United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9285.2-10FS
April 1991
&EPA
Hazardous Waste Operations
and Emergency Response:
Available Guidance
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
INTRODUCTION
The U.S. Environmental Protection
Agency (EPA) and the U.S.
Occupational Safety and Health
Administration (OSHA) have issued
identical health and safety standards
to protect workers engaged in hazardous waste operations .
and emergency response (HAZWOPER). The EPA
regulations are codified at 40 CFR Part 311 (54 FR
6654). The OSHA regulations are codified at 29 CFR
1910.120 (54 FR 9294 and 55 FR 14072).
The Environmental Response Team (ERT) at
EPA developed this Fact Sheet to alert interested parties
to the availability of guidance materials that will help
employers, employees, On-Scene Coordinators (OSCs),
and Remedial Project Managers (RPMs) to better
understand and comply with the new HAZWOPER
standards. This Fact Sheet is organized into four
sections, representing the four distinct formats used to
present information about the new requirements: (1)
Software; (2) HAZWOPER Fact Sheets; (3) Guidance
Documents; and (4) Training. Exhibit 1 presents at a
glance the various guidance that is described in this Fact
Sheet.
COMPUTER SOFTWARE
Two major ERT software systems are
currently available for HAZWOPER.
The topics addressed by these systems
are discussed below and are listed in
Exhibit 2.
Health and Safety Planner (U.S. EPA, 1990)
The Health and Safety Planner (HASP) — often
called the generic health and safety plan — is a menu-
driven computerized software system designed to assist
health and safety officers in designing, implementing, and
updating a site health and safety plan. HASP contains
several valuable data bases that include information on
chemical hazards associated with many of the chemicals
typically found at an uncontrolled hazardous waste site.
HASP allows the user to retrieve data on chemical
hazards, suggests appropriate monitoring devices,
identifies likely routes of exposure, and recommends
levels of personal protective equipment based on those
hazards and the tasks that will be performed at the site.
HASP also includes standard protocols for typical
assessment and remediation activities. Finally, HASP
uses standard text components to actually produce a site-
specific health and safety plan, addressing the potential
hazards identified for the site. The health and safety plan
format generated by HASP is consistent with OSHA's 29
CFR 1910.120 requirements. HASP is available on either
3^2" or 5!/4" diskettes, for either double density or high
density disk drives; it runs on most IBM-compatible
personal computers, and it comes with a User's Guide
(OSWER Directive 9285.8-01).
Field Certification Tracking System (U.S. EPA, 1989)
The Field Certification Tracking System (FCTS)
is a computerized software system that simplifies the
recordkeeping associated with the health and(safety
requirements under HAZWOPER. The system creates
personnel files, updates the personnel files, and produces
personnel reports. FCTS is essentially a tracking system;
it cannot be used to identify training and medical
monitoring requirements, but rather allows the user to
specify the requirements and to track the employee's
fulfillment of those requirements. Employees working at
a location, for example, may be grouped into categories,
such as HAZMAT Team Member, routine site worker, or
first responder, and then training and medical monitoring
requirements for each worker or each category of workers
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EXHIBIT 1
Available Guidance
Computer Software
Health and Safety Planner (HASP)
Field Certification Tracking System (FCTS)
HAZWOPER Fact Sheets
Hazardous Waste Operations and Emergency Response:
General Information and Comparison
Hazardous Waste Operations and Emergency Response:
Uncontrolled Hazardous Waste Sites and RCRA
Corrective Action
Hazardous Waste Operations and Emergency Response:
RCRA TSD and Emergency Response Without Regard to
Location
Establishing Work Zones at Uncontrolled Hazardous
Waste Sites
Guidance Documents
Hazmat Team Planning Guidance
Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel
Health and Safety Audit Guidelines
Standard Operating Safety Guides
Field Standard Operating Procedures
Training
Hazardous Materials Incident Response Training Program
Course Schedule
EXHIBIT 2
Computer Software
Health and Safety Planner
Identification of chemical hazards
Selection of monitoring devices
Identification of likely routes of exposure
Selection of personal protective equipment
Fieid Certification Tracking System
Simplification of rccordkeeping for field personnel
Creation of personnel files for health and safety
requirements
Updating of personnel files
must be input into the FCTS system. The training and
medical monitoring requirements entered for each
employee may be more or less stringent than those
specified in 29 CFR 1910.120. Thus, although all affected
employees must comply with the training and medical
monitoring requirements in 29 CFR 1910.120, FCTS
provides the user with flexibility regarding the elements
thai will be tracked. Once a personnel file is created, the
system can be used to list the required training for an
employee's category, update an employee's file to reflect
newly acquired training, and target personnel files to
identify employees who are overdue for a particular type
of training. FCTS is available on either 3!/2" or 51A"
diskettes, for either double density or high density disk
drives; it runs on most IBM-compatible personal
computers, and it comes with a User's Guide (OSWER
Directive 9285.3-03).
HAZWOPER FACT SHEETS
Currently, there are four available
ERT Fact Sheets (in addition to this
one) that provide guidance on the
HAZWOPER requirements. The
topics addressed by these Fact Sheets
are discussed below and are presented in Exhibit 3.
Hazardous Waste Operations and Emergency Response:
General Information and Comparison (U.S. EPA, 1991,
Pub. No. 9285.2-09FS)
This Fact Sheet explains the scope and purpose
of the HAZWOPER standards, and distinguishes the
Title I standards from regulations and consensus
standards covering the same or similar subject matter.
Specifically, this Fact Sheet provides a brief legislative
history of HAZWOPER, and compares it with other
programs governing the same kinds of activities, such as
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EXHIBIT 3
HAZWOPER Fact Sheets
General Information and
Comparison
Overview of EPA and OSHA Authority
Comparing Regulatory Requirements
Comparing General Requirements
NFPA's Hazardous Materials Incidents Publications
Sources of Additional Information
Uncontrolled Hazardous Waste Sites
and RCRA Corrective Action
Planning Requirements
Training Requirements
Medical Surveillance Requirements
Other Requirements
Employee Rights
Sources of Additional Information
RCRA TSD and Emergency
Response Without Regard to Location
Requirements for Planning, Training, and Medical
Surveillance for Emergency Response Without
Regard to Location
Requirements for Planning, Training, and Medical
Surveillance at RCRA TSD Facilities
Sources of Additional Information
Establishing Work Zones at Uncontrolled
Hazardous Waste Sites
Definitions of Work Zones
Data Collection Requirements
Selection of Work Zones
Ensuring Integrity of Work Zones
Consultation and References
SARA Title III and OSHA's proposed rule on highly
hazardous substances. This Fact Sheet also discusses how
the HAZWOPER requirements relate to the industry-
specific standards at 29 CFR 1910 and the standards
applicable to the construction industry at 29 CFR 1926.
Finally, this Fact Sheet describes relevant National Fire
Protection Association (NFPA) publications and their
relationship to HAZWOPER.
Hazardous Waste Operations and Emergency Response:
Uncontrolled Hazardous Waste Sites and RCRA Corrective
Action (U.S. EPA, 1991, Pub. No. 9285.2-08FS)
This Fact Sheet explains the principle
HAZWOPER requirements as they 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. Specifically, this Fact Sheet describes the
relevant planning, training, and medical surveillance
requirements in HAZWOPER, including the site control
and decontamination programs, the emergency response
plan, the spill containment program, and the specific
responsibilities of the OSC/RPM and ERT. Other
requirements, such as the procedures for handling drums
and containers, illumination and sanitation requirements,
and the informational and new technology programs also
are addressed. Finally, this Fact Sheet discusses
employee rights under section 8 of the Occupational
Safety and Health Act of 1970, as amended (OSH Act).
Hazardous Waste Operations and Emergency Response:
RCRA TSD and Emergency Response Without Regard to
Location (U.S. EPA, 1991, Pub. No. 9285.2-07FS)
This Fact Sheet describes the planning, training,
and medical surveillance requirements in HAZWOPER
as they apply to emergency responders regardless of
location, and employees who perform routine hazardous
waste operations at RCRA TSD facilities. The Fact
Sheet explains the applicable HAZWOPER planning and
medical monitoring requirements, as well as the five
specific levels of training required for responders to
emergencies that could occur at any location.
Establishing Work Zones at Uncontrolled Hazardous Waste
Sites (U.S. EPA, 1991, Pub. No. 9285.2-06FS)
This Fact Sheet summarizes the requirements
and procedures for establishing and maintaining Support
Zones (i.e., Clean Zones) at hazardous waste sites. The
Fact Sheet defines the different work zones usually found
at a hazardous waste site (i.e., Exclusion, Contamination
Reduction, and Support), describes data collection and
site characterization requirements for establishing a
Support Zone (both prior to and during initial site
entry), provides information on selecting and maintaining
work zones (i.e., data compilation and evaluation), and
provides information on maintaining the work zones (i.e.,
use of site controls, periodic monitoring of the support
zone, and other considerations). This Fact Sheet also
references a number of technical guidance documents
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that address some of the activities that are conducted in
establishing work zones (e.g., air monitoring).
GUIDANCE DOCUMENTS
Five major ERT guidance documents
are currently available for
HAZWOPER. The topics addressed
by these documents are discussed
briefly below and are presented in
Exhibit 4.
Hazmat Team Planning Guidance (U.S. EPA, 1990, Pub.
No. EPA/540/G-90/003)
The Hazmat Team Planning Guidance document
assists local fire departments and other response
organizations in establishing a HAZMAT Team. The
document identifies necessary equipment and suggests
ways to acquire and maintain the equipment and to train
personnel for the HAZMAT Team. The document offers
guidance in determining actual HAZMAT response
requirements, establishing the goals and levels of
expertise needed to meet those requirements, and
estimating the costs of meeting those goals. The
document also provides assistance in preparing response
plans and standard operating procedures (SOPs). The
Appendices to the document provide a summary of how
to begin the hazards analysis process and how to design
a medical program. The Appendices also contain a list
of EPA Regional Superfund training contacts and
selected guidance and reference documents.
Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel (U.S. EPA,
1990, Pub. No. OSWER Directive 9285.3-04)
This summary document provides guidelines
covering the requirements for a comprehensive
occupational medical monitoring program for personnel
involved in hazardous waste field activities. This
document outlines general medical monitoring
requirements such as the type of physician who must
perform or supervise examinations, and the procedures
required of the personnel who must undergo the
monitoring. The four types of examinations — baseline,
periodic, unscheduled, and termination — are described,
as well as reporting requirements, special requirements
(i.e., immunizations, research tests, and reproductive
hazards), and the relationship between occupational
medical monitoring and workers' compensation. The
Appendices to the document address the minimum
examination types and content, and provide guidelines for
immunization requirements. References arealso provided.
EPA Health and Safety Audit Guidelines (U.S. EPA, 1989,
Pub. No. EPA/540/G-89/010)
These Guidelines provide a representative sample
of the HAZWOPER requirements at different stages of
cleanup at an uncontrolled hazardous waste site, as well
as during emergency response operations that occur
without regard to location. It is in a workbook format
that provides the user with space for notes regarding the
comprehensiveness and efficacy of the written site-specific
health and safety plan, as well as the health and safety
measures being implemented in the field and during off-
site emergency response operations. The Guidelines may
be used to assist an auditor or site supervisor in
obtaining a sense of the likely level of compliance with
the HAZWOPER requirements; they, however, are not
meant to be a comprehensive compilation of all
requirements. If compliance with the specific elements in
a subsection of these guidelines is excellent, then it is
likely that all requirements under that subsection have
been met. If, on the other hand, compliance is sketchy or
weak, it is advisable to pursue additional questions and to
further investigate compliance with that subsection. The
EPA Audit Guidelines are in a simple, easy to follow,
question and answer format. The Appendices to the
document provide an incident safety check-off list, a
description of levels of personnel protection, and a log
and summary form for occupational injuries and illnesses. |
Standard Operating Safety Guides (U.S. EPA, 1988,
OSWER Directive 9285.1-OIC)
The Standard Operating Safety Guides (SOSG)
provide guidelines for use by any organization in
developing its own specific operation safety procedures.
These Guides should be adapted to address the safely
criteria required for protection of response personnel
from the hazards created by a specific operation or
incident. This document is not meant to be a
comprehensive safety manual, but rather it provides
technical information that should be considered in
developing instructions on how to accomplish specific
hazardous waste operations in a safe manner.
Field Standard Operating Procedures (FSOPs)
EPA has published a series of FSOPs that
provides procedures to minimize the risk of exposure to
hazardous substances. These procedures were derived
from early drafts of EPA's Standard Operating Safety
Guides and are presented in a format that is more
appropriate for use in the field. Five of the most
relevant FSOPs are described below.
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EXHIBIT 4
Guidance Documents
Hazmat Team Planning Guidance
Do you need a hazmat team?
Training and equipping your hazmat team
Preparing response plans and standard operating
procedures
Health and Safety Audit Guidelines
Preliminary evaluation
Written health and safety plan review
Health and safety field review
Off-site emergency response review
Occupational Medical Monitoring Program
Guidelines for SARA Hazardous Waste
Field Activity Personnel
General requirements
Baseline examination
Periodic examination
Unscheduled examination
Termination examination
Reporting requirements
Special requirements
Relationship between occupational medical monitoring
and workers' compensation
Minimum examination types and requirements
Guidelines for immunization requirements
Standard Operating Safety Guides
Environmental incidents
Standard operating procedures
Health and safety requirements
Site safety plan
Initial site survey and reconnaissance
Levels of personal protective equipment
Effects of stress
Work zones
Decontamination
Air surveillance
Field Standard Operating Procedures
Site entry
Work zones
Decontamination of response personnel
Air surveillance
Site safety plan '"
FSOP #4: Site Entry (U.S. EPA, 1985, OSWER
Directive 9285.2-01). This document discusses site entry
procedures, including proper selection, use, and
decontamination of personal protective equipment; use of
field equipment; activities conducted during initial site
entry; and check-out procedures for a self-contained
breathing apparatus.
FSOP #6: Work Zones (U.S. EPA, 1985, OSWER
Directive 9285.2-04). This document discusses a number
of topics related to work zones, including definitions of
work zones, methodology for selecting work zone
locations, personal protective levels, and air monitoring.
FSOP #7: Decontamination of Response Personnel
(U.S. EPA, 1985, OSWER Directive 9285.2-02). This
document provides flow charts for decontamination
layouts, descriptions of personal protective equipment,
procedures for decontamination, and lists of
decontamination equipment.
FSOP #8: Air Surveillance (U.S. EPA, 1985,
OSWER Directive 9285.2-03). This document describes
the types and methods of air surveillance, procedures and
equipment for air monitoring, and a method for analyzing
organic solvents by gas chromatography.
FSOP #9: Site Safety Plan (U.S. EPA, 1985,
OSWER Directive 9285.2-05). This document describes
the general requirements for a site safety plan, discusses
development and implementation of a site safety plan,
and provides sample plans and a checklist.
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TRAINING
As part of EPA's comprehensive
program for protecting the public and
the environment from releases of
hazardous materials, ERT developed
the Hazardous Materials Incident
Response Training (HMIRT) Program. A list of the
HMIRT courses is provided in Exhibit 5. A schedule of
these courses is available from ERT in Cincinnati, Ohio.
EXHIBIT 5
Training
Hazardous Materials Incident Response
Training Program Schedule of Courses
Personal Protection and Safety
Hazardous Materials Treatment Technologies
Air Surveillance for Hazardous Materials
Hazardous Materials Incident Response Operations
Risk Assessment Guidance for Superfund
Introduction to Groundwaler Investigations
Safety and Health Compliance for Managers
Sampling for Hazardous Materials
Radiation Safety at Superfund Sites
Emergency Response to Hazardous Materials
Incidents
Advanced Air Sampling for Hazardous Materials
Removal Cost Management System
Hazardous Materials Incident Response Training
Program Course Schedule
The HMIRT program is designed for emergency
responders and for personnel who investigate and clean
up uncontrolled hazardous waste sites. The HMIRT
program currently has a curriculum of 12 courses. (See
Exhibit 5.) The curriculum covers emergency operations,
as well as the scientific and technical aspects of response
to hazardous materials incidents. The courses provide
specific training in worker health and safety and in
various technical operations that must be performed by
site personnel and emergency responders to identify,
evaluate, and control releases of hazardous substances.
All HMIRT courses, which generally last from
three to five days, emphasize the practical application of
lecture material through problem solving, case studies,
and demonstrations, along with actual exercises using
response equipment and instruments. Many of the
HMIRT courses are accredited by .the American Council
on Education. The program also offers continuing
education units and American Board of Industrial
Hygiene (ABIH) • certificate maintenance credits for
course participants. Tuition for HMIRT courses is free
to any government worker, including federal, state, and
local personnel, as well as to volunteer fire companies;
however, there is a nominal tuition fee for members of
industry.
WHERE TO OBTAIN
GUIDANCE
The guidance described in this Fact
Sheet can be obtained from the
sources shown in Exhibit 6. When
calling or writing, please be certain to
specify the title and identification number (if available)
of the guidance.
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EXHIBIT 6
Where to Obtain Guidance
To Obtain:
• Computer Software
-- HASP (and User's Guide, 9285.8-01)
-- FCTS (and User's Guide, 9285.3-03)
. HAZWOPER Fact Sheets
- General Information and Comparison (9285.2-09FS)
- Uncontrolled Hazardous Waste Sites and RCRA
Corrective Action (9285.2-08FS)
- RCRA TSD and Emergency Response Without Regard
to Location (9285.2-07FS)
- Establishing Work Zones at Uncontrolled Hazardous
Waste Sites (9285.2-06FS)
• Occupational Medical Monitoring Program Guidelines for
SARA Hazardous Waste Field Activity Personnel
(9285.3-04)
• Standard Operating Safety Guides (9285.1-OIC)
• Field Standard Operating Procedures
- FSOP #4: Site Entry (9285.2-01)
- FSOP #6: Work Zones (9285.2-04)
— FSOP #7: Decontamination of Response Personnel
(9285.2-02)
- FSOP #8: Air Surveillance (9285.2-03)
- FSOP #9: Site Safety Plan (9285.2-05)
Call or Write:
U.S. EPA/ERT ERC H&S
2890 Woodbridge Avenue
Building 18 (MS-101)
Edison, NJ 08837-3679
(908) 321-6740 or (FTS) 340-6740
To Oblain:
• Hazmat Team Planning Guidance (EPA/540/G-90/003)
• Health and Safety Audit Guidelines (EPA/540/G-89/010)
Call or Write:
• National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
To obtain:
• HMIRT Course Schedule
Call or Write:
. U.S. EPA/ERT
26 West Martin Luther King
Cincinnati, OH 45268
(513) 569-7537 or (FTS) 684-7537
To Obtain:
• Other information on worker protection standards
Call or Write:
• Emergency Planning and Community Right-to-Know
Information
U.S. EPA (OS-120)
401 M Street, SW
Washington, D.C. 20460
(800) 535-0202 or (202) 479-2449
• Superfund Docket/U.S. EPA
401 M Street, SW
Room 2427 SDIC
Washington, D.C. 20460
(202) 382-3046
• U.S. Department of Labor
Occupational Safety and Health Administration (OSHA)
OSHA Publications Office, Room N3101
200 Constitution Avenue, NW
Washington, D.C. 20210
(202) 523-9667
• National Institute of Occupational Safety and Health
NIOSH Publications
4676 Columbia Parkway
Cincinnati, OH 45226
• Federal Emergency Management Agency (FEMA)
P.O. Box 70274
Washington, D.C. 20024
(or contact FEMA Regional Office directly)
• Emergency Management Institute (EMI)/
National Fire Protection Academy (NFA)
Federal Emergency Management Agency
16825 South Seton Avenue
Emmitsburg, MD 21727
(301) 447-1122
• National Fire Protection Association (NFPA)
1 Batterymarch Park
P.O. Box 9101
Quincy, MA 02269-9101
(617) 770-3000
• Fire Protection Publications
Oklahoma State University
Stillwater, OK 74078-0118
(405) 744-7576
• Superintendent of Documents
U.S. Government Printing Office
Washington, D.C. 20402
(202) 783-3238
• National Technical Information Service (NTIS)
5285 Port Royal Road
Springfield, VA 22161
(703) 487-4600
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