Various questions on 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 21, 1992

Dr. Colleen K. O'Toole
Vice President
Mr. Larry Bloomfield Chair
Greater Cincinnati Hospital Council
1811 Losantiville Avenue Suite 460
Cincinnati, Ohio 45237-3954

Dear Mr. Bloomfield:

This is in response to your inquiry of June 1, forwarded to OSHA's National Office from the OSHA Region V office, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (HAZWOPER), 29 CFR 1910.120.

Manufacturing facilities with potential for exposure to hazardous waste.

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.

September 22, 1992

Mr. Thomas A. Wehrenberg
Environmental Engineer
Grow Group, Inc.
4000 Dupont Circle
Louisville, Kentucky 40207

Dear Mr. Wehrenberg:

This is in response to your inquiry of July 27, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120.

Clarification on first aid requirements for hazardous waste sites.

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.

 

 

Health and safety plans for hazardous waste operations & 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.

March 24, 1993

Marc B. Evans, C.I.H., C.S.P.
Blasland & Bouck Engineers, P.C.
6723 Towpath Road Box 66
Syracuse, New York 13214-0066

Dear Mr. Evans:

This is in response to your inquiry of August 28, 1992, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120. We apologize for the delay in this response. OSHA has reviewed your approach to preparing health and safety plans (HASP) for hazardous waste sites, and has the following comments.

Operations regulated by 40 CFR 264 and 265 must comply with 1910.120 training.

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 28, 1989

Mr. James L. Laurence, Director
Health and Product Safety
The Sherwin-Williams Company
101 Prospect Avenue, N.W.
Cleveland, Ohio 44115-1075

Dear Mr. Laurence:

This is in response to your inquiry concerning the application of OSHA's final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120).

Application of 1910.120 to the construction of a building where the ground water would be classified as hazardous waste

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 15, 1989

Mr. Mark S. Zemelman
McCutchen, Doyle, Brown & Enersen
Counselors at Law
Three Embarcadero Center
San Francisco, California 94111

Dear Mr. Zemelman:

This is in response to your inquiry concerning the application of OSHA's Hazardous Waste Operations and Emergency Response Operations final standard to the construction of a building on property previously occupied by a dry cleaning facility.

Response to emergency in "normal work area" definition.

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.

 

Application of OSHA's final standard for 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.

July 28, 1989

Richard F. Boggs, Ph.D
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place N.W.
Washington, D.C. 20036

Dear Dr. Boggs:

This is in response to your inquiry requesting interpretations of OSHA's final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120).

For the sake of clarity, I will enumerate and respond to your questions in the order you raised them:

Whether an off-site HAZMAT emergency response team may be permitted to all areas of a hazardous waste site in an emergency response action.

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.

June 17, 1993

Mary Greenhalgh
Associate, ENVIRON Corporation
210 Carnegie Center, Suite 201
Princeton, New Jersey 08540

Dear Ms. Greenhalgh:

Thank you for your letter of January 22, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120.

Post-emergency response and medical surveillance requirements 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.

August 5, 1993

Mr. Edward E. Hartin
Vice-President of Operations
HAZMAT Training Information
Services, Inc.
9017 Red Branch Road
Columbia, Maryland 21045

Dear Mr. Hartin:

This is in response to your inquiry of March 22, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120. We apologize for the delay in responding to your inquiry.