Training Focus — Incidental and emergency releases — Train to know the difference
By: Lisa Neuberger
Publication: Environmental Regulatory Alert
Date Posted: 01/29/2018
Workers who are exposed, or could be exposed, to hazardous substances, including hazardous waste, may need specific training under OSHA’s Hazardous Waste Operations standard (HAZWOPER). How much training is needed depends upon the level of responsibility employees are expected to take in response to an emergency.
A few exemptions
There are a few exemptions for very small quantity generators (aka conditionally exempt small quantity generator). However, there are no exemptions for employers who are required by a federal or state agency to have their workers engage in emergency response or who direct their employees to engage in emergency response. If you always require employees to evacuate rather than respond to an emergency, you may not be required to provide HAZWOPER training.
Employees should know the difference between incidental and emergency releases
There are five distinct levels of HAZWOPER training, but all employees should be able to tell the difference between an emergency and an incidental spill.
An incidental release:
- Does not pose a significant safety or health hazard to employees in the immediate area or to the employee assigned to clean it up.
- Does not have the potential to become an emergency within a short timeframe.
- Is limited in quantity, exposure potential, or toxicity.
Small spills, such as a minor splash of used oil being transferred from a small container to a larger container and that is cleaned up with an absorbent rag would be considered an incidental release.
An uncontrolled release of a hazardous substance is an emergency requiring an emergency response if:
- Employees must be evacuated from the area.
- The response comes from outside the immediate release area.
- The release can cause conditions that are immediately dangerous to life and health.
- The release poses a serious threat of fire or explosion.
- The release requires immediate attention because of imminent danger.
- The release could cause exposure to high levels of toxic substances.
- There is uncertainty that the personnel in the work area can handle the severity of the hazard with available personal protective equipment.
- The situation is unclear or data is missing on important information.
- A fire involves spills or releases of hazardous substances (Structural fires or fires of nonhazardous substances are not typically covered by HAZWOPER.).
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