A COMPARISON OF OSHA HAZWOPER,OSHA HAZCOM,OSHA HAZMAT AND DOT HAZMAT TRAINING REQUIREMENTS AS THEY APPLY TO WASTE MANAGEMENT FIELD OPERATIONS

摘要

The primary regulations governing WESKEM,LLC field-response activities are the Occupational Safety and Health Administration’s(OSHA’s)29 CFR 1910.120-Hazardous Waste Operations and Emergency Response(HAZWOPER)and 29 CFR 1910.1200-Hazard Communication(HAZCOM).Regarding off-normal events,hazardous materials response (OSHA HAZMAT)is covered in 29 CFR 1910.120(q).Many of these same activities are regulated by the Department of Transportation(DOT)which addresses the transportation of hazardous materials(DOT HAZMAT)either in commerce or at on-site locations.Fortunately, HAZWOPER,HAZCOM and OSHA HAZMAT can be used to supplement DOT HAZMAT on the basis of equivalent training.However,all four acronyms can be,and are often used interchangeably throughout training or contractual documentation.Because of the differences between OSHA and DOT,it is essential that employees receive the proper training as applied to a comprehensive waste management program.To resolve these differences and to eliminate acronym confusion,this paper 1)clarifies the fundamental differences and training requirements of OSHA HAZWOPER,OSHA HAZCOM,OSHA HAZMAT,and DOT HAZMAT;and 2) demonstrates how OSHA resources,because of equivalency,can be used to supplement 49 CFR 172-Subpart H:Training for DOT HAZMAT employees.Although utilizing existing training information offered by HAZWOPER and HAZCOM eliminates duplication,the information provided by OSHA should neither be all-inclusive,nor a comprehensive substitute for DOT HAZMAT.Both HAZWOPER and HAZCOM do not necessarily train to the specific elements of 49 CFR 172 such as the hazardous materials table,appropriate packaging,segregation and securement,or loading/unloading in preparation of a hazardous materials shipment.DOT HAZMAT focuses on the work functions covered by the Hazardous Materials Regulations to ensure that shipments are completed according to regulation and accomplished safely without incident.