29 eCFR 1910.120

e-CFR Data is current as of May 3, 2012
Title 29: Labor
PART 1910—OCCUPATIONAL SAFETY AND HEALTH STANDARDS
Subpart H—Hazardous Materials
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§ 1910.120 Hazardous waste operations and emergency response.
Link to an amendment published at 77 FR 17776, Mar. 26, 2012.
(a) Scope, application, and definitions —(1) Scope. This section covers the following operations, unless the employer can
demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety
or health hazards:
(i) Clean-up operations required by a governmental body, whether Federal, state, local or other involving hazardous substances
that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the EPA's National Priority Site List (NPL),
state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are
conducted before the presence or absence of hazardous substances has been ascertained);
(ii) Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976
(RCRA) as amended (42 U.S.C. 6901 et seq. );
(iii) Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled
hazardous waste sites;
(iv) Operations involving hazardous wastes that are conducted at treatment, storage, and disposal (TSD) facilities regulated by 40
CFR parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and
(v) Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to
the location of the hazard.
(2) Application. (i) 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 whether covered by this section or not. 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)(1).
(ii) Hazardous substance clean-up operations within the scope of paragraphs (a)(1)(i) through (a)(1)(iii) of this section must
comply with all paragraphs of this section except paragraphs (p) and (q).
(iii) Operations within the scope of paragraph (a)(1)(iv) of this section must comply only with the requirements of paragraph (p) of
this section.

Notes and Exceptions: (A) All provisions of paragraph (p) of this section cover any treatment, storage or disposal
(TSD) operation regulated by 40 CFR parts 264 and 265 or by state law authorized under RCRA, and required to
have a permit or interim status from EPA pursuant to 40 CFR 270.1 or from a state agency pursuant to RCRA.
(B) Employers who are not required to have a permit or interim status because they are conditionally exempt small
quantity generators under 40 CFR 261.5 or are generators who qualify under 40 CFR 262.34 for exemptions from
regulation under 40 CFR parts 264, 265 and 270 (“excepted employers”) are not covered by paragraphs (p)(1)
through (p)(7) of this section. Excepted employers who are required by the EPA or state agency to have their

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employees engage in emergency response or who direct their employees to engage in emergency response are
covered by paragraph (p)(8) of this section, and cannot be exempted by (p)(8)(i) of this section. Excepted employers
who are not required to have employees engage in emergency response, who direct their employees to evacuate in
the case of such emergencies and who meet the requirements of paragraph (p)(8)(i) of this section are exempt from
the balance of paragraph (p)(8) of this section.
(C) If an area is used primarily for treatment, storage or disposal, any emergency response operations in that area
shall comply with paragraph (p)(8) of this section. In other areas not used primarily for treatment, storage, or
disposal, any emergency response operations shall comply with paragraph (q) of this section. Compliance with the
requirements of paragraph (q) of this section shall be deemed to be in compliance with the requirements of
paragraph (p)(8) of this section.
(iv) Emergency response operations for releases of, or substantial threats of releases of, hazardous substances which are not
covered by paragraphs (a)(1)(i) through (a)(1)(iv) of this section must only comply with the requirements of paragraph (q) of this
section.
(3) Definitions—Buddy system means a system of organizing employees into work groups in such a manner that each employee
of the work group is designated to be observed by at least one other employee in the work group. The purpose of the buddy
system is to provide rapid assistance to employees in the event of an emergency.
Clean-up operation means an operation where hazardous substances are removed, contained, incinerated, neutralized,
stabilized, cleared-up, or in any other manner processed or handled with the ultimate goal of making the site safer for people or
the environment.
Decontamination means the removal of hazardous substances from employees and their equipment to the extent necessary to
preclude the occurrence of foreseeable adverse health affects.
Emergency response or responding to emergencies means a response effort by employees from outside the immediate release
area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results, or is
likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous substances
where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate
release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.
Responses to releases of hazardous substances where there is no potential safety or health hazard (i.e., fire, explosion, or
chemical exposure) are not considered to be emergency responses.
Facility means (A) any building, structure, installation, equipment, pipe or pipeline (including any pipe into a sewer or publicly
owned treatment works), well, pit, pond, lagoon, impoundment, ditch, storage container, motor vehicle, rolling stock, or aircraft, or
(B) any site or area where a hazardous substance has been deposited, stored, disposed of, or placed, or otherwise come to be
located; but does not include any consumer product in consumer use or any water-borne vessel.
Hazardous materials response (HAZMAT) team means an organized group of employees, designated by the employer, who are
expected to perform work to handle and control actual or potential leaks or spills of hazardous substances requiring possible close
approach to the substance. The team members perform responses to releases or potential releases of hazardous substances for
the purpose of control or stabilization of the incident. A HAZMAT team is not a fire brigade nor is a typical fire brigade a HAZMAT
team. A HAZMAT team, however, may be a separate component of a fire brigade or fire department.
Hazardous substance means any substance designated or listed under paragraphs (A) through (D) of this definition, exposure to
which results or may result in adverse affects on the health or safety of employees:
(A) Any substance defined under section 103(14) of the Comprehensive Environmental Response Compensation and Liability Act
(CERCLA) (42 U.S.C. 9601).
(B) Any biological 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 be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological

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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.
Hazardous waste means—
(A) A waste or combination of wastes as defined in 40 CFR 261.3, or
(B) Those substances defined as hazardous wastes in 49 CFR 171.8.
Hazardous waste operation means any operation conducted within the scope of this standard.
Hazardous waste site or Site means any facility or location within the scope of this standard at which hazardous waste operations
take place.
Health hazard means a chemical, mixture of chemicals or a pathogen for which there is statistically significant evidence based on
at least one study conducted in accordance with established scientific principles that acute or chronic health effects may occur in
exposed employees. The term “health hazard” includes chemicals which are carcinogens, toxic or highly toxic agents,
reproductive toxins, irritants, corrosives, sensitizers, heptaotoxins, nephrotoxins, neurotoxins, agents which act on the
hematopoietic system, and agents which damage the lungs, skin, eyes, or mucous membranes. It also includes stress due to
temperature extremes. Further definition of the terms used above can be found in appendix A to 29 CFR 1910.1200.
IDLH or Immediately dangerous to life or health means an atmospheric concentration of any toxic, corrosive or asphyxiant
substance that poses an immediate threat to life or would cause irreversible or delayed adverse health effects or would interfere
with an individual's ability to escape from a dangerous atmosphere.
Oxygen deficiency means that concentration of oxygen by volume below which atmosphere supplying respiratory protection must
be provided. It exists in atmospheres where the percentage of oxygen by volume is less than 19.5 percent oxygen.
Permissible exposure limit means the exposure, inhalation or dermal permissible exposure limit specified in 29 CFR part 1910,
subparts G and Z.
Published exposure level means the exposure limits published in “NIOSH Recommendations for Occupational Health Standards”
dated 1986, which is incorporated by reference as specified in §1910.6 or if none is specified, the exposure limits published in the
standards specified by the American Conference of Governmental Industrial Hygienists in their publication “Threshold Limit
Values and Biological Exposure Indices for 1987–88” dated 1987, which is incorporated by reference as specified in §1910.6.
Post emergency response means that portion of an emergency response performed after the immediate threat of a release has
been stabilized or eliminated and clean-up of the site has begun. If post emergency response is performed by an employer's own
employees who were part of the initial emergency response, it is considered to be part of the initial response and not post
emergency response. However, if a group of an employer's own employees, separate from the group providing initial response,
performs the clean-up operation, then the separate group of employees would be considered to be performing post-emergency
response and subject to paragraph (q)(11) of this section.
Qualified person means a person with specific training, knowledge and experience in the area for which the person has the
responsibility and the authority to control.
Site safety and health supervisor (or official) means the individual located on a hazardous waste site who is responsible to the
employer and has the authority and knowledge necessary to implement the site safety and health plan and verify compliance with
applicable safety and health requirements.
Small quantity qenerator means a generator of hazardous wastes who in any calendar month generates no more than 1,000

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kilograms (2,205 pounds) of hazardous waste in that month.
Uncontrolled hazardous waste site, means an area identified as an uncontrolled hazardous waste site by a governmental body,
whether Federal, state, local or other where an accumulation of hazardous substances creates a threat to the health and safety of
individuals or the environment or both. Some sites are found on public lands such as those created by former municipal, county or
state landfills where illegal or poorly managed waste disposal has taken place. Other sites are found on private property, often
belonging to generators or former generators of hazardous substance wastes. Examples of such sites include, but are not limited
to, surface impoundments, landfills, dumps, and tank or drum farms. Normal operations at TSD sites are not covered by this
definition.
(b) Safety and health program.

Note to (b): Safety and health programs developed and implemented to meet other Federal, state, or local
regulations are considered acceptable in meeting this requirement if they cover or are modified to cover the topics
required in this paragraph. An additional or separate safety and health program is not required by this paragraph.
(1) General. (i) Employers shall develop and implement a written safety and health program for their employees involved in
hazardous waste operations. The program shall be designed to identify, evaluate, and control safety and health hazards, and
provide for emergency response for hazardous waste operations.
(ii) The written safety and health program shall incorporate the following:
(A) An organizational structure;
(B) A comprehensive workplan;
(C) A site-specific safety and health plan which need not repeat the employer's standard operating procedures required in
paragraph (b)(1)(ii)(F) of this section;
(D) The safety and health training program;
(E) The medical surveillance program;
(F) The employer's standard operating procedures for safety and health; and
(G) Any necessary interface between general program and site specific activities.
(iii) Site excavation. Site excavations created during initial site preparation or during hazardous waste operations shall be shored
or sloped as appropriate to prevent accidental collapse in accordance with subpart P of 29 CFR part 1926.
(iv) Contractors and sub-contractors. An employer who retains contractor or sub-contractor services for work in hazardous waste
operations shall inform those contractors, sub-contractors, or their representatives of the site emergency response procedures
and any potential fire, explosion, health, safety or other hazards of the hazardous waste operation that have been identified by the
employer, including those identified in the employer's information program.
(v) Program availability. The written safety and health program shall be made available to any contractor or subcontractor or their
representative who will be involved with the hazardous waste operation; to employees; to employee designated representatives;
to OSHA personnel, and to personnel of other Federal, state, or local agencies with regulatory authority over the site.
(2) Organizational structure part of the site program —(i) The organizationa1 structure part of the program shall establish the
specific chain of command and specify the overall responsibilities of supervisors and employees. It shall include, at a minimum,
the following elements:

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(A) A general supervisor who has the responsibility and authority to direct all hazardous waste operations.
(B) A site safety and health supervisor who has the responsibility and authority to develop and implement the site safety and
health plan and verify compliance.
(C) All other personnel needed for hazardous waste site operations and emergency response and their general functions and
responsibilities.
(D) The lines of authority, responsibility, and communication.
(ii) The organizational structure shall be reviewed and updated as necessary to reflect the current status of waste site operations.
(3) Comprehensive workplan part of the site program. The comprehensive workplan part of the program shall address the tasks
and objectives of the site operations and the logistics and resources required to reach those tasks and objectives.
(i) The comprehensive workplan shall address anticipated clean-up activities as well as normal operating procedures which need
not repeat the employer's procedures available elsewhere.
(ii) The comprehensive workplan shall define work tasks and objectives and identify the methods for accomplishing those tasks
and objectives.
(iii) The comprehensive workplan shall establish personnel requirements for implementing the plan.
(iv) The comprehensive workplan shall provide for the implementation of the training required in paragraph (e) of this section.
(v) The comprehensive workplan shall provide for the implementation of the required informational programs required in
paragraph (i) of this section.
(vi) The comprehensive workplan shall provide for the implementation of the medical surveillance program described in paragraph
(f) of this section.
(4) Site-specific safety and health plan part of the program —(i) General. The site safety and health plan, which must be kept on
site, shall address the safety and health hazards of each phase of site operation and include the requirements and procedures for
employee protection.
(ii) Elements. The site safety and health plan, as a minimum, shall address the following:
(A) A safety and health risk or hazard analysis for each site task and operation found in the workplan.
(B) Employee training assignments to assure compliance with paragraph (e) of this section.
(C) Personal protective equipment to be used by employees for each of the site tasks and operations being conducted as required
by the personal protective equipment program in paragraph (g)(5) of this section.
(D) Medical surveillance requirements in accordance with the program in paragraph (f) of this section.
(E) Frequency and types of air monitoring, personnel monitoring, and environmental sampling techniques and instrumentation to
be used, including methods of maintenance and calibration of monitoring and sampling equipment to be used.
(F) Site control measures in accordance with the site control program required in paragraph (d) of this section.
(G) Decontamination procedures in accordance with paragraph (k) of this section.
(H) An emergency response plan meeting the requirements of paragraph (l) of this section for safe and effective responses to

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emergencies, including the necessary PPE and other equipment.
(I) Confined space entry procedures.
(J) A spill containment program meeting the requirements of paragraph (j) of this section.
(iii) Pre-entry briefing. The site specific safety and health plan shall provide for pre-entry briefings to be held prior to initiating any
site activity, and at such other times as necessary to ensure that employees are apprised of the site safety and health plan and
that this plan is being followed. The information and data obtained from site characterization and analysis work required in
paragraph (c) of this section shall be used to prepare and update the site safety and health plan.
(iv) Effectiveness of site safety and health plan. Inspections shall be conducted by the site safety and health supervisor or, in the
absence of that individual, another individual who is knowledgeable in occupational safety and health, acting on behalf of the
employer as necessary to determine the effectiveness of the site safety and health plan. Any deficiencies in the effectiveness of
the site safety and health plan shall be corrected by the employer.
(c) Site characterization and analysis —(1) General. Hazardous waste sites shall be evaluated in accordance with this paragraph
to identify specific site hazards and to determine the appropriate safety and health control procedures needed to protect
employees from the identified hazards.
(2) Preliminary evaluation. A preliminary evaluation of a site's characteristics shall be performed prior to site entry by a qualified
person in order to aid in the selection of appropriate employee protection methods prior to site entry. Immediately after initial site
entry, a more detailed evaluation of the site's specific characteristics shall be performed by a qualified person in order to further
identify existing site hazards and to further aid in the selection of the appropriate engineering controls and personal protective
equipment for the tasks to be performed.
(3) Hazard identification. All suspected conditions that may pose inhalation or skin absorption hazards that are immediately
dangerous to life or health (IDLH), or other conditions that may cause death or serious harm, shall be identified during the
preliminary survey and evaluated during the detailed survey. Examples of such hazards include, but are not limited to, confined
space entry, potentially explosive or flammable situations, visible vapor clouds, or areas where biological indicators such as dead
animals or vegetation are located.
(4) Required information. The following information to the extent available shall be obtained by the employer prior to allowing
employees to enter a site:
(i) Location and approximate size of the site.
(ii) Description of the response activity and/or the job task to be performed.
(iii) Duration of the planned employee activity.
(iv) Site topography and accessibility by air and roads.
(v) Safety and health hazards expected at the site.
(vi) Pathways for hazardous substance dispersion.
(vii) Present status and capabilities of emergency response teams that would provide assistance to hazardous waste clean-up site
employees at the time of an emergency.
(viii) Hazardous substances and health hazards involved or expected at the site, and their chemical and physical properties.
(5) Personal protective equipment. Personal protective equipment (PPE) shall be provided and used during initial site entry in
accordance with the following requirements:

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(i) Based upon the results of the preliminary site evaluation, an ensemble of PPE shall be selected and used during initial site
entry which will provide protection to a level of exposure below permissible exposure limits and published exposure levels for
known or suspected hazardous substances and health hazards, and which will provide protection against other known and
suspected hazards identified during the preliminary site evaluation. If there is no permissible exposure limit or published exposure
level, the employer may use other published studies and information as a guide to appropriate personal protective equipment.
(ii) If positive-pressure self-contained breathing apparatus is not used as part of the entry ensemble, and if respiratory protection
is warranted by the potential hazards identified during the preliminary site evaluation, an escape self-contained breathing
apparatus of at least five minute's duration shall be carried by employees during initial site entry.
(iii) If the preliminary site evaluation does not produce sufficient information to identify the hazards or suspected hazards of the
site, an ensemble providing protection equivalent to Level B PPE shall be provided as minimum protection, and direct reading
instruments shall be used as appropriate for identifying IDLH conditions. (See appendix B for a description of Level B hazards and
the recommendations for Level B protective equipment.)
(iv) Once the hazards of the site have been identified, the appropriate PPE shall be selected and used in accordance with
paragraph (g) of this section.
(6) Monitoring. The following monitoring shall be conducted during initial site entry when the site evaluation produces information
that shows the potential for ionizing radiation or IDLH conditions, or when the site information is not sufficient reasonably to
eliminate these possible conditions:
(i) Monitoring with direct reading instruments for hazardous levels of ionizing radiation.
(ii) Monitoring the air with appropriate direct reading test equipment (i.e., combustible gas meters, detector tubes) for IDLH and
other conditions that may cause death or serious harm (combustible or explosive atmospheres, oxygen deficiency, toxic
substances).
(iii) Visually observing for signs of actual or potential IDLH or other dangerous conditions.
(iv) An ongoing air monitoring program in accordance with paragraph (h) of this section shall be implemented after site
characterization has determined the site is safe for the start-up of operations.
(7) Risk identification. Once the presence and concentrations of specific hazardous substances and health hazards have been
established, the risks associated with these substances shall be identified. Employees who will be working on the site shall be
informed of any risks that have been identified. In situations covered by the Hazard Communication Standard, 29 CFR 1910.1200,
training required by that standard need not be duplicated.

Note to paragraph (c)(7). Risks to consider include, but are not limited to:
(a) Exposures exceeding the permissible exposure limits and published exposure levels.
(b) IDLH concentrations.
(c) Potential skin absorption and irritation sources.
(d) Potential eye irritation sources.
(e) Explosion sensitivity and flammability ranges.
(f) Oxygen deficiency.
(8) Employee notification. Any information concerning the chemical, physical, and toxicologic properties of each substance known
or expected to be present on site that is available to the employer and relevant to the duties an employee is expected to perform

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shall be made available to the affected employees prior to the commencement of their work activities. The employer may utilize
information developed for the hazard communication standard for this purpose.
(d) Site control —(1) General. Appropriate site control procedures shall be implemented to control employee exposure to
hazardous substances before clean-up work begins.
(2) Site control program. A site control program for protecting employees which is part of the employer's site safety and health
program required in paragraph (b) of this section shall be developed during the planning stages of a hazardous waste clean-up
operation and modified as necessary as new information becomes available.
(3) Elements of the site control program. The site control program shall, as a minimum, include: A site map; site work zones; the
use of a “buddy system”; site communications including alerting means for emergencies; the standard operating procedures or
safe work practices; and, identification of the nearest medical assistance. Where these requirements are covered elsewhere they
need not be repeated.
(e) Training —(1) General. (i) All employees working on site (such as but not limited to equipment operators, general laborers and
others) exposed to hazardous substances, health hazards, or safety hazards and their supervisors and management responsible
for the site shall receive training meeting the requirements of this paragraph before they are permitted to engage in hazardous
waste operations that could expose them to hazardous substances, safety, or health hazards, and they shall receive review
training as specified in this paragraph.
(ii) Employees shall not be permitted to participate in or supervise field activities until they have been trained to a level required by
their job function and responsibility.
(2) Elements to be covered. The training shall thoroughly cover the following:
(i) Names of personnel and alternates responsible for site safety and health;
(ii) Safety, health and other hazards present on the site;
(iii) Use of personal protective equipment;
(iv) Work practices by which the employee can minimize risks from hazards;
(v) Safe use of engineering controls and equipment on the site;
(vi) Medical surveillance requirements, including recognition of symptoms and signs which might indicate overexposure to
hazards; and
(vii) The contents of paragraphs (G) through (J) of the site safety and health plan set forth in paragraph (b)(4)(ii) of this section.
(3) Initial training. (i) General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in
hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health
hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under
the direct supervision of a trained, experienced supervisor.
(ii) Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land
surveying, or geo-physical surveying) and who are unlikely to be exposed over permissible exposure limits and published
exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience
under the direct supervision of a trained, experienced supervisor.
(iii) Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are
under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization
indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of 24 hours of
instruction off the site and the minimum of one day actual field experience under the direct supervision of a trained, experienced

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supervisor.
(iv) Workers with 24 hours of training who are covered by paragraphs (e)(3)(ii) and (e)(3)(iii) of this section, and who become
general site workers or who are required to wear respirators, shall have the additional 16 hours and two days of training
necessary to total the training specified in paragraph (e)(3)(i).
(4) Management and supervisor training. On-site management and supervisors directly responsible for, or who supervise
employees engaged in, hazardous waste operations shall receive 40 hours initial training, and three days of supervised field
experience (the training may be reduced to 24 hours and one day if the only area of their responsibility is employees covered by
paragraphs (e)(3)(ii) and (e)(3)(iii)) and at least eight additional hours of specialized training at the time of job assignment on such
topics as, but not limited to, the employer's safety and health program and the associated employee training program, personal
protective equipment program, spill containment program, and health hazard monitoring procedure and techniques.
(5) Qualifications for trainers. Trainers shall be qualified to instruct employees about the subject matter that is being presented in
training. Such trainers shall have satisfactorily completed a training program for teaching the subjects they are expected to teach,
or they shall have the academic credentials and instructional experience necessary for teaching the subjects. Instructors shall
demonstrate competent instructional skills and knowledge of the applicable subject matter.
(6) Training certification. Employees and supervisors that have received and successfully completed the training and field
experience specified in paragraphs (e)(1) through (e)(4) of this section shall be certified by their instructor or the head instructor
and trained supervisor as having successfully completed the necessary training. A written certificate shall be given to each person
so certified. Any person who has not been so certified or who does not meet the requirements of paragraph (e)(9) of this section
shall be prohibited from engaging in hazardous waste operations.
(7) Emergency response. Employees who are engaged in responding to hazardous emergency situations at hazardous waste
clean-up sites that may expose them to hazardous substances shall be trained in how to respond to such expected emergencies.
(8) Refresher training. Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in
paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2)
and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of
related work, and other relevant topics.
(9) Equivalent training. Employers who can show by documentation or certification that an employee's work experience and/or
training has resulted in training equivalent to that training required in paragraphs (e)(1) through (e)(4) of this section shall not be
required to provide the initial training requirements of those paragraphs to such employees and shall provide a copy of the
certification or documentation to the employee upon request. However, certified employees or employees with equivalent training
new to a site shall receive appropriate, site specific training before site entry and have appropriate supervised field experience at
the new site. Equivalent training includes any academic training or the training that existing employees might have already
received from actual hazardous waste site work experience.
(f) Medical surveillance —(1) General. Employers engaged in operations specified in paragraphs (a)(1)(i) through (a)(1)(iv) of this
section and not covered by (a)(2)(iii) exceptions and employers of employees specified in paragraph (q)(9) shall institute a
medical surveillance program in accordance with this paragraph.
(2) Employees covered. The medical surveillance program shall be instituted by the employer for the following employees:
(i) All employees who are or may be exposed to hazardous substances or health hazards at or above the permissible exposure
limits or, if there is no permissible exposure limit, above the published exposure levels for these substances, without regard to the
use of respirators, for 30 days or more a year;
(ii) All employees who wear a respirator for 30 days or more a year or as required by §1910.134;
(iii) All employees who are injured, become ill or develop signs or symptoms due to possible overexposure involving hazardous
substances or health hazards from an emergency response or hazardous waste operation; and

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(iv) Members of HAZMAT teams.
(3) Frequency of medical examinations and consultations. Medical examinations and consultations shall be made available by the
employer to each employee covered under paragraph (f)(2) of this section on the following schedules:
(i) For employees covered under paragraphs (f)(2)(i), (f)(2)(ii), and (f)(2)(iv):
(A) Prior to assignment;
(B) At least once every twelve months for each employee covered unless the attending physician believes a longer interval (not
greater than biennially) is appropriate;
(C) At termination of employment or reassignment to an area where the employee would not be covered if the employee has not
had an examination within the last six months;
(D) As soon as possible upon notification by an employee that the employee has developed signs or symptoms indicating
possible overexposure to hazardous substances or health hazards, or that the employee has been injured or exposed above the
permissible exposure limits or published exposure levels in an emergency situation;
(E) At more frequent times, if the examining physician determines that an increased frequency of examination is medically
necessary.
(ii) For employees covered under paragraph (f)(2)(iii) and for all employees including those of employers covered by paragraph
(a)(1)(v) who may have been injured, received a health impairment, developed signs or symptoms which may have resulted from
exposure to hazardous substances resulting from an emergency incident, or exposed during an emergency incident to hazardous
substances at concentrations above the permissible exposure limits or the published exposure levels without the necessary
personal protective equipment being used:
(A) As soon as possible following the emergency incident or development of signs or symptoms;
(B) At additional times, if the examining physician determines that follow-up examinations or consultations are medically
necessary.
(4) Content of medical examinations and consultations. (i) Medical examinations required by paragraph (f)(3) of this section shall
include a medical and work history (or updated history if one is in the employee's file) with special emphasis on symptoms related
to the handling of hazardous substances and health hazards, and to fitness for duty including the ability to wear any required PPE
under conditions (i.e., temperature extremes) that may be expected at the work site.
(ii) The content of medical examinations or consultations made available to employees pursuant to paragraph (f) shall be
determined by the attending physician. The guidelines in the Occupational Safety and Health Guidance Manual for Hazardous
Waste Site Activities (See appendix D, Reference #10) should be consulted.
(5) Examination by a physician and costs. All medical examinations and procedures shall be performed by or under the
supervision of a licensed physician, preferably one knowledgeable in occupational medicine, and shall be provided without cost to
the employee, without loss of pay, and at a reasonable time and place.
(6) Information provided to the physician. The employer shall provide one copy of this standard and its appendices to the
attending physician, and in addition the following for each employee:
(i) A description of the employee's duties as they relate to the employee's exposures.
(ii) The employee's exposure levels or anticipated exposure levels.
(iii) A description of any personal protective equipment used or to be used.

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(iv) Information from previous medical examinations of the employee which is not readily available to the examining physician.
(v) Information required by §1910.134.
(7) Physician's written opinion. (i) The employer shall obtain and furnish the employee with a copy of a written opinion from the
attending physician containing the following:
(A) The physician's opinion as to whether the employee has any detected medical conditions which would place the employee at
increased risk of material impairment of the employee's health from work in hazardous waste operations or emergency response,
or from respirator use.
(B) The physician's recommended limitations upon the employee's assigned work.
(C) The results of the medical examination and tests if requested by the employee.
(D) A statement that the employee has been informed by the physician of the results of the medical examination and any medical
conditions which require further examination or treatment.
(ii) The written opinion obtained by the employer shall not reveal specific findings or diagnoses unrelated to occupational
exposures.
(8) Recordkeeping. (i) An accurate record of the medical surveillance required by paragraph (f) of this section shall be retained.
This record shall be retained for the period specified and meet the criteria of 29 CFR 1910.1020.
(ii) The record required in paragraph (f)(8)(i) of this section shall include at least the following information:
(A) The name and social security number of the employee;
(B) Physician's written opinions, recommended limitations, and results of examinations and tests;
(C) Any employee medical complaints related to exposure to hazardous substances;
(D) A copy of the information provided to the examining physician by the employer, with the exception of the standard and its
appendices.
(g) Engineering controls, work practices, and personal protective equipment for employee protection. Engineering controls, work
practices, personal protective equipment, or a combination of these shall be implemented in accordance with this paragraph to
protect employees from exposure to hazardous substances and safety and health hazards.
(1) Engineering controls, work practices and PPE for substances regulated in subparts G and Z. (i) Engineering controls and work
practices shall be instituted to reduce and maintain employee exposure to or below the permissible exposure limits for substances
regulated by 29 CFR part 1910, to the extent required by subpart Z, except to the extent that such controls and practices are not
feasible.

Note to paragraph (g)(1)(i): Engineering controls which may be feasible include the use of pressurized cabs or
control booths on equipment, and/or the use of remotely operated material handling equipment. Work practices
which may be feasible are removing all non-essential employees from potential exposure during opening of drums,
wetting down dusty operations and locating employees upwind of possible hazards.
(ii) Whenever engineering controls and work practices are not feasible or not required, any reasonable combination of engineering
controls, work practices and PPE shall be used to reduce and maintain employee exposures to or below the permissible exposure
limits or dose limits for substances regulated by 29 CFR part 1910, subpart Z.
(iii) The employer shall not implement a schedule of employee rotation as a means of compliance with permissible exposure limits

11

or dose limits except when there is no other feasible way of complying with the airborne or dermal dose limits for ionizing
radiation.
(iv) The provisions of 29 CFR, subpart G, shall be followed.
(2) Engineering controls, work practices, and PPE for substances not regulated in subparts G and Z. An appropriate combination
of engineering controls, work practices and personal protective equipment shall be used to reduce and maintain employee
exposure to or below published exposure levels for hazardous substances and health hazards not regulated by 29 CFR part
1910, subparts G and Z. The employer may use the published literature and MSDS as a guide in making the employer's
determination as to what level of protection the employer believes is appropriate for hazardous substances and health hazards for
which there is no permissible exposure limit or published exposure limit.
(3) Personal protective equipment selection. (i) Personal protective equipment (PPE) shall be selected and used which will protect
employees from the hazards and potential hazards they are likely to encounter as identified during the site characterization and
analysis.
(ii) Personal protective equipment selection shall be based on an evaluation of the performance characteristics of the PPE relative
to the requirements and limitations of the site, the task-specific conditions and duration, and the hazards and potential hazards
identified at the site.
(iii) Positive pressure self-contained breathing apparatus, or positive pressure air-line respirators equipped with an escape air
supply, shall be used when chemical exposure levels present will create a substantial possibility of immediate death, immediate
serious illness or injury, or impair the ability to escape.
(iv) Totally-encapsulating chemical protective suits (protection equivalent to Level A protection as recommended in appendix B)
shall be used in conditions where skin absorption of a hazardous substance may result in a substantial possibility of immediate
death, immediate serious illness or injury, or impair the ability to escape.
(v) The level of protection provided by PPE selection shall be increased when additional information on site conditions indicates
that increased protection is necessary to reduce employee exposures below permissible exposure limits and published exposure
levels for hazardous substances and health hazards. (See appendix B for guidance on selecting PPE ensembles.)

Note to paragraph (g)(3): The level of employee protection provided may be decreased when additional information
or site conditions show that decreased protection will not result in hazardous exposures to employees.
(vi) Personal protective equipment shall be selected and used to meet the requirements of 29 CFR part 1910, subpart I, and
additional requirements specified in this section.
(4) Totally-encapsulating chemical protective suits. (i) Totally-encapsulating suits shall protect employees from the particular
hazards which are identified during site characterization and analysis.
(ii) Totally-encapsulating suits shall be capable of maintaining positive air pressure. (See appendix A for a test method which may
be used to evaluate this requirement.)
(iii) Totally-encapsulating suits shall be capable of preventing inward test gas leakage of more than 0.5 percent. (See appendix A
for a test method which may be used to evaluate this requirement.)
(5) Personal protective equipment (PPE) program. A written personal protective equipment program, which is part of the
employer's safety and health program required in paragraph (b) of this section or required in paragraph (p)(1) of this section and
which is also a part of the site-specific safety and health plan shall be established. The PPE program shall address the elements
listed below. When elements, such as donning and doffing procedures, are provided by the manufacturer of a piece of equipment
and are attached to the plan, they need not be rewritten into the plan as long as they adequately address the procedure or
element.
(i) PPE selection based upon site hazards,

12

(ii) PPE use and limitations of the equipment,
(iii) Work mission duration,
(iv) PPE maintenance and storage,
(v) PPE decontamination and disposal,
(vi) PPE training and proper fitting,
(vii) PPE donning and doffing procedures,
(viii) PPE inspection procedures prior to, during, and after use,
(ix) Evaluation of the effectiveness of the PPE program, and
(x) Limitations during temperature extremes, heat stress, and other appropriate medical considerations.
(h) Monitoring —(1) General. (i) Monitoring shall be performed in accordance with this paragraph where there may be a question
of employee exposure to hazardous concentrations of hazardous substances in order to assure proper selection of engineering
controls, work practices and personal protective equipment so that employees are not exposed to levels which exceed
permissible exposure limits, or published exposure levels if there are no permissible exposure limits, for hazardous substances.
(ii) Air monitoring shall be used to identify and quantify airborne levels of hazardous substances and safety and health hazards in
order to determine the appropriate level of employee protection needed on site.
(2) Initial entry. Upon initial entry, representative air monitoring shall be conducted to identify any IDLH condition, exposure over
permissible exposure limits or published exposure levels, exposure over a radioactive material's dose limits or other dangerous
condition such as the presence of flammable atmospheres or oxygen-deficient environments.
(3) Periodic monitoring. Periodic monitoring shall be 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. Situations where it shall be considered whether the possibility that exposures
have risen are as follows:
(i) When work begins on a different portion of the site.
(ii) When contaminants other than those previously identified are being handled.
(iii) When a different type of operation is initiated (e.g., drum opening as opposed to exploratory well drilling).
(iv) When employees are handling leaking drums or containers or working in areas with obvious liquid contamination (e.g., a spill
or lagoon).
(4) Monitoring of high-risk employees. After the actual clean-up phase of any hazardous waste operation commences; for
example, when soil, surface water or containers are moved or disturbed; the employer shall monitor those employees likely to
have the highest exposures to hazardous substances and health hazards likely to be present above permissible exposure limits or
published exposure levels by using personal sampling frequently enough to characterize employee exposures. If the employees
likely to have the highest exposure are over permissible exposure limits or published exposure limits, then monitoring shall
continue to determine all employees likely to be above those limits. The employer may utilize a representative sampling approach
by documenting that the employees and chemicals chosen for monitoring are based on the criteria stated above.

Note to paragraph (h): It is not required to monitor employees engaged in site characterization operations covered by

13

paragraph (c) of this section.
(i) Informational programs. Employers shall develop and implement a program, which is part of the employer's safety and health
program required in paragraph (b) of this section, to inform employees, contractors, and subcontractors (or their representative)
actually engaged in hazardous waste operations of the nature, level and degree of exposure likely as a result of participation in
such hazardous waste operations. Employees, contractors and subcontractors working outside of the operations part of a site are
not covered by this standard.
(j) Handling drums and containers —(1) General. (i) Hazardous substances and contaminated soils, liquids, and other residues
shall be handled, transported, labeled, and disposed of in accordance with this paragraph.
(ii) Drums and containers used during the clean-up shall meet the appropriate DOT, OSHA, and EPA regulations for the wastes
that they contain.
(iii) When practical, drums and containers shall be inspected and their integrity shall be assured prior to being moved. Drums or
containers that cannot be inspected before being moved because of storage conditions (i.e., buried beneath the earth, stacked
behind other drums, stacked several tiers high in a pile, etc.) shall be moved to an accessible location and inspected prior to
further handling.
(iv) Unlabelled drums and containers shall be considered to contain hazardous substances and handled accordingly until the
contents are positively identified and labeled.
(v) Site operations shall be organized to minimize the amount of drum or container movement.
(vi) Prior to movement of drums or containers, all employees exposed to the transfer operation shall be warned of the potential
hazards associated with the contents of the drums or containers.
(vii) U.S. Department of Transportation specified salvage drums or containers and suitable quantities of proper absorbent shall be
kept available and used in areas where spills, leaks, or ruptures may occur.
(viii) Where major spills may occur, a spill containment program, which is part of the employer's safety and health program
required in paragraph (b) of this section, shall be implemented to contain and isolate the entire volume of the hazardous
substance being transferred.
(ix) Drums and containers that cannot be moved without rupture, leakage, or spillage shall be emptied into a sound container
using a device classified for the material being transferred.
(x) A ground-penetrating system or other type of detection system or device shall be used to estimate the location and depth of
buried drums or containers.
(xi) Soil or covering material shall be removed with caution to prevent drum or container rupture.
(xii) Fire extinguishing equipment meeting the requirements of 29 CFR part 1910, subpart L, shall be on hand and ready for use to
control incipient fires.
(2) Opening drums and containers. The following procedures shall be followed in areas where drums or containers are being
opened:
(i) Where an airline respirator system is used, connections to the source of air supply shall be protected from contamination and
the entire system shall be protected from physical damage.
(ii) Employees not actually involved in opening drums or containers shall be kept a safe distance from the drums or containers
being opened.
(iii) If employees must work near or adjacent to drums or containers being opened, a suitable shield that does not interfere with

14

the work operation shall be placed between the employee and the drums or containers being opened to protect the employee in
case of accidental explosion.
(iv) Controls for drum or container opening equipment, monitoring equipment, and fire suppression equipment shall be located
behind the explosion-resistant barrier.
(v) When there is a reasonable possibility of flammable atmospheres being present, material handling equipment and hand tools
shall be of the type to prevent sources of ignition.
(vi) Drums and containers shall be opened in such a manner that excess interior pressure will be safely relieved. If pressure can
not be relieved from a remote location, appropriate shielding shall be placed between the employee and the drums or containers
to reduce the risk of employee injury.
(vii) Employees shall not stand upon or work from drums or containers.
(3) Material handling equipment. Material handiing equipment used to transfer drums and containers shall be selected, positioned
and operated to minimize sources of ignition related to the equipment from igniting vapors released from ruptured drums or
containers.
(4) Radioactive wastes. Drums and containers containing radioactive wastes shall not be handled until such time as their hazard
to employees is properly assessed.
(5) Shock sensitive wastes. As a minimum, the following special precautions shall be taken when drums and containers
containing or suspected of containing shock-sensitive wastes are handled:
(i) All non-essential employees shall be evacuated from the area of transfer.
(ii) Material handling equipment shall be provided with explosive containment devices or protective shields to protect equipment
operators from exploding containers.
(iii) An employee alarm system capable of being perceived above surrounding light and noise conditions shall be used to signal
the commencement and completion of explosive waste handling activities.
(iv) Continuous communications (i.e., portable radios, hand signals, telephones, as appropriate) shall be maintained between the
employee-in-charge of the immediate handling area and both the site safety and health supervisor and the command post until
such time as the handling operation is completed. Communication equipment or methods that could cause shock sensitive
materials to explode shall not be used.
(v) Drums and containers under pressure, as evidenced by bulging or swelling, shall not be moved until such time as the cause
for excess pressure is determined and appropriate containment procedures have been implemented to protect employees from
explosive relief of the drum.
(vi) Drums and containers containing packaged laboratory wastes shall be considered to contain shock-sensitive or explosive
materials until they have been characterized.

Caution:Shipping of shock sensitive wastes may be prohibited under U.S. Department of Transportation regulations.
Employers and their shippers should refer to 49 CFR 173.21 and 173.50.
(6) Laboratory waste packs. In addition to the requirements of paragraph (j)(5) of this section, the following precautions shall be
taken, as a minimum, in handling laboratory waste packs (lab packs):
(i) Lab packs shall be opened only when necessary and then only by an individual knowledgeable in the inspection, classification,
and segregation of the containers within the pack according to the hazards of the wastes.
(ii) If crystalline material is noted on any container, the contents shall be handled as a shock-sensitive waste until the contents are

15

identified.
(7) Sampling of drum and container contents. Sampling of containers and drums shall be done in accordance with a sampling
procedure which is part of the site safety and health plan developed for and available to employees and others at the specific
worksite.
(8) Shipping and transport. (i) Drums and containers shall be identified and classified prior to packaging for shipment.
(ii) Drum or container staging areas shall be kept to the minimum number necessary to identify and classify materials safely and
prepare them for transport.
(iii) Staging areas shall be provided with adequate access and egress routes.
(iv) Bulking of hazardous wastes shall be permitted only after a thorough characterization of the materials has been completed.
(9) Tank and vault procedures. (i) Tanks and vaults containing hazardous substances shall be handled in a manner similar to that
for drums and containers, taking into consideration the size of the tank or vault.
(ii) Appropriate tank or vault entry procedures as described in the employer's safety and health plan shall be followed whenever
employees must enter a tank or vault.
(k) Decontamination —(1) General. Procedures for all phases of decontamination shall be developed and implemented in
accordance with this paragraph.
(2) Decontamination procedures. (i) A decontamination procedure shall be developed, communicated to employees and
implemented before any employees or equipment may enter areas on site where potential for exposure to hazardous substances
exists.
(ii) Standard operating procedures shall be developed to minimize employee contact with hazardous substances or with
equipment that has contacted hazardous substances.
(iii) All employees leaving a contaminated area shall be appropriately decontaminated; all contaminated clothing and equipment
leaving a contaminated area shall be appropriately disposed of or decontaminated.
(iv) Decontamination procedures shall be monitored by the site safety and health supervisor to determine their effectiveness.
When such procedures are found to be ineffective, appropriate steps shall be taken to correct any deficiencies.
(3) Location. Decontamination shall be performed in geographical areas that will minimize the exposure of uncontaminated
employees or equipment to contaminated employees or equipment.
(4) Equipment and solvents. All equipment and solvents used for decontamination shall be decontaminated or disposed of
properly.
(5) Personal protective clothing and equipment. (i) Protective clothing and equipment shall be decontaminated, cleaned,
laundered, maintained or replaced as needed to maintain their effectiveness.
(ii) Employees whose non-impermeable clothing becomes wetted with hazardous substances shall immediately remove that
clothing and proceed to shower. The clothing shall be disposed of or decontaminated before it is removed from the work zone.
(6) Unauthorized employees. Unauthorized employees shall not remove protective clothing or equipment from change rooms.
(7) Commercial laundries or cleaning establishments. Commercial laundries or cleaning establishments that decontaminate
protective clothing or equipment shall be informed of the potentially harmful effects of exposures to hazardous substances.

16

(8) Showers and change rooms. Where the decontamination procedure indicates a need for regular showers and change rooms
outside of a contaminated area, they shall be provided and meet the requirements of 29 CFR 1910.141. If temperature conditions
prevent the effective use of water, then other effective means for cleansing shall be provided and used.
(l) Emergency response by employees at uncontrolled hazardous waste sites —(1) Emergency response plan. (i) An emergency
response plan shall be developed and implemented by all employers within the scope of paragraphs (a)(1) (i)–(ii) of this section to
handle anticipated emergencies prior to the commencement of hazardous waste operations. The plan shall be in writing and
available for inspection and copying by employees, their representatives, OSHA personnel and other governmental agencies with
relevant responsibilities.
(ii) Employers who will evacuate their employees from the danger area when an emergency occurs, and who do not permit any of
their employees to assist in handling the emergency, are exempt from the requirements of this paragraph if they provide an
emergency action plan complying with 29 CFR 1910.38.
(2) Elements of an emergency response plan. The employer shall develop an emergency response plan for emergencies which
shall address, as a minimum, the following:
(i) Pre-emergency planning.
(ii) Personnel roles, lines of authority, and communication.
(iii) Emergency recognition and prevention.
(iv) Safe distances and places of refuge.
(v) Site security and control.
(vi) Evacuation routes and procedures.
(vii) Decontamination procedures which are not covered by the site safety and health plan.
(viii) Emergency medical treatment and first aid.
(ix) Emergency alerting and response procedures.
(x) Critique of response and follow-up.
(xi) PPE and emergency equipment.
(3) Procedures for handling emergency incidents. (i) In addition to the elements for the emergency response plan required in
paragraph (l)(2) of this section, the following elements shall be included for emergency response plans:
(A) Site topography, layout, and prevailing weather conditions.
(B) Procedures for reporting incidents to local, state, and federal governmental agencies.
(ii) The emergency response plan shall be a separate section of the Site Safety and Health Plan.
(iii) The emergency response plan shall be compatible and integrated with the disaster, fire and/or emergency response plans of
local, state, and federal agencies.
(iv) The emergency response plan shall be rehearsed regularly as part of the overall training program for site operations.
(v) The site emergency response plan shall be reviewed periodically and, as necessary, be amended to keep it current with new

17

or changing site conditions or information.
(vi) An employee alarm system shall be installed in accordance with 29 CFR 1910.165 to notify employees of an emergency
situation; to stop work activities if necessary; to lower background noise in order to speed communication; and to begin
emergency procedures.
(vii) Based upon the information available at time of the emergency, the employer shall evaluate the incident and the site
response capabilities and proceed with the appropriate steps to implement the site emergency response plan.
(m) Illumination. Areas accessible to employees shall be lighted to not less than the minimum illumination intensities listed in the
following Table H–120.1 while any work is in progress:
Table H–120.1—Minimum Illumination Intensities in Foot-Candles

Footcandles

Area or operations

5

General site areas.

3

Excavation and waste areas, accessways, active storage areas, loading platforms, refueling, and
field maintenance areas.

5

Indoors: Warehouses, corridors, hallways, and exitways.

5

Tunnels, shafts, and general underground work areas. (Exception: Minimum of 10 foot-candles
is required at tunnel and shaft heading during drilling mucking, and scaling. Mine Safety and
Health Administration approved cap lights shall be acceptable for use in the tunnel heading.)

10

General shops (e.g., mechanical and electrical equipment rooms, active storerooms, barracks or
living quarters, locker or dressing rooms, dining areas, and indoor toilets and workrooms.)

30

First aid stations, infirmaries, and offices.

(n) Sanitation at temporary workplaces —(1) Potable water. (i) An adequate supply of potable water shall be provided on the site.
(ii) Portable containers used to dispense drinking water shall be capable of being tightly closed, and equipped with a tap. Water
shall not be dipped from containers.
(iii) Any container used to distribute drinking water shall be clearly marked as to the nature of its contents and not used for any
other purpose.
(iv) Where single service cups (to be used but once) are supplied, both a sanitary container for the unused cups and a receptacle
for disposing of the used cups shall be provided.
(2) Nonpotable water. (i) Outlets for nonpotable water, such as water for firefighting purposes, shall be identified to indicate clearly
that the water is unsafe and is not to be used for drinking, washing, or cooking purposes.
(ii) There shall be no cross-connection, open or potential, between a system furnishing potable water and a system furnishing
nonpotable water.
(3) Toilet facilities. (i) Toilets shall be provided for employees according to the following Table H–120.2.

18

Table H–120.2—Toilet Facilities

Number of employees

Minimum number of facilities

20 or fewer

One.

More than 20, fewer than 200

One toilet seat and one urinal per 40 employees.

More than 200

One toilet seat and one urinal per 50 employees.

(ii) Under temporary field conditions, provisions shall be made to assure that at least one toilet facility is available.
(iii) Hazardous waste sites not provided with a sanitary sewer shall be provided with the following toilet facilities unless prohibited
by local codes:
(A) Chemical toilets;
(B) Recirculating toilets;
(C) Combustion toilets; or
(D) Flush toilets.
(iv) The requirements of this paragraph for sanitation facilities shall not apply to mobile crews having transportation readily
available to nearby toilet facilities.
(v) Doors entering toilet facilities shall be provided with entrance locks controlled from inside the facility.
(4) Food handling. All food service facilities and operations for employees shall meet the applicable laws, ordinances, and
regulations of the jurisdictions in which they are located.
(5) Temporary sleeping quarters. When temporary sleeping quarters are provided, they shall be heated, ventilated, and lighted.
(6) Washing facilities. The employer shall provide adequate washing facilities for employees engaged in operations where
hazardous substances may be harmful to employees. Such facilities shall be in near proximity to the worksite; in areas where
exposures are below permissible exposure limits and published exposure levels and which are under the controls of the employer;
and shall be so equipped as to enable employees to remove hazardous substances from themselves.
(7) Showers and change rooms. When hazardous waste clean-up or removal operations commence on a site and the duration of
the work will require six months or greater time to complete, the employer shall provide showers and change rooms for all
employees exposed to hazardous substances and health hazards involved in hazardous waste clean-up or removal operations.
(i) Showers shall be provided and shall meet the requirements of 29 CFR 1910.141(d)(3).
(ii) Change rooms shall be provided and shall meet the requirements of 29 CFR 1910.141(e). Change rooms shall consist of two
separate change areas separated by the shower area required in paragraph (n)(7)(i) of this section. One change area, with an exit
leading off the worksite, shall provide employees with a clean area where they can remove, store, and put on street clothing. The
second area, with an exit to the worksite, shall provide employees with an area where they can put on, remove and store work
clothing and personal protective equipment.
(iii) Showers and change rooms shall be located in areas where exposures are below the permissible exposure limits and
published exposure levels. If this cannot be accomplished, then a ventilation system shall be provided that will supply air that is
below the permissible exposure limits and published exposure levels.

19

(iv) Employers shall assure that employees shower at the end of their work shift and when leaving the hazardous waste site.
(o) New technology programs. (1) The employer shall develop and implement procedures for the introduction of effective new
technologies and equipment developed for the improved protection of employees working with hazardous waste clean-up
operations, and the same shall be implemented as part of the site safety and health program to assure that employee protection is
being maintained.
(2) New technologies, equipment or control measures available to the industry, such as the use of foams, absorbents, adsorbents,
neutralizers, or other means to suppress the level of air contaminates while excavating the site or for spill control, shall be
evaluated by employers or their representatives. Such an evaluation shall be done to determine the effectiveness of the new
methods, materials, or equipment before implementing their use on a large scale for enhancing employee protection. Information
and data from manufacturers or suppliers may be used as part of the employer's evaluation effort. Such evaluations shall be
made available to OSHA upon request.
(p) Certain Operations Conducted Under the Resource Conservation and Recovery Act of 1976 (RCRA). Employers conducting
operations at treatment, storage and disposal (TSD) facilities specified in paragraph (a)(1)(iv) of this section shall provide and
implement the programs specified in this paragraph. See the “Notes and Exceptions” to paragraph (a)(2)(iii) of this section for
employers not covered.)”.
(1) Safety and health program. The employer shall develop and implement a written safety and health program for employees
involved in hazardous waste operations that shall be available for inspection by employees, their representatives and OSHA
personnel. The program shall be designed to identify, evaluate and control safety and health hazards in their facilities for the
purpose of employee protection, to provide for emergency response meeting the requirements of paragraph (p)(8) of this section
and to address as appropriate site analysis, engineering controls, maximum exposure limits, hazardous waste handling
procedures and uses of new technologies.
(2) Hazard communication program. The employer shall implement a hazard communication program meeting the requirements
of 29 CFR 1910.1200 as part of the employer's safety and program.

Note to §1910.120: The exemption for hazardous waste provided in §1910.1200 is applicable to this section.
(3) Medical surveillance program. The employer shall develop and implement a medical surveillance program meeting the
requirements of paragraph (f) of this section.
(4) Decontamination program. The employer shall develop and implement a decontamination procedure meeting the requirements
of paragraph (k) of this section.
(5) New technology program. The employer shall develop and implement procedures meeting the requirements of paragraph (o)
of this section for introducing new and innovative equipment into the workplace.
(6) Material handling program. Where employees will be handling drums or containers, the employer shall develop and implement
procedures meeting the requirements of paragraphs (j)(1) (ii) through (viii) and (xi) of this section, as well as (j)(3) and (j)(8) of this
section prior to starting such work.
(7) Training program —(i) New employees. The employer shall develop and implement a training program, which is part of the
employer's safety and health program, for employees exposed to health hazards or hazardous substances at TSD operations to
enable the employees to perform their assigned duties and functions in a safe and healthful manner so as not endanger
themselves or other employees. The initial training shall be for 24 hours and refresher training shall be for eight hours annually.
Employees who have received the initial training required by this paragraph shall be given a written certificate attesting that they
have successfully completed the necessary training.
(ii) Current employees. Employers who can show by an employee's previous work experience and/or training that the employee
has had training equivalent to the initial training required by this paragraph, shall be considered as meeting the initial training
requirements of this paragraph as to that employee. Equivalent training includes the training that existing employees might have
already received from actual site work experience. Current employees shall receive eight hours of refresher training annually.

20

(iii) Trainers. Trainers who teach initial training shall have satisfactorily completed a training course for teaching the subjects they
are expected to teach or they shall have the academic credentials and instruction experience necessary to demonstrate a good
command of the subject matter of the courses and competent instructional skills.
(8) Emergency response program —(i) Emergency response plan. An emergency response plan shall be developed and
implemented by all employers. Such plans need not duplicate any of the subjects fully addressed in the employer's contingency
planning required by permits, such as those issued by the U.S. Environmental Protection Agency, provided that the contingency
plan is made part of the emergency response plan. The emergency response plan shall be a written portion of the employer's
safety and health program required in paragraph (p)(1) of this section. Employers who will evacuate their employees from the
worksite location when an emergency occurs and who do not permit any of their employees to assist in handling the emergency
are exempt from the requirements of paragraph (p)(8) if they provide an emergency action plan complying with 29 CFR 1910.38.
(ii) Elements of an emergency response plan. The employer shall develop an emergency response plan for emergencies which
shall address, as a minimum, the following areas to the extent that they are not addressed in any specific program required in this
paragraph:
(A) Pre-emergency planning and coordination with outside parties.
(B) Personnel roles, lines of authority, and communication.
(C) Emergency recognition and prevention.
(D) Safe distances and places of refuge.
(E) Site security and control.
(F) Evacuation routes and procedures.
(G) Decontamination procedures.
(H) Emergency medical treatment and first aid.
(I) Emergency alerting and response procedures.
(J) Critique of response and follow-up.
(K) PPE and emergency equipment.
(iii) Training. (A) Training for emergency response employees shall be completed before they are called upon to perform in real
emergencies. Such training shall include the elements of the emergency response plan, standard operating procedures the
employer has established for the job, the personal protective equipment to be worn and procedures for handling emergency
incidents.

Exception #1: An employer need not train all employees to the degree specified if the employer divides the work
force in a manner such that a sufficient number of employees who have responsibility to control emergencies have
the training specified, and all other employees, who may first respond to an emergency incident, have sufficient
awareness training to recognize that an emergency response situation exists and that they are instructed in that case
to summon the fully trained employees and not attempt control activities for which they are not trained.
Exception #2: An employer need not train all employees to the degree specified if arrangements have been made in
advance for an outside fully-trained emergency response team to respond in a reasonable period and all employees,
who may come to the incident first, have sufficient awareness training to recognize that an emergency response
situation exists and they have been instructed to call the designated outside fully-trained emergency response team

21

for assistance.
(B) Employee members of TSD facility emergency response organizations shall be trained to a level of competence in the
recognition of health and safety hazards to protect themselves and other employees. This would include training in the methods
used to minimize the risk from safety and health hazards; in the safe use of control equipment; in the selection and use of
appropriate personal protective equipment; in the safe operating procedures to be used at the incident scene; in the techniques of
coordination with other employees to minimize risks; in the appropriate response to over exposure from health hazards or injury to
themselves and other employees; and in the recognition of subsequent symptoms which may result from over exposures.
(C) The employer shall certify that each covered employee has attended and successfully completed the training required in
paragraph (p)(8)(iii) of this section, or shall certify the employee's competency at least yearly. The method used to demonstrate
competency for certification of training shall be recorded and maintained by the employer.
(iv) Procedures for handling emergency incidents. (A) In addition to the elements for the emergency response plan required in
paragraph (p)(8)(ii) of this section, the following elements shall be included for emergency response plans to the extent that they
do not repeat any information already contained in the emergency response plan:
( 1 ) Site topography, layout, and prevailing weather conditions.
( 2 ) Procedures for reporting incidents to local, state, and federal governmental agencies.
(B) The emergency response plan shall be compatible and integrated with the disaster, fire and/or emergency response plans of
local, state, and federal agencies.
(C) The emergency response plan shall be rehearsed regularly as part of the overall training program for site operations.
(D) The site emergency response plan shall be reviewed periodically and, as necessary, be amended to keep it current with new
or changing site conditions or information.
(E) An employee alarm system shall be installed in accordance with 29 CFR 1910.165 to notify employees of an emergency
situation; to stop work activities if necessary; to lower background noise in order to speed communication; and to begin
emergency procedures.
(F) Based upon the information available at time of the emergency, the employer shall evaluate the incident and the site response
capabilities and proceed with the appropriate steps to implement the site emergency response plan.
(q) Emergency response to hazardous substance releases. This paragraph covers employers whose employees are engaged in
emergency response no matter where it occurs except that it does not cover employees engaged in operations specified in
paragraphs (a)(1)(i) through (a)(1)(iv) of this section. Those emergency response organizations who have developed and
implemented programs equivalent to this paragraph for handling releases of hazardous substances pursuant to section 303 of the
Superfund Amendments and Reauthorization Act of 1986 (Emergency Planning and Community Right-to-Know Act of 1986, 42
U.S.C. 11003) shall be deemed to have met the requirements of this paragraph.
(1) Emergency response plan. An emergency response plan shall be developed and implemented to handle anticipated
emergencies prior to the commencement of emergency response operations. The plan shall be in writing and available for
inspection and copying by employees, their representatives and OSHA personnel. Employers who will evacuate their employees
from the danger area when an emergency occurs, and who do not permit any of their employees to assist in handling the
emergency, are exempt from the requirements of this paragraph if they provide an emergency action plan in accordance with 29
CFR 1910.38.
(2) Elements of an emergency response plan. The employer shall develop an emergency response plan for emergencies which
shall address, as a minimum, the following to the extent that they are not addressed elsewhere:
(i) Pre-emergency planning and coordination with outside parties.

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(ii) Personnel roles, lines of authority, training, and communication.
(iii) Emergency recognition and prevention.
(iv) Safe distances and places of refuge.
(v) Site security and control.
(vi) Evacuation routes and procedures.
(vii) Decontamination.
(viii) Emergency medical treatment and first aid.
(ix) Emergency alerting and response procedures.
(x) Critique of response and follow-up.
(xi) PPE and emergency equipment.
(xii) Emergency response organizations may use the local emergency response plan or the state emergency response plan or
both, as part of their emergency response plan to avoid duplication. Those items of the emergency response plan that are being
properly addressed by the SARA Title III plans may be substituted into their emergency plan or otherwise kept together for the
employer and employee's use.
(3) Procedures for handling emergency response. (i) The senior emergency response official responding to an emergency shall
become the individual in charge of a site-specific Incident Command System (ICS). All emergency responders and their
communications shall be coordinated and controlled through the individual in charge of the ICS assisted by the senior official
present for each employer.

Note to paragraph (q)(3)(i). The “senior official” at an emergency response is the most senior official on the site who
has the responsibility for controlling the operations at the site. Initially it is the senior officer on the first-due piece of
responding emergency apparatus to arrive on the incident scene. As more senior officers arrive (i.e., battalion chief,
fire chief, state law enforcement official, site coordinator, etc.) the position is passed up the line of authority which
has been previously established.
(ii) The individual in charge of the ICS shall identify, to the extent possible, all hazardous substances or conditions present and
shall address as appropriate site analysis, use of engineering controls, maximum exposure limits, hazardous substance handling
procedures, and use of any new technologies.
(iii) Based on the hazardous substances and/or conditions present, the individual in charge of the ICS shall implement appropriate
emergency operations, and assure that the personal protective equipment worn is appropriate for the hazards to be encountered.
However, personal protective equipment shall meet, at a minimum, the criteria contained in 29 CFR 1910.156(e) when worn while
performing fire fighting operations beyond the incipient stage for any incident.
(iv) Employees engaged in emergency response and exposed to hazardous substances presenting an inhalation hazard or
potential inhalation hazard shall wear positive pressure self-contained breathing apparatus while engaged in emergency
response, until such time that the individual in charge of the ICS determines through the use of air monitoring that a decreased
level of respiratory protection will not result in hazardous exposures to employees.
(v) The individual in charge of the ICS shall limit the number of emergency response personnel at the emergency site, in those
areas of potential or actual exposure to incident or site hazards, to those who are actively performing emergency operations.
However, operations in hazardous areas shall be performed using the buddy system in groups of two or more.

23

(vi) Back-up personnel shall stand by with equipment ready to provide assistance or rescue. Advance first aid support personnel,
as a minimum, shall also stand by with medical equipment and transportation capability.
(vii) The individual in charge of the ICS shall designate a safety official, who is knowledgable in the operations being implemented
at the emergency response site, with specific responsibility to identify and evaluate hazards and to provide direction with respect
to the safety of operations for the emergency at hand.
(viii) When activities are judged by the safety official to be an IDLH condition and/or to involve an imminent danger condition, the
safety official shall have the authority to alter, suspend, or terminate those activities. The safety official shall immediately inform
the individual in charge of the ICS of any actions needed to be taken to correct these hazards at the emergency scene.
(ix) After emergency operations have terminated, the individual in charge of the ICS shall implement appropriate decontamination
procedures.
(x) When deemed necessary for meeting the tasks at hand, approved self-contained compressed air breathing apparatus may be
used with approved cylinders from other approved self-contained compressed air breathing apparatus provided that such
cylinders are of the same capacity and pressure rating. All compressed air cylinders used with self-contained breathing apparatus
shall meet U.S. Department of Transportation and National Institute for Occupational Safety and Health criteria.
(4) Skilled support personnel. Personnel, not necessarily an employer's own employees, who are skilled in the operation of certain
equipment, such as mechanized earth moving or digging equipment or crane and hoisting equipment, and who are needed
temporarily to perform immediate emergency support work that cannot reasonably be performed in a timely fashion by an
employer's own employees, and who will be or may be exposed to the hazards at an emergency response scene, are not
required to meet the training required in this paragraph for the employer's regular employees. However, these personnel shall be
given an initial briefing at the site prior to their participation in any emergency response. The initial briefing shall include instruction
in the wearing of appropriate personal protective equipment, what chemical hazards are involved, and what duties are to be
performed. All other appropriate safety and health precautions provided to the employer's own employees shall be used to assure
the safety and health of these personnel.
(5) Specialist employees. Employees who, in the course of their regular job duties, work with and are trained in the hazards of
specific hazardous substances, and who will be called upon to provide technical advice or assistance at a hazardous substance
release incident to the individual in charge, shall receive training or demonstrate competency in the area of their specialization
annually.
(6) Training. Training shall be based on the duties and function to be performed by each responder of an emergency response
organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard,
shall be conveyed to them through training before they are permitted to take part in actual emergency operations on an incident.
Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance with the
following paragraphs:
(i) First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a
hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper
authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the
awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the
following areas:
(A) An understanding of what hazardous substances are, and the risks associated with them in an incident.
(B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.
(C) The ability to recognize the presence of hazardous substances in an emergency.
(D) The ability to identify the hazardous substances, if possible.
(E) An understanding of the role of the first responder awareness individual in the employer's emergency response plan including

24

site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.
(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
(ii) First responder operations level. First responders at the operations level are individuals who respond to releases or potential
releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property,
or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to
stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures.
First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to
objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer
shall so certify:
(A) Knowledge of the basic hazard and risk assessment techniques.
(B) Know how to select and use proper personal protective equipment provided to the first responder operational level.
(C) An understanding of basic hazardous materials terms.
(D) Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and
personal protective equipment available with their unit.
(E) Know how to implement basic decontamination procedures.
(F) An understanding of the relevant standard operating procedures and termination procedures.
(iii) Hazardous materials technician. Hazardous materials technicians are individuals who respond to releases or potential
releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations
level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance.
Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and
in addition have competency in the following areas and the employer shall so certify:
(A) Know how to implement the employer's emergency response plan.
(B) Know the classification, identification and verification of known and unknown materials by using field survey instruments and
equipment.
(C) Be able to function within an assigned role in the Incident Command System.
(D) Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials
technician.
(E) Understand hazard and risk assessment techniques.
(F) Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and
personal protective equipment available with the unit.
(G) Understand and implement decontamination procedures.
(H) Understand termination procedures.
(I) Understand basic chemical and toxicological terminology and behavior.
(iv) Hazardous materials specialist. Hazardous materials specialists are individuals who respond with and provide support to
hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require

25

a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials
specialist would also act as the site liaison with Federal, state, local and other government authorities in regards to site activities.
Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition have
competency in the following areas and the employer shall so certify:
(A) Know how to implement the local emergency response plan.
(B) Understand classification, identification and verification of known and unknown materials by using advanced survey
instruments and equipment.
(C) Know of the state emergency response plan.
(D) Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials
specialist.
(E) Understand in-depth hazard and risk techniques.
(F) Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and
personal protective equipment available.
(G) Be able to determine and implement decontamination procedures.
(H) Have the ability to develop a site safety and control plan.
(I) Understand chemical, radiological and toxicological terminology and behavior.
(v) On scene incident commander. Incident commanders, who will assume control of the incident scene beyond the first
responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition
have competency in the following areas and the employer shall so certify:
(A) Know and be able to implement the employer's incident command system.
(B) Know how to implement the employer's emergency response plan.
(C) Know and understand the hazards and risks associated with employees working in chemical protective clothing.
(D) Know how to implement the local emergency response plan.
(E) Know of the state emergency response plan and of the Federal Regional Response Team.
(F) Know and understand the importance of decontamination procedures.
(7) Trainers. Trainers who teach any of the above training subjects shall have satisfactorily completed a training course for
teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy, or they shall
have the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional
skills and a good command of the subject matter of the courses they are to teach.
(8) Refresher training. (i) Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive
annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in
those areas at least yearly.
(ii) A statement shall be made of the training or competency, and if a statement of competency is made, the employer shall keep a
record of the methodology used to demonstrate competency.

26

(9) Medical surveillance and consultation. (i) Members of an organized and designated HAZMAT team and hazardous materials
specialists shall receive a baseline physical examination and be provided with medical surveillance as required in paragraph (f) of
this section.
(ii) Any emergency response employees who exhibits signs or symptoms which may have resulted from exposure to hazardous
substances during the course of an emergency incident, either immediately or subsequently, shall be provided with medical
consultation as required in paragraph (f)(3)(ii) of this section.
(10) Chemical protective clothing. Chemical protective clothing and equipment to be used by organized and designated HAZMAT
team members, or to be used by hazardous materials specialists, shall meet the requirements of paragraphs (g) (3) through (5) of
this section.
(11) Post-emergency response operations. Upon completion of the emergency response, if it is determined that it is necessary to
remove hazardous substances, health hazards, and materials contaminated with them (such as contaminated soil or other
elements of the natural environment) from the site of the incident, the employer conducting the clean-up shall comply with one of
the following:
(i) Meet all of the requirements of paragraphs (b) through (o) of this section; or
(ii) Where the clean-up is done on plant property using plant or workplace employees, such employees shall have completed the
training requirements of the following: 29 CFR 1910.38, 1910.134, 1910.1200, and other appropriate safety and health training
made necessary by the tasks they are expected to perform such as personal protective equipment and decontamination
procedures. All equipment to be used in the performance of the clean-up work shall be in serviceable condition and shall have
been inspected prior to use.

Appendices to §1910.120—Hazardous Waste Operations and Emergency Response
Note: The following appendices serve as non-mandatory guidelines to assist employees and employers in complying
with the appropriate requirements of this section. However paragraph 1910.120(g) makes mandatory in certain
circumstances the use of Level A and Level B PPE protection.
Appendix A to §1910.120—Personal Protective Equipment Test Methods
This appendix sets forth the non-mandatory examples of tests which may be used to evaluate compliance with
§1910.120 (g)(4) (ii) and (iii). Other tests and other challenge agents may be used to evaluate compliance.
A. Totally-encapsulating chemical protective suit pressure test
1.0—Scope
1.1 This practice measures the ability of a gas tight totally-encapsulating chemical protective suit material, seams,
and closures to maintain a fixed positive pressure. The results of this practice allow the gas tight integrity of a totallyencapsulating chemical protective suit to be evaluated.
1.2 Resistance of the suit materials to permeation, penetration, and degradation by specific hazardous substances
is not determined by this test method.
2.0—Definition of terms
2.1 Totally-encapsulated chemical protective suit (TECP suit) means a full body garment which is constructed of
protective clothing materials; covers the wearer's torso, head, arms, legs and respirator; may cover the wearer's
hands and feet with tightly attached gloves and boots; completely encloses the wearer and respirator by itself or in

27

combination with the wearer's gloves and boots.
2.2 Protective clothing material means any material or combination of materials used in an item of clothing for the
purpose of isolating parts of the body from direct contact with a potentially hazardous liquid or gaseous chemicals.
2.3 Gas tight means, for the purpose of this test method, the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed pressure and time interval.
3.0—Summary of test method
3.1 The TECP suit is visually inspected and modified for the test. The test apparatus is attached to the suit to permit
inflation to the pre-test suit expansion pressure for removal of suit wrinkles and creases. The pressure is lowered to
the test pressure and monitored for three minutes. If the pressure drop is excessive, the TECP suit fails the test and
is removed from service. The test is repeated after leak location and repair.
4.0—Required Supplies
4.1 Source of compressed air.
4.2 Test apparatus for suit testing, including a pressure measurement device with a sensitivity of at least1/4inch
water gauge.
4.3 Vent valve closure plugs or sealing tape.
4.4 Soapy water solution and soft brush.
4.5 Stop watch or appropriate timing device.
5.0—Safety Precautions
5.1 Care shall be taken to provide the correct pressure safety devices required for the source of compressed air
used.
6.0—Test Procedure
6.1 Prior to each test, the tester shall perform a visual inspection of the suit. Check the suit for seam integrity by
visually examining the seams and gently pulling on the seams. Ensure that all air supply lines, fittings, visor, zippers,
and valves are secure and show no signs of deterioration.
6.1.1 Seal off the vent valves along with any other normal inlet or exhaust points (such as umbilical air line fittings or
face piece opening) with tape or other appropriate means (caps, plugs, fixture, etc.). Care should be exercised in the
sealing process not to damage any of the suit components.
6.1.2 Close all closure assemblies.
6.1.3 Prepare the suit for inflation by providing an improvised connection point on the suit for connecting an airline.
Attach the pressure test apparatus to the suit to permit suit inflation from a compressed air source equipped with a
pressure indicating regulator. The leak tightness of the pressure test apparatus should be tested before and after
each test by closing off the end of the tubing attached to the suit and assuring a pressure of three inches water
gauge for three minutes can be maintained. If a component is removed for the test, that component shall be replaced

28

and a second test conducted with another component removed to permit a complete test of the ensemble.
6.1.4 The pre-test expansion pressure (A) and the suit test pressure (B) shall be supplied by the suit manufacturer,
but in no case shall they be less than: (A)=three inches water gauge; and (B)=two inches water gauge. The ending
suit pressure (C) shall be no less than 80 percent of the test pressure (B); i.e., the pressure drop shall not exceed 20
percent of the test pressure (B).
6.1.5 Inflate the suit until the pressure inside is equal to pressure (A), the pre-test expansion suit pressure. Allow at
least one minute to fill out the wrinkles in the suit. Release sufficient air to reduce the suit pressure to pressure (B),
the suit test pressure. Begin timing. At the end of three minutes, record the suit pressure as pressure (C), the ending
suit pressure. The difference between the suit test pressure and the ending suit test pressure (B-C) shall be defined
as the suit pressure drop.
6.1.6 If the suit pressure drop is more than 20 percent of the suit test pressure (B) during the three-minute test
period, the suit fails the test and shall be removed from service.
7.0—Retest Procedure
7.1 If the suit fails the test check for leaks by inflating the suit to pressure (A) and brushing or wiping the entire suit
(including seams, closures, lens gaskets, glove-to-sleeve joints, etc.) with a mild soap and water solution. Observe
the suit for the formation of soap bubbles, which is an indication of a leak. Repair all identified leaks.
7.2 Retest the TECP suit as outlined in Test procedure 6.0.
8.0—Report
8.1 Each TECP suit tested by this practice shall have the following information recorded:
8.1.1 Unique identification number, identifying brand name, date of purchase, material of construction, and unique fit
features, e.g., special breathing apparatus.
8.1.2 The actual values for test pressures (A), (B), and (C) shall be recorded along with the specific observation
times. If the ending pressure (C) is less than 80 percent of the test pressure (B), the suit shall be identified as failing
the test. When possible, the specific leak location shall be identified in the test records. Retest pressure data shall be
recorded as an additional test.
8.1.3 The source of the test apparatus used shall be identified and the sensitivity of the pressure gauge shall be
recorded.
8.1.4 Records shall be kept for each pressure test even if repairs are being made at the test location.
Caution
Visually inspect all parts of the suit to be sure they are positioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each exhaust valve to make sure it is not blocked.
Care should also be exercised to assure that the inside and outside of the suit is completely dry before it is put into
storage.
B. Totally-encapsulating chemical protective suit qualitative leak test

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1.0—Scope
1.1 This practice semi-qualitatively tests gas tight totally-encapsulating chemical protective suit integrity by detecting
inward leakage of ammonia vapor. Since no modifications are made to the suit to carry out this test, the results from
this practice provide a realistic test for the integrity of the entire suit.
1.2 Resistance of the suit materials to permeation, penetration, and degradation is not determined by this test
method. ASTM test methods are available to test suit materials for these characteristics and the tests are usually
conducted by the manufacturers of the suits.
2.0—Definition of terms
2.1 Totally-encapsulated chemical protective suit (TECP suit) means a full body garment which is constructed of
protective clothing materials; covers the wearer's torso, head, arms, legs and respirator; may cover the wearer's
hands and feet with tightly attached gloves and boots; completely encloses the wearer and respirator by itself or in
combination with the wearer's gloves, and boots.
2.2 Protective clothing material means any material or combination of materials used in an item of clothing for the
purpose of isolating parts of the body from direct contact with a potentially hazardous liquid or gaseous chemicals.
2.3 Gas tight means, for the purpose of this test method, the limited flow of a gas under pressure from the inside of a
TECP suit to atmosphere at a prescribed pressure and time interval.
2.4 Intrusion Coefficient means a number expressing the level of protection provided by a gas tight totallyencapsulating chemical protective suit. The intrusion coefficient is calculated by dividing the test room challenge
agent concentration by the concentration of challenge agent found inside the suit. The accuracy of the intrusion
coefficient is dependent on the challenge agent monitoring methods. The larger the intrusion coefficient the greater
the protection provided by the TECP suit.
3.0—Summary of recommended practice
3.1 The volume of concentrated aqueous ammonia solution (ammonia hydroxide NH4OH) required to generate the
test atmosphere is determined using the directions outlined in 6.1. The suit is donned by a person wearing the
appropriate respiratory equipment (either a positive pressure self-contained breathing apparatus or a positive
pressure supplied air respirator) and worn inside the enclosed test room. The concentrated aqueous ammonia
solution is taken by the suited individual into the test room and poured into an open plastic pan. A two-minute
evaporation period is observed before the test room concentration is measured, using a high range ammonia length
of stain detector tube. When the ammonia vapor reaches a concentration of between 1000 and 1200 ppm, the suited
individual starts a standardized exercise protocol to stress and flex the suit. After this protocol is completed, the test
room concentration is measured again. The suited individual exits the test room and his stand-by person measures
the ammonia concentration inside the suit using a low range ammonia length of stain detector tube or other more
sensitive ammonia detector. A stand-by person is required to observe the test individual during the test procedure;
aid the person in donning and doffing the TECP suit; and monitor the suit interior. The intrusion coefficient of the suit
can be calculated by dividing the average test area concentration by the interior suit concentration. A colorimetric
ammonia indicator strip of bromophenol blue or equivalent is placed on the inside of the suit face piece lens so that
the suited individual is able to detect a color change and know if the suit has a significant leak. If a color change is
observed the individual shall leave the test room immediately.
4.0—Required supplies
4.1 A supply of concentrated aqueous ammonium hydroxide (58% by weight).

30

4.2 A supply of bromophenol/blue indicating paper or equivalent, sensitive to 5–10 ppm ammonia or greater over a
two-minute period of exposure. [pH 3.0 (yellow) to pH 4.6 (blue)]
4.3 A supply of high range (0.5–10 volume percent) and low range (5–700 ppm) detector tubes for ammonia and the
corresponding sampling pump. More sensitive ammonia detectors can be substituted for the low range detector
tubes to improve the sensitivity of this practice.
4.4 A shallow plastic pan (PVC) at least 12&inch;:14&inch;:1&inch; and a half pint plastic container (PVC) with tightly
closing lid.
4.5 A graduated cylinder or other volumetric measuring device of at least 50 milliliters in volume with an accuracy of
at least ±1 milliliters.
5.0—Safety precautions
5.1 Concentrated aqueous ammonium hydroxide, NH4OH, is a corrosive volatile liquid requiring eye, skin, and
respiratory protection. The person conducting the test shall review the MSDS for aqueous ammonia.
5.2 Since the established permissible exposure limit for ammonia is 35 ppm as a 15 minute STEL, only persons
wearing a positive pressure self-contained breathing apparatus or a positive pressure supplied air respirator shall be
in the chamber. Normally only the person wearing the totally-encapsulating suit will be inside the chamber. A standby person shall have a positive pressure self-contained breathing apparatus, or a positive pressure supplied air
respirator available to enter the test area should the suited individual need assistance.
5.3 A method to monitor the suited individual must be used during this test. Visual contact is the simplest but other
methods using communication devices are acceptable.
5.4 The test room shall be large enough to allow the exercise protocol to be carried out and then to be ventilated to
allow for easy exhaust of the ammonia test atmosphere after the test(s) are completed.
5.5 Individuals shall be medically screened for the use of respiratory protection and checked for allergies to
ammonia before participating in this test procedure.
6.0—Test procedure
6.1.1 Measure the test area to the nearest foot and calculate its volume in cubic feet. Multiply the test area volume
by 0.2 milliliters of concentrated aqueous ammonia solution per cubic foot of test area volume to determine the
approximate volume of concentrated aqueous ammonia required to generate 1000 ppm in the test area.
6.1.2 Measure this volume from the supply of concentrated aqueous ammonia and place it into a closed plastic
container.
6.1.3 Place the container, several high range ammonia detector tubes, and the pump in the clean test pan and
locate it near the test area entry door so that the suited individual has easy access to these supplies.
6.2.1 In a non-contaminated atmosphere, open a pre-sealed ammonia indicator strip and fasten one end of the strip
to the inside of the suit face shield lens where it can be seen by the wearer. Moisten the indicator strip with distilled
water. Care shall be taken not to contaminate the detector part of the indicator paper by touching it. A small piece of
masking tape or equivalent should be used to attach the indicator strip to the interior of the suit face shield.
6.2.2 If problems are encountered with this method of attachment, the indicator strip can be attached to the outside

31

of the respirator face piece lens being used during the test.
6.3 Don the respiratory protective device normally used with the suit, and then don the TECP suit to be tested.
Check to be sure all openings which are intended to be sealed (zippers, gloves, etc.) are completely sealed. DO
NOT, however, plug off any venting valves.
6.4 Step into the enclosed test room such as a closet, bathroom, or test booth, equipped with an exhaust fan. No air
should be exhausted from the chamber during the test because this will dilute the ammonia challenge
concentrations.
6.5 Open the container with the pre-measured volume of concentrated aqueous ammonia within the enclosed test
room, and pour the liquid into the empty plastic test pan. Wait two minutes to allow for adequate volatilization of the
concentrated aqueous ammonia. A small mixing fan can be used near the evaporation pan to increase the
evaporation rate of the ammonia solution.
6.6 After two minutes a determination of the ammonia concentration within the chamber should be made using the
high range colorimetric detector tube. A concentration of 1000 ppm ammonia or greater shall be generated before
the exercises are started.
6.7 To test the integrity of the suit the following four minute exercise protocol should be followed:
6.7.1 Raising the arms above the head with at least 15 raising motions completed in one minute.
6.7.2 Walking in place for one minute with at least 15 raising motions of each leg in a one-minute period.
6.7.3 Touching the toes with a least 10 complete motions of the arms from above the head to touching of the toes in
a one-minute period.
6.7.4 Knee bends with at least 10 complete standing and squatting motions in a one-minute period.
6.8 If at any time during the test the colorimetric indicating paper should change colors, the test should be stopped
and section 6.10 and 6.12 initiated (See ¶4.2).
6.9 After completion of the test exercise, the test area concentration should be measured again using the high range
colorimetric detector tube.
6.10 Exit the test area.
6.11 The opening created by the suit zipper or other appropriate suit penetration should be used to determine the
ammonia concentration in the suit with the low range length of stain detector tube or other ammonia monitor. The
internal TECP suit air should be sampled far enough from the enclosed test area to prevent a false ammonia
reading.
6.12 After completion of the measurement of the suit interior ammonia concentration the test is concluded and the
suit is doffed and the respirator removed.
6.13 The ventilating fan for the test room should be turned on and allowed to run for enough time to remove the
ammonia gas. The fan shall be vented to the outside of the building.
6.14 Any detectable ammonia in the suit interior (five ppm ammonia (NH3) or more for the length of stain detector
tube) indicates that the suit has failed the test. When other ammonia detectors are used a lower level of detection is

32

possible, and it should be specified as the pass/fail criteria.
6.15 By following this test method, an intrusion coefficient of approximately 200 or more can be measured with the
suit in a completely operational condition. If the intrusion coefficient is 200 or more, then the suit is suitable for
emergency response and field use.
7.0—Retest procedures
7.1 If the suit fails this test, check for leaks by following the pressure test in test A above.
7.2 Retest the TECP suit as outlined in the test procedure 6.0.
8.0—Report
8.1 Each gas tight totally-encapsulating chemical protective suit tested by this practice shall have the following
information recorded.
8.1.1 Unique identification number, identifying brand name, date of purchase, material of construction, and unique
suit features; e.g., special breathing apparatus.
8.1.2 General description of test room used for test.
8.1.3 Brand name and purchase date of ammonia detector strips and color change data.
8.1.4 Brand name, sampling range, and expiration date of the length of stain ammonia detector tubes. The brand
name and model of the sampling pump should also be recorded. If another type of ammonia detector is used, it
should be identified along with its minimum detection limit for ammonia.
8.1.5 Actual test results shall list the two test area concentrations, their average, the interior suit concentration, and
the calculated intrusion coefficient. Retest data shall be recorded as an additional test.
8.2 The evaluation of the data shall be specified as “suit passed” or “suit failed,” and the date of the test. Any
detectable ammonia (five ppm or greater for the length of stain detector tube) in the suit interior indicates the suit has
failed this test. When other ammonia detectors are used, a lower level of detection is possible and it should be
specified as the pass fail criteria.
Caution
Visually inspect all parts of the suit to be sure they are positioned correctly and secured tightly before putting the suit
back into service. Special care should be taken to examine each exhaust valve to make sure it is not blocked.
Care should also be exercised to assure that the inside and outside of the suit is completely dry before it is put into
storage.
Appendix B to §1910.120—General Description and Discussion of the Levels of Protection and Protective Gear
This appendix sets forth information about personal protective equipment (PPE) protection levels which may be used
to assist employers in complying with the PPE requirements of this section.
As required by the standard, PPE must be selected which will protect employees from the specific hazards which

33

they are likely to encounter during their work on-site.
Selection of the appropriate PPE is a complex process which should take into consideration a variety of factors. Key
factors involved in this process are identification of the hazards, or suspected hazards; their routes of potential
hazard to employees (inhalation, skin absorption, ingestion, and eye or skin contact); and the performance of the
PPE materials (and seams) in providing a barrier to these hazards. The amount of protection provided by PPE is
material-hazard specific. That is, protective equipment materials will protect well against some hazardous
substances and poorly, or not at all, against others. In many instances, protective equipment materials cannot be
found which will provide continuous protection from the particular hazardous substance. In these cases the
breakthrough time of the protective material should exceed the work durations.
Other factors in this selection process to be considered are matching the PPE to the employee's work requirements
and task-specific conditions. The durability of PPE materials, such as tear strength and seam strength, should be
considered in relation to the employee's tasks. The effects of PPE in relation to heat stress and task duration are a
factor in selecting and using PPE. In some cases layers of PPE may be necessary to provide sufficient protection, or
to protect expensive PPE inner garments, suits or equipment.
The more that is known about the hazards at the site, the easier the job of PPE selection becomes. As more
information about the hazards and conditions at the site becomes available, the site supervisor can make decisions
to up-grade or down-grade the level of PPE protection to match the tasks at hand.
The following are guidelines which an employer can use to begin the selection of the appropriate PPE. As noted
above, the site information may suggest the use of combinations of PPE selected from the different protection levels
(i.e., A, B, C, or D) as being more suitable to the hazards of the work. It should be cautioned that the listing below
does not fully address the performance of the specific PPE material in relation to the specific hazards at the job site,
and that PPE selection, evaluation and re-selection is an ongoing process until sufficient information about the
hazards and PPE performance is obtained.
Part A. Personal protective equipment is divided into four categories based on the degree of protection afforded.
(See part B of this appendix for further explanation of Levels A, B, C, and D hazards.)
I. Level A —To be selected when the greatest level of skin, respiratory, and eye protection is required.
The following constitute Level A equipment; it may be used as appropriate;
1. Positive pressure, full face-piece self-contained breathing apparatus (SCBA), or positive pressure supplied air
respirator with escape SCBA, approved by the National Institute for Occupational Safety and Health (NIOSH).
2. Totally-encapsulating chemical-protective suit.
1

3. Coveralls.

1

4. Long underwear.

5. Gloves, outer, chemical-resistant.
6. Gloves, inner, chemical-resistant.
7. Boots, chemical-resistant, steel toe and shank.

34

8. Hard hat (under suit).

1

9. Disposable protective suit, gloves and boots (depending on suit construction, may be worn over totallyencapsulating suit).
II. Level B —The highest level of respiratory protection is necessary but a lesser level of skin protection is needed.
The following constitute Level B equipment; it may be used as appropriate.
1. Positive pressure, full-facepiece self-contained breathing apparatus (SCBA), or positive pressure supplied air
respirator with escape SCBA (NIOSH approved).
2. Hooded chemical-resistant clothing (overalls and long-sleeved jacket; coveralls; one or two-piece chemical-splash
suit; disposable chemical-resistant overalls).
1

3. Coveralls.

4. Gloves, outer, chemical-resistant.
5. Gloves, inner, chemical-resistant.
6. Boots, outer, chemical-resistant steel toe and shank.
7. Boot-covers, outer, chemical-resistant (disposable).
8. Hard hat.

1

1

9. [Reserved]
1

10. Face shield.

III. Level C —The concentration(s) and type(s) of airborne substance(s) is known and the criteria for using air
purifying respirators are met.
The following constitute Level C equipment; it may be used as appropriate.
1. Full-face or half-mask, air purifying respirators (NIOSH approved).
2. Hooded chemical-resistant clothing (overalls; two-piece chemical-splash suit; disposable chemical-resistant
overalls).
1

3. Coveralls.
1

Optional, as applicable.

4. Gloves, outer, chemical-resistant.
5. Gloves, inner, chemical-resistant.

35

6. Boots (outer), chemical-resistant steel toe and shank.

1

1

7. Boot-covers, outer, chemical-resistant (disposable) .
8. Hard hat.

1

9. Escape mask.

1

1

10. Face shield.

IV. Level D —A work uniform affording minimal protection, used for nuisance contamination only.
The following constitute Level D equipment; it may be used as appropriate:
1. Coveralls.
1

2. Gloves.

3. Boots/shoes, chemical-resistant steel toe and shank.
4. Boots, outer, chemical-resistant (disposable).

1

5. Safety glasses or chemical splash goggles*.
6. Hard hat.

1

7. Escape mask.

1

1

8. Face shield.

Part B. The types of hazards for which levels A, B, C, and D protection are appropriate are described below:
I. Level A —Level A protection should be used when:
1. The hazardous substance has been identified and requires the highest level of protection for skin, eyes, and the
respiratory system based on either the measured (or potential for) high concentration of atmospheric vapors, gases,
or particulates; or the site operations and work functions involve a high potential for splash, immersion, or exposure
to unexpected vapors, gases, or particulates of materials that are harmful to skin or capable of being absorbed
through the skin;
2. Substances with a high degree of hazard to the skin are known or suspected to be present, and skin contact is
possible; or
3. Operations are being conducted in confined, poorly ventilated areas, and the absence of conditions requiring
Level A have not yet been determined.
II. Level B —Level B protection should be used when:
1. The type and atmospheric concentration of substances have been identified and require a high level of respiratory

36

protection, but less skin protection;
2. The atmosphere contains less than 19.5 percent oxygen; or
3. The presence of incompletely identified vapors or gases is indicated by a direct-reading organic vapor detection
instrument, but vapors and gases are not suspected of containing high levels of chemicals harmful to skin or capable
of being absorbed through the skin.
Note: This involves atmospheres with IDLH concentrations of specific substances that present severe inhalation
hazards and that do not represent a severe skin hazard; or that do not meet the criteria for use of air-purifying
respirators.
III. Level C —Level C protection should be used when:
1. The atmospheric contaminants, liquid splashes, or other direct contact will not adversely affect or be absorbed
through any exposed skin;
2. The types of air contaminants have been identified, concentrations measured, and an air-purifying respirator is
available that can remove the contaminants; and
3. All criteria for the use of air-purifying respirators are met.
IV. Level D —Level D protection should be used when:
1. The atmosphere contains no known hazard; and
2. Work functions preclude splashes, immersion, or the potential for unexpected inhalation of or contact with
hazardous levels of any chemicals.
Note: As stated before, combinations of personal protective equipment other than those described for Levels A, B, C,
and D protection may be more appropriate and may be used to provide the proper level of protection.
As an aid in selecting suitable chemical protective clothing, it should be noted that the National Fire Protection
Association (NFPA) has developed standards on chemical protective clothing. The standards that have been
adopted by include:
NFPA 1991—Standard on Vapor-Protective Suits for Hazardous Chemical Emergencies (EPA Level A Protective
Clothing).
NFPA 1992—Standard on Liquid Splash-Protective Suits for Hazardous Chemical Emergencies (EPA Level B
Protective Clothing).
NFPA 1993—Standard on Liquid Splash-Protective Suits for Non-emergency, Non-flammable Hazardous Chemical
Situations (EPA Level B Protective Clothing).
These standards apply documentation and performance requirements to the manufacture of chemical protective
suits. Chemical protective suits meeting these requirements are labelled as compliant with the appropriate standard.
It is recommended that chemical protective suits that meet these standards be used.
Appendix C to §1910.120—Compliance Guidelines

37

1. Occupational Safety and Health Program. Each hazardous waste site clean-up effort will require an occupational
safety and health program headed by the site coordinator or the employer's representative. The purpose of the
program will be the protection of employees at the site and will be an extension of the employer's overall safety and
health program. The program will need to be developed before work begins on the site and implemented as work
proceeds as stated in paragraph (b). The program is to facilitate coordination and communication of safety and
health issues among personnel responsible for the various activities which will take place at the site. It will provide
the overall means for planning and implementing the needed safety and health training and job orientation of
employees who will be working at the site. The program will provide the means for identifying and controlling worksite
hazards and the means for monitoring program effectiveness. The program will need to cover the responsibilities and
authority of the site coordinator or the employer's manager on the site for the safety and health of employees at the
site, and the relationships with contractors or support services as to what each employer's safety and health
responsibilities are for their employees on the site. Each contractor on the site needs to have its own safety and
health program so structured that it will smoothly interface with the program of the site coordinator or principal
contractor.
Also those employers involved with treating, storing or disposal of hazardous waste as covered in paragraph (p)
must have implemented a safety and health program for their employees. This program is to include the hazard
communication program required in paragraph (p)(1) and the training required in paragraphs (p)(7) and (p)(8) as
parts of the employers comprehensive overall safety and health program. This program is to be in writing.
Each site or workplace safety and health program will need to include the following: (1) Policy statements of the line
of authority and accountability for implementing the program, the objectives of the program and the role of the site
safety and health supervisor or manager and staff; (2) means or methods for the development of procedures for
identifying and controlling workplace hazards at the site; (3) means or methods for the development and
communication to employees of the various plans, work rules, standard operating procedures and practices that
pertain to individual employees and supervisors; (4) means for the training of supervisors and employees to develop
the needed skills and knowledge to perform their work in a safe and healthful manner; (5) means to anticipate and
prepare for emergency situations; and (6) means for obtaining information feedback to aid in evaluating the program
and for improving the effectiveness of the program. The management and employees should be trying continually to
improve the effectiveness of the program thereby enhancing the protection being afforded those working on the site.
Accidents on the site or workplace should be investigated to provide information on how such occurrences can be
avoided in the future. When injuries or illnesses occur on the site or workplace, they will need to be investigated to
determine what needs to be done to prevent this incident from occurring again. Such information will need to be used
as feedback on the effectiveness of the program and the information turned into positive steps to prevent any
reoccurrence. Receipt of employee suggestions or complaints relating to safety and health issues involved with site
or workplace activities is also a feedback mechanism that can be used effectively to improve the program and may
serve in part as an evaluative tool(s).
For the development and implementation of the program to be the most effective, professional safety and health
personnel should be used. Certified Safety Professionals, Board Certified Industrial Hygienists or Registered
Professional Safety Engineers are good examples of professional stature for safety and health managers who will
administer the employer's program.
2. Training. The training programs for employees subject to the requirements of paragraph (e) of this standard should
address: the safety and health hazards employees should expect to find on hazardous waste clean-up sites; what
control measures or techniques are effective for those hazards; what monitoring procedures are effective in
characterizing exposure levels; what makes an effective employer's safety and health program; what a site safety
and health plan should include; hands on training with personal protective equipment and clothing they may be
expected to use; the contents of the OSHA standard relevant to the employee's duties and function; and, employee's
responsibilities under OSHA and other regulations. Supervisors will need training in their responsibilities under the
safety and health program and its subject areas such as the spill containment program, the personal protective
equipment program, the medical surveillance program, the emergency response plan and other areas.

38

The training programs for employees subject to the requirements of paragraph (p) of this standard should address:
the employers safety and health program elements impacting employees; the hazard communication program; the
medical surveillance program; the hazards and the controls for such hazards that employees need to know for their
job duties and functions. All require annual refresher training.
The training programs for employees covered by the requirements of paragraph (q) of this standard should address
those competencies required for the various levels of response such as: the hazards associated with hazardous
substances; hazard identification and awareness; notification of appropriate persons; the need for and use of
personal protective equipment including respirators; the decontamination procedures to be used; preplanning
activities for hazardous substance incidents including the emergency reponse plan; company standard operating
procedures for hazardous substance emergency responses; the use of the incident command system and other
subjects. Hands-on training should be stressed whenever possible. Critiques done after an incident which include an
evaluation of what worked and what did not and how could the incident be better handled the next time may be
counted as training time.
For hazardous materials specialists (usually members of hazardous materials teams), the training should address
the care, use and/or testing of chemical protective clothing including totally encapsulating suits, the medical
surveillance program, the standard operating procedures for the hazardous materials team including the use of
plugging and patching equipment and other subject areas.
Officers and leaders who may be expected to be in charge at an incident should be fully knowledgeable of their
company's incident command system. They should know where and how to obtain additional assistance and be
familiar with the local district's emergency response plan and the state emergency response plan.
Specialist employees such as technical experts, medical experts or environmental experts that work with hazardous
materials in their regular jobs, who may be sent to the incident scene by the shipper, manufacturer or governmental
agency to advise and assist the person in charge of the incident should have training on an annual basis. Their
training should include the care and use of personal protective equipment including respirators; knowledge of the
incident command system and how they are to relate to it; and those areas needed to keep them current in their
respective field as it relates to safety and health involving specific hazardous substances.
Those skilled support personnel, such as employees who work for public works departments or equipment operators
who operate bulldozers, sand trucks, backhoes, etc., who may be called to the incident scene to provide emergency
support assistance, should have at least a safety and health briefing before entering the area of potential or actual
exposure. These skilled support personnel, who have not been a part of the emergency response plan and do not
meet the training requirements, should be made aware of the hazards they face and should be provided all
necessary protective clothing and equipment required for their tasks.
There are two National Fire Protection Association standards, NFPA 472—“Standard for Professional Competence
of Responders to Hazardous Material Incidents” and NFPA 471—“Recommended Practice for Responding to
Hazardous Material Incidents”, which are excellent resource documents to aid fire departments and other emergency
response organizations in developing their training program materials. NFPA 472 provides guidance on the skills and
knowledge needed for first responder awareness level, first responder operations level, hazmat technicians, and
hazmat specialist. It also offers guidance for the officer corp who will be in charge of hazardous substance incidents.
3. Decontamination. Decontamination procedures should be tailored to the specific hazards of the site, and may vary
in complexity and number of steps, depending on the level of hazard and the employee's exposure to the hazard.
Decontamination procedures and PPE decontamination methods will vary depending upon the specific substance,
since one procedure or method may not work for all substances. Evaluation of decontamination methods and
procedures should be performed, as necessary, to assure that employees are not exposed to hazards by re-using
PPE. References in appendix D may be used for guidance in establishing an effective decontamination program. In
addition, the U.S. Coast Guard's Manual, “Policy Guidance for Response to Hazardous Chemical Releases,” U.S.
Department of Transportation, Washington, DC (COMDTINST M16465.30) is a good reference for establishing an

39

effective decontamination program.
4. Emergency response plans. States, along with designated districts within the states, will be developing or have
developed local emergency response plans. These state and district plans should be utilized in the emergency
response plans called for in the standard. Each employer should assure that its emergency response plan is
compatible with the local plan. The major reference being used to aid in developing the state and local district plans
is the Hazardous Materials Emergency Planning Guide, NRT–1. The current Emergency Response Guidebook from
the U.S. Department of Transportation, CMA's CHEMTREC and the Fire Service Emergency Management
Handbook may also be used as resources.
Employers involved with treatment, storage, and disposal facilities for hazardous waste, which have the required
contingency plan called for by their permit, would not need to duplicate the same planning elements. Those items of
the emergency response plan that are properly addressed in the contingency plan may be substituted into the
emergency response plan required in 1910.120 or otherwise kept together for employer and employee use.
5. Personal protective equipment programs. The purpose of personal protective clothing and equipment (PPE) is to
shield or isolate individuals from the chemical, physical, and biologic hazards that may be encountered at a
hazardous substance site.
As discussed in appendix B, no single combination of protective equipment and clothing is capable of protecting
against all hazards. Thus PPE should be used in conjunction with other protective methods and its effectiveness
evaluated periodically.
The use of PPE can itself create significant worker hazards, such as heat stress, physical and psychological stress,
and impaired vision, mobility, and communication. For any given situation, equipment and clothing should be
selected that provide an adequate level of protection. However, over-protection, as well as under-protection, can be
hazardous and should be avoided where possible.
Two basic objectives of any PPE program should be to protect the wearer from safety and health hazards, and to
prevent injury to the wearer from incorrect use and/or malfunction of the PPE. To accomplish these goals, a
comprehensive PPE program should include hazard identification, medical monitoring, environmental surveillance,
selection, use, maintenance, and decontamination of PPE and its associated training.
The written PPE program should include policy statements, procedures, and guidelines. Copies should be made
available to all employees, and a reference copy should be made available at the worksite. Technical data on
equipment, maintenance manuals, relevant regulations, and other essential information should also be collected and
maintained.
6. Incident command system (ICS). Paragraph 1910.120(q)(3)(ii) requires the implementation of an ICS. The ICS is
an organized approach to effectively control and manage operations at an emergency incident. The individual in
charge of the ICS is the senior official responding to the incident. The ICS is not much different than the “command
post” approach used for many years by the fire service. During large complex fires involving several companies and
many pieces of apparatus, a command post would be established. This enabled one individual to be in charge of
managing the incident, rather than having several officers from different companies making separate, and sometimes
conflicting, decisions. The individual in charge of the command post would delegate responsibility for performing
various tasks to subordinate officers. Additionally, all communications were routed through the command post to
reduce the number of radio transmissions and eliminate confusion. However, strategy, tactics, and all decisions were
made by one individual.
The ICS is a very similar system, except it is implemented for emergency response to all incidents, both large and
small, that involve hazardous substances.
For a small incident, the individual in charge of the ICS may perform many tasks of the ICS. There may not be any,

40

or little, delegation of tasks to subordinates. For example, in response to a small incident, the individual in charge of
the ICS, in addition to normal command activities, may become the safety officer and may designate only one
employee (with proper equipment) as a back-up to provide assistance if needed. OSHA does recommend, however,
that at least two employees be designated as back-up personnel since the assistance needed may include rescue.
To illustrate the operation of the ICS, the following scenario might develop during a small incident, such as an
overturned tank truck with a small leak of flammable liquid.
The first responding senior officer would implement and take command of the ICS. That person would size-up the
incident and determine if additional personnel and apparatus were necessary; would determine what actions to take
to control the leak; and, determine the proper level of personal protective equipment. If additional assistance is not
needed, the individual in charge of the ICS would implement actions to stop and control the leak using the fewest
number of personnel that can effectively accomplish the tasks. The individual in charge of the ICS then would
designate himself as the safety officer and two other employees as a back-up in case rescue may become
necessary. In this scenario, decontamination procedures would not be necessary.
A large complex incident may require many employees and difficult, time-consuming efforts to control. In these
situations, the individual in charge of the ICS will want to delegate different tasks to subordinates in order to maintain
a span of control that will keep the number of subordinates, that are reporting, to a manageable level.
Delegation of task at large incidents may be by location, where the incident scene is divided into sectors, and
subordinate officers coordinate activities within the sector that they have been assigned.
Delegation of tasks can also be by function. Some of the functions that the individual in charge of the ICS may want
to delegate at a large incident are: medical services; evacuation; water supply; resources (equipment, apparatus);
media relations; safety; and, site control (integrate activities with police for crowd and traffic control). Also for a large
incident, the individual in charge of the ICS will designate several employees as back-up personnel; and a number of
safety officers to monitor conditions and recommend safety precautions.
Therefore, no matter what size or complexity an incident may be, by implementing an ICS there will be one individual
in charge who makes the decisions and gives directions; and, all actions, and communications are coordinated
through one central point of command. Such a system should reduce confusion, improve safety, organize and
coordinate actions, and should facilitate effective management of the incident.
7. Site Safety and Control Plans. The safety and security of response personnel and others in the area of an
emergeny response incident site should be of primary concern to the incident commander. The use of a site safety
and control plan could greatly assist those in charge of assuring the safety and health of employees on the site.
A comprehensive site safety and control plan should include the following: summary analysis of hazards on the site
and a risk analysis of those hazards; site map or sketch; site work zones (clean zone, transition or decontamination
zone, work or hot zone); use of the buddy system; site communications; command post or command center;
standard operating procedures and safe work practices; medical assistance and triage area; hazard monitoring plan
(air contaminate monitoring, etc.); decontamination procedures and area; and other relevant areas. This plan should
be a part of the employer's emergency response plan or an extension of it to the specific site.
8. Medical surveillance programs. Workers handling hazardous substances may be exposed to toxic chemicals,
safety hazards, biologic hazards, and radiation. Therefore, a medical surveillance program is essential to assess and
monitor workers' health and fitness for employment in hazardous waste operations and during the course of work; to
provide emergency and other treatment as needed; and to keep accurate records for future reference.
The Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities developed by the
National Institute for Occupational Safety and Health (NIOSH), the Occupational Safety and Health Administration
(OSHA), the U.S. Coast Guard (USCG), and the Environmental Protection Agency (EPA); October 1985 provides an

41

excellent example of the types of medical testing that should be done as part of a medical surveillance program.
9. New Technology and Spill Containment Programs. Where hazardous substances may be released by spilling from
a container that will expose employees to the hazards of the materials, the employer will need to implement a
program to contain and control the spilled material. Diking and ditching, as well as use of absorbents like
diatomaceous earth, are traditional techniques which have proven to be effective over the years. However, in recent
years new products have come into the marketplace, the use of which complement and increase the effectiveness of
these traditional methods. These new products also provide emergency responders and others with additional tools
or agents to use to reduce the hazards of spilled materials.
These agents can be rapidly applied over a large area and can be uniformly applied or otherwise can be used to
build a small dam, thus improving the workers' ability to control spilled material. These application techniques
enhance the intimate contact between the agent and the spilled material allowing for the quickest effect by the agent
or quickest control of the spilled material. Agents are available to solidify liquid spilled materials, to suppress vapor
generation from spilled materials, and to do both. Some special agents, which when applied as recommended by the
manufacturer, will react in a controlled manner with the spilled material to neutralize acids or caustics, or greatly
reduce the level of hazard of the spilled material.
There are several modern methods and devices for use by emergency response personnel or others involved with
spill control efforts to safely apply spill control agents to control spilled material hazards. These include portable
pressurized applicators similar to hand-held portable fire extinguishing devices, and nozzle and hose systems similar
to portable fire fighting foam systems which allow the operator to apply the agent without having to come into contact
with the spilled material. The operator is able to apply the agent to the spilled material from a remote position.
The solidification of liquids provides for rapid containment and isolation of hazardous substance spills. By directing
the agent at run-off points or at the edges of the spill, the reactant solid will automatically create a barrier to slow or
stop the spread of the material. Clean-up of hazardous substances is greatly improved when solidifying agents, acid
or caustic neutralizers, or activated carbon adsorbents are used. Properly applied, these agents can totally solidify
liquid hazardous substances or neutralize or absorb them, which results in materials which are less hazardous and
easier to handle, transport, and dispose of. The concept of spill treatment, to create less hazardous substances, will
improve the safety and level of protection of employees working at spill clean-up operations or emergency response
operations to spills of hazardous substances.
The use of vapor suppression agents for volatile hazardous substances, such as flammable liquids and those
substances which present an inhalation hazard, is important for protecting workers. The rapid and uniform
distribution of the agent over the surface of the spilled material can provide quick vapor knockdown. There are
temporary and long-term foam-type agents which are effective on vapors and dusts, and activated carbon adsorption
agents which are effective for vapor control and soaking-up of the liquid. The proper use of hose lines or hand-held
portable pressurized applicators provides good mobility and permits the worker to deliver the agent from a safe
distance without having to step into the untreated spilled material. Some of these systems can be recharged in the
field to provide coverage of larger spill areas than the design limits of a single charged applicator unit. Some of the
more effective agents can solidify the liquid flammable hazardous substances and at the same time elevate the
flashpoint above 140 °F so the resulting substance may be handled as a nonhazardous waste material if it meets the
U.S. Environmental Protection Agency's 40 CFR part 261 requirements (See particularly §261.21).
All workers performing hazardous substance spill control work are expected to wear the proper protective clothing
and equipment for the materials present and to follow the employer's established standard operating procedures for
spill control. All involved workers need to be trained in the established operating procedures; in the use and care of
spill control equipment; and in the associated hazards and control of such hazards of spill containment work.
These new tools and agents are the things that employers will want to evaluate as part of their new technology
program. The treatment of spills of hazardous substances or wastes at an emergency incident as part of the
immediate spill containment and control efforts is sometimes acceptable to EPA and a permit exception is described

42

in 40 CFR 264.1(g)(8) and 265.1(c)(11).
Appendix D to §1910.120—References
The following references may be consulted for further information on the subject of this standard:
1. OSHA Instruction DFO CPL 2.70—January 29, 1986, Special Emphasis Program: Hazardous Waste Sites.
2. OSHA Instruction DFO CPL 2–2.37A—January 29, 1986, Technical Assistance and Guidelines for Superfund and
Other Hazardous Waste Site Activities.
3. OSHA Instruction DTS CPL 2.74—January 29, 1986, Hazardous Waste Activity Form, OSHA 175.
4. Hazardous Waste Inspections Reference Manual, U.S. Department of Labor, Occupational Safety and Health
Administration, 1986.
5. Memorandum of Understanding Among the National Institute for Occupational Safety and Health, the
Occupational Safety and Health Administration, the United States Coast Guard, and the United States Environmental
Protection Agency, Guidance for Worker Protection During Hazardous Waste Site Investigations and Clean-up and
Hazardous Substance Emergencies. December 18, 1980.
6. National Priorities List, 1st Edition, October 1984; U.S. Environmental Protection Agency, Revised periodically.
7. The Decontamination of Response Personnel, Field Standard Operating Procedures (F.S.O.P.) 7; U.S.
Environmental Protection Agency, Office of Emergency and Remedial Response, Hazardous Response Support
Division, December 1984.
8. Preparation of a Site Safety Plan, Field Standard Operating Procedures (F.S.O.P.) 9; U.S. Environmental
Protection Agency, Office of Emergency and Remedial Response, Hazardous Response Support Division, April
1985.
9. Standard Operating Safety Guidelines; U.S. Environmental Protection Agency, Office of Emergency and Remedial
Response, Hazardous Response Support Division, Environmental Response Team; November 1984.
10. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, National Institute for
Occupational Safety and Health (NIOSH), Occupational Safety and Health Administration (OSHA), U.S. Coast Guard
(USCG), and Environmental Protection Agency (EPA); October 1985.
11. Protecting Health and Safety at Hazardous Waste Sites: An Overview, U.S. Environmental Protection Agency,
EPA/625/9–85/006; September 1985.
12. Hazardous Waste Sites and Hazardous Substance Emergencies, NIOSH Worker Bulletin, U.S. Department of
Health and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational
Safety and Health; December 1982.
13. Personal Protective Equipment for Hazardous Materials Incidents: A Selection Guide; U.S. Department of Health
and Human Services, Public Health Service, Centers for Disease Control, National Institute for Occupational Safety
and Health; October 1984.
14. Fire Service Emergency Management Handbook, International Association of Fire Chiefs Foundation, 101 East

43

Holly Avenue, Unit 10B, Sterling, VA 22170, January 1985.
15. Emergency Response Guidebook, U.S Department of Transportation, Washington, DC, 1987.
16. Report to the Congress on Hazardous Materials Training, Planning and Preparedness, Federal Emergency
Management Agency, Washington, DC, July 1986.
17. Workbook for Fire Command, Alan V. Brunacini and J. David Beageron, National Fire Protection Association,
Batterymarch Park, Quincy, MA 02269, 1985.
18. Fire Command, Alan V. Brunacini, National Fire Protection Association, Batterymarch Park,, Quincy, MA 02269,
1985.
19. Incident Command System, Fire Protection Publications, Oklahoma State University, Stillwater, OK 74078, 1983.
20. Site Emergency Response Planning, Chemical Manufacturers Association, Washington, DC 20037, 1986.
21. Hazardous Materials Emergency Planning Guide, NRT–1, Environmental Protection Agency, Washington, DC,
March 1987.
22. Community Teamwork: Working Together to Promote Hazardous Materials Transportation Safety. U.S.
Department of Transportation, Washington, DC, May 1983.
23. Disaster Planning Guide for Business and Industry, Federal Emergency Management Agency, Publication No.
FEMA 141, August 1987.
(The Office of Management and Budget has approved the information collection requirements in this section under
control number 1218–0139)
Appendix E to §1910.120—Training Curriculum Guidelines
The following non-mandatory general criteria may be used for assistance in developing site-specific training
curriculum used to meet the training requirements of 29 CFR 1910.120(e); 29 CFR 1910.120(p)(7), (p)(8)(iii); and 29
CFR 1910.120(q)(6), (q)(7), and (q)(8). These are generic guidelines and they are not presented as a complete
training curriculum for any specific employer. Site-specific training programs must be developed on the basis of a
needs assessment of the hazardous waste site, RCRA/TSDF, or emergency response operation in accordance with
29 CFR 1910.120.
It is noted that the legal requirements are set forth in the regulatory text of §1910.120. The guidance set forth here
presents a highly effective program that in the areas covered would meet or exceed the regulatory requirements. In
addition, other approaches could meet the regulatory requirements.
Suggested General Criteria
Definitions:
“Competent” means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or
activities satisfactorily as determined by the employer.
“Demonstration” means the showing by actual use of equipment or procedures.

44

“Hands-on training” means training in a simulated work environment that permits each student to have experience
performing tasks, making decisions, or using equipment appropriate to the job assignment for which the training is
being conducted.
“Initial training” means training required prior to beginning work.
“Lecture” means an interactive discourse with a class lead by an instructor.
“Proficient” means meeting a stated level of achievement.
“Site-specific” means individual training directed to the operations of a specific job site.
“Training hours” means the number of hours devoted to lecture, learning activities, small group work sessions,
demonstration, evaluations, or hands-on experience.
Suggested core criteria:
1. Training facility. The training facility should have available sufficient resources, equipment, and site locations to
perform didactic and hands-on training when appropriate. Training facilities should have sufficient organization,
support staff, and services to conduct training in each of the courses offered.
2. Training Director. Each training program should be under the direction of a training director who is responsible for
the program. The Training Director should have a minimum of two years of employee education experience.
3. Instructors. Instructors should be deem competent on the basis of previous documented experience in their area
of instruction, successful completion of a “train-the-trainer” program specific to the topics they will teach, and an
evaluation of instructional competence by the Training Director.
Instructors should be required to maintain professional competency by participating in continuing education or
professional development programs or by completing successfully an annual refresher course and having an annual
review by the Training Director.
The annual review by the Training Director should include observation of an instructor's delivery, a review of those
observations with the trainer, and an analysis of any instructor or class evaluations completed by the students during
the previous year.
4. Course materials. The Training Director should approve all course materials to be used by the training provider.
Course materials should be reviewed and updated at least annually. Materials and equipment should be in good
working order and maintained properly.
All written and audio-visual materials in training curricula should be peer reviewed by technically competent outside
reviewers or by a standing advisory committee.
Reviews should possess expertise in the following disciplines were applicable: occupational health, industrial
hygiene and safety, chemical/environmental engineering, employee education, or emergency response. One or more
of the peer reviewers should be an employee experienced in the work activities to which the training is directed.
5. Students. The program for accepting students should include:
a. Assurance that the student is or will be involved in work where chemical exposures are likely and that the student

45

possesses the skills necessary to perform the work.
b. A policy on the necessary medical clearance.
6. Ratios. Student-instructor ratios should not exceed 30 students per instructor. Hands-on activity requiring the use
of personal protective equipment should have the following student-instructor ratios. For Level C or Level D personal
protective equipment the ratio should be 10 students per instructor. For Level A or Level B personal protective
equipment the ratio should be 5 students per instructor.
7. Proficiency assessment. Proficiency should be evaluated and documented by the use of a written assessment and
a skill demonstration selected and developed by the Training Director and training staff. The assessment and
demonstration should evaluate the knowledge and individual skills developed in the course of training. The level of
minimum achievement necessary for proficiency shall be specified in writing by the Training Director.
If a written test is used, there should be a minimum of 50 questions. If a written test is used in combination with a
skills demonstration, a minimum of 25 questions should be used. If a skills demonstration is used, the tasks chosen
and the means to rate successful completion should be fully documented by the Training Director.
The content of the written test or of the skill demonstration shall be relevant to the objectives of the course. The
written test and skill demonstration should be updated as necessary to reflect changes in the curriculum and any
update should be approved by the Training Director.
The proficiency assessment methods, regardless of the approach or combination of approaches used, should be
justified, documented and approved by the Training Director.
The proficiency of those taking the additional courses for supervisors should be evaluated and documented by using
proficiency assessment methods acceptable to the Training Director. These proficiency assessment methods must
reflect the additional responsibilities borne by supervisory personnel in hazardous waste operations or emergency
response.
8. Course certificate. Written documentation should be provided to each student who satisfactorily completes the
training course. The documentation should include:
a. Student's name.
b. Course title.
c. Course date.
d. Statement that the student has successfully completed the course.
e. Name and address of the training provider.
f. An individual identification number for the certificate.
g. List of the levels of personal protective equipment used by the student to complete the course.
This documentation may include a certificate and an appropriate wallet-sized laminated card with a photograph of
the student and the above information. When such course certificate cards are used, the individual identification
number for the training certificate should be shown on the card.

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9. Recordkeeping. Training providers should maintain records listing the dates courses were presented, the names
of the individual course attenders, the names of those students successfully completing each course, and the
number of training certificates issued to each successful student. These records should be maintained for a minimum
of five years after the date an individual participated in a training program offered by the training provider. These
records should be available and provided upon the student's request or as mandated by law.
10. Program quality control. The Training Director should conduct or direct an annual written audit of the training
program. Program modifications to address deficiencies, if any, should be documented, approved, and implemented
by the training provider. The audit and the program modification documents should be maintained at the training
facility.
Suggested Program Quality Control Criteria
Factors listed here are suggested criteria for determining the quality and appropriateness of employee health and
safety training for hazardous waste operations and emergency response.
A. Training Plan.
Adequacy and appropriateness of the training program's curriculum development, instructor training, distribution of
course materials, and direct student training should be considered, including
1. The duration of training, course content, and course schedules/agendas;
2. The different training requirements of the various target populations, as specified in the appropriate generic
training curriculum;
3. The process for the development of curriculum, which includes appropriate technical input, outside review,
evaluation, program pretesting.
4. The adequate and appropriate inclusion of hands-on, demonstration, and instruction methods;
5. Adequate monitoring of student safety, progress, and performance during the training.
B. Program management, Training Director, staff, and consultants.
Adequacy and appropriateness of staff performance and delivering an effective training program should be
considered, including
1. Demonstration of the training director's leadership in assuring quality of health and safety training.
2. Demonstration of the competency of the staff to meet the demands of delivering high quality hazardous waste
employee health and safety training.
3. Organization charts establishing clear lines of authority.
4. Clearly defined staff duties including the relationship of the training staff to the overall program.
5. Evidence that the training organizational structure suits the needs of the training program.
6. Appropriateness and adequacy of the training methods used by the instructors.

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7. Sufficiency of the time committed by the training director and staff to the training program.
8. Adequacy of the ratio of training staff to students.
9. Availability and commitment of the training program of adequate human and equipment resources in the areas of
a. Health effects,
b. Safety,
c. Personal protective equipment (PPE),
d. Operational procedures,
e. Employee protection practices/procedures.
10. Appropriateness of management controls.
11. Adequacy of the organization and appropriate resources assigned to assure appropriate training.
12. In the case of multiple-site training programs, adequacy of satellite centers management.
C. Training facilities and resources.
Adequacy and appropriateness of the facilities and resources for supporting the training program should be
considered, including,
1. Space and equipment to conduct the training.
2. Facilities for representative hands-on training.
3. In the case of multiple-site programs, equipment and facilities at the satellite centers.
4. Adequacy and appropriateness of the quality control and evaluations program to account for instructor
performance.
5. Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course
evaluation, feedback, updating, and corrective action.
6. Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation
program.
7. Adequacy and appropriateness of the role of student evaluations to provide feedback for training program
improvement.
D. Quality control and evaluation.
Adequacy and appropriateness of quality control and evaluation plans for training programs should be considered,
including:

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1. A balanced advisory committee and/or competent outside reviewers to give overall policy guidance;
2. Clear and adequate definition of the composition and active programmatic role of the advisory committee or
outside reviewers.
3. Adequacy of the minutes or reports of the advisory committee or outside reviewers' meetings or written
communication.
4. Adequacy and appropriateness of the quality control and evaluations program to account for instructor
performance.
5. Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course
evaluation, feedback, updating, and corrective action.
6. Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation
program.
7. Adequacy and appropriateness of the role of student evaluations to provide feedback for training program
improvement.
E. Students
Adequacy and appropriateness of the program for accepting students should be considered, including
1. Assurance that the student already possess the necessary skills for their job, including necessary documentation.
2. Appropriateness of methods the program uses to ensure that recruits are capable of satisfactorily completing
training.
3. Review and compliance with any medical clearance policy.
F. Institutional Environment and Administrative Support
The adequacy and appropriateness of the institutional environment and administrative support system for the training
program should be considered, including
1. Adequacy of the institutional commitment to the employee training program.
2. Adequacy and appropriateness of the administrative structure and administrative support.
G. Summary of Evaluation Questions
Key questions for evaluating the quality and appropriateness of an overall training program should include the
following:
1. Are the program objectives clearly stated?
2. Is the program accomplishing its objectives?

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3. Are appropriate facilities and staff available?
4. Is there an appropriate mix of classroom, demonstration, and hands-on training?
5. Is the program providing quality employee health and safety training that fully meets the intent of regulatory
requirements?
6. What are the program's main strengths?
7. What are the program's main weaknesses?
8. What is recommended to improve the program?
9. Are instructors instructing according to their training outlines?
10. Is the evaluation tool current and appropriate for the program content?
11. Is the course material current and relevant to the target group?
Suggested Training Curriculum Guidelines
The following training curriculum guidelines are for those operations specifically identified in 29 CFR 1910.120 as
requiring training. Issues such as qualifications of instructors, training certification, and similar criteria appropriate to
all categories of operations addressed in 1910.120 have been covered in the preceding section and are not readdressed in each of the generic guidelines. Basic core requirements for training programs that are addressed
include
1. General Hazardous Waste Operations
2. RCRA operations—Treatment, storage, and disposal facilities.
3. Emergency Response.
A. General Hazardous Waste Operations and Site-specific Training
1. Off-site training .Training course content for hazardous waste operations, required by 29 CFR 1910.120(e), should
include the following topics or procedures:
a. Regulatory knowledge .
(1) An review of 29 CFR 1910.120 and the core elements of an occupational safety and health program.
(2) The content of a medical surveillance program as outlined in 29 CFR 1910.120(f).
(3) The content of an effective site safety and health plan consistent with the requirements of 29 CFR
1910.120(b)(4)(ii).
(4) Emergency response plan and procedures as outlined in 29 CFR 1910.38 and 29 CFR 1910.120(l).

50

(5) Adequate illumination.
(6) Sanitation recommendation and equipment.
(7) Review and explanation of OSHA's hazard-communication standard (29 CFR 1910.1200) and lock-out-tag-out
standard (29 CFR 1910.147).
(8) Review of other applicable standards including but not limited to those in the construction standards (29 CFR part
1926).
(9) Rights and responsibilities of employers and employees under applicable OSHA and EPA laws.
b. Technical knowledge .
(1) Type of potential exposures to chemical, biological, and radiological hazards; types of human responses to these
hazards and recognition of those responses; principles of toxicology and information about acute and chronic
hazards; health and safety considerations of new technology.
(2) Fundamentals of chemical hazards including but not limited to vapor pressure, boiling points, flash points, ph,
other physical and chemical properties.
(3) Fire and explosion hazards of chemicals.
(4) General safety hazards such as but not limited to electrical hazards, powered equipment hazards, motor vehicle
hazards, walking-working surface hazards, excavation hazards, and hazards associated with working in hot and cold
temperature extremes.
(5) Review and knowledge of confined space entry procedures in 29 CFR 1910.146.
(6) Work practices to minimize employee risk from site hazards.
(7) Safe use of engineering controls, equipment, and any new relevant safety technology or safety procedures.
(8) Review and demonstration of competency with air sampling and monitoring equipment that may be used in a site
monitoring program.
(9) Container sampling procedures and safeguarding; general drum and container handling procedures including
special requirement for laboratory waste packs, shock-sensitive wastes, and radioactive wastes.
(10) The elements of a spill control program.
(11) Proper use and limitations of material handling equipment.
(12) Procedures for safe and healthful preparation of containers for shipping and transport.
(13) Methods of communication including those used while wearing respiratory protection.
c. Technical skills.
(1) Selection, use maintenance, and limitations of personal protective equipment including the components and

51

procedures for carrying out a respirator program to comply with 29 CFR 1910.134.
(2) Instruction in decontamination programs including personnel, equipment, and hardware; hands-on training
including level A, B, and C ensembles and appropriate decontamination lines; field activities including the donning
and doffing of protective equipment to a level commensurate with the employee's anticipated job function and
responsibility and to the degree required by potential hazards.
(3) Sources for additional hazard information; exercises using relevant manuals and hazard coding systems.
d. Additional suggested items.
(1) A laminated, dated card or certificate with photo, denoting limitations and level of protection for which the
employee is trained should be issued to those students successfully completing a course.
(2) Attendance should be required at all training modules, with successful completion of exercises and a final written
or oral examination with at least 50 questions.
(3) A minimum of one-third of the program should be devoted to hands-on exercises.
(4) A curriculum should be established for the 8-hour refresher training required by 29 CFR 1910.120(e)(8), with
delivery of such courses directed toward those areas of previous training that need improvement or reemphasis.
(5) A curriculum should be established for the required 8-hour training for supervisors. Demonstrated competency in
the skills and knowledge provided in a 40-hour course should be a prerequisite for supervisor training.
2. Refresher training.
The 8-hour annual refresher training required in 29 CFR 1910.120(e)(8) should be conducted by qualified training
providers. Refresher training should include at a minimum the following topics and procedures:
(a) Review of and retraining on relevant topics covered in the 40-hour program, as appropriate, using reports by the
students on their work experiences.
(b) Update on developments with respect to material covered in the 40-hour course.
(c) Review of changes to pertinent provisions of EPA or OSHA standards or laws.
(d) Introduction of additional subject areas as appropriate.
(e) Hands-on review of new or altered PPE or decontamination equipment or procedures. Review of new
developments in personal protective equipment.
(f) Review of newly developed air and contaminant monitoring equipment.
3. On-site training.
a. The employer should provide employees engaged in hazardous waste site activities with information and training
prior to initial assignment into their work area, as follows:
(1) The requirements of the hazard communication program including the location and availability of the written

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program, required lists of hazardous chemicals, and material safety data sheets.
(2) Activities and locations in their work area where hazardous substance may be present.
(3) Methods and observations that may be used to detect the present or release of a hazardous chemical in the work
area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearances, or other
evidence (sight, sound or smell) of hazardous chemicals being released, and applicable alarms from monitoring
devices that record chemical releases.
(4) The physical and health hazards of substances known or potentially present in the work area.
(5) The measures employees can take to help protect themselves from work-site hazards, including specific
procedures the employer has implemented.
(6) An explanation of the labeling system and material safety data sheets and how employees can obtain and use
appropriate hazard information.
(7) The elements of the confined space program including special PPE, permits, monitoring requirements,
communication procedures, emergency response, and applicable lock-out procedures.
b. The employer should provide hazardous waste employees information and training and should provide a review
and access to the site safety and plan as follows:
(1) Names of personnel and alternate responsible for site safety and health.
(2) Safety and health hazards present on the site.
(3) Selection, use, maintenance, and limitations of personal protective equipment specific to the site.
(4) Work practices by which the employee can minimize risks from hazards.
(5) Safe use of engineering controls and equipment available on site.
(6) Safe decontamination procedures established to minimize employee contact with hazardous substances,
including:
(A) Employee decontamination,
(B) Clothing decontamination, and
(C) Equipment decontamination.
(7) Elements of the site emergency response plan, including:
(A) Pre-emergency planning.
(B) Personnel roles and lines of authority and communication.
(C) Emergency recognition and prevention.

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(D) Safe distances and places of refuge.
(E) Site security and control.
(F) Evacuation routes and procedures.
(G) Decontamination procedures not covered by the site safety and health plan.
(H) Emergency medical treatment and first aid.
(I) Emergency equipment and procedures for handling emergency incidents.
c. The employer should provide hazardous waste employees information and training on personal protective
equipment used at the site, such as the following:
(1) PPE to be used based upon known or anticipated site hazards.
(2) PPE limitations of materials and construction; limitations during temperature extremes, heat stress, and other
appropriate medical considerations; use and limitations of respirator equipment as well as documentation procedures
as outlined in 29 CFR 1910.134.
(3) PPE inspection procedures prior to, during, and after use.
(4) PPE donning and doffing procedures.
(5) PPE decontamination and disposal procedures.
(6) PPE maintenance and storage.
(7) Task duration as related to PPE limitations.
d. The employer should instruct the employee about the site medical surveillance program relative to the particular
site, including
(1) Specific medical surveillance programs that have been adapted for the site.
(2) Specific signs and symptoms related to exposure to hazardous materials on the site.
(3) The frequency and extent of periodic medical examinations that will be used on the site.
(4) Maintenance and availability of records.
(5) Personnel to be contacted and procedures to be followed when signs and symptoms of exposures are
recognized.
e. The employees will review and discuss the site safety plan as part of the training program. The location of the site
safety plan and all written programs should be discussed with employees including a discussion of the mechanisms
for access, review, and references described.

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B. RCRA Operations Training for Treatment, Storage and Disposal Facilities.
1. As a minimum, the training course required in 29 CFR 1910.120 (p) should include the following topics:
(a) Review of the applicable paragraphs of 29 CFR 1910.120 and the elements of the employer's occupational safety
and health plan.
(b) Review of relevant hazards such as, but not limited to, chemical, biological, and radiological exposures; fire and
explosion hazards; thermal extremes; and physical hazards.
(c) General safety hazards including those associated with electrical hazards, powered equipment hazards, lock-outtag-out procedures, motor vehicle hazards and walking-working surface hazards.
(d) Confined-space hazards and procedures.
(e) Work practices to minimize employee risk from workplace hazards.
(f) Emergency response plan and procedures including first aid meeting the requirements of paragraph (p)(8).
(g) A review of procedures to minimize exposure to hazardous waste and various type of waste streams, including
the materials handling program and spill containment program.
(h) A review of hazard communication programs meeting the requirements of 29 CFR 1910.1200.
(i) A review of medical surveillance programs meeting the requirements of 29 CFR 1910.120(p)(3) including the
recognition of signs and symptoms of overexposure to hazardous substance including known synergistic
interactions.
(j) A review of decontamination programs and procedures meeting the requirements of 29 CFR 1910.120(p)(4).
(k) A review of an employer's requirements to implement a training program and its elements.
(l) A review of the criteria and programs for proper selection and use of personal protective equipment, including
respirators.
(m) A review of the applicable appendices to 29 CFR 1910.120.
(n) Principles of toxicology and biological monitoring as they pertain to occupational health.
(o) Rights and responsibilities of employees and employers under applicable OSHA and EPA laws.
(p) Hands-on exercises and demonstrations of competency with equipment to illustrate the basic equipment
principles that may be used during the performance of work duties, including the donning and doffing of PPE.
(q) Sources of reference, efficient use of relevant manuals, and knowledge of hazard coding systems to include
information contained in hazardous waste manifests.
(r) At least 8 hours of hands-on training.
(s) Training in the job skills required for an employee's job function and responsibility before they are permitted to

55

participate in or supervise field activities.
2. The individual employer should provide hazardous waste employees with information and training prior to an
employee's initial assignment into a work area. The training and information should cover the following topics:
(a) The Emergency response plan and procedures including first aid.
(b) A review of the employer's hazardous waste handling procedures including the materials handling program and
elements of the spill containment program, location of spill response kits or equipment, and the names of those
trained to respond to releases.
(c) The hazardous communication program meeting the requirements of 29 CFR 1910.1200.
(d) A review of the employer's medical surveillance program including the recognition of signs and symptoms of
exposure to relevant hazardous substance including known synergistic interactions.
(e) A review of the employer's decontamination program and procedures.
(f) An review of the employer's training program and the parties responsible for that program.
(g) A review of the employer's personal protective equipment program including the proper selection and use of PPE
based upon specific site hazards.
(h) All relevant site-specific procedures addressing potential safety and health hazards. This may include, as
appropriate, biological and radiological exposures, fire and explosion hazards, thermal hazards, and physical
hazards such as electrical hazards, powered equipment hazards, lock-out-tag-out hazards, motor vehicle hazards,
and walking-working surface hazards.
(i) Safe use engineering controls and equipment on site.
(j) Names of personnel and alternates responsible for safety and health.
C. Emergency response training.
Federal OSHA standards in 29 CFR 1910.120(q) are directed toward private sector emergency responders.
Therefore, the guidelines provided in this portion of the appendix are directed toward that employee population.
However, they also impact indirectly through State OSHA or USEPA regulations some public sector emergency
responders. Therefore, the guidelines provided in this portion of the appendix may be applied to both employee
populations.
States with OSHA state plans must cover their employees with regulations at least as effective as the Federal OSHA
standards. Public employees in states without approved state OSHA programs covering hazardous waste operations
and emergency response are covered by the U.S. EPA under 40 CFR 311, a regulation virtually identical to
§1910.120.
Since this is a non-mandatory appendix and therefore not an enforceable standard, OSHA recommends that those
employers, employees or volunteers in public sector emergency response organizations outside Federal OSHA
jurisdiction consider the following criteria in developing their own training programs. A unified approach to training at
the community level between emergency response organizations covered by Federal OSHA and those not covered
directly by Federal OSHA can help ensure an effective community response to the release or potential release of

56

hazardous substances in the community.
a. General considerations .
Emergency response organizations are required to consider the topics listed in §1910.120(q)(6). Emergency
response organizations may use some or all of the following topics to supplement those mandatory topics when
developing their response training programs. Many of the topics would require an interaction between the response
provider and the individuals responsible for the site where the response would be expected.
(1) Hazard recognition, including:
(A) Nature of hazardous substances present,
(B) Practical applications of hazard recognition, including presentations on biology, chemistry, and physics.
(2) Principles of toxicology, biological monitoring, and risk assessment.
(3) Safe work practices and general site safety.
(4) Engineering controls and hazardous waste operations.
(5) Site safety plans and standard operating procedures.
(6) Decontamination procedures and practices.
(7) Emergency procedures, first aid, and self-rescue.
(8) Safe use of field equipment.
(9) Storage, handling, use and transportation of hazardous substances.
(10) Use, care, and limitations of personal protective equipment.
(11) Safe sampling techniques.
(12) Rights and responsibilities of employees under OSHA and other related laws concerning right-to-know, safety
and health, compensations and liability.
(13) Medical monitoring requirements.
(14) Community relations.
b. Suggested criteria for specific courses .
(1) First responder awareness level .
(A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q).
(B) Hands-on experience with the U.S. Department of Transportation's Emergency Response Guidebook (ERG) and

57

familiarization with OSHA standard 29 CFR 1910.1201.
(C) Review of the principles and practices for analyzing an incident to determine both the hazardous substances
present and the basic hazard and response information for each hazardous substance present.
(D) Review of procedures for implementing actions consistent with the local emergency response plan, the
organization's standard operating procedures, and the current edition of DOT's ERG including emergency notification
procedures and follow-up communications.
(E) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical
hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
(F) Awareness and knowledge of the competencies for the First Responder at the Awareness Level covered in the
National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous
Materials Incidents .
(2) First responder operations level .
(A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q).
(B) Hands-on experience with the U.S. Department of Transportation's Emergency Response Guidebook (ERG),
manufacturer material safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, and other
relevant sources of information addressing hazardous substance releases. Familiarization with OSHA standard 29
CFR 1910.1201.
(C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present,
the likely behavior of the hazardous substance and its container, the types of hazardous substance transportation
containers and vehicles, the types and selection of the appropriate defensive strategy for containing the release.
(D) Review of procedures for implementing continuing response actions consistent with the local emergency
response plan, the organization's standard operating procedures, and the current edition of DOT's ERG including
extended emergency notification procedures and follow-up communications.
(E) Review of the principles and practice for proper selection and use of personal protective equipment.
(F) Review of the principles and practice of personnel and equipment decontamination.
(G) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical
hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
(H) Awareness and knowledge of the competencies for the First Responder at the Operations Level covered in the
National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous
Materials Incidents .
(3) Hazardous materials technician .
(A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q).
(B) Hands-on experience with written and electronic information relative to response decision making including but
not limited to the U.S. Department of Transportation's Emergency Response Guidebook (ERG), manufacturer
material safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, computer data bases and

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response models, and other relevant sources of information addressing hazardous substance releases.
Familiarization with OSHA standard 29 CFR 1910.1201.
(C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present,
their physical and chemical properties, the likely behavior of the hazardous substance and its container, the types of
hazardous substance transportation containers and vehicles involved in the release, the appropriate strategy for
approaching release sites and containing the release.
(D) Review of procedures for implementing continuing response actions consistent with the local emergency
response plan, the organization's standard operating procedures, and the current edition of DOT's ERG including
extended emergency notification procedures and follow-up communications.
(E) Review of the principles and practice for proper selection and use of personal protective equipment.
(F) Review of the principles and practices of establishing exposure zones, proper decontamination and medical
surveillance stations and procedures.
(G) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical
hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
(H) Awareness and knowledge of the competencies for the Hazardous Materials Technician covered in the National
Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials
Incidents .
(4) Hazardous materials specialist .
(A) Review of and demonstration of competency in performing the applicable skills of 29 CFR 1910.120(q).
(B) Hands-on experience with retrieval and use of written and electronic information relative to response decision
making including but not limited to the U.S. Department of Transportation's Emergency Response Guidebook (ERG),
manufacturer material safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, computer data
bases and response models, and other relevant sources of information addressing hazardous substance releases.
Familiarization with OSHA standard 29 CFR 1910.1201.
(C) Review of the principles and practices for analyzing an incident to determine the hazardous substances present,
their physical and chemical properties, and the likely behavior of the hazardous substance and its container, vessel,
or vehicle.
(D) Review of the principles and practices for identification of the types of hazardous substance transportation
containers, vessels and vehicles involved in the release; selecting and using the various types of equipment
available for plugging or patching transportation containers, vessels or vehicles; organizing and directing the use of
multiple teams of hazardous material technicians and selecting the appropriate strategy for approaching release
sites and containing or stopping the release.
(E) Review of procedures for implementing continuing response actions consistent with the local emergency
response plan, the organization's standard operating procedures, including knowledge of the available public and
private response resources, establishment of an incident command post, direction of hazardous material technician
teams, and extended emergency notification procedures and follow-up communications.
(F) Review of the principles and practice for proper selection and use of personal protective equipment.
(G) Review of the principles and practices of establishing exposure zones and proper decontamination, monitoring

59

and medical surveillance stations and procedures.
(H) Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical
hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
(I) Awareness and knowledge of the competencies for the Off-site Specialist Employee covered in the National Fire
Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials
Incidents .
(5) Incident commander .
The incident commander is the individual who, at any one time, is responsible for and in control of the response
effort. This individual is the person responsible for the direction and coordination of the response effort. An incident
commander's position should be occupied by the most senior, appropriately trained individual present at the
response site. Yet, as necessary and appropriate by the level of response provided, the position may be occupied by
many individuals during a particular response as the need for greater authority, responsibility, or training increases. It
is possible for the first responder at the awareness level to assume the duties of incident commander until a more
senior and appropriately trained individual arrives at the response site.
Therefore, any emergency responder expected to perform as an incident commander should be trained to fulfill the
obligations of the position at the level of response they will be providing including the following:
(A) Ability to analyze a hazardous substance incident to determine the magnitude of the response problem.
(B) Ability to plan and implement an appropriate response plan within the capabilities of available personnel and
equipment.
(C) Ability to implement a response to favorably change the outcome of the incident in a manner consistent with the
local emergency response plan and the organization's standard operating procedures.
(D) Ability to evaluate the progress of the emergency response to ensure that the response objectives are being met
safely, effectively, and efficiently.
(E) Ability to adjust the response plan to the conditions of the response and to notify higher levels of response when
required by the changes to the response plan.
[54 FR 9317, Mar. 6, 1989, as amended at 55 FR 14073, Apr. 13, 1990; 56 FR 15832, Apr. 18, 1991; 59 FR 43270, Aug. 22,
1994; 61 FR 9238, Mar. 7, 1996; 67 FR 67964, Nov. 7, 2002; 71 FR 16672, Apr. 3, 2006; 76 FR 80738, Dec. 27, 2011]
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