1. OSHA personnel entering the CRZ or ExZ must have the following knowledge, for CSHOs or other OSHA Personnel and/or experiences:

   (1) You must have received fit testing and training in the use of respiratory and clothing protection to be worn on-site. You must be trained to recognize the signs and symptoms of exposure caused by contaminant breakthrough and heat stress
   
   (2) You must be trained in the use of the "buddy system" buddy system and site communication procedures, including Emergency alerting.
   
   (3) You must be trained in the proper general and site-specific procedures for putting on and taking off the personal protective equipment (PPE) used on-site.
   
   (4) You must be trained in the proper general and site-specific decontamination procedures to be used on-site.
   
   (5) You must be trained regarding site emergency evacuation procedures.
   
   (6) You must be trained in the proper use of hazardous atmosphere testing equipment.
   
   (7) You must know how to select the proper PPE (clothing and respiratory) for protection of OSHA personnel. To do this, you will need to know:
   
   

   1. The levels of air and surface contamination present, or likely to be present on-site, including immediately dangerous to life and health (IDLH) immediately dangerous to life and health (IDLH) conditions;
   2. The chemical, physical, and biological hazards that are present, or likely to be present on-site; and
   3. The limits of the PPE.

   (8) You must have the knowledge, experience, and resources to accurately evaluate the decontamination facilities and procedures on-site. You must determine whether they are adequate to protect the safety and health of OSHA personnel. If existing site conditions are not adequate, you must have the knowledge and experience to select, obtain, and establish proper decontamination procedures, materials and facilities to protect OSHA personnel from the hazards on-site.
   
   (9) You must have sufficient knowledge of and experience with the safety and health hazards present on-site. You must be able to provide guidance for OSHA personnel entering the CRZ or ExZ.
   
   (10) You must have the knowledge and experience necessary to set up "buddy" and communication systems for OSHA personnel entering the CRZ or ExZ.
   
   (11) You must be familiar with the HAZWOPER Standard. You also must be familiar with this instruction, and you must understand all the terms defined in Appendix C.

2. OSHA personnel may be asked by State and Federal agencies or site operators to demonstrate proof of training certification in certain instances. You are not required to provide this proof in order to enter a site and conduct an inspection. However, to expedite inspection activities, the AD in consultation with the RA may issue materials such as letters, memos, or pocket-size hazardous waste training certificates to OSHA personnel. Such documentation may only be issued after reviewing the record of training and experience. These materials should, at a minimum, include the name of the cardholder/OSHA personnel, a statement certifying the training level completed (i.e., team leader, CRZ and ExZ qualified), the name and signature of the certifying official, and the date of the certification. These materials should also indicate the OSHA personnel's participation in the medical monitoring program.
   
   
3. On a yearly basis, OSHA supervisors must evaluate the training for CSHOs or other needs of OSHA personnel who may be involved in hazardous waste site inspections.

1. Authorization to Enter. OSHA personnel must receive clearance from the AD in consultation the RA before they can enter a hazardous area. Where entry into hazardous areas is necessary, clearance should be based on your training and experience, the levels of risk involved, and the availability of appropriate and adequate protection.
   
   
2. Work Practices for OSHA Personnel. The following guidance is for OSHA personnel entering hazardous areas:

   (1) Review site Emergency procedures and alarm signals before entering a hazardous area.
   
   (2) Get authorization from the AD in consultation with the RA before you enter permit-required confined spaces 1910.146, Permit-required Confined Spaces. All requirements for entering the confined space must be met.
   
   (3) Use the buddy system buddy system when entering a hazardous area requiring respiratory protection. Appropriately equipped and trained personnel other than CSHOs (e.g., EPA personnel or site personnel) may serve as buddies if necessary. You must also understand and use the site communication procedures.
   
   (4) Determine the potential hazards before you enter a hazardous area. You must obtain special authorization from the appropriate administrator before entering a hazardous area that the employer has not characterized, or that may have an IDLH atmosphere.
   
   (5) When entering a hazardous area, maintain a safe distance from operations that involve opening or handling drums or containers that are being remediated. Do not move or open drums or containers of unknown contents or where opening a container poses an innate hazard, such as from picric acid or ethyl ether.

3. Personal Protective Equipment for OSHA Personnel. OSHA personnel who will enter the CRZ or the ExZ must wear appropriate personal protective equipment for the site. The specific hazards of the work zone determine the equipment needed for entry. The AD in consultation with the RA should also make appropriate arrangements for on-site medical monitoring. Appendix B of this instruction provides recommended equipment for OSHA personnel.
   
   
4. Decontamination Procedures for OSHA Personnel. Before entering a hazardous area, determine whether decontamination facilities exist. Also determine whether they are adequate for the expected contaminants at the site, and if they will be available for OSHA's use.
   
   When decontamination facilities including those for Emergency decontamination exist at the inspection site, evaluate whether they adequately meet the standard. If so, use them in accordance with the procedures established by the employer. OSHA personnel should not enter the CRZ or ExZ until decontamination facilities are adequate.

   (1) Remove from the site only contaminated items or materials that can be handled in a safe manner. That is, make sure the material is sealed in a labeled, air-tight container. Treat disposable contaminated items as contaminated waste and leave them on-site.
   
   (2) When taking items into potentially hazardous areas, seal them in contamination-proof containers that can be easily decontaminated and/or removed. In addition, avoid contact with areas of visible contamination such as puddles, discolored areas, and dusty areas.

1. The general category of hazardous waste clean-up operations is divided into three very specific groups in the scope of 29 CFR 1910.120(a)(1) and 1926.65(a)(1):

   (1) Clean-up operations required by a governmental body involving hazardous substances that are conducted at uncontrolled hazardous waste sites;
   
   (2) Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act (RCRA) of 1976 as amended; and
   
   (3) Voluntary clean-up operations at sites recognized by governmental bodies as uncontrolled hazardous waste sites.

   All of these operations must comply with paragraphs (b) through (o) of 29 CFR 1910.120 and/or 1926.65 and are covered by this directive.
   
   
2. RCRA Resource Conservation and Recovery Act (RCRA) -permitted treatment, storage and disposal facilities must comply with paragraph (p) of 29 CFR 1910.120 and/or 1926.65.
   
   
3. Hazardous substance emergency response operations (regardless of location) must comply with paragraph (q) of 29 CFR 1910.120 and/or 1926.65, where not already covered by another part of the standard. For more information, see CPL 02-02-059 (CPL 2-2.59A), Inspection Procedures for the Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120, Paragraph (q): Emergency Response to Hazardous Substance Releases, dated April 24, 1998.
   
   

[Note: (1910.120(a)(3)) - "Hazardous Substance means any substance designated or listed under (A) through (D) of this definition, exposure to which results or may result in adverse effects on the health or safety of employees:
[A] Any substance defined under section 101(14) or CERCLA;
[B] Any biologic agent and other disease causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably by anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such persons or their offspring.
[C] Any substance listed by the U.S. Department of Transportation as hazardous materials under 49 CFR 172.101 and appendices and
[D] Hazardous waste as herein defined.]

1. Like construction sites, hazardous waste sites are commonly multi-employer work sites multi-employer work sites. You should follow the guidance in CPL 02-00-124 (CPL 2-0.124), the Multi-Employer Citation Policy, issued December 10, 1999.
   
   
2. In addition to the usual topics covered at an opening conference, per CPL 02-00-103 (CPL 2.103), the Field Inspection Reference Manual (FIRM), the opening conference should cover such topics as the procedures to follow in the event of an emergency, the site warning signals, the nature and location of any ongoing hazardous activities, and any safety or health procedures not described in the current written safety and health program that should be followed while on-site. This should be done to ensure that you are familiar with the site's required procedures for entering and exiting the Exclusion Zone or in the event that an emergency occurs during the inspection.
   
   
3. You must not enter hazardous areas without meeting the requirements listed under Engineering Control, Work Practices, and PPE in subparagraph (g) of HAZWOPER and receiving clearance through your AD in consultation with the RA.

1. Safety and health program, as per 29 CFR 1910.120(b)(1) and/or 1926.65(b)(1). The safety and health program requires other written programs such as an organizational structure, a work plan, and a site-specific safety and health plan. See Section XIII for more information on the relationships between the written safety and health program, the site-specific safety and health plan, and the requirements of the HAZWOPER standard;
   
   
2. Site-specific safety and health plan, as per HAZWOPER paragraph (b)(1)(ii)(C). This may be part of the safety and health program listed above, and need not duplicate the employers standard operating procedures;
   
   
3. Documentation of site characterization and analysis, as per 29 CFR 1910.120(c)(4) and/or 1926.65(c)(4);
   
   
4. Spill containment program, as per 29 CFR 1910.120(j)(1)(viii) and/or 1926.65(j)(1)(viii);
   
   
5. Emergency response plan, as per 29 CFR 1910.120(l)(1) and/or 1926.65(l)(1);
   
   
6. New technology program, as per 29 CFR 1910.120(o) and/or 1926.65(o), which  may be part of the safety and health program; and
   
   
7. Other programs that may be needed because of special site conditions or special site procedures. Examples include programs for benzene, lead, asbestos, heat stress, process safety management (PSM), permit-required confined space, and lockout/tagout.
   
   

1. Environmental Protection Agency, the National Oil and Hazardous Substances Pollution Contingency Plan (NCP). The NCP is a set of regulations that sets forth the procedures that must be followed when implementing the Superfund program and the Oil Pollution Act of 1990 Oil Pollution Act of 1990 (OPA 90). These requirements, codified in 40 CFR Part 300, outline requirements for responding to situations in which oil is discharged into or upon the navigable waters of the United States, or hazardous substances, pollutants, or contaminants are released into the environment. The oil response regulations developed pursuant to the Clean Water Act (as amended by the Oil Pollution Act of 1990) are codified in Subpart D of the NCP (40 CFR 300.300). The hazardous substance regulations, developed pursuant to §105 of CERCLA and SARA, are codified in Subpart E (40 CFR 300.400).

   (1) The NCP addresses worker health and safety in 40 CFR 300.150. Paragraph 300.150(a) states the response actions under the NCP will comply with the provisions for response action worker safety and health in 29 CFR 1910.120.
   
   (2) The NCP also states in 40 CFR Part 300.175(b)(11)(ii) that "...on request, OSHA will provide advice and assistance to EPA and other NRT/RRT [National Response Team/Regional Response Team] agencies as well as to the OSC/RPM [On-Scene Coordinator/ Remedial Project Manager] regarding hazards to persons engaged in response activities. Technical assistance may include review of site safety plans and work practices, assistance with exposure monitoring, and help with other compliance questions. This advice and assistance does not take the place of OSHA's enforcement activities.
   
   

2. Department of Transportation, Hazardous Material Transportation Uniform Safety Act of 1990 (HMTUSA). The handling of hazardous materials in the transportation industry is regulated by HMTUSA. training for the safe handling and safe transportation of hazardous materials is required in Section 7 of HMTUSA, which states that, for purposes of Section 4(b)(1) of the OSH Act, no action taken by the Secretary of Transportation pursuant to Section 7 shall be deemed to be an exercise of statutory authority to prescribe or enforce standards or regulations affecting occupational safety and health.

   (1) On May 15, 1992, DOT published the final rule Hazardous Materials training for Safe Transportation Department of Transportation DOT (49 CFR 171-177) to enhance training requirements for persons involved in the transportation of hazardous materials. The rule requires employers to train their employees in the safe loading, unloading, handling, storing, and transportation of hazardous materials. Such employees are primarily in the private sector, but the DOT rule may apply to public sector employees if commerce is involved. The rule is also designed to improve Emergency preparedness for responding to accidents or incidents involving the transportation of hazardous materials.
   
   (2) The current DOT rule does not preempt OSHA from enforcing occupational safety and health regulations, such as 29 CFR 1910.120, when employers fall under the scope of HMTUSA. HAZWOPER applies if transporters are handling hazardous waste being transported to a hazardous waste site or to a Treatment Storage and Disposal (TSD) facility. HAZWOPER also applies when transporters become involved in Emergency responses to the release of hazardous substances.
   
   Note: HMTUSA was rewritten editorially in 1994 with no substantive changes. Check with OSHA's Office of General Industry Enforcement (202-693-1850) to determine if OSHA jurisdiction has changed.
   
   (3) Training provided to satisfy the OSHA, EPA, or DOT requirements may be used to satisfy comparable training requirements of the other agencies' rules. Multiple training courses are not necessary.
   
   

3. United States Coast Guard, Oil Pollution Act of 1990 (OPA 90). The Oil Pollution Act of 1990 (OPA) amended the Clean Water Act (CWA) and other statues to strengthen and expand the nation's oil and hazardous substances spill prevention, preparedness, and response activities. The removal of an oil discharge, according to Subtitle B of OPA 90, must be conducted in accordance with the NCP and any appropriate Area Contingency Plan. Therefore, the health and safety provisions within the NCP at 40 CFR 300.150 (discussed above) also apply to oil spills.
   
   The USCG regulates oil vessels, deepwater ports, and the marine transfer components of transportation-related onshore facilities, including some inland port areas. The USCG provides On Scene Coordinators (OSCs) for coastal spill response and must direct the response in cases where the coastal spill "is of such a size or character as to pose a substantial threat to the public health or welfare."  The USCG also manages the National Response Center (NRC) and maintains the National Strike Force, a team specifically trained and equipped to respond to major marine pollution incidents.
   
   

   (1) The NCP designates OSHA as the agency responsible for ensuring that employees are protected and for determining if the site is in compliance with HAZWOPER. The lead agency for the NCP (EPA or U.S. Coast Guard) may request OSHA's assistance, but OSHA is not preempted from its regular enforcement duties. Appendix E of 40 CFR 300 specifically addresses oil spill response.
   
   (2) In 1990, OSHA published CPL 02-02-051 (CPL 2-2.51) CPL 2-2.51, Inspection Guidelines for Post-Emergency Response Operations Under 29 CFR 1910.120. Although this directive can apply to any post-emergency response operation, it specifically addresses training for clean-up operations after an oil spill.

1. When do I cite 29 CFR 1910.120 vs. 29 CFR 1926.65?  Since OSHA issued the codified standards for construction in 1993, you must determine whether 1910.120 or 1926.65 is the more appropriate standard for issuing citations.

   (1) Determine if the employer is involved in general industry or construction activities on a hazardous waste site the same way that you would for any other type of workplace. That is, work for construction, alteration, and/or repair, including painting and decorating is considered "construction work" according to 1910.12 and must comply with the Construction Safety and Health Regulations within 29 CFR 1926. Once this determination is made, violations of the HAZWOPER standard should be cited under either 29 CFR 1910.120 or 29 CFR 1926.65, as appropriate.
   
   (2) Decisions about whether to cite standards outside of HAZWOPER for violative conditions should be based on selecting the most protective standard. 29 CFR 1910.120(a)(2)(i) states, "All requirements of part 1910 and part 1926 of Title 29 of the Code of Federal Regulations apply pursuant to their terms to hazardous waste and Emergency response operations. If there is a conflict or overlap, the provision more protective of employee safety and health shall apply without regard to 29 CFR 1910.5(c)(i)." Likewise, 29 CFR 1926.65(a)(2)(i) now has a similar statement that ends in "...without regard to 29 CFR 1926.20(e). You should reference 29 CFR 1910.120(a)(2)(i) or 29 CFR 1926.65(a)(2)(i) if a standard outside of HAZWOPER is cited.
   
   (3) Citations issued for HAZWOPER violative conditions will normally be classified as serious. The combined effects of multiple hazards should be considered when determining the seriousness of the violation and associated penalty. Further guidance on violation classifications and penalties can be found in the FIRM.

2. How do I decide which HAZWOPER paragraphs to cite, and how many citations should be issued?  It is possible to have any or all three sections of the HAZWOPER standard, paragraphs (b)-(o), (p), or (q), apply to one site, depending on conditions and specific activities. To make the determination of the applicable paragraphs, you may find it easier to first decide which sections do not apply rather than which sections do apply. Any sections that remain may apply and you should then cite the section that is most protective or should group citations for each applicable section as necessary.

   (1) It may be necessary for you to issue separate citations for similar kinds of violations of different parts of HAZWOPER. An employer may, for example, be in violation of both (e)(1)(ii) and (p)(7), requiring two separate citations because of the special training required for each type of employee (i.e., hazardous waste workers vs. TSD workers) or because two different operations are conducted at the same site. Similarly, an employer could receive grouped citations for two or more similar violations falling under different aspects of the HAZWOPER standard where abatement of one violation will result in abatement of all citations in the group.
   
   (2) Violations of both (l)(1)(i) and (p)(8) could result in issuing two citations grouped together or issuing a single citation for either paragraph, since a single Emergency response plan could have been developed to cover all Emergency responses for a given site. Using the example of an emergency response plan, a contractor involved in a cleanup on a TSD facility might be cited for 29 CFR 1926.65(l)(1)(i) and the employer who is operating the TSD could be cited for 29 CFR 1910.120(p)(8).

3. What about issuing programmatic citations for HAZWOPER? You should consider citing for failure to develop and/or implement programs when there is a strong potential for a hazard to exist and it has not been adequately addressed by the Site-Specific Safety and Health Plan or other written programs.

   (1) If, for example, workers are handling drums in an unsafe manner because the contents of the drums are unknown, you do not have to prove that the drums are hazardous. Instead, the drums are considered hazardous until it has been demonstrated otherwise. The site-specific safety and health plan (SSAHP) should, in this example, address the potential hazards of handling unclassified drums and include written procedures for classifying and handling those drums. You should consider citing the various applicable paragraphs of 29 CFR 1910.120(b)(4) and/or 29 CFR 1926.65(b)(4). Citations could also be issued for other applicable paragraphs of HAZWOPER. In this example, you could cite 29 CFR 1910.120(c)(7) and/or 29 CFR 1926.65(c)(7) for risk identification. You should also consider citing the more specific paragraphs for implementation, such as HAZWOPER paragraph (j)(1)(iv), where possible.
   
   (2) Consult OSHA Instruction CPL 02-00-111 (CPL 2.111), "Citation Policy for Paperwork and Written Program Requirement Violations," when preparing citations for programmatic violations. This directive gives citation guidance for violations of requirements to prepare a written plan. CPL 02-00-111 (CPL 2.111) discusses issuing citations when the employer's written program is missing or deficient but is not willful. In some cases, where the employer has not addressed a hazard or requirement in a written program, but the deficiency in the plan does not pose a hazard to employees, CSHOs are to issue other-than-serious violations with no penalty or are to not issue a citation.

4. Are there guidelines for issuing HAZWOPER citations when I am conducting a Process Safety Management (PSM) investigation?  Inspections of facilities that fall under both the Process Safety Management (PSM) standard (29 CFR 1910.119 and 1926.64) and HAZWOPER can lead to citations that may either be grouped or cited separately, depending on the specific violation. Paragraph (n) of the PSM standard specifically states that, "The employer shall establish and implement an Emergency Action Plan for the entire plant in accordance with 29 CFR1910.38" for general industry or 29 CDR 1926.35 for construction. It further states that, Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p), and (q) and/or 29 CFR 1926.65(a), (p), and (q)."

   (1) You should make the determination to cite HAZWOPER as if the site were not covered by the PSM standard. Once you have determined that HAZWOPER will be cited, the citation may either be grouped with a citation for paragraph (n) of the PSM standard, or paragraph (n) of the PSM standard can be cited and the appropriate HAZWOPER paragraph can be referenced in the Alleged Violation Description.
   
   (2) If, however, you should cite multiple violations of the HAZWOPER standard, you should cite them individually rather than grouping them all with the PSM standard paragraph (n).
   
   (3) For specific violations related to either evacuation or training for the Emergency Action Plan, you should cite 29 CFR 1910.38 or 1926.35 by way of the host standard, i.e., 1910.119(n) 1910.119, Process Safety Management or 1926.64(n). In no case where a host standard requires an Emergency action plan will 1910.38 or 1926.35 be cited alone. However, 1910.38 or 1926.35 may be referenced in the variable language with the host standard.

5. When do I cite Subpart T of 29 CFR 1926, Demolition, versus HAZWOPER? It is not unusual to see the dismantling and demolition of buildings and structures on hazardous waste sites and you should evaluate them according to the requirements in 1926 Subpart T. If hazardous waste or hazardous substances are involved (e.g., testing and removing hazardous materials from buildings before demolition) you need to consider the requirements in HAZWOPER as well as in 1926.850(e). The more protective provisions apply. Examples of frequently cited demolition violations include:

   (1) Not performing a written engineering survey of the structure before commencing demolition work [1926.850(a)].
   
   (2) Not providing fall protection for employees exposed to wall openings [1926.850(g)].
   
   (3) Not providing shoring or bracing for walls to prevent premature collapse [1926.850(b)].
   
   (4) Not properly inspecting and maintaining stairways and ladders in safe conditions for employee use [1926.851(b)].
   
   (5) Not properly testing and removing hazardous materials from within the structure before commencing demolition work [1926.850(e)].
   
   (6) Not providing sidewalk shed covers to protect employee entrances to the structure [1926.850(h)].

6. When do I cite Subpart P of 29 CFR 1926, Excavations, versus HAZWOPER? Trenching and excavation are also common activities on hazardous waste sites and you should evaluate them according to the requirements in 1926 Subpart P. If hazardous waste or hazardous substances are involved (e.g., excavating in contaminated or potentially contaminated soil, excavating buried drums or tanks containing hazardous substances) you need to consider the requirements in HAZWOPER as well as in 1926.651(g). The more protective provisions apply. When workers are handling drums or other containers during excavation, evaluate the work according to the requirements of HAZWOPER's paragraph (j).
   
   When a leak or spill from an underground storage tank is being remediated under the EPA requirements in 40 CFR 280, Technical Standards and Corrective Action Requirements for Owners and Operators of Underground Storage Tanks, this work fits within the scope of HAZWOPER as a RCRA Resource Conservation and Recovery Act (RCRA) corrective action, 1910.120(a)(1)(ii). According to the EPA requirements, cleanup and/or closure of a leaking underground storage tank that is 1,100 gallons or larger with at least 10% of the tank and/or piping located underground is a recognized cleanup site. The provisions of both 1926 Subpart P and HAZWOPER may apply.
   
   
7. When do I apply Expanded Health Standards versus the HAZWOPER standard? Paragraphs 29 CFR 1910.120(a)(2)(i) and 1926.65(a)(2)(i) state that when there is a conflict or overlap of coverage between standards, the provision that is the more protective of employee safety and health will apply. Employers must comply with all safety and health standards that are applicable to their workplace; however, certain provisions of HAZWOPER may be more protective than the comparable provisions of an expanded health standard. HAZWOPER does not completely supersede any standard. HAZWOPER supersedes provisions of another standard if HAZWOPER is more protective.
   
   For example, you can cite the provisions of one of two standards, the benzene standard and the HAZWOPER standard, depending on which provision offers more protection. The benzene standard provides specific requirements for exposure monitoring and medical surveillance that are more protective than those in the HAZWOPER standard. You should cite the appropriate paragraphs of the benzene standard rather than HAZWOPER in situations where an employer's monitoring or medical surveillance program is inadequate on a hazardous waste site where benzene is present.
   
   
8. What training does the Hazard Communication, CFR 1926.59 1926.59 require and what are its applications?  The HCS requires that employers train employees who may be exposed or potentially exposed to hazardous chemicals. Employers are to train employees in (i) methods to detect a hazardous chemical; (ii) the hazards of chemicals in the work area; (iii) measures employees can take to protect themselves; and (iv) the details of the hazard communication program hazard communication:program (further clarified in paragraph (h) of the HCS). It is important to note the objectives of both HAZWOPER and the HCS, especially where the two standards require training:

   (1) The HCS does not specifically apply to hazardous waste. The requirement that employers inform employees of the hazards associated with exposure to hazardous waste or waste-contaminated material are contained in the HAZWOPER standard (1910.120(i) or 1926.65(i)).
   
   (2) The HCS does apply to commercial hazardous materials that are stored, used, or handled on the site. Such materials may include motor fuels, decontamination solvents, compressed gases, or acids and caustics used in wastewater treatment, other chemical processes, and treatment of hazardous waste performed on the site.

9. What do I need to review when evaluating compliance with 29 CFR 1910.38 and 1926.35, Employee Emergency Plans and fire Prevention Plans?   See Section XIII, Emergency Response.
   
   
10. How do I inspect for compliance with 29 CFR 1910.146, Permit-required Confined Spaces? See Section XIII, Permit-Required Confined Space Program.
    
    
11. Does HAZWOPER overlap with 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens? The definition of hazardous substance found in HAZWOPER includes any biological agent or infectious material that may cause disease or death. Citations for exposures, mishandling, etc. of biological hazardous wastes should be cited under HAZWOPER. Citations for exposures to bloodborne pathogens as regulated under the Bloodborne Pathogen standard should be cited under 1910.1030. Where there is a conflict or overlap of the standards, the provision more protective of employee safety and health applies.
    
    
12. Is there a mandatory accreditation standard for HAZWOPER training programs? OSHA does not approve training programs or certify trainers. Appendix E of the HAZWOPER standard gives non-mandatory guidance for training programs. OSHA has removed the proposed standard addressing accreditation of training courses required by HAZWOPER: 29 CFR 1910.121, Accreditation of Training Programs for Hazardous Waste Operations.
    
    

1. Established prohibitions and requirements concerning closed and abandoned hazardous waste sites;
   
   
2. Provided for liability of persons responsible for releases of hazardous waste at these sites; and
   
   
3. Established a trust fund to provide for cleanup when no responsible part could be identified.

1. Stages of a Removal Action

   (1) Discovery: A hazardous substance release or an immediate threat posed by an abandoned hazardous waste site facility is reported to the EPA Environmental Protection Agency. Occasionally, a removal action is initiated as a post-Emergency operation or clean-up following an emergency response operation.
   
   (2) Removal Site Evaluation (RSE): As part of the RSE, the EPA On-Scene Coordinator (OSC) initially conducts an off-site preliminary assessment to help identify specific hazards and determine the appropriate response measures and safety measures to ensure the health and safety of the responders. Following an off-site preliminary assessment, the OSC conducts an on-site investigation to gather additional information and further evaluate the site risks and hazards.
   
   (3) Assessment of RSE Results Against Regulatory Criteria: If the results of the RSE do not meet regulatory criteria, the site is deferred to the State Authority, Remedial Program, or it is determined that there should be no further action. If the site does meet the criteria, the OSC obtains approval for a removal action.
   
   (4) Removal Action: When the OSC obtains approval for a removal action, the action is initiated, and clean-up contractor contractors go to the site.

1. Stages of a Remedial Action

   (1) Preliminary Assessment: The initial stage of the clean-up program is a facility-wide study to determine if there are sites that pose hazards to public health or the environment. Available information is collected on the source, nature, extent, and magnitude of actual and potential hazardous substance releases at facility sites.
   
   (2) Site Inspection: This stage consists of sampling and analysis to determine the existence of actual site contamination. Information gathered is used to evaluate the site and determine the response action needed. Uncontaminated sites do not proceed to later stages of the process.
   
   (3) Remedial Investigation: The remedial investigation may include a variety of site investigative, sampling, and analytical activities to determine the nature, extent, and significance of the contamination. The focus of the evaluation is determining the risk to the general population from the contamination.
   
   (4) Feasibility Study: Concurrent with the remedial investigations, feasibility studies are conducted to evaluate remedial action alternatives to determine which would provide the protection required.
   
   (5) Remedial Design: Detailed design plans for the chosen remedial action alternative are prepared.
   
   (6) Remedial Action: The chosen remedial alternative is implemented.
   
   (7) Interim Remedial Action: Remedial actions can be taken at any time during the clean-up process to protect public health or to control contaminant releases to the environment.

1. Sample bottles;
2. Zip-lock plastic bags for samples;
3. PVC bags, 8 mil.;
4. Labels;
5. Markers (e.g., Sharpie);
6. Tags;
7. Chemical wipes;
8. Wipe test - Whatman 41 filter paper;
9. Chain of custody;
10. Shipping container(s); and
11. Shipping tape.

1. PVC bags for decontamination;
2. Plastic buckets, 5-gallon;
3. Cold water detergent;
4. Long-handled stiff bristle brush; and
5. PVC plastic drop tarps and tiedowns.

1. Small explosion-proof flashlight with batteries;
2. Knife, folding pocket-type;
3. Scissors;
4. Qualitative fit test equipment to be used consistent with 1910.134(f);
5. first aid kit;
6. Duct tape, high tack adhesive;
7. pH paper
8. Thermal underwear, lightweight, 100% cotton or polypropylene;
9. Socks, cotton or polypropylene;
10. Warning signs;
11. Waterproof log book, pencils, and chemical-resistant pens;
12. fire extinguisher, small;
13. Polypropylene/nylon barrier rope;
14. Barrier tape;
15. Pop-up tent;
16. Binoculars
17. Face shield; and
18. Radio-frequency transceiver.
    

1. fire -resistant jumpsuit;
2. Chemical splash suit, hooded;
3. Rain gear, two-piece suit; and
4. Hard hat, adjustable.

1. Leather safety boots;
2. Chemically resistant boots: non-sparking, non-conductive material 12-inch height, safety toe, and steel shank; and
3. Disposable boot covers.

1. Safety glasses, prescription if necessary;
2. Safety glasses, prescription if necessary, for regular use under self-contained breathing apparatus (SCBA) (short leg or adapter kit); and
3. Chemical splash goggles.

1. SCBA protection:self-contained breathing apparatus (SCBA) pressure-demand, 30 minutes, with extra tank (only where CSHO training and job hazards warrant);
2. Full-face, air-purifying combination canister approved for organic vapor with dust, mist, fume pre-filter; and
3. SCBA, protection:self-contained breathing apparatus (SCBA) emergency escape, 5 minutes.

1. Cotton or polypropylene inner gloves (for wicking moisture under other gloves);
2. lightweight synthetic inner gloves;
3. Chemical, outer glove, 14-inch length, 22-millimeter thickness (nitrile rubber); and
4. Working gloves, leather

1. Detector tubes
2. Photoionization detector (e.g., HNU)
3. Personal sampling equipment