If it is part of their normal job task, then it must be documented. That is why you need rules on "When is a spill really a spill?" and written procedures to follow to determine the extent of response
Not all spills are emergencies
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Further to Ray's correct point, the clarification is in the HAZWOPER inspection guideline:
Another way of saying it is that if cleaning up the spill is part of an employee's "normal" job description and part of what they are responsible for, then it is not covered by the HAZWOPER standard.
Incidental releases that can be safely cleaned up by personnel through the use of methods and PPE they are trained to use from Hazard Communication and other on the job training do not trigger the HAZWOPER standard. The determination of when it is larger than incidental has always been the debate and OSHA attempted to clarify that by saying if you have to bring in a response team from outside the spill area (internal or external) then it triggers the standard.
Ray Cook, CIH, CSP
I Cor 1:18
Sent from my iPhone
On Oct 14, 2014, at 10:35 PM, Jack Armstrong <jack**At_Symbol_Here**AZSAFETY.COM> wrote:
I have always depended on you to add a voice of reason to the DCHAS discussions that were going off track. Today's Discussion is not new in this forum, but it is seriously getting off track again and I am surprised that we have not heard from you.
As you probably know, they are discussing about how to respond to a hazmat release. This question has been settled a long time ago with the OSHA HAZWOPER Standard 1910.120. The issues they are struggling with are covered in great detail in the training.
All emergency chemicals release responses (including laboratories) are covered by this standard. The Hazwoper level that determines who should respond to the release is the First Responder Operation (with the required 8 hours of training) they perform Risk Assessment and determine if the release is "Incidental" or requires a higher level of response like a Technician or the Fire Department.
I have got slapped down on the forum before by the moderator, so I am reluctant to say anything, but you have the required creditability to let them know that they should be considering understanding the HAZWOPER Standard and seeking training and compliance.
I ask you to please wake them up.
One of your admirers,
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