Post on 12-Mar-2018
1
HAZWOPER
Overview
Hazardous
Waste
Operations
and Emergency
Response
(HAZWOPER)
29 CFR 1910.120
29 CFR 1926.65
Objectives
Define application of HAZWOPER
standard
Discuss emergency response general
requirements
Define emergency response
Discuss levels of response
Discuss competencies for each level
Discuss training requirements
2
Application
Hazardous waste cleanup sites
– Superfund
– Voluntary
RCRA TSD facilities
– Also addresses corrective actions
Emergency response
Application
Hazardous waste cleanup sites
– Superfund
– Voluntary
RCRA TSD facilities
– Also addresses corrective actions
Emergency response
Application
Hazardous waste cleanup sites
– Superfund
– Voluntary
RCRA TSD facilities
– Also addresses corrective actions
Emergency response
3
General Requirements
Scope, application & definitions (a)
Safety & health program (b)
Evaluation of site’s characteristics (c)
Site control program to protect employees
against contamination (d)
Training (e,q)
Medical surveillance (f)
Reduce exposure below established exposure
levels (g)
Air monitoring (h)
General Requirements
Informational program (i)
Container handling (j)
Decontamination procedure (k)
Emergency response at uncontrolled
sites (l)
– Emergency response plan to handle
possible on-site emergencies
– Off-site emergency response plan
General Requirements
Illumination (m)
Sanitation (n)
New technology programs (o)
RCRA operation (p)
Emergency response (hazmat) (q)
4
Cross-referencing
Considerable cross-referencing between
(b)-(o) & (q)
Reflects fact that cleanup operations &
emergency response aren’t fundamentally
different from each other
Difference is primarily in time factor
Paragraph “q”
Emergency response
program to
“hazardous substance
releases”
Addresses employers
whose workers are
engaged in
emergency response,
no matter where it
occurs
What is an Emergency?
Opt-out?
Everybody’s definition is somewhat
different
Incidental spill
Emergency requiring an emergency
response team
– Internal response
– External response
5
Emergency Action Plan
Procedures for reporting fire or other
emergency
Procedures for emergency evacuation,
including type of evacuation & exit route
assignments
Procedures to be followed by employees
who remain to operate critical plant
operations before they evacuate
Procedures to account for all employees
after evacuation
Emergency Action Plan
Procedures to be followed by employees
performing rescue or medical duties
Employee alarm system
Training
Review of plan
Emergency Response Plan
Pre-emergency planning & coordination
with outside parties
Personnel roles, lines of authority, training
& communication
Emergency recognition & prevention
Safe distances & places of refuge
Site security & control
6
Emergency Response Plan
Evacuation routes & procedures or shelter-
in-place
Decontamination
Emergency medical treatment & first aid
Emergency alerting & response
procedures
Critique of response & follow-up
PPE & emergency equipment
Procedures for Handling
Emergency Response
Senior emergency response official
responding to emergency shall become
individual in charge (Incident Commander
or IC) of site-specific Incident Command
System (ICS)
All emergency responders & their
communications shall be coordinated &
controlled through Incident Commander,
assisted by senior official present for each
employer
Procedures for Handling
Emergency Response
Incident Commander shall identify, to
extent possible, all hazardous substances
or conditions present & shall address as
appropriate site analysis, use of
engineering controls, maximum exposure
limits, hazardous substance handling
procedures & use of any new technologies
7
Procedures for Handling
Emergency Response
Back-up personnel shall be standing by
with equipment ready to provide
assistance or rescue
Qualified basic life support personnel, as
minimum, shall also be standing by with
medical equipment & transportation
capability
Procedures for Handling
Emergency Response IC shall designate Safety
Officer, who is
knowledgeable in
operations being
implemented at site, with
specific responsibility to
identify & evaluate hazards
& provide direction with
respect to safety of
operations for emergency
at hand
Can overrule IC [(q)(3)(viii)]
Procedures for Handling
Emergency Response
After emergency operations have
terminated, Incident Commander shall
implement appropriate decontamination
procedures
8
Training
Training
Training shall be based on duties &
function to be performed by each member
of emergency response organization
Skill & knowledge levels required for all
new responders shall be conveyed to them
through training before they are permitted
to take part in actual emergency
operations
“Certification”
It is responsibility of employer to “certify”
employee to any given competency level
Certificate of training or attendance is not
same thing as “certification”
9
Training Competency
Hierarchy
Each competency level builds on level(s)
preceding it, with each getting
progressively longer & more complex
First Responder
Awareness Level
First Responders at Awareness Level are
individuals likely to witness or discover
hazardous substance release & trained to
initiate emergency response sequence by
notifying proper authorities of release
They take no further action beyond
notifying authorities of release
First Responder
Awareness Level
Approximately 8 hours of training
Similar to OSHA Hazcom (1910.1200)
1910.120(q)(6)(i)
10
First Responder
Awareness Level
First Responders at Awareness Level have
sufficient training or sufficient experience
to objectively demonstrate competency in
following areas:
Awareness
Competencies
Recognize presence of
hazardous substances
in emergency
Identify hazardous
substances, if possible
POISON
GAS
2
Awareness Competencies
Understand what hazardous
substances are & risks
associated with them
Understand potential
outcomes associated with
emergency created when
hazardous substances are
present
11
Awareness Competencies
Ability to realize need for additional
resources & make appropriate notifications
to communications center
Awareness Competencies
Understand role of first
responder awareness
individual in employer's
emergency response
plan including site
security & control &
DOT Emergency
Response Guidebook
(ERG)
First Responder
Operations Level
First Responders at Operations Level
respond to releases or potential releases
of hazardous substances as part of initial
response to site for purpose of protecting
nearby persons, environment or property
from effects of release
12
First Responder
Operations Level
First Responders at Operations Level shall
receive at least 8 hours of training or have
sufficient experience to objectively
demonstrate competency
Builds on Awareness competencies
Courses are 16-24 hrs with 24 being
common
1910.120(q)(6)(ii)
First Responder
Operations Level Trained to respond in
defensive fashion
without actually trying to
stop release
Function to contain
release from safe
distance, keep from
spreading & to prevent
exposures
Are stand-off
(confinement) actions
Operations Competencies
Understanding of basic hazardous
materials terms
Knowledge of basic hazard & risk
assessment techniques
Perform basic control, containment &/or
confinement operations
13
Operations Competencies
Implement basic decontamination
procedures
Understanding of relevant Standard
Operating Procedures (SOPs) & Standard
Operating Guidelines (SOGs)
Select & use proper Personal Protective
Equipment (PPE) (Level B maximum)
Hazmat Technician Level
Hazmat Technicians respond to releases
or potential releases for purpose of
stopping release
Assumes more aggressive role than
Operations & will approach point of release
in order to plug, patch or otherwise stop
release of hazardous substance
Hazmat Technician Level
Technicians receive
minimum of 24 hrs of
training equal to
Operations level
Builds on Awareness
& Operations
competencies (pre-
requisites)
1910.120(q)(6)(iii)
14
Hazmat Technician Level
Respond in offensive
fashion in trying to
stop release
May have substantial
exposures due to
offensive actions
Are hands-on
(containment) actions
Technician Competencies
Understand more advanced chemical &
toxicological terminology & behavior
Understand more advanced hazard & risk
assessment techniques
Implement employer's emergency
response plan
Perform assigned role(s) within Incident
Command System (ICS)
Technician Competencies
Select use proper advanced chemical PPE
(Level A)
Perform more advanced control,
containment and/or confinement
operations
Classify, identify & verify known &
unknown materials by using field survey
instruments & equipment
15
Technician Competencies
Understand & implement decontamination
procedures
Understand termination procedures
Hazmat Specialist Level
Hazmat
Specialists
respond with &
provide support
to Hazmat
Technicians
Hazmat Specialist Level
Duties parallel
Hazmat Technician,
but require more
directed or specific
knowledge of
various substances
16
Hazmat Specialist Level
Receive at least 24 hours of Technician-
level training & in addition have
competency in following areas:
Specialist Competencies
Understand advanced hazard & risk
techniques
Understand chemical, radiological &
toxicological terminology & behavior
Know state emergency response plan
Develop site safety & control plan
Specialist Competencies
Select & use proper specialized chemical
PPE
Perform specialized control, containment
&/or confinement operations
Determine & implement decontamination
procedures
17
Specialist Competencies
Act as site liaison with Federal, state, local
& other government authorities in regards
to site activities
Incident Command Level
Incident Commanders assume control of
incident scene beyond First Responder
Awareness Level & shall receive at least
24 hrs of training equal to First Responder
Operations Level & in addition have
competency in following areas:
Incident Command
Competencies
Implement
employer's Incident
Command System
Implement
employer's
Emergency
Response Plan
18
Incident Command
Competencies
Understand
hazards & risks
associated with
employees
working in
chemical
protective clothing
Incident Command
Competencies
Implement local emergency response plan
Know of state emergency response plan &
Federal Regional Response Teams
Incident Command
Competencies
Understand
importance of
decontamination
procedures
19
Skilled Support Personnel
Personnel, not necessarily employer's
own, skilled in operation of certain
equipment
– Mechanized earth moving or digging
equipment
– Crane & hoisting equipment
Needed temporarily to perform immediate
emergency support work that can’t be
performed by employer
Skilled Support Personnel
Will be or may be exposed to hazards at
emergency response incident
Shall be given initial briefing at site prior to
participation
Briefing shall include instruction in
appropriate PPE, chemical hazards
involved & duties to be performed
Specialist Employees
Employees as part of regular job duties,
work with & are trained in hazards of
specific hazardous substances
Will be called on to provide technical
advice or assistance to IC
Shall receive annual training or
demonstrate competency in specialization
area
20
Hazmat Trainers
Trainers shall have satisfactorily completed
training course, such as courses offered by
the US National Fire Academy, or have
training &/or academic credentials &
instructional experience necessary to
demonstrate competent instructional skills
and good command of subject matter
Refresher Training
Employees trained in accordance with
paragraph (q)(6) of this section shall
receive annual refresher training of
sufficient content & duration to maintain
competencies, or shall demonstrate
competency in those areas at least yearly
Document training and how it was
conducted
Medical Surveillance
Members of hazmat teams shall receive
baseline physical examination & be
provided with medical surveillance as
required in paragraph (f) of HAZWOPER
– All employees exposed to HM or health
hazards ≥PEL/TLV, without regard to
respirators, for ≥30 days/year
– All employees who wear respirator for ≥30
days/year or as required by 1910.134
21
Medical Surveillance
…be provided with medical surveillance as
required in paragraph (f) of HAZWOPER
– Any employee who exhibits signs or
symptoms resulting from exposure to
hazardous substances during course of
emergency or cleanup, either immediately or
subsequently, shall be provided with medical
consultation as required in paragraph (f)(3)(ii)
Chemical Protective Clothing
Chemical protective clothing & equipment
shall meet requirements of paragraphs
(g)(3)-(5) of HAZWOPER
Appendix B
Post-emergency Response
Upon termination of emergency response,
if determined necessary to remove
hazardous substances, health hazards &
materials contaminated with them
(contaminated soil or other elements of
natural environment) from site, employer
conducting cleanup shall comply with one
of following:
22
Post-emergency Response
Meet all requirements of paragraphs (b)-
(o) of standard; or
For in-plant cleanups using plant or
workplace employees, meet training
requirements of: 29 CFR 1910.38(a);
1910.134;1910.1200 & other appropriate
safety & health training made necessary
by tasks expected to perform
All equipment shall be in serviceable
condition & inspected prior to use
1910.120 Appendix E
Training Curriculum Guidelines core
criteria
These are criteria that compliance officers
look for
OSHA’s attempt to give you help in
evaluating internal training programs
Can also be used for evaluating outside
training providers
Appendix E - Training
Curriculum Guidelines
Training facility
Training Director
Instructors
Course materials
Students
Ratios
Proficiency
assessment
Course certificate
Recordkeeping
Program quality
control