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HAZWOPER

OSHA HAZWOPER Training Programs

Implementing a HAZWOPER Program

The U.S. Occupational Safety and Health Administration (OSHA) developed the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) program to protect workers for 3 different levels – General Site Workers at contaminated sites, Emergency Response Operations and RCRA TSD Operations. These regulations are codified in Title 29 Code of Federal Regulations Part 1910 and in the Construction regulations Part 1926. These well crafted regulations ensure their safety and health when followed correctly.

You must determine if your company falls under the Federal OSHA HAZWOPER standard or if you are subject to any of the 27 OSHA Plan States. These Plan States are state regulatory agencies approved by Federal OSHA to implement and enforce a HAZWOPER regulatory program. These programs must be at least as stringent as the Federal OSHA HAZWOPER regulations. Many of these Plan States have requirements that exceed the Federal Standards. 

The successful implementation of a HAZWOPER Program involves 3 key elements.

1. Proper planning
2. Training
3. Personal Protective Equipment (PPE)

Proper Planning

Planning ahead of time is absolutely critical to success during a HAZWOPER operation. Depending upon the hazardous substance you will encounter and the environment, your procedures will vary greatly. You must be able to plan ahead for resources needed to accomplish any work task. This includes personnel, equipment, training in advance, contingency plans, procedures etc.

Site-Specific Safety and Health Plan

The site safety and health plan, for HAZWOPER which must be kept on-site, should address the safety and health hazards of each phase of site operation and include the requirements and procedures for employee protection.

At a minimum, the HAZWOPER site-specific plan should address the following:

• A safety and health risk or hazard analysis for each site task and operation found in the work planSafety Compliant Air Tank
• Employee training assignments
• PPE to be used by employees for each of the site tasks and operations being conducted Medical surveillance requirements
• Frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instrumentation to be used, including methods of maintenance and calibration of monitoring and sampling equipment to be used
• Site control measures in accordance with the site control program
• Decontamination procedures
• An emergency response plan for safe and effective responses to emergencies, including the necessary PPE and other equipment
• Confined space entry procedures
• A spill containment program
• Pre-entry briefings to be held prior to initiating any site activity and at other times as necessary to ensure that employees are apprised of the site safety and health plan and that this plan is being followed

The standard also requires inspections conducted by the site safety and health supervisor or another knowledgeable individual as necessary to determine the effectiveness of the site safety and health plan. Any deficiencies in the site safety and health plan must be corrected promptly.

Training

General Site Remediation

Training for a contaminated site falls into 40 Hour, 24 Hour, 8 hour Supervisor and 8 hour annual refresher for each of these.

40-Hour HAZWOPER General Site Worker Initial

Individuals must be able to select, use, and maintain personal protective equipment to minimize exposure to hazards. You must become familiar with the operation and use of monitoring and sampling equipment used to conduct a thorough site characterization. You should also prepare Health and Safety Plans and conduct a mock site investigation. The course is designed for environmental engineers, safety and health personnel, plant/site workers, emergency response personnel, and all others involved in hazardous waste operations who must comply with the training requirements of 29 CFR 1910.120 (e).

24-Hour HAZWOPER General Site Worker Initial

This training is similar to the training described above but is intended for employees with a lower exposure, or likelihood of exposure, to hazardous materials. The course concentrates more on hazard recognition and measurement and covers personal protective equipment and work practices in keeping with the risk level.

8-Hour HAZWOPER Supervisor Initial

Training is required for onsite management and supervisory personnel who are engaged in hazardous waste operations under 29 CFR 1910.120 (e). Topics should include employer’s safety and health programs, drill planning and execution, and employee training programs. Other topics included are personal protective equipment programs, spill containment methods and procedures, and techniques for health hazard monitoring. Completion of the 40-Hour General Site Worker course is a prerequisite.

8-Hour HAZWOPER Site Worker Refresher

This annual OSHA regulatory training is required under 29 CFR 1910.120 (e). These specific refreshers for the 40-hour initial training are designed to reinforce and update current health and safety practices for personnel engaged in hazardous waste/substance operations. Students must provide proof of initial or, current refresher training.

Emergency Response Operations

Safety Compliant HAZMAT Suit

One of the first questions you need to ask is whether or not you will be performing emergency response. If your facility does perform emergency response, you must determine who is responsible for emergency response and to what level. The existence of a “spill team” does not necessarily mean the team performs emergency response.

The HAZWOPER standard establishes five basic training requirements related to chemical emergency response: the First Responder Awareness Level, First Responder Operations Level, Hazardous Materials Technician, Hazardous Materials Specialist, and On-Scene Incident Commander training. These training levels are based on an emergency response.

First Responder Awareness Level training is required for individuals who are likely to witness or discover a hazardous substance release and who would take no action beyond notification of the proper authorities. Even if you do not have a spill team and do not plan to respond to spill emergencies, your employees might need First Responder Awareness Level training. This training potentially could include everyone from the chemical operator to the security guard, mail clerk and salesperson. The standard specifies six areas of competency that must be achieved either through training or experience, including understanding the risks associated with a hazardous substance incident.

First Responder Operations Level training is required for individuals who respond to releases or potential releases as part of the initial response. They are trained to respond in a defensive manner to protect people, property and the environment. Defensive actions are those taken from a safe distance to keep the spill from spreading and to prevent exposures. Examples include covering drains, placing spill booms or barriers and barricading access points,” all from safe distances. Eight hours of training or sufficient experience to demonstrate competency is required. The areas of required competency include hazard and risk assessment techniques, selection and use of personal protective equipment, spill control and containment, decontamination and standard operating procedures.

Hazardous Materials Technician training is required for individuals who will respond to the release or potential release for the purpose of stopping the release. They usually will be close to the source of the release and, therefore, have a high potential for harmful exposures. Examples include over packing a leaking drum or collecting contaminated absorbents. The Hazardous Materials Technician level calls for 24 hours of training. Personnel also must demonstrate competency in several areas, including the emergency response plan, instrumentation, the incident command system, selection and use of personal protective equipment, hazard and risk assessment, containment and control, decontamination, termination procedures and basic chemistry and toxicology.

Hazardous Materials Specialist training is similar to the Hazardous Materials Technician training. However, the specialist is required to have greater knowledge of the chemicals to which he or she might respond, as well as to act as a liaison with governmental authorities. He or she also provides support to the hazardous materials technician and 24 hours of training is required. Areas of required competency include those required of the hazardous materials technician, plus an understanding of the state emergency plan and in- depth hazard and risk assessment techniques. He or she also must be able to determine decontamination procedures, develop a site safety and control plan and demonstrate a greater knowledge of chemistry and toxicology.

On-Scene Incident Commander training is required for response beyond the First Responder Awareness Level. The role of the incident commander is to assume control of the incident scene. The incident commander must be someone on-site who is designated and trained to be in charge of the incident.

The required training will vary with the level and complexity of the response. The minimum required training is 24 hours, including at least First Responder Operations Level training. Competency must be demonstrated in implementation of the incident command system, the employer’s emergency plan and the local emergency plan. He or she must understand the hazards and risks of working in personal protective equipment and the importance of decontamination.

RCRA TSD Operations

24-Hour HAZWOPER RCRA TSDF Initial

Individuals must be able to select, use, and maintain personal protective equipment to minimize exposure to hazards. You must become familiar with the operation and use of monitoring and sampling equipment used to conduct a thorough site characterization. The training is designed for environmental engineers, safety and health personnel, plant/site workers, emergency response personnel, and all others involved in hazardous waste operations relating to the treatment, storage or disposal of hazardous wastes at RCRA permitted facilities.

8-Hour HAZWOPER RCRA TSDF Refresher

This annual OSHA regulatory training is required under 29 CFR 1910.120 (p). These specific refreshers for the 24-hour or the RCRA/TSD initial training are designed to reinforce and update current health and safety practices for personnel engaged in hazardous waste/substance operations. Attendees must provide proof of initial or, current refresher training.

If your facility is a RCRA Part B permitted facility, you will fall under the purview of the RCRA Corrective Action regulations. This can have a profound impact on any remediation efforts at your facility. U.S. EPA enforces the RCRA Corrective Action regulations and any waste generated during remediation will be subject to the solid waste/hazardous waste definition. Hazardous wastes fall into 2 categories – Characteristic and Listed. If any of your generated wastes are considered “listed” the impact to your operation will be substantial. Anything that comes in contact with a listed hazardous waste must itself be managed as a hazardous waste. 

Any of the 3 HAZWOPER training levels must contain the following items.

Appropriate HAZMAT Gear

· HAZWOPER Overview and Regulation
· Organization Structure
· Safety and Health Programs
· Site Characterization
· Toxicology
· Hazard Recognition
· Personal Protective Equipment
· Decontamination
· Medical Surveillance
· Hazard controls
· Air Monitoring
· Confined Space Entry
· Emergency Procedures
· Other Hazards
· Illumination
· Critique
· Proper hygiene facilities

Personal Protective Equipment

As required by the OSHA PPE Standard 29 CFR 1910.134, PPE must be selected which will protect employees from the specific hazards which they are likely to encounter during their work on-site.

Selection of the appropriate PPE is a complex process which should take into consideration a variety of factors. Key factors involved in this process are identification of the hazards, or suspected hazards; their routes of potential hazard to employees (inhalation, skin absorption, ingestion, and eye or skin contact); and the performance of the PPE materials (and seams) in providing a barrier to these hazards. The amount of protection provided by PPE is material-hazard specific. That is, protective equipment materials will protect well against some hazardous substances and poorly, or not at all, against others. In many instances, protective equipment materials cannot be found which will provide continuous protection from the particular hazardous substance.

Other factors in this selection process to be considered are matching the PPE to the employee’s work requirements and task-specific conditions. The durability of PPE materials, such as tear strength and seam strength, should be considered in relation to the employee’s tasks. The effects of PPE in relation to heat stress and task duration are a factor in selecting and using PPE. In some cases layers of PPE may be necessary to provide sufficient protection, or to protect expensive PPE inner garments, suits or equipment.

The more that is known about the hazards at the site, the easier the job of PPE selection becomes. As more information about the hazards and conditions at the site becomes available, the site supervisor can make decisions to up-grade or down-grade the level of PPE protection to match the tasks at hand.

The following discusses chemical protective equipment for HAZWOPER work.

Level A

Should be worn when the highest level of respiratory, skin, and eye protection is needed (i.e., for use with highly toxic releases, such as chlorine or ammonia). Level A protection includes:

• Fully encapsulated chemical-resistant suits
• Positive-pressure SCBA or positive-pressure supplied air respirator with escape SCBA
• Double layer of chemical-resistant gloves
• Airtight seals between suit and gloves and bootsSafety Compliant HAZMAT Suit

Level B

Should be worn when the highest level of respiratory protection is needed, but a lesser degree of skin protection is needed (i.e., protects against splash hazards posed by acids or caustics). Level B protection includes:

• Positive-pressure SCBA or positive-pressure supplied air respirator with escape SCBA (NIOSH approved)
• Chemical-resistant clothing
• Double layer of chemical-resistant gloves
• Chemical-resistant boots, with steel toe and shank

Level C

Should be worn when the next highest level of respiratory protection is needed after Level B. Skin protection criteria are similar to Level B (i.e., protects against contaminants, such as asbestos and lead). Level C protection includes:

• Full-face or half-mask air purification respirator (NIOSH approved)
• Chemical-resistant clothing
• Double layer of chemical-resistant gloves
• Chemical-resistant boots, with steel toe and shank
• Eye protection if half-face respirator is worn

Level D

Should be worn only as a work uniform and not at any site with respiratory hazards. Provides no protection against chemical hazards. Level D protection includes essentially common work clothes, such as safety goggles, safety gloves, and protective shoes.

Protection for General Site Workers, Emergency Response & RCRA TSD Operations Personnel – Considerations

The level of PPE, including the type of material that 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 that PPE be evaluated for each task and not for the site as a whole. In addition, 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.

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