vvEPA
                      United States
                      Environmental Protection
                      Agency
                         Office of
                         Solid Waste and
                         Emergency Response
Publication 9285.2-08FS
April 1991
Hazardous Waste  Operations
and  Emergency  Response:
Uncontrolled Hazardous  Waste Sites
and RCRA Corrective Actions
 Office of Emergency and Remedial Response
 Emergency Response Division     MS-101
                                            Quick Reference Fact Sheet
INTRODUCTION
                Under the authority of section
                126 of the Superfund Amend-
                ments and Reauthorization Act
                of  1986  (SARA),  the  U.S.
                Environmental   Protection
                Agency (EPA) and  the  U.S.
                Occupational  Safety   and
Health  Administration  (OSHA)  promulgated
identical health and safety standards to protect
workers engaged in hazardous waste operations
and emergency response. The OSHA regulations,
codified at 29 CFR 1910.120, became effective on
March 6, 1990 (54 FR 9294). Corrections to the
OSHA regulations were published on  April 13,
1990  (55 FR 14072).   The EPA  regulations,
published on June 23,  1989 at 54 FR 26654,
incorporate the OSHA standards by reference and
are codified at 40 CFR 311.

      The EPA and  OSHA worker protection
standards for hazardous waste operations  and
emergency response (HAZWOPER) apply to three
primary groups of workers: (1) employees engaged
in  voluntary  and mandatory clean-ups  at
uncontrolled  hazardous  waste  sites,  including
corrective actions  at treatment, storage,  and
disposal (TSD) facilities regulated under  the
Resource  Conservation  and  Recovery  Act
(RCRA); (2)  employees engaged  in  routine
hazardous  waste  operations  at  RCRA  TSD
facilities; and (3) employees engaged in emergency
response operations without regard to location.
      The purpose of this Fact Sheet is to explain
the principle requirements of the EPA and OSHA
worker protection standards as they apply to
employees engaged in hazardous waste operations
at uncontrolled hazardous waste sites, including
                        employees who perform  corrective actions  at
                        RCRA TSD facilities. The other two groups of
                        employees  affected  by  the  regulations  are
                        addressed in a separate Fact Sheet entitled
                        Hazardous  Waste  Operations  and Emergency
                        Response: RCRA TSD and Emergency Response
                        Without  Regard  to  Location   (Publication
                        No. 9285.2-07FS). The requirements that apply to
                        individuals engaged in hazardous waste operations
                        at RCRA TSD facilities and emergency responders
                        who respond to emergencies without regard  to
                        location are specified at 29 CFR 1910.120(p) and
                        (q), respectively.

                             The   HAZWOPER  requirements  for
                        workers who engage in hazardous waste operations
                        and emergency response at uncontrolled hazardous
                        waste sites are specified at 29  CFR 1910.120(a)
                        through  (o), and are summarized  in Exhibit  1;
                        these requirements also apply  to those workers
                        who perform corrective actions at  RCRA TSD
                        facilities.    These  requirements  apply  to any
                        employee working at an uncontrolled hazardous
                        waste site who has the potential to be exposed to
                        hazardous substances.  As such,  the On-Scene
                        Coordinator  (OSC) and  the Remedial  Project
                        Manager (RPM) are both covered by the standards
                        and must fully implement the standards for other
                        employees engaged in hazardous waste site clean-
                        ups. These provisions also apply to  any activities
                        performed during the preliminary  planning and
                        evaluation stages of the remedial investigation and
                        feasibility study (RI/FS), such as the preliminary
                        assessment and site investigation (PA/SI).

                             In sum, all stages of a removal and remedial
                        operation performed at a site in which there is a
                        potential for exposure to  hazardous substances
                        must be conducted in accordance with the worker
                        protection  standards  specified  at 29  CFR

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                  EXHIBIT 1
        Hazardous Waste Operations and
      Emergency Response at Uncontrolled
             Hazardous Waste Sites
            (29 CFR 1910.120(a)-(o))
    (a)  Scope, application, and definitions.

    (b)  Safety and health program.

    (c)  Site characterization and analysis.

    (d)  Site control.

    (e)  Training.

    (£)  Medical surveillance.

    (g)  Engineering controls, work practices, and
        personal protective equipment for employee
        protection.

    (h)  Monitoring.

    (i)  Informational programs.

    (j)  Handling drums and containers.

    (k)  Decontamination.

    (I)  Emergency response by employees at
        uncontrolled hazardous waste sites.

    (m) Illumination.

    (n)  Sanitation at temporary workplaces.

    (o)  New technology programs.
 1910.120(a) through (o). The standards, however,
 do not apply to employees who do not have the
 potential to be exposed to hazardous substances.
 For example, administrative support personnel  in
 the Incident Command Post may not be covered by
 HAZWOPER.  These employees, however, must
 be made aware of the provisions of the emergency
 response plan.  Specifically, they  must be briefed
 on the procedures  to take during an emergency  at
 the site, and they must be familiar with general site
 operations, such as  the location  of work zones.
 Employees not covered by HAZWOPER are,  of
course, protected  by  other  OSHA standards
including  the  Hazard Communication Standard
 (HAZCOM).
       In addition to the requirements specified at
29  CFR 1910.120(a) through (o),  other worker
protection   requirements   may   also  apply   at
uncontrolled hazardous waste sites.  For example,
29  CFR 1910.120(q) applies to workers, such  as
local HAZMAT team members, who come on-site
specifically  to   perform   emergency  response
operations.  The requirements specified at (q),
however, do not apply  to regular site employees
who perform routine clean-up operations  at the
site and who may also perform emergency response
operations; these individuals are covered by the
requirements in 29 CFR 1910.120(e).

       This Fact Sheet is divided into six parts.
The first  three parts describe  the planning,
training, and medical surveillance requirements for
workers engaged in  hazardous waste  operations
and emergency response at uncontrolled hazardous
waste sites.  The fourth part  of  this Fact Sheet
discusses other requirements of HAZWOPER that
must be implemented  at uncontrolled hazardous
waste sites.  The fifth part of this  Fact Sheet
discusses employee rights  under section 8  of the
Occupational Safety  and Health Act  of  1970,  as
amended (OSH Act).  The final part of this Fact
Sheet provides important addresses and telephone
numbers.
                  PART 1:  PLANNING
                  REQUIREMENTS

                  Part  1  of  this  Fact  Sheet
                  explains the  purpose  of the
                  comprehensive    safety   and
                  health program  and the site-
specific health and safety plan (HASP); describes
the specific steps that must be taken to develop a
HASP; explains the type  of information that must
be included in the HASP; and summarizes the
responsibilities of  the  OSC,  RPM,  and  the
Environmental  Response   Team   (ERT)  in
developing a HASP at an EPA-lead site.

      There are many different  types of entities,
including state agencies, private corporations, and
the  federal government,  that  may have  lead
responsibility  in  cleaning up  an   uncontrolled
hazardous waste site or a contaminated  RCRA
TSD facility.  Each of these entities uses different
titles to identify  the person  who has  overall
responsibility for site activities.  For purposes of
this Fact Sheet, this responsible person is referred
to as the OSC/RPM, as it is at EPA-lead sites.

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Safety and Health Program

      Any  employer whose workers engage in
hazardous   waste   operations   and  emergency
response at an uncontrolled hazardous waste site
or who perform corrective actions at a RCRA TSD
facility must develop and implement a written
safety and health program.  This program must be
designed to identify, evaluate, and control safety
and health hazards at any site, and to provide for
emergency response during site operations.   The
written safety and health program must include an
organizational structure; a site-specific health and
safety plan (HASP); a comprehensive workplan; a
medical surveillance program; and a description of
the employer's standard operating procedures. For
a  complete list  of the elements required in the
written safety and health program, refer to 29 CFR
       The  primary purpose  of  the safely  and
health program is to serve  as the organization's
comprehensive health and safety policy that applies
to all employees of the company, irrespective of
the location of the actual  site where they are
working. This program must be maintained by the
employer and made available to any employee or
employee representative; contractor, subcontractor,
or other representative working for the employer
who will be  potentially  exposed to  hazardous
substances;  OSHA personnel; and personnel of
federal, state, and local agencies  with  regulatory
authority over the site.  It is important to note that
only one safety  and  health program  should be
developed by an employer,  even if the employer
has workers that  perform operations  at several
different sites.

       If an employer has  already  developed a
safety   and   health  program   to   meet   the
requirements  of other  federal,  state,  and -local
regulations,  the employer may use  the  existing
program to satisfy the HAZWOPER requirements,
so long as any additional information not covered
in  the existing  program  but  required under
HAZWOPER is incorporated into the  program.

Site-Specific HASP

       Although the standards require  employers
to develop  and implement  only  one safety  and
health program,  a site-specific  HASP must be
developed and implemented for each site where
workers  are potentially  exposed  to  hazardous
substances.
      The purpose of the site-specific HASP is to
address  the safety and  health  hazards  that may
exist  at  each phase  of site operations and  to
identify  procedures  for  protecting  employees.
Exhibit  2 presents a comprehensive list of the
elements that must be included in the HASP.

      Information  gained  during  the  site
characterization,   as   specified  at   29  CFR
1910.120(c), must be considered in developing the
HASP.  The site characterization may be divided
into three  stages:   preliminary evaluation (PE),
initial site entry, and ongoing monitoring. Under
the requirements of 29  CFR 1910.120(b)(4), the
HASP must be developed after the PE has been
performed  and before  any site  entry.   The
following is a brief discussion of the specific steps
that must be taken to  develop, implement, and
maintain a  HASP.

Step 1: Preliminary Evaluation

      The first step in  developing a HASP is to
perform a preliminary evaluation (PE) of the site's
characteristics.  The PE must be accomplished off-
site, so as not to endanger the health and  safety of
site workers.  The purpose of the PE is to obtain
preliminary information  to help  identify the
specific  hazards at the site and determine the
appropriate safely and health control procedures
(e.g.,  engineering  controls, personal  protective
equipment  (PPE), and  any additional  medical
surveillance needs) that are necessary to ensure the
protection of employees who perform tasks on-site.
The specific  information that must be obtained
during the  PE is summarized below and  outlined
in Exhibit 3. The information obtained during the
PE should be used to  develop the HASP.

      There are  several  ways  in  which  the
information specified in Exhibit  3 can be obtained.
For example, records of the site or interviews with
persons who are knowledgeable about the site can
provide useful  information about  the  potential
hazards  at  a site.   Potentially  useful sources  of
information include:  company records,  receipts,
logbooks, or ledgers that describe site activities;
records from state and  federal pollution control
regulatory  and enforcement agencies  and state
occupational and  health  offices; local  fire and
police department records; site photos; and media
reports.

      In addition to  interviewing knowledgeable
persons and  researching the history of  the site,

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                  EXHIBIT 2
           The Specific Components
                  of a HASP
Key personnel.

Safety and health risk or hazards analysis
for each site task and operation found in
the workplan.

Employee training assignments to assure
that each employee receives the training
required before they engage in any
operation that could potentially lead to
exposure to a hazardous substance or to
safety or health hazards.

Personal protective equipment appropriate
for each site task or operation conducted.

Medical surveillance requirements.

Employee and air monitoring equipment
and environmental sampling techniques and
instrumentation to be used.

Site control measures that include at a
minimum - a site map, a buddy system, site
communications system (including
emergency alerting), standard  operating
procedures or safe work practices, and
identification of the nearest medical
assistance.

Decontamination procedures both for
individuals and equipment on  site and in
places where there is a potential for
exposure to a hazardous substance.

An emergency response plan for safe and
effective responses to emergencies.

Confined space entry procedures.

A spill containment program to contain and
isolate the entire volume of any hazardous
substance spilled in the course of a transfer.

Hazard communications plan (29 CFR
1910.1200 and 29 CFR 1926.59).
data-gathering at the site perimeter (i.e., perimeter
reconnaissance)  may  help  in  identifying  site
hazards and potential pathways for exposure, and
determining the appropriate  level of PPE for the
initial site entry. Perimeter reconnaissance activities
during the PE must be  conducted off-site.   To
identify the appropriate sampling  techniques for
perimeter reconnaissance, the safety and  health
officer should review the  information obtained
during the records/interview research.  The most
important   thing   to  remember   is  that   the
OSC/RPM  must not, under any  circumstances,
allow  a worker  to enter  the site  to   collect
information for the PE.
                                                              THE PE MUST BE COMPLETED
                                                                         PRIOR TO
                                                               ANYONE ENTERING THE SITE
                                                      Step 2:  Developing the HASP

                                                             Once  the  PE   is  completed  and  the
                                                      appropriate   information   is   obtained,   the
                                                      OSC/RPM at the site  must use the information
                                                      gathered during the PE to develop the initial draft
                                                      of the site-specific HASP. The initial draft of the
                                                      HASP must include all elements listed in Exhibit
                                                      2.  Specifically, it must identify each anticipated
                                                      safety and health hazard  for each work operation
                                                      or activity, and describe how those hazards will be
                                                      eliminated or controlled.  In addition, the HASP
                                                      should identify appropriate monitoring procedures
                                                      and PPE for the initial site entry. The HASP must
                                                      remain  on-site at all times and only one HASP
                                                      should be developed for each site.
                                                                NO ONE MAY ENTER THE
                                                            SITE UNTIL THE HASP HAS BEEN
                                                             DEVELOPED, APPROVED, AND
                                                                     IMPLEMENTED
Step 3:  Initial Site Entry

       Once  the   HASP  is   developed  and
implemented,  the  second  stage  of  the  site
characterization and analysis (i.e., the initial site
entry) may begin.   The purpose of the initial site
entry is  to  gather  additional  information and
further evaluate the site's specific characteristics to
identify and  confirm existing site hazards  and  to
aid  in the  selection of appropriate  engineering
controls and PPE.

       At a minimum, activities  during the initial
site entry should consist  of a visual survey  for

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                 EXHIBIT 3
          Specific Components of the
            Preliminary Evaluation
           (29 CFR 1910.120(c)(4))
         Site location and size.
         Description of response activity and/or
         the job to be performed.
         Duration of the planned activity.
         Site topography and accessibility by air
         and roads.
         Safety and health hazards expected at
         the site.
         Pathways for hazardous substance
         dispersion.
         Present status and capabilities of
         emergency response teams that would
         provide assistance for on-site
         emergencies.
         Hazardous substances and health
         hazards involved or expected at the
         site, and the chemical and physical
         properties of these substances.
potential hazards and, when there is potential for
exposure,  air monitoring.  Multi-media sampling
should also be performed if the OSC/RPM has
reason to believe that  contamination may have
occurred.

       An  accurate  and  comprehensive  visual
survey of the site will assist the OSC/RPM in
identifying  and  determining  what   additional
information (e.g., sampling of soil or containers)
may be needed.  This visual survey could include
noting the  condition of waste containers  (e.g.,
undamaged   or   rusted);  noting  any  unusual
conditions; and determining potential pathways for
exposure.

       When entering the site, entry personnel
should  monitor  the  air  using  direct  reading
instruments for immediately dangerous to life and
health (IDLH) conditions (e.g., combustable or
explosive  atmospheres,  oxygen deficiency,  toxic
substances)  and  for  ionizing  radiation.    Such
monitoring, however, need only be conducted if the
PE produces information that indicates (1) existing
IDLH conditions, or (2) the potential  for ionizing
radiation, or if the information from the  PE  is
insufficient to reasonably conclude that neither of
these  two conditions exists.   When  monitoring,
entry personnel should look for signs of actual or
potential  IDLH  hazards  or  other  dangerous
conditions.   Examples  of  hazards  that may be
identified at  a site include confined space entry,
visible  vapor  clouds,  or  areas   that  contain
biological indicators such as dead vegetation.  The
specific monitoring requirements for initial  site
entry are specified at 29 CFR 1910.120(c)(6)  and
       In addition to air monitoring, multi-media
sampling should be performed during the initial
site entry, if the OSC/RPM believes contamination
may exist. The soil sampling techniques employed
will differ with each site.  Prior to beginning site
activities, it is imperative that the purpose of the
effort  and  the ultimate  use of  the data  be
established. Specific strategies should be selected
based on the information required.

       One important goal  of the initial site entry
is to identify the risks and hazards at the site so
that the work zones can be established. The three
most frequently identified zones are the Exclusion
Zone, the Contamination Reduction Zone, and the
Support Zone (also known as the Clean Zone).
The Support Zone  should  be an area  of the site
that is free from contamination and that may safely
be used as a staging area for other hazardous waste
operations at the site.  For additional information
and guidance on how to designate work zones,
consult the Fact Sheet entitled Establishing Work
Zones  at  Uncontrolled Hazardous  Waste  Sites
(Publication No. 9285.2-06FS).

       Any information concerning the chemical,
physical, and lexicological properties of hazardous
substances identified during the initial site entry
must be made available to employees prior to the
commencement of operations at the site.
      INITIAL SITE ENTRY ACTIVITIES
     MUST, AT A MINIMUM, INCLUDE A
    VISUAL SURVEY AND, WHEN THERE
       IS POTENTIAL FOR EXPOSURE,
             AIR MONITORING
Step 4:  Update the HASP

       Once the initial site entry is completed, the
OSC/RPM is responsible for updating the HASP
to  ensure that  it adequately identifies any new

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tasks or hazards at the site. At most sites, any air
and multi-media sampling performed during the
initial site entry will provide the OSC/RPM with
more    accurate  information  regarding   the
appropriate  level of  PPE to  be worn by site
employees and  the  proper designation of work
zones.
      UPDATE THE HASP AFTER
      THE INITIAL SITE ENTRY
Step 5:  On-Going Site Activities

      Once the HASP  is revised to reflect the
information gathered during the initial site entry,
on-going monitoring must occur  at  the  site  to
ensure that all new hazards are identified in  a
timely manner and that  the appropriate controls
are implemented to  protect site employees.

      If new tasks or hazards are identified at a
site, do not develop  a new HASP; instead, update
the original HASP.  If a  subcontractor is working
at  a site, the  subcontractor  should  carefully
evaluate and identify all  tasks associated with the
subcontracted activities, and prepare a health and
safety plan addressing any identified hazards. This
plan should be submitted to  the OSC/RPM who
will incorporate it into the general site  HASP after
it has been reviewed for concurrence with the site
workplan.
              THE RULE IS:
         ONE SITE, ONE HASP
      When developing a HASP, be  careful  to
ensure that all required information as specified at
29  CFR 1910.120(b)(4)(ii) is  addressed  in the
HASP.  The remainder  of this part of the Fact
Sheet will explain the specific elements that must
be included in the HASP.

Elements of the HASP

      The information that must be included in
the   HASP   is   specified    at   29   CFR
1910.120(b)(4)(ii) and summarized  in  Exhibit 2.
Some of the areas that must be addressed in the
HASP,  such  as  the employer's  monitoring and
decontamination programs, are discussed in further
detail below.  In addition to the elements specified
at 29  CFR 1910.120(b)(4)(ii),  the HASP  must
identify  key   personnel  and   HAZCOM
requirements and provide for pre-entry briefings to
be held before site  activity is  initiated.   These
meetings should be held at any time they appear
necessary to ensure that employees are adequately
apprised of the safety and health procedures being
followed at the  site.

Monitoring program (29 CFR 1910.120(h)).   The
OSC/RPM's proposed monitoring program  must
be  included  in the  HASP.   The monitoring
program must include procedures  for initial  entry
monitoring, periodic  monitoring, and monitoring
of  high  risk  employees.    The  monitoring
requirements for initial site entry  are specified at
29  CFR  1910.120(c)(6)  and  (h)(2)  and   are
discussed in detail on p. 5.

       In general, monitoring must be performed
whenever  there is  any possibility  that employees
may  be exposed to hazardous substances.   The
purpose of monitoring is to ensure that the proper
engineering controls, work practices, and PPE are
used to protect  employees at the site.

       Periodic  monitoring should be conducted
whenever  there is  any indication  that exposures
have risen above the permissible  exposure limits
(PELs), or other dangerous conditions exist such
as the presence of  flammable atmospheres or
environments   that   are  oxygen-deficient.
Monitoring of  high  risk  employees  should be
conducted on those employees suspected of having
the highest exposures to hazardous substances and
health hazards.

       In addition to the monitoring requirements
specified in 29 CFR 1910.120, there are other
applicable OSHA standards, specifically Subpart Z,
29 CFR 1910.1000, that refer  to particular air
sampling and monitoring procedures for chemical
contaminants. These standards also specify certain
PPE and recordkeeping requirements for a variety
of  compounds.    The  compounds  and  their
accompanying regulations are listed  in Exhibit 4.

Site control program (29 CFR 1910.120(d)).   The
site control  program in the HASP specifies  the
procedures that will be used to minimize employee
exposure to hazardous substances before clean-up
operations commence and during  site operations.
The  site  control  program  must  be developed

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EXHIBIT 4
Toxic and Hazardous Substances
Subpart Z, 29 CFR 1910.1000
Compound
Asbestos
Coal tar pitch volatiles
4-nitrobiphenyl
Alpha-Naphthylamine
Methyl chloromethyl ether
3,3'-dichlorobenzidine
bis-chloromethyl ether
Benzidine
4-aminodiphenyl
Ethyleneimine
beta-propiolactone
2-acetylaminofluorene
4-dimethylaminoazo-
benzene
N-nitrosodimethylamine
Vinyl chloride
Inorganic arsenic
Lead
Benzene
Coke oven emissions
l,2-dibromo-3-chloro
propane
Acrylonitrile
Ethylene oxide
Formaldehyde
OSHA Reference
29 CFR 1910.1001
29 CFR 1910.1002
29 CFR 1910.1003
29 CFR 1910.1004
29 CFR 1910.1006
29 CFR 1910.1007
29 CFR 1910.1008
29 CFR 1910.1010
29 CFR 1910.1011
29 CFR 1910.1012
29 CFR 1910.1013
29 CFR 1910.1014
29 CFR 1910.1015

29 CFR 1910.1016
29 CFR 1910.1017
29 CFR 1910.1018
29 CFR 1910.1025
29 CFR 1910.1028
29 CFR 1910.1029
29 CFR 1910.1044

29 CFR 1910.1045
29 CFR 1910.1047
29 CFR 1910.1048
during the planning stages of a hazardous waste
clean-up operation, and must be modified as any
new information becomes available.   The  site
control program must, at a minimum, include a
site  map,  work   zones,    communications,
identification of the nearest medical assistance, and
safe work practices.

       Engineering   controls   and  safe  work
practices  must be  specified  in the site control
program to protect employees from exposure to
hazardous substances and other safety and health
hazards.  Engineering controls and work practices
should be  implemented  to reduce  and maintain
employee exposure to levels at or below the PELs
for those  hazardous  substances  at  the  site.
Examples of engineering controls that may be used
include pressurized cabins and  control  booths on
equipment.  If, for whatever reason, it is not possible
to maintain employee exposure to levels at  or below
PELs, technical assistance should be obtained from
other sources before proceeding with site activities
(e.g., ERT or OSHA).

      PPE  should  be used as a  last resort  to
protect  employees against possible exposure  to
hazardous substances.  It should only be used when
engineering  controls  and work  practices are
insufficient to adequately protect against exposure.
The PPE used at the site must be reflective of the
potential site hazards identified during the PE and
initial site characterization.

Decontamination program (29 CFR 1910.120(k)).
The  decontamination  procedures  should  be
developed and appropriately communicated to all
employees before they enter a site where potential
for exposure to hazardous substances exists.  The
OSC/RPM    must   develop  and   include
decontamination procedures in the  HASP that
identify standard operating procedures at the site;
such procedures should provide employees with
information  on how to minimize their contact with
hazardous   substances.     In   addition,  the
decontamination program must include procedures
for employees who leave a contaminated area on
the site.  Such employees must be decontaminated
and their equipment  must be  disposed  of  or
decontaminated.    The  requirements  for  a
decontamination program are codified at 29 CFR
1910.120(k).

Emergency response plan (29 CFR 1910.120(1)). One
of the most important components of the HASP is
the written site-specific emergency response plan.
This  plan must include  a  description of how
anticipated emergencies would be handled at the
site and how the risks associated with a response
would be minimized.  The emergency response plan
must  be  developed  and  implemented prior  to
commencing operations at a site.

      The  requirements  for  an   emergency
response plan at an uncontrolled hazardous waste
site are summarized in Exhibit 5 and are codified
at 29 CFR 1910.120(1)(2).

      In  addition   to  these   elements,  the
emergency response plan must include information
relevant for conducting emergency operations at
the site, such  as information on site topography,
layout,  and prevailing  weather conditions, and
procedures  for reporting incidents to  local, state,
and federal agencies.   The emergency response
plan must also be rehearsed regularly and reviewed
periodically to ensure that it accounts for new or

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                  EXHIBIT 5
            Required Elements of an
        Emergency Response Plan at an
       Uncontrolled Hazardous Waste Site
            (29 CFR 1910.120(1) (2))
       Pre-emergency planning.
       Personnel roles, lines of authority, and
       communication.
       Emergency recognition and prevention.
       Safe distances and places of refuge.
       Site security and control.
       Evacuation routes and procedures.
       Decontamination procedures.
       Emergency medical treatment and first aid.
       Emergency alerting and response
       procedures.
       Critique of response and  follow-up.
       PPE and emergency equipment.
 changing  site conditions or new  information on
 potential  hazards at the site.

       In  lieu of preparing an emergency response
 plan, OSC/RPMs may prepare an emergency action
 plan in accordance with 29 CFR 1910.38(a).  This
 plan  may only  be  developed  in lieu of  the
 emergency  response  plan  if  employees   are
 evacuated from the site when an emergency occurs,
 and are not permitted to assist in responding to
 the  emergency.    An  emergency action  plan
 includes  an  evacuation  plan in  which  persons
 responsible for an  orderly  exit  are  identified.
 These designated individuals will direct employees
 to leave the site, maintain a safe distance, and call
 the appropriate emergency response organization.

       If  an  emergency action  plan is  prepared,
 arrangements   must  be made  with   the  local
 response community (e.g., fire department or other
 local  response  services)  for them  to respond to
 emergencies that may occur during site operations.
 The local  response community must be provided
 with  sufficient  information on  site  activities,
 including  the types of operations being conducted
 at the site, the type and degree of contamination at
 the site, the location of work zones, and any other
 relevant information  that may be necessary for an
 appropriate response.  Such information must be
 provided  prior  to  the  commencement  of  site
 operations.  Regardless of whether an  emergency
 action  plan or  an  emergency  response  plan  is
prepared, local response officials must be  notified of
site operations prior to the  commencement of any
site activities.

Spill   containment  program   (29  CFR
1910.120(j)(l)(viii)). In the event of a major spill
or a release on-site, the spill containment program
must  be implemented to contain and isolate the
hazardous substance release.

Responsibilities of the OSC/RPM

       The OSC/RPM is responsible for reviewing
the HASP  for consistency with the workplan and
accepting the HASP for the site. The HASP must
accurately reflect the work being performed at the
site, and must be reviewed and approved again
when any additions or revisions are made to the
HASP throughout the course of work at the site.

       The  OSC/RPM  is  also responsible  for
ensuring that employees are adequately  informed
of the procedures to  report  a health and safety
violation, as well as the procedures for filing  a
workman's compensation  report.    Specifically,
employees should be told that a health and safety
complaint  may  be made  either in writing or
verbally, and  that  such complaints  should be
addressed to the OSC/RPM, the contractor's health
and safety  officer, and the EPA contract officer.
The OSC/RPM should also ensure that workman
compensation  forms are available on-site.  For
additional information on employee rights, refer to
Part 5 of this Fact Sheet.

Role  of the Environmental  Response Team
(ERT)

       If additional guidance is needed or desired,
the OSC/RPM may submit the HASP to ERT for
review or may request a site audit. It is important
to note that ERT does not approve HASPs; ERT
will   only   review   them  and   provide
recommendations.  As soon as the HASP has been
accepted by the OSC/RPM, covered  operations at
the  site   may  commence;   a plan   may  be
implemented without ERT concurrence.

       In general, it  is  the  Agency's  policy  to
encourage the development of an effective HASP
and  to  assist  the Regions  with  the   task of
reviewing and  processing HASPs. As such, ERT
will provide consultation  and  assistance if such
assistance is requested. For further information on
ERT assistance,  contact the OSWER Health and
Safety Manager in ERT in Edison, New Jersey, at

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(FTS)  340-6740  or  (908) 321-6740.   Regional
Health and Safety Officers may also be available
for plan review and consultation.  Refer to your
Regional directory for the relevant addresses and
telephone numbers.
                  PART 2: TRAINING
                  REQUIREMENTS

                  This part of the  Fact Sheet
                  addresses the  HAZWOPER
                  training   requirements  that
                  apply to employees engaged in
hazardous   waste  operations   and  emergency
response at uncontrolled hazardous waste sites and
employees  who  perform  corrective  actions  at
RCRA TSD facilities.

General Training Requirements

       Each employer at a site is responsible for
ensuring  that  their  respective  employees  are
properly   trained   and   equipped   prior   to
commencing work at a site. The HAZWOPER
training required for site workers must identify the
hazards present on-site, the medical  surveillance
requirements, certain elements of the HASP, and
operating practices and procedures, including the
use of PPE and proper engineering controls. The
specific issues and topics that are  required to be
addressed during training are specified at 29 CFR
1910.120(e)(2). The amount of training required
for site workers is linked directly to an employee's
potential for exposure to hazardous substances and
to other health hazards at the site, and is specified
at 29 CFR 1910.120(e)(3) and (4). Employees may
not participate in or supervise any-site activity until
they  have been adequately trained.

       The HAZWOPER standards specify hourly
requirements for  four different categories of site
workers. The amount of training  a worker must
receive is  commensurate  with the  employee's
potential  for  exposure;   the  hourly  training
requirements  are described briefly  below  and
summarized in  Exhibit 6.

       General site workers at an uncontrolled
hazardous waste site include equipment  operators
and general laborers engaged in routine hazardous
waste removal.  These routine site workers must
have a minimum of 40 hours of instruction off-site
and  24  hours of field  experience  under  the
supervision  of  a  trained  and   experienced
supervisor.
                 EXHIBIT 6
       Initial Training Requirements for
          Employees at Uncontrolled
            Hazardous Waste Sites
             (29 CFR 1910.120(e))
   Routine Site     40 Hours Off-Site
   Employees      24 Hours Field Experience
    Occasional
    Employees and
    Routine Site
    Employees Unlikely
    to be Exposed
    Above PELs

    Supervisors      8
24 Hours Off-Site
 8 Hours Field Experience
    Site Employees
    Assigned Site
    Emergency
    Response
    Duties
  Hours of Specialized
    Training, in addition to
    the Requirements for
    the Employees they
    Supervise

    Trained to a Level
    of Competency in
    Addition to above
    Requirements
   All Site         8 Hours Annual
   Workers            Refresher Training
      Workers who are on-site only occasionally
to perform a  specific job, such as groundwater
monitoring, and who are unlikely to be exposed
over PELs, are required to have  a minimum of 24
hours of instruction  off-site and  a minimum of
eight hours of supervised field experience.

      Routine site workers who  work only in
areas where the exposure levels are monitored and
determined to be below PELs are also required to
receive 24 hours of instruction off-site and 8 hours
of supervised field experience.

      Supervisors  of  the  three  groups  of
employees described above are required to receive
the  same amount of  initial training  and field
experience as the employees they supervise, plus 8
additional  hours  of   specialized  training  in
managing hazardous  waste  operations.    For
example, if a supervisor only manages employees
who work on site occasionally, the supervisor must

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have a minimum of 24 hours of instruction off-site
and 8 hours of supervised field experience, plus an
additional eight hours of specialized management
training.

      In addition to the requirements listed above,
any worker who receives 24 hours of training and
who then becomes a general site worker or whose
job function requires that a respirator be worn,
must have an additional 16 hours  of instruction
off-site and 16 hours of supervised field experience
before commencing the new duties at the site.

      Some of the training requirements specified
above may be waived if the employee has had prior
work experience or training. For example, certain
training  requirements   may be waived  if  the
employee has  had  experience working at  an
uncontrolled  hazardous  waste site  or  if  the
employee has  participated in  training courses
offered by independent and federal organizations
(e.g., EPA).  If the employer  believes that an
employee has  sufficient  prior experience  or
training to waive some or all of the HAZWOPER
training   requirements,  the   employer  must
document the basis for his belief, denoting length
and  type of experience or training.

      Although there are no specific additional
training   requirements   for   employees   with
emergency  response  duties   at  a  site,  such
employees must be trained commensurate with the
duties that will be assumed.

Refresher Training

      All  employees   who  perform  clean-up
operations at uncontrolled hazardous waste sites,
including managers and  supervisors, must receive
a minimum of  eight hours of annual  refresher
training.  The purpose of refresher training is to
maintain certain competencies.  There are several
ways  to  satisfy the annual  refresher  training
requirement.  For example, as explained  on p.  7 of
this  Fact Sheet, the emergency response plan of
the  HASP must be rehearsed regularly.  These
rehearsals can be used to meet some of the annual
refresher training requirements.  Attendance at
applicable  seminars and  critiques   of actual
responses are also acceptable methods of satisfying
the annual refresher training requirements. Proper
documentation of attendance, however, should be
maintained.
Training Accreditation

      On January 26,  1990, OSHA published a
Notice of Proposed Rulemaking (NPRM) (55 FR
2776) that proposed accreditation procedures for
programs to train employees engaged in  clean-up
operations at uncontrolled hazardous waste sites,
and for employees engaged in certain hazardous
waste operations  at RCRA TSD  facilities.  The
NPRM  also proposed  amendments to  29  CFR
1910.120 to include appropriate references to the
provisions set forth in the proposed rule.  If this
regulation is promulgated as it was proposed, all
employees  subject  to  29  CFR 1910.120  at
uncontrolled hazardous waste sites will be required
to attend an accredited training  program or  to
document equivalent training and experience.
   4-HH
                 PART 3: MEDICAL
                 SURVEILLANCE
                 REQUIREMENTS

                 Part  3  of  this  Fact  Sheet
                 discusses   the   medical
                 surveillance requirements  in
HAZWOPER that apply to employees engaged in
hazardous  waste  operations   and  emergency
response at  uncontrolled hazardous waste sites,
including  employees  who  perform  corrective
actions at RCRA TSD facilities.

General Medical Surveillance Requirements

      The  HAZWOPER  medical  surveillance
requirements  (29 CFR 1910.120(f)) provide the
framework for a medical monitoring program for
workers at uncontrolled  hazardous waste sites.
The  standards  contain provisions for  baseline,
periodic, and  termination  medical examinations.

      A  medical  surveillance  program  must
include monitoring for the following four groups of
employees:

•     Employees who are, or may be, exposed to
      PELs or health hazards for 30 or more days
      a year;

•     Employees who wear a respirator for 30 or
      more days a year;

•     Members of organized HAZMAT Teams;
      and
                                               10

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•     Employees  who  are  injured  due  to
      overexposure during an emergency incident,
      or who show symptoms of illness that may
      have resulted from exposure to hazardous
      substances.

      If employees  fall  within  the first three
groups  specified  above,  they  must  undergo  a
baseline  medical examination prior  to  a site
assignment.    After  this  initial  examination,
employees  must  have  a  follow-up  medical
examination once a year; an attending physician
may suggest a shorter or longer interval, but this
period may not exceed two years.  The content of
these  examinations should be determined by the
attending physician, but certain key elements must
be  included.  For example, the  physician must
complete  a  medical  and  work   history and
determine the employee's  fitness for the type of
duties to be  assigned, including  the employee's
ability  to  wear  PPE.    Once  the  medical
examination has been completed,  the employer
must obtain and furnish the employee with a copy
of the physician's written opinion. The physician's
written  opinion  must include the results of the
medical examination and tests, any recommended
work  limitations,  and the  physician's  opinion
concerning the medical condition of the employee.

      In addition to the initial and follow-up
examinations, employees must  receive a medical
examination as soon as possible if they are injured
or  become ill  from exposure  to  hazardous
substances on-site or during an emergency, or they
develop signs or symptoms that indicate a possible
overexposure to hazardous substances. In addition,
employees  who   are   reassigned  or terminate
employment and,  therefore, will no longer  be
exposed to hazardous substances must receive a
final  examination.   This  examination  is  only
required if  the  employee has  not  had  an
examination within the past six months.   All
required medical examinations  must be provided
without cost to the employee, without loss of pay,
and at a reasonable time and place.

      Additional  guidance  on  these  medical
surveillance requirements can be found in:

•     U.S.   EPA  OERR  Medical  Monitoring
      Program   Guidelines,  OSWER Directive
      9285.3-04.   To obtain  a copy of these
      guidelines,  contact   the  Environmental
      Response  Team (ERT) of EPA in Edison,
      New Jersey.  (Refer to Exhibit 8 for the
      appropriate address and telephone number.)

•     Standard Operating Safety Guides, OSWER
      Directive 9285.1-OIC. To obtain a copy of
      this document, contact ERT in Edison, New
      Jersey.

•     Hazmat   Team   Planning   Guidance,
      Publication Number EPA/540/G-90/003. To
      obtain a copy of this document, contact the
      National Technical Information Service at
      (703) 487-4600.

•     Occupational Safety and  Health Guidance
      Manual for Hazardous Waste Site Activities
      (Chapter   5     Medical   Monitoring),
      Publication Number 017-033-00419-6.  To
      obtain a copy of this document, contact the
      Superintendent of Documents  at the U.S.
      Government Printing Office in Washington,
      D.C.  20402 ((202) 783-3238).

Medical Records

      Medical  records  for employees must be
maintained for a period of thirty years following
termination of employment.  These records must
include the name and social security number of the
employee;  the  physician's  written  opinions,
including recommended occupational limitations
and  results  of  examinations  and  tests;   any
employee medical complaints related to exposure
to hazardous  substances; and a  copy  of  the
information provided to the examining physician by
the employer.   The employer is responsible for
retaining the records if the employee or physician
leaves  the area,  or the company goes out of
business.  For additional information on  medical
recordkeeping equirements,  refer  to 29  CFR
1910.20.
                 PART 4: OTHER
                 REQUIREMENTS

                 This  part of  the  Fact  Sheet
                 discusses other requirements in
                 HAZWOPER  that  apply  to
                 employees   engaged   in
hazardous  waste  operations   and  emergency
response at uncontrolled hazardous  waste sites.
Specifically, this part outlines the requirements for:
(1)  handling   drums   and   containers,    (2)
illumination and sanitation requirements, and  (3)
informational and new technology programs.
                                                11

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Requirements  for  Handling  Drums  and
Containers (29 CFR 1910.120(j))

      When   performing   site   operations,
HAZWOPER specifies some  basic requirements
for handling  drums and containers  on-site.   In
general, site  operations should be organized to
minimize  the amount of drum  and container
movement. However, if drums or containers must
be  moved,  the following are  a  few  of  the
requirements that must be  met.

•     Drums and  containers  must be inspected
      prior to being moved. If this is not possible
      because the  drums are  buried beneath the
      earth  or  stacked several tiers high,  the
      drums or containers should be moved to an
      accessible location and then inspected prior
      to further handling.

•     Prior  to  the  movement  of  drums,  all
      employees who have  a  potential  to  be
      exposed to hazardous substances as a result
      of the transfer  operation must be notified
      of the potential hazards associated with the
      contents of the  drums or containers.

      In  addition  to  the above requirements,
HAZWOPER provides specific  procedures  for:
(1) opening drums  and containers;  (2) selecting
and  operating material handling equipment; (3)
handling radioactive and shock-sensitive wastes and
laboratory waste packs; (4) sampling the contents
of  drums   or  containers;  (5)  shipping   and
transporting drums or containers; and (6) handling
tanks and vaults containing hazardous substances.

Illumination and Sanitation Requirements
(29 CFR 1910.120(m) and (n))

      The employer is responsible  for ensuring
that appropriate procedures exist at the  site to
maintain certain minimum illumination intensities
and an adequate supply of water.  There must be
two  separate  systems  for furnishing  water:   a
potable and a nonpotable system.   The potable
system should provide drinking water only;  the
nonpotable system should  provide water for  fire
fighting purposes. There are also requirements for
toilet facilities, food handling, sleeping quarters,
washing facilities, and  shower/change rooms.
Informational and New Technology
Programs (29 CFR 1910.120(1) and (o))

      Two  additional  programs  that  must  be
developed, implemented, and included as part of
the employer's safety and health program are the
information and new technology  programs.   A
program must be developed and implemented to
inform employees of the nature, level, and degree
of  exposure  that  may occur  as  a  result  of
performing  hazardous  waste  operations.    In
developing  this  informational  program,   the
employer   should   consult  the   Hazard
Communications  Standard  (HCS)  (29  CFR
1910.1200 and 29 CFR 1926.59).  The HCS may
contain  information that would  be  useful  to
incorporate  into the informational  program  or
emergency response plan for a site.

      In addition to. developing an informational
program, the employer must include as part of the
safety  and   health  program   procedures   for
introducing new and innovative technologies into
the work area.  The  purpose of the new technology
program is  to  ensure  that new and  improved
technologies and equipment  are developed and
introduced to provide for the improved protection
of employees engaged in hazardous waste clean-up
operations.   As part  of the new  technology
program, the employer must carefully evaluate new
technologies,  equipment,  and control  measures,
such as  absorbents and neutralizers, as they  are
introduced and made available on the market. The
evaluation, which must be completed prior to using
the new technology at the site, must identify  the
effectiveness of the new equipment, method,  or
material. Any data or information obtained during
the evaluation must be  made available to OSHA
upon request.
                 PART 5:  EMPLOYEE
                 RIGHTS UNDER
                 SECTION 8 OF THE OSH
                 ACT
                 Section 8  of  the  OSH  Act,
                 Inspections, Investigations, and
Recordkeeping, gives employees certain  rights  to
inspect documents, and request and participate in
inspections.  Exhibit 7 provides a  summary of the
principle provisions of section 8 of the OSH Act.

      OSHA has authority to inspect a  site  on
their own initiative at any reasonable time.  Under
paragraph  (f)(l)  of  section  8,  however,  an
                                               12

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                 EXHIBIT 7
            Principal Provisions of
           Section 8 of the OSH Act
   Paragraph 8(c)(l):

   •  Employers are required to inform
      employees of their rights under the
      OSH Act

   Paragraph 8(c)(3):

   •  Employees are entitled access to any
      required records that indicate the
      person's exposure to toxic materials

   Paragraph 8(e):

   •  An employee and employer
      representative must be given the
      opportunity to accompany OSHA
      during any workplace inspection

   Paragraph 8(f):

   •  An employee or employee
      representative may request an OSHA
      inspection if the person believes that
      there is a violation of a safety or
      health standard that threatens physical
      harm, or that causes an imminent
      danger
employee  or employee representative also  can
request an OSHA inspection if the person making
the request believes either that there is a violation
of a  safety or health  standard  that threatens
physical harm, or  that an imminent danger exists.
The request must  be written and signed, and must
include a reasonable statement of the violation or
danger.  An employer is entitled to get a copy of
the request, but the employee can  ask OSHA not
to disclose his name.  When an employee makes a
request under this provision, OSHA must conduct
an inspection  if  they determine  that there  are
reasonable grounds to believe a violation or danger
exists. If OSHA makes a contrary determination,
the person who made the request must be  notified.

      Under paragraph (f)(2), before or during an
inspection,   an    employee  or   employee
representative has  the right to notify OSHA in
writing of any violation of the  OSH Act that the
person  has  reason  to  believe  exists in  the
workplace. If the person making the request asks,
OSHA must explain any determination not to
sanction the employer.

      If there is  an OSHA  inspection,  under
section   8(e),   an   authorized   employee
representative must  be  given the  chance  to
accompany OSHA during any inspection. If there
is  no  authorized  employee representative,  the
OSHA inspector has a further duty to consult with
a reasonable  number of employees on matters of
health and safety. Under section 8(e), employers
are also provided with the opportunity to designate
a  representative to  accompany  OSHA on  the
inspection.   An important point to remember,
however, is that  under no circumstances may the
employer designate the employee representative.

      Section 8 sets out three other important
employee   rights.    Paragraph (c)(l)  requires
employers  to post a notice or use some  other
appropriate means to inform employees of how the
OSH Act protects them, as well as  what employee
obligations are.  Further, where  the OSH Act
requires measuring  or monitoring potentially toxic
materials or harmful physical agents (e.g., Subpart
Z, 29 CFR 1910.1000), paragraph  (c)(3) gives an
employee   or  an  authorized  employee
representative the right to  observe any  such
activity, and to have  access to  the records.  This
same paragraph states that an employee or former
employee is entitled to have access  to any required
records that indicate the person's exposure to toxic
materials or  harmful physical  agents.   When  an
employee is so exposed, the employer must notify
him of an exposure above levels prescribed by an
applicable  OSHA  standard,  and  inform  the
employee of actions taken to correct the conditions
that led to the impermissible exposure.

      There are other provisions of the OSH Act
that  set forth employee  rights.   For additional
information, consult the OSH Act.  Another useful
source to consult on this subject  is  the OSHA
publication  entitled  Employee Workplace  Rights
(OSHA Publication No.  3021).  To obtain a copy
of this document,  contact OSHA's Publications
Office.  (Refer to  Exhibit 8 for the  appropriate
address and telephone number.)   When ordering
the document, be certain to specify the publication
number.
                                                13

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                 PART 6:  SOURCES OF
                 ADDITIONAL
                 INFORMATION AND
                 REFERENCE
                 MATERIALS
      Part  6  of   this   Fact   Sheet  provides
information on where you can obtain a  copy of a
generic HASP; describes  a set of Guidelines that
can help an OSC/RPM  assess  the efficacy of a
HASP;  and  provides  important addresses and
telephone numbers  for additional information  on
HAZWOPER requirements.

Generic HASPs

      ERT  has developed a computer software
package to assist field personnel in preparing a
site-specific health and safety plan, complete with
all the elements required by HAZWOPER.  You
can  obtain  a copy of  the  generic HASP  by
contacting:
   ERC - Health and Safety
   U.S. EPA/ERT
   2890 Woodbridge Avenue
   Building 18 (MS-101)
   Edison, NJ  08837-3679
   Attention: Generic HASP
      Single copies are available without charge.
Requestors must specify their  desired disk  size
(i.e., either 3 1/2 or 5 1/4 inch disk) and whether a
high density or double density disk is preferred.

Health and Safety Audit Guidelines

      ERT has developed  step-by-step guidance
for evaluating the comprehensiveness and efficacy
of the preliminary evaluation and the HASP for
activities  at uncontrolled hazardous wastes sites.
These "Health and  Safety Audit Guidelines" may
be used in conducting  a health and  safety  site
audit,  or  simply  to   assist  OSC/RPMs   in
determining whether a HASP is likely to comply
with the HAZWOPER requirements.

      A  copy of  the "Health and  Safety Audit
Guidelines"  (Publication  Number  EPA/540/G-
89/010) may  be obtained by calling  the National
Technical Information Service at (703) 487-4600.
Additional Sources of Information

      The following is a brief summary of where
to  obtain  additional   information   on   the
HAZWOPER standards. Please refer to Exhibit 8
for  the  appropriate  addresses  and  telephone
numbers of the contacts referenced below.

•     If you have questions regarding the existing
      relationship between EPA and OSHA with
      respect  to  the implementation  of  the
      standards, contact the ERT in Edison, NJ.

•     For  information about  EPA's  training
      courses, contact ERTs Operations Section
      in  Cincinnati, OH.

•     For  information and  guidance  on  the
      substance of 29 CFR 1910.120, contact  the
      appropriate OSHA Regional office.   If
      additional information is needed, contact
      the OSHA Office  of Health Compliance
      Assistance in Washington, D.C.

•     For information on how to obtain technical
      assistance   from   OSHA,   contact   the
      appropriate OSHA Regional office.  (Refer
      to  Exhibit 8 for appropriate addresses and
      telephone  numbers.)

•     There are four other HAZWOPER Fact
      Sheets that are available:

            Hazardous  Waste  Operations  and
            Emergency   Response:      General
            Information and  Comparison  (Pub.
            No. 9285.2-09FS) explains the scope
            of the HAZWOPER standards, and
            distinguishes them from regulations
            and consensus standards covering the
            same or similar subject matter;

            Hazardous  Waste  Operations  and
            Emergency Response:  RCRA TSD
            and  Emergency  Response  Without
            Regard to Location (Pub. No. 9285.2-
            07FS)   explains    the   principal
            HAZWOPER  requirements   for
            emergency response without regard
            to  location and  routine  hazardous
            waste  operations  at RCRA TSD
            facilities.
                                               14

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         Establishing   Work  Zones  at
         Uncontrolled Hazardous Waste Sites
         (Pub. No. 9285.2-06FS) describes the
         requirements  and procedures for
         establishing   support   zones  at
         uncontrolled hazardous waste sites.

         Hazardous  Waste  Operations  and
         Emergency  Response:    Available
         Guidance  (Pub.  No. 9285.2-10FS)
         describes    guidance    materials
            developed  by  the  Environmental
            Response Team  of EPA to  help
            workers engaged in hazardous waste
            operations and emergency response
            understand   the   HAZWOPER
            requirements.

      Copies  of  these  Fact  Sheets  may be
obtained by calling or writing ERT in Edison, NJ.
Please specify the title and directive number of the
Fact Sheet(s).   (Refer  to Exhibit  8 for  the
appropriate address and telephone number.)
                                       EXHIBIT 8
                     Important Telephone Numbers and Addresses
•     U.S. EPA/ERT
      2890 Woodbridge Avenue
      Building 18 (MS-101)
      Edison, NJ  08837-3679
      (908) 321-6740 or (FTS) 340-6740

•     U.S. EPA/ERT
      Operations Section
      26 West Martin Luther King
      Cincinnati, OH  45268
      (513) 569-7537 or (FTS) 684-7537

•     U.S. Department of Labor, OSHA
      Office of Health Compliance Assistance
      200 Constitution Avenue, NW
      Washington, D.C. 20210
      (202) 523-8036 or (FTS) 523-8036

•     U.S. Department of Labor, OSHA
      Publications Office
      Room N 3101
      200 Constitution Avenue, NW
      Washington, D.C. 20210
      (202) 523-9667

OSHA Regional Offices

•     U.S. Department of Labor, OSHA
      Region 1
      133 Portland Street, 1st Floor
      Boston, MA 02114
      (617) 565-7164 or (FTS) 835-7164
    U.S. Department of Labor, OSHA
    Region 2
    201 Varick Street, Room 670
    New York, NY 10014
    (212) 337-2325 or (FTS) 660-2378

    U.S. Department of Labor, OSHA
    Region 3
    Gateway Building, Suite 2100
    3535 Market Street
    Philadelphia, PA  19104
    (215) 596-1201 or (FTS) 596-1201

    U.S. Department of Labor, OSHA
    Region 4
    1375 Peachtree Street, NE, Suite 587
    Atlanta, GA 30367
    (404) 347-3573 or (FTS) 257-3573

    U.S. Department of Labor, OSHA
    Region 5
    230 South Dearborn Street
    32nd Floor, Room 3244
    Chicago, IL 60604
    (312) 353-2220 or (FTS) 353-2220

    U.S. Department of Labor, OSHA
    Region 6
    525 Griffin Street, Room 602
    Dallas, TX 75202
    (214) 767-4731 or (FTS) 729-4731

    U.S. Department of Labor, OSHA
    Region 7
    911 Walnut Street
    Kansas City, MO  64106
    (816) 426-5861 or (FTS) 867-5861
                                            15

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                                EXHIBIT 8  (continued)
                     Important Telephone Numbers and Addresses
OSHA Regional Offices (continued)

•     U.S. Department of Labor, OSHA
      Region 8
      1951 Stout Street
      Denver, CO  80204
      (303) 844-3061 or (FTS) 564-3061

•     U.S. Department of Labor, OSHA
      Region 9
      71 Stevenson Street, Suite 415
      San Francisco, CA 94105
      (415) 744-6670 or (FTS) 484-6670

•     U.S. Department of Labor, OSHA
      Region 10
      1111 Third Avenue, Suite 715
      Seattle, WA  98101-3212
      (206) 442-5930 or (FTS) 399-5930

EPA Regional Offices

•     U.S. Environmental Protection Agency
      Region 1
      John F. Kennedy Federal Building
      Room 2203
      Boston, MA  02203
      (617) 565-3715 or (FTS) 835-3715

•     U.S. Environmental Protection Agency
      Region 2
      Jacob K. Javitz Federal Building
      26 Federal Plaza
      New York, NY 10278
      (212) 264-2657 or (FTS) 264-2657

•     U.S. Environmental Protection Agency
      Region 3
      841 Chestnut Building
      Philadelphia, PA 19107
      (215) 597-9800 or (FTS) 597-9800

•     U.S. Environmental Protection Agency
      Region 4
      345 Courtland Street, NE
      Atlanta, GA  30365
      (404) 347-4727 or (FTS) 257-4727
U.S. Environmental Protection Agency
Region 5
230 South Dearborn Street
Chicago, IL  60604
(312) 353-2000 or (FTS) 353-2000

U.S. Environmental Protection Agency
Region 6
1445 Ross Avenue, 9th Floor
Dallas, TX  75202
(214) 655-6444 or (FTS) 255-6444

U.S. Environmental Protection Agency
Region 7
726 Minnesota Avenue
Kansas City, KS  66115
(913) 551-7000 or (FTS) 276-7000

U.S. Environmental Protection Agency
Region 8
999 18th Street, Suite 500
Denver, CO  80202-2405
(303) 293-1603 or (FTS) 293-1603

U.S. Environmental Protection Agency
Region 9
215 Fremont Street
San Francisco, CA 94105
(415) 556-6322 or (FTS) 556-6322

U.S. Environmental Protection Agency
Region 10
1200 6th Avenue
Seattle, WA 98101
(206) 442-1200 or (FTS) 399-1200

Call the Emergency Planning and
Community Right-to-Know Information
Hotline for the addresses and telephone
numbers of state  emergency response
commissions and  local emergency planning
committees in your area.  The telephone
numbers for the Hotline are:  toll-free
800-535-7672, or  202-475-9652 in the
Washington, D.C. area.
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