Hazardous Waste Operations and Emergency Response (HAZWOPER; // HAZ-waw-pər) refers to many types of hazardous waste operations and emergency services conducted around the world, especially those conducted under the auspices of the federal government of the United States. The term appears in hazardous waste treatment regulations currently published by the Occupational Safety and Health Administration (OSHA); however, the term predates OSHA, originating from disaster clean-ups sponsored by the Department of Energy.[when?]
The most common manual for HAZWOPER activities is Department of Health and Human Services Publication 85–115, "Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities". Targeted at government contractors and first responders, the manual documents the safety requirements for conducting clean-ups and emergency response operations.
Although the acronym pre-dates OSHA (Occupational Safety and Health Administration), today HAZWOPER is a term most often used to describe OSHA-required regulatory training. It had relevance dating back to World War II when waste accumulated in construction of the Atom Bomb at the Hanford Site (The Secret City). Years later, high-profile environmental mishaps forced action from the legislative branch of the US Government. For example, the 1978 Love Canal disaster and 1979 Valley of the Drums incident awakened America to the need to control and contain hazardous waste in the United States. Two programs, CERCLA, the Comprehensive Environmental Response, Compensation, and Liability Act, and RCRA, the Resource Conservation and Recovery Act of 1976 were implemented to deal with these wastes. CERCLA, also known as the Superfund, was designed to deal with already existing waste sites while RCRA was designed to deal with newly generated wastes. Originally, the term HAZWOPER was derived from the United States Department of Defense's Hazardous Waste Operations (HAZWOP), implemented on military bases which were slated for clean-up operations to dispose of hazardous wastes that were left on-site after World War II. One such 500-square-mile (1,300 km2) site is run by the US Government and some of the world's largest constructors such as Bechtel National, Inc. and others. In 1989, production stopped and work shifted to cleanup of portions of the site contaminated with hazardous substances, including both radionuclides and chemical waste. OSHA created HAZWOPER along with input from USCG, NIOSH, and United States Environmental Protection Agency (EPA). In 1984 the joint agency effort published the Hazardous Waste Operations and Emergency Response Guidance Manual  In 1989, OSHA promulgated the standard in March 6, 1990 as the HAZWOPER Standard, 1910.120, Hazardous Waste Operations and Emergency Response which codified the safety and health requirements companies would have to meet in order to perform hazardous waste cleanups or to respond to emergencies.
OSHA recently released an interpretation; the HAZWOPER 40-Hour training for clean-up workers will not suffice as technician level training for emergency response situations. This was in response to a letter from TRC in Indiana. However, (as a result of the Gulf Deepwater Horizon Oil Spill) according to the Washington D.C. compliance division, OSHA would allow exceptions to HAZWOPER 40-Hour trained workers being on or in marine modules that typically are in emergency response allowed to do technician-level work in the water with 24 Hour Technician level training and on the beaches where they could potentially come in contact with hazardous substances. Point being it was NOT regulated by OSHA however OSHA provided assistance while it was still a "National Emergency". Site safety and health officers in conjunction with the Site Specific Health and Safety Plan verify marine compliance on chemical or oil spill clean-ups in coordination with other agencies. A Site Safety Supervisor typically has 40 hours of HAZWOPER training unless they are required to go on.
HAZWOPER sites require site security and site controls. It is to protect the public, the environment, and the site from vandalism and especially protect the workers and account for them entering or leaving the site. National disasters are not regulated by OSHA until it has been downgraded from a disaster site. OSHA is only involved to assist the private sector in a National Disaster under the National Contingency Plan.
The HAZWOPER standard covers five specific areas of operations, including:
- Clean-up operations required by a governmental body, whether federal, state, local, or other involving hazardous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the EPA's National Priorities List of sites (NPL), state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are conducted before the presence or absence of hazardous substances has been ascertained);
- Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq);
- Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;
- Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S EPA to implement RCRA regulations; and
- Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
Hazardous wastes are defined by the standard as:
- A waste or combination of wastes as defined in 40 C.F.R. 261.3 ("Identification and listing of hazardous waste") or
- Those substances defined as hazardous wastes in 49 C.F.R. 171.8 ("General information, regulations, and definitions").
The term HAZWOPER recently has been referenced in international cleanup, mostly where U.S. military bases are still being cleaned up, or in some cases with NATO allies such as Canada, particularly when U.S. firms are involved with Hazardous Waste Operations and Emergency Response. While the OSHA standard does not apply to these operations, some of the countries involved are working on adopting similar standards to protect workers. In some cases it has proven difficult because they lack the safety infrastructure that the HAZWOPER standard is built on.
Levels of training
OSHA recognizes several levels of training, based on the work the employee will be performing and the level of hazard they will be facing. Each level requires a different training program, and OSHA specifies topics and minimum training times.
- General site workers initially require 40 hours of instruction, three days of supervised hands on training, and eight hours of refresher training annually
- Workers limited to a specific task or workers on fully characterized sites with no hazards above acceptable levels require 24 hours of initial training, one day supervised hands on training, and eight hours of refresher training annually
- Managers and supervisors require the same level of training as the people they supervise, plus eight additional hours of training
- Workers who are working at a Treatment, Storage, or Disposal facility that handles RCRA wastes require 24 hours of initial training and eight hours of refresher training annually
- First Responder Awareness level require sufficient training to demonstrate competency in their assigned duties
- First Responder Operations level Awareness level training plus eight hours training
- Hazardous Materials Technician 24 hours training plus additional training to achieve competency in several areas
- Hazardous Materials Specialist 24 hours training at the technician level, plus additional training to achieve competency in several areas
- On Scene Incident commander 24 hours training plus additional training to achieve competency in several areas
- In all there are 18 different points to training. The basic premise is that it is for preventing exposure or mitigating dangerous situations fire, explosion or chemical exposure.
The training is what makes HAZWOPER unique. In some instances the training levels may or may not overlap in other cases these are prohibited by OSHA because workers without specific training may not be able to characterize waste unless trained to do that task. The Site Safety Supervisor or Officer should be consulted and a competent industrial hygienist or other technically qualified person who is HAZWOPER trained.
Training and certification sources
There are many sources for OSHA-compliant HAZWOPER training. Community colleges, labor unions, employers, and training companies are all good sources for training. The employer must ensure the training provider covers the areas of knowledge required by the standard and provides certification to the students that they have passed the training. The certification attaches to the student, not the employer, so it is imperative that the trainer cover all aspects of HAZWOPER operations, not just those expected at the current worksite (EPA's formerly comprehensive approach). However OSHA's interpretations now require clean-up workers (to have focus on PPE) separated from emergency response (to deal with hazardous materials unknowns).[better source needed]
- 29 C.F.R. 1910.120
- "NPL Site Narrative for A.L. Taylor (Valley of Drums)". United States Environmental Protection Agency. September 8, 1983. Retrieved October 12, 2013. "EPA conducted emergency response activities in March 1979…."
- United States Department of Health and Human Services (National Institute for Occupational Safety and Health) (October 1985), Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities, p. 142, pub. no. 85-115, retrieved February 22, 2011
- Fairfax, Richard E. (April 28, 2008), Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER (letter to Robert E. Carson), retrieved October 12, 2013
- 29 C.F.R. 1910