Hazardous Waste Operations and Emergency Response Standard
Title 29 Code of
Federal Regulations (CFR) Part 1910.120
Known as: The
by Dr. Isabel Perry,
“The Safety Doctor”
This paper covers the requirements by Occupational Health
and Safety Administration (OSHA) for the handling and disposal of hazardous
waste.Hazardous wastes are chemicals
They can pollute our air, water or land, or cause fires or
explosions.This can occur where they
are stored in the company, when disposed of, and even long afterwards.
Hazardous waste is a serious problem that can cause health
and safety problems.This problem is not
just a concern when one disposes of waste, but far into the future.There are 25 states with OSHA-approved state
health and safety plans for the disposal of hazardous waste.State regulations must be at least as
stringent as the Federal ones.In these
states, the municipal, county and state employees such as police, firefighters
with local fire departments, and ambulance workers are covered.In the other 25 states without plans, these
workers are covered under EPA standards, which are based on OSHA standards.
Every organization must develop a health and safety program
that provides for the use, storage, and disposal of all hazardous chemicals and
waste, including emergency response to cleanup from spills.The standard covers workers in cleanup
operations at licensed sites and uncontrolled sites, including workers handling
emergency hazardous waste situations.
Developing a Health and Safety Program
The standard requires the development of a comprehensive
program to address all aspects of worker safety and hazard handling.The plan must:
¨Identify and evaluate, and control health and
¨Provide emergency response procedures for each:
storage and disposal facility
The program must have nine specific components:
A workplan should incorporate the following elements:
¨Procedures for implementation, including, but
not limited to:
i.Defining the tasks and objectives of the site plan
ii.Defining the logistics and resources required
¨Employer’s standard operating procedures to
protect the health and safety of employees
¨A person or person in charge of the program
i.Have a chain of command with accountability for
carrying out the program
ii.If there is more than one site, have a responsible
person at each site
¨Definition of the tasks and objectives of site
¨Logistics and resources required
ii.Requirements forplan implementation
¨If there is more than one site, requirements for
coordinating the program
HEALTH AND SAFETY PLAN
¨Includes all the basic requirements of the
health and safety plan
¨Identifies the hazards of each part of the
¨Must be kept at the site
¨Must conduct briefings before anyone enters the
site, and periodically after
¨Requires periodic inspections of the property
¨Correction of any deficiencies
EVALUATION AND CONTROL
¨A trained individual must conduct the first
evaluation to determine safety hazards and select appropriate protection for
¨Suspected conditions should also be part of this
¨A number of controls can be implemented to minimize
contamination of workers
¨Employers are required to develop and conduct
training for employees, contractors and subcontractors regarding:
i.Procedures of hazardous waste operations
ii.Degree of exposure likely
¨Employers are also required to develop and carry
out procedures to improve protection, such as the use of neutralizers,
absorbents, adsorbents, and foams.
¨Employers must develop and carry out a training
program for all levels of employees who work around or are exposed to hazardous
¨There are numerous levels and specifics of
¨Training specifications can require anywhere
from to 40 hours of training for any
one aspect of training needed.Most
employees are going to need numerous hours of training to give them sufficient
experience and competencies.
¨Written certification is required at the
completion of the training.
PROTECTIVE EQUIPMENT (PPE) PROGRAM
Employers must develop a PPE program for all employees
involved in hazardous waste operations.The PPE plan must include an explanation of the following:
¨Equipment selection and use
¨Maintenance and storage
¨Decontamination and disposal
¨Training and proper fit
¨Procedures for putting on and taking off
Where engineering controls aren’t possible, the employer
must provide the appropriate PPE for use specific to the site. Depending upon
the site, that might include:
¨Positive pressure air line respirators equipped
with an escape air supply
¨Totally encapsulating chemical protective suits
Employers must conduct air quality monitoring before workers
enter an uncontrolled hazardous waste site.They must accurately identify and quantify any airborne contaminants,
which might be immediately dangerous to life and health.Some of these might be:
¨Areas where toxic substance exposure are above
This makes it possible to:
¨Determine specific medical needs or monitoring
¨Assess the potential health risks of exposure
¨Determine the areas where protection and
controls are needed
¨Decide the appropriate PPE
Should there be a hazardous waste cleanup, the employer must
monitor any employees who were likely to have had a higher exposure to determine
whether they have had been exposed to levels in excess of permissible limits.
In a new work operation, the employer must monitor for any
potential condition that might be immediately dangerous to life and health or
for higher exposure levels
Employers must establish a medical surveillance program to
monitor employees, assessing the health and fitness of employees to work around
hazardous waste.Workers who fall under
¨Workers exposed for more than 30 days per year where:
employees are working with hazardous substances
permissible exposure limit is published
wear approved respirators
¨Those exposed to unexpected or emergency
situations (spills) of hazardous materials without wearing PPE or who show
signs or symptoms, signs or illness.
All exams are to be conducted:
¨Without cost to the employee
¨Without loss of pay
¨At a reasonable time and place
¨Be supervised by a licensed physician
¨Include medical and work history
¨Include special emphasis on symptoms related to
the handling of hazardous substances
¨Include fitness to duty, including the use of
Exams must be given:
¨Prior to job assignment
¨Every year unless the physician determines that
every two years is sufficient
¨When employment ends
¨Before reassignment to an area where medical
exams aren’t needed
¨As soon as possible for workers injured or ill
from exposure to hazardous substances
Physicians must be given:
¨A copy of the standard and its appendices
¨A description of the employee’s duties relating
to their exposure
¨The exposure level or expected exposure level
¨A description of any personal protective or
respiratory equipment used or to be used
¨Information from previous examinations
The physician must provide the employer with:
A written opinion with the exam results including any
medical conditions detected that would place the employee at increased risk
Any recommended work limitations
Any recommended use of PPE
The physician may NOT reveal, specific findings or diagnoses
unrelated to employment
¨All employees must be briefed before entering
the worksite on the decontamination procedures, which must be an integral part
of any Health and Safety plan.
¨The health and safety officer must monitor employee
decontamination or decontamination of the employee and disposal of their
clothing and equipment before they leave the workplace, including the solvents
used to decontaminate
¨Protective clothing must be decontaminated,
cleaned, maintained or replaced
¨Any person cleaning the clothing must be
informed that the clothing is potentially hazardous
¨The employer must provide the employees with
adequate showers and dressing rooms if they are required to shower
¨Develop emergency plans and implement them
before workers have to deal with hazardous waste
¨Make sure that all workers are trained in what
to do in case of an emergency situation, such as a spill.
The plan must contain the following elements at uncontrolled
hazardous waste sites, as well as at treatment, storage and disposal
¨Evacuation routes and procedures
¨Site security and control
¨Safe distances and places of refuge
¨Methods or procedures for alerting onsite
¨Procedures for lines of communication, lines of
authority, and personnel role
¨Emergency recognition and prevention
¨Emergency medical and first-aid treatment
¨Critique of response and follow-up
Additionally, the plan must include:
¨Prevailing weather conditions
¨Procedures for reporting incidents to federal,
state and local government agencies
¨Procedures compatible with government agencies
¨Regular rehearsals and periodic reviews of
¨A distinguishable alarm to use in alerting employees
to the emergency
¨Availability to federal government agencies
¨Institution of control methods
CONTROLS AND WORK PRACTICES
Wherever possible, the employer is supposed to put in place
engineering controls and work practices, including but not limited to PPE, use
of pressurized cabs, and control booths on equipment.Other procedures include removing
non-essential people from exposure while opening drums, wetting down dusty
operations, and placing employees on site upwind of a potentially dangerous
AND LABELING DRUMS AND CONTAINERS
¨Drums and containers must be labeled and
properly inspected before they can be handled.
¨Damaged drums and containers must be:
of contents – using a device classified for the material.
¨If there are leaks, ruptures or spills, suitable
containers must be used to collect the material, using an appropriate absorbent
material, and with the approved fire extinguishing equipment in case of fire.
¨Employees must be warned about the dangers of
handling containers that aren’t labeled.
¨Procedures for opening containers must be
¨Tools that prevent ignition are the only ones
that should be used.
¨Special care should be given when employees
handle shock sensitive waste explosive materials or laboratory waste packs.
oEvacuate all non essential employees.
oMake sure that you never lose communication.
oUse a barrier to protect equipment operators
¨Bulges, swells or crystalline deposits on the
outside of containers require special attention.
OF TEMPORARY WORKPLACES
Temporary worksites must have:
¨A supply of potable water and drink cups.
¨If permanent facilities don’t exist, toilet
facilities must be available in the form of:
only exception would be if it would violate local code.
¨All water outlets must be marked as safe or not
safe for drinking, washing or cooking.
¨Guards’ sleeping quarters must be provided near the
worksite that are well-lit and well-ventilated.
¨All workers must be provided with washing
facilities in a designated work area (controlled) within the worksite.
¨Food service must be provided by a licensed
¨Exposure records must be kept for 30 years.
¨Medical records must be kept for entire
employment plus 30 years.
¨Employees leaving before one year must be given
their records; the company is not required to keep them.
¨First aid records and one-time treatment records
don’t have to be kept.
¨Employers must notify employees of the
existence, availability and location of their records.
¨When a business closes permanently, the employer
must give the employees 3 months to access their records before the business closes.
¨The employer must also notify the National
Institute for Occupational Safety and Health.
Under the standard, medical records must contain:
¨Employees’ name and social security number.
¨Employees’ medical complaints related to
exposure to hazardous substances.
¨Physicians’ written opinions.
¨Information provided to the treating physician.
Title III of the Superfund Amendments and Reauthorization
Act of 1986 (SARA) requires:
¨Employers to maintain MSDS.
¨Submit this information to:
emergency response commissions
emergency planning committees
Hazardous waste is dangerous and must be handled
carefully.Employers and employees alike
want to have a safe work environment.This
can be accomplished only by working together.
Dr. Isabel Perry is
an internationally-known safety expert, motivational speaker, author, and
safety educator.Based in Orlando, Florida, she can be reached at 407-291-1209 or via e-mail at