The OSHA Hazardous Waste Operations and Emergency Response standard (aka “Hazwoper”) (1910.120(c)) requires that hazardous waste sites, i.e., facilities or locations in which hazardous waste operations take place, be evaluated to identify specific site hazards and determine the appropriate way to control them. This includes ventilation of hazardous atmospheres. Here’s a 10-step game plan to comply with ventilation requirements under Hazwoper.
Preliminary survey of the site must be carried out by a qualified person, i.e., one with the training, knowledge and experience to do the evaluation, before site entry to identify the hazards and help decide on appropriate control measures.
Specifically, the preliminary survey must identify all suspected conditions that may pose inhalation or skin absorption hazards immediately dangerous to life or health (IDLH) as well as any other conditions that can cause death or serious harm, e.g., potentially flammable situations or vapor clouds.
Such evaluation must be done by a qualified person immediately after first entry to analyze the hazards identified in the preliminary survey, determine if additional hazards exist and decide on control measures.
Information that you must make available before letting workers enter a site includes:
If the preliminary site evaluation shows the potential for ionizing radiation or IDLH conditions, or isn’t conclusive enough to rule out the potential for these hazards to exist, you must:
You must provide the information available about the chemical, physical and toxicological properties of each substance known or expected to be present on site to workers affected before they begin the work.
It’s okay to use training and information provided under GHS/Hazcom to meet this requirement.
Employers must use engineering controls, safe work practices and PPE to keep workers’ exposure to airborne contaminants regulated by Subpart Z of the General Industry Standard, i.e., Toxic and Hazardous Substance, e.g., asbestos, chromium VI, vinyl chloride and cadmium, at or below their PEL (permissible exposure level for the particular substance), unless those controls and practices “are not feasible.”
If engineering controls aren’t required or feasible, you must use “any reasonable combination of engineering controls, work practices and PPE” to keep exposure to Subpart Z substances at or below their PELs.
Note: You can’t use a worker rotation level to comply with PEL requirements unless there’s no other feasible way to comply with the airborne or dermal dose limits for ionizing radiation.
You must follow the requirements of Subpart G of the General Industry Standard, i.e., Occupational Health and Environmental Control Standard, including requirements relating to Ventilation (1910.94) and Non-Ionizing Radiation (1910.97).
You must use an appropriate combination of engineering controls, work practices and PPE to reduce and maintain exposure to PELs of hazardous substances and health hazards not regulated by Subparts G and Z, using exposure limits and published literature to determine safe exposure levels.
Representative air monitoring must be conducted at initial entry to identify any IDLH conditions, exposures above PELs or published exposure levels, exposure to radioactive materials over dose limits or other dangerous conditions such as flammable atmospheres or oxygen deficiency.
Periodic monitoring is required where there’s a possibility of IDLH conditions or flammable atmosphere develop or there’s an indication that exposure may have rise above PELs or published exposure levels since previous monitoring took place. Situations where you must consider the possibility that exposure increases have occurred include:
Prevent Dust Explosions at Your Work Site
Go to the SafetySmart Compliance Insider Dusts & Airborne Contaminants Compliance Center for help protecting workers from combustible dust and other airborne hazards: