Highly hazardous materials, widely used in modern industry, are an ever present source of potential danger during transportation, storage and use. A number of government departments and agencies such as the Department of Transportation (DOT), the Environmental Protection Agency (EPA), the Consumer Product Safety Commission (CPSC) and the Occupational Safety and Health Administration (OSHA), each have a role to play in ensuring health and safety enforcement in the US. The DOT regulates transportation of hazardous materials (hazmat). The CPSC oversees hazardous materials that may go into consumer and household goods, while the EPA regulates hazardous materials that are likely to negatively impact the environment.
OSHA is charged with the regulation of hazardous chemicals, to ensure safety in the workplace. Hazardous materials are regulated via the Process Safety Management (PSM) 29 CFR 1910.119 standard. The agency also regulates hazardous waste clean-up operations as well as emergencies arising from hazmat related incidents through OSHA regulation 29 CFR 1910.120.
This Hazardous Waste Operations and Emergency Response Standard, known in short as HAZWOPER, became effective on March 6, 1990. The HAZWOPER 1910.120 standard encompasses:
- Clean-up operations required by a governmental body, conducted at uncontrolled hazardous waste sites
- Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA)
- Voluntary clean-up operations at sites recognized by the government as uncontrolled hazardous waste sites
- Operations involving hazardous wastes that are conducted at treatment, storage and disposal (TSD) facilities pursuant to RCRA regulations
- Emergency response operations involving substantial threats involving hazardous substances, without regard to the physical location of these threats
The OSHA standard concerning worker exposure to hazardous materials deals with hazards that workers may be exposed to in the workplace, and is not only oriented differently but is more broad-based than that of the DOT (which is more concerned with Hazmat Transportation). It is interesting to note that even though the 1910.120 HAZWOPER is an OSHA standard, it does not use the OSHA Hazard Communication Standard (29 CFR 1910.1200) for hazardous chemicals. In fact the definition derives from the EPA’s Comprehensive Environmental Response, Compensation and Liability Act (CERCLA, also known as Superfund).
The HAZWOPER definition, in addition to the CERCLA listed hazardous substances, also includes: certain biological and disease-causing agents, the DOT defined hazardous materials, as well as hazardous waste.
The CERCLA Standard incorporates exhaustive guidelines on issues relevant to the safe handling of hazardous materials. It requires detailed written safety and health programs for employees involved in hazardous waste operations. It provides examples of risks that would be relevant, such as situations that are injury threatening, immediate danger to life and health (IDLH), and danger to life and health (IDLH). It also provides examples of threats to environments, oxygen deficient situations etc.
Another important aspect of the OSHA standard is training. The HAZWOPER standard, which deals with hazardous waste operations and emergency response situations, necessarily requires a certain level of skill on the part of employees. OSHA mandated training courses may range from 4 to 40 hours depending upon the nature of the hazards being dealt with. After the initial training, OSHA also requires follow-up / refresher training. Fortunately, there are a number of commercial organizations which provide OSHA training programs, to ensure compliance to OSHA standards.