Michael Hampton CSP, ARM University of Utah, RMCOEH

HAZWOP Applies to hazardous waste operations in various settings Hazwoper is not a sandwich at Burger King “But I don’t deal with hazardous waste” What does Hazwoper mean? Are you perplexed by Hazwoper? /ER Also applies to emergency responders at any industrial setting.

History of the standard Who is covered What is covered Training requirements What We’ll Cover

Regulatory History 1976 – RCRA passed into law to regulate the handling of hazardous waste 1980 – CERCLA (Superfund) 1986 – SARA - OSHA given responsibility for governing hazardous waste workers safety 1987 – OSHA issued NPR 1990 – Final Hazwoper rule goes into effect. “To prevent accidents involving hazardous materials”. Where Did This Come From Anyway?

“…those employees engaged in emergency response operations for releases or substantial threats of releases of hazardous substances, and post-emergency response operations to such releases at all workplaces.” Scope in Preamble

December 1984 – Bhopal India catastrophe August 1985 – Institute WV release 6,928 chemical accidents occurred in the United States within a five-year period What Drove This?

Who’s minding the store? 5 distinct groups of workers are covered Can be grouped into 3 “task” groups: Workers involved in waste clean up Employees working at a TSDF Employees engaged in emergency response operations for release of, or substantial threats of release of, hazardous substances. Are my employees covered?

Emergency-response operations include: Responses by properly trained employees from outside an immediate release area at a production facility, Trained responders from a fire department, or Contracted HAZMAT responders If your employees respond to emergencies caused by uncontrolled releases of hazardous substances no matter where they occur, then you must comply with HAZWOPER (q). Employees that respond to emergencies involving releases of hazardous substances

You are working for an environmental consulting company and your client tells you that the property they own is on EPA's NPL, the state has issued them a Notice of Violation, and they want you to tell them what's on the property and what's going to have to be done to clean it up. This action is covered under sections (i) & (ii) if under RCRA. "You want to be a good neighbor, and the regulators are telling you that your site is an uncontrolled hazardous waste site, but they haven't given you a Notice of Violation or a Compliance order -– that's covered by section (iii). If they give you the NOV, then you would be covered by either section (i) or (ii), depending on how the Notice was written. Section (iv) covers only those locations that have been permitted as TSDFs. "Everyone else who has a spill, release, or cleanup not covered by any of the above is covered by section (v). This also includes manufacturing plants that have teams to handle their spills or releases." Application in the “real world”…

“Hazardous Materials” - Physical“Hazardous Materials” - Chemical Sensitizers Irritants Corrosives Toxic & Highly Toxic agents Carcinogens Combustible Flammable Explosives Oxidizers Compressed Gases Organic Peroxides What Materials Are Covered? 29 CFR Toxic & Hazardous Substances, Table Z-1 DOT Hazardous Material Table, 49 CFR Roughly 2800 line items EPA – Discarded material that meets TRCI criteria

Site Control Plan Standard operating procedures Organizational structure Site Safety & Health Plan Hazard/Risk Identification PPE Safety and health training program Medical surveillance program Monitoring Spill Control Decontamination procedures Emergency Response Plan Standard’s Requirements

Job function & Exposure Potential Exposure Based – Waste Sites General Site Worker – work with hazardous substances with potential exposure >PEL Occasional Site Worker – periodic, unlikely exposure >PEL Management & Supervision Task Waste Treatment Operations based Emergency Response based Defensive or Offensive? Onsite vs. Offsite personnel Employee Training

General Site Worker – 40 hours of classroom instruction plus three days supervised field experience Occasional Site Worker – 24 hours of classroom instruction plus one day supervised field experience Management and Supervisor – Trained to the level of the employees being supervised plus an additional 8- hours of specialized training Refresher training – Eight hours of annual refresher training. As discussed above, the annual refresher should be tailored to the specific duties and not a “one size fits all”. Training Requirements – Waste Site Workers

Operations at TSDF Provide for the safe conduct of work around hazardous waste/materials 24 hours and 8 hour annual refresher Emergency Responders First Responder Awareness level First Responder Operations level HazMat Technician/HazMat Specialist Incident Commander Training Requirements – Task based

FR – Awareness Sees a spill and reports it, no time requirement FR - Operations All the above and attempts to contain spread but not to stop the leak, 8 hours minimum Technician/Specialist Offensive action to stop the leak, 24 hours at FRO level + standards requirements Incident Commander Overall control and charge of the situation, 24 hours at FRO level + standards requirements Refresher training for above must be annual and sufficient to maintain and demonstrate competency Emergency Response

Understanding Hazwoper can be confusing Hazwoper applies to most of us Determine what the employee is doing Hazardous Waste Site Worker – (e) TSDF Worker – (p) Emergency Responder – (q) Train according to the requirements Ensure that your documented program meets the standards criteria Summary

Training LevelRegulationTime Requirement General Site Worker (e)(3)(i)40 Hours + 3 days on-site Occasional Site Worker (e)(3)(ii)24 Hours + one day on-site Supervisor (e)(4)Additional 8 hours Occasional to General Crossover (e)(3)(iv)16 Hours + 2 days additional on-site Site Worker Refresher (e)(8)8 Hours TSDF Worker (p)(7)(i)24 Hours TSDF Worker Refresher (p)(7)(i)8 Hours First Responder Awareness (q)(6)(i)Non specified First Responder Operations (q)(6)(ii)8 Hours Hazardous Material Technician (q)(6)(iii)24 Hours Hazardous Materials Specialist (q)(6)(iv)24 Hours On Scene Incident Commander (q)(6)(v)24 Hours Emergency Response Refresher (q)(8)(i)Non specified Training Summary

OSHA/EPA/USCG/NIOSH manual entitled, "Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities“ USDOL, OSHA 3114 – Publication on HAZWOPER Single Source Pages, Hazardous Waste Multiple training resources are available HWWT program at RMCOEH Questions? Michael Hampton THANK YOU! Resources