v>EPA
                  United States
                  Environmental Protection
                  Agency
                         Office of
                         Solid Waste and
                         Emergency Response
Publication 9285.2-09FS
April 1991
Hazardous  Waste Operations
and  Emergency Response:
General Information and Comparison
   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 Title I), the
               U.S. Environmental Protection
               Agency (EPA) and the U.S.
               Occupational   Safety  and
Health Administration (OSHA) issued 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 these
regulations were published on April 13, 1990 (55
FR 14072) to clarify certain medical surveillance
requirements and to identify which employers must
comply with 29 CFR 1910.120(p).   The  EPA
regulations, published on June 23, 1989 at 54 FR
26654,  incorporate the OSHA standards by
reference and are codified at 40 CFR Part 311.

      The EPA and  OSHA  worker protection
standards  for hazardous waste operations and
emergency   response   (HAZWOPER)   affect
employers whose employees are engaged in the
following activities:

      Clean-up   operations   at  uncontrolled
      hazardous waste sites when a government
      authority  requires the  cleanup (29  CFR
      Corrective actions at treatment, storage,
      and  disposal  (TSD) facilities regulated
      under  the  Resource  Conservation  and
      Recovery   Act   (RCRA)   (29   CFR
                                 Voluntary  clean-up   operations  at
                                 uncontrolled hazardous waste sites (29 CFR
                            •    Hazardous waste operations conducted at
                                 RCRA  TSD  facilities   (29   CFR
                                 1910.120(a)(iv)); and

                            •    Emergency  response operations  without
                                 regard to location, where  there  is  the
                                 release or a substantial threat of release of
                                 a  hazardous  substance  (29   CFR
                                 1910.120(a)(v)).

                                 The purpose of this Fact Sheet is to explain
                            the scope and purpose of the worker protection
                            standards issued under  SARA Title I, and to
                            distinguish these standards from other regulations
                            and  consensus  standards  covering the same or
                            similar subject  matter.  This Fact Sheet is also
                            designed  to  facilitate  compliance  with  the
                            HAZWOPER requirements by helping employers
                            and  other interested readers to understand their
                            special  responsibilities   under   these  worker
                            protection  standards.  For a summary  of  the
                            HAZWOPER requirements, refer to Exhibit 1.

                                 This Fact Sheet is divided into five sections.
                            Section one gives a brief legislative history of the
                            EPA and OSHA worker protection standards for
                            hazardous   waste  operations  and  emergency
                            response, and explains the responsibilities of these
                            two  agencies  in  implementing   the standards^
                            Sections two, three, and four compare the 1910.120
                            standards with other programs governing the same
                            kinds of activities.  Finally, section five explains
                            how to obtain the publications discussed in  this
                            Fact Sheet.
                                                                           Printed on Recycled Paper

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                  EXHIBIT 1
       The Worker Protection  Standards
      for Hazardous Waste Operations and
             Emergency Response
              (29 CFR 1910.120)
   (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.

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

   (m) Illumination.

   (n)  Sanitation at temporary workplaces.

   (o)  New technology programs.

   (p)  Certain operations conducted under the
       Resource Conservation and Recovery Act of
       1976.

   (q)  Emergency response to hazardous substance
       releases by employees not previously covered.
                  Overview of EPA and
                  OSHA Worker
                  Protection Authority

                  The  Occupational Safety and
                  Health   Act   of   1970,   as
amended, (OSH Act) established health and safety
standards for the  American workplace.  Section 6
of the  OSH Act established Federal authority to
issue  general  health  and  safety standards  for
private industry; section 19 addresses standards for
Federal  government  employees.    Under  the
authority of section 6  of the  OSH Act, OSHA
promulgated  general  industry  standards   and
standards that apply specifically to the construction
industry; these standards are codified at 29 CFR
1910 and 1926, respectively.  These standards set
forth the minimum health and safety requirements
necessary to ensure protection for all private sector
employees in the United States. The scope of the
coverage of the standards set forth in 29 CFR 1910
and 1926 changed dramatically on February 26,
1980,   when  President Jimmy   Carter  signed
Executive Order  12196,  requiring the  Federal
government  to comply  with  the more stringent
general industry standards issued under section 6
of the  OSH Act.

       SARA section 126(a) requires the Secretary
of Labor to issue health and safety standards under
section 6 of the OSH Act for the benefit of private
sector  employees  -- and  through  the  Executive
Order, Federal employees - engaged in hazardous
waste operations and emergency response.  Federal
OSHA has  no authority to  enforce regulations
protecting state and local government employees.

       Under section 18 of the OSH  Act, a state
may elect  to  develop  and  implement its  own
occupational safety and  health program if: (1) the
state is willing to document its program in a state
plan, and (2) the state's requirements are at least
as stringent  as the Federal regulations.   Before a
state  program can  become  effective,  however,
OSHA must review and approve the state plan.
Through its  review and approval authority, OSHA
requires states to  extend occupational safety  and
health protection to state  and local  government
employees, as well as to private sector employees,
within the state's jurisdiction.  Currently, there are
23 states and two territories with delegated OSHA
programs. These state plans  must be amended to
incorporate  the newly promulgated standards in 29
CFR 1910.120, to address the safety and health of
employees engaged in hazardous waste operations
and emergency response.

       SARA section  126(f)  requires  the EPA
Administrator  to  issue standards  for  hazardous
waste operations and emergency response that are
identical to OSHA's  standards. Although the two
sets  of  standards contain  identical  substantive
provisions,  EPA  and  OSHA address  different
audiences.   EPA's authority  extends to state  and
local government employers conducting hazardous
waste operations and emergency response in states

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that  do not have in effect a  delegated OSHA
program.  Currently, 27 states,  one territory, and
the  District  of  Columbia  fall  under  EPA's
authority.    The  EPA  regulations cover both
compensated and uncompensated state and local
government employees engaged in the  covered
activities.  Therefore, the EPA standards protect
volunteers, such as volunteer fire fighters who are
responding to  hazardous substance emergencies.
Although   Federal   OSHA  recommends  that
delegated  state   programs    also   cover
uncompensated employees, not all states have
followed this recommendation.

       In summary, in states without an  OSHA-
approved plan, Federal OSHA standards protect
all private sector and Federal employees engaged
in hazardous  waste  operations and emergency
response;  the  EPA worker protection standards
protect all state and local government employees,
including volunteer  workers.   In  states  with an
OSHA-approved plan, the state program covers all
private sector employees, as well as state and local
government employees; Federal  OSHA covers
Federal employees in those states.  The shaded
area in Exhibit 2 shows jurisdictions without an
OSHA-delegated program.
Inter-Agency Agreement

      EPA  and OSHA  have  an agreement  to
share responsibility for implementing the Title I
worker protection standards. Under the terms of
this  agreement,  OSHA performs the following
activities:

•     Support of the National Response Team and
      Regional Response Teams.

•     Technical Assistance.   OSHA advises EPA
      on the types of actions EPA should take at
      uncontrolled  hazardous  waste  sites   to
      ensure  full   compliance   with  the
      HAZWOPER requirements. As an advisor,
      OSHA will identify problems that EPA may
      face and suggest appropriate solutions.

•     Compliance  Activities.   OSHA  conducts
      inspections and takes enforcement  actions
      to  ensure compliance with  the  worker
      protection standards at Superfund sites.

•     Implementation Activities.  OSHA supports
      EPA  in conducting workshops to explain
      the requirements  of the  standards,  and
      provides  official  interpretations  of the
      health and safety requirements.
                                           EXHIBIT 2
                       Shaded States Do Not Have Delegated OSHA Programs

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   If you have questions on the substance of
   the  worker   protection   standards  for
   hazardous waste operations and emergency
   response, contact an OSHA Regional Office
   or OSHA's Office of Health  Compliance
   Assistance in  Washington, D.C.  Refer to
   Exhibit  4  for  relevant  addresses  and
   telephone numbers.
       The next three sections of this Fact Sheet
compare OSHA's health and safety standards for
hazardous  waste  operations   and  emergency
response   with   several  related   regulations,
standards,  and guidelines  developed  by  OSHA,
EPA, and the National Fire Protection Association
(NFPA).   Be aware  that  in the context of this
discussion,  we   will  talk  about   "hazardous
substances,"  "extremely hazardous   substances"
(EHSs), "hazardous materials," "hazardous wastes,"
and "highly hazardous chemicals."  Each of these
terms  means  something  different,  and   the
regulatory  programs   that  employ  them   are
intended to prevent or mitigate the effects from
exposure to a distinct set of hazardous chemicals.
                 Comparing Regulatory
                 Requirements Under
                 SARA Title I, SARA
                 Title HI, and OSHA's
                 Proposed Rule on Highly
                 Hazardous Chemicals
SARA Title I
      Under the authority of Title I, section 126
of  SARA,  EPA  published worker  protection
standards  for  hazardous  waste operations  and
emergency  response   (HAZWOPER).
HAZWOPER specifies certain  health and safety
requirements  to   ensure  the  protection  of
employees engaged in hazardous waste operations
and  emergency response  during  five specified
activities  (see  page  1  of this  Fact  Sheet).
HAZWOPER   does  not  address   emergency
responders who engage only in handling traditional
fire  and  medical   emergencies;  other  OSHA
programs protect these employees. HAZWOPER,
however, requires that an employer provide, among
other things, proper emergency response planning,
training,  and  medical surveillance.   Affected
workers must  be protected during  the  entire
remedial process, from the preliminary evaluation
and initial site entry to final closure of the site.

      Emergency Response Planning. An employer
must  develop an  emergency  response  plan to
protect workers in an emergency resulting from the
release  of all  kinds  of hazardous  substances,
including EHSs,  CERCLA hazardous substances,
RCRA hazardous wastes, and any substance listed
by  the U.S. Department of Transportation as a
hazardous material.

      Training.  An employer also must ensure
that workers receive the  kind of training specified
in the regulation.  The standard reflects a tiered
approach to training, linking the amount and type
of training to an employee's potential for exposure
to  hazardous  substances  and to  other health
hazards during a  hazardous waste operation or an
emergency  response.   The greater  the potential
hazard, the more extensive and stringent are the
training requirements.
      Medical   Surveillance.
HAZWOPER
establishes a framework for a medical monitoring
program for certain workers engaged in hazardous
waste operations and emergency response.  The
medical  surveillance   requirements   include
provisions for a baseline, periodic, and termination
medical  examination  for  specific  groups  of
employees.    HAZWOPER  also requires  that
employees 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 develop signs or symptoms that
indicate a possible overexposure to  hazardous
substances.  Although an attending physician may
determine the content  of medical  examinations
required under the standard, the examination must
address key elements related to handling hazardous
substances.

SARA Title III

      SARA Title III, or the Emergency Planning
and  Community Right-to-Know Act, is a  law
enacted to improve state  and  local government
capacity to respond to an emergency caused by an
accidental release of an EHS; and to disseminate
information to the public on dangerous chemicals
made, used, or stored in their community.

      Think of this law as having four main parts.
The first part, sections 302 and 303, requires  each
state  to  create  a  State  Emergency  Response

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Commission (SERC).  In turn, these SERCs must
create  Local  Emergency  Planning Committees
(LEPCs)  that  correspond to  local  emergency
planning districts.   LEPCs develop and update
emergency response plans  for accidents involving
EHSs;  and receive, manage,  and provide  public
access  to information  about  toxic  and  other
hazardous substances in  the district.  SERCs
review emergency  response plans, and generally
supervise and coordinate LEPC activities.

      The second part of SARA Title III (section
304)  sets  out  emergency  release   reporting
requirements.   Under this part of the law, the
owner or operator of a facility from which an EHS
or CERCLA hazardous substance is released at or
above  a reportable quantity (RQ) must  notify
SERCs  and LEPCs  in  the affected  area  by
telephone.  There must be a written  follow-up
report  to  this immediate notification.  Both the
initial and follow-up reports must give details on
known  or anticipated  health  risks  and  advice
regarding  medical attention.

      The third part of SARA Title III (sections
311 and 312) gives people  the right to know what
substances are being made, used, or stored in their
communities. The OSHA Hazard Communication
Standard (HCS) requires owners and operators to
keep "material safety data sheets" (or MSDSs) with
information  about the health hazards of chemicals
at the facility, and to make these MSDSs available
to their employees. SARA Title III piggy-backs on
the MSDS  requirements  in  the HCS.   Under
SARA Title III, the owner or operator also must
send copies  of MSDSs, or lists of chemicals with
MSDSs, to SERCs, LEPCs, and fire departments.
LEPCs, in turn, make this information available to
the public during normal business hours.

      The final part of SARA Title III (section
313) requires certain owners and operators to
report toxic substances released  from their facility
- whether the release is routine  or accidental; and
to  report toxic  substances  they transport  to
another site  as waste.

      Of these four  parts, the  one  that most
closely  parallels  the  SARA  Title  I worker
protection standards  is the  part dealing with
emergency response planning (section 303).  There
are nine emergency response planning elements in
section 303  of SARA Title III.  Although these
planning elements do not correspond point-for-
point with  the emergency  response  planning
elements in the worker protection standards issued
under SARA Title I, each program covers similar
subjects.   Title  I  (HAZWOPER) and Title III
emergency response planning elements both:

•     Highlight the need for planning before there
      is an emergency;

•     Require planners to identify  emergency
      response   decision-makers   and    other
      personnel;

•     Require planners to develop guidelines for
      recognizing and evaluating releases;

•     Require evacuation planning;

•     Require that the emergency response plan
      set out an  orderly sequence of steps to
      follow in an emergency;

•     Direct planners to specify equipment that
      may be needed for various levels and types
      of emergencies; and

•     Require testing the  plan  and providing
      appropriate   training   for  emergency
      responders.

      On  the  other  hand,  there  are   some
important  differences  in  emergency  response
planning requirements under Title I and Title III.
For example, a Title I plan must address a number
of chemical hazards, while a Title  III plan must
cover only those emergencies arising from the
release of an  EHS.  Further,  a  plan  to protect
employees under Title I may  require far  more
specificity than a Title III plan.  Although a Title
III  plan  may be  too  general  for  use   as an
employer's Title I  plan, the  Title I plan  may
reference  the  Title  III plan  to  avoid  any
unnecessary duplication of information.  If a Title
III plan is referenced,  a copy  of the  referenced
document must be  kept with the Title I plan.

      The most important thing to remember in
distinguishing  Title  I  and  Title  III emergency
response  planning  is that Title I plans focus on
worker safety;  Title III plans focus on community
safety.  The similarities and differences between
the Title  I  and Title  III  emergency response
planning  requirements  are  addressed  in greater
detail in a paper entitled "SARA Title I/Title III
Emergency Response Planning Requirements." To
obtain  a  copy of  this  document, contact the
Environmental Response Team (ERT) of EPA in

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Edison, New Jersey.  (Refer to Exhibit 4 for the
appropriate address and telephone number.)

OSHA's Highly Hazardous Chemicals NPRM

      On July 17,1990, OSHA published a Notice
of Proposed Rulemaking (NPRM),  proposing a
new  regulation  entitled   "Process   Safety
Management of Highly Hazardous Chemicals'1 (55
FR 29150).  The NPRM proposes requirements
that will  eliminate  or  mitigate  the harm to
employees as a  consequence of chemical releases
during the manufacturing or processing of highly
hazardous chemicals.   OSHA's proposed  rule
emphasizes management of hazards associated with
highly hazardous chemicals, and defines a "highly
hazardous chemical" as:

      A  substance possessing toxic,  flammable,
      reactive, or explosive properties.

      The NPRM identifies 140 highly hazardous
chemicals and proposes  threshold quantities for
each  of  the listed chemicals.   The proposed
requirements are similar to the worker protection
standards issued under SARA Title I and the self-
implementing provisions of SARA Title III in that
each of these programs contains requirements for
emergency   response  planning  and  employee
training.

      The  NPRM  requires  an  employer to
establish and implement an emergency action plan
under 29 CFR  1910.38(a). An emergency action
plan  must  include an evacuation  plan through
which an employer identifies persons responsible
for an orderly  exit and  work area check in the
event of an emergency; and directs employees to
leave an  emergency incident site, maintain a safe
distance,  and  call  an  appropriate emergency
response organization. However, if an employer's
highly hazardous chemical operation falls within
one of the activities covered by HAZWOPER, the
emergency response planning elements of 1910.120
apply. (Under HAZWOPER, an employer also
may prepare a 1910.38(a) plan if the employer
does  not allow  employees   to  respond  to an
emergency.  If employees are allowed to respond,
however, a more detailed emergency response plan
is required.)   Title I, Title  III,  and the  Highly
Hazardous Chemicals NPRM also require training
for workers  commensurate with  their assigned
duties.
                 Comparing General
                 Requirements Under 29
                 CFR Parts 1910 and
                 1926 with the Particular
                 Requirements of 29 CFR
                 1910.120
      The  occupational  safety   and   health
standards published in 29 CFR set out minimum
requirements to ensure protection for all private
sector  employees  in  the United  States.   The
general industry standards contained in Part 1910
of Title 29 were  derived largely from standards
developed by industry consensus organizations and
non-OSHA Federal safety and health standards.
The 1910 requirements  reflect practices  already
recognized in most industrial sectors before there
was   an  Occupational   Safety   and   Health
Administration. Part 1910, however, makes those
practices mandatory.

      Many of the Part 1910 standards  set out
generic specifications for  worker tools, tolerances
and   specifications  for   industrial   structures,
requirements for installing equipment that make
the workplace safer (e.g.,  sprinkler systems), rules
for providing medical attention, and other general
health and safety practices applicable to all types
of employment.    Other  sections in  Part 1910,
however, are specific to  an identified activity or
industry; HAZWOPER is an example of the latter
type of standard.

      Section 1910.120 (HAZWOPER) contains
specific requirements to minimize the health and
safety   hazards   associated   with   conducting
hazardous  waste  operations  and   emergency
response at uncontrolled hazardous waste sites and
RCRA TSD facilities, and performing emergency
response operations without regard for location.
In some instances, 1910.120 incorporates general
worker protection provisions by reference.  For
example, 1910.120(g), Engineering  controls, work
practices,  and personal protective equipment for
employee protection, requires employers engaged in
hazardous  waste  operations  and   emergency
response  to  follow  the provisions   in  1910.94
through 1910.100  in setting up controls to protect
employees from exposure to hazardous substances
and safety and health hazards. Those referenced
sections  may apply  to  other  industries  and
activities as well, but HAZWOPER applies only to
hazardous  waste   operations  and   emergency

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response   during   the  covered  activities  and
locations.
   If ever  there  appears to  be a  conflict
   between the general industry standards in
   1910  or 1926 and   HAZWOPER,  the
   HAZWOPER requirements take precedent
   during the covered activities.
       In addition  to the requirements set forth
 under Part 1910, OSHA codified regulations in 29
 CFR 1926  Subpart C  that set forth  safety and
 health  standards  specifically applicable  to the
 construction  industry.    Part  1926  Subpart  C
 includes safety  standards for worker  tools, and
 other standards relevant to health and safety in the
 construction environment (e.g., 29 CFR  1926.21
 addresses programs for  the education and training
 of employees and employers).

       Parts 1910 and 1926 both require employers
 to provide  whatever training  and education  is
 appropriate for employees to perform a given task
 safely.  Appendix B in  EPA's  Health  and Safety
 Audit Guidelines  briefly summarizes the OSHA
 standards in  1910 and 1926 that  may be most
 applicable  to hazardous  waste  site  activities;
 Exhibit 3 presents a list of these OSHA standards.
 For additional information on the standards listed
 in Exhibit 3 or on other OSHA standards, contact
 your  local  OSHA Regional Office.   (Refer to
 Exhibit 4 for relevant  addresses and telephone
 numbers.)
                  Comparing the Section
                  1910.120 Standards and
                  the NFPA's Hazardous
                  Materials Incidents
                  Publications
       Private  organizations sometimes  publish
consensus  documents  addressing  subject matter
covered in Federal regulations.  The National Fire
Protection Association (NFPA) has published two
highly relevant documents: Recommended Practice
for Responding to Hazardous Materials Incidents
(NFPA  471),  and  Standard  for  Professional
Competence of Responders to Hazardous Materials
Incidents (NFPA 472).  The  NFPA standards are
not Federal regulations.
                EXHIBIT 3
       Other Potentially Applicable
             OSHA Standards
          (by section in 29 CFR)
   1910.20   Access to Employee Exposure and
             Medical Records
   1910.24   Fixed Industrial Stairs
   1910.27   Fixed Ladders
   1910.28   Safety Requirements for Scaffolding
   1910.38   Employee Emergency Plans and
             Fire Prevention Plans
   1910.57   Ventilation
   1910.95   Occupational Noise Exposure
   1910.101   Compressed Gases
   1910.133   Eye and Face Protection
   1910.134   Respiratory Protection
   1910.135   Occupational Head Protection
   1910.136   Occupational Foot Protection
   1910.141   Sanitation
   1910.151   Medical Services and First Aid
   1910.165   Employee Alarm Systems
   1910.181   Derricks
   1910.252   Welding, Cutting and Brazing
   1910.307   Hazardous Locations
   1910.1000  Toxic and Hazardous Substances
   1910.1200  Hazard Communication
   1926.20   General Safety and Health
             Provisions
   1926.21   Safety Training and Education
   1926.56   Illumination
   1926.59   Hazard Communication
   1926.151   Fire Prevention
   1926.152   Flammable and Combustible
             Liquids
   1926.200   Accident Prevention Signs  and Tags
   1926.301   Hand Tools
   1926.651   Specific Excavation Requirements
   1926.652   Trenching Requirements
      NFPA 471 offers guidance in identifying the
minimum competencies a responsible authority
should attain before responding to a hazardous
materials   incident,   and   specifies   operating
guidelines for  a response.   Like HAZWOPER,
NFPA 471 covers, among other things, planning
for  an  emergency  response,  ensuring   that
responders have the proper equipment at their
disposal, and conducting an emergency response.

      NFPA 472  is a competency standard for
workers  who  respond  to hazardous materials
incidents. NFPA 472 training criteria differ from
the 1910.120 standards in that  the former do not

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establish specific hourly training requirements for
emergency  response  personnel.   There  is  no
Incident Commander category in NFPA 472, but
an Appendix to the standard does identify the role
of an Incident  Commander.

      Indeed,   the   NFPA   publications   on
hazardous materials incident response are similar
in  approach  and  breadth   of  coverage  to
HAZWOPER.     In  many  instances,   NFPA
references  the Federal  standards.   You  must
remember,  however,  that although  the  NFPA
documents  provide useful guidance to emergency
response planners and responders, only the EPA
and  OSHA standards  are  mandatory Federal
standards.  If  your organization falls within the
scope of 29  CFR 1910.120,  you must comply.
Therefore,  in  any conflict  between  the . NFPA
Standard/Practice and the Title I worker protection
standards, the  Federal standards govern.
                 Where to
                 Information and
                 Publications

                 You can get any volume of the
                 CFR by contacting the  U.S.
Government Printing Office (GPO) or any Federal
Depository Library in your state. To contact GPO,
call or write:

       Superintendent of Documents
       Government Printing Office (GPO)
       Washington, D.C. 20402
       (202) 783-3238

       Many state college and university libraries
are also Federal Depository Libraries.   For a
complete list of these  libraries, ask GPO for A
Directory of U.S. Government Libraries.

       OSHA offers a  catalogue listing Agency-
issued publications and audiovisual aids that help
employers  and  other  interested  persons  to
understand both the scope of OSHA regulations,
and specific substantive provisions in health and
safety standards. You  can obtain a  free  copy of
the catalogue, OSHA Publications and Audiovisual
Programs,  by sending  your request  with a  self-
addressed mailing label to:

       U.S. Department of Labor, OSHA
       Publications Office,  Room N3101
       200 Constitution Avenue, NW
       Washington, D.C. 20210
      To get a  copy of the NFPA publications
discussed in this Fact Sheet, or to obtain additional
information on the substance of the publications,
write:

  National Fire Protection Association (NFPA)
             1 Batterymarch Park
                P.O. Box 9101
           Quincy, MA 02269-9904

      For additional  information on the SARA
Title  III  requirements,  contact  the  Emergency
Planning and Community-Right-to-Know Hotline.
The telephone numbers for the Hotline are: toll-
free   800-535-7672,  or  202-475-9652  in  the
Washington, D.C. area.

      Currently, there are four other Fact Sheets
that  are  available  on  the worker  protection
standards  for  hazardous waste  operations  and
emergency response:

            Hazardous  Waste  Operations  and
            Emergency Response:  Uncontrolled
            Hazardous  Waste  Sites and  RCRA
            Corrective Action (Pub. No. 9285.2-
            08FS)   explains   the   specific
            requirements   for  hazardous  waste
            operations conducted at uncontrolled
            hazardous  waste  sites,   including
            corrective actions  at  RCRA  TSD
            facilities.

            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:  RCRA TSD
            and  Emergency  Response  Without
            Regard to Location (Pub. No. 9285.2-
            07FS)    describes   the   principal
            requirements  of the  standards for
            hazardous waste operations at RCRA
            TSD   facilities   and  emergency
            response operations without  regard
            to location.

            Hazardous  Waste  Operations  and
            Emergency  Response:     Available
            Guidance (Pub. No.  9285.2-10FS)
            describes   guidance    materials

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         developed  by the  Environmental
         Response Team 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 the Environmental
Response Team of EPA in Edison, New Jersey.
(Refer to Exhibit 4 for the appropriate address and
telephone numbers.)   Please specify the title and
publication number of the Fact Sheet(s).
                                      EXHIBIT 4
                    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. Department of Labor, OSHA
      Office of Health Compliance Assistance
      200 Constitution Avenue, NW
      Washington, D.C. 20210
      (202) 523-8036 or (FTS) 523-8036

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

    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

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                                EXHIBIT 4 (continued)
                     Important Telephone Numbers and Addresses
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.
                                            10

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