OVERVIEW OF REQUIREMENTS UNDER HAZWOPER
Employees who may be exposed to hazardous substances in certain scenarios must receive HAZWOPER certification training. The OSH Act regulations specify that HAZWOPER training is required for employees who may encounter hazardous materials (hazmat) during cleanup work, while at hazardous waste facilities, or while responding to emergencies. Employers must follow specific work policies, practices, and procedures to ensure that employees are protected. HAZWOPER training is required for certain hazardous waste generators as hazardous waste is defined as a “hazardous substance” under HAZWOPER regulations.
HAZWOPER requires employee training, medical surveillance, and specifies proper material handling techniques. The hazmat classes required for training are based on the duties and responsibilities of the emergency responder and are tiered into five levels of training. Employees who work in areas with the potential for an uncontrolled release must have sufficient awareness training to recognize that an emergency response situation exists and to initiate emergency response procedures. Awareness level training may be integrated into the required by 29 CFR 1910.1200. Training requirements beyond first responder awareness level will depend on the roles
assigned to employees in the facility’s emergency response plan.
WHAT ARE MY HAZWOPER REQUIREMENTS AS A GENERATOR OF HAZARDOUS WASTE ?
Hazardous waste generators who store waste on-site for less than 90 days are only required to comply with the HAZWOPER emergency response program found in 29 CFR 1910.1200.
Hazardous waste generators must have an emergency response program and an emergency action plan that meet these OSHA standards. The emergency response program must address pre-emergency planning and coordination; personnel roles, hierarchy of authority, training, and communication; emergency recognition and prevention; safe evacuation distances and places of refuge; site security; evacuation routes and procedure; decontamination procedures; emergency medical treatment; emergency response procedures; and PPE and emergency equipment.
Conditionally exempt small quantity generators (CESQG) of hazardous waste are exempt from many of the OSHA programs required under OSHA’s HazCom regulations, except a CESQG must have an emergency response program or an emergency action plan.
What is hazmat? Hazmat, or hazardous materials, is defined by OSHA as:
[A] Any substance defined under section 103(14) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (42 U.S.C. 9601).
[B] Any biologic agent and other disease causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including: malfunctions in reproduction) or physical deformations in such persons or their offspring.
[C] Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR 172.101 and appendices.
[D] Hazardous waste as herein defined.