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Appendix D - Training Program

HAZWOPER Regulatory Requirements/Medical Surveillance

Objectives/Samples of Behavior:

  1. Summarize the key elements of 29 CFR 1910.120.

  2. Explain HAZWOPER training requirements

A.  Paragraph (a):  Scope, Application, and Definitions

  1. 29 CFR 1910.120 applies to all workers at these operations who are exposed or who may potentially be exposed to hazardous substances:

  1. Clean-up operations required by federal, state, or local government agencies.

  2. Corrective actions involved with clean-up operations at Resource Conservation & Recovery (RCRA) sites.

  3. Voluntary clean-up operations at sites recognized by Federal, State, local and other government bodies.

  4. Operations involving hazardous wastes that are conducted at treatment, storage, and disposal (TSD) facilities.

  5. Emergency response operations.

  1. Applications

  1. All requirements of 29 CFR 1910 and 1926 apply; if conflict then more protection shall apply without regard to 1910.5(c)(1), Applicability of Standards.

  2. Clean-up operations - all paragraphs of 1910.120 except (p) and (q).

  3. TSD facilities:  only paragraph (p) applies

  4. Emergency Response:  only paragraph (q) applies

  1. Definitions

    1. Includes common terms used in hazardous waste site operations.

    2. May want to review some definitions such as "IDLH," "LEL," or "SCBA."

B.  Paragraph (b):  Safety and Health Program

  1. General requirements - developed and implemented by employer to protect employees at hazardous waste sites.

  2. Organizational structure - establish chain of command and specifies responsibilities - general supervisor (or team leader or commander), site safety and health officer, and "all other personnel"

  3. Comprehensive workplan - addresses the tasks and objectives of site operations.  Identified the logistics and resources to meet these objectives.

  4. Site specific safety and health plan - specifies what minimum requirements that must be addressed.

C.  Paragraph (c):  Site Characterization and Analysis

  1. Evaluation of site characteristics before entry.

  2. Hazard identification for IDLH or other serious conditions.

  3. Required information to be obtained prior to site entry.

  4. PPE to be provided and used during site entry.

  5. Monitoring procedures to be used during initial site entry.

  6. Types of risks to be identified and evaluated.

  7. Employee notification of chemical, physical, and toxicological information known or suspected to be encountered.

D.  Paragraph (d):  Site Control

  1. Written site control program to be included in SSHP/HASP (health & safety plan)

  2. Minimum elements of site control program.

E.  Paragraph (e):  Training

  1. General - who is required to have training.

  2. Topics to be covered in training.

  3. Types and amount of training for:  Initial, refresher, emergency response, and supervisors.

  4. Employee certification/trainer qualifications.

F.  Paragraph (f):  Medical Surveillance

  1. Identifies employees requiring medical surveillance.

  2. Frequency of exams

  3. Contents of medical exams and costs - exams must be site-specific.

  4. Information provided to physicians

  5. Written opinion provided to employer by physician

  6. Record keeping - contents and period retained equal to criteria of 29 CFR 1910.20.

  7. Keep worker medical records 30 years after leaving job.

G.  Paragraph (g):  Engineering Controls, Work Practices, and Personnel Protective Equipment for Employee Protection

  1. Hierarchy of controls - engineering - administrative/work practices - PPE

  2. Objective is to reduce employee exposures below occupational exposure limits (OELs) and/or published exposure limits.

H.  Paragraph (h):  Monitoring

  1. Air monitoring to determine appropriate levels of protection

  2. Types of monitoring - initial, periodic, high risk employees

I.  Paragraph (i):  Informational Programs

  1. Provide information regarding nature, level, and degree of hazard to employees, contractors, and subcontractors (or their representative)

  2. Part of Safety & Health Program - paragraph (b)

J.  Paragraph (j):  Handling Drums and Containers

  1. How different hazardous substances must be handled, sampled, labeled, transported, and disposed.

  2. Tanks and vaults handled same as drums

K.  Paragraph (k):  Decontamination

  1. Specific decontamination procedures and equipment

  2. Procedures for showers, change rooms, commercial laundries, cleaning establishments

L.  Paragraph (l):  Emergency Response by Employees at Uncontrolled Hazardous Waste Sites

  1. Elements of an emergency response plan

  2. Procedures for handling emergency incidents

  3. Employers are exempt if they provide a plan that complies with 29 CFR 1910.38(a), Employee Emergency Plans & Fire Protection Plans.

M.  Paragraph (m):  Illumination

Lists minimum illumination intensities for in work areas.

N.  Paragraph (n):  Sanitation at Temporary Workplaces

  1. Potable and non potable water requirements

  2. Toilet facilities - types and minimum number

  3. Wash facilities, showers, and change room requirements

O.  Paragraph (o):  New Technology Program

  1. Any new technology developed shall be evaluated for effectiveness by the employer and made available, upon request, to OSHA

P.  Paragraph (p):  Certain Operations Conducted Under RCRA of 1976

  1. This applies to treatment, storage, and disposal facilities regulated under 40 CFR Parts 264 and 265 and not exempted by paragraph (a)(2)(iii) of 1910.120

  2. Most sections under paragraph (b) refer to paragraphs (b) through (o) for procedures and requirements.

Q.  Paragraph (q):  Emergency Response to Hazardous Substance Releases

  1. Covers employees engaged in emergency response other than those operations specified in paragraphs (a)(1)(i) through (a)(1)(iv) of 1910.120.

  2. Those emergency response organizations who have developed and implemented programs equivalent to this paragraph for handling releases of hazardous substances pursuant to section 3030 of Superfund Amendments and Reauthorization Act of 1986 (Emergency Planning and Community Right-to-Know Act of 1986, 42 U.S.C. 11003) shall be deemed to have met the requirements for this paragraph.

  3. Elements of emergency response plan.

  4. Procedures for handling emergency response (Incident Command System)