HAZWOPER Emergency Response Quick Quiz

Posted on 8/30/2016 by James Griffin

When you work with hazardous chemicals, spills happen. Spills can happen for all kinds of reasons, at any time of the day or night, in any facility. When spills do happen, the situation may trigger an emergency response situation under OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard at 29 CFR 1910.120. But that's not always the case.

To perform emergency response covered under OSHA's HAZWOPER rules, workers must complete a substantial program of training, field experience, and continuing education. Luckily, not every spill is a HAZWOPER-level problem. Can you pick out which of the de-containment scenarios described below would fall under OSHA's HAZWOPER emergency response Standard? And which can be cleaned up without HAZWOPER training?

Have questions about HAZWOPER training before you start? Check out the FAQ at

Chemical Spill 1: Phillip in the R&D Lab

Phillip works in a research & development laboratory. He mixes small amounts of different chemicals together in an effort to find a more efficient technique for applying lemon-scented-ness to high-quality moist towelettes.

One day he accidentally spills a 500 mL bottle of flammable, but non-toxic, adhesive on a countertop under a fume hood. To clean it up, he uses an absorbent mat from a roll under the sink to pick up most of the goop, sprays the rest with an organic cleaning product, and wipes up the rest with paper towels from under the sink. Phil was already wearing plastic gloves, eye protection, and a lab coat, because he spends all day working with this glue and other similar materials.

Is this a HAZWOPER emergency response? 

This is not a HAZWOPER emergency response. This is an 'incidental release' not an emergency spill. It did not pose a significant safety or health hazard to employees due to its limited quantity and restricted potential for exposure. It was safely cleaned up with equipment already in the work area, by an employee familiar with the hazards of the chemicals.

What rules did apply?

OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires employers to ensure each worker know about the hazards of the chemicals in his or her workspace. It applies equally to cleaning spills and performing chemical reactions. Other OSHA Standards are also likely to apply to small spill cleanups like this, depending on the nature of the material and the workspace, such as OSHA's Flammable liquids Standard at 29 CFR 1910.106 or OSHA's Standard for Personal Protective Equipment (PPE) at 29 CFR 1910.132 et seq.

And of course, the contaminated absorbents used to clean up the spill must be evaluated as potentially hazardous waste under US EPA's Resource Conservation and Recovery Act (RCRA), see 40 CFR Part 261.

Chemical Spill 2: Ross in the Basement

At the end of the day, Ross from maintenance makes his rounds of the shop floor and labs. He takes the small bin of contaminated absorbent materials from Phil's lab, along with many others, down to the basement. In the basement is a secure, well-ventilated room where many 55-gallon drums filled with hazardous waste sit quietly surrounded by a high-end fire suppression system and diked by a sealed concrete secondary containment system.

While transferring waste from the lab bins to the storage drums, Ross is startled by a rodent of unusual size (R.O.U.S.) and overtips a drum half full of mats, absorbents, and plastic labware all contaminated with flammable and toxic materials. The contaminated materials fall all over the floor, and the dregs of fluid start to spread over the concrete. He ambles to a janitor's closet down the hall for a broom and mop and cleans up all the hazardous waste and puts it back in the drums.

Is this a HAZWOPER emergency response? 

This is not a HAZWOPER emergency response. This is an 'incidental release' not an emergency spill. It did not pose a significant safety or health hazard to employees due to its limited quantity and restricted potential for exposure. It was safely cleaned up with equipment already in the work area, by an employee familiar with the hazards of the chemicals.

Because there was no significant risk of fire, explosion, or immediate lethality, this incident continues to be exempt from HAZWOPER emergency response requirements.

What rules did apply?

Because the stuff Ross is cleaning up is RCRA hazardous waste, it is NOT subject to regulation by the Hazard Communication Standard. [29 CFR 1910.1200(b)(6)(i)] But all other OSHA regulations for workplace safety (PPE, flammable liquid storage, etc.) would continue to apply.

The USEPA's RCRA regulations do include requirements for preparing for and responding to spills and releases. These rules [40 CFR 265 Subparts C and D] would apply to this cleanup.

Chemical Spill 3: Joel on the Highway

A few weeks later, Joel drives a long-haul truck to the plant to pick up some drums of hazardous waste and take them to a disposal facility. He gets a few drums of contaminated labware, an IBC full of spent caustic, and a half empty cylinder of carbon dioxide. While driving under the speed limit to the clean energy powered disposal facility, he swerves to avoid running over an endangered varmint. This causes the truck to jackknife, the cargo to break, and a fire to start. Because of the mixture of chemicals in the truck, the fire burns vigorously and the smoke is poisonous to inhale. The first responders to arrive don't have the right gear to approach the burning vehicle so they evacuate the area and call in a special unit equipped with alternative fire-fighting foams (the waste reacts poorly to water) and rebreathing gear. After the fire is fought, the highway department has to dig up the whole stretch of roadway and the dirt from the shoulder because it's contaminated with hazardous chemicals.

Is this a HAZWOPER emergency response?

This is a HAZWOPER emergency response. It caused a fire, had poison gas threatened people outside a normal workplace, required special equipment to respond to and will require special handling to clean up afterwards.

What rules did apply?

Under HAZWOPER, emergency responders are subject to the requirements of 29 CFR 1910.120(q), and personnel cleaning up contaminated sites are subject to 1910.120(b)-(o).

$99 HAZWOPER 8 Hour Refresher Training

By knowing which situations require HAZWOPER training and which do not, you can make informed decisions about which employees are prepared to respond to a chemical spill (if and when a spill happens). Knowing when HAZWOPER training is needed will help you make sure spills get cleaned up as quickly as possible without risking worker safety.

Emergency response personnel are not the only workers who need HAZWOPER training. For managers and personnel with responsibilities at "uncontrolled hazardous waste sites" like Superfund sites and other locations where voluntary clean-up activities are performed, Lion now offers the 8-hour OSHA HAZWOPER Refresher online course. Sign up to meet OSHA's annual training standard for workers at uncontrolled hazardous waste sites [29 CFR1910.120(a)(1)(i-iii).

To learn more or sign up now, visit today.


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