OSHA is not involved in regulating hazardous waste. However, they are concerned about the safety of workers who must handle, work with, or even work near areas where hazardous waste is present.
The OSHA 1910.120 standards, covering employees working with hazardous waste, are known as HAZWOPER. These standards apply to five types of operations:
The following is a broad overview of the worker protections and requirements included in OSHA 1910.120.
OSHA 1910.120 requires a written safety and health program covering employees who are involved in hazardous waste operations. Although it must address hazardous waste, it does not need to repeat anything already included in existing standard operating procedures. It must include:
Before work begins, sites potentially containing hazardous waste must be evaluated to identify the specific site hazards, the characteristics of the hazardous waste, and the safety and health control procedures needed to protect employees from those hazards.
A site control program defines how employees will be protected. It is initially written during the planning stages. As the work progresses it is modified as necessary. At a minimum the site control program must include:
All employees who may potentially be exposed to hazardous substances, health hazards, or safety hazards, must be trained before they start work. The training must:
A medical surveillance program must be in-place, and it must cover following all employees who:
Employers are required by OSHA 1910.120 to provide free medical examinations to all employees prior to the start of a work assignment involving hazardous waste. In addition, a free medical exam must be provided at least every 12 months, as well as when the employee stops working in an area where there is hazardous waste (if they've not had a medical exam in the past six months).
A medical exam must also be provided if an employee has been exposed to a hazardous substance, or should they develop the signs or symptoms of exposure to a hazardous substance.
Engineering controls, work practices, PPE, or a combination of these are used to protect employees from hazards, and must be described in the site's safety and health plan. However OSHA 1910.120 specifically excludes a common administrative control, rotation of workers, from being used, unless there is no other option for protecting workers.
Monitoring is required to verify that control measures are effective and that workers are not being exposed to hazards at a level that exceeds the permissible exposure limits (PELs). If OSHA has not established a PEL for a certain substance, then published exposure limits must be used.
Working at a site that contains hazardous materials often involves working with drums and other types of containers. In many cases some or all of these containers are buried. OSHA has specific requirements for handling and transporting drums, containers, contaminated soil, liquids, and residues.
The following is a short list of some of the requirements:
OSHA 1910.120 requires that there be decontamination procedures for all aspects decontamination, including accidental exposures. Decontamination operations must be documented in written procedures that also identify the location of decontamination equipment and supplies. In addition, the following must be provided:
There must be a written emergency response plan in place before starting any work involving hazardous waste. The plan must anticipated potential emergencies and address the following:
The employer is required to be aware of new technology, and to introduce new technology that provides better protection for employees working with or near hazardous waste.
OSHA's goal with 1910.120 is to ensure that no one is injured, or has their health affected, as a result of working with or near hazardous waste. Many of the dangers associated with hazardous waste are unseen, and protecting workers requires complete adherence to all of 19190.120's requirements. This has just been an overview of those requirements. Complete familiarity with OSHA 1910.120 is necessary before doing any work involving hazardous waste.