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Hazardous Waste Operations and Emergency Response Standard

Title 29 Code of Federal Regulations (CFR) Part 1910.120

Known as: The Standard

by Dr. Isabel Perry, “The Safety Doctor”



2063 words


This paper covers the requirements by Occupational Health and Safety Administration (OSHA) for the handling and disposal of hazardous waste.  Hazardous wastes are chemicals that are:


Ø      Toxic

Ø      Flammable

Ø      Corrosive


They can pollute our air, water or land, or cause fires or explosions.  This can occur where they are stored in the company, when disposed of, and even long afterwards. 


Hazardous waste is a serious problem that can cause health and safety problems.  This problem is not just a concern when one disposes of waste, but far into the future.  There are 25 states with OSHA-approved state health and safety plans for the disposal of hazardous waste.  State regulations must be at least as stringent as the Federal ones.  In these states, the municipal, county and state employees such as police, firefighters with local fire departments, and ambulance workers are covered.  In the other 25 states without plans, these workers are covered under EPA standards, which are based on OSHA standards.


Every organization must develop a health and safety program that provides for the use, storage, and disposal of all hazardous chemicals and waste, including emergency response to cleanup from spills.  The standard covers workers in cleanup operations at licensed sites and uncontrolled sites, including workers handling emergency hazardous waste situations.


Developing a Health and Safety Program


The standard requires the development of a comprehensive program to address all aspects of worker safety and hazard handling.  The plan must:

¨      Identify and evaluate, and control health and safety hazards

¨      Provide emergency response procedures for each:

o       Waste site

o       Treatment, storage and disposal facility


The program must have nine specific components:




A workplan should incorporate the following elements:

¨      Overall objectives

¨      Procedures for implementation, including, but not limited to:

                                                               i.      Defining the tasks and objectives of the site plan

                                                             ii.      Defining the logistics and resources required

¨      Employer’s standard operating procedures to protect the health and safety of employees

¨      A person or person in charge of the program

                                                               i.      Have a chain of command with accountability for carrying out the program

                                                             ii.      If there is more than one site, have a responsible person at each site

¨      Definition of the tasks and objectives of site operation

¨      Logistics and resources required

                                                               i.      Anticipated cleanup

                                                             ii.      Requirements for  plan implementation

                                                            iii.      Training

                                                           iv.      Medical requirements

¨      If there is more than one site, requirements for coordinating the program




¨      Includes all the basic requirements of the health and safety plan

¨      Identifies the hazards of each part of the specific plan

¨      Must be kept at the site

¨      Must conduct briefings before anyone enters the site, and periodically after

¨      Requires periodic inspections of the property

¨      Correction of any deficiencies




¨      A trained individual must conduct the first evaluation to determine safety hazards and select appropriate protection for employees.

¨      Suspected conditions should also be part of this evaluation.

¨      A number of controls can be implemented to minimize contamination of workers




¨      Employers are required to develop and conduct training for employees, contractors and subcontractors regarding:

                                                            i.      Procedures of hazardous waste operations

                                                          ii.      Degree of exposure likely

¨      Employers are also required to develop and carry out procedures to improve protection, such as the use of neutralizers, absorbents, adsorbents, and foams.

¨      Employers must develop and carry out a training program for all levels of employees who work around or are exposed to hazardous materials

¨      There are numerous levels and specifics of training requirements.

¨      Training specifications can require anywhere from 8 to 40 hours of training for any one aspect of training needed.  Most employees are going to need numerous hours of training to give them sufficient experience and competencies.

¨      Written certification is required at the completion of the training.




Employers must develop a PPE program for all employees involved in hazardous waste operations.  The PPE plan must include an explanation of the following:


¨      Equipment selection and use

¨      Maintenance and storage

¨      Decontamination and disposal

¨      Training and proper fit

¨      Procedures for putting on and taking off

¨      Inspection

¨      In-use monitoring

¨      Program evaluation

¨      Equipment limitations


Where engineering controls aren’t possible, the employer must provide the appropriate PPE for use specific to the site. Depending upon the site, that might include:

¨      Positive pressure air line respirators equipped with an escape air supply

¨      Totally encapsulating chemical protective suits




Employers must conduct air quality monitoring before workers enter an uncontrolled hazardous waste site.  They must accurately identify and quantify any airborne contaminants, which might be immediately dangerous to life and health.  Some of these might be:

¨      Oxygen deficiency

¨      Areas where toxic substance exposure are above permissible limits

This makes it possible to:

¨      Determine specific medical needs or monitoring

¨      Assess the potential health risks of exposure

¨      Determine the areas where protection and controls are needed

¨      Decide the appropriate PPE


Should there be a hazardous waste cleanup, the employer must monitor any employees who were likely to have had a higher exposure to determine whether they have had been exposed to levels in excess of permissible limits.


In a new work operation, the employer must monitor for any potential condition that might be immediately dangerous to life and health or for higher exposure levels




Employers must establish a medical surveillance program to monitor employees, assessing the health and fitness of employees to work around hazardous waste.  Workers who fall under this include:

¨      Workers exposed for more than 30 days per year where:

o       All employees are working with hazardous substances

o       No permissible exposure limit is published

o       Workers wear approved respirators

¨      Those exposed to unexpected or emergency situations (spills) of hazardous materials without wearing PPE or who show signs or symptoms, signs or illness.


All exams are to be conducted:

¨      Without cost to the employee

¨      Without loss of pay

¨      At a reasonable time and place


Exams must:

¨      Be supervised by a licensed physician

¨      Include medical and work history

¨      Include special emphasis on symptoms related to the handling of hazardous substances

¨      Include fitness to duty, including the use of PPE


Exams must be given:

¨      Prior to job assignment

¨      Every year unless the physician determines that every two years is sufficient

¨      When employment ends

¨      Before reassignment to an area where medical exams aren’t needed

¨      As soon as possible for workers injured or ill from exposure to hazardous substances


Physicians must be given:

¨      A copy of the standard and its appendices

¨      A description of the employee’s duties relating to their exposure

¨      The exposure level or expected exposure level

¨      A description of any personal protective or respiratory equipment used or to be used

¨      Information from previous examinations


The physician must provide the employer with:

A written opinion with the exam results including any medical conditions detected that would place the employee at increased risk from exposure

Any recommended work limitations

Any recommended use of PPE


The physician may NOT reveal, specific findings or diagnoses unrelated to employment




¨      All employees must be briefed before entering the worksite on the decontamination procedures, which must be an integral part of any Health and Safety plan.

¨      The health and safety officer must monitor employee decontamination or decontamination of the employee and disposal of their clothing and equipment before they leave the workplace, including the solvents used to decontaminate

¨      Protective clothing must be decontaminated, cleaned, maintained or replaced

¨      Any person cleaning the clothing must be informed that the clothing is potentially hazardous

¨      The employer must provide the employees with adequate showers and dressing rooms if they are required to shower




Employers must:

¨      Develop emergency plans and implement them before workers have to deal with hazardous waste

¨      Make sure that all workers are trained in what to do in case of an emergency situation, such as a spill. 


The plan must contain the following elements at uncontrolled hazardous waste sites, as well as at treatment, storage and disposal facilities:

¨      Evacuation routes and procedures

¨      PPE

¨      Decontamination procedures

¨      Site security and control

¨      Safe distances and places of refuge

¨      Methods or procedures for alerting onsite employees

¨      Pre-emergency planning

¨      Procedures for lines of communication, lines of authority, and personnel role

¨      Emergency recognition and prevention

¨      Emergency medical and first-aid treatment

¨      Critique of response and follow-up


Additionally, the plan must include:

¨      Site topography

¨      Layout and

¨      Prevailing weather conditions

¨      Procedures for reporting incidents to federal, state and local government agencies

¨      Procedures compatible with government agencies plans

¨      Regular rehearsals and periodic reviews of plan 

¨      A distinguishable alarm to use in alerting employees to the emergency

¨      Availability to federal government agencies

¨      Institution of control methods




Wherever possible, the employer is supposed to put in place engineering controls and work practices, including but not limited to PPE, use of pressurized cabs, and control booths on equipment.  Other procedures include removing non-essential people from exposure while opening drums, wetting down dusty operations, and placing employees on site upwind of a potentially dangerous situation.




¨      Drums and containers must be labeled and properly inspected before they can be handled.

¨      Damaged drums and containers must be:

o       Emptied of contents – using a device classified for the material.

o       Discarded properly.

¨      If there are leaks, ruptures or spills, suitable containers must be used to collect the material, using an appropriate absorbent material, and with the approved fire extinguishing equipment in case of fire.

¨      Employees must be warned about the dangers of handling containers that aren’t labeled.

¨      Procedures for opening containers must be followed.

¨      Tools that prevent ignition are the only ones that should be used.

¨      Special care should be given when employees handle shock sensitive waste explosive materials or laboratory waste packs.

o       Evacuate all non essential employees.

o       Make sure that you never lose communication.

o       Use a barrier to protect equipment operators from explosions.

¨      Bulges, swells or crystalline deposits on the outside of containers require special attention.




Temporary worksites must have:

¨      A supply of potable water and drink cups.

¨      If permanent facilities don’t exist, toilet facilities must be available in the form of:

o       Privies

o       Chemical toilets

o       Recirculating toilets

o       Combustion toilets

o       The only exception would be if it would violate local code.

¨      All water outlets must be marked as safe or not safe for drinking, washing or cooking.

¨      Guards’ sleeping quarters must be provided near the worksite that are well-lit and well-ventilated.

¨      All workers must be provided with washing facilities in a designated work area (controlled) within the worksite.

¨      Food service must be provided by a licensed organization.




¨      Exposure records must be kept for 30 years.

¨      Medical records must be kept for entire employment plus 30 years.

¨      Employees leaving before one year must be given their records; the company is not required to keep them.

¨      First aid records and one-time treatment records don’t have to be kept.

¨      Employers must notify employees of the existence, availability and location of their records.

¨      When a business closes permanently, the employer must give the employees 3 months to access their records before the business closes.

¨      The employer must also notify the National Institute for Occupational Safety and Health.


Under the standard, medical records must contain:

¨      Employees’ name and social security number.

¨      Employees’ medical complaints related to exposure to hazardous substances.

¨      Physicians’ written opinions.

¨      Information provided to the treating physician.




Title III of the Superfund Amendments and Reauthorization Act of 1986 (SARA) requires:

¨      Employers to maintain MSDS.

¨      Submit this information to:

o       State emergency response commissions

o       Local emergency planning committees

o       Local fire department

o       Surrounding communities

o       Employees


Hazardous waste is dangerous and must be handled carefully.  Employers and employees alike want to have a safe work environment.  This can be accomplished only by working together. 


Dr. Isabel Perry is an internationally-known safety expert, motivational speaker, author, and safety educator.  Based in Orlando, Florida, she can be reached at 407-291-1209 or via e-mail at [email protected]