Brownfields and HAZWOPER – the Nuts and Bolts Sven J. Rundman III OSHA Office of Health Enforcement Washington, DC 2006 Brownfields Conference November.

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Presentation transcript:

Brownfields and HAZWOPER – the Nuts and Bolts Sven J. Rundman III OSHA Office of Health Enforcement Washington, DC 2006 Brownfields Conference November 13 – 15, 2006

A Revolution in Redevelopment & Revitalization2 Objective: To Clarify... What OSHA looks for & when HAZWOPER is required How to apply HAZWOPER when it’s only contractually required How to approach brownfields health & safety effectively

A Revolution in Redevelopment & Revitalization3 When OSHA Requires HAZWOPER at Site Cleanups Government-required cleanups at “listed” sites (NPL, State lists) RCRA corrective actions Voluntary cleanups at “government-recognized” sites OSHA LOI 3/25/92

A Revolution in Redevelopment & Revitalization4 Hazardous Waste Site If OSHA considers your brownfield a hazardous waste site then you must comply with: –The HAZWOPER Standard, and –All other applicable General Industry (1910) Standards, or –All other applicable Construction Industry (1926) Standards

A Revolution in Redevelopment & Revitalization5 Where HAZWOPER May Contractually Apply Sites funded under EPA Superfund Cooperative Agreements Sites where VCP requires HAZWOPER or parts of HAZWOPER

A Revolution in Redevelopment & Revitalization6 Site Assessment & Cleanup - Hazards Site chemicals Heavy equipment Heat or cold stress Ergonomic risks Slips, trips or falls Cave-ins Electrical risks Confined space entry Noise

A Revolution in Redevelopment & Revitalization7 HAZWOPER: Controls in Proportion to Hazards Cleanup requirements in paragraphs (b)-(o) Focus on hazards associated with site contaminants Controls minimal where potential exposure low

A Revolution in Redevelopment & Revitalization8 A HASP: Written Plan Effective means to plan and record site health and safety procedures Paragraph (b) lists HASP contents Site-specific

A Revolution in Redevelopment & Revitalization9 Characterizing the Site & Analyzing Job Hazards Provides the basis for site controls May draw on Phase I or Phase II data Must quantify worker exposure levels

A Revolution in Redevelopment & Revitalization10 HASP Written Plan Assistance e-HASP 2 Software Allows for site-specificity Windows based downloadable software Provides “model” language for preparing a HASP

A Revolution in Redevelopment & Revitalization11 e-HASP 2 Main Menu

A Revolution in Redevelopment & Revitalization12 e-HASP2 Entering Information – Job Hazard Analysis Chapter New chemicals can be entered here Chemicals from e-HASP 2 database

A Revolution in Redevelopment & Revitalization13 e-HASP 2 Example Safety and Health Plan Text

A Revolution in Redevelopment & Revitalization14 Important to Include Emergency response Other applicable OSHA standards More protective standard

A Revolution in Redevelopment & Revitalization15 OSHA Compliance: Non-HAZWOPER Hazard assessment ( (d), , other standards) Controls and other applicable standards based on hazard assessment HASP as tool to plan and document your approach

A Revolution in Redevelopment & Revitalization16 OSHA Compliance: Summary HAZWOPER: controls in proportion to hazards Other applicable standards HASP as useful tool

A Revolution in Redevelopment & Revitalization17 Additional Information –Click “B” on the Site Index to locate the “Brownfields” link or “H” for the “Hazardous Waste” link e-HASP2: – s/ehasp/index.html OSHA Hotline – OSHA