the environment, killing thousands of people and injuring thousands more (the exact number of fatalities and injuries are unknown). This accident occurred at the plant pictured to the right. This prompted Congress to inform workers and communities of hazards in their immediate vicinity. The so-called "right to know laws" mandated that industry provides key information on hazardous substances.

Under the Hazard Communication standard, employers must provide employees with three items. The first is training on the hazardous substances which the employer uses, produces, stores, etc. Next MSDS, providing detailed information on the respective hazardous substances in use. Finally, labels or placards must clearly identify contents of hazardous substances. The types of labels or placards frequently encountered are hazardous waste labels, Department of Transportation placards, and NFPA triangle labels. Module 6 covers the placards and labeling aspects of hazardous materials.

 

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