Occupational Safety
Employers must develop programs that identify, evaluate and control health and safety hazards and provide response procedures for each hazardous waste site or storage facility.
Programs must include specific information on the following:
- Organizational Work Plan
- Site Evaluation and Control
- A Site-specific Safety and Health Plan
- Information and Training Program
- Personal Protective Equipment Program
- Monitoring
- Medical Surveillance Program
- Decontamination Procedures
- Emergency Response Program
- Other Provisions
Program must be made available to all affected part-time and full-time employees, and be updated periodically. For more information, visit Occupational Health and Safety Administration website at http://www.osha.gov/.
Organizational work plan
A workplan needs to be implemented that supports all Standard Operating Procedures for health and safety. This includes the establishment of a chain of command that specifies employer and employee responsibilities in activating the health and safety program. The workplan is also designed to define the aims and tasks of site operation and the logistics and resources required to perform these tasks. For example, the workplan should include the name of the person who supervises all of the hazardous waste operations, and the anticipated clean-up and/or operating procedures in the event of an accident.
Site evaluation and control
Evaluation of the facilities provides workers with the information needed to identify site hazards or even potential hazards. A trained person must conduct a preliminary evaluation of an uncontrolled hazardous waste site prior to entering. This appraisal must include any or all conditions that are suspicious of being immediately dangerous to life and health. An evaluation must include: the location and size of the site, topography, accessibility by air and roads, pathways for hazardous substances to disperse, detailed descriptions of worker duties, the amount of time needed to perform a given task, and the present status and capabilities of the emergency response team. Re-evaluations should be conducted periodically for treatment, disposal and storage facilities as conditions and operations change.
Controlling the activities of workers and the movement of equipment is another aspect of the health and safety program. This will minimize potential contamination of workers and protect the public from hazards. In implementing a site control program, the following info can be useful: site maps, site work zones, site communication, safe work practices, and the name, location and phone number of the nearest medical assistance.
A Site-specific Safety and Health Plan
This is considered a complementary program that assists in the control of anticipated safety and health hazards. This plan differs from the general health and safety program in that it incorporates characteristics that are unique to a particular site. For instance, a site-specific plan may discuss procedures for confined space entry, air and personal monitoring and environmental sampling, and a spill containment program to address particular hazards present at the site.
The site-specific safety and health plan must identify the hazards of each phase of the specific site operation and must be kept at the work site. Pre-entry briefings are included in the site-specific plan and must be conducted prior to site entry. Periodic safety and health inspections are an integral part of this facet of the overall plan.
Information and Training Program
Part of the safety and health program concerns the employee’s right-to-know. Workers must be informed of the potential hazards presented to them during the course of their jobs, specifically in performing hazardous waste operations; they must be aware of the level and degree of exposure they are likely to encounter. It is the employer’s responsibility to develop and implement procedures for introducing innovative technologies that may improve worker protection in hazardous waste operations.
In addition, a training program must be developed to ensure the safety of those who operate under hazardous conditions on a regular basis. Supervisors and workers alike must be trained to recognize hazards and know how to prevent them, to select, care for, and use protective equipment properly, to understand engineering controls and their use, to use proper decontamination procedures, and to understand all appropriate work practices, such as the emergency response plan. Workers are required to know the names of personnel and their alternates who are responsible for site safety and health.
Employees are not permitted to perform any hazardous waste operations unless they have been adequately trained, and these requirements are defined by the nature of their work. Certification is necessary to demonstrate that the proper education has been conducted upon completion of any training program. In addition, all emergency responders must have annual refresher training to ensure their competency.
Personal Protective Equipment Program
The employer must also develop a documented Personal Protective Equipment (PPE) program for employees who routinely work in hazardous waste operations. This is part of the site-specific plan and must include (but is not limited to) the following information: explanation of equipment selection and use, maintenance and storage, decontamination and disposal, training and proper fit, inspection procedures, in-use monitoring, and program evaluation and equipment restrictions.
Personal Protective Equipment ranges in level of protection provided, from A-D, with A being the highest level, fit for the most hazardous operations. PPE must be selected that is appropriate for the requirements and limitations of the site, the task-specific conditions and duration, and the hazards and potential hazards identified at the site.
Monitoring
One major component of hazardous waste operations is the potential for airborne contaminants to threaten personal health and safety. Therefore, air monitoring is an important part of an effective safety and health program. Monitoring must be conducted by the employer prior to entry at uncontrolled hazardous waste sites. Reliable information regarding air quality can be useful for the selection of personal safety equipment, the delineation of areas where protection and controls are needed, assessing the potential health effects of exposure, and determining the need for specific medical monitoring.
After the commencement of a hazardous waste clean-up operation, the employer is required to periodically monitor those employees who are at high risk for exposure to scrutinize their health and safety. Any potential condition that is deemed immediately dangerous, or for higher exposures that may occur as a result of new work operations must also be thoroughly monitored by the employer.
Medical Surveillance Program
In order to assess and monitor the health and fitness of employees working with hazardous substances, a medical surveillance program must be developed. The surveillance provided will vary depending on health risks of those employees who qualify for this added measure of safety; for example, workers who wear approved respirators for 30 or more days per year on the site, and members of HAZMAT teams fall under this category.
All examinations have to be performed by a licensed physician at no cost to the employee. They must also include a medical and work history with special emphasis on symptoms related to the handling of hazardous substances, as deemed necessary by their job. These examinations must be given in the following manner: prior to job assignment and annually thereafter, at the termination of employment, prior to reassignment to an area where medical exams are not required, at the physician’s suggestion, and as soon as possible for employees who are injured due to overexposure to hazardous substances.
Decontamination Procedures
This is another component of the site-specific safety and health plan, and must be implemented before workers enter a hazardous waste site. The person in charge of site safety must enforce and supervise (if necessary) the decontamination and disposal of the employee’s clothing, equipment and solvents used for decontamination before the employee leaves the work area. All protective clothing and equipment must be decontaminated, cleaned, laundered, maintained or replaced to maximize effectiveness.
Emergency Response Program
Emergency planning and response are important elements of the health and safety program because they minimize injury due to exposure. The employer must develop a written response plan to handle possible emergencies before performing hazardous waste operations. The plan has to include the following components: personnel roles, lines of authority, and communication procedures, pre-emergency planning, emergency recognition and prevention, emergency medical and first-aid treatment, methods or procedures for alerting on-site employees, safe distances/ places of refuge, site security and control, decontamination procedures, critique of response and follow-up, personal protective and emergency equipment, and evacuation routes and procedures.
The plan must also include site topography, layout, and prevailing weather conditions, as well as procedures for reporting incidents to local, state, and federal government agencies. The plan must be rehearsed regularly, reviewed periodically, and amended as necessary to keep them up-to-date with new or changing site conditions or information. A distinct alarm system must be in operation at all times to notify employees of emergencies, and the emergency plan must be made available for inspection and copying by employees, their representatives, OSHA personnel, and other governmental agencies with relevant responsibilities. Furthermore, back-up and first-aid support personnel must be made available for immediate assistance.
Other Provisions
- Engineering Controls and Work Practices
- Proper Handling and Labeling of Drums and Containers
- Sanitation of Temporary Workplaces
- Record-Keeping