Listed below are several items that relate to HAZWOPER work. If you are new or have been in this field for a while, you may find this information of use.

40 Hour HAZWOPER (Hazardous Waste Operations and Emergency Response) Respirators

Self-Contained Breathing Apparatus (SCBA)
A 40 Hour HAZWOPER self-contained breathing apparatus (SCBA) usually consists of a facepiece connected by a hose and a regulator to an air source (compressed air, compressed oxygen, or an oxygen-generating chemical) carried by the wearer. SCBAs offer protection against most types and levels of airborne contaminants. However, the duration of the air supply is an important planning factor in SCBA use. This is limited by the amount of air carried and its rate of consumption. In addition, SCBAs are bulky and heavy; thus, they increase the likelihood of heat stress and may impair movement in confined spaces. Under MSHA regulations in 30 CFR Part 11.70(a), SCBAs may be approved for both entry into and escape from a hazardous atmosphere or escape only.

Escape-Only SCBA Respirators
During 40 hour HAZWOPER work, Escape-only SCBAs are frequently continuous-flow devices with hoods that can be donned to provide immediate emergency protection. Employers should provide and ensure that employees carry an escape SCBA where such emergency protection may be necessary.

Entry-and-Escape SCBA Respirators
40 hour HAZWOPER entry-and-escape SCBA respirators include an air tank worn by the worker. Entry and escape SCBAs give workers untethered (i.e., unrestricted) access to nearly all portions of the work site. However, they decrease worker mobility, particularly in confined areas, because of the bulk and weight of the units. Their use is particularly advisable when dealing with unidentified and unquantified airborne contaminants. Generally, these 40 hour HAZWOPER SCBAs are required of workers operating in oxygen deficient atmospheres (under 19.5 percent), in contaminated zones, and in atmospheres that are Immediately Dangerous to Life and Health (IDLH).

Two types of entry-and-escape SCBAs are:
– Open-circuit In an open-circuit SCBA, air is exhaled directly into the ambient atmosphere.
– Closed-Circuit In a closed-circuit SCBA, exhaled air is recycled by removing the carbon dioxide with an alkaline scrubber and by replenishing the consumed oxygen with oxygen from a solid, liquid, or gaseous source.

As required by MSHA/NIOSH 30 CFR Part 11.80, all 40 hour HAZWOPER compressed breathing gas cylinders must meet minimum U.S. Department of Transportation requirements for HAZWOPER interstate shipment. (For further information, see 49 CFR Part 173 and 178.) All compressed air, compressed oxygen, liquid air, and liquid oxygen used for respiration shall be of high purity and must meet all requirements of OSHA 29 CFR Part 1910.134(d). In addition, breathing air must meet or exceed the requirements of Grade D breathing air as specified in the Compressed Gas Association pamphlet G-7.1 and ANSI Z86.1-1973.

Deciding the Appropriate Use of SCBA for the 40 hour HAZWOPER course

Key questions should be asked when considering whether an SCBA is appropriate for HAZWOPER work:
– Is the 40 hour HAZWOPER atmosphere IDLH or is it likely to become IDLH? If yes, a positive-pressure SCBA should be used. A positive-pressure SAR with an escape SCBA may also be used.
– Is the duration of air supply sufficient for accomplishing the necessary tasks? If no, a larger cylinder should be used, a different respirator should be chosen, and/or the work plan should be modified.
– Will the bulk and weight of the SCBA interfere with task performance or cause unnecessary stress? If yes, use of a SAR may be more appropriate if conditions permit.
– Will temperature effects compromise respirator effectiveness or cause added stress in the worker? If yes, the workperiod should be shortened or the mission postponed until the temperature changes.

What Are Supplied-Air Respirators (SARs)?

40 hour HAZWOPER Supplied-air respirators, also known as air line respirators, supply AIR never oxygen to a facepiece via a supply line from a stationary source. SARs are available in positive-pressure and negative-pressure modes. Pressure-demand SARs with escape provisions provide the highest level of protection (among SARs) at 40 hour hazwoper sites and are the only SARs recommended for use at hazardous waste sites. SARs are NOT recommended for entry into IDLH atmospheres (MSHA/NIOSH 30 CFR Part 11) unless the apparatus is equipped with an escape SCBA. These are a must to use during 40 hour HAZWOPER work.
The air source for supplied-air respirators used for 40 hour HAZWOPER work may be compressed air cylinders or a compressor that purifies and delivers ambient air to the facepiece. SARs suitable for use with compressed air are classified as “Type C” supplied-air respirators as defined in MSHA/NIOSH 30 CFR Part II. All SAR coupling must be incompatible with the outlets of other gas systems used on-site to prevent a worker from connecting to an inappropriate compressed gas source (OSHA 29 CFR 1910.134(d)).

SARs enable longer work periods than do SCBAs and are less bulky. However, the air line impairs worker mobility and requires workers to retrace their steps when leaving the area. Also, the air line is vulnerable to puncture from rough or sharp surfaces, chemical permeation, damage from contact with heavy equipment, and obstruction from falling drums, etc. To the extent possible, all such hazards should be removed prior to use. When in use, air lines should be kept as short as possible (300 feet or 90 meters is the longest approved hose length for SARs). Other workers and vehicles should be kept away from the air line.
The use of air compressors as the air source for an SAR at a 40 hour hazwoper hazardous waste site is severely limited by the same concern that requires workers to wear respirators; the questionable quality of the ambient air. On-site compressor use is limited by OSHA standards (29 CFR Part 1910.134(d)).

Deciding the Appropriate Use of 40 hour HAZWOPER SAR Key questions to ask when considering SAR use are:
– Is the atmosphere IDLH or likely to become IDLH? If yes, SAR/SCBA combination or SCBA is necessary.
– Will the hose significantly impair worker mobility? If yes, the work task should be modified or other respiratory protection should be used.
– Is there a danger of the air line being damaged or obstructed (e.g., by heavy equipment, falling drums, rough terrain, or sharp objects) or permeated and/or degraded by chemicals (e.g., by pools of chemicals)? If yes, either the hazard should be removed or another form of respiratory protection should be used.
– If a compressor is the air source for 40 hour HAZWOPER work, is it possible for airborne contaminants to enter the air system? If yes, have the contaminants been identified, and are efficient filters and/or sorbents available that are capable of removing those contaminants? If no, either cylinders should be used as the air source or another form of respiratory protection should be used.
– Can other workers and vehicles that might interfere with the air line be kept away from the area? If no, another form of respiratory protection should be used. HAZWOPER refresher training must also be given to maintain the certification.

Personal Protective Equipment (PPE) Use

Most 40 hour HAZWOPER PPE and the organizational operating procedures for employee use are not designed for multiple hazards and prolonged periods of use. The selection and use of PPE may need to be adjusted to provide adequate protection during disaster operations when site hazards are varied and work shifts are extended. For example, a cartridge change schedule designed for routine use during a standard 8-hour shift will need to be reevaluated for use during a 12-hour shift (assuming the same level of exposure). If exposures are anticipated to be higher during the extended period and/or additional chemicals will be present, respirator cartridges may need to be changed more frequently, a different set of cartridges may be necessary, or a more protective respirator may be required. Similar adjustments may be necessary for other types of PPE, particularly chemical protective clothing. Additionally, 40 hour HAZWOPER PPE use and, in particular, the use of respiratory protection, poses a physiological burden under normal working conditions during traditional working hours. This burden will likely be increased if the PPE or respiratory protection is used for extended work shifts/rotations.

What Are HAZWOPER Site Conditions and Other Potential Hazards?

40 hour HAZWOPER disasters create uniquely challenging physical and environmental conditions for workers, including: non-existent, damaged, or limited critical infrastructure (roads/traffic signals, utilities, transportation/distribution of basic necessities, etc.); downed power and communication lines; vegetative, construction, and hazardous debris; flooding; hazardous material releases; limited temporary housing (for victims and workers); and damaged or collapsed commercial structures and homes. In addition to these conditions, the volume of resources needed to restore the area after a large-scale disaster will likely exceed those available in the affected communities. Resources, including workers, will need to be brought in from outside the local area, creating a host of logistical issues (e.g., locating, staging, and housing goods and workers; credentialing for out-of-state professionals; and training critical skilled workers unfamiliar with disaster work). These HAZMAT site conditions and circumstances affect workers’ physiological capabilities, influencing their performance and impacting their safety and health decision-making.

Relevance of HAZWOPER Training Levels to First Responders and 40 Hour HAZWOPER

40 hour HAZWOPER training for workers at contaminated waste sites is quite a bit different than for First Responders. An OSHA letter of interpretation discusses the roles of 24 Hour HAZWOPER responders and other emergency responders at the scene of a hazardous substance release. “Standard emergency medical practice dictates that HAZWOPER personnel are to survey the accident scene and remain away from the hazard area until it is safe to approach. In the case of a HAZWOPER roadway emergency, the incident needs to be brought under control by more highly skilled HAZWOPER emergency responders before it would be permissible for personnel, including those certified at the first responder operations level, to enter to perform rescue or provide medical treatment.” (OSHA, 1995-Nechis).

First responder training beyond the operations level is not necessary for worker activities that are restricted to medical treatment and decontamination. However, many HAZWOPER first responders have qualifications at higher levels of HAZWOPER training. These are personnel who elect to be cross-trained to serve an expanded role (e.g., firefighter, HAZMAT team member), and might receive other levels of hazwoper training as needed in support of those additional roles.

For example, firefighters commonly obtain additional education to qualify as emergency responders (in addition to continuing to qualify as firefighters) and some HAZWOPER personnel are trained at the 24 hour HAZWOPER Hazardous Materials Technician or Hazardous Materials Specialist level to serve on special HAZMAT teams. Any HAZWOPER training that a responder receives beyond the first responder operations level would be to support the role of firefighter or HAZMAT team member. The responder might, in the capacity of firefighter, enter dangerous areas to perform non-medical activities such as controlling a hazardous substance release or performing rescue, for which the higher level of HAZWOPER training is required.

Heat Stress | HAZWOPER Zones Factors Leading to Heat Stress

Working in a HAZWOPER Zone can have many hazards. One of the ones most frequently over looked is heat stress. What kind of heat disorders and health effects are possible and how should they be treated?
Heat Stroke is the most serious heat related disorder and occurs when the body’s temperature regulation fails and body temperature rises to critical levels. It is a medical emergency that may result in death. The primary signs and symptoms of heat stroke are confusion; irrational behavior; loss of consciousness; convulsions; a lack of sweating (usually); hot, dry skin; and an abnormally high body temperature. If a worker shows signs of possible heat stroke, professional medical treatment should be obtained immediately. Until professional medical treatment is available, the worker should be placed in a shady, cool area and the outer clothing should be removed. Douse the worker with cool water and circulate air to improve evaporative cooling. Provide the worker fluids (preferably water) as soon as possible.

Heat Exhaustion is only partly due to exhaustion; it is a result of the combination of excessive heat and dehydration. Signs and symptoms are headache, nausea, dizziness, weakness, thirst, and giddiness. Fainting or heat collapse is often associated with heat exhaustion. Workers suffering from heat exhaustion should be removed from the hot environment and given fluid replacement. They should also be encouraged to get adequate rest, and when possible, ice packs should be applied.

Heat Cramps are usually caused by performing hard physical labor in a hot environment. Heat cramps have been attributed to an electrolyte imbalance caused by sweating and are normally caused by the lack of water replenishment. It is imperative that workers in hot environments drink water every 15 to 20 minutes and also drink carbohydrate-electrolyte replacement liquids (e.g., sports drinks) to help minimize physiological disturbances during recovery.

Heat Rashes are the most common problem in hot work environments where the skin is persistently wetted by unevaporated sweat. Heat rash looks like a red cluster of pimples or small blisters. It is more likely to occur on the neck and upper chest, in the groin, under the breasts, and in elbow creases. The best treatment for heat rash is to provide a cooler, less humid environment. Keep the affected area dry. Dusting powder may be used to increase comfort, but avoid using ointments or creams—they keep the skin warm and moist and may make the condition worse.

Administrative or work practice controls to offset heat effects
• Acclimatize workers by exposing them to work in a hot environment for progressively longer periods.
• Replace fluids by providing cool water or any cool liquid (except alcoholic and caffeinated beverages) to workers and encourage them to drink small amounts frequently, e.g., one cup every 20 minutes. Ample supplies of liquids should be placed close to the work area.

Elements of a HAZWOPER Injury and Illness Prevention Program

An effective injury and prevention program can be summarized into the following 13 required elements.
1 Accident prevention policy/mission statement
2 Written performance/accountability standards and objectives for managers and supervisors to:
a.Reduce injuries and illnesses
b. Enhance workplace health and safety
3. Compliance activities and programs.
4. Designated agency safety coordinator
5. Health and safety committees
6. Written safety rules and practices
7. Health and safety training and education
8. Health and safety inspections/surveys
9. Loss prevention and control techniques
10. Health and safety promotion and awareness programs
11. Accident investigation and reporting procedures
12. Worker’s Compensation claims management
13. Early return to work programs

1. Accident Prevention Policy/Mission Statement
Your employer’s commitment to employee health and safety shows in the decisions you make and the specific actions you take to develop and promote your program. Both reflect the priority your agency places on these issues.
Employees (and supervisors) in return will respond to that level of commitment.
Every successful organization realizes that maximum efficiency and quality can only be achieved by eliminating or controlling potential hazardous work practices before they result in a workplace injury or illness. Agencies can begin developing an effective injury and illness prevention program by integrating this philosophy into their entire operation and organizational values.
One way to visibly demonstrate this philosophy and the commitment of top-management is to develop an accident prevention policy or mission statement. Your policy/mission statement should clearly communicate to your employees the value in which health and safety protection is held in your agency in relation to other organizational values and objectives. Your policy/ mission statement should also make the order of priorities clear so that all employees will know what choice to make if a conflict occurs between employee health and safety and another organizational value.
In order for your health and safety policy to be effective, you must clearly communicate your policy to all your employees by both explanation and example. For example, you may want to explain your policy in group meetings and/or express your commitment in a letter sent to each employee.
You should also consider posting your mission statement throughout each of your locations. Your policy is also communicated by example when managers and supervisors follow all agency safety rules and practice the same safe behavior and habits that are expected of employees.

2. Written Performance and Accountability Standards and Objectives for Managers and Supervisors to:
a. Reduce injuries and illnesses
b. Enhance workplace health and safety
Your commitment to protecting your employees from workplace hazards and injuries is reflected in all aspects of your safety and health program, but nowhere more than in the organization and management of the program. In order to leave no doubt about your agency’s conviction that safety and health is just as important as productivity and quality, you should equate safety and health activities with your other agency functions. For example, the following actions would demonstrate to your employees and management team that your agency is serious about safety and health protection.

3. Compliance Activities and Programs:
Safety and Health Recordkeeping
No organization can be successful without adequate recordkeeping. This enables you to learn from past experience and make corrections for future operations. Records of accidents, work- related injuries, illnesses and property losses also serve a similar purpose.
These records will help you to identify the causes of accidents and injuries and the control procedures that should be instituted to prevent losses from recurring. These records will also provide you with one measure for evaluating the success of safety and health activities. Success normally means a reduction or elimination of employee injuries and illnesses during a calendar or fiscal year. Success can also be measured in terms of reduced overtime costs, and absenteeism.

4. Designated Agency Safety Coordinator
OSHA regulations requires that each employer assign someone the responsibility and authority to manage/coordinate its employee health and safety program. The person assigned as your organization’s safety coordinator must be identified by name or position in your written program. In smaller agencies, the safety coordinator function can be added to an existing position. In larger agencies, a full-time position may be required.
The success of your organization’s health and safety program hinges on the individual you choose. This person cannot succeed however, without your agency’s or institution’s full cooperation and support. Remember, even when you appoint someone as your safety coordinator and delegate to that person the authority to manage your program, the ultimate responsibility for health and safety in your workplace still rests with your management team.

5. Health and Safety Committees
A well-organized and functioning health and safety committee can provide a valuable avenue for developing and maintaining positive interest in employee health and safety. To guarantee flexibility and efficiency, the composition of health and safety committees should be tailored to the specific needs and structure of each organization.

6. Written Work Rules and Safe Work Practices
Written rules and safe work procedures are an essential part of an effective program. Written rules describe acceptable and safe behavior and identifies actions that are not appropriate and could endanger the safety of employees and visitor.

7. Health and Safety Training and Education
Training (i.e., HAZWOPER) is one of the most important elements of any injury and illness prevention program. An effective training program allows employees to learn their jobs properly, brings new ideas into the workplace, reinforces existing ideas and practices, and puts your health and safety program into action.

8. Health and Safety Inspections/Surveys
Periodic inspections/surveys and procedures for hazard detection and control provide an effective method of identifying existing or potential hazards in the workplace, and for eliminating or controlling hazards before they contribute to an injury or illness. Hazard control is the heart of a successful injury and illness prevention program. Your hazard control system is also the basis for developing safe work procedures and injury/illness prevention training.

9. Loss Prevention and Control Techniques
An effective Health and Safety Program relies on the use of various loss prevention and control techniques to prevent or control hazards that contribute to work-related injuries and illnesses.
Hazards in the workplace take many forms, including air contaminants, tasks involving repetitive motions, chemical spills, equipment with moving parts, extreme heat or cold, noise, fire and toxic materials such as silica and asbestos. There are seven basic methods or techniques to prevent or control these hazards before they result in an injury or illness.

10. Health and Safety Promotion and Awareness Programs
Your HAZWOPER program must include a system for promoting health and safety awareness.

11. Accident Investigation and Reporting Procedures
A primary tool you should be using in an effort to identify and recognize the hazards or areas responsible for accidents is a thorough and properly completed accident investigation. The accident investigation should be in writing and adequately identify the cause(s) of the injury/illness or near-miss occurrence.
Accident investigations should be conducted by trained individuals, and with the primary focus of understanding why the accident or near miss occurred and what actions can be taken to avoid recurrence.

12. Worker’s Compensation Claims Management
Effective claims management can not only significantly reduce worker’s compensation costs, but can also help promote positive employee participation in your injury prevention program. The key to effective claims management is to establish and maintain close communication with the injured employee and his/her medical providers. How the employee perceives the organization’s response to his/her injury or illness will set the tone of the entire claim management process.

13. Early Return to Work Programs
Returning an injured employee to work in a HAZWOPER zone as soon as medically feasible is an essential part of any claims management program.
National research has shown that the majority of injured workers will return to their previous jobs at full capacity if employers establish a return to work program.
The following facts will easily persuade you that return to work programs make good sense for everyone:
• Returning employees back to work will reduce costs by not having to hire replacement personnel for essential work.
• Future worker’s compensation costs may be reduced, depending on how effective claims and injuries are managed.
• Even if employees initially can only return to work part time, temporary partial disability payments will be less costly than temporary total disability payments while the employee is off work completely.
• Employees off work for six months will have only a 50% chance of returning to work at all.

Employer’s Legal Responsibilities

OSHA 29 CFR 1910.120(q) and EPA 40 CFR 311 (EPA 311) require that HAZWOPER 40 emergency response employees be completely trained before they perform in emergencies. At a minimum, such training should include the elements of the emergency response plan, standard operating procedure (SOP’s) established by the employer, and procedures for notification and handling of emergency incidents.
The employer must certify annually that each employee has successfully completed the required training. The method used to demonstrate competency for certification of training must be recorded and maintained by the employer.

Important concepts to remember are:
• The chief or director is responsible for determining the appropriate level of training required based on actions required of members as stated in the SOP’s.
• The chief or director is responsible for implementing the required training or certifying that members of the organization have the competencies required. Documentation of training is critical.
• OSHA 1910.120(q) rules apply to all individuals and agencies that are expected to respond to an emergency involving hazardous materials, that is, career or volunteer, fire, emergency medical services (EMS), or law enforcement personnel.
OSHA 1910.120(q) and EPA 311 apply to employers whose employees are engaged in emergency response to hazardous materials incidents. Employer responsibilities under these regulations fall into four primary areas:
• Development of an emergency response plan
• Development of specific procedures for handling hazardous materials incidents
• Training requirements
• Health and safety requirements (medical monitoring for the use of chemical protective clothing and exposure records)
• Employers’ Training Requirements Employers must ensure that employees receive training in emergency response to hazardous materials incidents, based on their expected duties and functions. Such training must be performed before employees are permitted to perform in emergencies.
• An employer is responsible for determining the appropriate level of training required, based on actions expected of employees as stated in the agency’s SOP’s. • An employer is responsible for implementing the required training. Emphasis should be on achieving the required competencies for the appropriate level of response rather than on minimal requirements for length of training.
• An employer is responsible for selecting qualified, competent instructors.
• An employer must provide annual refresher training sufficient to maintain competencies, or employees must demonstrate required competencies annually.
• An employer must maintain a record of demonstrated competencies including an explanation of how each competency was demonstrated. Training records must contain dates of training, student rosters, curriculum outlines, demonstration checklists or performance records and evaluation tools, and scores, if appropriate.

The Challenge of Competency

As part of a comprehensive program to protect the public and the environment from chemical incidents resulting from such occurrences as transportation accidents, spills, discharges from industrial operations, and terrorist or other criminal activity, training must be conducted for personnel who address planning, safety, response, and technical programs. Many personnel needing training related to hazardous materials and terrorist incident response are volunteers or part-time employees. Maintaining minimum competency levels for full-time paid staff may be difficult, but training part-time or volunteer responders is an even bigger challenge. Two of the most significant challenges are determining what constitutes a minimal level and ensuring minimal requirements are met. Another challenge is presented by part-time and volunteer responders’ time constraints and limited flexibility to attend training.

No single generic course can fit the needs of all elements of the diverse national response audience. Although there are basic competencies, trainers must adjust material to suit police, fire, emergency medical service (EMS), public works, transportation, sanitation employees, and so forth. Training options must be offered accordingly, given these variations of need.
OSHA has defined the minimum number of hours for training at operations, technician, specialist, and incident commander levels. However, each employer is responsible for employees being trained to competency, and agencies often exceed the minimum hours of training to teach and test for competencies at the levels outlined by OSHA. The training needed to reach competency depends on the preexisting skills and experience of the trainees.

Agencies frequently discover that training needs exceed the minimum required hours. On the other hand, employees of a response agency who have sufficient skills and experience may require minimal time to attain the competency level desired. An effective response is based on the competency of the responders, not the number of their training hours. At a minimum, employers should evaluate the amount of learning that resulted from the instruction.

OSHA is concerned that the knowledge and skills gained during initial hazardous materials training will be lost if refresher training is not provided. OSHA realizes that it will not take as many hours to cover the information in a review as during the initial presentation; therefore, there is no hour requirement for re- fresher training. It is up to the employer to determine that employees maintain their original competencies through refresher training. If it is determined that employees maintain their competency without refresher training, OSHA allows them to demonstrate this annually. If the employer decides to use demonstrated competencies instead of providing training, the employer must document how each employee demon- strated competency.

HAZWOPER Roles & Responsibilities

This page provides guidance to assist in the preparation of the Key Personnel portion of the HAZWOPER site-specific Health and Safety Plan (HASP). In this section, the HASP should:
Identify an individual who has the authority to direct all activities
Identify the other personnel needed for the project and assign their general functions and responsibilities
Show lines of authority, responsibility, and means of contact
Identify the interface with the response community

Organizational Structure

The HASP should specifically identify the names and organizational relationships among key personnel, such as the Project Manager, Field Team Leader, and Site Safety and Health Officer (SSHO). Designated alternates for the key personnel, responsibilities, and lines of authority, methods of communication, and an organizational structure should be identified. If specific key job responsibilities listed in this chapter are not needed, or more than one function is to be performed by a person, those responsibilities should be addressed in the HASP.

During the first stages of planning, an organizational structure that supports the overall objectives of the project should be developed. An explanation of the structure including the chain of command and overall responsibilities of supervisors and employees in carrying out the health and safety program should be included in the HAZWOPER HASP. An organizational chart should be developed depicting the structure and identifying all key personnel and other onsite and offsite personnel. The chart should be placed in a central location, and included in the HASP. At a minimum, the organizational chart should include the Project Manager, the SSHO, the Field Team Leader, the Command Post Supervisor, the Decontamination Station Officer(s), site security, and the specialty team.

As the project progresses, it may be necessary to modify some organizational aspects, such as personnel responsibilities and authorities, so that individual tasks can be performed as efficiently and safely as possible. Any changes to the overall organizational structure should be recorded in the appropriate sections of the HASP that are developed for individual phases or tasks. These specific changes should be communicated to all parties involved.

Onsite Essential Personnel

Project Manager
The name and position of the individual who has the authority to direct all activities should be identified (i.e., Project Manager, Project Team Leader, or Site Supervisor). A designated alternate for this position should be identified by name. A general description including areas of responsibility (i.e., assumes total control over site activities, authority to direct response operations) should be provided for the Project Manager who should be considered an “onsite essential” person. The specific responsibilities of the Project Manager should be stated. These responsibilities should include, but are not limited to:
Management of the project
Preparation of the work plan, preparation of the HASP, and designation of the field team
Designation of an individual within each project to act as the confined space coordinator (if required)
Identification of work-site confined spaces
Designation of an individual to act as the medical program administrator
Access permission for visitors, new hires, etc., and coordinates activities with appropriate officials
Confirmation of each team member’s suitability for work based on employees training and physician’s recommendation
Briefing field teams on their specific assignments
Coordination with the SSHO on safety and health requirements
Preparation of the final report and support files on the response activities
Liaison with public officials
Maintenance of a daily site log
Site Safety and Health Officer
The Site Safety and Health Officer (SSHO) should be identified by name for each organization. A designated alternate for each SSHO should be identified by name. A general description of duties, including lines of authority (i.e., stop work authority) should be provided. The SSHO should be an “onsite essential” person. The specific responsibilities of the SSHO should include, but are not limited to:
Managing the safety and health program for the site
Periodically inspecting protective clothing and equipment
Monitoring and evaluating HASP implementation
Monitoring protective clothing and equipment to ensure that they are properly stored and maintained
Monitoring entry and exit to the exclusion zone
Verifying each team member’s suitability for work based on employee’s training and physician’s recommendation
Monitoring the work parties for signs of stress, such as cold exposure, heat stress, and fatigue
Advising medical personnel of potential exposures and consequences
Participating in the preparation and implementation of the HASP
Conducting periodic inspections to verify if the HASP is being properly implemented
Verifying that the “buddy” system is being implemented
Knowing emergency procedures, evacuation routes, and the telephone numbers of the ambulance, local hospital, poison control center, fire department, and police department
Notifying local public emergency officials when necessary
Coordinating emergency medical care
Safety and Health Personnel
Names and responsibilities of other personnel that have safety and health duties should be listed. These should include, but are not limited to:
Construction safety experts
Safety specialists/technicians
Health physicists
Industrial Hygienists

Field Team Leader
The individual who is responsible for field team operations and safety should be identified by name. In some cases, the Field Team Leader may also be the same person as the Project Manager and may be a member of the specialty team. A designated alternate for them should be identified by name. A general description, including areas of responsibility (i.e., responsible for field team operations and safety) should be provided for the Field Team Leader, who should be considered an “onsite essential” person. The specific responsibilities of the Field Team Leader should be stated. These responsibilities include, but are not limited to:
Managing field operations
Executing the work plan and schedule
Enforcing safety procedures
Coordinating with the SSHO in determining protection levels
Enforcing site control
Documenting field activities, including sample collection
Serving as liaison with public officials where there is no Public Affairs official designated

Command Post Supervisor
The individual who is responsible for communications and emergency assistance should be identified by name. In some cases, the Command Post Supervisor may be the same person as the Field Team Leader. A designated alternate should be identified by name. A general description, including areas of responsibility (i.e., responsible for communications and emergency assistance) should be provided for the Command Post Supervisor, who should be considered an “onsite essential” person. The specific responsibilities of the Command Post Supervisor should be stated. These responsibilities should include, but are not limited to:
Notifying emergency response personnel by telephone or radio in the event of an emergency
Assisting the SSHO in rescue operations, if necessary
Maintaining a log of communication and site activities
Assisting other field team members in the clean areas, as needed
Maintaining line-of-sight and communication contact with the work parties via walkie-talkies, signal horns, or other means

Emergency Response Coordinator
The individual who has the authority to direct, control, and evaluate site emergency response/emergency activities should be identified. A designated alternate should be identified by name. The Emergency Response Coordinator should be considered an “on-site essential” person. A general description including areas of authority and responsibilities should be provided.

These responsibilities should include, but are not limited to:
Developing, implementing, and updating the emergency response/emergency action plan
Conducting rehearsals, employee training, evaluations of responses/actions
Assuring the evacuation, emergency treatment, emergency transport of site personnel and notifying emergency response units and the appropriate management staff

Decontamination Station Officer
The individual who is responsible for decontamination procedures, equipment, and supplies should be identified by name. In some cases, the Decontamination Station Officer may be the same person as the Field Team Leader. A designated alternate should be identified by name. A general description, including areas of responsibility (i.e., responsible for decontamination procedures, equipment, and supplies) should be provided for the Decontamination Station Officer, who should be considered an “onsite essential” person. The specific responsibilities of the Decontamination Station Officer should be stated.

These responsibilities should include, but are not limited to, the following:
Setting up decontamination lines and the decontamination solutions appropriate for the type of chemical contamination on site
Controlling the decontamination of all equipment, personnel, and samples from the contaminated areas
Assisting in the disposal of contaminated clothing and materials
Ensuring all required equipment is available and in working order
Providing for collection, storage and disposal of waste

Security Officer
The individual who is responsible for managing site security should be identified by name. A general description, including areas of responsibility (i.e., maintains site security) should be provided for the Security Officer, who should be considered an “onsite essential” person. Specific responsibilities of the Security Officer should be stated.

These responsibilities should include, but are not limited to:
Conducting routine area patrols
Controlling facility access and egress
Assisting with communication during an emergency
Securing accident/incident scenes
Maintaining a log of site access and egress

Specialty Teams
Specialty Teams, consisting of field team members (e.g., to include rescue teams for retrieving personnel from dangerous situations, and sampling teams for obtaining samples of potentially hazardous materials) who complete the onsite tasks required to fulfill the work plan, should be identified. A general description, including areas of responsibility and stop work authority (i.e., any or all of the field team may be in the Specialty Team and should consist of at least two people) should be provided. Specialty Team personnel should be considered “onsite essential” personnel. Specific responsibilities of the Specialty Teams should be stated.

These responsibilities should include, but are not limited to:
Safely completing the onsite tasks required to fulfill the work plan
Complying with HASP
Notifying the SSHO or supervisor of unsafe or potentially unsafe conditions

Overview of Pertinent Environmental Regulations

In 1970 the U.S. Environmental Protection Agency (EPA) was established to provide a regulatory framework for environmental statutes passed by Congress. The myriad of regulations cover areas such as the Clean Air Act, Resource Conservation and Recovery Act, Clean Water Act, Comprehensive Environmental Response Compensation and Liability Act (CERCLA), etc. From the environmental regulations, our focus will be on CERCLA as this is the predominant regulation governing the restoration of abandoned hazardous waste sites. However, our primary focus will center on the OSHA regulation as this mandated the protection of workers. The OSHA regulations are written by the U.S. Department of Labor and carry the weight of laws.

Congress passed the OSHA in 1970 to create a governmental agency that would regulate and govern worker protection. All workers have the right to as healthy and safe of a workplace as possible. Chemical exposure may cause or contribute to serious health effects such as rashes, burns, lung and kidney damage, heart ailments, cancer, etc. Worker awareness and proper response to hazardous materials is a must to minimize unnecessary exposures. The primary components of the OSHA regulation applicable to the proper management of hazardous materials are Title 29, Code of Federal Regulations (CFR) Parts 1910.20 (Access to Medical Records), 1910.120 (HAZWOPER Standard), 1910.146 (Confined Space Entry Standard), and 1910.1200 (Hazard Communication Standard). These applicable components of the OSHA regulations will be covered in depth.

Access to Medical Records

All workers have the right to request any information on hazardous materials at their respective work site. This includes medical analyses, monitoring data, chemical inventories, and health and safety studies of the work place, Safety Data Sheets (SDS), and any other relevant information. Employers must provide this information to any employee making a request for this information – at no cost to the employee.

This section in the OSHA regulations is the centerpiece of worker protection standards. The major requirements are training for personnel engaged in the handling or use of hazardous substances, a written site-specific health and safety plan, use of personal protective equipment (PPE) when needed, and development of an emergency response plan. Depending on the job classification, a 40-hour (worker) or at least 24 -hour (supervisor) initial HAZWOPER training must be taken prior to working with hazardous substances. Also, an annual 8-hour HAZWOPER refresher training is required to maintain the initial training certification. The training must train workers and supervisors on a) personnel responsible for safety, b) health and other hazards at the worksite, c) use of PPE, d) minimization of risks to work hazards, e) safe use of engineering controls and equipment at the site, f) medical surveillance requirements, and g) the contents of the site specific health and safety plan. These are the requirements as listed in the OSHA regulations.

Hazard Communication Standard

Congress passed the hazard communication standard largely because of accidents involving hazardous substances. Specifically, the 1983 Bhopal, India tank accident, which released large amounts of methyl isocyanate to the environment, killing thousands of people and injuring thousands more (the exact number of fatalities and injuries are unknown). This accident occurred at the plant pictured below. This prompted Congress to inform workers and communities of hazards in their immediate vicinity. The so-called “right to know laws” mandated that industry provides key information on hazardous substances.

Under the Hazard Communication standard, employers must provide employees with three items. The first is training on the hazardous substances which the employer uses, produces, stores, etc. Next, SDS, providing detailed information on the respective hazardous substances in use. Finally, labels or placards must clearly identify contents of hazardous substances. The types of labels or placards frequently encountered are hazardous waste labels, Department of Transportation placards, and National Fire Protection Agency triangle labels.

Why Healthcare Workers Take HAZWOPER Training

The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) covers employees in various industries who have been exposed to hazardous substances or those who have potentially been exposed to them. One industry in particular where HAZWOPER training is important is healthcare. A variety of employee categories in this field deal with hazardous waste every day, including doctors, nurses and certified nursing assistants.

Daily Risks

Healthcare workers encounter a variety of chemicals and waste on a daily basis. They may work with blood, feces, urine, gases and medicines that can cause medical and contamination emergencies. HAZWOPER training helps employees identify hazardous chemicals, monitor medical emergencies, document emergency clean-up procedures and create health and safety procedures.

Proactive Education

Nurses, phlebotomists, doctors, certified nursing assistants and other health care employees need HAZWOPER training to keep them up-to-date and knowledgeable about how to handle chemical and waste spills or other contamination scenarios. This education also helps them prevent such situations. This knowledge can help prevent panic in emergency medical situations in which contamination of a disease or chemical can quickly spread.

Understanding Procedures

HAZWOPER training gives medical personnel the tools they need to lead and carry out decontamination procedures in an efficient and professional way. Without the ability to understand the causes of a potential contamination emergency and how to defuse and contain it, healthcare workers cannot properly do their jobs. Patients and the public depend on healthcare workers to have the knowledge and strength to help them through difficult medical emergencies.

Learning Proper Techniques

HAZWOPER training also provides healthcare employees with what they need to protect themselves from contamination. When they are in the thick of cleaning up a hazardous mess, they must be able to keep themselves out of harm’s way. Knowing the proper techniques and procedures for protecting themselves is essential to keeping a contamination clean-up going and to complete it as completely as possible.

Training Requirements

Healthcare employees should complete the eight-hour course each year and keep themselves current on new information in the field of waste and chemical clean-up. To maintain a health environment for themselves and their co-workers, employees must complete the required federal training in HAZWOPER. Without it, they, their workplaces, colleagues, patients and the general public can be seriously endangered. With the right knowledge about waste and chemical contamination, however, they can protect everyone potentially affected by such an emergency. HAZWOPER training is essential to keeping healthcare workers and the public safe. It helps prevent medical emergencies and solve contamination problems should they occur. All healthcare workers should view this training as an important part of their professional development.





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