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