Resource: HAZMAT

images4HAZWOPER (HAZardous Waste OPerations and Emergency Response) regulations require a medical surveillance program that must be offered to all employees who are:

  • Potentially exposed to hazardous substances, without re­gard to the use of a respirator, for more than 30 days per year.
  • Required to use a respirator for more than 30 days per year.
  • Injured from exposure to hazardous substances during an emergency incident.
  • Members of a hazardous materials (HazMat) team.

The standard requires employer-provided medical examinations:

  • Prior to assignment.
  • At least once every 12 months, unless the physician believes a longer interval, not to exceed 2 years, is appropriate.
  • Termination of employment or transfer to a non-covered assignment.
  • As soon as possible following overexposure or the appearance of signs or symptoms indicating possible overexposure.
  • When deemed medically necessary by the examining physician.

Detailed records of all examinations must be kept and maintained in the same way as other OSHA-mandated medical records.

Baseline Medical Examinations

The content of the examination is to be determined by the attending physician, who must keep in mind the worker’s unique employment conditions. The work they do is nearly always heavy, often outside, and frequently in unfavorable terrain. An increasing number of the workers are women. At most sites, workers perform multiple tasks, so they must frequently handle heavy tools and work with construction equipment. Their protective clothing often includes fully protective suits, full-face masks, and SCBA. Personal protective equipment has not always been appropriate for the needs of the hazardous waste workers, nor have they always had training available to teach them proper use. The equipment can severely compromise vision and movement, meaning that accidents and trauma can be more dangerous than chemical exposure.

Based on these working conditions, the history should detail:

  • Any past adverse effects of chemical exposures.
  • The circumstances of any previous heat-stress episodes.
  • Any history of problems while wearing personal protective equipment.
  • Any continuing exposures to chemicals such as secondary employment or hobbies.

More Information:

The Occupational Safety and Health Administration (OSHA), in concert with the Environmental Protection Agency (EPA), has issued regulations covering  employees  potentially ex­posed to hazardous materials for more than 30 days per year. The regulation, known as HAZWOPER (HAZardous Waste OPerations and Emergency Response) also applies to work­ers who wear a respirator for more than 30 days per year or who are members of a hazardous materials (HazMat) team.

Provisions of the Standard

HAZWOPER  (OSHA : 29 CFR 1910.120; EPA: 40 CFR 311) became effective on March 6, 1990, and minor corrections were published on April 13, 1990. The regulation applies to work carried out:

  • On federal sites.
  • On sites that are a part of a federal mandate.
  • On sites that are designated as uncontrolled hazardous waste sites.
  • During emergency-response operations at releases of hazardous substances.

The regulation includes a number of requirements aimed at protecting the health and safety of workers . It requires a site-specific safety and health plan, which must discuss all phases of the anticipated work, the specific hazards expected to be encountered, their pathways, and emergency procedures. Engineering controls, work practices, personal protective equipment, and decontamination procedures are also included. Generic plans are not adequate.

Worker training is required, with the number of training hours depending on the exact work anticipated and the number of days per year worked.