HAZWOPER Requirements for Small Quantity Generators

In order to keep employees safe while handling hazardous waste, the Occupational Health and Safety Administration (OSHA) has developed the Hazardous Waste Operations and Emergency Response Standard (HAZWOPER), written in 29 CFR 1910.120. These regulations identify information and training requirements that facilities must comply with to keep employees safe during emergency response involving hazardous chemicals.

Facilities who are considered to be Small Quantity Generators (SQGs) generate 100 kilograms or less per month of hazardous waste. Even though these facilities handle smaller amounts of hazardous waste than Large Quantity Generators (LQGs), they must comply with some requirements listed in the HAZWOPER standard. SQGs must comply with paragraph (p)(8) of the HAZWOPER standard, which states that if the facility requires employees to engage in emergency response, the facility must prepare and implement a written emergency response plan. This emergency response plan should include procedures for handling emergency incidents involving hazardous chemicals handled on site, including:

  • Pre-emergency planning and coordination with outside parties;
  • Personnel roles, lines of authority, and communication;
  • Emergency recognition and prevention;
  • Safe distances and places of refuge;
  • Site security and control;
  • Evacuation routes and procedures;
  • Decontamination procedures;
  • Emergency medical treatment and first aid;
  • Emergency alerting and response procedures;
  • Critique of response and follow-up;
  • PPE and emergency equipment.

Paragraph (p)(8) also states that emergency response employees are required to be trained before they are called upon to perform in real emergencies. This training should include elements of the facility’s emergency response plan, standard operating procedures for emergency response, and what personal protective equipment (PPE) should be worn. The facility should certify that these employees have attended and completed this training annually.

In addition to these requirements, ALL FACILITIES that have employees who are engaged in emergency response, no matter where it occurs, must comply with paragraph (q) of the HAZWOPER standard. Paragraph (q) outlines the requirements for a site-specific Incident Command System (ICS). All members of a facility’s ICS must receive specific training depending on their response category. These categories include:

First Responder (Awareness Level): These are the employees who are likely to witness or discover a hazardous substance release, but will only notify proper authorities of the incident. Awareness-Level First Responders must be given basic training that outlines what hazardous substances are and what risks are associated with them. Training should also ensure that these first responders understand their role and know to seek additional resources and make appropriate notifications to the communication center in the event of an emergency.

First Responder (Operations Level): These are the employees who will respond to releases of hazardous substances as part of the initial response in order to protect nearby people, property, or the environment. These first responders should be trained to respond to a release in a defensive fashion without trying to stop the release. Operations-Level First Responders must receive at least 8 hours of training that includes knowledge of basic hazard and risk assessment techniques, how to use and select proper PPE, and know how to perform basic control, containment, or confinement operations within the capabilities of the resources available to them.

Hazardous Materials Technicians: These are the employees who will respond to a release of hazardous substance with the intent of stopping the release using plugs, patches, or other methods. Hazardous Materials Technicians must receive at least 24 hours of training that includes how to use survey instruments and equipment, how to use and select specialized PPE, how to perform containment, control, and decontamination procedures, and understand basic chemical and toxicological behavior of hazardous materials.

Hazardous Materials Specialists: These are the employees who will provide support to Hazardous Materials Technicians. Specialists have similar duties to technicians, but should have more specific knowledge about the hazardous materials. Hazardous Materials Specialists are required to receive at least 24 hours of training on the same level as Hazardous Materials Technicians, along with having an understanding of additional information regarding hazardous materials and how to properly address a release.

On-Scene Incident Commander: This is the employee who will assume control of the incident scene behind the first responders. The Incident Commander should be competent in implementing the facility’s ICS and ERP and should understand the risks and hazards faced by employees working with hazardous materials. The On-Scene Incident Commander must receive at least 24 hours of training.

Refresher training for all categories of emergency responders must be given on an annual basis.

In addition to these specific categories, support personnel who are skilled in the operation of certain equipment and may be needed to perform immediate emergency support or may be exposed to hazards at an emergency response scene should be given an initial briefing prior to their participation in any emergency action. This briefing should include instruction in how to wear appropriate PPE, what chemical hazards are involved, and what duties are to be performed. Also, specialist employees who work with and are trained in the hazards of specific hazardous substances who are likely to be called to provide technical advice or assistance in event of a release of hazardous substances must receive training or demonstrate competency in the area of their specialization annually.

If you have any questions about what HAZWOPER requirements your facility is required to comply with, please feel free to contact us at (770) 263-6330, or by email at cti@conversiontechnology.com.

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