Knowing the difference between a hazardous waste site and a construction site was the topic presented yesterday at a roundtable session at the American Industrial Hygiene Conference and Exposition (AIHCE) in Orlando, Fla.
Earl Cook, CIH, member of the OSHA Response Team for OSHA in Salt Lake City, Utah, presented attendees with a list of the differences between a hazardous waste site and a construction site.
Cook noted that a hazardous waste site has several characteristics a construction site lacks. These are:
- uncontrolled condition of the site;
- variety of hazardous substances;
- unidentified hazardous substances;
- disorderly physical environment;
- hazards are not obvious;
- hazards vary according to site location and task; and
- hazards change with site activities.
"This is not your typical construction site. A construction site may allow for more of these factors to be identifiable, such as hazardous substances," said Cook.
After Cook presented the differences between a construction site and a hazardous waste site, he noted specific requirements for hazardous waste sites. These include:
- A written safety and health program.
- Forty hours of training.
- Site control measures.
- Spill contaminant program.
- Medical surveillance program.
- Comprehensive work plan.
- Periodic review and evaluation of program.
"These are all good IH practices anyway. You should be doing these things anyway if you have an effective hazardous waste program," said Cook.
So what does it cost to protect employees and keep your company within the OSHA regulations for hazardous waste sites?
Cook said companies need to look at the cost of their hazardous waste program, the cost of demonstrating that the program works, the cost of a comprehensive safety and health program and the cost of employee injury and illness.
"If you do it right, you don''t need to worry about OSHA," said Cook. "If you have a good program, you will be covered. Remember it has to be a hazard for your company to get a citation."
by Virginia Sutcliffe