The next phase of Hazwoper compliance is to take the appropriate measures to eliminate or control risks to employees exposed to hazardous substances during operations (Sec. 1910.120(g)). Such measures include a combination of engineering controls like ventilation systems, work practices like buddy systems and use of respiratory protective equipment and other PPE. Here’s an overview of what’s required.
Click here for Model PPE Policy to include in your HASP.
Click here for Model Hazwoper Safe Work Requirements to include in your HASP.
Engineering Controls, Work Practices & PPE
Different requirements apply depending on the kind of substance(s) to which employees are exposed.
Subpart Z Substances
Subpart Z Substances include:
Employers must use engineering controls and work practices to keep employee exposure of substances regulated by Subpart Z of the General Industry Standard, i.e., Toxic and Hazardous Substance, at or below their PEL, unless those controls and practices “are not feasible.”
Feasible engineering controls may include the use of 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 employees from potential exposure during opening of drums, wetting down dusty operations and/or locating employees upwind of hazards.
If engineering controls aren’t required or feasible, employers must use “any reasonable combination of engineering controls, work practices and PPE” to keep exposure to Subpart Z substances at or below their PELs.
You can’t use an employee rotation level as a means of complying with PEL.
requirements unless there’s no other feasible way to comply with the airborne or dermal dose limits for ionizing radiation.
Subpart G Substances
Employers must follow the requirements that pertain to regulation of hazardous substances under 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).
Where Subparts G and Z Don’t Apply
Employers 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.
Selection of PPE
You must select and use PPE appropriate to protect employees from the hazards and potential hazards they’re likely to encounter as identified during the site characterization and analysis process.
Positive pressure self-contained breathing apparatus, or positive pressure air-line respirators equipped with escape air must be used when chemical exposure levels:
Employers must also implement a PPE program as part of the required written safety and health program and the site-specific safety and health plan explained above (See Step 1) addressing:
Other OSHA Standards Incorporated by Reference: