Possible Solutions

HAZWOPER may or may not apply to your brownfield site. See the OSHA Standards section for answers about when OSHA requires compliance with HAZWOPER. You may be required to comply with HAZWOPER through funding contracts or participation in your state Voluntary Clean-up Program. Information on this page and the OSHA Standards page assist in meeting these requirements.

Hazardous Waste Operations and Emergency Response (HAZWOPER)

If your brownfield site is considered to be a "hazardous waste site," you must comply with all the regulations contained in the HAZWOPER standard 29 CFR 1910.120 or 29 CFR 1926.65. Use the following references to determine if your site should be classified as a "hazardous waste site."

General

• Brownfields Health & Safety: For Sites Evaluated & Remediated under Federal Brownfields Initiatives or State Voluntary Clean-up Programs. OSHA Question and Answer Sheet. Compliance information about site assessment and clean-up activities on brownfields.
  • Is a brownfield site a hazardous waste site? Does OSHA's HAZWOPER standard (29 CFR 1910.120 or 1926.65) apply to work done
  • Who prepares a site HASP and who is covered by it? Can a HASP prepared by site contractors cover oversight personnel or other workers on site only occasionally?
  • What is the difference between the site-specific HASP and the Health and Safety Program required by HAZWOPER?
  • Who is responsible for safety and health oversight at a brownfield site?
  • Who enforces safety and health requirements at a brownfield site?
  • What is OSHA's role at a brownfield site?
  • What is the EPA's role in safety and health at a brownfield site?
  • What is the State's role in S&H at a brownfield site?
  • Do all responses to hazardous substance releases on a brownfield site require emergency responses?
  • How do brownfield site emergency responders need to be trained and prepared?
• HAZWOPER may be your primary concern, but other General Industry and Construction Industry standards may also apply to your site activities.
  • What OSHA Health and Safety Requirements Apply to My Brownfield?. OSHA and the Environmental Protection Agency (EPA) Environmental Response Team, (2000). OSHA poster presentation at Brownfields 2000 Conference. Summarizes compliance information related to brownfield sites.

Chemical

If your site meets the scope of HAZWOPER, then a qualified person must characterize the site, identifying the presence and concentrations of hazardous substances and their associated risks (29 CFR 1910.120(c)/29 CFR 1926.65(c)). Otherwise, a hazard assessment must be conducted in order to determine if hazards are present, or likely to be present, that necessitate the use of personal protective equipment (29 CFR 1910.132(d)).

• Preventing Occupational Illnesses through Safer Chemical Management. OSHA.
• Related Safety and Health Topics Pages
  • Carcinogens
  • Dermal Exposure
  • Personal Protective Equipment
  • Reproductive Hazards
  • Respiratory Protection
  • Toxic Metals
  • OSHA also regulates chemical exposures through health-based chemical specific standards, see the chemical specific Safety and Health Topics Pages such as Benzene and Methylene Chloride that may apply to your site.

Physical

• Construction Industry Digest. OSHA Publication 2202, (2015).
• Related Safety and Health Topics Pages
  • Confined Spaces
  • Demolition
  • Electrical
  • Fall Protection
  • Fire Safety
  • Control of Hazardous Energy (Lockout/Tagout)
  • Hand and Power Tools
  • Occupational Heat Exposure
  • Occupational Noise Exposure
  • Trenching and Excavation
  • Welding, Cutting, and Brazing

Biological

• For additional information, see OSHA's Bloodborne Pathogens and Needlestick Prevention Safety and Health Topics Page.

General

• Brownfields Health & Safety: For Sites Evaluated & Remediated under Federal Brownfields Initiatives or State Voluntary Clean-up Programs. OSHA Question and Answer Sheet. Compliance information about site assessment and clean-up activities on brownfields.
  • Our loan/contract/Cooperative Agreement requires a site-specific health and safety plan (HASP) consistent with 1910.120 prior to starting field work. What is this plan and what must it contain?
  • Who prepares a site HASP and who is covered by it? Can a HASP prepared by site contractors cover oversight personnel or other workers on site only occasionally?
  • The State requires a site-specific HASP and "compliance with 1910" to participate in the Voluntary Clean-up Program (VCP). What does this mean?
• Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities. National Institute for Occupational Safety and Health (NIOSH), OSHA, U.S. Coast Guard (USCG), and the Environmental Protection Agency (EPA), (1985). Identifies hazards and exposure controls, and provides a generic health and safety plan template in Appendix B.
• Summary of the Small Business Liability Relief and Brownfields Revitalization Act. Environmental Protection Agency (EPA). Congress passed this act in January 2002, amending the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). The amendment defines the term "brownfield site," provides funding for brownfield site assessment and clean-up, and clarifies liability issues for sites that have completed State Voluntary Cleanup Programs.

Chemical

Many of the resources listed here are also applicable for Physical and Biological hazards.

• Small Entity Compliance Guide for the Respiratory Protection Standard. OSHA Publication 3384, (2011). Provides small entities with a comprehensive step-by-step guide complete with checklists and commonly asked questions that will aid both employees and employers in small businesses with a better understanding of OSHA’s respiratory protection standard.
• Respiratory Protection. OSHA eTool. Highlights selection, use, fit testing, change-out schedules, medical and written program requirements.
• Recommendations for Chemical Protective Clothing Database. National Institute for Occupational Safety and Health (NIOSH). Identifies protective clothing materials appropriate for chemicals listed in this pocket guide.
• Personal Protective Technology. National Institute for Occupational Safety and Health (NIOSH) Program Portfolio. Provides an example of a written program.
• For additional information, see OSHA's Safety and Health Topics Pages on:
  • Medical Screening and Surveillance
  • Personal Protective Equipment
  • Respiratory Protection
  • Ventilation

Physical

• Construction Industry. OSHA. Provides links to OSHA Construction Standards and agency policies.
• Engineering Manual EM 385-1-1. U.S. Army Corps of Engineers (USACE), (November 15, 2008). Identifies safety and health requirements including physical hazards and exposure controls.
• For additional information, see OSHA's Brownfields Exposure Evaluation Safety and Health Topics section.

Biological

• Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards (PDF). OSHA Publication 3186, (2003).
• Lyme disease vaccination. Centers for Disease Control and Prevention (CDC). The vaccine for Lyme disease is no longer available.
• Lyme Disease. Centers for Disease Control and Prevention (CDC).
• Lyme Disease. National Institute for Occupational Safety and Health (NIOSH) Workplace Safety & Health Topic.
• Hantavirus: Education Materials and Media. Centers for Disease Control and Prevention (CDC). Provides brochures, manuals, podcasts and video on Hantavirus Disease.
• Biological Hazards. Canadian Centre for Occupational Health and Safety (CCOHS).
• For additional information, see OSHA's Bloodborne Pathogens and Needlestick Prevention Safety and Health Topics Page.