What Puts the HAZ in HAZWOPER?

Posted on 4/26/2016 by Roger Marks

If you manage hazardous waste at your site, you likely know OSHA's HAZWOPER Standard as an additional set of requirements for the safe remediation of sites contaminated with hazardous waste. After all, HAZWOPER stands for Hazardous Waste Operations and Emergency Response-"hazardous waste" is right there in the name! But did you know that the HAZWOPER definition of "hazardous substance" at 29 CFR 1910.120(a)(3) comprises not only RCRA-regulated hazardous waste, but other materials as well?

As laid out in OSHA's HAZWOPER Standard, the definition of "hazardous substance" actually has four distinct parts:

1. Any substance defined under §103(14) of the Comprehensive Environmental Response Compensation and Liability Act (CERCLA) (42 U.S.C. 9601).

2. Any biologic agent and other disease-causing agent that, 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 malfunctions (including malfunctions in reproduction), or physical deformations in such persons or their offspring.

3. Any substance listed by the US Department of Transportation as a hazardous material under 49 CFR 172.101 and appendices.

4. Hazardous wastes as defined under RCRA at 40 CFR 261.3 or any waste that requires us of the Hazardous Waste Manifest.
As EHS professionals know, it's not uncommon for each regulatory agency to put its own "spin" on common terms. By knowing how OSHA defines "hazardous substance," you can be better prepared to comply with OSHA's HAZWOPER Standard and know when HAZWOPER training will be required to perform cleanup duties at a specific contaminated site.

Who Needs HAZWOPER Training?

Major situations where operators and employees may need HAZWOPER training include:

Cleanup operations required by Federal, State, or Local government involving hazardous substances at the following sites:
  • Uncontrolled hazardous waste sites or "Superfund" sites, incl. EPA's National Priority Site List (NPL)
  • State priority sites
  • Sites recommended for the EPA National Priority Site List (NPL)
  • Initial investigations of identified sites where hazardous substances may be present
Employees who work at an uncontrolled hazardous waste site are required by OSHA to complete initial training on the HAZWOPER rules. This initial HAZWOPER training is typically 24 or 40 hours in length. After initial training, personnel must maintain their certification by completing 8 hours of HAZWOPER refresher training once per year.

New! 8-hour OSHA HAZWOPER Refresher Training

Stay HAZWOPER-ready with the convenient, interactive 8-hour OSHA HAZWOPER Refresher Online Course. Designed for personnel who work at uncontrolled hazardous waste sites (including Superfund sites), the online course prepares personnel to safely perform hazardous waste cleanup operations and maintain compliance with the many OSHA HAZWOPER requirements.

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