Hazardous Waste Operations and Emergency Response Training
The Resource Conservation and Recovery Act of 1976 (RCRA) provides for the development of federal and state programs for the development of resource recovery programs. It regulates anyone engaged in the creation, transportation, treatment, and disposal of hazardous wastes. It also regulates facilities for the disposal of all solid wastes and prohibits the use of open dumps for solid wastes in favor of requiring sanitary landfills.
There are, however, many hazardous waste disposal sites that were created prior to the passage of RCRA. These sites are often abandoned and contain unknown quantities of unknown wastes.
In response to the need to clean-up and properly reclaim these pre-RCRA sites, Congress enacted the Comprehensive Environmental Response, Compensation and Liability Act of 1980 (CERCLA) commonly known as Superfund. Superfund established two related funds to be used for the immediate removal of hazardous substances released into the environment. Superfund is intended to establish a mechanism of response for the immediate clean-up of hazardous waste contamination from accidental spills and from chronic environmental damage such as is associated with abandoned hazardous waste disposal sites.
The treatment and disposal of hazardous wastes under RCRA and CERCLA creates a significant risk to the safety and health of employees who work in treatment and disposal operations. Exposure to hazardous wastes through skin contact, skin absorption, and inhalation pose the most significant risks to employees. Employee exposure to these risks occurs when employees respond to hazardous substance or waste emergencies, when they work with hazardous wastes during storage, treatment and disposal operations or when they participate in the clean-up of abandoned-waste sites. This risk of exposure and the need for protecting employees exposed to hazardous wastes is addressed in the “Superfund Amendments and Reauthorization Act of 1986” (SARA).
In October of 1986 the “Superfund Amendments and Reauthorization Act of 1986 (SARA) became law. As part of SARA, in section 126 of Title I, Congress addressed the risk of injury to employees by providing that the Secretary of Labor issue interim final worker protection regulations within 60 days after the date of enactment of SARA that would provide no less protection for workers engaged in hazardous waste operations than the protection contained in the U.S. Environmental Protection Agency’s (EPA) Health and Safety Requirements for Employees Engaged in Field Activities” manual (EPA Order 1440.2 dated 1981, and the existing OSHA standards under Subpart C of 29 CFR Part 1926. OSHA published those interim final regulations in the Federal Register in December 1986 (51 FR 45654).
OSHA’s Hazardous Waste Operations and Emergency Response regulation became effective in December 1986 in accordance with section 126(e) of SARA, and applies to all regulated workplaces. OSHA utilized several sources for the proposal. These included the EPA manual entitled “Health and Safety Requirements for Employees Engaged in Field Activities” (1981) and various documents issued either jointly or separately by the EPA, OSHA, the U.S. Coast Guard, and the National Institute for Occupational Safety and Health (NIOSH).
Employee training programs presented prior to 1986 which have the designation of EPA Order 1440.2 are instruction agendas developed using the EPA Health and Safety Requirements for Employees Engaged in Field Activities manual.
In other words, the EPA document Health and Safety Requirements for Employees Engaged in Field Activities (EPA Order 1440.2 dated 1981 was a guideline for the development of the OSHA standard Hazardous Waste Operations and Emergency Response.
OSHA or Occupational Health Assessment
- Accident Experience
a. Number and type of accidents
b. First-Aid Cases
c. Worker’s Compensation numbers
d. Recordable injury/illness - Employee Education and Training
a. New employee orientation
b. Standardized operating procedures
c. OSHA mandated training - Safety Standards for Equipment
a. Machine guarding
b. Material handling
c. Personal protective equipment
d. Chemical hazard control
e. Flammable & explosive material control
f. Ventilation
g. Waste disposal - Inspections
a. Identify potential hazards
– production
– maintenance
– warehousing
b. Internal plant audits - Personal Protective Equipment
- Safety Meetings
- Chemical Hazards Control
a. Hazard evaluation capability
b. Written safe work practices
c. Annual employee training in health hazards of chemicals - Hazard Communication Program
a. Master file of MSDS’s
b. Notification to employees of location
c. Required annual training
d. Documentation - Chemical Exposure Monitoring
a. Chemicals to be monitored and monitoring frequency
b. Baseline and periodic monitoring studies conducted
c. Technical skills to conduct monitoring
d. Recordkeeping procedures - Hearing Conservation
a. Noise exposure measurement and recordkeeping
b. Mandatory hearing protection areas designated and enforced
c. Audiometric testing program
d. Annual employee training program - Respiratory Protection Program
a. Written respiratory protection program
b. Appropriate types of respiratory selected & properly used
c. Annual employee training program, including fit-testing
d. Respiratory protection inspections, maintenance, storage and cleaning program
e. Annual medical surveillance - Additional Program Areas
a. Heat stress
b. Indoor air quality