The HAZWOPER standard requires every employer to develop and implement a written Safety and Health Program for each of the three categories of hazardous waste sites — before work begins.
Incident Command and Site Coordination
Incident Command serves as the central hub for hazardous waste operations.
Each cleanup effort must have a site-specific Health and Safety Plan (HASP) developed and led by the site coordinator or the employer’s designated representative.
The HASP ensures that site operations are organized, hazards are properly controlled, and all personnel understand their roles and responsibilities during cleanup activities
Purpose of the Safety and Health Program
The goal of the Safety and Health Program is to:
- Identify, evaluate, and control safety and health hazards at the worksite.
- Establish emergency response procedures specific to each hazardous waste site.
- Reduce work-related injuries and illnesses by maintaining a safe and healthful work environment.
An effective, well-implemented program is essential for protecting employees and ensuring regulatory compliance under OSHA’s HAZWOPER standard.
Program Components
The written program must describe work policies, practices, and procedures, and include the following core elements:
- Organizational Structure
Defines the chain of command, roles, and communication responsibilities at the site. - Comprehensive Work Plan
Outlines tasks, objectives, and operational methods for site activities. - Site Characterization and Evaluation
Identifies existing and potential hazards through preliminary and detailed site assessments. - Site-Specific Health and Safety Plan (HASP)
Provides detailed procedures for protecting employees from site-specific hazards. - Safety and Health Training Program
Ensures employees receive proper instruction before engaging in site operations. - Medical Surveillance Program
Monitors worker health to detect early signs of exposure or illness. - Standard Operating Procedures (SOPs)
Establishes safe work methods for handling hazardous materials and waste.
Program Maintenance and Communication
- The written Safety and Health Program must be reviewed and updated periodically.
- It must be readily available to all affected employees, contractors, and subcontractors.
- Employers are required to inform contractors and subcontractors about any known safety, health, fire, or explosion hazards before they begin work.
A single, site-specific Safety and Health Program is acceptable if it covers all site operations and employers, and employees are trained to use it.
However, each contractor and subcontractor must independently comply with all applicable HAZWOPER requirements.
Module Focus
In this module, we will explore the first five elements of the written Safety and Health Program.
The remaining three elements will be covered in the next module.
Although this discussion focuses on cleanup operations, the same principles and program elements apply to TSD facilities and other hazardous waste sites.