Safety Programs
Several statutory safety programs exist at the Federal and state levels that directly impact remediation projects. These include Occupational Safety and Health Administration (OSHA) standards and the Department of Transportation (DOT) Hazardous Materials Shipping regulations.
The OSHA standards applicable to remediation projects include 29 CFR 1910 (General Industry) and 29 CFR 1926 (Construction). In particular, the requirements of 29 CFR 1910.120 directly address Hazardous Waste Operations (HAZWOPER) and are applicable to work performed on all contaminated sites during all stages of the remedial process. Many portions of the remainder of 29 CFR 1910 are applicable to specific activities that may be encountered in the remedial process. 29 CFR 1926 is specifically applicable to construction activities, which may also be encountered during field phases of the remedial process.
The DOT Hazardous Materials Shipping regulations found at 49 CFR Parts 171 through 177 are applicable to the shipping of hazardous materials via a commercial carrier. Hazardous materials shipping may occur during remediation or in other phases of the remedial process such as shipping samples. Note that while RCRA provides an exemption for shipping samples, that exemption applies only to the RCRA hazardous waste shipping requirements (e.g. manifests, licensed shipping companies, etc.), and does not extend to the DOT Hazardous Materials shipping requirements, which must still be met. Significant penalties can and have been levied against improper shipping of samples. Given the current climate regarding security, it is imperative that hazardous materials be recognized, properly identified, properly packaged, labeled, and correctly shipped via a carrier licensed to receive and transport them. The DOT regulations also place the onus on the person shipping the hazardous materials to provide the carrier with any applicable notices and/or placards.
Experience
I am thoroughly familiar with the OSHA regulations as they apply to work in the remediation business. I have worked for numerous clients who have earned the world-class safety organization designation and demand zero incidents on their job sites. Accordingly, I have developed the ability to anticipate what types of hazards may be present, and how to properly plan for safe execution of the work. The work planning exercise will typically evaluate each step of the work relative to the potential hazards and identify ways to mitigate the hazards prior to executing the work. I have also developed a keen eye for identifying potential hazards that could not be anticipated prior to the work. Because of such cases, I believe that every worker needs to be empowered to stop work to avoid accidents.
During my career, I have also been tasked with shipping thousands of tons of hazardous waste as well as many thousands of environmental samples. As a result, I have developed expertise in the DOT Hazardous Materials Shipping Regulations and have provided training to personnel involved in shipping hazardous materials. I also believe that any person responsible for shipping via commercial carrier should have awareness training to avoid illegally shipping hazardous materials or shipping packages that are improperly labeled. Shipping incidents can end up in the public eye even if there are no injuries or property damage, and can cost tens of thousands of dollars in fines and re-training.