Understanding Hazwoper 29 CFR 1910.120

Michael Hampton CSP, ARM
University of Utah, RMCOEH
Are you perplexed by
• Hazwoper is not a sandwich at Burger King
• “But I don’t deal with hazardous waste”
• What does Hazwoper mean?
Applies to hazardous
waste operations in
various settings
Also applies to emergency
responders at any industrial setting.
What We’ll Cover
• History of the standard
• Who is covered
• What is covered
• Training requirements
Where Did This Come From
• Regulatory History
• 1976 – RCRA passed into law to regulate the
handling of hazardous waste
• 1980 – CERCLA (Superfund)
• 1986 – SARA - OSHA given responsibility for
governing hazardous waste workers safety
• 1987 – OSHA issued NPR
• 1990 – Final Hazwoper rule goes into effect.
“To prevent accidents involving hazardous
Scope in Preamble
• “…those employees engaged in
emergency response operations for
releases or substantial threats of
releases of hazardous substances, and
post-emergency response operations
to such releases at all workplaces.”
What Drove This?
• December 1984 – Bhopal India
• August 1985 – Institute WV release
• 6,928 chemical accidents occurred in
the United States within a five-year
Are my employees covered?
• Who’s minding the store?
• 5 distinct groups of workers are covered
• Can be grouped into 3 “task” groups:
• Workers involved in waste clean up
• Employees working at a TSDF
• Employees engaged in emergency
response operations for release of, or
substantial threats of release of,
hazardous substances.
Application in the “real world”…
You are working for an environmental consulting company and your client
tells you that the property they own is on EPA's NPL, the state has issued
them a Notice of Violation, and they want you to tell them what's on the
property and what's going to have to be done to clean it up. This action is
covered under sections (i) & (ii) if under RCRA.
"You want to be a good neighbor, and the regulators are telling you that
your site is an uncontrolled hazardous waste site, but they haven't given you
a Notice of Violation or a Compliance order -– that's covered by section (iii).
If they give you the NOV, then you would be covered by either section (i) or
(ii), depending on how the Notice was written.
Section (iv) covers only those locations that have been permitted as TSDFs.
"Everyone else who has a spill, release, or cleanup not covered by any of the
above is covered by section (v). This also includes manufacturing plants that
have teams to handle their spills or releases."
What Materials Are Covered?
29 CFR 1910.1000 Toxic & Hazardous Substances , Table Z-1
“Hazardous Materials” - Physical
“Hazardous Materials” - Chemical
• Combustible
• Flammable
• Explosives
• Oxidizers
• Compressed Gases
• Organic Peroxides
• Sensitizers
• Irritants
• Corrosives
• Toxic & Highly Toxic
• Carcinogens
• DOT Hazardous Material Table, 49 CFR 172.101
• Roughly 2800 line items
• EPA – Discarded material that meets TRCI criteria
Standard’s Requirements
• Site Control Plan
• Standard operating procedures
• Organizational structure
• Site Safety & Health Plan
Hazard/Risk Identification
Safety and health training program
Medical surveillance program
Spill Control
Decontamination procedures
• Emergency Response Plan
Employee Training
Job function & Exposure Potential
Exposure Based – Waste Sites
General Site Worker – work with hazardous substances
with potential exposure >PEL
Occasional Site Worker – periodic , unlikely exposure
Management & Supervision
Waste Treatment Operations based
Emergency Response based
• Defensive or Offensive?
• Onsite vs. Offsite personnel
Training Requirements – Waste Site
General Site Worker – 40 hours of classroom
instruction plus three days supervised field experience
Occasional Site Worker – 24 hours of classroom
instruction plus one day supervised field experience
Management and Supervisor – Trained to the level of
the employees being supervised plus an additional 8hours of specialized training
Refresher training – Eight hours of annual refresher
training. As discussed above, the annual refresher
should be tailored to the specific duties and not a “one
size fits all”.
Training Requirements – Task based
• Operations at TSDF
• Provide for the safe conduct of work around
hazardous waste/materials
• 24 hours and 8 hour annual refresher
• Emergency Responders
First Responder Awareness level
First Responder Operations level
HazMat Technician/HazMat Specialist
Incident Commander
Emergency Response
• FR – Awareness
• Sees a spill and reports it, no time requirement
• FR - Operations
• All the above and attempts to contain spread but not to stop
the leak, 8 hours minimum
• Technician/Specialist
• Offensive action to stop the leak, 24 hours at FRO level +
standards requirements
• Incident Commander
• Overall control and charge of the situation, 24 hours at FRO
level + standards requirements
• Refresher training for above must be annual and sufficient to
maintain and demonstrate competency
• Understanding Hazwoper can be confusing
• Hazwoper applies to most of us
• Determine what the employee is doing
• Hazardous Waste Site Worker – 1910.120(e)
• TSDF Worker – 1910.120(p)
• Emergency Responder – 1910.120(q)
Train according to the requirements
Ensure that your documented program meets the
standards criteria
Training Summary
Training Level
Time Requirement
General Site Worker
40 Hours + 3 days on-site
Occasional Site Worker
24 Hours + one day on-site
Occasional to General Crossover
Site Worker Refresher
8 Hours
TSDF Worker
24 Hours
TSDF Worker Refresher
8 Hours
First Responder Awareness
Non specified
First Responder Operations
8 Hours
Hazardous Material Technician
24 Hours
Hazardous Materials Specialist
24 Hours
On Scene Incident Commander
24 Hours
Emergency Response Refresher
Non specified
Additional 8 hours
16 Hours + 2 days additional on-site
OSHA/EPA/USCG/NIOSH manual entitled, "Occupational Safety and Health
Guidance Manual for Hazardous Waste Site Activities“
USDOL, OSHA 3114 – Publication on HAZWOPER
Single Source Pages, Hazardous Waste https://www.osha.gov/SLTC/hazardouswaste/
Multiple training resources are available
HWWT program at RMCOEH
Michael Hampton
[email protected]

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