Application of HAZWOPER.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 31, 1997

John F. Reagan, CHMM
Regulatory Affairs Manager
Mercury Refining Company, Inc.
1218 Central Avenue
Albany, New York 12205

Dear Mr. Reagan:

The requirements of paragraph (m) in the OSHA HAZWOPER Standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

October 29, 1997

Mr. Scott Sylvester
Laidlaw Environmental Services, Inc.
Post Office Box 11393
Columbia, South Carolina 29221

Dear Mr. Sylvester:

Interpretation concerning 1910.120 requirements for air monitoring, a site safety and health plan, training, and medical surveillance

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

August 19, 1988

Dr. Paul W. Jonmaire
Ecology and Environment, Inc.
Buffalo Corporate Center
368 Pleasantview Drive
Lancaster, New York 14086

Dear Dr. Jonmaire:

Access to employee exposure and medical records.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

 

 

The requirement for change rooms whenever employees are required to wear personal protective clothing.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

February 22, 1996

Mr. Gerald P. Cavaluzzi
Attorney and Counselor at Law
34 Beekman Avenue
Croton-on-Hudson, New York 10520

Dear Mr. Cavaluzzi:

This is in response to your letter dated October 6, 1995, to Assistant Secretary Joseph Dear of the Occupational Safety and Health Administration (OSHA). Please accept my apology for the delay in this reply.

Emergency response training requirements for hospital staff.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

April 25, 1997

Mr. Thomas Whittaker
New England Hospital
Engineers' Society, Inc.
303 Buttonball Lane
Glastonbury, Connecticut 06033

Dear Mr. Whittaker:

Training provisions of OSHA's HAZWOPER standard.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

January 14, 1997

Mr. Gene Kostka
Hoechst Celanese
Post Office Box 58190
Houston, Texas 77258-8190

Dear Mr. Kostka:

Interpretation on medical surveillance requirements under OSHA's Hazardous Waste Operations and Emergency Response.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

In your letter, you defined hazardous waste technicians as employees "who might be expected to work in personal protective equipment in potentially close contact with hazardous wastes during ... emergency response ... and cleanup operations." In addition, you indicated that OHM's decision to reduce the scheduled frequency of periodic medical examinations was arrived at in coordination with OHM's Medical Director, based on a review of expected duties, exposures, and past medical surveillance data for the affected personnel.

Interpretations of the Hazardous Waste Operations and Emergency Response Standard.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 22, 1990

Mr. James M. Kuszaj Ogletree, Deakins, Nash, Smoak, and Stewart Law Offices Post Office Box 31608 Raleigh, North Carolina 27622

Dear Mr. Kuszaj:

This is in response to your Freedom of Information Act (FOIA) request of March 1 to the Occupational Safety and Health Administration (OSHA). We received your request in this office on March 6. You asked for interpretations of the Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120, and a copy of the Memorandum for Regional Administrators dated October 16, 1989.

Removal activities involving underground storage tanks.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

July 31, 1990

MEMORANDUM FOR: MICHAEL G. CONNORS

 

REGIONAL ADMINISTRATOR

FROM: PATRICIA K. CLARK, DIRECTOR DESIGNATE DIRECTORATE OF COMPLIANCE PROGRAMS

THROUGH: LEO CAREY, DIRECTOR OFFICE OF FIELD PROGRAMS

SUBJECT: 29 CFR 1910.120/Underground Storage Tanks

This is in response to your request for further guidance on the application of the Hazardous Waste Operations and Emergency Response standard (29 CFR 1910.120) to removal activities involving underground storage tanks.