What is HAZWOPER?
The term “HAZWOPER” refers to the requirements of OSHA standards 1910.120 (general industry) and 1926.65 (construction). Both of these standards are titled “Hazardous Waste Operations and Emergency Response Standard,” and are known as HAZWOPER for short.
These OSHA standards do not cover the handling or clean-up of hazardous wastes. Those activities are regulated by other government agencies. OSHA's concern is that workers are safe in the workplace. In the area of hazardous waste, OSHA is primarily interested in employees being properly trained for the work they will be doing.
When Do OSHA's HAZWOPER Standards Apply?
The OSHA HAZWOPER standards apply to any employers with workers who are or may be exposed to hazardous substances, or are otherwise involved in any of the following types of work:
- Clean-up operations involving hazardous substances, including clean-ups required by a governmental body, or any clean-up conducted at uncontrolled hazardous waste sites.
- Corrective actions involving hazardous waste clean-up operations at sites covered by RCRA (the Resource Conservation and Recovery Act of 1976).
- Voluntary clean-up operations at “uncontrolled hazardous waste sites”, as recognized by a governmental body.
- Work involving hazardous waste that takes place at treatment, storage, and disposal facilities regulated by either:
- Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or
- Agencies that, under agreement with the EPA, implement RCRA regulations.
- Any emergency response operation, without regard to the location of the hazard, that results from the release, or substantial threat of release, of hazardous substances.
Since HAZWOPER applies to working with hazardous waste, it is important to know the definition of hazardous waste. The legal definition is managed by the EPA.
What Are the OSHA HAZWOPER Training Requirements?
OSHA's HAZWOPER standards require workers to be trained appropriately for the type of work they may do. They must be able to perform their job without endangering themselves or others.
For workers in a facility where only a limited number of hazardous wastes are present, the required training is fairly simple to determine. Those workers must be trained so that they can safely work with those specific hazardous wastes. The situation is different for emergency responders and hospital workers. They must be trained to deal with any hazardous waste that exists in the community.
Hospitals, for example, must consider the hazardous wastes in the community they serve, and how those hazardous wastes will impact their work. The worst-case scenario should be assumed for planning purposes.
For example, hospital staff may be expected to perform limited decontamination before addressing medical issues. That means they need to be trained in the use of PPE and decontamination procedures. In many cases, the best option is to have hospital employees who are designated to perform this type of work attend first responder training. The hospital may then provide additional training related specifically to the hospital setting where the decontamination will take place.
However the training is performed, the OSHA HAZWOPER standard requires that the employer certify that their employees have the required training and competencies. The OSHA HAZWOPER standard also requires that employees receive annual refresher training, or that they be able to demonstrate the required competency.
The general principle is that if an employee might be involved with or exposed to hazardous waste in one way or another, that employee must have the appropriate training.
Are There HAZWOPER Training Requirements for Workers Not Directly Involved in Cleanup Activities?
Some workers, such as those employed to work on utilities, are needed at a hazardous waste site, but they are not directly involved with cleanup. However, that does not exempt them from the HAZWOPER training requirements. The HAZWOPER standard requires them to be fully trained for the hazards they may encounter. In addition, their work must be done under the direction of an on-site supervisor, and under a site-specific safety and health plan. Once the site characterization shows that the area where they are working is free of potential exposure, the work can be treated as normal maintenance or construction work, not associated with hazardous waste.
HAZWOPER and Emergency Response
There is always the possibility of an unexpected, accidental release of hazardous materials that requires an emergency response. The OSHA HAZWOPER standards apply to emergency responses, but knowing the definition of a HAZWOPER Emergency Response is important.
If a workplace activity meets the definition of an OSHA “HAZWOPER Emergency Response,” then everyone involved in the emergency response must comply with HAZWOPER paragraph (q) and all other General Industry (1910) or Construction Industry (1926) standards.
An employer cannot just declare a situation that requires immediate attention to be an emergency response. OSHA has a specific HAZWOPER definition of “emergency response.” As defined by the HAZWOPER standard, the term “HAZWOPER Emergency Response” only applies to a response to an uncontrolled release of a hazardous substance, or to a situation in which an uncontrolled release is likely.
OSHA has provided a list of conditions that are considered situations requiring an emergency response. In addition, similar conditions that may develop as a consequence of a release of hazardous substances or the threat of release are also considered to require an emergency response.
- High concentrations of toxic substances.
- Immediately Dangerous to Life and Health (IDLH) environments.
- Situations that present an oxygen deficient atmosphere.
- Conditions that pose a fire or explosion hazard.
- Situations that require an evacuation of the area.
- Situations that require immediate attention because of the danger posed to employees in the area.
What About Incidental Releases of Hazardous Substances?
In most cases, the release of a hazardous substance is considered “incidental” if that release is limited in quantity, limited in exposure potential, or limited in toxicity. In addition, the release must not result in an emergency situation, and it must not be a significant threat to the safety and health of people in the immediate vicinity, or to those who are working to clean it up.
An example of an incidental release would be a small spill at a tanker truck loading station. If the spill is contained by employees in the immediate vicinity, and it can be cleaned up using absorbents without causing safety and health threats, it is an incidental release.
On the other hand, a significant release of chlorine gas, for example, would likely be an immediate hazard to life and health. If large enough, it might even obscure visibility, causing an additional hazard. In this case, the chlorine gas release would require an emergency HAZWOPER response.
Although HAZWOPER may not apply to an incidental release, there are other OSHA standards that may apply, such as the Hazard Communication Standard (HCS). In addition, without regard to the type of hazard, OSHA requires the employer to provide a safe workplace. This means that when employees are expected to handle any type of hazardous material release, including incidental releases, they must have the appropriate training and they must use appropriate PPE.
Finally, if the requirements of the HAZWOPER standards conflict or overlap with any other OSHA standard, the provision that provides the greatest protection must be followed.
Benefits of HAZWOPER Training
Employees who take a HAZWOPER training course receive several benefits, which are shared with their company. Those include:
- Situation readiness: Workers can prepare for situations where they may be exposed to hazardous substances and respond accordingly. Extensive training enables employees to understand risks and hazards, take proper precautions, wear the right PPE, and engage in best practices when working around hazardous material.
- Improved safety: HAZWOPER training doesn’t just benefit the employee who takes it; that worker can, in turn, identify risks and situations that may lead to widespread exposure and work to ensure the safety of all potentially impacted employees in a facility.
- OSHA compliance: Workplaces that don’t follow key standards may face OSHA violations and hefty fines. Training and education can mitigate this risk and create a safer work environment.
HAZWOPER Sign, Label, and Tag Solutions
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