HAZWOPER

HAZWOPER ( /ˈhæzwɒpər/) is an acronym for Hazardous Waste Operations and Emergency Response. It refers to five types of hazardous waste operations conducted in the United States under OSHA Standard 1910.120 "Hazardous Waste Operations and Emergency Response." The standard contains the safety requirements employers must meet in order to conduct these operations.

Contents

History

In 1978, the Love Canal disaster and Valley of the Drums[1] awakened America to the need to control and contain hazardous waste in the United States. Two programs, CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act, and RCRA, the Resource Conservation and Recovery Act of 1976 were implemented to deal with these wastes. CERCLA, also known as the Superfund, was designed to deal with already existing waste sites while RCRA was designed to deal with newly generated wastes. Originally, the term HAZWOPER was derived from the United States Department of Defense's Hazardous Waste Operations (HAZWOP), implemented on military bases which were slated for clean-up operations to dispose of hazardous wastes that were left on-site after World War II. One such location is the Hanford Site, where materials for the first nuclear bomb to be used in war were produced. The over 500-square-mile (1,300 km2) site is run by the US Government and constructors such as some of the world's largest like Bechtel National, Inc. and others.[2] Mike Moore (former OSHA employee) and others who worked on the original standards with OSHA created HAZWOPER as it was based on input from OSHA, USCG, NIOSH, and United States Environmental Protection Agency (EPA). In 1984 the joint agency effort published the Hazardous Waste Operations and Emergency Response Guidance Manual.[3] In 1989, OSHA promulgated the standard in 1990 March 6 as the HAZWOPER Standard, 1910.120,[4][5] Hazardous Waste Operations and Emergency Response which codified the safety and health requirements companies would have to meet in order to perform hazardous waste cleanups or to respond to emergencies.

The Occupational Safety and Health Administration (OSHA) [6] recently released an interpretation; the HAZWOPER 40-Hour training for clean-up workers will not suffice as technician level training for emergency response situations. This was in response to a letter from TRC in Indiana. However, (as a result of the Gulf Deepwater Horizon Oil Spill) according to the Washington D.C. compliance division, OSHA may make exceptions to HAZWOPER 40-Hour trained workers in marine modules being allowed to do technician-level work in the water and on the beaches where they could potentially come in contact with hazardous substances. Site safety and health officers in conjunction with the Site Specific Health and Safety Plan verify marine compliance on chemical or oil spill clean-ups in coordination with other agencies. A Site Safety Supervisor typically has 40 hours of HAZWOPER training unless they are required to go on.

Scope

The HAZWOPER standard covers 5 specific areas of operations, including:

  1. Clean-up operations required by a governmental body, whether Federal, state local or other involving hazardous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the EPA's National Priorities List of sites (NPL), state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are conducted before the presence or absence of hazardous substances has been ascertained);
  2. Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq);
  3. Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;
  4. Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and
  5. Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.

Hazardous wastes are defined by the standard as:

[A] A waste or combination of wastes as defined in 40 CFR 261.3,[7] or

[B] Those substances defined as hazardous wastes in 49 CFR 171.8.[8]

The term HAZWOPER recently has been referenced in international cleanup, mostly where U.S. military bases are still being cleaned up, or in some cases with NATO allies such as Canada, particularly when U.S. firms are involved with Hazardous Waste Operations and Emergency Response. While the OSHA standard does not apply to these operations, some of the countries involved are working on adopting similar standards to protect workers. In some cases it has proven difficult because they lack the safety infrastructure that the HAZWOPER standard is built on.

Levels of Training

OSHA recognizes several levels of training, based on the work the employee will be performing and the level of hazard they will be facing. Each level requires a different training program, and OSHA specifies topics and minimum training times.

  1. General site workers initially require 40 hours of instruction, 3 days of supervised hands on training, and 8 hours of refresher training annually
  2. Workers limited to a specific task or workers on fully characterized sites with no hazards above acceptable levels require 24 hours of initial training, 1 day supervised hands on training, and 8 hours of refresher training annually
  3. Managers and supervisors require the same level of training as the people they supervise, plus 8 additional hours of training
  4. Workers who are working at a Treatment, Storage, or Disposal facility that handles RCRA wastes require 24 hours of initial training and 8 hours of refresher training annually
  5. First Responder Awareness level require sufficient training to demonstrate competency in their assigned duties
  6. First Responder Operations level Awareness level training plus 8 hours training
  7. Hazardous Materials Technician 24 hours training plus additional training to achieve competency in several areas
  8. Hazardous Materials Specialist 24 hours training at the technician level, plus additional training to achieve competency in several areas
  9. On Scene Incident commander 24 hours training plus additional training to achieve competency in several areas

The training is what makes HAZWOPER unique. In some instances the training levels may or may not overlap in other cases these are prohibited by OSHA because workers without specific training may not be able to characterize waste unless trained to do that task.[9] The Site Safety Supervisor or Officer should be consulted and a competent industrial hygienist or other technically qualified person who is HAZWOPER trained.

Training and Certification Sources

There are many sources for OSHA compliant HAZWOPER training. Community colleges, labor unions, employers, and training companies are all good sources for training. The employer must ensure the training provider covers the areas of knowledge required by the standard and provides certification to the student that they have passed the training. The certification attaches to the student, not the employer, so it is imperative that the trainer cover all aspects of HAZWOPER operations, not just those expected at the current worksite.

See also

References

  1. ^ http://www.epa.gov/superfund/sites/npl/nar447.htm
  2. ^ http://www.hanford.gov/?page=78&parent=15
  3. ^ DHHS (NIOSH) (October 1985), Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, pp. 142, Pub. no. 85-115, http://www.cdc.gov/niosh/85-115.html, retrieved 2011-02-22 
  4. ^ 29CFR1910.120 Hazardous Waste Operations and Emergency Response
  5. ^ "Hazardous waste operations and emergency response (HAZWOPER)". Occupational Safety and Health Administration (OSHA). 2006. U.S. Patent 1,910,120. http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9765. Retrieved 17 February 2010. 
  6. ^ http://www.osha.gov
  7. ^ 40 CFR 261.3 Identification and listing of hazardous waste
  8. ^ 49 CFR 171.8 General information, regulations, and definitions
  9. ^ http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27187

External links