Cal OSHA guidelines for hazardous waste disposal are based on California Title 8 regulations. There are several components or steps to ensure Cal OSHA compliance. They include 1. A safety and health Program 2. Site characterization 3. Training 4. Medical Surveillance 5. Engineering controls and 6. Monitoring.
We take a brief look at each of these steps below:
Safety and Health Program
All employers are required to develop and enforce a written safety and health program for all employees involved in hazardous waste operations. The program should aim to identify, evaluate, and control safety and health hazards, as well as outline emergency responses to hazardous waste operations.
A written safety and health program must include the following:
- An organization structure
- A comprehensive work plan
- A site-specific safety and health plan separate from the employer’s standard operating procedures
- A safety and health training aspect
- A medical surveillance aspect
- The employer’s standard safety and health operating procedures
Site Characterization and Analysis
All hazardous waste sites have to be evaluated by qualified professionals to identify hazards that are specific to these sites and to determine safety and health control protocols that are required to protect employees from these hazards.
Here is a list of the details that should be obtained by the employer and given to employees before these employees enter these sites:
- The location and approximate size of the site
- An outline of the response activity that employees are tasked with
- How long the activity will take
- Site topography and accessibility via roads or air if necessary
- The expected safety and health hazards
- Pathways through which hazardous substances could disperse
- The current state and capabilities of emergency response teams in charge of assisting employees in hazardous waste clean-up sites during emergencies.
- Hazardous substances and health hazards at the site, including their chemical and physical characteristics
Training
All employees working on hazardous waste disposal sites who run the risk of being exposed to such hazardous chemicals should receive review training. This includes equipment operators, general operators, and other workers.
Employees should not be allowed to participate in or supervise field activities before undergoing the necessary level of training. The training should include:
- The names of personnel responsible for site safety and health
- Hazards to health and safety on the site
- Use of personal protective equipment
- Work practices that can help employees minimize hazard risks
- Safe use of engineering controls and on-site equipment
- Medical surveillance requirements, such as being able to recognize symptoms that might indicate overexposure to hazards
Medical Surveillance
A medical surveillance program should also be included for any employee who may be exposed to hazardous substances. Medical examinations should also be conducted regularly by employers on employees at least once every 12 months.
Engineering Controls
Engineering controls designed to make the workplace safe for your employees and to reduce exposure to hazardous waste should be implemented. This includes Personal protective equipment guard rails. Safety Data Sheets can be used as guidance when enacting these controls.
Monitoring
Monitoring should be frequently carried out at sites where hazardous waste is located and in which employees have to work. Soil and air should frequently be checked to ensure that the level of toxic substances in them is not abnormally high to pose a risk to employees.
Employees at high-risk of exposure should also be regularly monitored. Monitoring should always be carried out under circumstances where the risk of exposure is high. This includes:
- When work starts on a different part of the site.
- When new contaminants are being handled.
- When a different operation is initiated
- When employees handle drums or containers with leaks or work in areas with apparent liquid contamination
Conclusion
Hazardous waste disposal presents significant risks to both worker health and the environment. OSHA has established clear guidelines for defining and classifying hazardous waste, which employers must understand. A comprehensive safety and health program is essential to protect employees, ensuring they are well-trained in precautions, protective measures, and equipment use.
Also, regular monitoring of hazardous waste levels helps avoid potential violations. Due to the complexity of OSHA regulations, it’s advisable to have experts manage compliance and safety to meet EHS standards.
This is where we step in at CDMS. We offer services that cover hazardous waste reporting, determination, and minimization. With in-depth knowledge of state laws and regulations, CDMS is perfectly placed to assist you in navigating hazardous waste disposal compliance challenges. Contact CDMS for expert assistance today.
