Safety Professionals should have a working knowledge of a broad range of Health, Safety and Environmental (HSE) regulations for several reasons:

  • It makes them more valuable to their current and future employers.

  • It allows them to make more informed decisions because they see the bigger HSE picture.

  • Regulatory Compliance is more streamlined and without redundancy.

  • Checks and balances are more likely to occur, reducing the chance for error.

  • Common goals for mutual benefit can be achieved.

OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard provides an excellent backdrop for taking an overview of many inter-related safety, environmental, and hazardous materials regulations. The HAZWOPER standard is very comprehensive and complex.

It should be noted that this paper will not address air and water environmental regulations. If you can understand the HAZWOPER standard, you can understand a great deal about HSE and how many standards are inter-related. Using HAZWOPER as our backdrop, what standards can be inter-related?

Figure 1 (available in full paper).

It is important to start with some basic understandings about the regulatory framework:

Framework (available in full paper).

HAZWOPER - Hazardous Waste Operations and Emergency Response is one of OSHA's most comprehensive standards. When hazardous waste became more tightly regulated in the early 1980s, and workers started attempting to clean up all the messes, all sorts of mayhem started happening. Hence, the need was recognized for OSHA to develop a standard to protect these workers.

HAZWOPER essentially requires a full health and safety process that includes virtually all regulations covered by OSHA. Considering the hazards that may arise in an uncontrolled hazardous waste site, it's clear that most regulations could apply. Many of these regulations are noted in Figure 1. Also note that there is a construction standard for HAZWOPER: 1926.65.

Figure 2 (available in full paper).

As noted, a very broadly written Safety and Health Program is required under HAZWOPER. Written programs are required for all hazards that are found on the waste site covered by OSHA. Thus, the written program will be very comprehensive. The HAZWOPER standard is the only place OSHA requires a written program covering this wide a scope. Because of this, the HAZWOPER standard can serve as a good model for businesses to compare their written programs for completeness.

Comparable to environmental assessments, HAZWOPER requires a characterization and analysis for safety and health hazards and potentials. Accordingly, control measures must be specified to address the hazard potentials identified.

The HAZWOPER standard requires a large amount and many different types of training depending on the type of waste site - uncontrolled, Treatment, Storage, Disposal (TSD), generator, or other, and the job functions of all personnel involved. Training is delineated throughout the standard based on these factors and cross-referencing in often used. Because of this, there is difficulty understanding how to conduct training.

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