HAZWOPER

Hazardous Waste Operations and Emergency Response (HAZWOPER; /ˈhæzwɒpər/ HAZ-waw-pər) is a set of guidelines produced and maintained by the Occupational Safety and Health Administration which regulates hazardous waste operations and emergency services in the United States and its territories.[1] With these guidelines, the U.S. government regulates hazardous wastes and dangerous goods from inception to disposal.

HAZWOPER applies to five groups of employers and their employees. This includes employees who are exposed (or potentially exposed) to hazardous substances (including hazardous waste) and who are engaged in one of the following operations as specified by OSHA regulations 1910.120(a)(1)(i-v) and 1926.65(a)(1)(i-v):[2]

  • Cleanup operations required by a governmental body (federal, state, local or other) involving hazardous substances 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 cleanup operations at sites recognized by a federal, state, local, or other governmental body as uncontrolled hazardous-waste sites
  • Operations involving hazardous waste which are conducted at treatment, storage and disposal facilities regulated by Title 40 of the Code of Federal Regulations, parts 264 and 265 pursuant to the RCRA, or by agencies under agreement with the 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 hazard's location)

The most commonly used manual for HAZWOPER activities is Department of Health and Human Services Publication 85–115, Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities.[3] Written for government contractors and first responders, the manual lists safety requirements for cleanups and emergency-response operations.

History

Although its acronym predates OSHA, HAZWOPER describes OSHA-required regulatory training. Its relevance dates to World War II, when waste accumulated during construction of the atomic bomb at the Hanford Site. Years later, high-profile environmental mishaps (such as Love Canal in 1978 and the attempted 1979 Valley of the Drums cleanup) spurred federal legislative action,[4] awakening the U.S. to the need to control and contain hazardous waste. Two programs—CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act and the Resource Conservation and Recovery Act (RCRA) of 1976—were implemented to deal with these wastes. CERCLA (the Superfund) was designed to deal with existing waste sites, and RCRA addressed newly generated waste. The acronym HAZWOPER originally derived from the Department of Defense's Hazardous Waste Operations (HAZWOP), implemented on military bases slated for the disposal of hazardous waste left on-site after World War II. In 1989 production ended at the Hanford Site, and work shifted to the cleanup of portions of the site contaminated with hazardous substances including radionuclides and chemical waste.[5] OSHA created HAZWOPER, with input from the Coast Guard, the National Institute for Occupational Safety and Health and the Environmental Protection Agency (EPA). In 1984, the combined-agency effort resulted in the Hazardous Waste Operations and Emergency Response Guidance Manual.[6] On March 6, 1990 OSHA published Hazardous Waste Operations and Emergency Response 1910.120,[7] the HAZWOPER standard codifying the health-and-safety requirements companies must meet to perform hazardous-waste cleanup or respond to emergencies.

Scope

Hazardous waste, as defined by the standard, is a waste (or combination of wastes) according to 40 CFR §261.3 [8] or substances defined as hazardous wastes in 49 CFR §171.8.[9]

Training levels

OSHA recognizes several levels of training, based on the work the employee performs and the degree of hazard faced. Each level requires a training program, with OSHA-specified topics and minimum training time.

  • General site workers initially require 40 hours of instruction, three days of supervised hands-on training and eight hours of refresher training annually.
  • Workers limited to a specific task, or workers on fully characterized sites with no hazards above acceptable levels, require 24 hours of initial training, one day of supervised hands-on training and eight hours of refresher training annually.
  • Managers and supervisors require the same level of training as those they supervise, plus eight hours.
  • Workers at a treatment, storage or disposal facility handling RCRA waste require 24 hours of initial training, best practice two days of supervised hands-on training and eight hours of refresher training annually. 1910.120(p)(8)(iii)(B) [10] Employee members of TSD facility emergency response organizations shall be trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees. This would include training in the methods used to minimize the risk from safety and health hazards; in the safe use of control equipment; in the selection and use of appropriate personal protective equipment; in the safe operating procedures to be used at the incident scene; in the techniques of coordination with other employees to minimize risks; in the appropriate response to over exposure from health hazards or injury to themselves and other employees; and in the recognition of subsequent symptoms which may result from over exposures.
  • The First Responder Awareness Level requires sufficient training to demonstrate competence in assigned duties.
  • The First Responder Operations Level requires Awareness-Level training plus eight hours.
  • Hazardous Materials Technicians require 24 hours training plus additional training to achieve competence in specialized areas.
  • Hazardous Materials Specialists require 24 hours training at the Technician level, plus additional specialized training.
  • On-scene Incident Commanders require 24 hours training plus additional training to achieve competence in designated areas.

In some instances, training levels overlap; other levels are not authorized by OSHA because their training is not sufficiently specific.[11] A site safety supervisor (or officer) and a competent industrial hygienist or other technically qualified, HAZWOPER-trained person should be consulted.

Training and certification sources

OSHA-compliant sources for HAZWOPER training are available from community colleges, labor unions, employers and training companies. An employer must ensure that the training provider covers the areas of knowledge required by the standard and provides certification to students that they have passed the training. Since the certification is for the student, not the employer, the trainer must cover all aspects of HAZWOPER operations and not only those at the current site. OSHA training requires cleanup workers to focus on personal protective equipment separately from emergency-response equipment.[12] There are 4 levels of PPE that range from A-D that HAZWOPER training will cover that vary in skin, respiratory and eye protection.[13]

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See also

References
  1. "Hazardous waste operations and emergency response. - 1910.120". osha.gov. Retrieved 1 March 2015.
  2. "OSHA FAQs - HAZWOPER". osha.gov. Retrieved 1 March 2015.
  3. "OS&H Guidance Manual for Hazardous Waste Site Activities". osha.gov. Retrieved 1 March 2015.
  4. "NPL Site Narrative for A.L. Taylor (Valley of Drums)". United States Environmental Protection Agency. September 8, 1983. Retrieved October 12, 2013. EPA conducted emergency response activities in March 1979….
  5. "Hanford Overview and History - Hanford Site". hanford.gov. Archived from the original on 25 February 2015. Retrieved 1 March 2015.
  6. United States Department of Health and Human Services (National Institute for Occupational Safety and Health) (October 1985), Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities (PDF), p. 142, pub. no. 85-115, retrieved February 22, 2011
  7. 29 C.F.R. 1910.120
  8. "Identification and listing of hazardous waste". Code of Federal Regulations. Retrieved March 10, 2015.
  9. "General information, regulations, and definitions". Code of Federal Regulations. Retrieved March 10, 2015.
  10. "1910.120 - Hazardous waste operations and emergency response. - Occupational Safety and Health Administration". www.osha.gov.
  11. Fairfax, Richard E. (April 28, 2008), Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER (letter to Robert E. Carson), retrieved October 12, 2013
  12. 29 C.F.R. 1910
  13. "General description and discussion of the levels of protection and protective gear". OSHA.gov. 2015-08-24.
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