OSHA 29 CFR 1910.120: Hazardous Waste Operations/Response

Hazardous Material Waste Response and MonitoringOSHA 29 CFR 1910.120 sub-part H covers the monitoring of Hazardous Waste Operations and Response, and the responsible control, storage and handling of those materials. While CFR 1910.120 sub-part H is not law it or a code of safety, per se, the regulation is issued in compliance with previously passed law and has the force of law. Regulations issued by an administrative agency of the Federal Government (OSHA) tend to be more specific than laws, explaining in greater detail how the general requirements of a law are to be implemented.

The Occupational Safety and Health Administration (OSHA) is an agency within the United States Department of Labor, and was formed in December of 1970. OSHA’s mission is to “assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education and assistance”. It is also tasked with enforcing a variety of whistle-blower statutes and regulations.

Within the Occupational Safety and Health Administration, are the regulations known in the industry as HAZWOPER. HAZWOPER is an acronym for “Hazardous Waste Operations and Emergency Response”. The standards contain the safety requirements employers and their sub-contractors or public sector responders must meet in order to conduct clean-ups or emergency response operations. The standards were established after the horrific Love Canal disaster and Valley of the Drums incident to provide information and requirements to employees who deal with the clean-up or handling of materials which could cause a potential hazard.

CFR 1910.120 sub-part H deals specifically with the requirements of HAZWOPER for the monitoring of hazardous materials on the job or clean-up site. CFR 1910.120 is organized under four sub-headings which deal with: general monitoring, air monitoring, initial entry, periodic monitoring, and the monitoring of high risk employees respectively. Generally speaking monitoring is used to insure employee safety, and to gauge the effectiveness of HAZWOPER training. Air monitoring is used to identify and quantify the presence of hazardous airborne materials. It also provides valuable information to employers and contractors about the appropriate level of employee protection that is required to operate within the work/clean-up site. Initial entry requirements establish guidelines for the safe entry and to avoid entering a site which is compromised by hazardous airborne materials. Periodic monitoring is conducted when the possibility of an IDLH condition or flammable atmosphere has developed or when there is indication that exposures may have risen over permissible exposure limits or published exposure levels since prior monitoring. These situations can arise when works begins in a different area of the site, different contaminates are handled than those originally worked with, when a different type of operation is started, or when employees are handling leaking drums or containers or working in areas with obvious liquid contamination (like a spill or lagoon). Monitoring of high risk employees insures the ongoing safety and health of workers who are exposed to the highest levels and most hazardous situations in the work or clean-up site.