Step 10: Emergency Response Plan for Hazardous Waste Operations

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

The next set of requirements in Hazwoper (Sec. 1910.120(l)) deals with the development and implementation of emergency response plans prior to the beginning of hazardous waste operations. Here’s an overview.


Click here for Model Emergency Response Plan



When Is a Written Emergency Response Plan Required?

A written emergency response plan must be developed and implemented before the start of hazardous waste operations by employers at 2 kinds of sites regulated by Hazwoper:

  • Clean-up operations required by a federal, state or local government body conducted at uncontrolled hazardous waste sites, including but not limited to EPA National Priority Site List (NPL), state priority site lists, sites recommended for the EPA NPL and initial investigation of government identified sites conducted before the presence or absence of hazardous substances has been ascertained (Sec. 1910.120(a)(i)). ; and
  • Corrective actions involving clean-up operations at sites covered by the federal Resource Conservation and Recovery Act (Sec. 1910.120(a)(ii)).

Exemption: Employers are exempt from emergency response plan requirements if 2 conditions are met:

  • They evacuate employees from the danger area when an emergency occurs; and
  • They already have an emergency plan that meets the requirements of emergency action plans under the Means of Egress standard, Sec. 1910.38.

What Must Be in Emergency Response Plan

The emergency response plan must address at least:

  • Pre-emergency planning;
  • Personnel roles, lines of authority, training and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination procedures not already covered by the site safety and health plan;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up; and
  • PPE and emergency equipment.

Emergency Incident Handling Procedures

Emergency response plans must also include the following:

  • Site topography, layout and prevailing weather conditions; and
  • Procedures for reporting incidents to federal, state and local government agencies.

Other Emergency Site Response Plan Requirements

The emergency response plan must be a separate section of the Site Safety and Health Plan (See Step 1). In addition:

  • The plan must be compatible and integrated with the disaster, fire and/or emergency response plans of federal, state and local government agencies;
  • The plan must be rehearsed regularly as part of the overall training program for site operations;
  • The plan must be reviewed periodically and amended, as necessary, to remain current with new information or new or changing site conditions;
  • An employee alarm system must be installed in accordance with the OSHA Fire Protection standard, Sec. 1910.165, to notify employees of emergencies, halt work, if necessary, lower background noise so as to speed communication and initiate emergency procedures;
  • You must evaluate the incident and site response capabilities based on the information available when the emergency occurs and proceed accordingly to implement the emergency response plan; and
  • The emergency response plan must be kept available for inspection and copying by employees, their representatives, OSHA and other government officials.

OSHA Guidelines

Compliance Guidelines (Appendix C)