The Hazardous Waste Operations and Emergency Response (HAZWOPER) Health and Safety Plan (HASP) applies to cleanup operations required by government agencies at uncontrolled hazardous waste sites, corrective actions involving cleanup at Resource Conservation and Recovery Act (RCRA) regulated sites, and voluntary cleanup at uncontrolled hazardous waste sites.

HASP is limited to the Occupational Safety and Health Administration’s (OSHA) HAZWOPER requirements found at 29 CFR 1910.120(b)-(o) and, therefore, does not apply to treatment, storage, and disposal facilities (TSDFs) licensed under RCRA that are not subject to corrective actions, nor to the emergency responder requirements under Section (q) of the standard.

Following is a section-by-section explanation of the basic elements that should be included in your facility’s HASP: 

1. Site Characterization and Analysis (29 CFR 1910.120(c))

Initial site characterization and analysis must be performed by a qualified person in order to choose and justify engineering controls, work practices, and personal protective equipment (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 (see #5). Exposure controls and monitoring instruments (see #5) must be based on an up-to-date characterization and hazard analysis.

2. Site Control (29 CFR 1910.120(d))

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. Your HASP must delineate work zones and establish safe work and communication procedures for each zone. It must contain 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. HASP must identify your method for controlling entry into contaminated areas, restricting this to authorized employees who are properly trained and protected. Employees entering contaminated zones must follow the work procedures in HASP, including using the buddy system. To enable a quick response, emergency medical information, including the name of and route to the nearest medical facility, must be posted in the contamination reduction or support zone. Emergency communication procedures must be written and explained to employees.

3. Training (29 CFR 1910.120(e)) and Information Programs (29 CFR 1910.120 (i))

Your employees must be trained to do their assigned duties safely before they begin work on-site. The required training, described in 29 CFR 1910.120(e), is a combination of classroom instruction, site-specific information, and supervised fieldwork. You can send your workers to an outside training organization for their classroom instruction, but you are ultimately responsible for ensuring that your employees are properly trained. The hours of initial training vary depending on an employee’s duties and anticipated exposures. Initial training must be updated with 8 hours of refresher training annually. You are also required by 29 CFR 1910.120(i) to inform employees and contractors of the types and level of hazards associated with operations.

Nonmandatory Appendix E provides training criteria and content guidance. Your HASP must identify which jobs require training, how much training is needed, and how all of the training requirements in 29 CFR 1910.120(e) are fulfilled. The location and maintenance of training documentation and certification must also be identified. In addition to the training requirements, your HASP must also document how information about changes in site-specific information is communicated to interested parties, including employees, contractors, etc. Each worker, however, must have 8 hours of refresher training annually.

4. Medical Surveillance (29 CFR 1910.120(f))

If your employees are exposed to hazardous substances as a part of their work, you may be required to monitor their health through a medical surveillance program. Employees must be included in the medical surveillance program if they:

  • Are or may be exposed to hazardous substances above permissible limits for at least 30 days per year.
  • Wear a respirator for at least 30 days per year.
  • Become ill or show signs or symptoms of job-related overexposure to hazardous substances.
  • Are members of a hazardous materials (hazmat) team.

If you have employees who meet any of these criteria, you need to establish a medical surveillance program. You must consult a licensed physician to determine the content of the medical exams to be provided to your employees. Baseline, periodic, and exit exams are required by the standard. You will also need to keep the physician’s written opinion provided after each employee’s medical exam.

With few exceptions, you must keep both employees’ medical and exposure records for the duration of their employment, plus 30 years. Employees and their representatives have the right to access these records during this time.

5. Engineering Controls, Work Practices, and PPE for Employee Protection (29 CFR 1910.120(g))

Engineering controls and work practices are the best ways to reduce employee exposures; they should be selected and highlighted first in HASP. Often these controls will need to be used in combination with PPE to provide sufficient protection during hazardous waste site operations. If your employees require PPE, you must include a written PPE program in your HASP. This portion of the HASP must clearly describe how you select and use PPE based on the tasks and the nature and concentration of site contaminants. The PPE program must address how PPE will be used correctly and identify the limitations of its use; appropriate work mission durations; and procedures for decontaminating, maintaining, storing, and discarding PPE. Employees using PPE must be physically capable of doing so, and the PPE program must address the limitations of PPE use during temperature extremes, heat stress, and other appropriate medical considerations. Employees must also be trained to use PPE correctly, including how to inspect it before, during, and after use. If PPE will be used, the PPE program that includes all the elements listed must be evaluated to ensure that it is effective.

6. Monitoring (29 CFR 1910.120(h))

Since site monitoring data are the basis for selecting many of your exposure controls, generating accurate and complete data is critical and must be addressed in HASP. Your HASP must identify how often monitoring will be conducted and the method and equipment for each contaminant. HAZWOPER requires monitoring during initial site entry and periodic monitoring during site operations. Periodic monitoring must be conducted when there is the possibility of an immediately dangerous to life or health (IDLH) condition, a flammable atmosphere, or when employee exposures may have risen above published values (OSHA PELs, NIOSH RELs, ACGIH TLVs since prior monitoring). For example, periodic monitoring must be conducted when:

  • Site conditions change (new tasks, locations, or hazards).
  • New operations are started (such as drum opening after exploratory drilling).
  • Leaky containers are handled.
  • Work is conducted in areas with obvious liquid contamination.

You must monitor the breathing zones of employees who have the highest potential exposure(s). If their exposures meet or exceed published values, you must monitor all employees likely to be exposed over those published limits. Your HASP must also indicate the airborne concentrations at which you reevaluate your site’s engineering controls, work practices, and personal protective equipment (PPE).

Calibration and maintenance schedules, as per manufacturers’ recommendations, should also be maintained. You must take lab-analyzed samples and compare your real-time readings to the laboratory results. You may want to consult with an accredited laboratory to determine proper analytical sampling procedures. Results of personal sampling are considered employee exposure records.

7. Handling Drums and Containers (29 CFR 1910.120(j))

If you have drums or containers on your site (buried or aboveground) and you plan to move them, you must (1) inspect them before movement, (2) move them sparingly, and (3) stage them carefully. If drums or containers could create a major spill, you also need to develop a spill containment program. Employees inspecting drums must evaluate the integrity of the container. Employees should also locate and interpret important label information and assume the worst if a label does not exist. Drums in staging areas should be arranged to allow employees easy access and egress. Drum opening and sampling operations must be isolated if the contents are unknown. If spills, leaks, or ruptures may occur, you must provide proper training and containment equipment to personnel who will control and contain spilled material. You also must stock equipment such as salvage drums or containers, absorbent material, shovels, and PPE for spill response. All containers transported off-site must have proper Department of Transportation (DOT) labels, bills of lading, etc.

Shock-sensitive wastes must be treated with special precautions, including evacuating all nonessential employees. There must be the availability of continuous communications between the employee in charge of the handling area, the site health and safety supervisor, and the command post. Any container or drum showing signs of pressure buildup, such as bulging or swelling, cannot be moved until the source of the pressure is found and relieved. Lab waste packs must be opened only when necessary and only by knowledgeable personnel. If crystalline material is found in the lab pack(s), it must be treated as shock-sensitive material until proven otherwise. Tanks and vaults containing hazardous substances must be handled similar to drums and containers, taking into account the size of the tank or vault. If tanks or vaults will be entered, appropriate entry procedures must be identified in HASP and be followed by employees conducting the entry.

8. Decontamination (29 CFR 1910.120(k))

Decontamination procedures address how employees’ contact with contaminants or contaminated equipment (including PPE) will be minimized. Your HASP must include written decontamination procedures that address this goal, eliminate the movement of contaminants to clean areas, and prevent mixing of incompatible substances. Decontamination procedures must be appropriate for the contaminants present, for the equipment, and PPE used on-site. In addition, you must evaluate the effectiveness of the decontamination procedures you implement. One way to evaluate your procedures is to collect samples from key surfaces and analyze them for site contaminants. Samples should be collected from the surfaces of decontaminated reusable PPE, heavy equipment, and “clean” areas such as break and changing rooms.

Your HASP should also identify how disposable PPE and site decontamination waste will be discarded and how reusable PPE will be cleaned and placed back in service. If you use a commercial laundry or cleaners, they must be informed of the potential effects of the hazardous substances.

9. Emergency Response by Employees at Uncontrolled Hazardous Waste Sites (29 CFR 1910.120(l))

You must have a written emergency response plan (ERP) that identifies the actions employees will take if fire, personal injury, chemical release, or other emergencies occur on the site. The items needed to be included in your ERP are listed in 29 CFR 1910.120(l)(2) and (l)(3). The ERP must be tested and critiqued regularly.

If your plan is to rely on local emergency response organizations such as the fire department, you must contact them and explain your response needs. If they cannot provide the services you need, you must retain a service provider who can. Even if you have an on-site hazmat team, you must coordinate your ERP with the local response plan, including incident reporting procedures. The ERP must contain information on the following topics:

  • Personnel roles, lines of authority, training, and communication
  • Employee recognition and prevention of emergencies
  • Safe distances and places of refuge
  • Site security and control in the event of an emergency
  • Evacuation routes/procedures, including site topography, layout, and prevailing weather
  • Emergency decontamination procedures not covered elsewhere in HASP
  • Emergency alerting and response procedures, including PPE and emergency equipment

Rather than an ERP, you may also choose to evacuate your employees and follow an emergency action plan developed in accordance with 1910.38(a). Choosing this option requires that you provide an emergency action plan and integrate the plan with the local response plan as a separate part of your HASP.

10. Illumination and Sanitation at Temporary Workplaces (29 CFR 1910.120s(m) and 29 CFR 1910.120s(n))

You must provide suitable lighting, potable water, and toilet facilities. When work operations are expected to exceed 6 months, you must also provide showers and change rooms. Site illumination levels must meet the minimum illumination levels provided in 29 CFR 1910.120(m) Table H-120. Adequate potable water with proper dispensers must be maintained on-site. Showers and change rooms must meet OSHA requirements in the Sanitation standard at 29 CFR 1910.141. Site water sources must be labeled as either potable or nonpotable. Adequate toilet and hand-washing facilities must also be provided.

11. New Technology Programs (29 CFR 1910.120(o))

OSHA requires that you have procedures for evaluating technological innovations that could provide more effective protection to your employees. Manufacturers’ literature can be a useful source of information. Before you implement the use of new technologies, equipment, or control measures on a large scale, however, ensure that they offer the protection you anticipate.

For more information or assistance with your Environmental and Health & Safety regulatory compliance needs, contact Ralph Carito at Total Environmental & Safety, LLC (Total) at rcarito@TotalEnviron.com or 908-442-8599.