Standard Operating Procedures (SOPs) ensure that all employees understand and consistently follow the correct methods and processes for performing work safely. Well-developed SOPs help maintain uniform safety standards, reduce human error, and protect workers from unnecessary exposure to hazardous substances.
SOPs must be included in every Safety and Health Plan and should clearly define how operations are to be conducted at the site.
Hazard Control Strategies
A critical part of an SOP involves determining how employers will control hazards and limit employee exposure at hazardous waste sites. To achieve this, employers must apply the Hierarchy of Controls — a structured approach that prioritizes the most effective control methods for reducing or eliminating hazards.
Hierarchy of Controls
The Hierarchy of Controls, from most effective to least effective, includes:
- Elimination – Physically remove the hazard.
- Substitution – Replace the hazard with a safer alternative.
- Engineering Controls – Isolate people from the hazard through design or equipment modification.
- Barriers and Enclosures – Create physical separations or containment zones.
- Administrative Controls – Modify work policies or schedules to minimize exposure.
- Safe Work Practices – Adopt safe methods and procedures to prevent exposure.
- Personal Protective Equipment (PPE) – Use protective gear when other controls are insufficient.
Note: Engineering and administrative controls must always be considered before relying on PPE as the primary method of protection.
Engineering Controls
Whenever feasible, employers must implement engineering controls and work practices to reduce and maintain exposure levels at or below OSHA’s permissible exposure limits (PELs).
Examples include:
- Using pressurized cabs or control booths on heavy equipment.
- Employing remotely operated material-handling systems to minimize direct contact with hazards.
Safe Work Practices
Safe work practices complement engineering controls by focusing on procedural safety and worker behavior in the field.
Examples include:
- Restricting non-essential personnel from areas where drums or containers are being opened.
- Wetting down dusty operations to prevent airborne contaminants.
- Positioning workers upwind from potential sources of chemical or particulate exposure.
Key Takeaways
- SOPs ensure consistent, safe, and effective operations on hazardous waste sites.
- Employers must integrate the Hierarchy of Controls into all work planning.
- Engineering and administrative controls take precedence over PPE whenever possible.
- Regular review and employee training on SOPs are essential for maintaining compliance and safety.