The Ins and Outs of The Ins and Outs of HAZWOPER HAZWOPER

ororIs it a true HAZWOPER event Is it a true HAZWOPER event or something else completely?or something else completely?

Presented byPresented byBarry Rutledge, Senior EH&S SpecialistBarry Rutledge, Senior EH&S SpecialistProtech Environmental Compliance and SafetyProtech Environmental Compliance and Safety

HazHazardous ardous WWaste aste OpOperationserations– Contaminated SitesContaminated Sites

Not our issue hereNot our issue here

EEmergency mergency RResponseesponse

– Chemical SpillsChemical Spills

May be our issue hereMay be our issue hereor maybe not!or maybe not!

HAZWOP ER

HAZWOPThe Hazardous Waste Operations portion dealswith those who work on contaminated work sites.

Do these picture look like activities you might deal with?

Emergency ResponseThe emergency response portion deals with those who areexpected to respond to emergencies, like chemical spills.

Do these picture look like activities you might deal with?

HAZWOPER, 29CFR 1910.120HAZWOPER, 29CFR 1910.120

Passed in 1987.Passed in 1987.

Caused lots of confusion.Caused lots of confusion.

Organization unsure how it affected them.Organization unsure how it affected them.

Many went overboard in an attempt to Many went overboard in an attempt to comply.comply.

Most attempted to implement the full brunt Most attempted to implement the full brunt of HAZWOPER. of HAZWOPER.

HAZWOPER ImplementationHAZWOPER Implementation

Maintenance workers and janitorial staffs Maintenance workers and janitorial staffs transformed into Incident Response teams.transformed into Incident Response teams.

Standard PPE was replaced with Moon Standard PPE was replaced with Moon Suite’s and SCBA’s equipped with escape Suite’s and SCBA’s equipped with escape bottles.bottles.

Full decontamination procedures replaced Full decontamination procedures replaced common sense chemical hygiene.common sense chemical hygiene.

The spill area became the “Exclusion Zone” The spill area became the “Exclusion Zone” with “Reduction Zones” near by. with “Reduction Zones” near by.

HAZWOPER ImplementationHAZWOPER Implementation(Continued)(Continued)

All that equipment was expensive to buyAll that equipment was expensive to buyExpensive to maintain.Expensive to maintain.It is confusing to use if not used regularly.It is confusing to use if not used regularly.So that brings us to training.So that brings us to training.40 Hr. HAZWOPER training all the staff40 Hr. HAZWOPER training all the staffSCBA and Respirator training + medicalSCBA and Respirator training + medical8 Hr. refresher training annually.8 Hr. refresher training annually.Mock Spill Drills held annually.Mock Spill Drills held annually.

HAZWOPER, 29CFR 1910.120HAZWOPER, 29CFR 1910.120

?

Is all this really necessary?Is all this really necessary?

The answer lies with your definition of Emergency

Emergency DefinedEmergency Defined

Response to Emergencies requires a Response to Emergencies requires a HAZWOPER style of response.HAZWOPER style of response.

Responses to non-emergencies do not.Responses to non-emergencies do not.

What does the REG. say?What does the REG. say?

“Responses to incidental releases of hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the scope of this standard.”

Emergency DefinedEmergency Defined

So OSHA gives you latitude in the Reg.So OSHA gives you latitude in the Reg.

According to the Reg., you don’t need a According to the Reg., you don’t need a team of 40 Hr. trained HazMat Techs to team of 40 Hr. trained HazMat Techs to clean up most spills you will see.clean up most spills you will see.

From a Risk Management perspective you From a Risk Management perspective you may still want to.may still want to.

The The choicechoice is yours to make! is yours to make!

Recognizing the EmergencyRecognizing the Emergency

100ml bottle of 10% Sodium Azide broken 100ml bottle of 10% Sodium Azide broken on the floor in front of a fume hood.on the floor in front of a fume hood.– Hazardous?Hazardous?– Response level needed?Response level needed?– What do you do?What do you do?– Waste requirementsWaste requirements

Recognizing the EmergencyRecognizing the Emergency

- Hazardous?- Response level need?- What do you do?- Waste requirements?

(4-Nitro-1,2-phenylenediamine)Harmful Solid

IrritantPossible mutagen

Recognizing the EmergencyRecognizing the Emergency

A broken 2.5 liter bottle of HCL between A broken 2.5 liter bottle of HCL between the air lock entry doors of a Vivarium. the air lock entry doors of a Vivarium. Very little ventilation.Very little ventilation.

- Hazardous?- Response level need?- What do you do?- Waste requirements?

Recognizing the EmergencyRecognizing the Emergency

- Hazardous?- Response level need?- What do you do?- Waste requirements?

Numerous broken containers from a refrigerator.

Recognizing the EmergencyRecognizing the EmergencyA pressurized 240 liter tank of acetonitrile with a broken fittingleaking in a “H” rated storage room equipped with secondarycontainment. Over 40 liters already spilled.

- Hazardous?- Response level need?- What do you do?- Waste requirements?

Recognizing the EmergencyRecognizing the Emergency

Scientist reports a leak in a protein cleaving Scientist reports a leak in a protein cleaving system which uses HF gas. The lab has been system which uses HF gas. The lab has been evacuated but there are people still in the rear evacuated but there are people still in the rear offices. offices.

- Hazardous?- Response level need?- What do you do?- Waste requirements?

Recognizing the EmergencyRecognizing the Emergency

Three unknown victims are found Three unknown victims are found laying on the floor in a chemistry laying on the floor in a chemistry laboratory.laboratory.– The door is closed.The door is closed.– No apparent spill visible No apparent spill visible

thru window in door. thru window in door.

- Hazardous?- Response level need?- What do you do?- Waste requirements?

The RegThe Reg

The HAZWOPER RegulationThe HAZWOPER Regulation– Designed for Emergency ResponseDesigned for Emergency Response– Not intended for small incidental Not intended for small incidental

spillsspills– Requires lots of equipmentRequires lots of equipment– Requires lots of trainingRequires lots of training– Requires lots of practiceRequires lots of practice

Emergency DefinitionEmergency Definition

Size of spillSize of spill

Location of spillLocation of spill

Compound spilledCompound spilled

Hazards of materialsHazards of materials

Each case will be differentEach case will be different

ResponseResponse

Full HAZWOPER Full HAZWOPER ResponseResponse

Smaller responseSmaller response

No responseNo response

Things to Think AboutThings to Think About

The LawThe LawYour OrganizationYour OrganizationComfort LevelComfort LevelLevel of risk Level of risk Risk ManagementRisk ManagementYour LiabilityYour LiabilityEmployee SafetyEmployee SafetyStudent SafetyStudent SafetyPublic OpinionPublic Opinion

So hang in there baby!