![]() ![]() Further, as your letter describes your operations, your workers are clearly being asked to respond outside of their "normal work area." Your letter also states that the entire plant should be considered the "normal work area." This appears to assume that workers responding within their normal work area is a crucial element in determining whether they are covered by HAZWOPER this is not the case. These workers have received training in accordance with the requirements of the Hazard Communication Standard (.1200) regarding the hazardous materials present in the other process areas. During off-shifts, assistance may be requested from workers from another process area "in the event of a hazardous material emergency" because there are a limited number of workers on-site. Your facility does not have a HAZMAT team, and an outside HAZMAT team would be called in to handle emergency response beyond the Operations Level. In your letter you state that your workers are trained to the First Responder Operations Level to perform defensive action in responding to emergencies within their own process area unit. OSHA is not in agreement with the approach you have described. Your question requests clarification on the acceptability of your off-shift incident and emergency response capabilities, particularly regarding your training program for First Responder Operations Level responders who perform defensive action outside of their own process area. Thank you for your letter of April 15, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation. ![]()
0 Comments
Leave a Reply. |
AuthorWrite something about yourself. No need to be fancy, just an overview. ArchivesCategories |