OSHA 1926.65a

OSHA 1926.65a: HAZWOPER (continue….)

Medical Surveillance (1926.65(f))

Who Needs It? : OSHA 1926.65a: HAZWOPER

• Employees exposed to hazards for ≥30 days per year, including those wearing respirators or on HAZMAT teams.
• Who suffer from workplace exposure said by OSHA 1926.65a

When to Examine: OSHA 1926.65a: HAZWOPER

• At hiring, then annually (or biennially if approved by a physician).
• Upon job change or termination, if the last exam was over 6 months ago.
• Immediately after any signs of exposure, injury, or overexposure.
• For symptomatic or injured workers, as soon as possible after the incident, with follow‑up exams as needed.

What the Exam Covers: OSHA 1926.65a: HAZWOPER

• Reviews medical and work history, focusing on symptoms linked to hazardous exposures and ensuring the worker can safely wear PPE (like respirators) under site conditions.
• Specific tests are at the physician’s discretion, guided by OSHA 1926.65a: HAZWOPER manual.

Cost & Provider Credentials

• Exams are free to employees, during paid time, and conducted by a licensed physician—ideally trained in occupational health.

Doctor’s Report

• Employers must receive a written opinion, shared with the employee, summarizing:
  1. Medical fitness and PPE use
  2. Any recommended work restrictions
  3. Test results if requested
  4. Confirmation that the employee was informed of findings
• Confidential health details beyond this summary may not be shared.

Recordkeeping

• Employers must retain medical records per OSHA’s recordkeeping rules (29 CFR 1926.33), including test results, opinions, and exposure-related complaints.

OSHA 1926.65(g): Controls & PPE for Hazardous Worksites

Hierarchy First: Engineering & Work Practice Controls

1. Use engineering controls and safer methods whenever possible to keep exposure below legal limits (e.g., sealed cabs, remote handling, isolating dusty operations, positioning workers upwind)
2. If those aren’t feasible, combine controls and PPE to maintain safety levels
3. Job rotation can only be used to reduce radiation exposure when no other control works

Applying Controls to Unregulated Hazards

• For hazards not governed by a specific OSHA limit, use engineering, work practices, and PPE to keep exposures below published safety limits (e.g., SDS or scientific studies)

Choosing the Right PPE

• PPE must be designed specifically for identified site hazards and work conditions
• Selection should consider PPE performance, site demands, task duration, and environmental factors
• Use positive-pressure respirators (SCBA or supplied-air with escape backup) if exposure poses immediate or serious health risks
• Wear fully-encapsulating Level A suits where skin contact could cause serious injury or impair escape Adjust protection levels (up or down) as more site info becomes available
• All PPE selections must comply with OSHA Subpart E standards

Monitoring & Suit Integrity

• Total-encapsulation suits must maintain positive pressure to seal out contaminants
• Air monitoring should guide PPE and control decisions to ensure exposures remain within safe limits, using instruments and site data

1926.65(g)(4): Fully Encapsulating Suits (Level A)

• Custom protection: These total-encapsulation suits must shield workers from the specific hazards identified on-site.
• Positive pressure: The suit must maintain internal air pressure to prevent contamination.
• Leak-tight performance: Compliance requires leakage of less than 0.5% during pressurized testing.

1926.65(g)(5): Written PPE Program

Employers must maintain a site-specific PPE plan covering:

1. PPE selection and limits
2. Duration of use
3. Maintenance and storage
4. Decontamination and disposal
5. Fit, training, and safe don/doff procedures
6. Inspection before, during, and after use
7. Effectiveness reviews
8. Consideration of temperature and heat stress

1926.65(h): Air Monitoring

• Purpose: Ensure exposures stay below permissible or published limits via air testing.
• Initial checks: First entry calls for tests for IDLH, oxygen deficiency, radiation, and flammable atmospheres.
• Periodic monitoring: Anytime site conditions change—new area work, container disturbance, unknown contaminants.
• High-risk sampling: Workers in heavy-exposure tasks (e.g., soil or container handling) must use personal sampling to track exposure levels

1926.65(i): Information Sharing

Provide all workers, contractors, and subcontractors with details about potential hazards, exposure levels, and protective measures before they enter the work area.

1926.65(j): Drum & Container Handling

• Safe practices: Transport and label hazardous materials per OSHA, DOT, and EPA guidelines.
• Pre-move checks: Inspect any drum or container before moving; if inaccessible (e.g., buried or stacked), relocate it safely first.

Handling Drums & Containers Safely (1926.65(j.1.iv–viii))

• Unlabeled containers are hazardous by default: Treat and handle them as if they contain dangerous substances until properly identified and labeled.
• Minimize movement: Plan site activities to limit how often containers are shifted.
• Warn employees: Inform personnel near containers before any movement operation begins.
• Prepare for spills: Keep DOT-approved salvage drums and absorbents nearby in high-risk areas.
• Major spill containment: Sites must have systems ready to isolate full volumes of spilled material.

Safe Container Transfer (1926.65(j)(1.ix–xii))

• Remove contents carefully: If a container can’t be moved safely, transfer material into secure functional vessels.
• Locate hidden containers: Use ground-penetrating or similar devices to detect buried drums before digging.
• Careful excavation: Dig slowly around buried containers to avoid accidental punctures.
• Fire protection: Match site fire suppression tools with OSHA Subpart F requirements.

Opening Drums (1926.65(j)(2))

• Air-line respirator care: Protect air connections and devices from contamination or damage.
• Restrict access: Only trained workers may open containers; others keep a safe distance behind shielding.
• Remote controls: Use explosion-resistant shielding for pre-opening controls and fire gear.
• Ignition control: For flammable atmospheres, only non-sparking tools and equipment may be used.
• Pressure relief: Safely vent container pressure, preferably remotely or shielded.
• No standing on drums

Specialized Containers (j.3–j.5)

• No ignition sources: Equipment used for handling must not create sparks or ignition risks.
• Radioactive contents: Assess hazards before moving or opening containers.
• Shock-sensitive materials:
  • Evacuate unnecessary staff
  • Use explosion-proof shields and barriers
  • Maintain continuous low-impact communication
  • Avoid moving bulging or pressurized drums until secured
  • Handle laboratory waste (“lab packs”) as potentially explosive until characterized

Safe Handling of Shock-Sensitive Waste & Lab Packs

j(5) Shock-Sensitive Waste Controls

• Audible Alerts: Use alarm systems that are louder than ambient site noise and visible above surrounding light to signal start and end of explosive waste handling
• Ongoing Communication: Maintain reliable contact (radios, hand signals, phones) between the handler, site safety supervisor, and command post—avoid gear that could trigger reactions
• Pressurized Container Safety: Don’t move bulging or swollen drums until pressure causes are identified and secured
• Lab Pack Precaution: Treat containers with crystalline residue as potentially explosive until fully assessed

j(6) Handling Laboratory Waste Packs

• Expert Handling Only: Only trained personnel knowledgeable in waste classification should open lab packs
• Crystalline Alert: Any crystallized container must be treated as shock-sensitive until proven safe

j(7–8) Sampling & Transport

• Certified Sampling: Follow pre-approved, site-specific procedures when taking samples from drums/containers
• Safe Staging & Shipment:
  • Identify and classify all drums/containers correctly before shipment
  • Keep staging zones minimal, clearly marked, and with safe access routes
  • Only combine wastes after complete characterization to avoid unexpected hazards

j(9) Tanks & Vaults

• Use Drum-Level Caution: Apply the same safe practices for drums and containers to tanks or vaults, scaled to their size.
• Follow Entry Protocols: Enter tanks/vaults only under approved, site-specific safety procedures