The Ins and Outs of HAZWOPER or Is it a true HAZWOPER event or something else completely? Presented by Barry Rutledge, Senior EH&S Specialist Protech Environmental Compliance and Safety

Hazardous Waste Operations –Contaminated Sites Not our issue here Emergency Response –Chemical Spills May be our issue here or maybe not! HAZWOP ER

HAZWOP The Hazardous Waste Operations portion deals with those who work on contaminated work sites. Do these picture look like activities you might deal with?

Emergency Response The emergency response portion deals with those who are expected to respond to emergencies, like chemical spills. Do these picture look like activities you might deal with?

HAZWOPER, 29CFR Passed in Caused lots of confusion. Organization unsure how it affected them. Many went overboard in an attempt to comply. Most attempted to implement the full brunt of HAZWOPER.

HAZWOPER Implementation Maintenance workers and janitorial staffs transformed into Incident Response teams. Standard PPE was replaced with Moon Suite’s and SCBA’s equipped with escape bottles. Full decontamination procedures replaced common sense chemical hygiene. The spill area became the “Exclusion Zone” with “Reduction Zones” near by.

HAZWOPER Implementation (Continued) All that equipment was expensive to buy Expensive to maintain. It is confusing to use if not used regularly. So that brings us to training. 40 Hr. HAZWOPER training all the staff SCBA and Respirator training + medical 8 Hr. refresher training annually. Mock Spill Drills held annually.

HAZWOPER, 29CFR ? Is all this really necessary? The answer lies with your definition of Emergency

Emergency Defined Response to Emergencies requires a HAZWOPER style of response. Responses to non-emergencies do not.

What does the REG. say? “Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.”

Emergency Defined So OSHA gives you latitude in the Reg. According to the Reg., you don’t need a team of 40 Hr. trained HazMat Techs to clean up most spills you will see. From a Risk Management perspective you may still want to. The choice is yours to make!

Recognizing the Emergency 100ml bottle of 10% Sodium Azide broken on the floor in front of a fume hood. –Hazardous? –Response level needed? –What do you do? –Waste requirements

Recognizing the Emergency - Hazardous? - Response level need? - What do you do? - Waste requirements? (4-Nitro-1,2-phenylenediamine) Harmful Solid Irritant Possible mutagen

Recognizing the Emergency A broken 2.5 liter bottle of HCL between the air lock entry doors of a Vivarium. Very little ventilation. - Hazardous? - Response level need? - What do you do? - Waste requirements?

Recognizing the Emergency - Hazardous? - Response level need? - What do you do? - Waste requirements? Numerous broken containers from a refrigerator.

Recognizing the Emergency A pressurized 240 liter tank of acetonitrile with a broken fitting leaking in a “H” rated storage room equipped with secondary containment. Over 40 liters already spilled. - Hazardous? - Response level need? - What do you do? - Waste requirements?

Recognizing the Emergency Scientist reports a leak in a protein cleaving system which uses HF gas. The lab has been evacuated but there are people still in the rear offices. - Hazardous? - Response level need? - What do you do? - Waste requirements?

Recognizing the Emergency Three unknown victims are found laying on the floor in a chemistry laboratory. –The door is closed. –No apparent spill visible thru window in door. - Hazardous? - Response level need? - What do you do? - Waste requirements?

The Reg The HAZWOPER Regulation –Designed for Emergency Response –Not intended for small incidental spills –Requires lots of equipment –Requires lots of training –Requires lots of practice

Emergency Definition Size of spill Location of spill Compound spilled Hazards of materials Each case will be different

Response Full HAZWOPER Response Smaller response No response

Things to Think About The Law Your Organization Comfort Level Level of risk Risk Management Your Liability Employee Safety Student Safety Public Opinion So hang in there baby!