Step 1: Developing a Health & Safety Program for Hazardous Waste Operations

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Hazwoper & Emergency Response |

The first requirement of Hazwoper is to “develop and implement” a written health and safety program for employees involved in hazardous wasteoperations to identify, evaluate and control the hazards. (Sec. 1910.120(b)) Here’s how.

3 Elements a Safety Program Must Contain

The written health and safety program must include 3 things:

1. An Organizational Structure

The first requirement is an organizational structure setting out the chain of command and overall responsibilities of supervisors and employees and:

  • Designating a general supervisor with responsibility and authority to direct all hazardous waste operations;
  • Designating a site safety and health supervisor with responsibility and authority to develop and implement the site safety and health plan;
  • Listing the general functions and responsibilities of all other personnel needed for hazardous waste site operations and response;
  • Providing clear lines of authority, responsibility and communication; and
  • Specifying that the organizational structure will be reviewed and updated as necessary to reflect current operations.

2. A Comprehensive Workplan


The second requirement for a safety program is a comprehensive workplan setting out the tasks and objectives of site operations and the methods and resources necessary to carry out those tasks and meet those objectives. The workplan must also:

  • Address anticipated clean-up activities and normal operating procedures;
  • List personnel needed to carry out the plan;
  • Provide for the training personnel need to carry out their assignments (See Step 4); and
  • Provide for the implementation of the information plan requirements and medical surveillance activities (See Step 5).

3. A Site-Specific Health and Safety Plan


A site-specific health and safety must be kept on site and address, at a minimum:

  • Conducting of a hazard analysis for each task and operation at the site contained in the comprehensive workplan (See Step 2);
  • Employee trainingassignments (See Step 4);
  • PPEto be used for each task; (See Step 6);
  • Medical surveillance (See Step 5);
  • Frequency and types of air monitoring, personnel monitoring and environmental sampling, including instruments to be used and how they’ll be maintained and calibrated (See Step 7);
  • Site control measures under the site control program (See Step 2);
  • Decontamination procedures (See Step 9);
  • The emergency response plan(See Step 10);
  • Confined space entry procedures;
  • The spill containment program (See Step 10);
  • The requirement that the site safety and health supervisor, or if he/she’s not available, another knowledgeable person, conduct inspections as necessary to verify the effectiveness of the site safety and health plan and the steps necessary to correct deficiencies identified; and
  • The requirement that pre-entry briefings be held before site activities begin and whenever necessary, as indicated by data generated from the sitecharacterization and analysis process to keep employees apprised of the hazards and plan to deal with them.


Other Plan Requirements


You must also notify all contractors and subcontractors you hire to carry out hazardous waste operations about your site emergency response procedure and the potential for fire, explosion or other hazards you’ve identified in your information program.

Finally, you must make your written safety and health program available to contractors or subcontractors involved in hazardous waste operations, designated employee representatives and OSHA officials.