Ten Step Compliance Game Plan

Ventilation/Airborne Contaminant Control of Hazwoper Sites

Date First Published on SafetySmart Compliance: January 7th, 2013
Topics: Environmental Compliance | Hazwoper & Emergency Response |

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.

Step 2: Conduct Post-Entry Evaluation

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.

Step 3: Make Information Available to Workers

Information that you must make available before letting workers enter a site includes:

  • The site’s location and approximate size;
  • Description of the response activity and/or job task to be performed;
  • How long the planned employee activity will last;
  • The site’s topography and accessibility by air and road;
  •  Safety and health hazards expected at the site;
  • Pathways for hazardous substance dispersion;
  •  Present status and capabilities of emergency response teams that would help workers in an emergency;
  •  Hazardous substances and health hazards at the site and their physical and chemical properties.

Step 4: Conduct IDLH Air Monitoring

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:

  • Conduct monitoring for ionizing radiation with direct reading instruments;
  • Monitoring for IDLH and other conditions that may cause death or serious harm, e.g., oxygen deficiency, combustible atmosphere or toxic substances, with direct reading test equipment;
  • Conduct visual observation for signs of actual or potential IDLH or other dangerous conditions;
  • Implement an ongoing air monitoring program.

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.

Step 6: Maintain Safe Level of Exposure to Subpart Z Substances

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.”

  • Feasible engineering controls may include pressurized cabs or control booths on equipment, and/or use of remotely operated material handling equipment;
  • Feasible work practices may include removing all non-essential workers from potential exposure during opening of drums, wetting down dusty operations and/or locating employees upwind of hazards.
  • PPE may include positive pressure self-contained breathing apparatus, positive pressure air-line respirators equipped with escape air and totally-encapsulating chemical protective suits.

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.

Step 7: Comply With Subpart G Ventilation Requirements

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).

Step 8: Maintain Safe Level of Exposure to Other Contaminants Not Covered by Subparts G or Z

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.

Step 9: Conduct Initial Entry Air Monitoring

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.

Step 10: Conduct Periodic Air Monitoring

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:

  • Where work begins on a different portion of the site;
  • When contaminants other than those previously identified are handled;
  • When different types of operations begin, e.g., drum opening rather than exploratory well drilling;
  • When workers handle leaking drums or containers or work in areas with obvious liquid contamination, e.g., a spill or lagoon.

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