OSHA Hazwoper FactSheet - FAQs ABout OSHA Required Hazwoper Hazardous Materials Training

OSHA Hazwoper FactSheet - FAQs ABout OSHA Required Hazwoper Hazardous Materials Training

HAZARDOUS WASTE OPERATIONS, 29 CFR 1910.120

• What is the actual language from the Superfund Amendment and Reauthorization Act that expanded OSHA's regulatory authority to create the HAZWOPER regulation?
• At a permitted RCRA site, how does the RadCon Manual interface with the HAZWOPER standard in those instances where the radiation is a constituent of the waste? and when it is coincidental?

SCOPE AND APPLICATION

• Do all of the requirements of 1910.120 apply if a site characterization analysis reveals no hazards?
• Under 1910.120(a)(1), "Scope", OSHA indicates that "This section covers the following operations, unless the employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety or health hazards." How broadly does OSHA define safety and health hazards in this clause. For instance, while working in the desert there are always the hazards of snake and spider bites, as well as slips, trips, and falls. Is the exception limited to demonstrating no hazardous waste-related hazards?
• Do the HAZWOPER training requirements apply when you are digging in soil which has a high natural silica content but no hazardous waste, i.e. the only hazardous exposure is coincidental to the operation and not directly related to the hazardous waste activity?

• Are the HASP and training requirements applicable to regulated disposal of low level medical wastes? The TSD facility has a disposal shaft for low level radioactive wastes. Trucks transport lined casks, size 30 gallons or less, containing these wastes to the shaft, where the casks are unloaded and rolled down the shaft for disposal. Monitoring has demonstrated no worker exposures above allowable levels and no surface contamination of personnel or clothing. When casks are being unloaded, a 100 foot exclusion zone is created around the shaft to keep out all unauthorized personnel. Fall protection is recognized as the major safety issue for the driver and the radcon technician, who are the only workers involved in this operation.
• Is 1910.120 applicable to people who are doing construction work in contaminated soil that is unrelated to the cleanup activities for the site? For example, are workers who are trenching in order to lay utility pipes covered by HAZWOPER? The removed soil will be staged and removed by another contractor and the groundwater, which is contaminated, will be pumped out of the excavation to a holding tank.
• Is underground storage tank (UST) remediation work covered under the HAZWOPER standard (29 CFR 1910.120)? The operation involves the removal of underground petroleum storage tanks.

HAZARDOUS WASTE SITE REMEDIATION

• Is the Health and Safety Officer required to be on site under HAZWOPER? Is substitution of an alternate acceptable?
• For HAZWOPER workers working a hazardous waste site, is 1910.120(q) applicable when they are expected to respond to spills or releases in their work area? These workers are covered by 1910.120(b)-(o).
• Are there any interpretations regarding provision of drinking water on hazardous waste sites.
• How do the medical surveillance requirements of HAZWOPER mesh with other OSHA standards for respiratory protection and specific chemicals?

HAZWOPER TRAINING REQUIREMENTS

• The question concerns the minimum training requirements for visitors, auditors, and non-workers at a DOE hazardous waste site. The caller pointed out that a guidance document entitled "OSHA Training Requirements for Hazardous Waste Operations" dated December 1991 (DOE/EH-0227P) is in conflict with a requirement in the HAZWOPER standard. Based on the 1991 DOE requirements, what are the minimum training requirements for visitors, auditors, and non-workers observing work at a hazardous waste site?
• What does 1910.120 mean in (e)(5) regarding the qualifications of instructors?
• Is there an exemption from the training requirements of 1910.120 for people with experience, such as CIH's and CSP's?
• How do you document the 3-day field experience required under 1910.120(e)?
• If a worker has not completed the refresher training within 12 months of the initial training or subsequent annual refresher training, is the worker required to take the initial training again in order to qualify for field work?
• How much time can be reasonably expected for an employee who was trained under a specific standard and has become inactive or allowed the re-certification time to lapse before the employee must take the training again? For instance the RAD-CON Manual (April 1994, pp. 6-4) specifies radiological training shall be completed every two years, radiological worker I and II retraining shall be completed every 2 years. The caller is aware of an OSHA interpretation pertaining to the amount of time permitted before retraining is required under 1910.120, HAZWOPER. OSHA permits up to 3 years to lapse. The caller wants to know what other information is available about retraining and the amount of time allowed to lapse (i.e., Asbestos Standard 1910.1001)?
• Can the 8 hour supervisor course be used to fulfill the requirement for 8 hours of refresher training the year a general hazardous waste site worker becomes a supervisor?

TREATMENT, STORAGE AND DISPOSAL FACILITIES

• What is meant by a storage facility in 1910.120(p)? The caller's facility stores waste process solutions for a few weeks, but is not an EPA permitted storage facility under RCRA. Does this waste storage fall within the scope of 1910.120(p)?

• A hazardous waste treatment, storage and disposal facility (TSDF) has a site wide health and safety plan (HASP) that covers all routine activities. Is it acceptable to break out non- routine activities and allow SOPs to cover those activities? Employees performing the non-routine activities are escorted by a site representative.
• Are supervisors required to have specific training under 1910.120 (p)?

US DOE ISSUES

• Are there DOE orders that say 1910.120(q) is applicable? The caller asks for clarification of the training requirements for visitors to TSD facilities.
• The DOE "OSHA Training Requirements for Hazardous Waste Workers", December, 1991 indicates in Attachment 1 that non-worker/visitors do not need the 24-hour initial training and the caller believes that this conflicts with 1910.120(p).
• A contractor is moving contaminated equipment in a hazardous waste/radiologically contaminated area. In another scenario a contractor needs to enter the same site to do non- hazardous work, such as fix a sprinkler head. Does DOE recognize "visitor" status if the visitor is escorted?

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