Step 2: Performing Hazard Analysis

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

Hazwoper (Sec. 1910.120(c)) requires evaluation of hazardous waste sites, i.e., facilities or locations in which hazardous waste operations take place, to identify specific site hazards and determine the appropriate way to control them. Here’s what you need to do to comply.

Preliminary Survey

The first step in hazard analysis is performing a preliminary survey of the site. The survey 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.

The preliminary survey must identify all suspected conditions that may pose inhalation or skin aborption 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.

Post-Entry Evaluation & Information to Obtain

 

Next, a more detailed post-entry evaluation must be done by a qualified person immediately after first entry to analyze the hazards identified in the preliminary survey to determine if additional hazards exist and decide on control measures.

The employer must also obtain the following information—if it’s available—before letting employees enter the site:

  • 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 employees in an emergency; and
  • Hazardous substances and health hazardsat the site and their physical and chemical properties.

PPE Requirements

Before entry for the preliminary site evaluation, employers must ensure that PPE is provided and used.

Before subsequent entry, employers must ensure that PPE keeping exposure to known or suspected hazardous substances identified in the preliminary site evaluationis kept below Permissible Exposure Limits (PELs) and published exposure levels, i.e., levels listed in “NIOSH Recommendations for Occupational Health Standards,” (1986 ed.) or, if no limits are listed by NIOSH, exposure limits in the ACGIH “Threshold Limit Values and Biological Exposure Indices for 1987-88.” If there are no PELs or published exposure levels for the substance, you can look at other studies and guides to determine the appropriate PPE.

Click here for Model PPE Policy to include in your HASP.

If the preliminary site evaluation finds that respiratory protection is needed, before site entry:

  • A positive-pressure self-contained breathing apparatus must be used as part of the entry ensemble; or
  • Employees must carry a self-contained breathing apparatus with at least 5 minutes of respirable air.

If the preliminary site evaluation doesn’t find enough information to identify exactly what the hazards or suspected hazards of the site are:

  • Employees must be provided an entry ensemble equivalent to Level B PPE (as explained in guidelines set out in Appendix B of the standard); and
  • Direct reading instruments must be used to identify IDLH conditions.

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 the following steps must be taken:

  • Monitoring for ionizing radiation must be done 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, must be done with direct reading test equipment;
  • Visual observation for signs of actual or potential IDLH or other dangerous conditions must be conducted; and
  • An ongoing air monitoring program must be implemented.

 

Click here for Model Employee Exposure Monitoring Policy to include in your HASP.

 

Employee Notification & Training

The final requirement for hazard analysis is that employers provide the information available about the chemical, physical and toxicological properties of each substance known or expected to be present on site to employees affected before they begin the work.

Compliance Pointer: It’s okay to use training and information provided under HazCom to meet this requirement.

 

 

 
 
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