1 Environmental Complaince Manual for Aosh Course

This publication updates in
March/September
This publication updates in
March/September
Environmental Compliance Manual
Copyright 2014
J. J. Keller & Associates, Inc.

3003 Breezewood Lane
P.O. Box 368
Neenah, Wisconsin 54957-0368
Phone: (800) 327-6868
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Original content is the copyrighted property of J. J. Keller & Associates, Inc.

Introduction
More than three decades ago, the American public began demanding a higher standard of
environmental accountability from industry. Safer air, cleaner water, uncontaminated land, and
community safety came to the forefront of the American agenda. In response to the demand, the
Environmental Protection Agency (EPA) was established in 1970. Summarized in a single,
unyielding mission, EPA pledged to protect human health and the environment.
Focusing on air, water, and land, EPA has developed specific programs to clean up past mistakes
and prevent future pollution. Today, EPA’s regulations touch on almost every aspect of industry,
from air emissions, to drinking water and stormwater control, to chemical and waste storage,
shipping, and cleanup. These increasingly complex and costly regulations often overlap with
workplace safety, transportation, and other federal and state laws.
Whether you are the company owner, the plant manager, or the safety supervisor, if you have
the responsibility of administering environmentally regulated company policies and proce-
dures, you need to stay current with EPA’s rules and regulations and how they affect your
operations. Use this manual to help you get started or to improve an existing program.
Revision bars, like the one at the left of this paragraph, are used in this publication to show
where significant changes were made on update pages. The revision bar next to text on a page
indicates that the text was revised. The date at the bottom of the page tells you when the
revised page was issued.
Due to the constantly changing nature of government regulations, it is impossible to guarantee
absolute accuracy of the material contained herein. The Publisher and Editors, therefore,
cannot assume any responsibility for omissions, errors, misprinting, or ambiguity contained
within this publication and shall not be held liable in any degree for any loss or injury caused
by such omission, error, misprinting or ambiguity presented in this publication.
This publication is designed to provide reasonably accurate and authoritative information in
regard to the subject matter covered. It is sold with the understanding that the Publisher is not
engaged in rendering legal, accounting, or other professional service. If legal advice or other
expert assistance is required, the services of a competent professional person should be sought.
The Editors & Publisher
9/14 iii


3003 Breezewood Lane,, P.O. Box 368
Neenah, Wisconsin 54957-0368
Phone: (800) 327-6868
Fax: (800) 727-7516
JJKeller.com
publishers ROBERT L. KELLER

JAMES J. KELLER
EDITORIAL
vice president – editorial resources WEBB A. SHAW
director – editorial resources PAUL V. ARNOLD
project editor LISA M. NEUBERGER
sr. editorial manager - workplace safety PETER M. MCLAUGHLIN
sr. editor - workplace safety J. TRAVIS RHODEN
editor - workplace safety ROBERT A. ERNST
editor - workplace safety TRICIA S. HODKIEWICZ
editor - workplace safety JUDIE SMITHERS
editor - workplace safety MARK H. STROMME
editor - workplace safety JENNIFER J. STROSCHEIN
sr. metator/xml analyst MARY K. FLANAGAN
sr. layout editor MICHAEL P. HENCKEL
PUBLISHING GROUP
chairman ROBERT L. KELLER
vice chairman & treasurer JAMES J. KELLER
president & ceo MARNE L. KELLER- KRIKAVA
evp & chief operating officer RUSTIN R. KELLER
chief financial officer DANA S. GILMAN
sr. director of product development CAROL A. O’HERN
sr. product development manager JENNIFER M. JUNG
product development specialist ASHLEY C. PUCKER
director of manufacturing TODD J. LUEKE
sr. electronic publishing & prepress manager GERALD L. SABATKE
The Editorial Staff is available to provide information generally associated with this publication to a
normal and reasonable extent, and at the option of, and as a courtesy of, the Publisher.
iv 9/14

Environmental compliance
Clean air
Clean water
HazCom
Storage tanks
Waste
Community right to know
Hazardous materials
Hazardous waste operations and emergency response
Process safety management/risk management plan
TSCA
Compliance guidance
Industry specific
Security
ISO 14000 environmental management standards
Sustainability
References
State information
Federal information
Subject Index
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Reserved
vi 3/13

How to use this manual

Whether you’re a safety and security specialist, the environmental health and safety manager,
a facility operator, or the owner of a small business, you wear many hats. It can be a real
challenge to keep up with the growing list of environmental regulations, especially when they
are only part of your responsibilities.
To protect yourself, your company, and its assets, it is important for you to stay current on
environmental laws. That’s because the Environmental Protection Agency (EPA) has ramped
up its inspection and enforcement efforts. The agency has shown a new willingness to pursue
criminal prosecutions for environmental violations.
EPA enforcement data for FY 2012 shows the agency assessed over $252 million in criminal
fines and civil penalties and required companies to invest an additional $44 million in invest-
ments for supplemental environmental projects.
Further, EPA is using the power of public accountability for its environmental compliance
initiatives. The agency publishes lists of violators on its website and provides information to
communities on possible pollution threats from neighboring industries.
The purpose of this manual is to help you keep your head above water by providing information
and compliance help for those detailed and complex environmental rules, regulations, and
related requirements. Keep in mind that the lion’s share of environmental regulation is carried
out on the state, regional, and local level. Most states can, and do, have more strict regulations
in place than the federal. Where state law differs from the federal, we will strive to point out
those differences. However, you should always check with your state environmental regulatory
agency before taking action on any environmental topic.
Since environmental laws are so varied, each section in this book will necessarily differ in the
amount of information presented and the compliance tools that go with it. However, you can
expect every topic to provide you with an in-depth review of the environmental law, from the
statute to the specific regulations and methods for complying with them.
A word of caution
The material presented in this book will be up-to-date at the time of publication, however, this
manual is not intended to take the place of the environmental regulations found in the Code of
Federal Regulations (CFR) at 40 CFR Protection of the Environment. Due to the constantly
changing nature of these regulations, it is impossible to guarantee absolute accuracy of the
material contained herein. The Publisher and Editors, therefore, cannot assume any respon-
sibility for omissions, errors, misprinting, or ambiguity contained within this publication and
shall not be held liable in any degree for any loss or injury caused by such omission, error,
misprinting, or ambiguity presented in this publication.
This publication is designed to provide reasonably accurate and authoritative information in

regard to the subject matter covered. It is sold with the understanding that the Publisher is not
engaged in rendering legal, accounting, or other professional service. If legal advice or other
expert assistance is required, the services of a competent professional person should be sought.
3/13 vii

Introduction to the Environmental Protection Agency

The Environmental Protection Agency (EPA), established on December 2, 1970, is the country’s
overseer of environmental laws. The Agency began with a focus on conservation and ecology,
moving toward today’s emphasis on preventing pollution, enforcement activities, and environ-
mental justice.
Before EPA, factories could release toxins into the air with impunity, waste could leach into
groundwater, and poisons could be dumped into lakes; there were no legal resources to stop the
pollution. But the country was recognizing the need for environmental reform. The first Earth
Day, a grass roots effort to bring attention to needed pollution controls, took place on April 22,
1970. Americans demanded cleaner water, air, and land; in response EPA was assigned the job
of repairing environmental damage and establishing guidelines to prevent further pollution.
Today, few federal agencies are as polarizing as the EPA. Agency actions can have far-reaching
effects on the economy, foreign-policy, state government policies, business growth and develop-
ment, and even personal freedoms. While many believe that being pro-environment or pro-
industry are mutually exclusive, it is possible to meet environmental obligations and maintain
a successful business. In fact, focusing on environmental impacts can often have a positive effect
on a company’s bottom line. For instance, developing and maintaining an environmental man-
agement system (EMS) can help a business approach risks in a systematic way and help
identify opportunities to create safer, healthier workplaces, as well as ways to become more
efficient and remain in compliance with environmental laws. In addition, many businesses find
their customers want them to be aware of their environmental impact. A good environmental
program can reduce insurance premiums, create customer goodwill, and save money.
How EPA is organized

EPA is run at both the federal and regional levels. At the federal level, the Agency is divided into
12 main offices.
Office of the Administrator (AO)

Office of Administration and Office of Air and Radiation Office of Chemical Safety Office of the Chief Financial
Resources Management (OAR) and Pollution Prevention Officer (OCFO)
(OARM) (OCSPP)
Office of Enforcement and Office of Environmental Office of General Counsel Office of Inspector General
Compliance Assurance Information (OEI) (OGC) (OIG)
(OECA)
Office of International and Office Research and Office of Solid Waste and Office of Water (OW)
Tribal Affairs (OITA) Development (ORD) Emergency Response
(OSWER)
EPA also operates 10 regional offices around the nation.
viii 3/13

Plans and priorities

EPA is accountable to the President, Congress, and the American people for its budget and its
performance. As such, the Agency manages its planning, budget, and performance results in a
continuous cycle. EPA lays out multi-year strategic plans and sets goals for pollution controls
and enforcement. Accomplishments are judged by how well the Agency met the goals for the
previous year.
EPA’s top 7 themes

In 2013, EPA Administrator Gina McCarthy listed the agency’s “themes” going forward:
1. Making a visible difference in communities across the country.
2. Addressing climate change and improving air quality.
3. Taking action on toxics and chemical safety.
4. Launching a new era of state, tribal, and local partnerships.
5. Embracing EPA as a high performing organization.
6. Working toward a sustainable future.
However, as the Agency focuses on those themes, it also answers to Congress and the President.
In January 2011, President Obama signed Executive Order 13563 that effectively increases
oversight on government agencies such as EPA. Under the order, agencies must now consider
both the paperwork burdens and financial burdens of proposed rules, and allow more public
participation in the rulemaking process. Agencies must now choose the least burdensome regu-
lations, look for ways to avoid issuing direct regulations, and whenever possible specify
performance objectives rather than identifying a particular manner of compliance.
Multi-year strategic planning

EPA’s strategic plan for fiscal year (FY) 2011-2015 advances the Agency’s stated priorities. You
can read the plan at bit.ly/EPAStrategicPlan2011. The plan identifies five strategic goals and
lays out a blueprint for achieving those goals. Those goals are:
• Goal 1: Taking Action on Climate Change and Improving Air Quality
• Goal 2: Protecting America’s Waters

• Goal 3: Cleaning Up Communities and Advancing Sustainable Development
• Goal 4: Ensuring the Safety of Chemicals and Preventing Pollution
• Goal 5: Enforcing Environmental Laws
Climate change takes center stage in EPA’s planning. The agency believes climate change poses
great risks to human health, the environment, cultural resources, the economy, and quality of
life. To address this issue, EPA will take action to reduce greenhouse gas emissions.
Further, the Agency says it will improve air quality by achieving and maintaining health-based
air pollution standards and reduce toxic air pollutants and indoor air contaminants.
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Other objectives include restoring the ozone layer and reducing unnecessary exposures to
radiation.
A focus on enforcement activities

Part of EPA’s purpose is to enforce environmental regulations. The Agency certainly hasn’t been
hesitant to use criminal and civil remedies to go after polluters. The Agency says, “Enforcement
deters those who might otherwise profit from violating the law, and levels the playing field with
environmentally compliant companies.”
EPA’s Enforcement arm is divided into three main focus areas: Civil, cleanup, and criminal.
Civil enforcement uses legal action to bring violators into compliance with state and federal
environmental laws.
Cleanup actions require those responsible for a hazardous waste site to either clean up or
reimburse EPA for the cleanup. EPA’s most often used and most powerful cleanup enforcement
mechanism is the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA or Superfund). Superfund is a cleanup authority only and does not otherwise regulate
a facility’s operations. The Resource Conservation and Recovery Act (RCRA), including the
Underground Storage Tank (UST) program, contain both cleanup and regulatory authority.
RCRA’s cleanup authority is the RCRA Corrective Action program, which addresses cleanup
activities at RCRA regulated facilities.
The Integrated Cleanup Initiative (ICI) is a current program, initiated in 2010, to focus on
ensuring responsible parties are compelled to clean up contaminated sites.
The criminal enforcement program enforces the law through investigating cases, collecting
evidence, conducting forensic analyses, and providing legal guidance to assist in the prosecu-
tion of criminal conduct that threatens health and the environment.
Enforcement data
To get an idea of how EPA uses legal remedies to enforce its agenda, take a look at these figures
from EPA’s compliance and enforcement analysis for 2011:
2011 EPA enforcement estimates:
• $19 billion invested to improve environmental performance (a record year);
• $3 billion (included in the $19 billion) to clean up hazardous waste in communities

and ensure that the polluter pays (a record year);
• $168 million assessed penalties to deter pollution (Includes $16 million in state pen-
alties from joint federal enforcement action);
• $25 million in additional investments for supplemental environmental projects that

benefit communities;
• 3.6 billion pounds of hazardous waste treated, minimized, or properly disposed of;
x 3/14

• 1.8 billion pounds of pollution reduced, treated or eliminated; and
• 89.5 years of incarceration for environmental criminals.
The Agency breaks out its annual enforcement data into its civil, criminal, cleanup, federal
facility, compliance and environmental justice programs.
In addition, EPA tracks enforcement data by regions and communities. You can find EPA’s
Enforcement Cases Map for 2011 at epa.gov/compliance/resources/reports/endofyear/eoy2011/
nationalmap.html.
Along the same lines, EPA keeps track of National Enforcement Trends (NETs) totaling
national and regional federal activity in both the short and long terms. NETs use a variety of
graphic and interactive tools to chart the top enforcement cases starting in 1996, enforcement
of national priorities, inspections and investigations, civil and criminal penalties, and more.
EPA’s NETs page is at epa.gov/compliance/data/results/nets.html.
What is environmental justice?

EPA says environmental justice is the fair treatment and meaningful involvement of all people
regardless of race, color, national origin, or income with respect to the development, implemen-
tation, and enforcement of environmental laws, regulations, and policies. Basically, the Agency
wants a level playing field for all people to have a healthy environment.
EPA is working toward achieving environmental justice through various advisory committees,
outreach efforts, grants, programs, awards, and enforcement initiatives.
The National Environmental Justice Advisory Council (NEJAC) is a federal committee that
provides recommendations to EPA on environmental justice. The committee is made up of
approximately 26 members as well as one designated federal officer. In addition, the public is
invited to attend NEJAC meetings, submit comments for review, or access records.
EPA sponsors local, state, regional, and national grants and cooperative agreements to promote
environmental justice. These include programs such as the Environmental Justice Small
Grants Program, which provides financial assistance to organizations to build collaborative
partnerships, identify local environmental and/or public health issues, and to empower com-
munities through education, training, and outreach. Another program is the State
Environmental Justice Cooperative Agreements Program, which funds state entities that work
collaboratively with affected communities to understand, promote, and integrate approaches to
provide meaningful and measurable improvements to public and environmental health.
Plan EJ 2014 is EPA’s blueprint for incorporating environmental justice into Agency programs,
policies, and activities. Goals of the plan include:
• Protect health in communities over-burdened by pollution.
• Empower communities to take action to improve their health and environment.
• Establish partnerships with local, state, tribal, and federal organizations to achieve
healthy and sustainable communities.
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Part of the plan includes using legal tools to advance environmental justice. EPA’s Office of
General Counsel (OGC) identifies opportunities to use the Agency’s statutory authorities to
advance environmental justice. OGC uses the law as a tool to advance environmental justice by
providing legal assistance to EPA policy makers and providing legal support to environmental
justice workgroups.
Other major facets of the plan include incorporating environmental justice into Agency
rulemakings, permitting decisions, community-based action programs, and Agency adminis-
tration.
The National Environmental Policy Act, a foundation for protecting the environ-
ment
No introduction to the EPA — or discussion of national environmental policy — would be
complete without touching on the National Environmental Policy Act (NEPA). NEPA, which
became law in 1970, was one of the first national laws focusing on environmental protection,
and its job was to assure all branches of government gave consideration to the environment
prior to undertaking any major federal action that significantly affects the environment. The
Act created a national environmental policy and set goals for the protection, maintenance, and
enhancement of the environment along with providing a process for achieving those goals
within federal agencies.
The NEPA process involves three levels of analysis:
• Categorical Exclusion: At the first level, an undertaking may be categorically
excluded from a detailed environmental analysis if it meets certain criteria which a
federal agency has previously determined as having no significant environmental
impact. A number of agencies have developed lists of actions which are normally cat-
egorically excluded from environmental evaluation under their NEPA regulations.
• EA/FONSI: At the second level of analysis, a federal agency prepares a written
environmental assessment (EA) to determine whether or not a federal undertaking
would significantly affect the environment. If the answer is no, the agency issues a
finding of no significant impact (FONSI). The FONSI may address measures which
an agency will take to mitigate potentially significant impacts.
• EIS: If the environmental assessment determines that the environmental conse-
quences of a proposed federal undertaking may be significant, an EIS is prepared.
An EIS is a more detailed evaluation of the proposed action and alternatives. The
public, other federal agencies, and outside parties may provide input into the prepa-
ration of an EIS and then comment on the draft EIS when it is completed.
EPA reviews and comments on all EISs prepared by other federal agencies, and maintains a
national filing system for all EISs at epa.gov/compliance/nepa/eisdata.html. The Office of Fed-
eral Activities (OFA) coordinates EPA’s review of the EISs, as well as ensures EPA’s own
compliance with NEPA. Federal agencies must also consider environmental justice in their
activities under NEPA.
A quick look at the regulatory process

Congress passes the overarching laws that govern the nation; but federal agencies create the
rules and regulations under those laws.
xii 3/12

Once an agency such as EPA determines that a regulation is necessary, it takes the following
steps:
1. Proposed rules. The Agency proposes a regulation, known as a Notice of Proposed

Rulemaking (NPRM). The proposal is published in the Federal Register allowing
time for the public to comment on it. The proposed rule and any supporting docu-
ments are also posted on EPA’s official docket on Regulations.gov.
2. Final rules. Once EPA has considered all the comments received on the proposed
regulation, the Agency revises the regulation (if necessary) and issues a final rule.
This rule is also published in the Federal Register and on Regulations.gov.
3. Code of Federal Regulations. Once a regulation has been published in the Fed-
eral Register as a final rule, it is added to the Code of Federal Regulations (CFR).
The CFR is the official record of all regulations created by the federal government.
It is divided into 50 volumes, called titles, which focus on a particular regulatory
area. Almost all of the environmental regulations are codified in Title 40. Title 40 is
revised every July 1.
You can stay current on regulatory development using EPA’s Retrospective Review Tracker (Reg
DaRRT), which provides monthly updates to priority rulemakings that are under development
as well as reviews of existing regulations. Reg DaRRT provides information on rulemakings
from the beginning, sometimes months ahead of when the proposed rule is published.
(yosemite.epa.gov/opei/RuleGate.nsf/content/index.html?opendocument)
EPA’s Actions Initiation List (AIL) includes every new rulemaking that EPA is initiating, even
if it isn’t a priority rulemaking. (epa.gov/lawsregs/regulations/ail.html)
Also, the Regulatory Agenda is published twice a year listing all of EPA’s rulemakings.
(reginfo.gov/public/do/eAgendaMain)
Many rulemakings undergo a regulatory process called a regulatory review. Under Executive
Order 12866, the Office of Information and Regulatory Policy (OIRA) (part of the White House
Office of Management and Budget (OMB) ) reviews certain rules at various stages of develop-
ment. If OIRA undertakes a review, it is limited by the Executive Order to 90 days. There is no
minimum period for review, and the review period may be extended by an agency director. Also,
the OMB Director may extend the review period on a one-time basis for no more than 30 days.
Occasionally, OIRA will “return” a rule to the agency, meaning that further agency effort is
needed before the agency can publish the rule. (www.whitehouse.gov/omb/inforeg)
EPA and businesses

Understanding EPA’s priorities, goals, and organization is crucial for running your business. If
your business impacts the environment in any way — if you use water resources, discharge
stormwater off your site, use a commercial or industrial incinerator or boiler, generate used oil
or hazardous waste, or even use mercury-containing fluorescent light bulbs — you will be
affected by environmental law and the EPA.
The Agency does provide help for businesses grappling with complex environmental regula-
tions.
3/12 xiii

Small businesses can turn to the EPA Small Business Gateway at epa.gov/epahome/
business.htm for access to the small business ombudsman and other small business guidance.
Also, the Small Business Administration offers programs to assist small businesses in comply-
ing with federal regulations and advocates on their behalf.
Technical Assistance Programs (TAPs) offer businesses the latest environmental management
assistance and help in identifying and implementing measures to reduce or eliminate pollution
at its source. TAPs can walk you through voluntary onsite audits and assist you in planning and
training. The program works through local and regional providers. Find TAPs at epa.gov/oppt/
p2home/pubs/assist/index.htm.
EPA’s Compliance Assistance webpage at epa.gov/compliance/assistance/index.html is a good
starting point if you are looking for one-to-one counseling, online resource centers, fact sheets,
guides, and training materials. The Agency points out that compliance assistance is at its most
effective when it combines monitoring (inspections), compliance incentives and auditing (self-
disclosure policies), and enforcement.
The regulated business community must comply with all applicable federal and state laws.
Large industrial sectors will have to meet requirements for multiple regulations, while small
businesses may only have to comply with one or two. Knowing which laws apply to your
business can save you in time, aggravation, and money.
This book can help you understand which regulations apply to your operations, but you’ll also
want to cultivate a relationship with state and local regulators, as local and state rules are often
stricter than the federal. And be sure to check out EPA’s Industry and Government Sectors page
at epa.gov/compliance/assistance/sectors/index.html, which can give you a heads-up on regula-
tions that affect your specific industry.
xiv 3/12

CLEAN AIR
CONTENTS
Clean air — Meeting EPA’s requirements ................................................................ 1

The Clean Air Act of 1970 .............................................................................. 1
CAA Titles 1-7............................................................................................. 3
Title I: Air pollution prevention and control.............................................................. 4
National ambient air quality standards (NAAQS) ................................................ 4
Criteria pollutants - NAAQS Implementation ..................................................... 6
State implementation plans (SIPs) ................................................................... 7
National emissions standards for hazardous air pollutants (MACT Standards) ........... 9
Mandatory reporting of greenhouse gases......................................................... 12
Additional source categories.......................................................................... 15
Title II: Emissions standards for moving sources ..................................................... 17
Clean-fuel fleet program............................................................................... 17
GHG emission standards.............................................................................. 18
Emission standards........................................................................................... 18
Labeling requirements................................................................................. 19
Renewable fuel standard (RFS) program and clean fuels............................................ 20
Diesel particulate filters..................................................................................... 22
Exhaust gas recirculation ................................................................................... 23
Selective catalytic reduction ................................................................................ 23
CARB ............................................................................................................ 24
California’s clean vehicle program .................................................................. 24
Drayage Trucks emissions ............................................................................ 24
Heavy-duty diesel vehicle inspection program (HDVIP) ....................................... 25
Idling Reduction Program............................................................................. 25
TRUs....................................................................................................... 25
Diesel-fueled auxiliary power systems ............................................................. 27
Fuel-fired cab heaters.................................................................................. 27
“Truck and Bus” rule................................................................................... 28
EPA’s SmartWay Partnership Program ............................................................ 29
On-board diagnostics ................................................................................... 31
Idle reduction laws ........................................................................................... 31
Title III: Air toxics ............................................................................................ 33
Title IV: Acid deposition control ........................................................................... 34
Title V: Permits................................................................................................ 35
Which sources are subject to Title V permitting requirements?.............................. 36
Your responsibilities as a business owner ......................................................... 40
Permits for GHG emissions........................................................................... 40
GHG Tailoring Rule .................................................................................... 40
9/14 Clean air TOC–1

Title VI: Stratospheric ozone and global climate protection......................................... 42

What is the Montreal Protocol?...................................................................... 42
Title VII: Provisions relating to enforcement ........................................................... 43
Clean Air Act regulatory actions .......................................................................... 43
Transport rules .......................................................................................... 43
Help for small businesses ............................................................................. 46
Annual reporting deadlines under the Clean Air Act ........................................... 46
Indoor air quality ............................................................................................. 48
Causes of indoor air quality problems.............................................................. 48
Sources of indoor air pollution ....................................................................... 48
Create an indoor air quality program .............................................................. 52
2–Clean air TOC 9/14

Clean air — Meeting EPA’s requirements

In recent years, EPA has been extremely active in creating clean air rules, especially as they
apply to emissions from factories, power plants, heavy-duty equipment, and even
automobiles. Air rules can create compliance difficulties for businesses because they apply to
so many different industries, emissions standards and limits change so often, and they can
be very technical. Many larger facilities are able to hire full-time environmental profession-
als to help them with monitoring their emissions and keeping up with the changing
regulations. But other companies must navigate through the rules on their own. This section
is designed to help you understand the air rules that apply to your facility and what you
need to do to comply with them.
The Clean Air Act of 1970

All of EPA’s authority to create rulemakings and enforce air regulations comes from the
Clean Air Act (CAA) of 1970. According to the Agency, the Act will prevent over 230,000
early deaths by 2020. The CAA is the comprehensive federal law that regulates air emis-
sions from both stationary and mobile sources establishing clean air standards and
requirements to protect public health and welfare.
Examples of stationary sources include manufacturers, processors, refiners, power plants,
chemical facilities, and steel mills. Mobile sources include cars, trucks, buses, nonroad
equipment, and planes.
In 1990, Congress revised and expanded the CAA, providing EPA even broader authority to
implement and enforce regulations reducing air pollutant emissions. The passage of the
1990 amendments marked an overall change in the federal approach to air pollution. The
new legislation placed renewed emphasis on controlling emissions of hazardous air pollut-
ants and introduced efforts aimed at controlling acid rain and ozone depletion in the
3/12 Clean air–1

atmosphere. Five major goals for protecting and promoting human health and public welfare
are identified in the CAA as amended:
1. Mitigating potentially harmful human and ecosystem exposure to six criteria
pollutants;
2. Limiting the sources of and risks from exposure to hazardous air pollutants, which
are also called air toxics;
3. Protecting and improving visibility impairment in wilderness areas and national
parks;
4. Reducing the emissions of chemicals that cause acid rain, specifically SO2 and NOx;
and
5. Curbing the use of chemicals that have the potential to deplete the stratospheric
ozone layer.
EPA’s regulations for air quality are found at 40 CFR Parts 50-99. States and tribal nations
may also develop their own regulations for meeting the requirements set in the Clean Air
Act.
Two of the main regulatory air categories that may affect your business are the NAAQS and
HAPs.
The CAA sets National Ambient Air Quality Standards (NAAQS) in each state for six air
pollutants. States must achieve these standards by developing state implementation plans
(SIPs), which apply to applicable industrial sources and mobile sources in each state. EPA
then has the authority to approve or disapprove a state’s SIP. If a state does not meet EPA’s
standards, the Agency can impose sanctions and even take over enforcing the CAA in that
state.
Section 112 of the CAA addresses emissions of hazardous air pollutants, or HAPs. The 1990
Amendments revised Section 112 to first require EPA to set technology-based standards for
major sources and certain area sources of HAPs.
A major source is a stationary source or group of stationary sources that emit or have
the potential to emit 10 tons per year or more of a HAP or 25 tons per year or more of a
combination of HAPs.
An area source is defined as any stationary source that is not a major source.
Additionally, according to Section 112, EPA must establish emission standards for major
sources and require the maximum degree of reduction in emissions of HAPs. These emis-
sions standards are known as “maximum achievable control technology” or MACT
standards. The law calls for EPA to review the technology-based MACT standards for each
source category every eight years to determine whether any residual risk exists for the
source category, and if necessary, revise the standards. Basically, the CAA requires major
stationary sources to install pollution control equipment and to maintain that equipment in
good working order.
Major stationary sources must obtain clean air operating permits.
Mobile sources — automobiles and nonroad vehicles — also fall under the regulations of the
CAA. The CAA mandates both the composition of fuels and emission-control components on
2–Clean air 3/12

motor vehicles and nonroad engines. Fuel standards for gasoline and diesel must be met by
refiners and importers of fuel, and other businesses engaged in fuel distribution.
Regulation of vehicles includes vehicle emission limits for hydrocarbons (HC), carbon monox-
ide (CO), and Nitrogen Oxides (NOx), and particulates in the case of diesel vehicles. These
limits, which must be met by the vehicle manufacturers, apply to on-road vehicles, off-road
vehicles, and non-road sources (e.g., marine engines, locomotives, and lawn & garden
equipment). Under the 1990 CAA amendments, vehicle standards are being made more
stringent, in stages.
CAA Titles 1-7

The Clean Air Act is divided into seven distinct titles, each addressing a different air pollu-
tion control area. We’ll look at each in turn.
Title I - Air pollution prevention and control
Part A — Air Quality and Emission Limitations (CAA § 101-131; USC § 7401-7431 )
Part B — Ozone Protection (replaced by Title VI)
Part C — Prevention of Significant Deterioration of Air Quality (CAA § 160-169b; USC §
7470-7492)
Part D — Plan Requirements for Nonattainment Areas (CAA § 171-193; USC § 7501-7515)
Title II - Emission standards for moving sources
Part A — Motor Vehicle Emission and Fuel Standards (CAA § 201-219; USC § 7521-7554)
Part B — Aircraft Emission Standards (CAA § 231-234; USC § 7571-7574)
Part C — Clean Fuel Vehicles (CAA § 241-250; USC § 7581-7590)
Title III - General (CAA § 301-328; USC § 7601-7627)
Title IV - Acid deposition control (CAA § 401-416; USC § 7651-7651o)
Title V - Permits (CAA § 501-507; USC § 7661-7661f )
Title VI - Stratospheric ozone protection (CAA § 601-618; USC § 7671-7671q )
Title VII - Provisions relating to enforcement
3/12 Clean air–3

Title I: Air pollution prevention and control

When Congress enacted Title I, it declared, “A primary goal of this chapter is to encourage
or otherwise promote reasonable federal, state, and local governmental actions, consistent
with the provisions of this chapter, for pollution prevention.”
National ambient air quality standards (NAAQS)

This section establishes national ambient air quality standards (NAAQS) to limit levels of
“criteria pollutants,” including carbon monoxide, lead, nitrogen dioxide, particulate matter,
ozone, and sulfur dioxide. Ambient air is the air the general public breathes (not the air in a
smokestack or in a warehouse). Under the CAA, EPA is required to revise the NAAQS for
each of the criteria pollutants every five years.
The country is divided into different geographic areas, known as “attainment areas.” (An
area that does not meet its NAAQS is called a non-attainment area.) EPA maintains a
resource called the Green Book that answers questions on the status on nonattainment
areas. Find it at epa.gov/oar/oaqps/greenbk/.
Section 110 of the CAA requires each state to develop a state implementation plan (SIP) to
identify sources of pollution and determine which reductions are required to meet federal air
quality standards.
What does it cost a state or area to be out of attainment?

Being out of attainment (nonattainment) can cost an area in lost federal funding for high-
ways and other transportation projects. Facilities in nonattainment areas will be subject to
more restrictive permitting, and the area will be subject to mandated federal pollution con-
trol measures. In addition, the federal government can impose special requirements for
vehicles, such as emissions testing, that can affect ordinary citizens. Certain fuel blends may
also be required for the area.
Once an area is found to be in non-attainment, the state, county, or area has three years to
address the pollution and create an implementation plan describing how it will meet and
maintain the standards. The plan must address reducing the criteria pollutants through pol-
lution controls for stationary sources and vehicle emissions testing requirements.
Primary and secondary NAAQS

EPA sets requirements for both primary and secondary NAAQS at a national level. Primary
NAAQS protect everyone including children, people with asthma, and the elderly from
health risk. Secondary NAAQS cover damage to crops and vegetation, buildings and prop-
erty, and ecosystems. The standards correspond to a specific averaging time, and some
pollutants have standards for more than one averaging time.
The current primary and secondary NAAQS are listed in the table below. The units of mea-
sure are parts per million (ppm) by volume, parts per billion (ppb) by volume, and
micrograms per cubic meter of air (μg/m3).
4–Clean air 3/12

Primary and Secondary NAAQS as listed at 40 CFR Part 50 (August 2013)
Primary or sec-
Criteria pollutant with final rule cite Averaging time Level Form
ondary
Carbon monoxide 76 FR 54294, 8/31/ Primary 8-hour 9 ppm Not to be
2011 1-hour 35 ppm exceeded more
than once per
year.
Lead 73 FR 66964, 11/12/2008 Both Rolling 3 month 0.15 µg/m3 (1) Not to be
average exceeded.
Nitrogen dioxide 75 FR 6474, 2/09/2010; Primary 1-hour 100 ppb 98th percentile,
61 FR 52852, 10/08/1996 averaged over 3
years
Both Annual 53 ppb (2) Annual mean
(3)
Ozone 73 FR 16436, 03/27/2008 Both 8-hour 0.075 ppm Annual fourth-
highest daily
maximum 8-hour
concentration,
averaged over 3
years.
Particle pollu- PM 2.5 Primary Annual 12 µg/m3 Annual mean,
tion Dec. 14, averaged over 3
2012 years.
Secondary Annual 15 µg/m3 Annual mean,
averaged over 3
years.
Both 24-hour 35 µg/m3 98th percentile,
averaged over 3
years.
PM 10 Both 24-hour 150 µg/m3 Not to be
exceeded more
than once per
year averaged
over 3 years.
(4)
Sulfur dioxide 75 FR 35520, 6/22/2010; Primary 1-hour 75 ppb 99th percentile
38 FR 25678, 9/14/1973 of 1-hour daily
maximum con-
centrations,
averaged over 3
years.
Secondary 3-hour 0.5 ppm Not to be
exceeded more
than once per
year.
(1)
Final rule signed October 15, 2008. The 1978 lead standard (1.5 µg/m3 as a quarterly average) remains in effect until one year after
an area is designated for the 2008 standard, except that in areas designated nonattainment for 1978. The 1978 standard remains in effect
until implementation plans to attain or maintain the 2008 standard are approved.
(2)
The official level of the annual NO2 standard is 0.053 ppm, equal to 53 ppb, which is shown here for the purpose of clearer comparison
to the 1-hour standard.
(3)
Final rule signed March 12, 2008. The 1997 ozone standard (0.08 ppm, annual fourth-highest daily maximum 8-hour concentration,
averaged over 3 years) and related implementation rules remain in place. In 1997, EPA revoked the 1-hour ozone standard (0.12 ppm,
not to be exceeded more than once per year) in all areas, although some areas have continued obligations under that standard
(“anti-backsliding”). The 1-hour ozone standard is attained when the expected number of days per calendar year with maximum hourly
average concentrations above 0.12 ppm is less than or equal to 1.
(4)
Final rule signed June 2, 2010. The 1971 annual and 24-hour SO2 standards were revoked in that same rulemaking. However, these
standards remain in effect until one year after an area is designated for the 2010 standard, except in areas designated nonattainment for
the 1971 standards, where the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standard are
approved.
9/13 Clean air–5

Criteria pollutants - NAAQS Implementation

Carbon monoxide: Carbon monoxide (CO) is a colorless, odorless, and (at higher levels)
poisonous gas that is formed when carbon in fuels is partially burned. It is found in motor
vehicle exhaust, which EPA says contributes approximately 60 percent of all CO emissions
nationwide. In fact, in cities, as much as 95 percent of all CO emissions may come from
automobiles. Other sources of CO emissions can include industrial processes such as carbon
black manufacturing, other types of fuel combustion, and natural sources such as wildfires.
Exposure to higher CO levels can cause impairment in visual perception, manual dexterity,
learning ability, and performance of complex tasks.
Lead: Lead (Pb) is metal that is found both in natural sources and in manufactured
products. At one time, major sources of lead emissions were from automobile emissions and
industrial sources. However, emissions from on-road vehicles decreased almost entirely after
the requirement to use unleaded gasoline. (Leaded gasoline was banned in 1995.) Today,
major sources of lead emissions are ore and metals processing and piston-engine aircraft
operating on leaded airplane fuel.
Not surprisingly, the highest levels of lead in the air are usually found near lead smelters.
Other sources are waste incinerators, utilities, and lead-acid battery manufacturers. EPA
says combustion and smelting processes operate at high temperatures and emit submicron
particulate matter lead. Material handling and mechanical operations emit larger particles
of lead.
Nitrogen dioxide: Nitrogen dioxide (NO2) is a brownish, highly reactive gas that is found
in urban settings. NO2 can irritate the lungs, lead to bronchitis, pneumonia, and other
respiratory infections. Nitrous oxides are one of the main precursors to ozone (O3) and acid
rain.
NO2 forms in the atmosphere through the oxidation of the primary air pollutant nitric oxide
(NOx). NOx forms when fuel is burned at high temperatures. The two major emissions
sources are the transportation sector and stationary fuel combustion sources such as electric
utilities and industrial boilers.
Ozone: Ozone (O3) is a gas that is found in two distinct forms: upper atmospheric and
ground level. O3 can be “good” or “bad” for human health and the environment, depending
upon its location in the atmosphere. Considered “bad” at ground level, O3 acts as a pollutant
and a significant health risk, especially for people with asthma. It can also damage crops,
trees, and other vegetation and is a major component of urban smog.
In the upper atmosphere, O3 acts as a natural shield, protecting the Earth from harmful
solar ultraviolet (UV) rays. EPA says that this stratospheric ozone layer has been damaged
or “depleted” by man-made chemicals such as chlorofluorocarbons (CFCs). This depletion
means more UV rays reach the ground, leading to more annual cases of skin cancer and
cataracts. EPA’s regulations addressing stratospheric ozone are found at 40 CFR Part 82.
Particulate matter: Particulate matter (PM) is a complex mixture of extremely small par-
ticles and liquid droplets. PM can be made up of a number of components, including acids
(such as nitrates and sulfates), organic chemicals, metals, and soil or dust particles.
6–Clean air 9/13

The size of the particle is directly linked to its potential for causing health problems. EPA
sets limits for particles that are 10 micrometers in diameter or smaller because those are
the particles that can pass through the throat and nose and enter the lungs. Once inhaled,
these particles can affect the heart and lungs, and cause serious health effects.
Regulated PM is grouped into two categories:

1. Inhalable coarse particles, such as those found near roadways and “dusty” industrial
processes. These are larger than 2.5 micrometers and smaller than 10 micrometers
in diameter; and
2. Fine particles,such as those found in smoke and haze, are 2.5 micrometers in diam-
eter and smaller. They can be directly emitted from sources such as forest fires, or
they can form when gases emitted from power plants, industries, and vehicles react
in the atmosphere.
Sulfur dioxide: Sulfur dioxide (SO2) is a primary contributor to acid deposition, or acid
rain, which causes acid levels to rise in lakes and streams and can damage trees, crops, his-
toric buildings and statues. Sulfur compounds in the air can contribute to visibility
impairments in many parts of the country.
SO2 in the atmosphere results largely from stationary sources such as steel mills, refineries,
pulp and paper mills, nonferrous smelters, and industrial processes using coal and oil
combustion.
High concentrations of SO2 may affect breathing and may aggravate existing respiratory
and cardiovascular disease, especially for people with asthma, bronchitis, or emphysema.
State implementation plans (SIPs)

The CAA requires EPA to examine the requirements of the federally enforceable state imple-
mentation plans (SIPs) in each state every three years, and to make its findings available to
the public. SIPs are a state’s plan for attaining and/or maintaining the primary and second-
ary NAAQS. They are developed through a public process, formally adopted by the state,
and submitted by a governor’s designee to EPA.
SIP requirements applicable to all areas are provided in section 110 of the Act. Section 110
and Part D describe the elements of an SIP and include emission inventories, a monitoring
network, an air quality analysis, modeling, attainment demonstrations, enforcement mecha-
nisms, and regulations which have been adopted by the state to attain or maintain NAAQS.
EPA’s regulatory requirements for preparing, adopting, and submitting SIPs and SIP revi-
sions are found at in 40 CFR Part 51, and EPA’s action on each state’s SIP is listed at 40
CFR Part 52.
The contents of a typical SIP fall into several categories:
1. State-adopted control measures which consists of either rules/regulations or source-
specific requirements (e.g., orders and consent decrees);
2. State-submitted comprehensive air quality plans, such as attainment plans, mainte-
nance plans, rate of progress plans, and transportation control plans demonstrating
how these state regulatory and source-specific controls, in conjunction with federal
programs, will bring and/or keep air quality in compliance with federal air quality
standards;
3/12 Clean air–7

3. State-submitted “non-regulatory” requirements, such as emission inventories, small

business compliance assistance programs, statutes demonstrating legal authority,
monitoring networks, etc.; and
4. Additional requirements promulgated by EPA (in the absence of a commensurate
state provision) to satisfy a mandatory Section 110 or part D requirement.
EPA will impose a federal implementation plan whenever it finds a state plan to be inad-
equate or if the state is not able to create its own plan.
In addition to addressing NAAQS, states in nonattainment areas must include a New

Source Review (NSR) permitting program (the Nonattainment New Source Review or NA
NSR).
States that are in attainment must submit Prevention of Significant Deterioration (PSD)
permitting programs. These programs require the permitting of new sources or sources that
are expanding operations to ensure that they either reduce emissions or will not cause an
area to lose its attainment status.
EPA also has the authority to require states to include air quality goals other than the
NAAQS in their SIPs; regional haze programs are one example.
Most SIPs are available for viewing on state websites. They can also be accesses by search-
ing on the state name in the Federal Register archives.
New source performance standards (NSPS)

Title I of the CAA sets New Source Performance Standards (NSPS). NSPS are national
emissions standards for new stationary sources in certain industrial categories, and are
based on the pollution control technology available to that industry, but allowing some flex-
ibility in finding cost-effective emissions reductions strategies. EPA says it will progressively
tighten the NSPS over time to achieve a “steady rate” of air quality improvement “without
unreasonable economic disruption.” NSPS are based on the best demonstrated technology
(BDT), which in turn refers to the best system of continuous emissions reduction that has
been demonstrated to work in a given situation. BDT also considers costs. NSPS can take
the form of numerical emissions limits, design standards, equipment standards, or work
practice standards. EPA enforces NSPS, but the Agency also assigns responsibility to the
states, which can impose their own NSPS.
Prevention of Significant Deterioration of air quality

States must ensure that new sources will not adversely affect their emissions under their
SIPs; therefore, all new major sources will be subject to air pollution permitting and a
review process known as a New Source Review before beginning construction. Permits for
sources in attainment areas are referred to as prevention of significant air quality deteriora-
tion (PSD) permits while permits for sources located in nonattainment areas are referred to
as NAA permits. The entire program, including both PSD and NAA permit reviews, is
referred to as the NSR program.
No source or modification subject to PSD review may be constructed without a permit. PSD
permits require installing pollution controls using the best available control technology
(BACT). BACT is defined as an emission limit based on the maximum degree of reduction of
each pollutant subjected to regulation under the Clean Air Act. BACT is done on a case-by-
case basis, and considers energy, environmental, and economic impacts.
8–Clean air 3/12

Permits in nonattainment areas (NAAs) must meet the lowest achievable emission rate
(LAER). In all cases, the BACT and LAER must be at least as strict as any existing NSPS
for the source. The important difference between the New Source Review permits and the
New Source Performance Standards program is that NSR is source specific, whereas the
NSPS program applies to all sources nationwide. This gives states the authority to require
more stringent controls to meet the ambient air quality standards in specific geographic
areas.
National emissions standards for hazardous air pollutants (MACT Standards)

Under Title 1, EPA sets national emissions standards for hazardous air pollutants
(NESHAPs). Examples of toxic air pollutants include benzene, which is found in gasoline;
perchlorethlyene, which is emitted from some dry cleaning facilities; and methylene chloride,
which is used as a solvent and paint stripper by a number of industries. Examples of other
listed air toxics include dioxin, asbestos, toluene, and metals such as cadmium, mercury,
chromium, and lead compounds. The majority of the HAPs are volatile organic compounds
(VOCs).
The NESHAPS are listed in 40 CFR Part 61 and Part 63. THE NESHAPS at Part 61 only
regulate the following seven hazardous air pollutants:
• Arsenic
• Asbestos
• Benzene
• Beryllium
• Mercury
• Radon/Radionuclides
• Vinyl Chlorides
The 1990 CAA Amendments set new NESHAPS for 188 hazardous air pollutants. In addi-
tion, the Act required EPA to develop standards based on maximum achievable control
technology, or “MACT.” Thus, the NESHAPS are commonly called the MACT standards.
EPA is allowed to take the cost of the technologies and other factors into consideration when
setting the MACT standards to reduce HAP emissions.
MACT floors
EPA sets different MACT floors for different source categories. The Agency looks at the emis-
sion levels from the best-performing segments of an industry using clean processes, control
devices, work practices, and more. This level is set as the baseline, or floor, for the MACT
standard. The law requires the MACT standards to achieve a level of emissions control that
is at least equivalent to the MACT floor.
MACT standards for new sources must equal the current level of emissions control achieved
by the best-controlled similar sources.
For existing sources, MACT represents the average emission limit achieved by the best per-
forming 12 percent of the existing sources for which EPA has information. If there are fewer
than 30 existing sources, EPA says the MACT floor must equal the average emissions from
the best-performing five sources in the industry.
3/13 Clean air–9

MACT standards apply to both major sources and area sources. A major source is defined as
a source that emits 10 tons per year or more of any of the listed HAPs, or 25 tons per year
of a mixture of HAPS.
An area source is defined as facilities that emit less than 10 tons per year of a single HAP,
or less than 25 tons per year of a mixture of HAPS.
The CAA set a goal of developing MACT standards for all major source categories of HAPS.
EPA is currently behind schedule in achieving that goal. MACT standards have been final-
ized for the following source categories:
Keep in mind that if your facility is subject to a MACT standard, you will also be required to
apply for air permits.
NESHAPS listings
Find a current listing of NESHAPS for affected major source categories along with Agency
contact information at epa.gov/ttn/atw/mactfnlalph.html.
If you are an area source, EPA has compiled a listing of NESHAPS standards and Title V
permit requirements, along with applicable compliance dates and contacts at epa.gov/ttn/
atw/area/compilation.html.
Boilers and incinerators

On December 20, 2012, EPA issued final changes to Clean Air Act standards for major and
area source boilers and commercial/industrial solid waste incinerators. The standards will
cover almost 200,000 boilers and incinerators at both major and area sources that emit pol-
lutants such as mercury, cadmium, and particle pollution.
Boilers burn natural gas, coal, wood, oil, and other fuels such as biomass to produce steam,
which, in turn, is used to produce electricity or provide heat. Major source boilers are found
at refineries, chemical plants, and other large industrial facilities. Area source boilers are
located at universities, hospitals, hotels, and commercial buildings.
A commercial and industrial solid waste incinerator (CISWI) unit is a device that is used to
burn solid waste at a commercial or industrial facility. This includes units designed to dis-
card solid waste; energy recovery units designed to recover heat that combust solid waste;
and waste-burning kilns that combust solid waste in the manufacturing of a product.
According to EPA, there are only 106 CISWI units covered by these standards.
Compliance dates
Major source boilers will have until 2016 to comply with the standard and can be granted a
fourth year if needed to install controls.
Existing area source boilers will have until March 21, 2014, to comply with the standards,
and may also apply for an additional year, if needed.
Existing CISWI units must comply no later than 2018.
According to EPA, 86 percent of all boilers in the U.S. already burn clean natural gas that
emits little toxic air pollution. Boilers that burn other materials will need to follow work
practice standards such as annual tune-ups to minimize toxic releases. For the highest emit-
ting 0.4 percent of all boilers in the U.S., including those located at refineries, chemical
plants, and other industrial facilities, more focused numeric emission limits will apply.
10–Clean air 3/13

Subcategories
Boilers also fall into subcategories. Each subcategory has its own list of requirements to
reach achievable emissions limits for various pollutants.
Major source boilers
The new standards will:
• Create new subcategories for light and heavy industrial liquids to reflect design dif-
ferences in the boilers that burn these fuels.
• Create a new subcategory for coal fluidized bed units with a fluidized bed heat
exchanger designed to burn coal.
• Set new emission limits for particulate matter (PM) for each biomass subcategory to
better reflect emissions during real-world operating conditions.
• Set new emission limits for carbon monoxide (CO) based on new data that show CO
emissions from boilers vary greatly. EPA is setting new limits to more adequately
capture that variability.
• Allow an alternative total selective metals emission limit to regulate metallic air
toxics instead of using PM as a surrogate, allowing more flexibility and decreasing
compliance costs for units that emit low levels of HAP metals.
• Replace numeric dioxin emission limits with work practice standards to reflect a
more robust analysis that shows dioxin emissions are below levels that can be accu-
rately measured.
• Increase flexibility in compliance monitoring by adding alternative monitoring
approaches for demonstrating continuous compliance with the PM limit.
• Revise emission limits for units located outside the continental U.S. to reflect new
data and to better reflect the unique operating conditions associated with operating
these units.
• Allow units burning clean gases to qualify for work practice standards instead of
numeric emission limits.
Area source boilers
Due to how little these sources emit, EPA is continuing to require work practice/
management practice standards, which include tune-ups for over 99 percent of area source
boilers covered by the final standards. Less than one percent of area source boilers will need
to meet numerical emission limits. The new standards apply to:
• Seasonal use and limited use subcategories: EPA is establishing subcategories for
seasonal use boilers and limited use boilers that will reduce the compliance burden
for these less frequently used boilers.
• Existing dual-fuel fired boilers: EPA is revising provisions for existing dual-fuel fired
units that fuel switch from gas to coal, biomass or oil such that they would still be
considered existing sources, promoting flexibility for these existing sources that were
designed to accommodate an alternate fuel.
• Initial tune-ups: To increase flexibility for existing sources, EPA is requiring initial
compliance tune-ups within three years (by March 21, 2014) instead of one year, to
give facilities ample time to comply with the standards.
3/13 Clean air–11

• Initial notification: EPA is revising the deadline for initial notification to no later
than January 20, 2014, to provide additional time for the many existing boilers that
are just becoming aware, or are not yet aware, that they are subject to requirements
under the rule.
• Periodic tune-ups: EPA is requiring tune-ups every five years instead of every two
years for certain area source boilers: seasonal use units, limited use units, small
oilfired units and units with oxygen trim systems that would otherwise be required
to perform tune-ups every two years. These units do not need to conduct tune-ups as
frequently as other boilers.
• New boilers burning low sulfur oil: EPA is adding a provision specifying that com-
bustion of low sulfur oil by new oil-fired units is considered an alternative method.
• Boilers subject to mercury and PM emission limits: EPA is encouraging units to per-
form well below the standards by adjusting the continuous compliance
requirements. Under certain circumstances, after units demonstrate initial compli-
ance, further fuel sampling and further PM performance testing is not required.
• Carbon monoxide monitoring requirements: EPA is increasing compliance flexibility
by providing the option of continuous emissions monitoring to demonstrate continu-
ous compliance with the CO emission limit.
Learn more about how the boiler and CISWI rules may affect your facility at epa.gov/
airquality/combustion/index.html.
Mandatory reporting of greenhouse gases

Without the Endangerment Finding of 2009, EPA could not have developed emissions stan-
dards and reporting rules for greenhouse gases. The endangerment finding said that GHG
emissions are a danger to public health and welfare; therefore, EPA must regulate them.
The endangerment finding applies to six “key well-mixed” gases in the atmosphere: carbon
dioxide (CO2), methane (CH4), nitrous oxide (N2O), hydrofluorocarbons (HFC),
perfluorocarbons (PFC), and sulfur hexafluoride (SF6). In addition, the endangerment find-
ing says that the combined emissions from motor vehicles causes and contributes to climate
change.
12–Clean air 3/13

The Mandatory Reporting of Greenhouse Gases Rule at 40 CFR Part 98 requires reporting
of greenhouse gas (GHG) emissions from large sources and suppliers in the United States,
and is intended to collect accurate and timely emissions data to inform future policy
decisions.
Under the rule, suppliers of fossil fuels or industrial greenhouse gases, manufacturers of
vehicles and engines, and facilities that emit 25,000 metric tons or more per year of GHG
emissions are required to submit annual reports to EPA.
Reporting is at the facility level, except that certain suppliers of fossil fuels and industrial
greenhouse gases and vehicle and engine manufacturers report at the corporate level. Facili-
ties and suppliers began collecting data on January 1, 2010. The first emissions reports were
due on March 31, 2011, for emissions during 2010. All subsequent reports from these facili-
ties will be due annually by March 31 for the previous reporting year.
Note: EPA issued a one-time deadline extension (March 31, 2012, to September 28, 2012) for
12 source categories that were required to begin collecting GHG data in 2011. These sources
include industrial waste landfills, petroleum and natural gas systems, industrial wastewater
treatment facilities, underground coal mines, and facilities that use or manufacture electric
transmissions and distribution equipment.
Manufacturers of vehicles and engines outside of the light-duty sector will begin reporting
CO2 for model year 2011 and other GHGs in subsequent model years as part of existing
EPA certification programs.
On January 11, 2012, EPA released the first GHG data reported from large U.S. facilities
and suppliers for reporting year (RY) 2010. The data includes public information from facili-
ties in nine industry groups that directly emit large quantities of GHGs, as well as suppliers
of certain fossil fuels.
To report GHG data, facilities must use EPA’s electronic Greenhouse Gas Reporting Tool
(e-GGRT). Before using e-GGRT, reporters must register as uses at ghgreporting.epa.gov.
Who must report

Source categories are grouped into four separate reporting categories:
1. All-in source categories. These source categories are automatically required to
report.
2. Threshold-based source categories. These source categories emit 25,000 metric tons
of CO2e/year.
3. Stationary combustion sources. These are sources with only stationary combustion
emissions.
4. Suppliers. These sources produce, import, or export fossil fuels and industrial
GHGs.
3/13 Clean air–12A

Reserved
12B–Clean air 3/13

Table 1. All-in Source Categories

Electricity Generation if report CO2 year-round through Part 75
Adipic Acid Production
Aluminum Production
Ammonia Manufacturing
Cement Production
HCFC-22 Production
HFC-23 Destruction Processes that are not collocated with a HCFC-22 production facility and that destroy more than
2.14 metric tons of HFC-23 per year
Lime Manufacturing
Nitric Acid Production
Petrochemical Production
Petroleum Refineries
Phosphoric Acid Production
Silicon Carbide Production
Soda Ash Production
Titanium Dioxide Production
Municipal Solid Waste Landfills that generate CH4 equivalent to 25,000 metric tons CO2e or more per year
Manure Management Systems with combined CH4 and N2O emissions in amounts equivalent to 25,000 metric tons
CO2e or more per year.
Table 2. Threshold Source Categories: Facilities That Emit at Least 25,000 Metric Tons of CO2e Per
Year From All Sources, Combustion Units, and Miscellaneous Use of Carbonates
Ferroalloy Production
Glass Production
Hydrogen Production
Iron and Steel Production
Lead Production
Pulp and Paper Manufacturing
Zinc Production
Table 3. Stationary Combustion Units: These Sources Must Report if Their Aggregate Maximum
Rated Heat Input Capacity Is at Least 30 MmBtu Per Hour AND They Emit at Least 25,000 Metric
Tons of CO2e Per Year.
Boilers
Stationary Internal Combustion Engines
Process Heaters
Combustion Turbines
Incinerators
Other Stationary Fuel Combustion Equipment
Facilities and suppliers can stop having to report annually by reducing their GHG emis-
sions:
• After 5 consecutive years of emissions below 25,000 metric tons CO2e/year.
• After 3 consecutive years of emissions below 15,000 metric tons CO2e/year.
• If the GHG-emitting processes or operations are shut down.
3/12 Clean air–13

The rule affects 40 CFR Parts 86, 87, 89, 90, 94, 98, 1033, 1039, 1042, 1045, 1048, 1051,
1054, and 1065. More information on the Mandatory Reporting of Greenhouse Gases can be
found at: http://www.epa.gov/climatechange/emissions/ghgrulemaking.html.
EPA estimates there are about 10,000 facilities covered by the rule. These facilities include
stationary combustion facilities, landfills, natural gas suppliers, electricity generators, pulp
and paper manufacturers, and more.
GHG data
2012 was the first year EPA began analyzing GHG data. The GHG Reporting Program Data
and Data publication Tool at epa.gov/climatechange/emissions/ghgdata allow users to view
and sort 2010 GHG data from over 6,700 facilities by facility location, industrial sector, and
the type of GHG emitted. Some highlights from the 2010 data show:
• Power plants were the largest stationary sources of direct emissions with 2,324 mil-
lion metric tons of carbon dioxide equivalent (mmtCO2e), followed by petroleum
refineries with emissions of 183 mmtCO2e.
• CO2 accounted for the largest share of direct GHG emissions at 95 percent, followed
by methane at four percent, and nitrous oxide and fluorinated gases accounting for
the remaining one percent.
• 100 facilities each reported emissions over seven mmtCO2e, including 96 power
plants, two iron and steel mills, and two refineries.
Vehicle manufacturers must report GHGs

Under the mandatory reporting rule, all vehicle and engine manufacturers (outside of the
light-duty sector) must report emissions rates of CO2, nitrous oxide (N2O), and methane
(CH4) from their products. The rules are incorporated into long-standing conventional crite-
ria pollutant testing and reporting requirements under Title II of the CAA. This means the
GHG reporting requirements are based on existing measurement methods and existing data
collection systems.
14–Clean air 3/12

Mobile Source Categories and Reportable GHGs

for new vehicles and
engines certified under or
Manufacturers of the must report the following subject to the Code of
following mobile source GHGs… in units of… Federal Regulations
categories… (CFR) Title 40, including
amendments to these
parts.
a
Highway heavy-duty CO 2 , N 2 O, CH 4 grams per mile 86
vehicles (chassis-certified)
a
Highway heavy-duty CO 2 , N 2 O, CH 4 grams per bhp-hour 86, 1065
engines
a
Highway motorcycles CO 2 , N 2 O, CH 4 grams per kilometer 86
a
Nonroad diesel engines CO 2 , N 2 O, CH 4 grams per kilowatt-hour 89, 1039, 1065
a,b b
Marine diesel engines CO 2 , N 2 O, CH 4 grams per kilowatt-hour 94, 1042, 1065
a
Locomotive engines CO 2 , N 2 O, CH 4 grams per bhp-hour 1033, 1065
a
Nonroad small spark CO 2 , N 2 O, CH 4 grams per kilowatt-hour 90, 1054, 1065
ignition engines
a
Nonroad large spark CO 2 , N 2 O, CH 4 grams per kilowatt-hour 1048, 1065
ignition engines
a
Marine spark ignition CO 2 , N 2 O, CH 4 grams per kilowatt-hour 1045, 1065
engines/personal watercraft
a
Snowmobiles CO 2 , N 2 O, CH 4 grams per kilowatt-hour 1051, 1065
a
Off-highway motorcycles CO 2 , N 2 O, CH 4 grams per kilometer 86, 1051
and ATVs
Aircraft engines c CO 2 , NO x grams per kilonewton 87
Find this table at epa.gov/climatechange/emissions/downloads/infosheets/mobilevehicle_enginemanuf.pdf.
a
N2O requirements only apply to new engines equipped with NOx after-treatment technology.
b
Except C3 marine engines.
c
Only applies to turbofan and turbojet engines in production in 2011 with a rated output greater than 26.7 kilonewtons.
GHG resources
Learn more about how the GHG reporting program applies to your specific situation using
the following:
• EPA’s Applicability Tool:
epa.gov/climatechange/emissions/GHG-calculator/index.html.
• Mandatory reporting of greenhouse gases:
epa.gov/climatechange/emissions/ghgrulemaking.html.
• Resources by subpart: epa.gov/climatechange/emissions/subpart.html.
• Data reporting system: epa.gov/climatechange/emissions/data-reporting-system.html.
• Confidential business information: epa.gov/climatechange/emissions/CBI.html.
Additional source categories

On June 28, 2010, the EPA issued a final rule that requires annual GHG emissions report-
ing from four source categories: magnesium production, underground coal mines, industrial
waste landfills and industrial wastewater treatment. This reporting rule amends the Green-
house Gas Reporting Program under 40 CFR part 98 to require reporting from additional
large emission sources. Facilities are required to report their emissions to EPA if they emit
3/12 Clean air–15

25,000 metric tons CO2e or more per year in combined emissions from source categories cov-
ered by 40 CFR part 98.
This action also announced EPA’s final decision not to include ethanol production and food
processing or suppliers of coal under the rule at this time.
EPA did not include ethanol production and food processing because the proposals for these
subparts did not include any unique requirements for monitoring or reporting of process
emissions. These types of facilities are still required to report emissions under other sub-
parts of the rule if they meet the reporting threshold of 25,000 metric tons of CO2
equivalent per year for all covered emissions sources such as subpart C (stationary combus-
tion), subpart HH (landfills), and subpart II (wastewater treatment).
For suppliers of coal, EPA did not include reporting requirements because the agency’s near-
term needs for information on GHG emissions from coal consumption can be met through
existing reporting requirements under Part 98, as well as other readily available and exist-
ing data sources.
EPA estimates that approximately 680 facilities, responsible for 1 percent of U.S. GHG emis-
sions, will report under this final rule. The estimated total cost of reporting by the private
sector under this rule would be $7.0 million for the first year of reporting and $5.5 million in
subsequent years.
Overview of reporting requirements

All underground coal mines that are subject to quarterly (or more frequent) sampling of ven-
tilation systems by the Mine Safety and Health Administration (MSHA) must report
emissions to EPA.
Underground coal mines, magnesium production facilities, industrial waste landfills and
industrial wastewater treatment facilities that meet the reporting threshold must begin
monitoring GHG emissions on January 1, 2011 and must submit the first annual report to
EPA by March 31, 2012.
EPA has added a provision that will allow facilities in magnesium production, underground
coal mines, industrial waste landfills and industrial wastewater treatment to submit a
request to use Best Available Monitoring Methods as specified in 40 CFR 98.3(d)(1) instead
of using the monitoring methods specified in each subpart for calendar year 2011
monitoring. The use of Best Available Monitoring Methods will not be approved beyond
December 31, 2011.
Data collection for the source categories included in this rule began on January 1, 2011, with
the first reports due to EPA on March 31, 2012.
16–Clean air 3/12

Title II: Emissions standards for moving sources

Title II of the Clean Air Act addresses air pollutants from mobile sources including aircraft,
ships, nonroad vehicles, nonroad engines, and fuels. While motor vehicles built today emit
fewer pollutants (60 to 80 percent less, depending on the pollutant) than those built in the
1960s, cars and trucks still account for almost half the emissions of volatile organic com-
pounds (VOCs) and nitrogen oxides (NOx), and up to 90 percent of the carbon monoxide
emissions in urban areas. The principal reason for this problem is the rapid growth in the
number of vehicles on the roadways, and the total miles driven. This growth has offset a
large portion of the emission reductions gained from motor vehicle controls.
Because of this growth in automobile emissions, combined with the serious air pollution
problems in many urban areas, Congress has made significant changes to the motor vehicle
provisions in the CAA.
The Clean Air Act of 1990 established tighter pollution standards for emissions from auto-
mobiles and trucks. These standards reduce tailpipe emissions of hydrocarbons, carbon
monoxide, and nitrogen oxides. Automobile manufacturers are also required to reduce
vehicle emissions resulting from the evaporation of gasoline during refueling.
Clean-fuel fleet program

Use of alternative fuels and development of cleaner engines was to be stimulated by the
Clean-Fuel Fleet Program (CFFP). In all of the most seriously polluted ozone and CO
nonattainment areas, centrally fueled fleets of 10 or more passenger cars and light-duty
trucks and heavy-duty fleets must contain a certain percentage of clean-fuel vehicles. A
clean fuel vehicle is one which meets Low Emission Vehicle (LEV) standards and operates
on reformulated gasoline, reformulated diesel, methanol, ethanol, natural gas, liquefied
petroleum gas, hydrogen, or electricity.
To learn more, go to EPA’s Clean Fuel Fleet Program Implementation Guidance at wwwp.
epa.gov/otaq/regs/fuels/cff/cffp-imp.pdf.
9/14 Clean air–17

GHG emission standards

EPA established the first national GHG emissions standards in April 2010 to control emis-
sions from new cars and light trucks, beginning with model year 2012. Under the standards,
cars, minivans, and other light trucks must meet combined emissions levels that EPA says
will average 250 grams/miles of CO2 by 2016. The standards will continue to be phased in
over the next few years.
The standards were developed jointly with the National Highway Traffic Safety Administra-
tion’s CAFÉ standards (fuel economy standards). At the same time, California agreed to
harmonize its strict GHG emissions standards, so the auto industry wouldn’t have several
sets of standards to meet.
EPA imposed tighter requirements on certification (an auto’s useful life is defined as 100,000
miles instead of the earlier 50,000 miles) on emissions allowed during refueling, low tem-
perature CO emissions, in-use performance over time, and warranties for the most expensive
emission control components (8 years/80,000 miles for the catalytic converter, electronic
emissions control unit, and onboard emissions diagnostic unit). Regulations were also
extended to include nonroad fuels and engines.
Standards for trucks and buses using diesel engines were also strengthened. Authority to
further strengthen these standards led to promulgation in January 2001 of new emission
standards requiring a further 90- to 95-percent reduction in emissions phased in over the
2007-2010 model years, and a reduction of 97 percent in the allowable amount of sulfur in
highway diesel fuel.
Emission standards
In addition to regulations on newly manufactured engines, EPA has devised a number of
emissions reduction strategies for diesel engines. The National Clean Diesel Campaign
(NCDC) partners EPA with manufacturers, fleet operators, air quality professionals, environ-
mental and community groups, and state and local governments to reduce diesel emissions.
EPA also offers many diesel emission reduction programs that apply to diesel vehicles, ves-
sels, locomotives, or other diesel equipment. Strategies to help older diesel engines operate
more cleanly include:
• Install diesel retrofit devices with verified technologies;
• Maintain, repair, rebuild, repower engines;
• Replace older vehicles and equipment;
• Improve operational strategies; and
• Use cleaner fuels including natural gas and propane.
Funding may be available through EPA to develop diesel emission reduction programs.
National programs that may help you with funding and technical expertise include:
• The National Clean Diesel Funding Assistance Program
(epa.gov/cleandiesel/prgnational.htm);
• The National Clean Diesel Emerging Technologies Program
(epa.gov/cleandiesel/prgemerg.htm);
18–Clean air 9/14

• The SmartWay Clean Diesel Finance Program (epa.gov/cleandiesel/prgfinance.htm);

and
• The State Clean Diesel Grant Program (epa.gov/cleandiesel/prgstate.htm).
EPA’s emission standards for engines are issued based on the date of engine manufacture.
As an example: If the date of manufacture was before 2004, the engine would have to meet
the standards that were in place at the time of manufacture (the 1998 standards).
The vehicle can be upgraded to a later standard, but it cannot be allowed to fall below the
standards that were in effect on the date of manufacture. It is a violation of federal law to
tamper with or remove any emissions components.
The vehicle is subject to inspection and testing to verify that it is complying with the emis-
sion standards that were in effect at the time of manufacture. If the vehicle has been altered
or cannot pass an emissions test due to alteration or lack of proper maintenance, the com-
pany can be fined.
Labeling requirements
Each vehicle and engine must have a label stating which emission standard the vehicle/
engine was built under. It is a federal requirement (and a state requirement in many states)
that these labels be present on the vehicle.
If the label is missing (most commonly a problem with engines) you will need to locate the
engine identification number and contact the engine manufacturer for a new label. It may be
a good idea to add this to your annual or quarterly inspections.
As well as the federal emission standards, there are state requirements. California is seen
as the leader in the emissions area, having tougher standards in some areas than EPA. Most
original equipment manufacturers (OEMs) have been designing their vehicles and engines to
meet the California Air Resource Board (ARB or CARB) standards, as well as the EPA
standards.
Diesel engines used in heavy-duty vehicles are divided into service classes by gross vehicle
weight rating (GVWR). Light heavy-duty diesel engines are engines used in vehicles with a
GVWR of 8,500 to 19,500 pounds (14,000 to 19,500 pounds in California; CARB holds
vehicles under 14,000 pounds to the same standards as light vehicles) — the exception is
personal passenger vehicles with a GVWR of up to 10,000 pounds (these are treated as pas-
senger vehicles in the standards). Medium heavy-duty diesel engines are used in vehicles
with a GVWR of 19,500 to 33,000 pounds. Heavy heavy-duty diesel engines (including urban
buses) are used in vehicles with a GVWR of 33,000 pounds or more.
In October 1997, EPA adopted new emission standards for model year 2004 and later heavy-
duty diesel truck and bus engines. The goal was to reduce NOx emissions from highway
heavy-duty engines to levels approximately 2.0 g/bhp/hr beginning in 2004.
9/14 Clean air–19

The new regulation also introduced a new method for calculating emissions. Rather than
considering hydrocarbons and nitrogen oxide separately, the standards created a combined
category of nonmethane hydrocarbons combined with nitrogen oxide (NMHC + NOx). Manu-
facturers were given the flexibility of meeting one of these two options:
2004 EPA Emission Standards for Heavy-Duty Diesel Engines, grams per brake horsepower hour (g/bhp/hr)
2004 option NMHC + NOx NMHC
1 2.4 n/a
2 2.5 0.5
All other emission standards remained the same (CO and PM) as the 1998 standards.
The next set of standards, passed in 2000, apply to the model years 2007 to 2010. These
standards will require a lowering of particulate matter and NOx emissions over this three
year span. Here are the standards:
2007 to 2010 EPA Emission Standards for Heavy-Duty Diesel Engines, grams per brake horsepower hour (g/bhp/hr)
Model year NMHC NOx PM
2007 2.5 NMHC + NOx 1.5 0.01
2010 0.14 0.20 0.01
To meet these standards, OEMs have had to create new technology and emission compo-
nents, because simply improving engine electronics and combustion technology cannot meet
the new standards. To sum it up, after-treatment of the exhaust became necessary as of the
2007 standards.
Also, meeting these standards (in particular the new PM standard) required the develop-
ment of “clean fuels.”
Renewable fuel standard (RFS) program and clean fuels

The RFS program sets a minimum for the amount of renewable fuel that must be in each
gallon of transportation fuel sold in the U.S. The RFS program was created under the
Energy Policy Act of 2005, and expanded under the Energy Independence and Security act of
2007 (EISA). The original RFS program required 7.5 billion gallons of renewable fuel to be
blended into gasoline by 2012.
In 2007, new “RFS2” EISA mandates included:
• Expanding the program to include diesel fuels, as well as gasoline;
• Increasing the volume of renewable fuel required to be blended into transportation
fuel to 36 billion gallons by 2022;
• Establishing new categories of renewable fuel, with separate volume requirements
for each one; and
• Requiring EPA to apply lifecycle GHG performance threshold standards to ensure
that each category or renewable fuels emits fewer GHGs than the petroleum fuel it
replaces.
20–Clean air 9/14

E15 waiver
E15 is a blend of gasoline and up to 15 volume percent ethanol. On October 13, 2010, EPA
granted a partial waiver for E15 use in model year 2007 and newer light-duty motor
vehicles (i.e. cars, light-duty trucks, and medium-duty passenger vehicles) subject to certain
conditions. In January 2011, EPA granted a second partial waiver for E15 use in model year
2001-2006 light-duty motor vehicles. Until EPA granted the waiver, the amount of ethanol in
motor vehicle gasoline was limited to 10 volume percent (E10). E10 was granted a waiver
under Clean Air Act section 211(f)(4) more than 30 years ago and is now ubiquitous in the
marketplace, making up over 90 percent of the U.S. gasoline market. The primary source of
ethanol is corn, but other grains or biomass sources may be used as feedstocks.
What Vehicles May Use E15?

• Flexible-fuel vehicles (FFVs)
• MY2001 and newer cars
• MY2001 and newer light-duty trucks
• MY2001 and newer medium-duty passenger vehicles (SUVs)
What Vehicles and Engines May Not Use E15?
• All motorcycles
• All vehicles with heavy-duty engines, such as school buses, transit buses, and deliv-
ery trucks
• All off-road vehicles, such as boats and snowmobiles
• All engines in off-road equipment, such as lawnmowers and chain saws
• All MY2000 and older cars, light-duty trucks, and medium-duty passenger vehicles
(SUVs)
A major concern with E15 is the possibility of “misfueling,” or the inability of an engine to
use E15. Therefore, the waiver calls for all E15 retailers to have a label that informs con-
sumers about which vehicles can use E15.
9/14 Clean air–21

EPA’s fuels and fuel additive page contains information on renewable and alternative fuels,
gasoline (including the Tier 2 Gasoline sulfur program), diesel, state fuel programs, emer-
gency fuel waivers, fuel and fuel additive registration, reporting requirements, and other
information on the RFS2 program. Find it here: epa.gov/otaq/fuels/index.htm.
Ultra-low sulfur diesel (ULSD)

EPA’s diesel fuel program regulations are found at 40 CFR 80 Subpart I.
Ultra-low sulfur diesel (ULSD) is a diesel fuel with substantially lowered sulfur contents.
Traditional diesel fuel contains roughly 500 parts per million (ppm) of sulfur. ULSD contains
less than 15 ppm of sulfur.
As of 2006, almost all of the petroleum-based diesel fuel available in North America is of a
ULSD type. The move to ULSD is necessary to allow the application of newer emissions con-
trol technologies that substantially lower emissions of particulate matter from diesel
engines. New emissions standards, dependent on the cleaner fuel, have been in effect in the
United States since model year 2007.
On June 1, 2006, refiners were required to produce 80 percent of their annual output as
ULSD, and pumps were required to label diesel fuel, diesel fuel additives, and kerosene
pumps with EPA-authorized language disclosing fuel type and sulfur content.
Diesel particulate filters

As regulations continue to reduce the amount of allowable particulate discharge by a heavy-
duty diesel engine, manufacturers have had to develop new technology. One of these new
technologies is the diesel particulate filter, or DPF.
The concept of a DPF is not new (they have been around since the 1980s). With the emis-
sions standard changes in 2004 and 2007, OEMs began adapting the technology to on-road
heavy diesels.
22–Clean air 9/14

One point about DPFs — they are not required. What is required is that the particulate dis-
charge be below the regulatory thresholds. To meet these requirements most OEMs have
decided to install DPFs.
The principle of a DPF is similar to most filters. The DPF cleans exhaust gas by forcing the
gas to flow through the filter which “scrubs out” the particulates. The DPF then oxidizes the
trapped particulates, converting them into less harmful components. There are a variety of
diesel particulate filter technologies on the market. Several DPFs use a filter material that
is also a catalyst that helps reduce other emissions (carbon monoxide and hydrocarbon
byproducts).
DPFs must be used with ultra-low sulfur diesel fuel (ULSD — 15 parts per million sulfur).
Use of regular diesel fuel in a DPF-equipped vehicles could eventually clog the filter. This
could lead to exhaust back-pressure increases and engine damage.
Exhaust gas recirculation

Exhaust gas recirculation (EGR) is a NOx emissions reduction technique used in many die-
sel engines to meet present or upcoming emission standards.
EGR works by recirculating a portion of an engine’s exhaust gas back to the engine cylin-
ders, intermixing the incoming air with recirculated exhaust gas dilutes the mix with inert
gas, lowering the flame temperature, and (in diesel engines) reducing the amount of excess
oxygen. The exhaust gas also increases the specific heat capacity of the mix, lowering the
peak combustion temperature.
Because NOx formation progresses much faster at high temperatures, EGR serves to limit
the generation of NOx. NOx is primarily formed when a mix of nitrogen and oxygen is sub-
jected to high temperatures. By keeping temperatures lower, the generation of NOx is
reduced.
Selective catalytic reduction

Selective catalytic reduction (SCR) is a means of converting NOx, an unwanted emission
from a diesel engine, with the aid of a catalyst into diatomic nitrogen (an inert gas) and
water.
To accomplish this, a gaseous reducing agent (urea in the case of on-road diesel engines) is
added to the exhaust flow in a materially- and geometrically- controlled environment. The
ensuing chemical reaction causes the conversion of NOx into nitrogen and water, which are
then discharged out of the SCR unit with the exhaust flow.
SCR systems do come with some problems, the primary one being the additional mainte-
nance requirements. If the unit is allowed to run out of urea, it will not function. Also, it is
another area of the exhaust system that will see additional heat.
All major engine manufacturers in the medium and heavy-duty engine market have gone to
SCR to meet the 2010 emission requirements. Most use a combination approach, combining
SCR with engine performance adjustments (electronic control adjustments, and air and fuel
flow adjustments) and/or EGR to achieve the required NOx levels.
9/14 Clean air–23

The reducing agent that the manufacturers have settled on for on-road diesel engines is
urea. As a result, trucks built with SCR-equipped engines need to be equipped with a “diesel
exhaust fluid,” or “DEF” (urea) tank. The size and serviceability of the tank needs to match
the carrier operation unless the carrier is willing to purchase DEF on the road at retail
prices. Example: An over-the-road truck will need a larger DEF tank than a truck involved
in local delivery that receives weekly maintenance. The other consideration is the additional
weight that a large DEF tank (when full) will add to the vehicle.
CARB
CARB (or simply ARB inside California) is the California Air Resources Board — an agency
that was created to move air-quality decisions out of the political process. CARB regulates
everything from power plant emissions to windshield washer fluid. Basically, anything enter-
ing the air in California is under CARB’s authority.
California’s clean vehicle program

In addition to setting more stringent standards for all vehicles, California used this author-
ity to establish a program requiring auto manufacturers to sell ZEVs (zero-emissions
vehicles) in the state beginning in 2003. This program has been substantially modified since
it was enacted, and now allows credit for hybrid and partial ZEV vehicles in addition to true
ZEVs.
CARB unanimously approved the Advanced Clean Cars program in January 2012. The pro-
gram combines the control of smog-causing pollutants and greenhouse gas emissions into a
single coordinated package of requirements for model years 2017 through 2025. The new
rules will clean up gasoline and diesel-powered cars, and deliver increasing numbers of zero-
emission technologies, such as full battery electric cars, newly emerging plug-in hybrid
electric vehicles and hydrogen fuel cell cars. The package will also ensure adequate fueling
infrastructure is available for the increasing numbers of hydrogen fuel cell vehicles planned
for deployment in California.
CARB has several other programs either in effect or going into effect that have an impact on
mobile sources. Some of these programs only apply to California-based equipment, while oth-
ers apply to any diesel-powered vehicle operating in California (regardless of where it is
registered). Vehicles registered in California have additional requirements (periodic smoke
inspection requirements and special regulations on utility, public agency, and trash collection
vehicle in California).
While CARB and some of the CARB programs are unique to California and California-based
vehicles, many other states have similar rules.
Drayage Trucks emissions

This program applies to all trucks that haul into, out of, or within port and rail facilities in
California. This regulation requires the registration of all trucks entering and operating in
ports and rail facilities, and establishes emissions reduction requirements that began phas-
ing in as of January 1, 2010 (vehicles can be registered at www.arb.ca.gov/drayagetruck). As
of January 1, 2010, class 8 trucks equipped with pre-1994 engines are no longer allowed into
the facilities. As of the most recent phase-in, class 7 and 8 trucks equipped with model year
24–Clean air 9/14

1994 to 2006 engines must meet the 2007 emissions standards (as of January 1, 2014). This
involves replacing the engine in the older trucks with a newer engine (2007 or newer) or
replacing the truck with a 2007 or newer truck. The final step is all trucks operating in the
port and rail facilities meeting the 2010 engine emission standards by January 1, 2023
(2010 and newer engines are fully compliant and will not require any updating).
Heavy-duty diesel vehicle inspection program (HDVIP)

Under this program, any heavy-duty diesel vehicle operating in California can be inspected
at any time to make sure it is meeting the emissions standards in place the year the engine
was manufactured. Part of the inspection also includes verifying that the emission control
system has not been tampered with. Many states have similar roadside emission inspection
programs.
Heavy-duty diesel vehicles registered in California are also subject to periodic (regularly
scheduled) emissions inspections. This is another emission program that many other states
also have in place.
Idling Reduction Program

Idling of any heavy-duty vehicle is limited to no more than five minutes in California. Also,
any heavy-duty vehicle operated in California with a model year 2008 or later engine must
have an automatic “shut-down” that turns the engine off after five minutes of idling. There
are a few exceptions to this rule (Clean Idle vehicles, operating auxiliary equipment, loading
and unloading passengers, etc.). However, idling to control cab temperature while the driver
is resting in a sleeper berth is not one of the exceptions.
TRUs
CARB has rules in place that began phasing in as of December 2008 pertaining to Transport
Refrigeration Units (TRUs). TRUs are defined as a refrigeration system (a system designed
to heat or cool products) that is powered by a diesel engine that is used in the transporta-
tion of goods. This definition includes the standard refrigerated units (the diesel engine
directly powers the compressor) and generator set (genset) refrigeration units that use a die-
sel engine to run a generator to provide power to an electric refrigeration unit. Refrigeration
systems that do not use a diesel engine for power (are powered off a power unit’s main
engine or are powered by “shore power”) are not considered to be TRUs by these regulations.
These rules will require all TRUs to meet the following emission standards:
• Low emission TRU (LETRU): 0.30 g/hr-hp emission if the diesel engine produces
less than 25 hp, and .22 g/hr-hp if over 25 hp, or be equipped with an emission sys-
tem meeting the Level 2 Verified Diesel Emission Control Strategy (VDECS) retrofit
standards.
• Ultra low emission TRU (ULETRU): 0.02 g/hr-hp if the diesel engine produces over
25 hp, or be equipped with an emission system meeting the Level 3 VDECS retrofit
standards (diesel engine less than 25 hp must meet the Level 3 VDECS retrofit
requirements and have no other compliance options).
9/14 Clean air–25

Here is a breakdown of the specific rules based on the compliance dates:

• August 1, 2009: All owners and operators of California-based TRUs must file with
CARB and secure an Air Resource Board Identification Number (ARB IN) by com-
pleting an application (for each TRU) that includes owner information, TRU
information (year, make, model, identification number, etc.), engine information
(year, make, model, horsepower, identification number), compliance status with the
performance standards, and how compliance was achieved. Once CARB has assigned
the TRU an ARB IN, the company has 30 days to display the number on the TRU.
This is the only requirement that out-of-state TRUs do not have to meet (voluntary
compliance is allowed for out-of-state TRU owners and operators).
• December 31, 2009: TRUs with an engine from model year (MY) of 2001 or earlier
must meet the LETRU requirements.
• December 31, 2009: TRUs from MY 2002 must meet the LETRU standards.
• December 31, 2010 (enforcement began March 31, 2011): TRUs with an engine from
MY 2003 must meet the LETRU or the ULETRU standards.
• December 31, 2011: TRUs with MY 2004 engines of less than 25 hp must meet the
LETRU or ULETRU standards. MY 2004 engines of 25 hp and greater must meet
the ULETRU standards.
• December 31, 2012: TRUs with an engine from MY 2005 must meet the ULETRU
standards.
standards.
standards.
• December 31, 2015: TRUs with an engine MY of 2001 or earlier must meet the
ULETRU requirements.
standards.
standards.
standards.
standards. MY 2003 engines that met the LETRU standards in 2010 must meet the
ULETRU standards.
standards. MY 2004 engines of less than 25 hp engines that met the LETRU stan-
dards in 2011 must meet the ULETRU standards.
standards.
CARB does account for engine changes. However, all an engine change will do at this time is
change the compliance date. Example: If you place a MY 2009 engine into a 2003 TRU, you
have changed the compliance date for the TRU from December 31, 2010, to December 31,
2016.
26–Clean air 9/14

There are several administrative actions pending that may have an impact on the TRU
implementation. Carriers that operate TRUs in California should plan on meeting the com-
pliance dates. However, be sure to monitor industry news for possible changes in the TRU
requirements.
Diesel-fueled auxiliary power systems

Diesel-Fueled Auxiliary Power Systems (also referred to as APUs) use small diesel engines
to generate power for cab heating, cab cooling, and operating ancillary appliances. These
units can also be used to heat the engine block in cold weather and recharge the vehicle’s
battery.
A Diesel-Fueled Auxiliary Power System operated on a truck equipped with a 2007 or newer
engine must be fitted with a verified Level 3 particulate control device (85 percent particu-
late reduction efficiency), or have its exhaust plumbed into the vehicle’s exhaust upstream to
use the vehicle’s particulate matter aftertreatment device. Also, the Diesel-Fueled Auxiliary
Power Systems must be approved by CARB and the vehicle must have an approved “Verified
Clean APS” label affixed to the hood.
A list of approved Diesel-Fueled Auxiliary Power Systems is available through the CARB
website at: arb.ca.gov/msprog/cabcomfort/cabcomfort.htm.
For trucks with 2006 and earlier model year engines, any California- or federally-certified
Internal Combustion Auxiliary Power System may be used.
Fuel-fired cab heaters

Fuel-Fired Heaters (also know as Fuel Operated Heaters) provide heat to the cab and the
engine block, and use only a fraction of the fuel that would be used by idling the vehicle’s
primary engine. They can be paired with cooling technologies (such as battery-electric,
vehicle-battery, or thermal energy storage systems) for a more complete heating and cooling
package.
Fuel-Fired Heaters operated on trucks equipped with 2007 and newer engines must meet
emission standards specified in California’s Low Emission Vehicle Program (as indicated on
the unit).
A list of approved Fuel-Fired Heaters is available through the CARB website at: arb.ca.gov/
msprog/cabcomfort/cabcomfort.htm.
On trucks equipped with 2006 and earlier model year engines, any Fuel-Fired Heater may
be used.
The reason for the regulatory distinction between pre-2007 vehicle engines and 2007 and
newer engines in these two areas is CARB wants to see less emission being generated by the
auxiliary unit than by the vehicle’s main engine. If an older auxiliary unit is placed on a
2007 or newer engine, this may not be the case.
9/14 Clean air–27

“Truck and Bus” rule

In 2008, CARB passed rules requiring that all trucks be brought up to the 2010 diesel par-
ticulate matter (DPM or simply PM) and Nitrogen Oxide (NOx) emissions requirements.
This will be accomplished by requiring all trucks built before 2010 to undergo a retrofit.
This rule is informally called the Truck and Bus rule or the Private Fleet rule (referring to
privately owned vehicles, not private carriers). Much like the TRU rules, the retrofit require-
ments and schedule will be based on the model year of the vehicle’s engine. The
implementation began by requiring vehicles with engines from model year 1996 to 1999 be
retrofitted to meet the PM requirements by January 1, 2012, and ends when all trucks with
pre-2010 engine are retrofitted to meet the 2010 standards by January 1, 2023. Here is the
implementation schedule:
Vehicle/Engine Model-Year Compliance Deadline, Jan 1… Requirements

Pre-1994 2015 2010 Engine
1994-1995 2016 2010 Engine
1996-1999 2012 PM BACT
2020 2010 Engine
2000-2004 2013 PM BACT
2021 2010 Engine
2005-2006 2014 PM BACT
2022 2010 Engine
2007-2009 2023 2010 Engine
2010 No requirements Meets all requirements
BACT — Best Available Control Technology, a.k.a. Particulate Matter (PM) Filter. “2010 Engine” means that the vehicle must be retrofitted
with a 2010 or newer engine by the compliance date shown if it is to stay in service.
There are provisions in the regulation that allow a fleet to phase in compliance based on
fleet averaging. This can allow a carrier to keep older equipment on the road if newer equip-
ment is purchased to reduce the fleet’s overall emissions. The carrier needs to be able to
show a “good faith effort” to comply. This involves having documentation showing that the
parts were ordered in a timely manner and/or that the attempt at financing was done in a
timely manner. The proof of the good faith effort must be retained at the company headquar-
ters and carried in the affected vehicles. To use any of the exceptions or phase-in provisions,
the company must also have registered with the program using the TRUCRS online regis-
tration tool before the applicable deadline. Go to https://ssl.arb.ca.gov/ssltrucrs/trucrs_
reporting/reporting.php or call 866-6DIESEL (634-3735) for registration information.
There is a separate implementation schedule for lighter trucks (trucks with a GVWR of
14,000 to 26,000 pounds) starting in 2015. The basic principle is that once a truck’s engine
reaches 20 years old, it must be replaced with a newer truck up to the 2001 and later model
years. The 2001 and later model years have a different implementation schedule. To start
the program, trucks with a 1995 or older model year engine would have to be replaced by
January 1, 2015. Fleets would have the option to install a PM filter retrofit on a lighter
truck by 2014 to make the truck exempt from replacement until January 1, 2020.
Details can be found at the CARB website at arb.ca.gov/msprog/onrdiesel/onrdiesel.htm.
28–Clean air 9/14

Please note: California has been considering adjusting some of the requirements and imple-
mentation dates to ease the impact of this rule.
EPA’s SmartWay Partnership Program

This regulation references a federal voluntary program called EPA SmartWay Partnership
Program. The EPA SmartWay Partnership Program aims to improve energy efficiency,
reduce greenhouse gases (GHG) and air pollutant emissions, and improve energy security of
the ground freight movement system by improving fuel mileage (reducing the amount of fuel
burned).
Under the SmartWay program, EPA certifies tractors and trailers that have been demon-
strated to be more fuel efficient than their traditional counterparts. At this time, there are
SmartWay specifications for tractors with sleeper cabs and for 53-foot or longer dry-van
trailers, and therefore, only these products can be certified by original equipment manufac-
turers under the SmartWay program. The SmartWay program also approves individual
aerodynamic equipment for trailers and efficient (low-rolling resistance) tires for tractors
and trailers.
The CARB regulation requires new and existing long-haul on-road tractors pulling 53-foot or
longer box-type trailers that operate on California highways, to be equipped with SmartWay-
approved aerodynamic technologies and low-rolling resistance tires. For purposes of the
regulation, a box-type trailer is a dry-van trailer or a refrigerated-van trailer. The regulation
does not apply to tractors pulling other types of trailers, e.g., box-type trailers of lengths
shorter than 53 feet, or to tractors pulling flatbeds, or logging trailers, drop-frame trailers,
curtain-side trailers, or chassis trailers hauling shipping containers. Also exempt from the
requirements of the regulation are authorized emergency vehicles and military tactical sup-
port vehicles, as well as short-haul and drayage tractors.
Beginning January 1, 2010, a 2011 and subsequent model year tractor with a sleeper berth
that pulls a 53-foot or longer box-type trailer on a California highway was required to be an
EPA-certified SmartWay tractor. SmartWay does not currently certify a tractor without a
sleeper berth, i.e., day cab, and thus, these tractors would not be required to be SmartWay
certified.
In addition, low-rolling resistance tires that meet EPA SmartWay specifications were
required beginning January 1, 2010, for a 2011 and subsequent model year tractor regard-
less of whether it has a sleeper berth. Beginning January 1, 2013, a 2010 and earlier model
year tractor with or without a sleeper berth that pulls a 53-foot or longer box-type trailer on
a California highway was required to be equipped with low-rolling resistance tires. This
would be the only retrofit requirement for these tractors.
The regulation required model year 2010 and older tractors, and tractors equipped with two
or more open-shoulder drive tires to use SmartWay verified low rolling resistance tires by
January 1, 2013. However, CARB has clarified that tractors using new non-SmartWay drive
tires manufactured before January 1, 2013 (based on the date stamp on the tire) can con-
tinue to use those tires for the useful life of that tread, or until January 1, 2015, whichever
comes first.
Any new drive tire placed on a covered tractor after January 1, 2013, must be a SmartWay
verified low rolling resistance tire. Tractors using new non-SmartWay open-shoulder drive
9/14 Clean air–29

tires manufactured before January 1, 2013, can continue to use those tires for the useful life
of that tread, or until January 1, 2015, whichever comes first. Any new open-shoulder drive
tire manufactured after January 1, 2013, and installed on a covered vehicle must be a
SmartWay verified low rolling resistance tire. Non-SmartWay open-shoulder retreaded tires
manufactured prior to January 1, 2014, may continue to be used for the useful life of that
tread, or until January 1, 2016, whichever comes first. Any open-shoulder retreaded drive
tire retreaded after January 1, 2014, must be capped with a SmartWay verified low rolling
resistance retread material on any casing.
MY 2010 and older trailers must also use SmartWay verified low rolling resistance tires by
January 1, 2017. The MY 2003 to 2009 refrigerated trailers equipped with 2003 or newer
MY transport refrigeration units have a compliance phase-in between 2017 and 2019.
53’ Trailer Compliance Options for Low Rolling Resistance Tires
Trailer Type Purchase Certified Retrofitted with SmartWay- Retrofitted with SmartWay-
SmartWay Trailer approved low rolling approved low-rolling
resistance tires and resistance tires and
SmartWay-approved aerodynamic devices
aerodynamic devices demonstrated to meet min.
fuel savings per SmartWay
Program
Dry-Van Available Aero = side skirts + rear or Aero must provide 5
front fairing precent fuel savings
Refrigerated-Van Not available on new Aero = side skirts Aero must provide 4
trailers at this time precent fuel savings
For older tractors and trailers, and vehicles using recaps, CARB requires the following:
1. Model year 2011 and newer tractors and trailers using retreaded tires comprised of
a SmartWay casing capped with any retread material prior to January 1, 2013, can
continue to use those tires for the useful life of the tread or until January 1, 2015,
for tractors and January 1, 2017, for trailers, whichever comes first.
2. Any tire retreaded after January 1, 2013, must be capped with a SmartWay verified
low rolling resistance retread material on any casing.
The regulations do provide an implementation schedule for trailers built before January 1,
2010, with additional time provided for small carriers to comply, and a few exceptions. Full
details on the small fleet and general exceptions are available at the CARB website at arb.
ca.gov/cc/hdghg/hdghg.htm.
Exempt from this regulation are:

• Custom extended sleeper cab tractors,
• Curtain side vans,
• Container chassis,
• Drayage tractors and trailers that operate within a 100 mile radius of a port or
intermodal rail yard, and
• Solid waste vehicles.
30–Clean air 9/14

The type or number of technologies required will be based on the percentage of greenhouse
gas emissions reduction of each device. These required percentages can be found in the regu-
lation at: arb.ca.gov/regact/2008/ghghdv08/ghghdv08.htm.
On-board diagnostics
On September 8, 2008, EPA granted the CARB waiver request related to on-board emissions
diagnostics. Under this CARB rule all heavy-duty trucks operating in California built in
model year 2010 or later must have an on-board diagnostic system that notifies the driver if
the emissions system is not functioning correctly. The diagnostic system must monitor all
vehicle systems and components that can effect emissions, such as fuel, catalytic converter,
turbocharger, exhaust gas recirculation, particulate matter filter, cooling, and valve timing.
If a malfunction is detected by the system, the diagnostic system must immediately report
the malfunction to the driver (via a dash display). The rule requires that the driver be noti-
fied as soon as any component involved in the emissions system malfunctions, not when the
emissions exceed the regulatory limits.
Idle reduction laws

In an attempt to lower emissions being generated by on-road diesel engines, many states
have enacted idle reduction laws. These laws limit the amount of time the main engine on a
vehicle can be idled when the vehicle is parked. Vehicles equipped with APUs, gensets, and
other idle or emission reduction systems are allowed to use these systems and still be con-
sidered in compliance.
Here are the states that have idling laws and a brief explanation of their laws:
• Arizona does not have a statewide law, but does have a law that requires counties
above a specified population to have an idle reduction law. As a result, only
Maricopa County limits idling.
• California allows five minutes of idling unless the vehicle is marked with a Califor-
nia Clean Idle label.
• Connecticut allows an engine to be idled for three minutes unless the temperature
is below 20 degrees.
• Delaware allows an engine to be idled for three minutes if the temperature is
above freezing and for 15 minutes if the temperature is between minus 10 and 32
degrees. If the temperature goes below minus 10 degrees there is no limit on idling.
• District of Columbia allows three minutes of idling, unless the temperature falls
below 32 degrees, then the engine may be idled up to five minutes.
• Florida allows five minutes of idling.
• Hawaii allows up to three minutes of idling to warm up or cool down the engine
only.
• Illinois does not allow the idling of unattended vehicles under any circumstances.
Illinois also has a state law regulating idling in the counties of Cook, DuPage, Lake,
Kane, McHenry, Will, Madison, St. Clair, and Monroe, and the townships of Aux
Sable and Goose Lake in Grundy County and the township of Oswego in Kendall
County. In these counties and townships idling is allowed for 10 minutes of any 60
9/14 Clean air–31

minute period. There are exceptions if it is necessary for the driver’s rest when in
the sleeper berth or if the temperature is under 32 degrees or over 80 degrees.
• Maine allows five minutes of idling in any one-hour period. There is no limit If the
temperature goes below zero degrees. The law includes various exemptions, includ-
ing sleeper berth heating or cooling during rest or sleep periods.
• Maryland allows up to five minutes of idling.
• Massachusetts allows up to five minutes of idling.
• Missouri allows up to five minutes of idling in any hour (30 minutes/hour when
waiting to load/unload) in the following counties: Clay, Franklin, Jackson, Jefferson,
Platte, and St. Charles. St. Louis County is restricted to three minutes of idling.
• Nevada allows up to 15 minutes of idling.
• New Hampshire allows five minutes of idling if the temperature is over 32 degrees
and 15 minutes if the temperature is between minus 10 and 32 degrees. If the tem-
perature goes below minus 10 degrees there is no limit on idling.
• New Jersey allows three minutes of idling if the temperature is above 25 degrees.
If the temperature goes below 25 degrees the engine may be idled for 15 minutes if
the vehicle is parked for over three hours. New Jersey does allow idling if the driver
is in the sleeper berth resting, and the truck is equipped with a model year 2007 or
newer engine, or if the truck has been retrofitted with a diesel particulate filter.
• New York allows five minutes of idling if the temperature is above 25 degrees. If
the temperature goes below 25 degrees the engine may be idled if the vehicle is
parked for over two hours.
• North Carolina allows five minutes of idling in any one hour period. Idling by
vehicles marked with a California Clean Idle label is allowed.
• Oregon allows five minutes of idling in any 60 minute period. This extends to 30
minutes of idling in any 60 minute period if the vehicle is waiting to load or unload,
or is loading or unloading. Oregon also allows idling if the driver is resting in the
vehicle and the temperature is under 50 degrees or over 75 degrees.
• Pennsylvania allows five minutes in any one hour period. Idling by vehicles
marked with a California Clean Idle label is allowed.
• Rhode Island allows five minutes of idling each hour if the temperature is above
32 degrees. If the temperature is between zero and 32 degrees the limit increases to
15 minutes per hour. When the temperature is below zero there is no limit on idling.
• South Carolina allows 10 minutes of idling. The law includes various exemptions,
including sleeper berth heating or cooling during rest or sleep periods if the tem-
perature is below 40 degrees or above 80 degrees, and the truck is at a rest area,
terminal, or truck stop.
• Texas State Codes apply to only the following counties: Bastrop, Caldwell, Collin,
Dallas, Hays, Kaufman, Tarrant, Travis, and Williamson and the following cities
and towns: Arlington, Austin, Bastrop, Benbrook, Cedar Hill, Celina, Colleyville,
Dallas, Duncanville, Elgin, Euless, Fort Worth, Georgetown, Hurst, Hutto, Keene,
Lake Worth, Lancaster, Little Elm, Lockhart, Luling, Mabank, McKinney, Mesquite,
North Richland Hills, Pecan Hill, Richardson, Round Rock, Rowlett, San Marcos,
University Park, Venus, and Westlake. The Texas State Codes in effect in these
municipalities allows for a maximum of five minutes of idling.
• Utah does not allow an unattended vehicle to be left idling.
32–Clean air 9/14

• Virginia limits idling to 10 minutes in commercial and residential areas.

• West Virginia allows 15 minutes of idling in any 60-minute period. Idling by
vehicles marked with a California Clean Idle label and vehicles powered by alter-
nate clean fuels is allowed.
Many municipalities also have laws prohibiting or limiting idling.
Title III: Air toxics

Toxic air pollutants are those pollutants that are hazardous to human health or the environ-
ment, but are not specifically covered under another portion of the Clean Air Act. These
pollutants are typically carcinogens, mutagens, and reproductive toxins.
Information generated from the Community Right to Know rule (SARA §313) indicates that
more than 2.7 billion pounds of toxic air pollutants are emitted annually in the United
States.
Completely rewritten by the Clean Air Act Amendments of 1990, Section 112 of the Act
establishes programs for protecting the public health and environment from exposure to
toxic air pollutants. As revised by the 1990 amendments, the section contains four major
provisions:
• Maximum Achievable Control Technology (MACT) requirements;
• Health-based standards;
• Standards for stationary area sources; and
• Requirements for the prevention of catastrophic releases.
First, EPA established technology-based emission standards, called MACT standards, for
sources of 188 pollutants listed in the legislation (refer to Table 1), and to specify categories
of sources subject to the emission standards. EPA must revise the standards periodically (at
least every eight years). EPA can, on its initiative or in response to a petition, add or delete
substances or source categories from the lists.
In addition, EPA is required to set standards for sources of the listed pollutants that achieve
“the maximum degree of reduction in emissions” taking into account cost and other non-air-
quality factors. The list of source categories must include: (1) major sources emitting 10
tons/year of any one, or 25 tons/year of any combination of those pollutants; and, (2) area
sources.
The second major provision of Section 112 directs EPA to set health-based standards to
address situations in which a significant residual risk of adverse health effects or a threat of
adverse environmental effects remains after installation of MACT. This provision requires
that EPA, after consultation with the Surgeon General of the United States, submit a report
to Congress on the public health significance of residual risks, and recommend legislation
regarding such risks. If Congress does not legislate in response to EPA’s recommendations,
then EPA is required to issue standards for categories of sources of hazardous air pollutants
as necessary to protect the public health with an ample margin of safety or to prevent an
adverse environmental effect.
9/14 Clean air–33

A residual risk standard is required for any source emitting a cancer-causing pollutant that
poses an added risk to the most exposed person of more than one-in-a-million. Residual risk
standards would be due eight years after promulgation of MACT for the affected source
category. Existing sources would have 90 days to comply with a residual risk standard, with
a possible two-year extension. In general, residual risk standards do not apply to area
sources.
Third, in addition to the technology-based and health-based programs for major sources of
hazardous air pollution, EPA is to establish standards for stationary area sources deter-
mined to present a threat of adverse effects to human health or the environment. The
provision requires EPA to regulate the stationary area sources responsible for 90% of the
emissions of the 30 hazardous air pollutants that present the greatest risk to public health
in the largest number of urban areas. In setting the standard, EPA can impose less stringent
“generally available” control technologies, rather than MACT.
Finally, Section 112 addresses prevention of sudden, catastrophic releases of air toxics by
establishing an independent Chemical Safety and Hazard Investigation Board. The Board is
responsible for investigating accidents involving releases of hazardous substances, conduct-
ing studies, and preparing reports on the handling of toxic materials and measures to reduce
the risk of accidents.
EPA is also directed to issue prevention, detection, and correction requirements for cata-
strophic releases of air toxics by major sources. Section 112 requires owners and operators to
prepare risk management plans including hazard assessments, measures to prevent
releases, and a response program. (See the Risk management/process safety tab in this
book.)
Title IV: Acid deposition control

Acid rain occurs when sulfur dioxide and nitrogen oxide emissions are transformed in the
atmosphere and return to the earth in rain, fog, or snow. Approximately 20 million tons of
sulfur dioxide are emitted annually in the United States, mostly from the burning of fossil
fuels by electric utilities. Acid rain damages lakes, harms forests and buildings, contributes
to reduced visibility, and may also damage health.
The Clean Air Act resulted in a permanent 10 million ton reduction in sulfur dioxide emis-
sions from 1980 levels. To achieve this, EPA allocated allowances in two phases, permitting
utilities to emit one ton of sulfur dioxide. The first phase, which was effective January 1,
1995, required 110 power plants to reduce their emissions to a level equivalent to the prod-
uct of an emissions rate of 2.5 lbs. of sulfur dioxide/mmBtu times an average of their 1985
through 1987 fuel use. The law also allocated 200,000 annual allowances per year (for each
of the 5 years of Phase I) to power plants in Illinois, Indiana, and Ohio.
The second phase, effective January 1, 2000, required approximately 2000 utilities to reduce
their emissions to a level equivalent to the product of an emissions rate of 1.2 lbs. of sulfur
dioxide/mm Btu times the average of their 1985 through 1987 fuel use. In both phases,
affected sources were required to install systems that continuously monitor emissions in
order to track progress and assure compliance.
The law allows utilities to trade allowances within their systems, and/or buy or sell allow-
ances to and from other affected sources. Each source must have sufficient allowances to
34–Clean air 9/14

cover its annual emissions. If not, the source is subject to a $2,000 per ton excess emissions
fee, and a requirement to offset the excess emissions in the following year.
Nationwide, plants that emit sulfur dioxide at a rate below 1.2 lbs/mm Btu were able to
increase emissions by 20% between a baseline year, and the year 2000. Bonus allowances
were distributed to accommodate growth by units in states with a statewide average below
0.8 lbs/mm Btu. Plants experiencing increases in their use in the last five years also receive
bonus allowances. Fifty thousand bonus allowances per year are allocated to plants in 10
Midwestern states that make reductions in Phase I. Plants that repower with a qualifying
clean coal technology may receive a 4 year extension of the compliance date for Phase II
emission limitations.
The Act also requires EPA to inventory industrial emissions of SO2 and to report every five
years, beginning in 1995. If the inventory shows that industrial emissions may reach levels
above 5.60 million tons per year, then EPA must take action to ensure that the 5.60-million-
ton cap is not exceeded.
The law also includes specific requirements for reducing emissions of nitrogen oxides, based
on EPA regulations issued in 1992 for certain boilers, and in 1997 for all remaining boilers.
Title V: Permits
The three major permitting programs required by the CAA include:
• Acid rain permits (Title IV permits),
• Preconstruction permits (New Source Review permits), and
• Operating permits (Title V permits).
The purpose of the Title V operating permits program is to ensure compliance with all appli-
cable requirements of the CAA, and to enhance EPA’s ability to enforce the Act. Air pollution
sources subject to the program must obtain an operating permit.
Under the CAA, EPA is the regulating authority while the states must develop and imple-
ment the program. EPA reviews each state’s proposed program and oversees the state’s
efforts to implement any approved programs. EPA must develop and implement a federal
permit program when a state fails to adopt and implement its own program. The law also
requires a construction permit for certain pollution sources. 35 states currently have their
own laws requiring operating permits.
The program clarifies and makes more enforceable a source’s pollution control requirements.
Otherwise, a source’s pollution control obligations might be scattered throughout numerous
hard-to-find provisions of state and federal regulations. The permit program ensures that all
of a source’s obligations with respect to its pollutants will be contained in one permit docu-
ment, and that the source will file periodic reports to both the state and EPA identifying
how it has complied with those obligations. Both of these requirements greatly enhance the
ability of federal and state agencies to evaluate air quality situations.
The program provides a way for states to assume administration, subject to federal over-
sight, of significant parts of the air toxics program and the acid rain program. Permit fees
allow a state to administer pollution control programs by requiring sources of pollution to
pay a portion of the costs of the program.
9/14 Clean air–35

Operating permits are issued to all major sources and a limited number of area sources. The
permit stipulates how much of and what types of pollutants a source is allowed to emit. As a
part of the permit process, a source must prepare a compliance plan and certify compliance.
Each permit issued to a facility will be for a fixed term of up to five years and will include a
fee to cover reasonable direct and indirect costs of the permitting program.
The state permitting authority must determine whether or not to approve an application
within 18 months of the date it receives the application. Some states are working on making
the time from submittal to approval even shorter.
EPA has 45 days to review each permit and to object to permits that violate the CAA. If EPA
fails to object to a permit that violates the Act or the implementation plan, any person or
may petition EPA to object within 60 days following EPA’s 45-day review period, and EPA
must grant or deny the permit within 60 days. Judicial review of EPA’s decision on a citi-
zen’s petition can occur in the federal court of appeals.
Sources subject to the permit requirements generally include major sources that emit or
have the potential to emit 100 tons per year of any regulated pollutant, plus stationary and
area sources that emit or have potential to emit lesser specified amounts of hazardous air
pollutants. However, in nonattainment areas, the permit requirements also include sources
which emit as little as 50, 25, or 10 tons per year of volatile organic compounds (VOCs),
depending on the severity of the region’s nonattainment status (serious, severe, or extreme).
Which sources are subject to Title V permitting requirements?

• Any Major Source:
❍ A major source has actual or potential emissions that meet or exceed the major
source threshold for their location.
❍ The major source threshold for any air pollutant is 100 tons/year .
❍ Lower thresholds apply in non-attainment areas for the pollutant that is in
non-attainment.
❍ Major source thresholds for hazardous air pollutants (HAPs ) are 10 tons/year
for a single HAP or 25 tons/year for any combination of HAP.
• Any Source with a Major Source Permit under PSD or NSR.
• “Affected Sources” under Acid rain rules.
• Solid waste incineration units under Section 129 including:
❍ Municipal waste combustors (large and small);
❍ Hospital/medical/infectious waste incinerators;
❍ Commercial and industrial solid waste incinerators;
❍ Other solid waste incinerators; and
❍ Sewage sludge incinerators.
• Non-major Sources subject to NESHAPS (MACT or GACT) standards includ-
ing:
❍ Portland cement manufacturers;
❍ Mercury cell color-alkali plants;
36–Clean air 9/14

❍ Secondary lead smelters;

❍ Carbon black production;
❍ Chemical manufacturing: chromium compounds;
❍ Primary copper smelting;
❍ Secondary copper smelting;
❍ Nonferrous metals area sources: zinc, cadmium, and beryllium;
❍ Glass manufacturing;
❍ Electric arc furnace steelmaking facilities;
❍ Gold mine ore processing and production; and
❍ Hazardous waste combustors.
• Certain synthetic minor sources subject to NESHAPS standards:
❍ Chemical manufacturing.
• Non-major sources subject to MACT and NSPS standards:
❍ Municipal solid waste landfills.
Note: Newly promulgated NSPS or MACT standards applying to area sources must clarify
whether the area sources are required to obtain Title V permits.
Businesses that generally need permits
All types of businesses may need to apply for an air operating permit based on their
emissions. Evaporation from paints, printing inks, coatings, or cleaning solvents are
examples of emissions that are regulated. Recent regulations have been written affecting the
following types of small businesses:
• Lithographic printers;
• Motor vehicle refinishers;
• Solvent parts cleaners;
• Users of industrial adhesives;
• Wood furniture manufacturers;
• metal. finishing operations; and
• Painting and coating operations.
Permit exemptions
All businesses are required to get an air operating permit unless they meet a specific exemp-
tion, or a general exemption. Many states that have the authority to operate their own air
program have set specific exemptions for particular air pollution sources that either cur-
rently emit air pollution, or have the potential to emit. These sources include:
• painting or coating operations;
• graphic arts operations;
• cold cleaning equipment;
• open top vapor degreasing equipment with a total air-to-vapor interface of 1.0
square meters or less during operation;
9/14 Clean air–37

• dry cleaning operations; and

• gasoline dispensing facilities that dispense gasoline or other petroleum products.
The lists above are only partial lists. A complete list of covered businesses and specific
exemptions can be obtained from your state environmental agency, or your state’s Small
Business Clean Air Assistance Program, normally overseen by your state Department of
Commerce.
General exemptions
A general exemption is based on your facility’s Maximum Theoretical Emissions (MTE). This
is a calculation of the greatest possible amount of air pollution your business could emit if
you operated at maximum production capacity, 24 hours a day, 365 days a year, without any
air pollution control devices.
Your MTE needs to be less than the air operating program limits for the following different
pollutants:
• Volatile organic compounds, particulate matter, nitrogen oxides or lead;
• Sulfur dioxide or carbon monoxide;
• Single hazardous air pollutant; and
• Any combination of hazardous air pollutants.
To find out the operating program limits for these pollutants, you will need to contact an air
specialist with your state environmental agency.
You also need to be aware that your state may have specified many more hazardous air
pollutants. It is possible that some of these pollutants are on both the federal list and your
state’s list. If you need help in determining whether you have any hazardous air pollutants,
review your material safety data sheets, contact your suppliers, or call a state air compli-
ance specialist or a representative with your state’s Small Business Clean Air Assistance
Program.
Permanent exemptions
EPA has finalized permanent exemptions from the Title V operating permit program for five
categories of area sources that are subject to national emission standards for hazardous air
pollutants (NESHAPS). EPA made a finding for these categories that compliance with Title
V permitting requirements is impracticable, infeasible, or unnecessarily burdensome on the
source categories.
This final rule affects only whether area sources regulated by certain NESHAPS are
required to obtain a Title V operating permit and whether Title V permits may be issued to
these and other area sources once EPA has promulgated exemptions for them. It has no
other effect on any requirements of the NESHAPS regulations, nor on the requirements of
state or federal Title V operating permit programs.
The five source categories are:
• Dry cleaners,
• Halogenated solvent degreasers,
• Chrome electroplaters,
• Ethylene oxide sterilizers, and
38–Clean air 9/14

• Secondary aluminum smelters.
Calculating maximum theoretical emissions

Here’s a general example of how to figure out your MTE for the VOCs in a paint spraying
operation:
1. Find out the highest VOC content in the material(s) you use. (VOC lb/gal)
2. Determine the maximum amount of this material you can use in one hour.
(gal/hour)
3. Calculate how much VOC you would emit if you used this amount of material for 24
hours a day for a year.
(24 hours × 365 days = 8,760 hours)
Example:
VOC per gallon: 6.7 lb/gal
Maximum usage of material: 4 gal/hr
6.7 lb/gal × 4 gal/hr = 26.8 lb/hr
26.8 lb/hr × 8760 hr/yr = 234,768 lb/yr
234,768 lb/year 2000 lb/ton = 117 tons/year
Do you need a permit?

If your MTE calculations show that you need an air operating permit, your next step is to
identify what type of permit you’ll need. You do this by calculating your facility’s potential to
emit (PTE). Your potential to emit shows if your business is considered to be a major source
of air pollution.
Calculating your potential to emit

Like the MTE calculations, when figuring your PTE, look at your business’ air pollution
emissions at maximum production capacity, 24 hours a day, 365 days per year. This PTE cal-
culation may be different from your maximum theoretical emissions calculation because
certain allowances can be made, such as physical or operational limits on your production
capacity, or use of existing air pollution control equipment.
However, any allowances must be enforced in an existing air permit, or by an existing emis-
sion standard. Examples of these allowances include:
• Any physical or operational limits on your facility’s capacity;
• Air pollution control devices;
• Restriction on hours of operations; and
• Restrictions on type or amount of material combusted, stored or processed.
Determining if your business is considered a major source of air pollution

If your PTE calculations show that your facility has the potential to emit more than or equal
to any of the following limits, your business is considered to be a major source of air
pollution.
• Any single air contaminant - 100 tons/year
• Single hazardous air pollutant - 10 tons/year
• Total of all hazardous air pollutants - 25 tons/year
9/14 Clean air–39

• Volatile organic compounds - 25 tons/year (Only in federally designated non-

attainment areas.)
As a major source, you can choose between two types of permits:
• A Title V Permit (also called a “Part 70” Permit) is for businesses with a PTE over
the threshold values listed previously; or
• A Synthetic Minor permit is for a business that has the potential to be a major
source, but has agreed by permit conditions to stay under major source emission
limits. (This could be done by requesting restrictions on hours of operation, type or
amount of material processed, etc., to limit PTE.)
The Synthetic Minor Permit is designed to have an easier application process; however, it
may limit your business’ future growth. You need to decide which type of permit suits your
situation best.
Note: If your business is not a major source, you will need a State Operating Permit (also
referred to as a Non-Part 70 Permit).
Your responsibilities as a business owner

It is your responsibility as a business owner to determine whether you need an Air Operat-
ing Permit, and if so, to submit a permit application to your state environmental agency. It
is illegal to operate your business without an Air Operating Permit if your business is
required to have one. To request a permit application, contact an air specialist with your
state environmental agency.
Permits for GHG emissions

On May 13, 2010, the EPA issued a final rule that addresses greenhouse gas emissions from
stationary sources under the Clean Air Act (CAA) permitting programs. This final rule sets
thresholds for greenhouse gas (GHG) emissions that define when permits under the New
Source Review Prevention of Significant Deterioration (PSD) and Title V Operating Permit
programs are required for new and existing industrial facilities.
Known as the GHG Tailoring Rule because it “tailors” the requirements of these CAA per-
mitting programs to limit which facilities will be required to obtain PSD and Title V
permits, facilities responsible for nearly 70 percent of the national GHG emissions from sta-
tionary sources will now be subject to permitting requirements. This includes the nation’s
largest GHG emitters — power plants, refineries, and cement production facilities. However,
emissions from small farms, restaurants, and all but the very largest commercial facilities
will not be covered by these programs at this time.
GHG Tailoring Rule

The GHG Tailoring Rule establishes a schedule that will initially focus CAA permitting pro-
grams on the largest sources with the most CAA permitting experience. The rule then
expands to cover the largest sources of GHG that may not have been previously covered by
the CAA for other pollutants. Finally, it describes EPA plans for any additional steps in this
process.
The CAA permitting program emissions thresholds for criteria pollutants such as lead, sul-
fur dioxide, and nitrogen dioxide, are 100 and 250 tons per year (tpy). While these
40–Clean air 9/14

thresholds are appropriate for criteria pollutants, they are not feasible for GHGs because
GHGs are emitted in much higher volumes.
Without this tailoring rule, the lower emissions thresholds would have taken effect auto-
matically for GHGs on January 2, 2011. PSD and Title V requirements at these thresholds
would have lead to dramatic increases in the number of required permits — tens of thou-
sands of PSD permits and millions of Title V permits. State, local, and tribal permitting
authorities would have been overwhelmed and the programs’ abilities to manage air quality
would be severely impaired.
EPA is taking a three-step approach to phasing in the CAA permitting requirements for
GHGs.
Phased approach
Step 1. (January 2, 2011 – June 30, 2011) Only sources currently subject to the PSD per-
mitting program (i.e., those that are newly-constructed or modified in a way that
significantly increases emissions of a pollutant other than GHGs) would be subject to per-
mitting requirements for their GHG emissions under PSD.
For these projects, only GHG increases of 75,000 tpy or more of total GHG, on a CO2e basis,
would need to determine the Best Available Control Technology (BACT) for their GHG
emissions.
Similarly for the operating permit program, only sources currently subject to the program
(i.e., newly constructed or existing major sources for a pollutant other than GHGs) would be
subject to Title V requirements for GHG.
During this time, no sources would be subject to Clean Air Act permitting requirements due
solely to GHG emissions.
Step 2. (July 1, 2011 to June 30, 2013) Step 2 will build on Step 1.
In Step 2, operating permit requirements will, for the first time, apply to sources based on
their GHG emissions even if they would not apply based on emissions of any other pollutant.
Facilities that emit at least 100,000 tpy CO2e will be subject to Title V permitting
requirements.
EPA estimates that about 550 sources will need to obtain Title V permits for the first time
due to their GHG emissions. The majority of these newly permitted sources will likely be
solid waste landfills and industrial manufacturers. There will be approximately 900 addi-
tional PSD permitting actions each year triggered by increases in GHG emissions from new
and modified emission sources.
Step 3. (June 29, 2012) EPA issued a final rule that did not revise the GHG permitting
thresholds that were established in Step 1 and 2 of the GHG Tailoring Rule. Step 3 contin-
ues permitting requirements for new facilities with GHG emissions of at least 100,000 tons
per year (tpy) carbon dioxide equivalent (CO2e) and existing facilities with at least 100,000
tpy CO2e making changes that would increase GHG emissions by at least 75,000 tpy CO2e
to obtain PSD permits. Facilities that must obtain a PSD permit anyway, to cover other
regulated pollutants, must also address GHG emissions increases of 75,000 tpy CO2e or
more. New and existing sources with GHG emissions above 100,000 tpy CO2e must also
obtain operating permits.
9/14 Clean air–41

By the end of April 2015, EPA says it will complete a study on remaining GHG permitting
burdens that would exist if it applied the program to smaller sources. EPA will consider the
results of the study to complete a rule by April 30, 2016, further addressing Clean Air Act
permitting for these facilities. EPA may decide that successful streamlining will allow it to
phase in more sources, but it may also decide that certain smaller sources need to be perma-
nently excluded from permitting.
Implementation
Step 1 of this final rule took effect on January 2, 2011. The final rule asked states to inform
EPA whether they must make rule changes to implement the new GHG emissions thresh-
olds, and when such changes will be adopted. If there are cases where this couldn’t happen
by January 2, 2011, EPA said it would take appropriate action to ensure that the existing
CAA permitting rules do not apply to sources excluded by rule at this time.
EPA also plans to develop supporting guidance and other information to assist permitting
authorities as they begin to address permitting actions for GHG emissions for the first time.
EPA will be actively working with states on technical information and data needs related to
identifying BACT requirements for PSD permits. The guidance would first cover source cat-
egories that typically emit GHGs at levels exceeding the thresholds established through this
rulemaking.
Note that a June 2014 Supreme Court ruling may affect implementation of the Tailoring
Rule. The Court said EPA could continue to require permits for major sources that are
already covered under permitting requirements for conventional air pollutants (lead, mer-
cury, ozone, etc.), but that the agency could not require permitting for a source that only
emitted greenhouse gases. For the most up-to-date information, see epa.gov/nsr/
ghgpermitting.html.
Title VI: Stratospheric ozone and global climate protection

Title VI builds on the market-based structure and requirements currently contained in
EPA’s regulations to phase out the production of substances that deplete the ozone layer.
The law requires a complete phase-out of chlorofluorocarbons (CFCs) and halons with
interim reductions and some related changes to the existing Montreal Protocol, revised in
June 1990.
What is the Montreal Protocol?

In 1974, scientists discovered that CFCs could deplete the stratospheric ozone layer, and in
fact, a large hole was forming over Antarctica. In response many world leaders met in Mon-
treal in 1987 to sign a treaty — the Montreal Protocol — designed to heal the ozone layer
and end production of ozone-depleting substances.
Under these provisions, EPA must list all regulated substances along with their ozone deple-
tion potential, atmospheric lifetimes, and global warming potentials within 60 days of
enactment. In addition, EPA must ensure that Class I chemicals are phased out on a sched-
ule similar to that specified in the Montreal Protocol — CFCs, halons, and carbon
tetrachloride were phased out by 2000; methyl chloroform by 2002 — but with more strin-
gent interim reductions. Class II chemicals (HCFCs) must be phased out by 2030.
42–Clean air 9/14

The law also requires EPA to publish a list of safe and unsafe substitutes for Class I and II
chemicals, and to ban the use of unsafe substitutes. Nonessential products releasing Class I
chemicals must be banned within 2 years of enactment. In 1994 a ban went into effect for
aerosols and non-insulating foams using Class II chemicals, with exemptions for flammabil-
ity and safety.
Title VI also contains several implementing strategies to avoid releases of ozone-depleting

chemicals to the atmosphere, including (1) for Class 1 substances used as refrigerant — low-
est achievable level of use and emissions, maximum recycling, and safe disposal required by
July 1, 1992; (2) for servicing or disposing refrigeration equipment containing Class 1 and 2
substances — venting banned as of July 1, 1992; (3) for motor vehicle air conditioners con-
taining Class 1 or 2 substances — recycling required by January 1, 1992 (smaller shops by
January 1, 1993); (4) sale of small containers of class 1 and 2 substances — banned within
two years of enactment; and (5) nonessential products — banned within two years of
enactment.
Find tables listing Class I ozone-depleting substances and Class II ozone-depleting sub-
stances at epa.gov/ozone/science/ods/index.html.
Title VII: Provisions relating to enforcement

EPA has the authority to issue administrative penalty orders up to $200,000, and field cita-
tions up to $5,000 for lesser infractions. Civil judicial penalties are enhanced, criminal
penalties for knowing violations are upgraded from misdemeanors to felonies, and new
criminal authorities for knowing and negligent endangerment will be established.
In addition, sources must certify their compliance, and EPA has authority to issue adminis-
trative subpoenas for compliance data. EPA will also be authorized to issue compliance
orders with compliance schedules of up to one year.
The citizen suit provisions have also been revised to allow citizens to seek penalties against
violators, with the penalties going to a U.S. Treasury fund for use by EPA for compliance
and enforcement activities. The government’s right to intervene is clarified, and citizen
plaintiffs will be required to provide the U.S. with copies of pleadings and draft settlements.
Clean Air Act regulatory actions

EPA has undertaken a number of regulatory initiatives to address and mitigate air
pollution. Here are a few of the air programs that may affect your operations.
Transport rules
Clean Air Interstate Rule and the Cross-State Air Pollution Rule (CSAPR)
EPA finalized the Cross-State Air Pollution Rule (CSAPR) on July 6, 2011. The rule was
designed to reduce air pollution that is generated in one state but drifts into another state.
CSAPR requires states to significantly improve air quality by reducing power plant emis-
sions that contribute to ozone and/or fine particle pollution in downwind states. The rule
also addressed “Summertime NOx” in five states (IA, MI, MO, OK, and WI). CSAPR would
mandate 28 states to reduce annual SO2 emissions, annual NOx emissions, and/or ozone
9/14 Clean air–43

season NOx emissions to assist in attaining the 1997 ozone and fine particle and 2006 fine
particle NAAQS.
Note: On August 21, 2012, the U.S. Court of Appeals for the D.C. Circuit ruled that
CSAPR overstepped the bounds of the Clean Air Act and struck down the rule. For
now, EPA must enforce the earlier transport rule, the Clean Air Interstate rule.
CAIR calls for federal implementation plans (FIPs), EPA-approved CAIR state implementa-
tion plans (SIPs), and three CAIR trading programs (the ozone-season nitrogen oxides (NOx)
trading program, the annual NOx trading program, and the annual sulfur dioxides (SO2)
trading program).
CAIR covers 28 eastern states and the District of Columbia. Basically, CAIR is a cap-and-
trade system aimed at reducing SO2 and NOx by 70 percent. States must achieve the
required emission reductions by either:
1. Meeting the state’s emission budget by requiring power plants to participate in an
EPA-administered interstate cap and trade system that “caps” emissions in two
stages; or
2. Meeting an individual state emissions budget through measures of the state’s
choosing.
CAIR cap-and-trade
EPA already allocated emission “allowances” for SO2 to sources subject to the Acid Rain
Program. These allowances will also be used in the CAIR model SO2 trading program. For
the model NOx trading programs, EPA will provide emission “allowances” for NOx to each
state, according to the state budget. The states will allocate those allowances to sources (or
other entities), which can trade them. As a result, sources are able to choose from many
compliance alternatives, including: installing pollution control equipment; switching fuels; or
buying excess allowances from other sources that have reduced their emissions.
Because each source must hold sufficient allowances to cover its emissions each year, the
limited number of allowances available ensures required reductions are achieved.
The mandatory emission caps and stringent emissions monitoring and reporting require-
ments with significant penalties for noncompliance, ensure that human health and
environmental goals are achieved and sustained.
The flexibility of allowance trading creates financial incentives for electricity generators to
look for new and low-cost ways to reduce emissions and improve the effectiveness of pollu-
tion control equipment.
To find out if your facility is covered under CAIR, or for technical details on how to comply,
go to EPA’s Technical Information webpage at epa.gov/airmarkets/progsregs/cair/technical.
html.
Geologic sequestration of CO2

Geologic sequestration (GS) is the process of capturing CO2 from a stationary source coal-
fired electric generating power plant, and injecting it underground for long-term storage.
The technology is still being developed, but GS may serve to reduce CO2 emissions in the
future. In July 2008, EPA published the federal requirements under the Underground Injec-
tion Control (UIC) Program for CO2 GS wells.
44–Clean air 9/14

The Agency believes that almost all of the largest stationary sources of CO2 emissions in the
U.S. are within 50 miles of a candidate GS site. Find out more about GS at epa.gov/
climatechange.emissions/co2_geosequest.html.
Regional haze program

Since 1999, the Regional Haze Rule has called for state and federal agencies to cooperate to
improve visibility in national parks and wilderness areas. The program requires the states,
along with EPA, the National Park Service, U.S. Fish and Wildlife Service, the U.S. Forest
Service, and other agencies to develop and implement air quality protection plans to reduce
the pollution that causes visibility impairment. Under the rule, “old” industrial facilities
(35-50 years old) would be required to install pollution controls to limit emissions if they
contribute toward regional haze.
Haze-forming particles include nitrogen oxides, sulfur dioxides, and particulate matter. Haze
reduces visibility and poses increased risks for respiratory diseases such as asthma. Reduc-
ing haze also may promote local tourism and benefit local economies.
State implementation plans (SIPs) were due in 2007; but in 2009 EPA made a finding that
37 states or territories had failed to submit all or portions of their Regional Haze SIPs.
When EPA still had not demanded the states submit those SIPS by the beginning of 2011,
several environmental groups filed suit against the agency to force it to issue proposed and
final deadlines for those SIPs.
While many states have made significant progress in addressing the complex issues sur-
rounding regional haze, so far, only a few states have achieved final approval of their plans.
However, EPA entered into a consent agreement on December 2, 2011, to require 34 states to
submit their SIPs for approval. The timeline for states to submit their plans ranges from
December 2011 to November 2012. If the states do not get their plans in on time, or if EPA
does not approve them, the Agency will be compelled to issue federal implementation plans
(FIPs) for those states.
Learn about regional haze in your area at epa.gov/visibility/index.html.
Mercury and air toxics standards (MATS) for power plants

On December 21, 2011, EPA announced standards to limit mercury, acid gases, and other
toxic pollution from power plants. Specifically, the rule will reduce emissions from new and
existing coal- and oil-fired electric utility steam generating units (EGUs). In addition, EPA
revised the new source performance standards (NSPS) for fossil-fired EGUs. The NSPS
revises the standards that new coal- and oil-fired power plants must meet for particulate
matter (PM), sulfur dioxide (SO2), and nitrogen oxides (NOx).
The MATs will address emissions of heavy metals, including mercury (Hg), arsenic (As),
chromium (Cr), and nickel (Ni); and acid gases, including hydrochloric acid (HCl) and
hydrofluoric acid (HF). These hazardous air pollutants are known or suspected of causing
cancer and other serious health effects.
Existing sources will have up to four years to comply with the MATS. This includes the
three years provided to all sources by the CAA. EPA believes most, if not all, sources will be
able to comply within the three-year timeframe. State permitting authorities will have the
power to grant an additional year as needed for technology installation.
9/14 Clean air–45

EPA is also providing a pathway for “reliability critical units” to obtain a schedule with up
to one additional year to comply with the MATS. The Agency will work with facilities that
have difficulty complying with the deadlines.
The MATS applies to EGUs larger than 25 megawatts that burn coal or oil for the purpose
of generating electricity for sale and distribution through the national electric grid to the
public. This includes investor-owned units as well as units owned by the federal govern-
ment, municipalities, and cooperatives that provide electricity for commercial, industrial,
and residential uses.
The Agency estimates that there are approximately 1,400 units affected by the MATS (1,100
existing coal-fired units and 300 oil-fired units at about 600 power plants).
The final MATS identifies two subcategories of coal-fired EGUs, four subcategories of oil-
fired EGUs, and a subcategory for units that combust gasified coal or solid oil (integrated
gasification combined cycle (IGCC) units) based on the design, utilization, and/or location of
the various types of boilers at different power plants. The rule includes emission standards
and/or other requirements for each subcategory.
The NSPS will affect EGUs that burn fossil fuel to produce steam. The steam is used to pro-
duce electricity for sale to the grid.
Read more on how to comply with the MATS at epa.gov/airquality/powerplantstoxics/actions.
html.
Help for small businesses

1. EPA Small Business Ombudsman: Call or write the EPA Small Business
Ombudsman for more specific information about the programs under the 1990 Clean
Air Act that affect small businesses. Contact: 202-564-6568 or 800-368-5888.
2. State Small Business Assistance Programs: The 1990 Clean Air Act requires
each State government to develop and implement a Small Business Technical and
Environmental Compliance Assistance Program. These State programs will include
the following components to help small businesses comply with the Act.
3. Business Associations: Contact the small business association or trade group that
represents you for industry-specific details about what your State and local govern-
ments will be doing to implement the Act in your area.
4. EPA Technical Support Centers: Several of EPA’s Technical Support Centers and
telephone hotlines are expanding their services to provide support to State and local
air pollution control agencies as they develop and carry out the small business assis-
tance programs. The EPA Clean Air Technology Center at 919-541-0800 or epa.gov/
ttn/catc will be the starting point for general business assistance questions.
Annual reporting deadlines under the Clean Air Act

The following table lists annual federal reporting deadlines for various programs under the
CAA. Keep in mind that the dates are subject to change and your state may have additional
reporting requirements under the CAA.
46–Clean air 9/14

Annual CAA Reporting Deadlines

Month Date Requirement
January 30 Sources required to install continuous emission monitoring systems
must submit Written Report of Excess Emissions for the preceding
July through Dec.
February 1 Facilities subject to new source performance standards under 40
CFR 60, Subpart AAAA, located within small municipal waste
combustor plants, submit annual and semiannual reports.
14 Producers, importers, exporters of Class II controlled substance
submit report to EPA with info. on the chemicals during the
previous quarter .
28 Renewable fuel producers and importers, gasoline refiners and
importers, and others involved in the RFS2 must submit the annual
compliance report.
March 31 Certain large GHG emitting facilities must submit GHGRP annual
reports. Note: The date is postponed until Sept. 28, 2012, for 12
source categories.
April 22 Existing sources subject to organic HAP emission controls under
40 CFR 63, Subpart H, for equipment leaks from Groups II and IV
chemical process units must submit semiannual reports to EPA.
May 15 Sources subject to national emission standards for HAPs from
pharmaceuticals production under 40 CFR 63, Subpart GGG, must
submit a report on routine maintenance procedures for combustion
control devices.
June 1 Facilities, manufacturers and importers under the RFS2 program
submit Production Outlook Report. Note: Quarterly reports are due
within 2 months of the end of each calendar quarter.
July 26 Existing sources subject to organic HAP emission controls under
40 CFR 63, Subpart PPP, must submit periodic reports to EPA.
30 Sources required to install CEMS submit written report of excess
emissions for the preceding January - June.
August 1 Facilities subject to new source performance standards under 40
CFR 60, Subpart Eb, located within large municipal waste
combustor plants must submit semiannual reports.
14 Each producer, importer, or exporter of a Class II controlled
substance must submit reports to EPA providing information on the
production, import, and export of such chemicals during the
previous quarter.
29 Existing sources that are subject to organic HAP emission controls
under 40 CFR 63, Subpart G, for synthetic organic chemical
manufacturing industry production processes must submit a
quarterly report to EPA.
September 5 Owners or operators of flexible operation units not designed as
elastomer product processing units in accordance with national
emission standards for HAPs for Group I polymers and resins, 40
CFR 63, Subpart U, must perform an annual applicability
determination.
12 Owners/operators of flexible operation units not designed as
thermoplastic product processing units in accordance with national
emission standards for HAPs for Group IV polymers and resins, 40
CFR 63, Subpart JJJ must perform an annual applicability
determination.
October 22 Existing sources subject to organic HAP emission controls under
40 CFR 63, subpart H, for equipment leaks from Groups II and IV
chemical process units must submit a semiannual report to EPA.
9/14 Clean air–47

Annual CAA Reporting Deadlines, Continued

Month Date Requirement
November 14 Each producer, importer, or exporters of a Class II controlled
substance must submit a report to EPA providing information on
the production, import, and export of such chemicals during the
previous quarter.
19 Sources subject to organic HAP emission controls under 40 CFR
63, Subpart G, for synthetic organic chemical manufacturing
industry production processes must submit a semiannual report.
29 Each owner or operator of an existing source subject to the
organic HAP emission controls under 40 CFR 63, Subpart G, for
synthetic organic chemical manufacturing industry production
processes must submit a quarterly report on emission points,
including an emissions average.
Indoor air quality

In the last several years, a growing body of scientific evidence has indicated that the air
within our working environments can be more seriously polluted than the outdoor air, even
in the largest and most industrialized cities. The levels of air pollution from individual
sources may not pose a significant risk to health by themselves, but most working environ-
ments have more than one source that contributes to indoor air pollution.
Poor indoor air quality can lead to a number of well-identified illnesses, including Legion-
naire’s disease, asthma, and humidifier fever. These building-related illnesses are usually
treatable, but often require prolonged recovery times. Other health effects from exposure to
indoor pollutants include irritation of the nose, eyes, and throat, sneezing, stuffy or runny
nose, fatigue, headache, dizziness, nausea, irritability, and forgetfulness.
Causes of indoor air quality problems

The two main causes of indoor air quality problems are indoor pollution sources and
improper ventilation. Common pollutants found in the workplace include tobacco smoke,
asbestos, formaldehyde, cleaning agents, air fresheners, mold, radon, carbon monoxide,
paints, pesticides, and adhesives — just to name a few. Inadequate ventilation can increase
indoor pollutant levels by not bringing in sufficient outside air to dilute emissions from
indoor sources, and by not carrying indoor pollutants outside of the facility. High tempera-
tures and humidity levels can also increase concentrations of certain pollutants.
In addition, poorly located vents can even pull in outdoor air pollutants such as diesel
exhaust, boiler emissions, or fumes from dumpsters. Dirty ventilation systems can harbor
biological indoor air pollutants such as molds, germs, and other contaminants, and they can
circulate dirt and soot throughout the workplace.
Sources of indoor air pollution

Indoor air quality is affected by pollution from inside and outside of buildings and from poor
ventilation. Human metabolic activity, smoking, structural components of the building,
building contents, biological contamination, office and mechanical equipment, and outside air
pollutants that enter the building all contribute to indoor air pollution.
48–Clean air 9/14

Inadequate ventilation
If too little outdoor air enters your facility, pollutants can accumulate to a level that can
pose discomfort and health problems for your employees. Air-tight buildings are especially at
risk.
What you can do: Open windows, run window air conditioning units with the vent control
open, and run outdoor vented fans to increase outdoor air circulation. Be sure to vent areas
where chemical emissions are more likely to build up, such as copy rooms, rest rooms,
chemical storage areas, and print shops.
Chemical contaminants from outdoor sources
The outdoor air that enters a building can be a source of indoor air pollution. Pollutants
from motor vehicle exhausts, building exhausts, and other air contaminants can enter the
building through poorly located intake vents, windows, and other openings. In addition, com-
bustion products can enter a building from a nearby garage. Maintaining positive air
pressure in the building can minimize the intake of contaminated outdoor air also.
What you can do: Be aware of the environment around your building. Relocate vents located
near outdoor pollutant sources such as garages and dumpsters, or relocate the outdoor pol-
lutant sources.
Biological contaminants
Biological contaminants include bacteria, molds, pollen, and viruses that thrive in moist or
wet environments - especially in areas such as ducts, humidifiers, and drain pens, or where
water has collected on ceiling tiles, carpeting, or insulation. Physical symptoms related to
biological contamination include cough, chest tightness, fever, chills, muscle aches, and aller-
gic reactions such as mucus membrane irritation and upper respiratory congestion.
What you can do: Moisture control is the key to keeping biological contaminants at bay.
Wash molds off hard surfaces with a mixture of detergent and water and allow them to dry
completely. Install humidity controls and keep humidity within 30 to 50 percent. Be sure to
dry out water damaged areas as soon as possible - within 24 hours if possible. Fix leaky
plumbing and roofing materials; absorbent materials such as ceiling tiles may have to be
replaced.
Carbon monoxide
This colorless, odorless gas has long been known to be noxious and toxic to humans, yet it
can be difficult to detect. In office buildings, the most common source of carbon monoxide is
outside air sucked into the building’s ventilation system; this is especially possible in down-
town or freeway-adjacent office buildings.
Other frequent sources of carbon monoxide problems include underground garages or load-
ing docks where high levels of carbon monoxide are generated, accumulate, and then can
filter up into offices. Be suspicious of carbon monoxide problems if several employees are
complaining of headaches, dizziness, or other flu-like symptoms, especially during specific
times of the day that coincide with increased external traffic or loading dock activity.
9/14 Clean air–49

What you can do: Never run generators or other gas-powered equipment indoors. Make sure
you have adequate ventilation for vehicle exhaust. Keep all combustion devices such as boil-
ers and furnaces in good working order, and install carbon monoxide detectors throughout
your building.
Formaldehyde
This substance is known to be toxic if ingested and has caused cancer in laboratory rats, but
the problems it causes in buildings stems from synthetic materials in textiles such as
drapes, wall coverings, and other office furnishings. It can also be found in building materi-
als such as urea-formaldehyde foam insulation, particle board, plywood, and adhesives. High
concentrations of formaldehyde can cause watery eyes, burning sensations in the eyes and
throat, nausea, and difficulty breathing, and may trigger asthma attacks in some people.
What you can do: Choose “exterior-grade” pressed wood products over lesser grade ones; they
contain phenol resins, not urea resins. Control temperature and humidity to reduce emis-
sions from fabrics and wood products, and increase ventilation, particularly after bringing in
new sources of formaldehyde.
Nitrogen dioxide (NO2)
Nitrogen dioxide (NO2) is a toxic gas that is both a highly reactive oxidant and a corrosive.
Primary sources of NO2 indoors include combustion processes such as unvented gas stoves,
welding, tobacco smoke, or vented appliances that have been installed incorrectly. NO2 may
cause eye, nose, and throat irritation along with impaired lung function.
What you can do: Vent NO2 sources to the outdoors and make sure all combustion appli-
ances are in good working order. Install and use exhaust fans over gas stoves.
Respirable particles
Respirable particles, or particulate matter (PM), are any substance small enough to be
inhaled into the body, such as dust, soot, or ash. PM can become deposited in the lungs and
cause respiratory infections or bronchitis, along with eye, nose, and throat irritation. PM has
been known to cause cancer. Cigarette smoke can worsen the problem by concentrating PM
in the air and keeping it suspended rather than allowing it to be eliminated through the
ventilation system.
What you can do: Vent all furnaces outdoors. Have trained professionals inspect and, if nec-
essary, clean and tune-up central heating systems annually, and change filters regularly.
Tobacco smoke
While no federal ban on smoking in the workplace exists, many states prohibit the practice.
Secondhand smoke has been shown to cause a variety of health problems, including respira-
tory infections and asthma.
What you can do: Ban smoking in the workplace.
Radon
Radon is a colorless, odorless, radioactive gas produced by the decay of radium. Found in
underground rock formations and groundwater, radium is widespread in the United States.
50–Clean air 9/14

It gets indoors by passing through the soil from underneath buildings or through tap water.
Radon is the second-leading cause of lung cancer in the nation; only smoking ranks higher.
What you can do: Test for radon. If your building is found to have high levels of radon, there
are simple steps you can take to make the air safe to breathe.
Asbestos
This substance is a mineral fiber that was once used widely in building construction as a fire
retardant. The material was also used in many schools, restaurants, and hotels. When prod-
ucts containing asbestos are in good shape, the substance does not pose much of a problem.
However, when those materials fray, chip, or flake, the asbestos fibers can become airborne.
The loose fibers, when inhaled, can cause cancer in the lungs, esophagus, stomach, colon, or
rectum. No level of exposure is considered safe; any exposure involves some health risks.
What you can do: If you suspect your building contains asbestos, be sure to hire a certified
contractor before you do any repairs, remodeling, or demolition. Federal and state laws may
apply to your project.
Volatile organic compounds (VOCs)
Volatile organic compounds (VOCs) are emitted as gases from certain solids or liquids. VOCs
are found in higher concentrations indoors than outdoors and are emitted by a vast array of
products. VOCs are found in paints, lacquers, paint strippers, cleaning supplies, pesticides,
building materials, copiers and printers, correction fluids, and many more items. Health
effects include eye, nose, and throat irritation, headaches, loss of coordination, nausea, kid-
neys and liver damage, central nervous system damage, and possibly cancer.
What you can do: Learn more about the chemicals found in the products around your
building. Choose less toxic options, when available. Be sure to have adequate ventilation
whenever using cleaning products, painting, or performing work using chemicals, and reduce
their use whenever possible. Follow the label instructions carefully and never mix products
unless directed to do so on the label.
Lead
Lead was once commonly used in many products, especially in lead-based paint. Its use was
banned in paint in 1978, but old, lead-based paint is still the number one source of lead
exposure in the U.S. Deteriorating lead paint can become airborne as dust or particles. At
high levels, lead can cause convulsions, coma, and even death. At lower levels, lead can
impair mental and physical development in children.
What you can do: Leave lead-based paint alone if it is in good condition. Use a certified con-
tractor to remove lead paint or when building or remodeling.
Sick building syndrome and building related illness

The term “sick building syndrome” (SBS) emerged in the 1980s to describe situations in
which building occupants experience acute health and comfort effects that appear to be
linked to time spent in a building, but no specific illness or cause can be identified. Some
complaints may be linked to particular rooms or zones, while others were widespread
throughout a building. Symptoms include headaches, eyes, nose, or throat irritation, dry
9/14 Clean air–51

cough, itchy skin, dizziness, nausea, distractibility, fatigue, and sensitivity to odors. Most of
the time, symptoms disappear when the sufferer leaves the building.
Building related illness (BRI), on the other hand, is a term used when a specific illness can
be diagnosed and attributed directly to airborne building contaminants. Symptoms include
cough, chest tightness, fever, chills, and muscle aches. Many times, prolonged recovery time
is necessary even after the sufferer has left the building.
Create an indoor air quality program

An indoor air quality program can identify and correct existing problems and prevent future
problems. It involves completing a comprehensive building assessment and establishing
guidelines along with a reporting system. The effectiveness of your program will depend
upon the support and feedback of all employees.
IAQ Building assessment
An IAQ building assessment will identify sources of indoor air pollution and formulate solu-
tions to the problem. The goal should be to prevent problems from reoccurring and avoid
creating other problems. When you conduct a walkthrough assessment of your building, pay
special attention to the four basic factors that influence air quality:
• Employees;
• Heating and ventilation system (HVAC), paying particular attention to humidity
and temperature;
• Inside contamination such as copy machines, office products, cleaning products, and
other chemicals stored indoors; and
• Outside contaminant sources such as vehicle exhaust from parking garages or load-
ing docks. Take note of air intake placement, wind conditions and other ways
outside air comes into the building.
Other sources to investigate:
• Blueprints of the building
• The history of the building
• Any employee complaints
• Known HVAC concerns
• Areas prone to moisture problems
• New building materials
• Any building use changes
• Condition of outside air dampers
• Condition of the air filtration system
• Any noticeable odors
EPA does not recommend testing or sampling for air contaminants unless a specific contami-
nant is suspected. The agency says contaminant concentrations can be misleading. You may
want to test for radon, however, if you live in an area known to have high concentrations of
the gas.
52–Clean air 9/14

Next steps
Establish a routine for cleaning HVAC systems, maintaining combustion equipment, and
replacing or repairing water-damaged materials. Look for ways to increase ventilation rates
and improve air circulation throughout the building and consider local exhaust ventilation in
areas such as rest rooms, copy rooms, and other areas where chemical concentrations may
build up.
Air cleaners
How well an air cleaner works depends on how well it collects pollutants from indoor air,
and how much air it draws in through the cleaning or filtering element. Keep in mind that
typical furnace filters do not efficiently capture small particles. More expensive, high perfor-
mance filters will capture the particles, but can be prohibitive to install and operate. Also,
mechanical filters do not remove gases. Some absorbent beds will remove gaseous pollutants,
but most devices are expensive and require frequent replacements.
Additional resources
If you suspect a problem with the indoor air quality in your building, there are a variety of
resources to turn to for help.
• Address any health problems with a physician, nurse, or safety and health official.
• Make sure management is aware of the problem.
• Consider hiring a commercial company that conducts building investigations to diag-
nose the problem and to offer solutions.
• Call the National Institute for Occupational Safety and Health (NIOSH) for infor-
mation about obtaining a health hazard evaluation of the working environment.
• Call the state or local health agencies or area air pollution control agency to discuss
the symptoms and possible causes.
9/14 Clean air–53

Reserved
54–Clean air 9/14

CLEAN WATER
CONTENTS
The Clean Water Act........................................................................................... 1

Stormwater ...................................................................................................... 2
Cooling water intake structures....................................................................... 3
Pollution prevention plans (PPPs) .................................................................. 4A
Construction General Permit (CGP) ............................................................... 4B
Pretreatment program ........................................................................................ 5
Who’s the authority? ..................................................................................... 6
How it works .............................................................................................. 6
Industrial user defined .................................................................................. 6
Pretreatment defined .................................................................................... 7
Two sets of standards.................................................................................... 7
Wetlands and section 404 permitting ...................................................................... 8
Total maximum daily loads (TMDLs) and watershed management................................. 8
Water quality planning and management .......................................................... 9
TMDLs and stormwater ................................................................................ 9
Oil pollution.................................................................................................... 10
Spill Prevention, Control, and Countermeasures (SPCC)...................................... 10
Facility Response Plans (FRP) ..................................................................... 14B
Safe Drinking Water Act .................................................................................... 16
Drinking Water Strategy .............................................................................. 16
National primary drinking water regulations (NPDWRs) ..................................... 17
National secondary drinking water regulations.................................................. 19
Underground Injection Control Program .......................................................... 19
Further resources ....................................................................................... 20
Audit Checklists............................................................................................... 20
Vehicle maintenance stormwater pollutants checklist .......................................... 20
Clean water NPDES permits audit checklist ..................................................... 22
NPDES permit application checklist ............................................................... 24
SPCC written plan audit checklist.................................................................. 25
9/14 Clean water TOC–1

Reserved
2–Clean water TOC 9/14

The Clean Water Act

The Clean Water Act (CWA) is the primary federal law in the United States governing water
pollution. The objective of the CWA is to restore and maintain the chemical, physical, and
biological integrity of the nation’s surface waters.
Pollutants regulated under the CWA are classified as either:

• “Toxic” pollutants;
• “Conventional” pollutants, such as biochemical oxygen demand (BOD), total sus-
pended solids (TSS), fecal coliform, oil and grease, and pH; or
• “Non-conventional” pollutants, including any pollutant not identified as either con-
ventional or priority.
The CWA regulates both direct and “indirect” dischargers (those who discharge to publicly
owned treatment works). The National Pollutant Discharge Elimination System (NPDES)
permitting program controls direct discharges into navigable waters. Direct discharges or
“point source” discharges are from sources such as pipes and sewers. NPDES permits, issued
by either EPA or an authorized state (EPA has authorized many states and territories to
administer the NPDES program), contain industry-specific, technology-based and water
quality-based limits and establish pollutant monitoring and reporting requirements.
A facility that proposes to discharge into the nation’s waters must obtain a permit prior to
initiating a discharge. A permit applicant must provide quantitative analytical data identify-
ing the types of pollutants present in the facility’s effluent. The permit will then set forth
the conditions and effluent limitations under which a facility may make a discharge.
3/12 Clean water–1

Stormwater
In 1987, the CWA was amended to require EPA to establish a program to address
stormwater discharges. In response, EPA promulgated NPDES permitting regulations for
stormwater discharges. These regulations require that facilities with the following types of
stormwater discharges, among others, apply for an NPDES permit:
1. A discharge associated with industrial activity;
2. A discharge from a large or medium municipal storm sewer system; or
3. A discharge which EPA or the state determines to contribute to a violation of a
water quality standard or is a significant contributor of pollutants to waters of the
United States.
The term “stormwater discharge associated with industrial activity” means a stormwater
discharge from one of 11 categories of industrial activity defined at 40 CFR 122.26. Six of
the categories are defined by SIC codes while the other five are identified through narrative
descriptions of the regulated industrial activity.
If the primary SIC code of the facility is one of those identified in the regulations, the facil-
ity is subject to the stormwater permit application requirements. If any activity at a facility
is covered by one of the five narrative categories, stormwater discharges from those areas
where the activities occur are subject to stormwater discharge permit application
requirements.
Those facilities/activities that are subject to stormwater discharge permit application

requirements are:
• Facilities subject to stormwater effluent limitations guidelines, new source perfor-
mance standards, or toxic pollutant effluent standards;
• Facilities classified as SIC 24-lumber and wood products (except wood kitchen cabi-
nets); SIC 26-paper and allied products (except paperboard containers and
products); SIC 28-chemicals and allied products (except drugs and paints);SIC
29-petroleum refining; SIC 311-leather tanning and finishing; SIC 32 (except 323)-
stone, clay, glass, and concrete; SIC 33-primary metals; SIC 3441-fabricated
structural metal; and SIC 373-ship and boat building and repairing;
• Facilities classified as Standard Industrial Classifications 10 through 14 (mineral
industry) including active or inactive mining operations (except for areas of coal
mining operations no longer meeting the definition of a reclamation area under 40
CFR 434.11(1) because the performance bond issued to the facility by the appropri-
ate authority has been released, or except for areas of non-coal mining operations
which have been released from applicable State or Federal reclamation require-
ments after December 17, 1990) and oil and gas exploration, production, processing,
or treatment operations, or transmission facilities that discharge stormwater con-
taminated by contact with or that has come into contact with, any overburden, raw
material, intermediate products, finished products, byproducts or waste products
located on the site of such operations; (inactive mining operations are mining sites
that are not being actively mined, but which have an identifiable owner/operator;
inactive mining sites do not include sites where mining claims are being maintained
prior to disturbances associated with the extraction, beneficiation, or processing of
mined materials, nor sites where minimal activities are undertaken for the sole pur-
pose of maintaining a mining claim);
2–Clean water 3/12

• Hazardous waste treatment, storage, or disposal facilities;

• Landfills, land application sites, and open dumps that receive or have received any
industrial wastes;
• Facilities involved in the recycling of materials, including metal scrap yards, battery
reclaimers, salvage yards, and automobile junkyards, including but limited to those
classified as Standard Industrial Classification 5015 and 5093;
• Steam electric power generating facilities, including coal handling sites;
• Facilities classified as SIC 40-railroad transportation; SIC 41-local passenger trans-
portation; SIC 42-trucking and warehousing (except public warehousing and
storage); SIC 43-U.S. Postal Service; SIC 44-water transportation; SIC
45-transportation by air; and SIC 5171-petroleum bulk storage stations and termi-
nals which have vehicle maintenance shops, equipment cleaning operations, or
airport deicing operations;
• Treatment works treating domestic sewage or any other sewage sludge or wastewa-
ter treatment device or system, used in the storage treatment, recycling, and
reclamation of municipal or domestic sewage;
• Construction activity including clearing, grading and excavation, except operations
that result in the disturbance of less than five acres of total land area. Construction
activity also includes the disturbance of less than five acres of total land area that is
a part of a larger common plan of development or sale if the larger common plan
will ultimately disturb five acres or more;
• Facilities classified as SIC 20-food and kindred products; SIC 21-tobacco products;
SIC 22-textile mill products; SIC 23-apparel related products; SIC2434-wood kitchen
cabinets manufacturing; SIC 25-furniture and fixtures; SIC265-paperboard contain-
ers and boxes; SIC267-converted paper and paperboard products; SIC 27-printing,
publishing, and allied industries; SIC 283-drugs; SIC 285-paints, varnishes, lacquer,
enamels, and allied products; SIC 30-rubber and plastics; SIC 31-leather and leather
products (except leather and tanning and finishing); SIC 323-glass products; SIC
34-fabricated metal products (except fabricated structural metal); SIC 35-industrial
and commercial machinery and computer equipment; SIC 36-electronic and other
electrical equipment and components; SIC 37-transportation equipment (except ship
and boat building and repairing); SIC 38-measuring, analyzing, and controlling
instruments; SIC 39-miscellaneous manufacturing industries; and SIC 4221-4225-
public warehousing and storage.
To determine whether a particular facility falls within one of these categories, consult the
regulations at 40 CFR Part 122. (Find them using the e-CFR at ecfr.gpoaccess.gov/)
Cooling water intake structures

On August 15, 2014, EPA finalized regulations applying to cooling water intake structures at
existing facilities. Effective October 14, 2014, the rules apply to existing facilities that use
cooling water intake structures to withdraw water from waters of the United States and
have or require an NPDES (National Pollutant Discharge Elimination System) permit
issued under section 402 of the Clean Water Act.
Existing facilities subject to this regulation include those with a design intake flow greater
than 2 million gallons per day (mgd) and use at least 25 percent of the water they withdraw
exclusively for cooling purposes. Facilities that required NPDES permits, but do not meet

the 2 mgd intake flow threshold must check with their permitting authority to see if the new
rules apply to them.
The term cooing water intake structure means the total physical structure and any associ-
ated constructed waterways used to withdraw cooling water from waters of the U.S. The
cooling water intake structure extends from the point at which water is first withdrawn
from the waters of the U.S. source up to, and including, the intake pumps.
Generally, facilities that meet these criteria fall into two major groups: steam electric gener-
ating facilities and manufacturing facilities. The final rule also makes limited changes to the
requirements for new facilities.
Purpose of the rule
Section 316(b) of the Clean Water Act requires that NPDES permits for facilities with cool-
ing water intake structures ensure that the location, design, construction, and capacity of
the structures reflect the best technology available to minimize harmful impacts on the
environment. The concern is that the withdrawal of cooling water removes billions of aquatic
organisms from waters of the U.S. each year, including fish, larvae and eggs, crustaceans,
shellfish, sea turtles, marine mammals and other aquatic life. Most impacts are to early life
stages of fish and shellfish through impingement (being pinned against cooling water intake
structures) and entrainment (being drawn into cooling water systems and affected by heat,
chemicals or physical stress).
The final rule is meant to reduce impingement and entrainment of fish and other aquatic
organisms at cooling water intake structures. The regulations affected are at 40 CFR Parts
122 and 125.
Three main components
The three main components of the new rule are:

1. All affected facilities must reduce fish impingement. They may choose from one of
seven options for meeting best technology available requirements.
2. Existing facilities that withdraw at least 125 million gallons per day are required to
conduct studies to help their permitting authority determine whether and what site-
specific controls, if any, would be required to reduce entrainment. This decision
process would include public input.
3. New units that add electrical generation capacity at an existing facility must also
add technology that achieves one of two alternatives under national standards for
entrainment for new units at existing facilities. Under the first alternative new unit
entrainment standard, the owner or operator of a facility must reduce actual intake
flow at the new unit, at a minimum, to a level that can be attained by the use of a
closed-cycle recirculating system. Under the second alternative new units entrain-
ment standard, the owner or operator of a facility must demonstrate that it has
installed, and will operate and maintain, technological or other control measures for
each intake at the new unit that achieves a prescribed reduction in entrainment
mortality of all stages of fish and shellfish that pass through a sieve with a maxi-
mum opening dimension of 0.56 inches.
For more information, visit water.epa.gov/lawsregs/lawsguidance/cwa/316b/.

Pollution prevention plans (PPPs)

Companies and municipalities who must file general stormwater permits must complete and
implement stormwater pollution prevention plans. Although the plans need not be submitted
to EPA, they must be on file, and on request be given to an EPA inspector.
Baseline pollution prevention plans have two major objectives. They must: 1) identify poten-
tial sources of pollution; and 2) describe and ensure practices to reduce pollutants in
stormwater discharges. These objectives can be broken down as follows:
Source Identification Information Plans

Source Identification Information Plans must include the following information to assist in
evaluating pollutant sources:
1. Site drainage map.
2. Estimate of the area of impervious surfaces, and the total area drained by each
outfall.
3. Narrative description of specified features that may impact the pollution potential of
a discharge.
4. List of significant spills and leaks of toxic or hazardous pollutants that occurred at
the facility after the effective date of the permit.
5. Prediction of the direction of flow, and an estimate of the types of pollutants that
may be present in stormwater discharges associated with industrial activity, predic-
tion of the direction, rate of flow and total quantity of pollutants that may be
present in stormwater discharges associated with industrial activity.
6. Summary of existing sampling data describing pollutants in stormwater discharges.
Best Management Practices and Program Elements to Reduce Pollutants

Best Management Practices and Program Elements to Reduce Pollutants, at a minimum,
must provide information regarding:
1. Pollution prevention committee,
2. Risk identification and assessment/material inventory,
3. Preventive maintenance,
4. Good housekeeping,
5. Spill prevention and response procedures,
6. Traditional stormwater management,
7. Sediment and erosion prevention,
8. Employee training,
9. Visual inspections,
10. Record keeping and internal reporting procedures, and
11. Certification that stormwater discharges have been tested for the presence of non-
stormwater pollution sources.
EPA’s NPDES Stormwater discharges from industrial facilities webpage at cfpub.epa.gov/
npdes/stormwater/indust.cfm can give you more information on the general permitting
9/14 Clean water–4A

process. You’ll also find links to EPA’s Industrial stormwater permit guide and industrial sec-
tor fact sheets. Also, be sure to contact your state stormwater or NPDES program for specific
permitting requirements for your location.
Construction General Permit (CGP)

Stormwater discharges from construction activities that disturb one or more acres, or
smaller sites that are part of a larger common plan of development or sale, are also regu-
lated under the NPDES stormwater program. Before any stormwater can leave the site,
4B–Clean water 9/14

construction operators must obtain coverage under a NPDES permit. This permit will either
be administered by the state, or by EPA, depending upon where the site is located.
Where EPA is the permitting authority, construction stormwater discharges are almost
always permitted under the Construction General Permit (CGP). The CGP requires compli-
ance with effluent limits and other permit requirements, such as the development of a
stormwater pollution prevention plan (SWPPP). Construction operators intending to seek
coverage under the CGP must submit a Notice of Intent (NOI) certifying that they have met
the permit’s eligibility conditions and that they will comply with the permit’s effluent limits
and other requirements. You can use EPA’s eNOI system (cfpub.epa.gov/npdes/stormwater/
cgpenoi.cfm) to submit your NOIs.
On February 16, 2012, EPA issued the final 2012 CGP. The 2012 CGP replaces the 2008
CGP (which expired on February 15, 2012), and provides coverage for eligible new and exist-
ing construction projects for a period of five years. You can read the 2012 CGP at epa.gov/
npdes/pubs/cgp2012_finalpermit.pdf.
The 2012 CGP includes new Effluent Limitations Guidelines and New Source Performance
Standards for Construction and Development point sources, known as the “C&D rule.” The
C&D rule requires construction site operators to meet restrictions on erosion and sediment
control, pollution prevention, and stabilization.
Coverage under the 2012 CGP will be available for eligible construction activities in the fol-
lowing areas:
• Idaho, Massachusetts, New Hampshire, New Mexico, District of Columbia;
• American Samoa, Guam, Johnston Atoll, Midway and Wake Islands, North Mariana
Islands, Puerto Rico;
• Indian Country lands within Alaska, Arizona, California, Colorado, Connecticut,
Idaho, Iowa, Kansas, Louisiana, Massachusetts, Michigan, Minnesota, Montana,
Nebraska, Nevada, New Mexico, New York, North Dakota, Oklahoma, Oregon,
Rhode Island, South Dakota, Texas, Utah, Vermont, Washington, Wisconsin,
Wyoming;
• Areas within Colorado, Delaware, Vermont, Washington subject to construction by
Federal Operators;
• Limited areas of Oklahoma and Texas.
Construction SWPPP template

EPA released a sample template to help you develop your construction SWPPP. The template
is designed to help you meet the minimum requirements of EPA’s 2012 CGP and is
customizable to specific sites and projects. Find the template and other useful NPDES infor-
mation at cfpub.epa.gov/npdes/stormwater/swppp.cfm.
Pretreatment program
Another type of discharge that is regulated by the CWA is one that goes to a publicly owned
treatment works (POTWs). The national pretreatment program (CWA section 307(b)) con-
trols the indirect discharge of pollutants to POTWs by “industrial users.” Facilities regulated
under section 307(b) must meet certain pretreatment standards.

The regulations establish responsibilities of government, industry, and the public to imple-
ment pretreatment standards to control pollutants from the industrial users which may pass
through or interfere with POTW treatment processes or contaminate sewage sludge.
EPA has developed technology-based standards for industrial users of POTWs. Different
standards apply to existing and new sources within each category. EPA has also developed
“Categorical” pretreatment standards applicable to an industry on a nationwide basis. In
addition, POTWs develop their own “local limits,” to assist in achieving the effluent limita-
tions in their permits.
Regardless of whether a state is authorized to implement either the NPDES or the pretreat-
ment program, if it develops its own program, it may enforce requirements more stringent
than federal standards.
Who’s the authority?

The pretreatment program places the majority of the responsibility on local municipalities.
All large POTWs (i.e., those designed to treat flows of more than five million gallons per
day) and smaller POTWs with significant industrial discharges establish local pretreatment
programs.
These local programs enforce all national pretreatment standards and requirements in addi-
tion to any more stringent local requirements necessary to protect site-specific conditions at
the POTW.
How it works
To ensure compliance with pretreatment requirements, POTWs:
• Identify and locate all industrial users (IUs) subject to the pretreatment program;
• Identify the character and volume of pollutants contributed by such users;
• Notify users of applicable pretreatment standards and requirements;
• Receive and analyze reports from IUs;
• Sample and analyze IU discharges and evaluate the need for IU slug control plans;
• Investigate instances of noncompliance; and
• Comply with public participation requirements.
Industrial user defined

The General Pretreatment Regulations apply to all non-domestic sources which introduce
pollutants into a POTW. These sources are more commonly referred to as industrial users
(IUs).
IUs can be as simple as an unmanned coin operated car wash or as complex as an automo-
bile manufacturing plant or a synthetic organic chemical producer.

Pretreatment defined
The term “pretreatment” refers to the requirement that non-domestic sources discharging
wastewater to POTWs control their discharges and meet limits on the amount of pollutants
allowed to be discharged.
The control of the pollutants may necessitate treatment prior to discharge to the POTW
(therefore the term “pretreatment”).
Limits may be met by the non-domestic source through:

• Pollution prevention techniques (product substitution recycle and reuse of materi-
als); or
• Treatment of the wastewater.
Two sets of standards

There are two sets of standards: categorical pretreatment standards and prohibited dis-
charge standards. These uniform national requirements restrict the level of pollutants that
may be discharged by non-domestic sources to sanitary sewer systems.
Categorical pretreatment standards are limits on pollutant discharges to POTWs that apply
to specified process wastewaters of particular industrial categories. These are found in the
regulations at 40 CFR 403.6 and 40 CFR Parts 405-471.
Prohibited discharge standards prohibit the discharge of wastes that pass through or inter-
fere with POTW operations (including sludge management). These are the general
prohibitions. There are also specific prohibitions that prohibit the discharge, from all non-
domestic sources, certain types of wastes that:
• Create a fire or explosion hazard in the collection system or treatment plant;
• Are corrosive , including any discharge with a pH less than 5.0, unless the POTW is
specifically designed to handle such wastes;
• Are solid or viscous pollutants in amounts that will obstruct the flow in the collec-
tion system and treatment plant, resulting in interference with operations;
• Contain any pollutant discharged in quantities sufficient to interfere with POTW
operations; and
• Have temperatures above 104°F when they reach the treatment plant, or are hot
enough to interfere with biological processes.
These standards are found in 40 CFR 403.5.
In addition to the national standards, local limits are developed for pollutants [e.g. metals,
cyanide, BOD5 (5-day biochemical oxygen demand), total suspended solids, oil and grease,
organics] that may cause interference, pass through, sludge contamination, and/or worker
health and safety problems if discharged in excess of the receiving treatment plant’s capa-
bilities and/or receiving water quality standards.
If your facility qualifies as an industrial user, it’s your responsibility to comply with appli-
cable pretreatment standards and reporting requirements set by your local program.
Demonstration of compliance requires certain IUs to submit reports, self monitor, and main-
tain records.

Wetlands and section 404 permitting

Wetlands, commonly called swamps, marshes, fens, bogs, vernal pools, playas, and prairie
potholes, are a subset of “waters of the United States,” as defined in section 404 of the CWA.
The placement of dredge and fill material into wetlands and other water bodies (i.e., waters
of the United States) is regulated by the United States Army Corps of Engineers (Corps)
under 33 CFR Part 328. The Corps regulates wetlands by administering the CWA section
404 permit program for activities that impact wetlands.
EPA’s authority under section 404 includes veto power of Corps permits, authority to inter-
pret statutory exemptions and jurisdiction, enforcement actions, and delegating the section
404 program to the states.
On February 21, 2012, the Corps published a notice in the Federal Register announcing the
reissuance of all existing nationwide permits (NWPs), general conditions, and definitions
with some modifications. The Corps also issued two new NWPs, three new general condi-
tions, and three new definitions. The NWPs will be effective on March 19, 2012, and will
expire on March 18, 2017.
For more information on complying with wetlands permitting: www.spn.usace.army.mil/

regulatory/nwp.html.
Total maximum daily loads (TMDLs) and watershed management

A watershed is a large drainage area that empties into a common waterway such as a
stream, lake, estuary, wetland, bay, or even the ocean. EPA says watershed management is
the best approach to restore the nation’s waters to “fishable, swimmable” condition. Clean
Water Act section 1313 addresses waters that do not meet the national goal of being fishable
or swimmable, despite the fact that required levels of pollution control technology have been
implemented by many pollution sources.

Section 303(d) of the CWA requires states to identify impaired waters and develop total
maximum daily loads (TMDLs) for the affected watersheds. These polluted waters do not
meet the water quality standards set by the states. TMDL is a calculation of the maximum
amount of a pollutant that a waterbody can receive and still safely meet water quality
standards.
Localities and individual sources are affected by an area’s TMDL. They must work together
to meet the watershed’s limits for pollutants and other impurities. Examples of items that
may be covered by a TMDL include:
• Pathogens
• Nutrients
• Sediment
• Mercury
• Metals
• Dissolved oxygen
• Temperature
• pH
• Pesticides
• Other organics
Water quality planning and management

The regulations governing the TMDL program are found at 40 CFR 130.7. Once a state has
identified its impaired waters, it must:
• Set up its TMDLs;
• Set priorities for developing the loads;
• Establish loads for segments identified, including water quality monitoring, model-
ing, data analysis, calculation methods, and the list of pollutants to be regulated;
• Submit the list of segments identified, priority ranking, and loads established to
EPA for approval;
• Incorporate the approved loads in to the state’s water quality management plans
and NPDES permits;
• Involve the public, affected dischargers, designated area-wide agencies, and local
governments in the process; and
• Describe the process in its State Continuing Planning Process.
TMDLs and stormwater

Across the nation, many waterbodies are listed as impaired because of pollutants found in
stormwater. These pollutants include sediment, pathogens, nutrients, and metals. The
impaired waters call for a TMDL to identify the total pollutant load the waterbody can
handle before it cannot meet its water quality standards. Stormwater TMDLs are imple-
mented through the NPDES stormwater permitting system. The program covers most
municipalities and even most construction activities.

Watersheds are affected by construction activities because land development coverts natural
areas into “impervious cover.” Blacktopped parking lots, buildings, streets, and other imper-
vious surfaces prevent water from soaking into the ground or being taken up by plants. The
more impervious cover an area has, the more stormwater runoff will find its way into nearby
waterbodies. The increase in volume and rate of runoff can erode stream channels and
transport more pollutants into streams, lakes, and other bodies of water. Construction com-
panies must meet specific effluent limits for stormwater runoff in their NPDES permits.
Currently, EPA is working on setting stricter effluent limits for companies to acquire these
permits.
Find out more about TMDLs, including a national listing of impaired waters, at water.epa.
gov/lawsregs/lawsguidance/cwa/tmdl/.
Oil pollution
Section 311(b) of the CWA prohibits the discharge of oil, in such quantities as may be harm-
ful, into the navigable waters of the United States and adjoining shorelines. The EPA
Discharge of Oil regulation, 40 CFR Part 110, provides information regarding these
discharges.
Spill Prevention, Control, and Countermeasures (SPCC)

One of the cornerstones of EPA’s strategy to prevent oil spills from reaching our nation’s
waters is the Spill Prevention, Control, and Countermeasures (SPCC) rule. SPCC, found in
the Oil Pollution Prevention regulation at 40 CFR Part 112, requires regulated facilities to
prepare and implement spill prevention and control measures. This ensures that facilities
have containment and other countermeasures in place to prevent oil spills from reaching
navigable waters or adjoining shorelines.
Who is regulated?
Before a facility is subject to the SPCC rule, it must meet three criteria:
1. It must be non-transportation-related;
2. It must have an aggregate aboveground storage capacity greater than 1,320 gal-
lons or a completely buried storage capacity greater than 42,000 gallons; AND
3. There must be a reasonable expectation of a discharge into or upon navigable
water of the U.S. of adjoining shorelines.
However, even if a facility meets all the above applicability criteria, it may be exempt if it
meets any one of the many exceptions listed at 40 CFR 112.1(d).
Calculating capacity
A facility may be subject to SPCC rule if it has at least one of the following oil storage
capacities:
• Total aboveground oil storage capacity greater than 1,320 gallons, or
• Completely buried oil storage capacity greater than 42,000 gallons.
The regulations apply specifically to a facility’s storage capacity, regardless of whether the
tank(s) is completely filled.

When calculating oil storage capacity, do not count:

• Containers with less than 55 gallons capacity;
• Completely buried tanks that are subject to all of the technical requirements of the
Underground Storage Tank (UST) regulation (40 CFR Part 280) or all of the techni-
cal requirements of a state UST program approved under 40 CFR Part 281;
• Containers that are permanently closed as defined in 40 CFR Part 112.2;
• Parts of the facility used exclusively for wastewater treatment and not used to sat-
isfy any requirement of 40 CFR Part 112. (The production, recovery, or recycling of
oil is not considered wastewater treatment);
• Any underground oil storage tanks deferred under 40 CFR Part 280 that supply
emergency diesel generators at a nuclear power generation facility licensed by the
Nuclear Regulatory Commission and subject to any Nuclear Regulatory Commission
provision regarding design and quality criteria, including, but not limited to, 10
CFR Part 50 (such emergency generator tanks must be marked on the facility dia-
gram as provided in §112.7(a)(3), if the facility is otherwise subject to 40 CFR 112);
• Intra-facility gathering lines subject to the regulatory requirements of 49 CFR 192
or 195, except that such a line’s location must be identified and marked as “exempt”
on the facility diagram as provided in §112.7(a)(3), if the facility is otherwise subject
to 40 CFR 112;
• The capacity of a “motive power container” as defined in §112.2 (the transfer of fuel
or other oil into a motive power container at an otherwise regulated facility is not
eligible for this exemption);
• Hot-mix asphalt or any hot-mix asphalt container;
• Containers for heating oil used solely at a single-family residence;
• Pesticide application equipment and related mix containers;
• Any offshore oil drilling, production, or workover facility that is subject to the
notices and regulations of the Minerals Management Service, as specified in the
Memorandum of Understanding between the Secretary of Transportation, the Secre-
tary of the Interior, and the Administrator of EPA, dated November 8, 1993 (see 40
CFR 112 Appendix B).
What is oil?
The term oil means oil of any kind or in any form, including, but not limited to:
• Petroleum;
• Fats, oils, or greases of animal, fish, or marine mammal origin;
• Vegetable oils, including oil from seeds, nuts, fruits, or kernels; and
• Other oils and greases, including synthetic oils and mineral oils.
Petroleum
Petroleum oils include:
• Crude and refined petroleum products,
• Asphalt,
• Gasoline,

• Fuel oils,
• Mineral oils,
• Naphtha,
• Sludge,
• Oil refuse, and
• Oil mixed with wastes other than dredged spoil.
Hazardous substances and hazardous waste

The definition of oil includes “oil mixed with wastes other than dredged spoil.” Oils covered
under the SPCC rule include certain hazardous substances or hazardous wastes that are
mixed with oil, as well as certain hazardous substances or hazardous wastes that are them-
selves oils.
Containers storing these substances may also be covered by other regulations, such as the
Resource Conservation and Recovery Act (RCRA), or the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA), also known as Superfund.
Hazardous substances that are neither oils nor mixed with oils are not subject to SPCC rule
requirements.
Natural gas
Natural gas (including liquid natural gas and liquid petroleum gas) is not considered an oil.
EPA does not consider highly volatile liquids that volatilize on contact with air or water,
such as liquid natural gas or liquid petroleum gas, to be oil.
Petroleum distillate or oil that is produced by natural gas wells and stored at atmospheric
pressure and temperature (commonly referred to as condensate or drip gas), however, is con-
sidered an oil.
Non-transportation-related facilities
A non-transportation-related facility (including all equipment and appurtenances) may
include but is not limited to:
• Fixed onshore and offshore oil well drilling facilities;
• Mobile onshore and offshore oil well drilling platforms, barges, trucks, or other
mobile facilities when in a fixed position;
• Fixed onshore and offshore oil production structures, platforms, derricks, and rigs
(including separators and storage facilities);
• Mobile onshore and offshore oil production facilities (including separators and stor-
age facilities);
• Oil refining or storage facilities;
• Industrial, commercial, agricultural, or public facilities using or storing oil;
• Certain waste treatment facilities;
• Loading racks, transfer hoses, loading arms, and other equipment appurtenant to a
non-transportation related facility;

• Highway vehicles and railroad cars used to transport oil exclusively within the con-
fines of a non-transportation related facility; and
• Pipeline systems used to transport oil exclusively within the confines of a non-
transportation-related facility.
Bulk oil storage

SPCC recognizes that oil is sometimes stored in bulk and sometimes used operationally. A
bulk storage container is any container storing oil at a facility. Bulk oil storage containers
may include, but are not limited to tanks, containers, drums, and mobile or portable totes.
Operational use includes oil-filled electrical equipment and manufacturing equipment.
Operational use of oil is not subject to the rule’s bulk storage requirements. The shell capac-
ity of the container (maximum volume) must be considered and not the actual amount of
product stored in the container (operational volume).
Bulk Storage Container Inspection

The rule requires inspections of bulk storage containers to detect oil leaks, spills, or other
potential integrity or structural issue before they can result in discharge of oil to navigable
waters of the U.S. or adjoining shorelines. Regularly scheduled inspections, evaluations, and
testing of bulk oil storage containers by qualified personnel are critical parts of discharge
prevention.
A container integrity inspection and/or testing program may involve one or more of the fol-
lowing: an external visual inspection of containers, foundations, and supports; non-
destructive testing (examination) to evaluate integrity of certain containers; and additional
evaluations, as needed, to assess the containers’ fitness for continued service. The type of
inspection program and its scope will depend on site specific conditions and the application
of good engineering practices and this can be accomplished by following applicable industry
standards. Find a bulk storage container checklist at epa.gov/oem/docs/oil/spcc/integrity-
testing-factsheet.pdf.
Discharge
Determining if your facility could reasonably discharge oil into or upon navigable waters or
adjoining shorelines is based solely upon the location of your facility.
The location of the facility must be considered in relation to streams, ponds, and ditches
(perennial or intermittent), storm or sanitary sewers, wetlands, mudflats, sandflats, or other
navigable waters.
The distance to navigable waters, volume of material stored, worst-case weather conditions,
drainage patterns, land contours, soil conditions, etc., must also be taken into account.
In addition, according to the rule, this determination may NOT include consideration of
man-made features such as dikes, equipment, or other structures which may serve to
restrain, hinder, contain, or prevent an oil discharge.

The SPCC Plan

If your facility is covered by the Spill Prevention, Control, and Countermeasure (SPCC) rule,
you must prepare and implement an SPCC Plan.
An SPCC Plan is a detailed, facility-specific, written description of how a facility’s operations
comply with the prevention guidelines in the Oil Pollution Prevention regulation. While
unique to the facility it covers, it must include certain elements as outlined in 40 CFR 112.7.
Three areas which should be addressed in the Plan are:
1. Operating procedures the facility implements to prevent oil spills;
2. Control measures installed to prevent oil from entering navigable waters or
ad-joining shorelines; and
3. Countermeasures to contain, cleanup, and mitigate the effects of an oil spill that has
an impact on navigable waters or adjoining shorelines.
Each SPCC Plan must be unique to the facility. Development of a unique SPCC Plan
requires detailed knowledge of the facility and the potential effects of any oil spill. Each
Plan, while unique to the facility it covers, must include certain standard elements to ensure
compliance with the regulations. These elements include:
• A description of the physical layout and a facility diagram.
• Contact list and phone numbers for the facility response coordinator, National
Response Center, cleanup contractors, and all appropriate federal, state, and local
agencies who must be contacted in case of a discharge.
• A prediction of the direction, rate of flow, and total quantity of oil that could be dis-
charged where experience indicates a potential for equipment failure.
• A description of containment and/or diversionary structures or equipment to prevent
discharged oil from reaching navigable waters. (For on-shore facilities, one of the
following must be used at a minimum: dikes, berms, or retaining walls; curbing; cul-
verts, gutters, or other drainage systems; weirs, booms, or other barriers; spill
diversion ponds; retention ponds; sorbent materials.)
• Where appropriate, a demonstration that containment and/or diversionary struc-
tures or equipment are not practical; periodic integrity and leak testing of bulk
containers and associated valves and piping; oil spill contingency plan; and a writ-
ten commitment of manpower, equipment, and materials to quickly control and
remove spilled oil.

• A complete discussion of the spill prevention and control measures applicable to the
facility and/or its operations.
A copy of the entire SPCC Plan must be maintained at the facility if it’s normally attended
for at least four hours per day. Otherwise, a copy must be kept at the nearest field office.
The SPCC Plan must be available to EPA for on-site review and inspection during normal
working hours.
Who prepares the SPCC Plan?

Preparation of the SPCC Plan is the responsibility of the facility owner or operator, but in
most cases it must be certified by a licensed Professional Engineer. By certifying the SPCC
Plan, the Professional Engineer, having examined the facility, attests that:
1. He or she is familiar with the requirements of Part 112;
2. He or she (or a designated agent) has visited and examined the facility;
3. The Plan has been prepared in accordance with good engineering practices, includ-
ing consideration of applicable industry standards, and with the requirements of
Part 112;
4. Procedures for required inspections and testing have been established; and
5. The Plan is adequate for the facility.
EPA compliance
To ensure that facilities comply with the spill prevention regulations, EPA periodically con-
ducts onsite facility inspections. EPA also requires that facilities submit their SPCC Plans
for review after having two discharges (over 42 gallons) in any 12-month period.
Compliance dates
In June 2009, EPA amended the dates by which facilities and farms must prepare or amend
SPCC Plans, and implement those Plans. These amendments became effective on Novem-
ber 10, 2010. The compliance dates for implementing the required changes are as follows:
A facility, including a mobile or portable

facility, starting operation . . . Must:
On or before Aug. 16, 2002 Maintain its existing SPCC Plan. Amend and implement the revised
Plan no later than Nov. 10, 2011.
After Aug. 16, 2002 through Nov. 10, 2011 Prepare and implement an SPCC Plan by Nov. 10, 2011.
After Nov. 10, 2011 (excluding production Prepare and implement an SPCC Plan before beginning operations.
facilities)
After Nov. 10, 2011 (production facilities) Prepare and implement an SPCC Plan within six months after
beginning operations.
Because some oil fields face variability in oil reservoir conditions, EPA finalized an amend-
ment on December 5, 2008, to allow new oil production facilities to operate as follows:
3/13 Clean water–14A

A drilling, production or workover facility, including a

mobile or portable facility, located offshore or with an
offshore component; or an onshore facility that is Must:
required to have and submit FRPs starting operation
...
On or before Aug.16, 2002 Maintain its existing SPCC plan. Amend and implement
the revised SPCC Plan no later than Nov. 10, 2010.
After Aug. 16, 2002 through Nov. 10, 2010 Prepare and implement an SPCC plan no later than Nov.
10, 2010.
After Nov. 10, 2010 (excluding production facilities) Prepare and implement an SPCC Plan before beginning
operations.
After Nov. 10, 2010 (production facilities) Prepare and implement an SPCC Plan within six months
after beginning operations.
A note on farms: On October 18, 2011, EPA amended the date by which farms must prepare
or amend and implement their SPCC Plans to May 10, 2013. The final rule does not remove
the regulatory requirement for owners or operators of farms in operation before August 16,
2002, to maintain and continue implementing an SPCC Plan in accordance with the SPCC
regulations then in effect. Such farms continue to be required to maintain plans during the
interim until the applicable compliance date for amending and implementing the amended
Plans. Finally, the final rule does not relieve farms from any other applicable environmental
regulations or requirements.
A farm starting operation... Must...

On or before Aug. 16, 2002 Maintain its existing SPCC Plan Amend and implement
the amended SPCC Plan no later than May 10, 2013.
After Aug. 16, 2002, through May 10, 2013 Prepare and implement an SPCC Plan no later than
May 10, 2013.
After May 10, 2013 Prepare and implement an SPCC Plan before beginning
operations.
EPA’s SPCC rule compliance dates webpage is www.epa.gov/oem/content/spcc/compliance_

dates.htm.
EPA offers examples and templates for SPCC Plans on its website at epa.gov/oem/content/
spcc/tier1temp.htm.
Facility Response Plans (FRP)

In 1990, Congress passed the Oil Pollution Act which amended the CWA to require facilities
that handle oil and could cause “substantial harm” to the environment to prepare and sub-
mit Facility Response Plans (FRPs) under the SPCC program.
The intent of a FRP is to provide for planned responses to discharges of oil. In doing so,
facilities:
• Improve discharge prevention measures through early identification of risks;
• Ensure the availability of response resources (e.g., response equipment, trained
personnel);
• Help local and regional response authorities better understand the potential hazards
and response capabilities in their area; and
• Reduce a discharge’s impact and severity.
14B–Clean water 3/13

Who is regulated?
According to the FRP regulation, a facility could reasonably be expected to cause “substan-
tial harm” to the environment by discharging oil into or on the navigable waters or adjoining
shorelines on, if it meets any of the following criteria:
• The facility transfers oil over water to or from vessels and has a total oil storage
capacity greater than or equal to 42,000 gallons; or
• The facility’s total oil storage capacity is greater than or equal to one million gal-
lons, and one of the following is true:
❍ The facility does not have secondary containment for each aboveground stor-
age area sufficiently large to contain the capacity of the largest aboveground
oil storage tank within each storage area plus sufficient freeboard to allow
for precipitation;
❍ A discharge from the facility could cause injury to fish and wildlife and sen-
sitive environments;
❍ A discharge from the facility would shut down a public drinking water
intake; or
❍ The facility has had a reportable oil discharge in an amount greater than or
equal to 10,000 gallons within the last 5 years.
The FRP
An FRP is a detailed, facility-specific, written description of how a facility’s planned
response to a discharge of oil will be conducted. It must follow the format of the model
facility-specific response plan included in Appendix F of 40 CFR Part 112, unless you have
prepared an equivalent response plan acceptable to the Regional Administrator to meet state
or other federal requirements. Once completed, you must submit the FRP to the appropriate
EPA Regional Office for approval.
As you prepare your FRP, be sure that your plan includes the following elements:
• Emergency Response Action Plan (an easily accessible stand-alone section of the
overall plan) including the identity of a qualified individual with the authority to
implement removal actions;
• Facility name, type, location, owner, and operator information;
• Emergency notification, equipment, personnel, evidence that equipment and person-
nel are available (by contract or other approved means), and evacuation information;
• Identification and evaluation of potential discharge hazards and previous
discharges;
• Identification of small, medium, and worst case discharge scenarios and response
actions;
• Description of discharge detection procedures and equipment;
• Detailed implementation plans for containment and disposal;
• Facility and response self-inspection; training, exercises, and drills; and meeting
logs;
• Diagrams of facility and surrounding layout, topography, evacuation paths, and
drainage flow paths;

• Security measures, including fences, lighting alarms, guards, emergency cutoff

valves, and locks; and
• Response plan cover sheet (form with basic information concerning the facility).
The FRP must be reviewed and updated periodically to reflect changes at your facility.
Safe Drinking Water Act

The Safe Drinking Water Act (SDWA) is the main federal law that protects Americans’
drinking water. Under SDWA, EPA sets standards for drinking water quality and oversees
the states, localities, and water suppliers who implement those standards.
Originally passed in 1974, SDWA was amended in 1986 and 1996 to expand the law from a
focus on tap water to recognize source water protection, operator training, funding for water
system improvements, and public information. The law requires actions that protect drink-
ing water and its sources, including lakes, rivers, reservoirs, springs, and groundwater.
Drinking Water Strategy

In March 2010, EPA head Lisa Jackson laid out EPA’s new Drinking Water Strategy (DWS)
designed to strengthen public health protection from contaminants in drinking water.
Intended to streamline decision-making and expand protections under existing laws, as well
as promoting cost-effective new technologies.
Every day, millions of Americans access their drinking water from public water systems.
These systems may be publicly or privately owned and are defined as a system that provides
to the public piped drinking water that has at least 15 service connections or that serves an
average of at least 25 individuals daily for 60 days out of the year. SDWA does not regulate
private wells that serve fewer than 25 individuals.

According to EPA, there are currently 160,000-170,000 public water systems operating in the
U.S.
While usually safe, a number of situations could pose health risks to the public, including
drinking water that is not properly treated or disinfected, or drinking water that travels
through an improperly maintained distribution system. In addition, contaminants that pose
a threat to drinking water include:
• Improperly disposed chemicals,
• Animal wastes,
• Pesticides,
• Human wastes,
• Wastes injected deep underground, and
• Naturally occurring substances
Under SDWA, states can apply for “primacy” in implementing their drinking water
programs. States that are granted primacy must show that their standards are at least as
stringent as EPA’s, and that they have the ability to meet those standards. All states and
territories besides Wyoming and the District of Columbia have received primacy.
States with primacy (or EPA acting as the primacy agent) must ensure all water systems do
the following:
1. Test for contaminants,
2. Review plans for water system improvements,
3. Conduct on-site inspections and sanitary surveys,
4. Provide training and technical assistance, and
5. Enforce the standards.
Pollution barriers
SDWA sets up barriers against pollution to ensure that drinking water is safe. These
include:
• Source water protection. (Water systems treat and test their water on a frequent
basis for specified contaminants and report test results to the states.)
• Treatment.
• Distribution system integrity.
• Public information. (If a water system does not meet the standards it must notify its
customers. Many suppliers are also required to submit annual reports to customers.)
National primary drinking water regulations (NPDWRs)

The National primary drinking water regulations (NPDWRs) are the legally enforceable
standards that apply to public water systems. Find the list of all the contaminants and stan-
dards — including organic chemicals, inorganic chemicals, disinfectants, disinfection
byproducts, microorganisms, and radionuclides — as well as the “maximum contaminant
levels” (MCLs) at 1.usa.gov/dwmcls46M.

Under SDWA, EPA is required to set “maximum contaminant level goals” (MCLGs) for all
the known or anticipated contaminants to drinking water. EPA works toward achieving
these non-enforceable goals whenever possible.
Rules under the NPDWRs include the following:
Lead and copper rule

In 1991, EPA published the lead and copper rule to minimize lead and copper in drinking
water. The rule established a maximum contaminant level goal (MCLG) of zero for lead in
drinking water and a treatment technique to reduce corrosion within the distribution
system. The rule was revised in 2007.
Lead and copper enter drinking water mainly through plumbing materials. Exposure to
either element can cause a variety of health problems ranging from stomach distress to
brain damage.
The rule requires water systems to monitor drinking water at customer taps. If lead concen-
trations exceed an action level of 15 parts per billion (ppb) or copper concentrations exceed
an action level of 1.3 parts per million (ppm) in more than 10 percent of customer taps
sampled, the system must undertake a number of additional actions to control corrosion.
The water system must also inform the public of any exceedences and steps they should
take to protect their health.
Groundwater rule
Published in 2006, the rule was established to protect against microbial contamination of
drinking water systems that use groundwater sources. Under the rule, states must conduct
sanitary surveys every 3 years for community water systems and every 5 years for non-
community water systems. The rule contains additional requirements such as hydro-geologic
sensitivity assessment and enhanced source water monitoring for certain systems.
Surface water treatment rule

This rule was establishes filtrations and disinfection requirements to guard against water-
borne diseases caused by viruses such as Legionella and Giardia Lamblia.
Arsenic rule
EPA set a standard of 10 parts per billion (ppb) in January 2001(down from 50 ppb). Water
systems were required to comply with this standard by January 2006 including reporting on
the Consumer Confidence Report.
Radon rule
EPA established standards for radon in drinking water in November 1999. The rule applies
to water systems that use ground water or a mixture of ground water and surface water. A
major provision of the proposal is the option to implement a multimedia mitigation program.
Radionuclides rule
EPA updated standards for radionuclides in drinking water in December 2000. The Agency
also set a new standard for uranium. The standards are: combined radium 226/228 (5 pCi/
L); beta emitters (4 mrems); gross alpha standard (15 pCi/L); and uranium (30 μg/L).

Total coliform rule

When coliform bacteria show up in drinking water, it’s an indication that the treatment sys-
tem is not working or that there are problems in the distribution system. The total coliform
standards require that systems detect the bacteria in no more than 5 percent of samples
taken each month. Coliform contamination in drinking water usually results in gastrointes-
tinal upset. However, more serious illness or death can result. The minimum number of
samples a system must take is outlined in 40 CFR 141.21.
National secondary drinking water regulations

National secondary drinking water regulations are non-enforceable guidelines that apply to
contaminants that may have cosmetic or aesthetic effects at certain exposures in drinking
water. These effects include tastes, odors, or colors, or skin and teeth discolorations.
States may choose to adopt the secondary standards, but are not mandated to do so by EPA.
Contaminant Secondary Maximum Contaminant Level
Aluminum 0.05 to 0.2 mg/L
Chloride 250 mg/L
Color 15 (color units)
Copper 1.0 mg/L
Corrosivity noncorrosive
Fluoride 2.0 mg/L
Foaming Agents 0.5 mg/L
Iron 0.3 mg/L
Manganese 0.05 mg/L
Odor 3 threshold odor number
pH 6.5-8.5
Silver 0.10 mg/L
Sulfate 250 mg/L
Total Dissolved Solids 500 mg/L
Zinc 5 mg/L
Underground Injection Control Program

The Underground Injection Control (UIC) Program regulates the construction, operation,
permitting, and closure of injection wells that place fluids underground for storage or
disposal. These fluids may be water, wastewater, saltwater, or water that is mixed with
chemicals. EPA defines injection wells as:
• A bored, drilled, or driven shaft, or a dug hole that is deeper than it is wide,
• An improved sinkhole, or
• A subsurface fluid distribution system.
There are six types of injection wells:
Class I - Industrial & municipal waste disposal wells,
Class II - Oil and gas related wells,
Class III - Mining wells,

Class IV - Shallow hazardous and radioactive injection wells,

Class V - Shallow non-hazardous injection wells, and
Class VI - Geologic sequestration wells.
EPA regulates UICs under the SDWA to protect public health by preventing injection wells
from contaminating underground sources of drinking water. For a technical overview of UIC
regulations, type in epa.gov/safewater/uic/pdfs/uic_techovrview.pdf.
Further resources
Find guidance and tools for completing with rules and regulations under the SDWA at epa.
gov/lawsregs/guidance/sdwa/index.cfm.
Underground Injection Control Program: Criteria and Standards (40 CFR Parts 144-147)
gpoaccess.gov/cfr/index.html.
U.S. Environmental Protection Agency: Preparing Your Drinking Water Consumer Confi-
dence Report, Guidance for Water Suppliers, EPA/816-R-99-002 (March 1999) epa.gov/
safewater/topics.html.
National Primary Drinking Water Regulations (40 CFR Part 141) gpoaccess.gov/cfr/index.
html.
Audit Checklists
Vehicle maintenance stormwater pollutants checklist

Looking to improve the management of stormwater pollutants generated around your
vehicle maintenance area? The following are some uncomplicated, best management prac-
tices recommended by EPA that can be implemented with vehicle and equipment
maintenance and equipment cleaning operations.
Fueling
• Use spill and overfill protection.
• Minimize runon of stormwater into the fueling area by grading the area so that
stormwater only runs off.
• Reduce exposure of the fuel area to stormwater by covering the area.
• Use dry cleanup methods for fuel area instead of hosing the fuel area down.
• Use proper petroleum spill control.
• Perform preventive maintenance on storage tanks to detect potential leaks before
they occur.
• Inspect the fueling area to detect problems before they occur.
• Train employees on proper fueling techniques.

Vehicle and equipment maintenance

• Maintain an organized inventory of materials used in the maintenance shop.
• Dispose of greasy rags, oil filters, air filters, batteries, spent coolant, and degreasers
properly.
• Label and track the recycling of waste material (e.g., used oil, spent solvents,
batteries).
• Drain oil filters before disposal or recycling.
• Drain and contain all fluids from wrecked vehicles and “parts” cars.
• Store cracked batteries in a nonleaking secondary container.
• Promptly transfer used fluids to the proper container. Do not leave full drip pans or
other open containers around the shop. Empty and clean drip pans and containers.
• Do not pour liquid waste down floor drains, sinks, or outdoor storm drain inlets.
• Plug floor drains that are connected to the storm or sanitary sewer. If necessary,
install a sump that is pumped regularly.
• Inspect the maintenance area regularly for proper implementation of control
measures.
• Train employees on proper waste control and disposal procedures.
Outdoor vehicle and equipment storage and parking

• Use drip pans under all vehicles and equipment waiting for maintenance.
• Cover the storage area with a roof.
• Inspect the storage yard for filling drip pans and other problems regularly.
• Train employees on procedures for storage and inspection items.
Painting areas
• Keep paint and paint thinner away from traffic areas to avoid spills.
• Spray paint in an Occupational Safety and Health Act (OSHA) approved hood.
• Use effective spray equipment that delivers more paint to the target area with less
over-spray.
• Avoid sanding in windy weather and collect and dispose of waste properly.
• Recycle paint, paint thinner, and solvents.
• Inspect painting procedures to ensure that they are conducted properly.
• Train employees on proper sanding, painting, and spraying techniques.
Vehicle or equipment washing areas

• Avoid washing parts or equipment outside.
• Use phosphate-free biodegradable detergents.
• Designate an area for cleaning activities.
• Contain and recycle washwaters.
• Ensure that washwaters drain well.
• Inspect cleaning area regularly.

• Train employees on proper washing procedures.
Liquid substances in aboveground storage

• Maintain good integrity of all storage containers.
• Install safeguards (such as diking or berming) against accidental releases at the
storage area.
• Inspect storage tanks to detect potential leaks and perform preventive maintenance.
• Inspect piping systems (pipes, pumps, flanges, couplings, hoses and valves) for fail-
ures or leaks.
• Train employees on proper filling and transfer procedures.
Cold weather activities

• Minimize salt application.
• Use uncontaminated dirt or ash, if use is necessary.
• Train employees on proper salt, dirt, sand, or ash application.
Improper connections to storm sewer

• Plug all floor drains connected to sanitary or storm sewer or if connection is
unknown. Alternatively, install a sump that is pumped regularly.
• Perform smoke or dye testing to determine if interconnections exist between sani-
tary water system and storm sewer system.
• Update facility schematics to accurately reflect all plumbing connections.
• Install a safeguard against vehicle washwaters entering the storm sewer unless
permitted.
• Maintain and inspect the integrity of all underground storage tanks. Replace when
necessary.
• Train employees on proper disposal practices for all materials.
Clean water NPDES permits audit checklist

Are there any stormwater point sources outfalls at this facility?
Does this facility have an NPDES PERMIT?
If yes, who is issuing authority (EPA, state, or both)?
What is the NPDES permit expiration date?
How many and what kind of outfalls are listed on the permit?
Process wastewater
Utility wastewater
Sanitary wastewater
stormwater
Combination
Are there special NPDES restrictions (i.e., priority pollutant analysis, bio-
monitoring, etc.) and/or reporting requirements?

Is this facility under any permit compliance schedule?

Has this facility filed any noncompliance reports within the last three years?
Is there a procedure for handling permit excursions?
Are noncompliance incidents reported within five working days?
Are there any outstanding Notices of Violation or Administrative Orders?
Are all on-site treatment systems properly operated, maintained and fully
functional?
Does this facility have or use any of the priority pollutants?
Has the facility’s effluent been analyzed for any priority pollutants?
How are required samples taken and by whom ___________________?
Does this facility have a formalized and documented training program for
samplers?
Are the samples properly labeled, i.e., time, date, sampler, outfall?
Are the samples preserved?
Is the time lapse between sampling and analyses kept to a minimum?
Does this facility analyze for any permit parameters in its own laboratory?
Are your analytical records kept a minimum of three years?
Is the analyzer and date of analysis identified for each analysis?
Are EPA analytical methods used for all analysis?
Does the lab have an analytical audit/quality control program?
Are lab personnel periodically trained and checked for accuracy?
Are any outside labs used for the required permit analyses?
Is the time lapse between sampling and analyses kept to a minimum?
Are analytical records kept a minimum of 3 years?
Are the analyzer and date and method of analysis identified for each analysis
and part of the documentation record?
Are EPA analytical methods used for all analyses?
Is the lab certified by a state or federal agency?
Have you reviewed the lab’s last agency inspection report?
Do you have a copy of the outside laboratory’s quality assurance and audit
program results?
Are discharge monitoring reports (DMR) submitted?
Are the DMRs submitted on time?
Is there a designated person who signs the DMRs?
Does the facility have a letter of signature authorization?
Are samples saved until results are available?
Are all monitoring/laboratory equipment maintenance documented?

Are procedures in place to notify EPA when a change in activity has occurred
causing discharge of toxic pollutants significantly (10 times) above or not in
permit limits?
NPDES permit application checklist

Action Checklist Date Completed
Signature of
Person Filling Out
1. Determine whether a permit is required for the stormwater
discharge.
Contact the permitting authority, if necessary
Record name of contact person
2. Determine whether the state in which the discharge(s) is
located has an EPA-approved NPDES program
Determine which forms need to be submitted for individual
applications
If EPA is the permitting authority, list appropriate forms
For EPA-approved states, contact the permitting authority
for appropriate forms and instructions
3. Determine if a general permit will be, or has been, issued for
the discharge.
4. If no general permit, select between participating in a group
application or submitting an individual application.
5. Determine what the deadlines are for the permit application.
Contact the state permitting agency if this information is not
provided in the application form or instructions provided by
that agency
6. Complete the appropriate application forms. All applicants are
to submit Forms #1 and 2F. Determine if Forms 2C, 2D, and/or
2E need to be submitted.
7. Retain a complete copy of the permit application and all
supporting documentation.
8. Submit the completed application forms to the appropriate
permitting agency by the application deadline identified above.

SPCC written plan audit checklist

When performing your audit, for every “No” answer, attach a description of the missing
information and the action required to bring the site into compliance.
Yes No SPCC written plan requirements
Is the written plan up to date?
Does the plan include a Professional Engineer certification?
Does the plan follow the format listed in the rule OR cross-reference the requirements in 40
CFR Part112.7?
Does the plan include a site diagram that identifies the location and contents of each container
(including underground storage tanks that are otherwise exempt from the SPCC requirements)?
For each container, does the plan include the type of oil stored and storage capacity?
Does the plan include site procedures for preventing oil spills (discharge prevention measures
and oil handling procedures)?
Does the plan include oil spill predictions including direction, flow rate, and total quantity that
could be discharged as a result of a major equipment failure?
Does the plan include site drainage?
Does the plan include site inspection documentation?
Does the plan include site security?
Does the plan include management approval?
Does the plan include requirements for mobile, portable containers (e.g., totes, drums, or fuel
vehicles)?
Does the plan identify secondary containment or diversionary structures?
Does the plan identify secondary containment for fuel transfer?
Does the plan include personnel training records and oil spill briefings?
Does the plan include tank integrity testing?
Does the plan include bulk storage container compliance?
Does the plan include transfer procedures and transfer equipment information (including pip-
ing)?
Does the plan include countermeasures for discharge discovery, response, and cleanup (both
the facility’s capability and those that might be required of a contractor)?
Does the plan include a contact list and phone numbers for the facility response coordinator,
National Response Center, cleanup contractors with whom you have an agreement for
response, and all appropriate federal, state, and local agencies who must be contacted in case
of a discharge?
If construction lasts five years, does the plan include the five-year plan review?
Yes No Meeting oil spill prevention requirements

Is the site following site security procedures from the written plan?
Is the site following plan requirements for mobile, portable containers (e.g., totes, drums, or fuel
vehicles)?
Is the site following plan requirements for tank integrity testing?
Is the site following plan requirements for bulk storage container compliance?
Is the site following plan transfer (loading and unloading) procedures and maintaining transfer
equipment (e.g., piping)?
Is the site regularly inspecting the oil storage containers to check for spills and leaks?
Is the site following the procedures outlined in the plan to prevent oil spills?
Are the appropriate secondary containment or diversionary structures in place?
Are the secondary containment practices for fuel transfer in place?
Are all employees trained on how to prevent oil spills and what to do in the event of an oil
spill?

Yes No Meeting oil spill prevention requirements

Do the SPCC records include written inspection procedures?
Do the SPCC records include inspection reports and any corrective actions taken based on the
inspection? (These records must be maintained for three years.)
Field-audit: SPCC requirements
Date of audit:
Auditor (name, title, qualifications):
Name and location of project/site:
Oil storage area:
1. Is the site following the SPCC Plan transfer (loading and unloading) procedures
and maintaining transfer equipment (e.g., piping)?
Transfer procedures and observations:
Corrective actions needed/Expected completion date:
2. Are there any spills or leaks at the oil storage containers?

Container locations and observations:
3. Are the appropriate secondary containment or diversionary structures in place?

Containment locations and observations:
4. Are the secondary containment practices for fuel transfer in place?

Containment practices and observations:

Self-audit checklist: SPCC requirements following an oil spill
Date of spill:
Description/location of spill:
Name and location of project/site:
Yes No If a spill resulted in a discharge to navigable waters or adjoining shorelines, did the site
notify the following?
• Site Emergency Coordinator and any client representatives.
• National Response Center (800-424-8802) (if oil discharge meets the “sheen rule.” The rules
define an oil discharge as a quantity that: violates applicable water quality standards; causes a
film or “sheen” upon, or discoloration of, the surface water or adjoining shorelines; or causes a
sludge or emulsion to be deposited beneath the surface of the water or upon adjoining
shorelines.)
• State Emergency Response Commission (if spill may potentially harm people off site).
• Local Emergency Planning Committee or local fire department (if spill may potentially harm
people off site).
If a spill has occurred, were the necessary response actions, as outlined in the SPCC
plan, performed?
Was EPA notified of any spills over 1,000 gallons or of any two spills over 42 gallons
within a 12-month period?
For any reportable oil spills, did the site add a copy of the report with oil spill details to
the SPCC plan documentation? The oil spill details should include corrective actions
taken, cause of discharge, and additional preventive measures taken.

Reserved

HAZCOM
CONTENTS
The Hazard Communication Standard (HCS) ........................................................... 1

HazCom timetable ....................................................................................... 1
The Globally Harmonized System for classifying and labeling chemicals (GHS) ................ 2
GHS basics................................................................................................. 3
GHS benefits .............................................................................................. 3
The harmonized system................................................................................. 4
Chemical hazard evaluation ........................................................................... 4
Harmonized elements ................................................................................... 4
Hazard classification..................................................................................... 5
Health hazards............................................................................................ 5
Physical hazards.......................................................................................... 5
Substances hazardous to the aquatic environment ............................................... 6
Hazards Not Otherwise Classified (HNOC) ........................................................ 6
Defined hazards........................................................................................... 7
Classifying mixtures ..................................................................................... 7
Container labels ................................................................................................ 8
Product identifier ......................................................................................... 9
Pictograms ................................................................................................. 9
Signal words ............................................................................................. 11
Hazard statements...................................................................................... 11
Precautionary statements............................................................................. 12
Supplier identification ................................................................................. 12
How the label elements work together ............................................................. 12
Single-pack label ........................................................................................ 13
DOT/CPSC labels ....................................................................................... 13
Workplace container labels ........................................................................... 13
Safety data sheets ............................................................................................ 13
Compiled SDSs .......................................................................................... 20
Trade secrets ............................................................................................. 20
Exemptions to the standard .......................................................................... 20
Implement the Hazard Communication program...................................................... 21
Appoint a hazard communication coordinator .................................................... 21
Evaluate the potential hazards ...................................................................... 22
Develop a written Hazard Communication program.................................................. 22
SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM .................................. 24
List of Hazardous Chemicals ......................................................................... 24
Chemical Hazard Classification ..................................................................... 25
Safety Data Sheets (SDSs)............................................................................ 25
Labels and Other Forms of Warning ............................................................... 25
Training ................................................................................................... 27
9/12 HazCom TOC–1

Training Content ........................................................................................ 27

Hazards of Nonroutine Tasks ........................................................................ 28
Hazards of Unlabeled Pipes .......................................................................... 28
Additional Information ................................................................................ 29
Appendix .................................................................................................. 29
Develop a comprehensive chemical list .................................................................. 30
Maintaining chemical lists.................................................................................. 30
Chemical name .......................................................................................... 30
CAS registry number .................................................................................. 31
Chemical synonyms .................................................................................... 31
Hazardous chemicals training ............................................................................. 33
Hazard Communication — An overview ................................................................. 33
Training tips: ............................................................................................ 33
Hazard Communication — Health hazards ............................................................. 35
Training tips: ............................................................................................ 35
Hazard Communication — Labels & Labeling ......................................................... 36
Training tips: ............................................................................................ 36
Hazard Communication — Safety Data Sheets ........................................................ 37
Training tips: ............................................................................................ 37
Hazard Communication — Other hazards .............................................................. 38
Hazard Communication — Physical hazards ........................................................... 39
Hazard Communication checklist ......................................................................... 41
Hazard Communication program checklist ............................................................. 41
General.................................................................................................... 41
Chemical inventory ..................................................................................... 41
Safety Data Sheets (SDSs)............................................................................ 41
Labeling................................................................................................... 41
Training ................................................................................................... 41
Operations ................................................................................................ 42
REACH: registration, evaluation, and authorization of chemicals................................. 42
Scope....................................................................................................... 42
Objectives ................................................................................................. 43
How does it work? ...................................................................................... 43
What to do if you import into EU ................................................................... 44
What is the timeline for REACH implementation? ............................................. 44
Which chemicals will be excluded from REACH?................................................ 44
Are nanoparticles covered under REACH? ........................................................ 45
Regulated chemicals.......................................................................................... 45
HazCom definitions........................................................................................... 54
Reference information for HazCom/GHS ................................................................ 58
2–HazCom TOC 9/12

The Hazard Communication Standard (HCS)

The Hazard Communication (HazCom) Standard, often referred to as Worker Right to Know,
covers all employers with employees exposed to hazardous chemicals in the workplace. The
Hazard Communication Standard (HCS) is based on a relatively simple concept, which is
that employees have both a need and a right to know about chemical hazards, and the iden-
tities of the chemicals to which they are exposed. They also need to know what protective
measures are available to prevent adverse effects of chemical exposure from occurring.
OSHA revised the HCS to align it with the Globally Harmonized System for classifying and
labeling chemicals (GHS) and published the final standard in the Federal Register on March
26, 2012. It will be fully implemented in 2016.
Under the revised standard, manufacturers and employers must classify chemicals according
to their health and physical hazards, and establish consistent labels and safety data sheets
for all chemicals used in the United States.
The parts of the standard that did not relate to the GHS (such as the basic framework,
scope, and exemptions) remained largely unchanged. There have been some modifications to
terminology in order to align the revised HCS with language used in the GHS. For example,
the term “hazard determination” has been changed to “hazard classification” and “material
safety data sheet” was changed to “safety data sheet.”
HazCom timetable
During the transition period to the effective dates, chemical manufacturers, importers, dis-
tributors and employers may comply with the former standard, the new standard, or both.
OSHA recognizes that hazard communication programs will go through a period of time
where labels and safety data sheets under both standards will be present in the workplace.
This will be considered acceptable, and employers are not required to maintain two sets of
labels and safety data sheets for compliance purposes.
9/12 HazCom–1

Effective Completion Date Requirement(s) Who

December 1, 2013 Train employees on the new label Employers
elements and safety data sheet
(SDS) format.
June 1, 2015 Compliance with all modified provi- Chemical manufacturers, importers,
sions of this final rule, except: distributors and employers
December 1, 2015 The Distributor shall not ship contain-
ers labeled by the chemical
manufacturer or importer unless it is
a GHS label
June 1, 2016 Update alternative workplace labeling Employers
and hazard communication program
as necessary, and provide additional
employee training for newly identified
physical or health hazards.
The Globally Harmonized System for classifying and labeling

chemicals (GHS)
Many chemicals pose hazards to humans and to the environment from “cradle to grave,”
that is, from initial production through the handling, transport, use, and final disposal.
People of all ages and from all cultures, who use different languages and alphabets, and who
come from different social conditions and educational backgrounds are routinely using or are
affected by a myriad of chemicals. But there has been little standardization regarding haz-
ard information for the chemicals people purchase and use, both on and off the job.
To further complicate the situation, there has not been much uniformity among existing
national chemical hazard regulations (if a country had existing regulations at all). In some
countries, a chemical may be classified as flammable, while in another it isn’t. Likewise, a
substance may be considered a carcinogen in some countries but not in others. These incon-
sistencies result in incompatible definitions, warnings, and labeling, not to mention
language barriers.
Often, there were differing labels and safety data sheets required for the same product,
depending upon where it was being shipped. Labeling and safety data sheet compliance for
multiple countries can end up being costly and time-consuming.
To address this problem, in 1992, the United Nations formed a working group to develop a
“globally harmonized system of classification and labeling of chemicals.” Various agencies,
including the International Labour Organization and the UN Committee of Experts on the
Transport of Dangerous Goods worked together to further harmonization. The result was the
Globally Harmonized System of Classification and Labeling of Chemicals, or GHS, a com-
mon classification system that will provide uniform, comprehensive information about
chemicals and their hazards. The GHS includes criteria for the classification of health,
physical and environmental hazards, as well as specifying what information must be
included on labels of hazardous chemicals as well as safety data sheets.
2–HazCom 9/12

GHS basics
The GHS is not a regulation or a standard that imposes requirements. It is a set of defini-
tions and recommendations that uses a “building block” approach. A country may adopt
those parts, or “blocks,” of the system which fit with its existing regulations.
While the full range of building blocks is available to everyone, all of them do not have to be
adopted. Countries and authorities can choose those parts of the system that are most appli-
cable, allowing them to change or “harmonize” their existing laws and regulations to be
consistent with the GHS. Those portions of the GHS that a country adopts become manda-
tory only when the adopting country implements them through its own regulatory process -
as OSHA has done in the U.S.
GHS benefits
Global harmonization benefits all companies that trade internationally. With a standardized
system, companies doing business globally won’t have to spend time researching a country’s
hazardous chemical laws or translating hazard information. Countries that adopt the GHS
will benefit from the consistency in chemical hazard classification and information which
will ultimately provide a huge boost for international trade.
Standardized SDSs and labels means less potential for liability from incomplete or missing
data. In addition, eliminating the various, sometimes conflicting requirements around the
world will facilitate chemical trade, particularly for small businesses.
For countries that do not have existing systems, or may not have the resources to develop
and maintain them, a globally harmonized approach will enable them to easily participate in
international trade. Also, the use of symbols and standard phrases will improve awareness,
understanding, and simplify comparison of hazard information.
Around the world

Currently, the EU, Japan, China, Korea, Singapore, New Zealand, Australia, Brazil, and
Canada have adopted or are currently adopting GHS into their existing chemical safety
legislation.
Other nations in Asia, in the Pacific rim, in Central and South America, in Africa, and in the
Middle East are working toward implementation with the help of the UN, other developed
countries, and other interested groups such as international labor organizations.
U.S. participation
The United States was an early and active supporter of a globally harmonized approach to
chemical hazard communication information. Representatives from OSHA, DOT, EPA, and
the Consumer Product Safety Commission have served on GHS committees or UN working
groups.
DOT, EPA and CPSC

The Department of Transportation’s (DOT) hazardous materials regulations are already har-
monized with the GHS because that agency adopts the Transportation of Dangerous Goods
subcommittee through the UN Model Regulations.
9/12 HazCom–3

Under Environmental Protection Agency (EPA) regulations, the GHS will affect pesticide
and aquatic toxicity classifications. When the EPA adopts the GHS, EPA will have to harmo-
nize the classification criteria for physical hazards, health hazards, and aquatic toxicity.
Finally, the Consumer Product Safety Commission will have to harmonize with the Federal
Hazardous Substances Act, which will primarily consist of changing definitions and hazard
symbols, signal words, and hazard statements.
The harmonized system

The GHS establishes definitions for chemical and physical hazards that everyone can agree
on and use. For instance, prior to GHS there was no world-wide agreement on the definition
for a “flammable liquid,” or what separated a flammable liquid from a combustible liquid.
The harmonized system also defines what constitutes acceptable evidence of a hazard - in
other words, stating what types of studies or research may be used to determine the hazard
of a given chemical. And it establishes a logical system for determining the hazards of
chemical mixtures.
The GHS covers all hazards; physical, health, and environmental. The definitions, test meth-
ods, and classification criteria for transport were used as a basis for the GHS categories, as
those were already fairly well advanced and internationally agreed upon through the UN
Committee of Experts on the Transport of Dangerous Goods.
Chemical hazard evaluation

The GHS provides uniform definitions for chemical and physical hazards by establishing a
hazard class and category for each of the hazards. Each hazard class is divided into two or
more categories that reflect the relative severity of the effect. The revised HCS has adopted
all of the hazard classes and many of the categories.
The harmonized system also defines what constitutes acceptable evidence of a hazard - in
other words, stating what types of studies or research may be used to determine the hazard
of a given chemical. And it establishes a logical system for determining the hazards of
chemical mixtures.
The definitions, test methods, and classification criteria for transport were used as a basis
for the GHS categories, as those were already fairly well advanced and internationally
agreed upon through the UN Committee of Experts on the Transport of Dangerous Goods.
OSHA has included the general provisions for hazard classification in paragraph (d) of the
revised rule, and added extensive appendixes (Appendixes A and B) that address the criteria
for each health or physical effect.
While the GHS classification criteria covers physical hazards, health hazards, and environ-
mental hazards, OSHA did not include environmental hazards in the HCS, as the Agency
has no authority over environmental hazards.
Harmonized elements
The revised HCS addresses container labels, which include symbols/pictograms, signal
words, hazard statements, precautionary information; and safety data sheets (SDS).
4–HazCom 9/12

It establishes definitions for chemical and physical hazards that everyone can agree on and
use. For instance, prior to GHS there was no world-wide agreement on the definition for a
“flammable liquid,” or what separated a flammable liquid from a combustible liquid. The
harmonized system also defines what constitutes acceptable evidence of a hazard - in other
words, stating what types of studies or research may be used to determine the hazard of a
given chemical. And it establishes a logical system for determining the hazards of chemical
mixtures.
The globally harmonized system covers both health and environmental hazards, including
toxins, skin and eye irritants and corrosives, cancer-causing chemicals, and environmentally
hazardous materials. These represent the recognized physical hazard categories. The defini-
tions, test methods, and classification criteria for transport were used as a basis for the GHS
categories, as those were already fairly well advanced and internationally agreed upon
through the UN Committee of Experts on the Transport of Dangerous Goods.
Hazard classification
The GHS uses the term “hazard classification” for the process of assigning a chemical a spe-
cific hazard class and category. Both pure substances and mixtures are considered.
Classification is based on the following steps:
1. Identification of relevant data regarding the hazards of a substance or mixture;
2. Subsequent review of those data to ascertain the hazards associated with the sub-
stance or mixture; and
3. A decision on whether the substance or mixture will be classified as a hazardous
substance or mixture and the degree of hazard, where appropriate, by comparison of
the data with agreed hazard classification criteria.
Each hazard class will have one or more sub-categories. For each of these hazard classes
and categories, standardized label information is predetermined, and that information must
appear in Section 2 of the safety data sheets.
Health hazards
The GHS uses the following categories for classifying health effects:
• Acute toxicity,
• Skin irritation/corrosion,
• Eye irritation/corrosion,
• Respiratory/skin sensitization,
• Carcinogenicity,
• Mutagenicity,
• Reproductive toxicity, and
• Target organ toxicity.
Physical hazards
The GHS categories used for classifying physical hazards are:
• Flammable solids,
9/12 HazCom–5

• Liquids,
• Gases and aerosols,
• Explosives,
• Pyrophoric liquids and solids,
• Self-heating materials,
• Oxidizing solids,
• Liquids and gases,
• Organic peroxides,
• Self-reactive substances,
• Water reactive, and
• Corrosive to metal.
Substances hazardous to the aquatic environment

The GHS categories describing substances hazardous to the aquatic environment include:
• Acute (short-term) aquatic hazard, or
• Long-term aquatic hazard.
OSHA has no authority over environmental issues, so OSHA cannot enforce the use of
aquatic marking and inclusion of that information on the SDS. However, to be fully GHS-
compliant, employers may choose to include this information.
Hazards Not Otherwise Classified (HNOC)

OSHA included coverage of hazards which were covered under the old HCS but which do not
fall into one of the established GHS hazard classes in a category called “Hazards Not Other-
wise Classified (HNOC).”
HNOC means an adverse physical or health effect identified through evaluation of scientific
evidence during the classification process that does not meet the specified criteria for the
physical and health hazard classes addressed in this section. HNOC classification does not
extend coverage to adverse physical and health effects for which there is a hazard class
addressed in HCS.
Rather, it covers those hazards whose effects either fall below the cut-off value/concentration
limit of the hazard class or is under a GHS hazard category that has not been adopted by
OSHA (e.g., acute toxicity Category 5).
Chemical manufacturers and importers are expected to assess these hazards when they are
conducting their hazard evaluation of physical and health hazards. A new or separate evalu-
ation is not required.
HNOC hazards will not be required to be disclosed on the label but will be required to be
disclosed in section 2 of the Safety Data Sheet (SDS). This reflects how GHS recommends
these hazards should be disclosed.
OSHA has removed pyrophoric gases, simple asphyxiants, and combustible dust from the
HNOC hazard category and has addressed these chemicals individually.
6–HazCom 9/12

Defined hazards
OSHA has added pyrophoric gases, simple asphyxiants and combustible dust to the defini-
tion of “hazardous chemical” in the HCS. OSHA has also added definitions to the revised
HCS for pyrophoric gases and simple asphyxiants, and provided guidance on how to define
combustible dust for the purposes of complying with the HCS.
• Pyrophoric gases: OSHA has retained the definition for pyrophoric gases from the
old HCS. Pyrophoric gases must be addressed both on container labels and SDSs.
• Simple asphyxiants: OSHA has revised the definition of simple asphyxiants in the
revised HCS. Simple asphyxiants must be labeled where appropriate, and be
addressed on SDSs.
• Combustible dust: The definition for combustible dust is being provided through
existing documents, including the Combustible Dust National Emphasis Program
Directive CPL 03-00-008 and a number of voluntary industry consensus standards
(particularly those of the NFPA). Combustible dust hazards must be addressed on
labels and SDSs.
For chemicals in a solid form that do not present a combustible dust hazard, but may form
combustible dusts while being processed in normal downstream uses, the label may be
transmitted to the customer at the time of the initial shipment, but the label does not need
to be included with subsequent shipments unless it changes.
Classifying mixtures
GHS allows the use of bridging principles for classifying untested mixtures. When a mixture
has not been tested as a whole, but there are sufficient data on the components or on similar
tested mixtures, the following bridging principles can be applied:
• Dilution can be used when a mixture is diluted with a chemical of an equivalent or
lower toxicity. Then the hazards of the new mixture are assumed to be equivalent to
the original.
• Batching refers to producing a batch of a complex substance under a controlled
process, where the hazards of the new batch are assumed to be equivalent to previ-
ous batches.
• Concentration of Highly Toxic Mixtures means assuming that the concentrated
form of a severely hazardous mixture is also severely hazardous.
• Interpolation within One Toxic Category: Mixturesmeans mixtures which have
component concentrations within a range where the hazards are known then it is
assumed that a mixture would have those same hazards.
• Substantially Similar Mixtures where slight changes in the concentrations of
components are not expected to change the hazards of a mixture and substitutions
involving similar components are not expected to change the hazards
• Aerosol can be used where an aerosol form of a mixture is assumed to have the
same hazards as the tested, non-aerosolized form of the mixture unless the propel-
lant affects the hazards upon spraying.
All bridging principles do not apply to every health and environmental endpoint, and you
will have to consult each endpoint to determine which bridging principles can be applied.
9/12 HazCom–7

When the bridging principles do not apply or cannot be used, the health and environmental
hazards of mixtures are estimated based on component information. In the GHS, the meth-
odology used to estimate these hazards varies by endpoint. The GHS Document or “Purple
Book” should be consulted for more complete information on classifying mixtures.
Container labels
The HCS requires labels to have six elements, four of which have been “harmonized” within
the GHS system, based upon the chemical’s hazard class and category.
Those required label elements are:
• Product identifier;
• Signal word;
• Hazard statement(s);
• Pictogram(s);
• Precautionary statement(s); and
• The name, address, and telephone number of the chemical manufacturer, importer,
or other responsible party.
Pictogram Product identifier Signal word
Hazard
Statements
Precautionary
Statements
Chemical manufacturer, importer,

or other responsible party.
The GHS harmonized elements are the:

• Pictogram(s): a symbol plus other graphic elements, such as a border, background
pattern, or color that is intended to convey specific information about the hazards of
a chemical. Each pictogram consists of a different symbol on a white background
within a red square frame set on a point (i.e. a red diamond). There are nine
pictograms under the GHS. However, only eight pictograms are required under the
HCS.
8–HazCom 9/12

• Signal word: a single word used to indicate the relative level of severity of hazard
and alert the reader to a potential hazard on the label. The signal words used are
“danger” and “warning.” “Danger” is used for the more severe hazards, while “warn-
ing” is used for less severe hazards.
• Hazard statement(s): a statement assigned to a hazard class and category that
describes the nature of the hazard(s) of a chemical, including, where appropriate,
the degree of hazard.
• Precautionary statement(s): a phrase that describes recommended measures to
be taken to minimize or prevent adverse effects resulting from exposure to a hazard-
ous chemical or improper storage or handling of a hazardous chemical.
This relieves the chemical producer of the burden of creating the hazard warning language
by supplying the proper signal words and correct hazard statements. All of the required
label information will appear in Section 2 of the safety data sheet.
Product identifier
The product identifier on the label should match the product identifier used on the safety
data sheet. Where a substance or mixture is covered by the UN Model Regulations on the
Transport of Dangerous Goods, the UN proper shipping name should also be used on the
package.
Pictograms
A pictogram is a graphic composition that includes a symbol plus other graphic elements,
such as a border, background pattern, or color that is intended to convey specific
information. All hazard pictograms must be in the shape of a square set at a point.
Some pictograms are fairly self-explanatory, others are not so, which is one of the reasons
they may not have been more widely adopted in the U.S. With the exception of the fish and
tree symbol and the exclamation point, these are all currently used in the UN Recommenda-
tions on the Transport of Dangerous Goods Model Regulations.
Pictograms indicate hazards to the environment using a dead fish and tree; flammable mate-
rials (liquids and solids) represented by a flame over a bar; and corrosives showing a liquid
dissolving solids and/or skin.
The Health Hazard pictogram is used for chemicals which are carcinogens, respiratory
sensitizer, reproductive toxins, target organ toxins, mutagens, or aspiration toxins.
9/12 HazCom–9

The Skull and Crossbones identifies those chemicals that are acutely toxic (severe).
The Exclamation Mark is used for irritants, dermal sensitizer, acute toxins (harmful),
narcotic effects, and respiratory tract irritants.
Chemicals which are explosive, self-reactive, or which are organic peroxides have the
Exploding Bomb pictogram.
Oxidizers will carry the Flame Over Circle pictogram.
The Flame pictogram will represent flammables, self-reactives, pyrophorics, self-heating

substances, chemicals that emit flammable gases, and organic peroxides.
Corrosives will be identified using the Corrosion pictogram.
10–HazCom 9/12

The pictogram for compressed gases is the Gas Cylinder.
Finally, the Environmental pictogram is used for those chemicals which are toxic to the
environment. However, OSHA is not picking up this pictogram because the agency has no
authority over those issues.
Signal words
A signal word is a word used to indicate the relative level of severity of hazard and alert the
reader to a potential hazard on the label. The signal words used in the GHS are “Danger”
and “Warning”.
“Danger” is used for the more severe hazard classes and hazard categories 1 and 2, while
“Warning” is used for the less severe. A signal word is not always required for the least haz-
ardous categories of a given class of hazard, but when a signal word is required it will
always be one of these two.
Hazard statements
Hazard statements are standardized phrases which are assigned to a hazard class and
category. Hazard statements describe the nature of the hazards of a product, including,
where appropriate, the degree of hazard.
Hazard statements provide immediate hazard information about the material by briefly pro-
viding measures to be taken to minimize or prevent adverse effects from physical, health or
environmental hazards. This information must appear on the label and be included on the
SDS. For chemicals that have multiple hazards, the appropriate hazard statement for each
hazard should appear on the label.
A unique alphanumeric code is assigned to each statement consisting of the letter H, for
“hazard,” followed by three numbers. Those that begin with the number “2” describe physi-
cal hazards, those that being with the number “3” denote health hazards, and those
beginning with “4” environmental hazards.
Examples of hazard statements

H200 Unstable explosive
H221 Flammable gas
H301 Toxic if swallowed
H371 May cause damage to organs
H400 Very toxic to aquatic life
3/14 HazCom–11

H411 Toxic to aquatic life with long lasting effects

The alphanumeric code will only appear on the SDS, and not on the label. The only thing
that will appear on the label are the statements themselves.
Precautionary statements
Use of precautionary statements, while optional in the GHS system, are mandatory in
OSHA’s HazCom standard. Precautionary statements are linked to each hazard class and
category. These statements, which supplement the hazard information on the label, are used
to minimize or prevent adverse effects from physical, health, or environmental hazards.
First aid information will be included in this precautionary information.
Precautionary statements are assigned a unique alphanumeric code which begins with the
letter “P” for precautionary statement, followed by three numbers. The first of the three
numbers indicates what type of precautionary statement it is.
“1” is for general precautionary statements;
“2” is for prevention precautionary statements;
“3” is for response statements;
“4” is for storage precautions; and
“5” is for disposal precautions.
Examples of precautionary statements

P103 Read label before use.
P233 Keep container tightly closed.
P331 Do NOT induce vomiting.
P403 Store in a well-ventilated place.
P502 Refer to manufacturer/supplier for information on recover/recycling.
Many of the statements must be completed by the preparer, for instance, P411 states to
“Store at temperature not exceeding . . .” and a temperature must be filled in. And P370
states “In case of fire: Use . . . To extinguish.” and the preparer must fill in the appropriate
extinguishing medium.
Supplier identification
The name, address and telephone number of the manufacturer or supplier of the substance
or mixture.
How the label elements work together

The pictogram, signal word, and hazard statement should be located together on the label.
These three pieces of information work together to alert users of the hazards.
Hazards Not Otherwise Categorized will not be required to be disclosed on the label but
will be required to be disclosed in section 2 of the Safety Data Sheet (SDS).
12–HazCom 3/14

Single-pack label
Here is another label which would be used on a drum or tote — a so-called single pack label
— where DOT elements must also appear.
OSHA says that where the DOT markings appear, such as the red diamond or white dia-
mond seen on the sample label, the GHS pictogram should not appear, although the GHS
allows them to.
But the other required label elements can be seen, the product id, the signal word, hazard
statements, precautionary statements, and so on.
DOT/CPSC labels
OSHA does not require that you re-label any containers that are already properly labeled
per another federal agency. So containers that are appropriately marked for transport per
DOT or products on the shelf that are labeled for sale to consumers do not have to re-labeled
or have any additional labeling.
Workplace container labels

Any containers leaving the workplace, and those which enter your workplace, must have
GHS-style HazCom labels. And you must maintain these HazCom labels on those containers
while they are in your facility.
Alternative labeling systems such as the National Fire Protection Association (NFPA) 704
Hazard Rating and the Hazardous Material Information System (HMIS) are permitted for
workplace containers. However, the information supplied on these labels must be consistent
with the revised HCS, e.g., no conflicting hazard warnings or pictograms.
Employers may continue to use signs, placards, process sheets, batch tickets, operating pro-
cedures, or other such written materials in lieu of affixing labels to individual stationary
process containers, as long as the alternative method identifies the containers to which it is
applicable and conveys the information required by paragraph (f)(7) of 1910.1200.
And as before, employers don’t have to label portable containers. However, if the container is
used to pass chemical along to another employee or another shift, it MUST be properly
labeled.
Safety data sheets

The revised HCS requires chemical manufacturers, distributors, or importers to provide
Safety Data Sheets (SDSs) (formerly known as Material Safety Data Sheets or MSDSs) to
communicate the hazards of hazardous chemical products.
The information contained in the SDS is largely the same as the MSDS, except now the
SDSs are required to be presented in a consistent user-friendly, 16-section format. The SDS
format is the same as the ANSI standard format which is widely used in the U.S. and is
already familiar to many employees.
9/13 HazCom–13

The SDS includes information such as the properties of each chemical; the physical, health,
and environmental health hazards; protective measures; and safety precautions for han-
dling, storing, and transporting the chemical. The information contained in the SDS must be
in English (although it may be in other languages as well). In addition, OSHA requires that
SDS preparers provide specific minimum information as detailed in Appendix D of 29 CFR
1910.1200. The SDS preparers may also include additional information in various section(s).
Sections 1 through 8 contain general information about the chemical, identification, hazards,
composition, safe handling practices, and emergency control measures (e.g., firefighting).
This information should be helpful to those that need to get the information quickly. Sec-
tions 9 through 11 and 16 contain other technical and scientific information, such as
physical and chemical properties, stability and reactivity information, toxicological informa-
tion, exposure control information, and other information including the date of preparation
or last revision. The SDS must also state that no applicable information was found when the
preparer does not find relevant information for any required element.
The SDS must also contain Sections 12 through 15, to be consistent with the UN Globally
Harmonized System of Classification and Labeling of Chemicals (GHS), but OSHA will not
enforce the content of these sections because they concern matters handled by other
agencies.
A description of all 16 sections of the SDS, along with their contents, is presented below:
SDS Sections
1. Identification This section identifies the chemical on the SDS as well as the recommended
uses. It also provides the essential contact information of the supplier. The
required information consists of:
• Product identifier used on the label and any other common names or syn-
onyms by which the substance is known.
• Name, address, phone number of the manufacturer, importer, or other
responsible party, and emergency phone number.
• Recommended use of the chemical (e.g., a brief description of what it
actually does, such as flame retardant) and any restrictions on use (includ-
ing recommendations given by the supplier).
2. Hazard(s) identification This section identifies the hazards of the chemical presented on the SDS and
the appropriate warning information associated with those hazards. The
• The hazard classification of the chemical (e.g., flammable liquid, category).
• Signal word.
• Hazard statement(s).
• Pictograms (the pictograms or hazard symbols may be presented as
graphical reproductions of the symbols in black and white or be a descrip-
tion of the name of the symbol (e.g., skull and crossbones, flame).
• Precautionary statement(s).
• Description of any hazards not otherwise classified.
• For a mixture that contains an ingredient(s) with unknown toxicity, a state-
ment describing how much (percentage) of the mixture consists of
ingredient(s) with unknown acute toxicity. Please note that this is a total
percentage of the mixture and not tied to the individual ingredient(s).
14–HazCom 9/13

3. Composition/information on This section identifies the ingredient(s) contained in the product indicated on
ingredients the SDS, including impurities and stabilizing additives. This section includes
information on substances, mixtures, and all chemicals where a trade secret
is claimed. The required information consists of:
Substances
• Chemical name.
• Common name and synonyms.
• Chemical Abstracts Service (CAS) number and other unique identifiers.
• Impurities and stabilizing additives, which are themselves classified and
which contribute to the classification of the chemical.
Mixtures
• Same information required for substances.
• The chemical name and concentration (i.e., exact percentage) of all ingre-
dients which are classified as health hazards and are:
Present above their cut-off/concentration limits or
Present a health risk below the cut-off/concentration limits
• The concentration (exact percentages) of each ingredient must be speci-
fied except concentration ranges may be used in the following situations:
A trade secret claim is made,
There is batch-to-batch variation, or
The SDS is used for a group of substantially similar mixtures.
Chemicals where a trade secret is claimed
• A statement that the specific chemical identity and/or exact percentage
(concentration) of composition has been withheld as a trade secret is
required.
4. First-aid measures This section describes the initial care that should be given by untrained
responders to an individual who has been exposed to the chemical. The
• Necessary first-aid instructions by relevant routes of exposure (inhalation,
skin and eye contact, and ingestion).
• Description of the most important symptoms or effects, and any symptoms
that are acute or delayed.
• Recommendations for immediate medical care and special treatment
needed, when necessary.
5. Firefighting measures This section provides recommendations for fighting a fire caused by the
chemical. The required information consists of:
• Recommendations of suitable extinguishing equipment, and information
about extinguishing equipment that is not appropriate for a particular
situation.
• Advice on specific hazards that develop from the chemical during the fire,
such as any hazardous combustion products created when the chemical
burns.
• Recommendations on special protective equipment or precautions for
firefighters.
9/12 HazCom–15

6. Accidental release measures This section provides recommendations on the appropriate response to spills,
leaks, or releases, including containment and cleanup practices to prevent or
minimize exposure to people, properties, or the environment. It may also
include recommendations distinguishing between responses for large and
small spills where the spill volume has a significant impact on the hazard. The
required information may consist of recommendations for:
• Use of personal precautions (such as removal of ignition sources or pro-
viding sufficient ventilation) and protective equipment to prevent the
contamination of skin, eyes, and clothing.
• Emergency procedures, including instructions for evacuations, consulting
experts when needed, and appropriate protective clothing.
• Methods and materials used for containment (e.g., covering the drains and
capping procedures).
• Cleanup procedures (e.g., appropriate techniques for neutralization, decon-
tamination, cleaning or vacuuming; adsorbent materials; and/or equipment
required for containment/clean up).
7. Handling and storage This section provides guidance on the safe handling practices and conditions
for safe storage of chemicals. The required information consists of:
• Precautions for safe handling, including recommendations for handling
incompatible chemicals, minimizing the release of the chemical into the
environment, and providing advice on general hygiene practices (e.g., eat-
ing, drinking, and smoking in work areas is prohibited).
• Recommendations on the conditions for safe storage, including any
incompatibilities. Provide advice on specific storage requirements (e.g.,
ventilation requirements).
8. Exposure controls/personal pro- This section indicates the exposure limits, engineering controls, and personal
tection protective measures that can be used to minimize worker exposure. The
• OSHA Permissible Exposure Limits (PELs), American Conference of Gov-
ernmental Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs),
and any other exposure limit used or recommended by the chemical
manufacturer, importer, or employer preparing the safety data sheet, where
available.
• Appropriate engineering controls (e.g., use local exhaust ventilation, or use
only in an enclosed system).
• Recommendations for personal protective measures to prevent illness or
injury from exposure to chemicals, such as personal protective equipment
(PPE) (e.g., appropriate types of eye, face, skin or respiratory protection
needed based on hazards and potential exposure).
• Any special requirements for PPE, protective clothing or respirators (e.g.,
type of glove material, such as PVC or nitrile rubber gloves; and break-
through time of the glove material).
16–HazCom 9/12

9. Physical and chemical proper- This section identifies physical and chemical properties associated with the
ties substance or mixture. The minimum required information consists of:
• Appearance (physical state, color, etc.);
• Upper/lower flammability or explosive limits;
• Odor;
• Vapor pressure;
• Odor threshold;
• Vapor density;
• pH;
• Relative density;
• Melting point/freezing point;
• Solubility(ies);
• Initial boiling point and boiling range;
• Flash point;
• Evaporation rate;
• Flammability (solid, gas);
• Upper/lower flammability or explosive limits;
• Vapor pressure;
• Vapor density;
• Relative density;
• Solubility(ies);
• Partition coefficient: n-octanol/water;
• Auto-ignition temperature;
• Decomposition temperature; and
• Viscosity. The SDS may not contain every item on the above list because
information may not be relevant or is not available. When this occurs, a nota-
tion to that effect must be made for that chemical property. Manufacturers
may also add other relevant properties, such as the dust deflagration index
(Kst) for combustible dust, used to evaluate a dust’s explosive potential.
9/12 HazCom–17

10. Stability and reactivity This section describes the reactivity hazards of the chemical and the chemi-
cal stability information. This section is broken into three parts: reactivity,
chemical stability, and other. The required information consists of: Reactivity
• Description of the specific test data for the chemical(s). This data can be
for a class or family of the chemical if such data adequately represent the
anticipated hazard of the chemical(s), where available. Chemical stability
• Indication of whether the chemical is stable or unstable under normal
ambient temperature and conditions while in storage and being handled.
• Description of any stabilizers that may be needed to maintain chemical
stability.
• Indication of any safety issues that may arise should the product change in
physical appearance. Other
• Indication of the possibility of hazardous reactions, including a statement
whether the chemical will react or polymerize, which could release excess
pressure or heat, or create other hazardous conditions. Also, a description
of the conditions under which hazardous reactions may occur.
• List of all conditions that should be avoided (e.g., static discharge, shock,
vibrations, or environmental conditions that may lead to hazardous
conditions).
• List of all classes of incompatible materials (e.g., classes of chemicals or
specific substances) with which the chemical could react to produce a haz-
ardous situation.
• List of any known or anticipated hazardous decomposition products that
could be produced because of use, storage, or heating. (Hazardous com-
bustion products should also be included in Section 5 (Fire-Fighting
Measures) of the SDS.)
11. Toxicological information This section identifies toxicological and health effects information or indicates
that such data are not available. The required information consists of:
• Information on the likely routes of exposure (inhalation, ingestion, skin and
eye contact). The SDS should indicate if the information is unknown.
• Description of the delayed, immediate, or chronic effects from short- and
long-term exposure.
• The numerical measures of toxicity (e.g., acute toxicity estimates such as
the LD50 (median lethal dose)) - the estimated amount [of a substance]
expected to kill 50% of test animals in a single dose.
• Description of the symptoms. This description includes the symptoms
associated with exposure to the chemical including symptoms from the
lowest to the most severe exposure.
• Indication of whether the chemical is listed in the National Toxicology Pro-
gram (NTP) Report on Carcinogens (latest edition) or has been found to
be a potential carcinogen in the International Agency for Research on Can-
cer (IARC) Monographs (latest editions) or found to be a potential
carcinogen by OSHA.
18–HazCom 9/12

12. Ecological information (non- This section provides information to evaluate the environmental impact of the
mandatory) chemical(s) if it were released to the environment. The information may
include:
• Data from toxicity tests performed on aquatic and/or terrestrial organisms,
where available (e.g., acute or chronic aquatic toxicity data for fish, algae,
crustaceans, and other plants; toxicity data on birds, bees, plants).
• Whether there is a potential for the chemical to persist and degrade in the
environment either through biodegradation or other processes, such as
oxidation or hydrolysis.
• Results of tests of bioaccumulation potential, making reference to the
octanol-water partition coefficient (Kow) and the bioconcentration factor
(BCF), where available.
• The potential for a substance to move from the soil to the groundwater
(indicate results from adsorption studies or leaching studies).
• Other adverse effects (e.g., environmental fate, ozone layer depletion
potential, photochemical ozone creation potential, endocrine disrupting
potential, and/or global warming potential).
13. Disposal considerations (non- This section provides guidance on proper disposal practices, recycling or rec-
mandatory) lamation of the chemical(s) or its container, and safe handling practices. To
minimize exposure, this section should also refer the reader to Section 8
(Exposure Controls/Personal Protection) of the SDS. The information may
include:
• Description of appropriate disposal containers to use.
• Recommendations of appropriate disposal methods to employ.
• Description of the physical and chemical properties that may affect dis-
posal activities.
• Language discouraging sewage disposal.
• Any special precautions for landfills or incineration activities.
14. Transport information (non- This section provides guidance on classification information for shipping and
mandatory) transporting of hazardous chemical(s) by road, air, rail, or sea. The informa-
tion may include:
• UN number (i.e., four-figure identification number of the substance).
• UN proper shipping name.
• Transport hazard class(es).
• Packing group number, if applicable, based on the degree of hazard.
• Environmental hazards (e.g., identify if it is a marine pollutant according to
the International Maritime Dangerous Goods Code (IMDG Code)).
• Guidance on transport in bulk (according to Annex II of MARPOL 73/783
and the International Code for the Construction and Equipment of Ships
Carrying Dangerous Chemicals in Bulk (International Bulk Chemical Code
(IBC Code)).
• Any special precautions which an employee should be aware of or needs
to comply with, in connection with transport or conveyance either within or
outside their premises (indicate when information is not available).
15. Regulatory information (non- This section identifies the safety, health, and environmental regulations spe-
mandatory) cific for the product that is not indicated anywhere else on the SDS. The
information may include:
• Any national and/or regional regulatory information of the chemical or mix-
tures (including any OSHA, Department of Transportation, Environmental
Protection Agency, or Consumer Product Safety Commission regulations).
16. Other information This section indicates when the SDS was prepared or when the last known
revision was made. The SDS may also state where the changes have been
made to the previous version. You may wish to contact the supplier for an
explanation of the changes. Other useful information also may be included
here.
9/12 HazCom–19

Employers must ensure that SDSs are readily accessible to employees.
Sections 12-15 may be included in the SDS, but are not required by OSHA. However, for the
SDS to be GHS-compliant, those sections would have to appear.
OSHA is retaining the requirement to include the American Conference of Government

Industrial Hygienists (ACGIH) Threshold Limit Values (TLVs) on SDS in the revised
standard. OSHA says that requiring TLVs will provide employers and employees with useful
information to help them assess the hazards presented by their workplaces. In addition to
TLVs, OSHA permissible exposure limits (PELs), and any other exposure limit used or rec-
ommended by the chemical manufacturer, importer, or employer preparing the safety data
sheet are also required.
Compiled SDSs
In the former HCS, OSHA allowed formulators of chemicals to develop an SDS by simply
providing the SDSs for all the ingredients rather than compiling a specific SDS for the
product.
OSHA does not believe that this practice is widely used, and it is not allowed under the new
HCS. Hazard classification under GHS requires the consideration and application of bridg-
ing principles to determine the classification for the mixture as a whole.
Trade secrets
The revised HCS requires chemical manufacturers, distributors, or importers to provide
Safety Data Sheets (SDSs) to communicate the hazards of hazardous chemical products.
For chemical manufacturers, the disclosure of trade secrets and other confidential business
information is a concern. Generally, it is the chemical manufacturer’s desire and right to
protect proprietary chemicals and formulas. Because of the wide difference in national laws
and how those laws are enforced, the GHS working group determined that the GHS will not
include the subject of confidential business information. The GHS recommends that national
authorities address:
• Confidential business information protections so as not to compromise the health
and safety of the chemical users,
• Any coverage under a confidential claim be restricted to names of chemicals and
their concentrations in mixtures, and
• A disclosure mechanism for that information in emergency and non-emergency
situations.
Exemptions to the standard

OSHA considers most office products, such as pens, pencils, and adhesive tape to be exempt
under the provisions of the Hazard Communication rule, either as articles, or as consumer
products. In addition, OSHA has previously stated that intermittent or occasional use of a
copying machine does not result in coverage under the rule. However, if an employee
handles the chemicals to service the machine, or operates it for long periods of time, then
the program would have to be applied.
20–HazCom 9/12

Similarly, if your employees’ use of specific cleaning products, such as handwashing soap,
rubbing alcohol, or bleach, is the same as that of normal consumers (they use the cleanser
as one would at home to clean sinks or counter tops, for example), then such products would
not need to be addressed in your hazard communication program. If, however, an employee’s
job goes beyond normal household use (cleaning sinks all day), then the employee would be
entitled to the hazard communication information on the hazards that product may pose.
As a general rule, the HCS does not apply to the following:

• Any hazardous waste, as defined and regulated under the Resource Conservation
and Recovery Act (RCRA);
• Tobacco or tobacco products;
• Wood or wood products;
• Foods, drugs, cosmetics, or alcoholic beverages in a retail establishment that are
packaged for sale to consumers;
• Foods, drugs, or cosmetics intended for personal consumption by employees while in
the workplace;
• Any consumer product when used in the same manner as normal consumer use;
• Any drug when it is a solid, in a final form for patient use, such as tablets or pills;
and
• Articles (manufactured items other than a fluid or a particle).
Implement the Hazard Communication program
Appoint a hazard communication coordinator

Knowledge acquired under the Hazard Communication Standard (HCS) helps you to provide
safer workplaces for your employees. When you have information about the chemicals being
used, you can take steps to reduce exposures, substitute less hazardous materials, and
establish proper work practices. These efforts will help prevent the occurrence of work-
related illnesses and injuries caused by chemicals, and the best place to start is by
appointing a hazard communication coordinator.
Hazard communication is a continuous process. In order for the communication program to

be successful, it will be necessary to assign responsibility for both the initial and ongoing
activities associated with the rule. In some cases, these activities may already be part of cur-
rent job assignments. For example, site supervisors are frequently responsible for on-the-job
training sessions. Early identification of the responsible employees, and involvement of them
in the development of your plan of action, will result in a more effective program design.
Evaluation of the effectiveness of your program will also be enhanced by involvement of
affected employees.
Most facilities or operations have multiple functions, each performing different jobs. You will
find that developing an acceptable HCS program requires a comprehensive effort, and coop-
eration from each department (or site) in your facility. Having a committee or a group of
coordinators results in unfulfilled tasks, time lost on meetings, and stalled decisions, with no
one in charge.
9/12 HazCom–21

Your coordinator should be responsible for:

• Organizing your safety data sheets;
• Setting up and conducting employee training programs;
• Maintaining inventory lists on chemicals present in the workplace;
• Ensuring that all chemicals are properly labeled by the manufacturer, or your
company;
• Processing requests for information from employees and OSHA;
• Documenting each step of compliance in your company’s written hazard communica-
tion program; and
• Ensuring that each department follows through with compliance.
And, most important, he or she should know how the HCS program was implemented over-
all (carefully documenting every step), and be able to answer any questions from employees
and/or OSHA representatives.
Evaluate the potential hazards

The HCS addresses the issues of evaluating hazards to workers. Evaluation of chemical haz-
ards involves a number of technical concepts, and is a process that requires the professional
judgement of experienced experts. That’s why the HCS is designed so that employers who
simply use chemicals, rather than produce or import them, are not required to evaluate the
hazards of those chemicals. Remember, hazard determination is the responsibility of the pro-
ducers and importers of the materials. Producers and importers of chemicals are then
required to provide the hazard information to employers that purchase their products.
OSHA’s definition of a hazardous chemical is fairly broad, so you will find that hazardous
chemicals are not limited to those substances that have skull and crossbones markings. In
fact, you will find that many commonplace items, such as diesel fuel, lubricating oil, window
cleaner, drain cleaner, mineral spirits, solvents, gasoline, and paint are considered hazard-
ous chemicals. Identifying hazardous chemicals begins with developing a comprehensive list
of the chemicals at your facility; information about developing a list is provided elsewhere in
this section.
If you don’t produce or import chemicals, then you need only focus on those parts of the rule
that deal with establishing a workplace program, and communicating that information to
your workers, such as through the use of material safety data sheets (MSDSs).
Develop a written Hazard Communication program

You must develop, implement, and maintain at your facility, a written, comprehensive haz-
ard communication program that includes provisions for container labeling, collection and
availability of SDSs, and an employee information and training program. The program must
also contain a list of hazardous chemicals in each work area, the means you will use to
inform employees of the hazards of non-routine tasks (for example, the cleaning of reactor
vessels), and the hazards associated with chemicals in unlabeled pipes.
Employees must have access to the written hazard communication program, a list of hazard-
ous chemicals present in the workplace, and to the SDSs.
22–HazCom 9/12

If your workplace has multiple employers on-site (for example, a construction site), you must
ensure that information regarding hazards and protective measures is made available to
other employers on-site, where appropriate.
The following sample written hazard communication program contains all the required ele-
ments under the standard.
9/12 HazCom–23

SAMPLE WRITTEN HAZARD COMMUNICATION PROGRAM

Our company is complying with the requirements of OSHA’s Hazard Communication Stan-
dard for construction by compiling a list of hazardous chemicals, using safety data sheets
(SDSs), ensuring that containers are labeled or provided other forms of warning, and train-
ing our worksite employees. In addition, we share information with other employers involved
in a specific project so that they may keep their employees informed.
This program applies to all work operations at [enter company name]

where employees may be exposed to hazardous chemicals under normal working conditions
or during an emergency situation. Under this program, our employees will be informed of
the contents of the Hazard Communication Standard, the hazards of chemicals with which
they work, safe handling procedures, and measures to take to protect themselves from these
chemicals, among other training elements.
[enter name/title ], the Hazard Communication Program Coordinator,

has overall responsibility for the program, including to review and update the program, as
necessary. Copies of this written program may be obtained from [enter
name/title ] who keeps the program [enter location ]. Moreover, all
employees, or their designated representatives, may obtain further information about this
written program, the Hazard Communication Standard, applicable SDSs, and our chemical
list from (enter your answer).
Finally, if after reading this program, you find that improvements can be made, please con-
tact [enter name/title] . We encourage all suggestions because we are
committed to the success of our written Hazard Communication Program. We strive for clear
understanding, safe behavior, and involvement in the program from every level of the
company.
List of Hazardous Chemicals

Our “chemical inventory” is a list of product identifiers of hazardous chemicals known to be
present at our workplace. Anyone who comes in contact with the hazardous chemicals on the
list needs to know what those chemicals are and how to protect themselves. That is why it is
so important that hazardous chemicals are identified, whether they are found in a container
or generated in work operations (for example, welding fumes, dusts, and exhaust fumes).
The hazardous chemicals on the chemical inventory can cover a variety of physical forms
including liquids, solids, gases, vapors, fumes, and mists. Sometimes hazardous chemicals
can be identified using purchase orders. Identification of other chemicals may require an
actual survey of the workplace.
[enter name/title] updates the hazardous chemical inventory as

necessary.
The inventory is attached to this written Hazard Communication Program. However, the
Program Coordinator also keeps a copy of the chemical inventory list located [enter loca-
tion] where it is accessible during work hours. The chemical inventory serves as a list of
every hazardous chemical for which an SDS must be maintained.
24–HazCom 9/12

Chemical Hazard Classification

[enter company name] manufactures the following hazardous chemi-
cals:
[list chemicals]
The company uses the following methods to classify the hazards of the chemicals it manufac-
tures:
[enter methods]
Safety Data Sheets (SDSs)

SDSs are basically fact sheets for chemicals that pose a physical or health hazard in the
workplace. These sheets provide our employees with specific information on the chemicals in
their work areas.
[enter name/title] is responsible for obtaining and maintaining the

SDSs at our workplace and will contact the chemical manufacturer or vendor if additional
chemical information is needed. All new procurements for the company must be cleared by
[enter name/title].
SDSs are kept readily accessible to all employees during each work shift at the following
location(s): [enter locations]. Employees may obtain access to them by:
[enter method of access].

The procedure followed if the SDS is not received with the first shipment is as follows:
[enter procedure].
We generate SDSs for certain chemicals:
[list chemicals]. Each SDS is provided in English and includes the sections required by
OSHA in the order listed in the Hazard Communication Standard. The procedure we use to
update these SDSs when new and significant health information is found is:
[enter procedure].
The SDSs that our company generates are supplied by [enter company
name].
It should be noted that OSHA allows SDSs to be kept in any form, as long as the informa-
tion is provided for each hazardous chemical and is readily accessible during each work shift
to employees when they are in their work area(s). Therefore, we have taken advantage of
this flexible OSHA provision for alternatives to SDSs in the workplace. Our alternative(s)
includes: [enter alternatives].
Labels and Other Forms of Warning

In most cases, hazardous chemical containers at the workplace must be clearly labeled,
tagged, or marked in accordance with the Hazard Communication Standard, either with:
• The product identifier, signal word, hazard statement(s), pictogram(s), and precau-
tionary statement(s); or
9/12 HazCom–25

• The product identifier and words, pictures, symbols, or combination thereof, which
provide at least “general” information regarding the hazards of the chemicals, and
which, in conjunction with the other information immediately available to employees
under the Hazard Communication Program, will provide employees with the “spe-
cific” information regarding the physical and health hazards of the hazardous
chemical.
While not required for in-house labeling, the name and address of the manufacturer,
importer, or other responsible party may also be found on the label, tag, or marking because
shipped containers of hazardous chemicals must bear this information. Hazards not other-
wise classified, if any, do not have to be addressed on a container but must be addressed on
the SDS.
Because the product identifier is found on the label, the SDS, and our chemical inventory,
the product identifier links these three sources of information, permitting cross-referencing.
The product identifier used by the supplier may be a common or trade name, a chemical
name, or a number. Employees should be aware that label information can be verified by
referring to the corresponding SDS.
[enter name/title] is responsible for ensuring that all hazardous
chemicals in containers at the workplace have proper labels or other forms of warning that
are legible, in English (although other languages may also be included), and displayed
clearly on the container or readily available in the work area throughout each work shift, as
required. This person will update labels, as necessary. (enter your answer) also ensures that
newly purchased chemicals are checked for labels when containers are received.
[enter name/title] is responsible for ensuring the proper labeling, tag-
ging, or marking of any shipped containers leaving the workplace. These labels, tags, or
marks must provide not only the product identifier, signal word, hazard statement(s),
pictogram(s), and precautionary statement(s) but also the name, address, and telephone
number of the chemical manufacturer, importer, or other responsible party.
A poster is displayed to inform employees about the Hazard Communication Standard. It is
[enter location].
If employees transfer chemicals from a labeled container to a portable, secondary container
that is intended only for their IMMEDIATE use, no labels, tags, or markings are required on
the portable container. Otherwise portable containers must be labeled, tagged, or marked in
accordance with our in-house labeling system for workplace containers.
The in-house labeling system we use for workplace container labeling is:
[enter labeling system].

OSHA also allows for alternatives to labeling, tagging, and marking to convey the required
information, as long as the containers to which the alternative method is applicable are
identified. We use the following alternative method(s) to label, tag, or mark workplace
chemical containers: [enter alternative].
26–HazCom 9/12

Finally, the following procedures are used to review and update label information when nec-
essary, to ensure that labels that fall off or become unreadable are immediately replaced:
[enter procedure].
Training
Everyone who works with or is potentially “exposed” to hazardous chemicals on the job will
receive initial training on the Hazard Communication Standard and the safe use of those
hazardous chemicals before starting work. “Exposure” means that “an employee is subjected
in the course of employment to a chemical that is a physical or health hazard, and includes
potential (e.g., accidental or possible) exposure.”
Whenever a new chemical hazard is introduced or an old hazard changes, additional train-
ing is provided. All training is conducted by [enter name/title].
Effective information and training is a critical part of the Hazard Communication Program.
We train our employees to read and understand the information on labels and SDSs, deter-
mine how the information can be obtained and used in their own work areas, and
understand the risks of exposure to the chemicals in their work areas, as well as ways to
protect themselves. Our goal is to ensure employees know that they are exposed to hazard-
ous chemicals, have the skills to read and use labels and SDSs, and understand how to
appropriately follow the protective measures we have established. We urge our employees to
ask [enter name/title] questions for greater comprehension.
As part of the assessment of the training program, [enter name/title]
asks for input from employees regarding the training they have received and their sugges-
tions for improving it. In this way, we hope to reduce any incidence of chemical-related
illness or injury.
Training Content
The format of the training program used is [enter format].
The training program emphasizes these elements:
• Summary of the Hazard Communication Standard.
• What hazardous chemicals are present in operations in employee work areas.
• Chemical and physical properties of hazardous chemicals (e.g., flash point, reactiv-
ity, etc.) and how to detect the presence or release of these chemicals (including
chemicals in unlabeled pipes).
• Physical hazards of chemicals (e.g., potential for fire, explosion, etc.).
• Health hazards, including signs and symptoms of overexposure, associated with
exposure to chemicals and any medical condition known to be aggravated by expo-
sure to them.
• Any simple asphyxiation, combustible dust, and pyrophoric hazards, as well as haz-
ards not otherwise classified, of chemicals in work areas.
• Any steps the company has taken to reduce or prevent exposure to hazardous
chemicals, such as engineering controls.
9/12 HazCom–27

• Procedures to protect against hazards and exposure (e.g., work practices or methods
to assure proper use and handling of chemicals and any required personal protective
equipment and its proper use and maintenance).
• Procedures for reporting and responding to chemical emergencies.
• How to read and use both the workplace labeling system and labels received on
shipped containers.
• The order of information found on SDSs and how to read the information and what
it means.
• How to access SDSs and the written Hazard Communication Program, including the
chemical inventory.
The procedure to train new employees at the time of their initial assignment is
[enter procedure]. We train employees when a new hazard is
introduced by [enter training method].
Training logs are signed by employees upon completion of their training and are kept by
[enter name/title].
Hazards of Nonroutine Tasks

Periodically, employees are required to perform nonroutine tasks that involve hazardous
chemicals. When employees will be required to perform hazardous nonroutine tasks, such as
[enter nonroutine task], that have the potential to expose employees to
hazardous chemicals, we inform them of these hazards by:
[enter method].
Hazards of Unlabeled Pipes

Work activities are sometimes performed by employees in areas where hazardous chemicals
are transferred through unlabeled pipes. We inform employees of the hazards of chemicals
contained in unlabeled pipes in their work areas by: [enter method].
Multi-Employer Facility
When contractors or any other employers’ workers will be working at this workplace, the
Hazard Communication Program Coordinator, [enter name/title] will:
Provide the other employer(s) as follows with SDSs for any of our hazardous chemicals to
which their employees may be exposed:
[list chemicals].
Relay to other employer(s) as follows all necessary in-house labeling system and precaution-
ary information for normal operations and foreseeable emergencies:
[enter labeling system and precautionary information].

Moreover, it is the responsibility of [enter name/title] to obtain from
each contractor or other employer the appropriate hazard information on chemicals they
bring onsite, including SDSs, the labeling system used, and the precautionary measures to
be taken in working with or near these chemicals.
28–HazCom 9/12

Additional Information
As stated earlier, all employees, or their designated representatives, may obtain further
information on this written program, the Hazard Communication Standard, applicable
SDSs, and the chemical inventory from [enter name/title].
Appendix
We have attached to this written program our chemical inventory and other information to
ensure better understanding of our program.
9/12 HazCom–29

Develop a comprehensive chemical list

The best way to prepare a comprehensive chemical list is to survey your workplace. Your
purchasing records will also provide important information, and you should establish proce-
dures to ensure that, in the future, purchasing procedures result in SDSs being received
before using a chemical.
The broadest possible perspective should be taken when performing the survey. Sometimes
people think of chemicals as being only liquids in containers. The HCS covers chemicals in
all physical forms — liquids, solids, gases, vapors, fumes, and mists — whether they are
contained or not. The hazardous nature of the chemical, and the potential for exposure are
the factors that determine whether a chemical is covered. If it’s not hazardous, it’s not cov-
ered, and if there is no potential for exposure, the rule does not cover the chemical.
Look around. Identify chemicals in containers, including pipes, but also think about chemi-
cals generated in the work operations. For example, welding fumes, dusts, and exhaust
fumes are all sources of chemical exposures. Read labels provided by the suppliers for haz-
ard information, and make a list of all chemicals in the workplace that are potentially
hazardous.
List the names of all hazardous chemicals by using the identity that is referenced on the
MSDS. This identity is often a common name, such as the product or trade name. For your
own information and planning, you may also want to note on the list the location(s) of the
products within the workplace, and an indication of the hazards as found on the label. This
will help you as you prepare the rest of your program.
Maintaining chemical lists

When working with chemicals, be sure that you understand how to find out information
about the chemical using the:
• Chemical name;
• Chemical Abstracts Service (CAS) Registry Number; and
• Chemical synonyms.
Chemical name
The chemical name is any one of many possible terms for a given chemical. Besides chemical
names, there are chemical formulas, such as H2504, trade names, such as Freon, and manu-
facturer names, such as WILSON MIXTURE ABC.
To further complicate the issue, there are even multiple chemical names (synonyms) for
most every chemical. So, when you are investigating a chemical, if you find nothing listed
under the name you have, try another designation for the substance, such as the Chemical
Abstracts Service (CAS) Registry Number.
30–HazCom 9/12

CAS registry number

As soon as it is developed, every chemical has a CAS Registry Number (CAS is a registered
service mark of the American Chemical Society) assigned to it. Each Registry Number desig-
nates only one chemical substance, though there may be more than one synonym; it is
simply an identification number.
CAS number listings are in numerical sequence. If you have a CAS number, you can look it
up to find out what chemical name is being referred to under that number. Then, look up
the chemical name to find out all the regulatory information listed for that chemical.
What does it mean if you look up your CAS Number and discover it is not listed? That could
be good news. It means that the number you have is not specifically listed on any of the
chemical lists. But, does it mean that the substance is not hazardous, or not regulated? Not
necessarily. Many lists do not list every substance that is considered to be hazardous. For
example, RCRA designates certain substances specifically, but then explains that every sub-
stance that meets certain hazardous characteristics, such as corrosiveness, is also regulated.
Chemical synonyms
There is a confusing array of multiple names for each chemical. Each of these additional
names for the same chemical formula is considered to be a synonym, meaning that the same
substance might be referred to under a variety of names by different government agencies.
In some cases, you must use only the chemical name specified. Therefore, it can be difficult
to determine whether or not the chemical that you have is actually covered under a certain
regulation. For example, you may need to look under several different names to discover if
your substance is listed under SARA, Section 313.
9/12 HazCom–31

CHEMICAL INVENTORY LIST
HAZARDOUS CHEMICALS CAS NO. OPERATION /AREA USED (OPTIONAL) MSDSs

ON FILE
© Copyright J.J. Keller & Associates, Inc Neenah, WI USA (800) 327-68688
32–HazCom 9/12

Hazardous chemicals training

OSHA is requiring that employees are trained on the new label elements (e.g., pictograms
and signal words) and SDS format by December 2013, while full compliance with the final
rule will begin in 2015.
An effective training program is a critical component of any workplace safety and health
program, especially when it comes to the safe use and handling of chemicals. Workers who
are fully informed and engaged in the protective measures established by you will play a
significant role in the prevention of adverse health effects. Ineffective training will not serve
the purpose of making workers full participants in the program, and the likelihood of a suc-
cessful program for safety and health in the absence of an effectively trained workforce is
remote.
Be sure to provide appropriate training at all personnel levels; such training will allow
workers to make better judgments about changing hazards in the workplace. Remember
that informed workers are the first line of defense against injuries and fatalities.
Under the Hazard Communication Standard, you must establish an effective training and
information program for every employee routinely exposed to hazardous chemicals in the
work area. This training must be provided at the time of initial assignment, and whenever a
new physical or health hazard is introduced into the work area.
OSHA allows you to train o the hazards of each hazardous chemical in your facility, or to
train on classes of chemical hazard, such as flammables. This allows you some flexibility in
how you train your workers.
The following pages contain training tips for employers along with handout sheets for
employees.
Hazard Communication — An overview
Training tips:
• Review the requirements of 29 CFR 1910.1200;
• Show samples of hazard labels. Use a sample SDS to explain what information is
available on the SDS and where employees can find SDSs in their work areas;
• Tell employees which jobs involved hazardous chemicals; and
• Take a tour of the workplace to show employees where they can access a copy of the
written HazCom program and SDSs.
Employee handout — Hazard Communication

Overview
OSHA’s Hazard Communication Standard (HCS) is based upon the concept that employees
have both a need and a right to know the chemical hazards they may be exposed to in their
work areas, and how they can protect themselves from those hazards.
9/12 HazCom–33

What must the employer do?

Employers must:
• Keep a list of hazardous chemicals in the workplace;
• Prepare and follow a written hazcom program;
• Make sure all chemical containers are properly labeled;
• Make sure safety data sheets (SDSs) are available to employees; and
• Provide training to employees.
What are chemical hazards?
There are two general types of chemical hazards:
• “Physical hazard” which means a chemical that is classified as posing one of the fol-
lowing hazardous effects: explosive; flammable (gases, aerosols, liquids, or solids);
oxidizer (liquid, solid or gas); self-reactive; pyrophoric (liquid or solid); self-heating;
organic peroxide; corrosive to metal; gas under pressure; or in contact with water emits
flammable gas; and
• “Health hazard” which means a chemical which is classified as posing one of the
following hazardous effects: acute toxicity (any route of exposure); skin corrosion or
irritation; serious eye damage or eye irritation; respiratory or skin sensitization; germ
cell mutagenicity; carcinogenicity; reproductive toxicity; specific target organ toxicity
(single or repeated exposure); or aspiration hazard.
A chemical can have both physical and health hazards.
What are your rights?
Under the HCS, you have the right to training about:
• The HCS standard itself;
• Operations in the workplace that use hazardous chemicals;
• The hazards of the chemicals you work with;
• How you can detect a release of those chemicals;
• How you can get a copy of the written HazCom program;
• Where SDSs are located and how you can access them; and
• The labels found on containers of hazardous chemicals.
34–HazCom 9/12

Hazard Communication — Health hazards
Training tips:
• Review the requirements of 29 CFR 1910.1200;
• Explain the types of health hazards employees are likely to be exposed to.
• Train employees on each specific chemical used, or train employees based upon haz-
ard categories (flammable liquids, corrosive material, carcinogens…).
Employee handout — Health hazards

OSHA requires that employees who come into contact with hazardous chemicals be provided
with thorough and accurate information on each hazardous chemical present in the
workplace.
How can it hurt me?
Many chemicals pose health problems to humans. OSHA defines “Health hazards” as those
chemicals which are classified as a health hazard according to one of the GHS criteria:
• acute toxicity (any route of exposure);
• skin corrosion or irritation;
• serious eye damage or eye irritation;
• respiratory or skin sensitization;
• carcinogenicity;
• reproductive toxicity;
• specific target organ toxicity (single or repeated exposure); or
• aspiration hazard.
Hazards are classified by hazard class and category, and this information must be included
on the container label and the SDS.
You can come into contact with chemicals in three ways:
• If they come into contact with your bare skin.
• If they are swallowed, or if you eat or drink contaminated food or drink, or if you eat
with contaminated fingers.
• By breathing in the dust or vapors.
What must my employer do?
Your employer must:
• Develop a written hazard communication plan, and make a copy available to you if you
request one.
9/12 HazCom–35

• Have copies of all SDSs for the chemicals used in your workplace available for you to
look at.
• Train you on chemical safety to be followed in the workplace.
What must I do?
You must:
• Attend chemical hazard training, and ask questions if you don’t understand that
training.
• Know where to find SDSs and understand what information they provide you.
• Follow all workplace chemical safety rules.
Hazard Communication — Labels & Labeling
Training tips:
• Using the employee handout, review the requirements of §1910.1200.
• Explain the location of the company’s written hazard communication program.
• Show a sample label for a hazardous chemical in your workplace. Explain how to
interpret the information on the label.
Employee handout — Labels & Labeling

Exposure to chemicals sometimes poses a threat to health for many workers. The Depart-
ment of Labor estimates that up to 32 million workers are potentially exposed to one or
more chemical hazards.
How can it hurt me?
Chemical exposure may cause or contribute to many serious health effects such as heart ail-
ments; kidney, liver and lung damage; sterility; cancer; and burns and rashes. Some
chemicals may present physical hazards, having the potential to cause fires or explosions.
OSHA developed the Hazard Communication Standard to establish uniform requirements
for informing employees about hazards related to workplace chemicals.
The Hazard Communication standard ensures that the hazards of all chemicals produced
are evaluated, and that information concerning these hazards is transmitted to employers
and employees.
36–HazCom 9/12

Hazard Communication — Safety Data Sheets
Training tips:
• Review the requirements of §1910.1200.
• Explain the location of the Safety Data Sheets (SDSs) and how employees can access
them.
• Go over the format of an SDS and what must be included on it.
Employee handout — Safety Data Sheets

workplace. The revised HazCom standard requires the use of the GHS-compliant, 16-section
Safety Data Sheet (SDS).
Safety Data Sheets must be readily accessible to all employees. Your employer must obtain
or develop an SDS for each hazardous chemical that they produce or use in the workplace.
Your employer will tell you where those SDSs are located in your workplace.
What must be included on an SDS?
OSHA requires that all SDSs, whether printed or electronic, have the following information:
• Section 1, Identification
• Section 2, Hazard(s) identification
• Section 3, Composition/information on ingredients
• Section 4, First-aid measures
• Section 5, Fire-fighting measures
• Section 6, Accidental release measures
• Section 7, Handling and storage
• Section 8, Exposure controls/personal protection
• Section 9, Physical and chemical properties
• Section 10, Stability and reactivity
• Section 11, Toxicological information
• Section 12, Ecological information
• Section 13, Disposal considerations
• Section 14, Transport information
• Section 15, Regulatory information
9/12 HazCom–37

• Section 16, Other information
Why should I consult the SDS?
You should consult the SDS to:
• Determine if symptoms you are experiencing can be attributed to the chemicals.
• Make sure you are using the correct PPE for the chemical.
• Find out if the chemicals you are working with are toxic.
• Verify the information on the label of the container of chemicals you are using.
An awareness of the hazard information on the SDS can mean the difference between safely
working with chemicals, and a chemical tragedy.
Hazard Communication — Other hazards

Training tips
• Train employees on each specific chemical used, or train each employee based upon
hazard categories (flammable liquids, corrosive material, carcinogens).
Employee handout — Other hazards

OSHA defines a “hazardous chemical” as any chemical which is classified as a physical haz-
ard or a health hazard, a simple asphyxiant, pyrophoric gas, combustible dust, or hazard not
otherwise classified.
Simple asphyxiant
“Simple asphyxiant” means a substance or mixture that displaces oxygen in the ambient
atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to
unconsciousness and death.
Pyrophoric gas
“Pyrophoric gas” means a chemical in a gaseous state that will ignite spontaneously in air at
a temperature of 130 degrees F (54.4 degrees C) or below.
Combustible dust
“Combustible dust” is a combustible particulate solid that presents a fire or deflagration haz-
ard when suspended in air or some other oxidizing medium over a range of concentrations,
regardless of particle size or shape..
Hazards Not Otherwise Classified (HNOC)
“Hazard not otherwise classified (HNOC)” refers to a physical or health effect identified
through the classification process that does not meet the GHS criteria for the physical and
health hazard classes, or which falls below the cut-off value/concentration limit of the hazard
38–HazCom 9/12

class or is under a GHS hazard category that has not been adopted by OSHA (e.g., acute
toxicity Category 5).
Hazard Communication — Physical hazards

A hazardous chemical is any chemical which is classified as a physical hazard or a health
hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not otherwise
classified.
Chemical manufacturers, importers, or suppliers are required to evaluate the chemicals they
produce or import to determine the hazard classes and category for each chemical being
evaluated.
“Physical hazard” means a chemical that is classified as posing one of the following hazard-
ous effects:
• explosive;
• flammable (gases, aerosols, liquids, or solids);
• oxidizer (liquid, solid or gas);
• self-reactive;
• pyrophoric (liquid or solid);
• self-heating;
• organic peroxide;
• corrosive to metal;
• gas under pressure; or
• in contact with water emits flammable gas.
Training tips
• Explain the types of hazards employees are likely to be exposed to.
Employee handout — Physical hazards

workplace.
How can it hurt me?
Many chemicals pose health problems to humans. “Physical hazards” are those chemicals
which:
• explosive;
• flammable (gases, aerosols, liquids, or solids);
• oxidizer (liquid, solid or gas);
9/12 HazCom–39

• self-reactive;
• pyrophoric (liquid or solid);
• self-heating;
• organic peroxide;
• corrosive to metal;
• gas under pressure; or
• in contact with water emits flammable gas.
Workers can come into contact with chemicals in three ways:
• through the skin-burning, irritation, or penetration of the skin into the body.
• ingestion-swallowing a chemical by eating contaminated food, or by touching the

mouth or handling food with contaminated fingers.
• inhalation-breathing in toxic dust or vapors.
Safety data sheets
An SDS is available for each product containing hazardous materials in your work area.
SDSs provide information on the hazards, precautions for safe handling and use, emergency
and first aid procedures, and so on.
Hazard labels
Incoming containers of hazardous chemicals must have warning labels. Do not remove or
deface these labels. If chemicals are transferred into unlabeled containers in the workplace,
those containers must be labeled with the chemical’s identity and its hazards.
Your employer must train you on the HazCom standard, and on the in-house labeling sys-
tem being used in your workplace. Be sure you understand how to read hazcom labels before
you use any chemicals.
Your employer must:
• Develop a written hazard communication plan, and make a copy available to you if you
request one.
• Have copies of all SDSs for the chemicals used in your workplace available for you to
look at.
• Train you on chemical safety to be followed in the workplace.
40–HazCom 9/12

Hazard Communication checklist

Many companies find checklists helpful to ensure important items are not overlooked. The
following checklist is a guideline, and not required by the standard. You should tailor the
checklist to your specific operations.
Hazard Communication program checklist
General
❏ Have you developed a written HazCom program?
❏ Have you assigned someone the responsibility of storing the Hazard Communication Program?
❏ Do you have a specific location for the HazCom Program?
Chemical inventory
❏ Have you developed procedures for keeping the chemical inventory current?
❏ Do you have a specific location(s) for the chemical inventory list?
❏ Do you maintain a list of the chemicals you manufacture?
❏ DO you have a method to classify chemicals that you manufacture?
Safety Data Sheets (SDSs)

❏ Have you assigned someone the responsibility of obtaining/maintaining safety data sheets (SDSs)?
❏ Do you have a specific location(s) for the SDSs located at your workplace?
❏ Can employees access SDSs easily?
❏ Have employees been trained in how to find and read SDSs?
❏ Do you have a follow-up procedure if an SDS is not received at the time of the first shipment?
Labeling
❏ Have you appointed someone responsible for making sure containers at the workplace are labeled
properly?
❏ Have you appointed someone responsible for making sure shipped containers are labeled correctly?
❏ Do you have a labeling system to identify in-house hazardous chemicals?
❏ Do you have any labeling alternative (such as signs, placards, process sheets, batch tickets, or
operating procedures for stationary process containers) for in-house containers at your site?
❏ Do you have procedures to review and update label information, when necessary, to ensure that
labels that fall off or become unreadable are immediately replaced?
Training
❏ Do you conduct employee training in hazard communication?
❏ Have you appointed someone responsible for conducting training on hazard communication?
❏ Have you developed criteria to determine which employees will receive training?
❏ Are employees trained on specific hazardous chemicals present or are they trained by hazard
categories (i.e., flammable liquids, carcinogens…)?
❏ Do you provide training for new employees at the time of their initial assignment?
❏ Do you provide training to affected employees when a new chemical hazard is introduced?
❏ Do you provide retraining on an annual or other basis?
9/12 HazCom–41

❏ Do you have employees sign training logs upon completion of their training?
❏ Do you maintain a file for the training logs and monitors whether employee training is up-to-date?
❏ Are wheel chocks for nurse tanks, motor transports, and rail cars available?
Operations
❏ Do your operations involve nonroutine tasks having the potential to expose workers to hazardous
chemicals (e.g., the cleaning of reactor vessels, cleaning tanks, or entering confined spaces)?
❏ Do you have a procedure to inform employees of the hazards of nonroutine tasks?
❏ Do you inform employees of the hazards of chemicals contained in unlabeled pipes in their work
areas?
❏ Is your site a multi-employer site?
❏ Do you provide the other employer(s) with SDSs for any of your chemicals to which their employees
may be exposed?
❏ Do you relay to the other employer(s) any necessary in-house labeling system and precautionary
information for normal operations and foreseeable emergencies?
REACH: registration, evaluation, and authorization of chemicals

REACH is the European Union (EU) regulatory framework for Registration, Evaluation and
Authorization of Chemicals (REACH). REACH was adopted on October 29, 2003 and entered
into force on June 1, 2007.
Under REACH, the chemical manufacturer is responsible for collecting data on most chemi-
cals on the market, assessing the risks of those chemicals, and defining safe uses for the
chemicals down the supply chain. It also requires the chemical user to justify the continued
use of chemicals of “very high concern.”
With REACH, some 30,000 chemicals will need a registration for the EU market and, for the
most dangerous chemicals, an authorization must be obtained prior to using the chemical.
Obligations under REACH will apply not only to chemical companies, but to any business
which uses chemicals and exports products to the EU. Electronics, automotive, cosmetics
and textiles are only a few examples of sectors that will be affected by REACH.
REACH provides the appropriate methodologies, tools, and technical guidance needed to
meet this goal through a number of REACH Implementation Projects (RIPs).
Scope
In principle, REACH applies to all chemicals — not only chemicals used in industrial
processes. It covers chemicals used in all facets of our day-to-day lives, such as cleaning
products and paint, as well as in articles, such as clothing, furniture, and electrical
appliances.
REACH covers all substances whether manufactured, imported, used as intermediates, or
placed on the market, either on their own, in preparations or in articles, unless they are
radioactive, subject to customs supervision, or are non-isolated intermediates. Waste is spe-
cifically exempted. Food is not subject to REACH as it is not a substance, preparation, or
article. Member states may exempt substances used in the interests of defense. Other sub-
stances are exempted from parts of REACH, where other equivalent legislation applies.
42–HazCom 9/12

Objectives
The aims of REACH are to:
• Improve the protection of human health and the environment from the risks that
can be posed by chemicals
• Enhance the competitiveness of the EU chemicals industry, a key sector for the
economy of the EU
• Promote alternative methods for the assessment of hazards of substances
• Ensure the free circulation of substances on the internal market of the European
Union
How does it work?

Under REACH, industry is responsible to manage the risks posed by chemicals and provide
appropriate safety information to their users. It allows the EU to control those chemicals
which are considered to be highly dangerous substances.
REACH also creates the European Chemicals Agency (ECHA) with a central coordination
and implementation role in the overall process.
All manufacturers and importers of chemicals must identify and manage risks linked to the
substances they manufacture and market. For substances produced or imported in quanti-
ties of one tonne or more per year per company, manufacturers and importers need to
demonstrate that they have appropriately done so by means of a registration dossier, which
shall be submitted to the Agency.
Once the registration dossier has been received, the Agency may check that it is compliant
with the Regulation and shall evaluate testing proposals to ensure that the assessment of
the chemical substances will not result in unnecessary testing, especially on animals.
Where appropriate, authorities may also select substances for a broader substance evalua-
tion to further investigate substances of concern.
REACH also foresees an authorization system aiming to ensure that substances of very high
concern are adequately controlled, and progressively substituted by safer substances or tech-
nologies or only used where there is an overall benefit for society of using the substance.
These substances will be prioritized and over time included in Annex XIV. Once they are
included, industry will have to submit applications to the Agency on authorization for con-
tinued use of these substances. In addition, EU authorities may impose restrictions on the
manufacture, use or placing on the market of substances causing an unacceptable risk to
human health or the environment.
Manufacturers and importers must provide their downstream users with the risk informa-
tion they need to use the substance safely. This will be done via the classification and
labeling system and Safety Data Sheets (SDS), where needed.
Substances can be exempted from all or a part of the obligations under REACH.
9/12 HazCom–43

What to do if you import into EU

Non-EU manufacturers and distributors will either:
• Supply information to their customers on all chemical substances which they import
into the EU at or above one tonne, so that the customers may register the chemi-
cals; or
• Appoint a representative or establish a legal entity within the EU to manage the
registration.
What is the timeline for REACH implementation?

June 1, 2007: Entry into force of REACH.
June 1, 2008: European Chemicals Agency becomes operational.
June 1, 2008 to December 1, 2008: Pre-registration of so-called phase-in substances.
November 30, 2010: Registration deadline for substances in quantities of 1000 tonnes and
above as well as carcinogens, mutagens and substances toxic to reproduction (CMR category
1 and 2) above 1 tonne/year and substances classified as very toxic to aquatic organisms
(R50/53) above 100 tonnes.
May 31, 2013: Registration deadline for substances in quantities of 100 tonnes and more.
May 31, 2018: Registration deadline for substances in quantities of 1 tonne and more.
Voluntary registration prior to the deadline is of course possible. Registration dossiers can
be submitted as of June 1, 2008.
New substances need to be registered before they are placed on the market. Their registra-
tion begins June 1, 2008.
Which chemicals will be excluded from REACH?

Substances of low risks such as water, oxygen, noble gases and cellulose pulp are excluded
from registration. Other substances occurring in nature such as minerals, ores, and or con-
centrates as well as cement clinker are also not required to be registered as long as they are
not chemically modified.
There are also exemptions from large parts of REACH for substances in food and medicinal
products because those are regulated in specific legislation. Waste is exempted from REACH
and Member States may exempt substances used in the interests of defense.
If chemical substances used to manufacture other chemical substances are never separated
from the mixture of other chemicals inside a closed system, they are fully exempt from
REACH (non-isolated intermediates). Intermediates that are separated out during the pro-
duction process (isolated intermediates) will have to be registered, but with simplified
information requirements commensurate with their lower risk.
Polymers are for the time being also exempted from registration and evaluation. (However,
its basic constituents, monomers, must be registered; the Commission may also introduce
requirements for the registration of polymers once a practicable and cost-effective way of
44–HazCom 9/12

identifying dangerous polymers on the basis of sound technical and valid scientific criteria
has been established).
Are nanoparticles covered under REACH?

Substances in the nano-scale fall under the scope of REACH and their health and environ-
ment properties must therefore be assessed following the provisions of this regulation.
However, methodologies for identifying hazards and evaluating risks of substances at the
nano-scale need to be further refined over the next few years.
The European Commission is funding research projects to assess the health and environ-
ment impacts of nano particles under the 7th Research Framework Programme. It will also
be necessary to carefully monitor over the next few years whether the threshold for registra-
tion and the information requirements under REACH are adequate to address potential
risks from particles on a nano-scale.
Regulated chemicals
The following table identifies some commonly used chemicals that may be present in your
workplace and their associated hazard ratings. This may be helpful when labeling, cross ref-
erencing, and identifying chemicals. Keep in mind that not all regulated chemicals are
listed.
Chemical Ratings List
CAS # The CAS Registry number is a unique number assigned to a chemical by the
Chemical Abstracts Service.
Tier I/II SARA Threshold Planning Quantities (TPQ). The Superfund Amendments and
Reauthorization Act of 1986 (SARA) required EPA to publish a list of Extremely
Hazardous Substances and establish a threshold planning quantity for each
substance on the list. An entry in the Threshold Planning Quantity field
indicates that the substance appears on EPA’s List of Extremely Hazardous
Substances and their Threshold Planning Quantities. All Threshold Planning
Quantities are in units of 1, 10, 100, 500, 1,000, and 10,000 pounds. Solids are
subject to either of two thresholds (i.e., 500/10,000). If certain high hazard
criteria are met, the lower amount applies.
ACGIH The American Conference of Governmental Industrial Hygienists publishes
threshold limit values (TLVs) which refer to airborne concentrations of
substances under which nearly all workers might be repeatedly exposed day
after day without adverse effects. An entry in this column indicates that the
chemical appears in the ACGIH list.
NTP Each year, the National Toxicology Program (NTP) publishes a document called
the Report on Carcinogens. This document is cited under Hazard
Communication as a list of regulated substances. The most recent report is the
11th report (January 2005). Substances found on the 11th report are indicated
with either a: K–the substance is known to be a human carcinogen, or an R–the
substance is reasonably anticipated to be a human carcinogen. A 2 indicates the
substance will most likely be on the 12th edition of the report.
9/12 HazCom–45

Chemical Ratings List, Continued

IARC The International Agency for Research on Cancer (IARC) Monographs are a
series of authoritative independent assessments by international experts of the
carcinogenic risks posed to humans by a variety of agents, mixtures and
exposures. The IARC field lists the agents, mixtures, or exposures classified as
to their carcinogenic risk to humans in accordance with the procedures adopted
as standard IARC practice. A 1 in this field indicates the substance is
carcinogenic to humans. A 2A indicates the chemical is probably carcinogenic to
humans and a 2B agent indicates the substance is possibly carcinogenic to
humans. A 3 in this field identifies chemicals that are not classifiable as to
carcinogenicity to humans and a 4 is for chemicals that are probably not
carcinogenic to humans.
Sub–Z OSHA uses the Z1, Z2, and Z3 lists in Section 1910.1000 to set permissible
exposure limits (PELs) for a number of chemicals. A “Yes” in the Sub-Z column
indicates that the chemical is on the 1910.1000 list.
Tier I/II
Chemical Name CAS # ACGIH NTP IARC Sub-Z
SARA TPQ
Acetaldehyde 75-07-0 Yes R 2B Yes
Acetic Acid 64-19-7 Yes Yes
Acetic Anhydride 108-24-7 Yes Yes
Acetone 67-64-1 Yes Yes
Acetonitrile 75-05-8 Yes
Acetylene 74-86-2 Yes
Acreylamide 79-06-1 1000 Yes R 2A Yes
lb/10,000 lb
Acrylonitrile 107-13-1 10,000 lb Yes R 2B Yes
Adipic Acid 124-04-9 Yes
Allyl Alcohol 107-18-6 1000 lb Yes Yes
Ammonia (Gas) 7664-41-7 500 lb Yes Yes
Ammonium dichromate 7789-09-5
n-Amyl acetate 628-63-7 Yes
Aniline 62-53-3 1000 lb 3 Yes
Antimony and compounds 7440-36-0 2B Yes
Antimony trioxide 1309-64-4 Yes 2B
Arsenic powders 7440-38-2 Yes 1
Arsenic trioxide 1327-53-3 100 lb/10,000
lb
Arsine 7784-42-1 100 lb Yes
Asbestos 1332-21-4 Yes K 1 Yes
Asphalt fumes 8052-42-4 3
Barium 7440-39-3 Yes
Barium sulfate 7727-43-7 Yes Yes
Benzene 71-43-2 K 1 Yes
Benzine 8030-30-6 Yes Yes
Benzoic acid 65-85-0
Benzoyl chloride 98-88-4 2A
Benzoyl peroxide 94-36-0 3 Yes
46–HazCom 9/12

Tier I/II
SARA TPQ
Benzyl alcohol 100-51-6
Beryllium powders 7440-41-7 K 1 Yes
Bromine 7726-95-6 500 lb Yes Yes
1,3-Butadiene 106-99-0 K 1 Yes
Butane 106-97-8
sec-Butyl acetate 105-46-4 Yes Yes
n-Butyl alcohol 71-36-3 Yes
sec-Butyl alcohol 78-92-2 Yes Yes
tert-Butyl alcohol 75-65-0 Yes Yes
Butyl benzyl phthalate 85-68-7 3
n-Butyl glycidyl ether 2426-08-6 Yes
Butyl lactate 138-22-7 Yes
Butyl methacrylate 97-88-1
Butyraldoxime 110-69-0
Cadmium oxide 1306-19-0 100 lb
Calcium oxide 1305-78-8 Yes Yes
Camphor 76-22-2 Yes Yes
Caprolactam 105-60-2 Yes 4
Carbaryl 63-25-2 3 Yes
Carbon black 1333-86-4 Yes 2B Yes
Carbon dioxide 124-38-9 Yes Yes
Carbon disulfide 75-15-0 10,000 lb Yes
Carbon monoxide 630-08-0 Yes Yes
Carbon tetrachloride 56-23-5 Yes R 2B Yes
Cellulose and compounds 9004-34-6 Yes Yes
Chlorine 7782-50-5 100 lb Yes Yes
Chlorine dioxide 10049-04-4 Yes Yes
Chloroacetaldehyde 107-20-0 Yes Yes
Chloroacetyl Chloride 79-04-9 Yes
Chlorobenzene 108-90-7 Yes Yes
Chloroform 67-66-3 10,000 lb Yes R 2B Yes
Chloropicrin 76-06-2 Yes Yes
2-Chlorostyrene 2039-87-4 Yes
2-Chlorotoluene 95-49-8 Yes
Chlorthanlonil 1897-45-6 2B
Chromium 7440-47-3 3 Yes
Chromium trioxide 1333-82-0
Chrysene 218-01-9 2B
Coal tar pitch (volatiles) 8007-45-2 K 1
Cobalt (metal, dust, fume) 7440-48-4 Yes 2B Yes
Copper (powder) 7440-50-8 Yes Yes
Copper nitrate 3251-23-8
Cresol (All isomers) 1319-77-3 Yes
o-Cresol 95-48-7 1000 lb Yes
Cristobalite (silica, crystalline) 14464-46-1 Yes
9/12 HazCom–47

Tier I/II
SARA TPQ
Cumene 98-82-8 Yes Yes
Cyanamide 420-04-2 Yes
Cycloheximide 66-81-9 100 lb
Cyclohexane 110-82-7 Yes
Cyclohexanol 108-93-0 Yes Yes
Cyclohexanone 108-94-1 3 Yes
Cyclohexene 110-83-8 Yes Yes
Cyclopentadiene 542-92-7 Yes Yes
Cyclopentane 287-92-3 Yes
Diacetone alcohol 123-42-2 Yes Yes
Diborane 19287-45-7 100 lb Yes
1,2-Dibromo-3-chlorpropane 96-12-8 R 2B Yes
Dibutylamine 111-92-2
Dibutyl phosphate 107-66-4 Yes Yes
Dibutyl phthalate 84-74-2 Yes Yes
m-Dichlorobenzene 541-73-1 3
o-Dichlorobenzene 95-50-1 3 Yes
p-Dichlorobenzene 106-46-7 R 2B Yes
3,3 ’ -Dichlorobenzidine 91-94-1 Yes R 2B Yes
Dichloroethane 107-06-2 Yes R 2B Yes
1,2-Dichloroethylene 540-59-0 Yes Yes
Dichloroethyl ether 111-44-4 10,000 lb Yes 3 Yes
1,3-Dichloropropene 542-75-6 R 2B
Dicyclopentadiene 77-73-6 Yes
Diethanolamine 111-42-2 3
Diethylamine 109-89-7 Yes Yes
n,n-Diethylethanolamine 100-37-8 Yes Yes
Diethylene triamine 111-40-0 Yes
Di(2-ethylhexyl)phthalate 117-81-7 Yes 2 3 Yes
Diethyl ketone 96-22-0 Yes
Diethyl phthalate 84-66-2 Yes
Diethyl sulfate 64-67-5 R 2A
Diglicidyl ether 2238-07-5 1000 lb Yes
Diisobutyl ketone 108-83-8 Yes Yes
Diisopropylamine 108-18-9 Yes Yes
Dimethyl acetamide 127-19-5 Yes Yes
Dimethylamine 124-40-3 Yes Yes
n,n-Dimethylethanolamine 108-01-0
Dimethylformamide 68-12-2 3 Yes
1,1-Dimethylhydrazine 57-14-7 1000 lb Yes R 2B Yes
Dimethyl phthalate 131-11-3 Yes Yes
Dinitrobenzene (all isomers) 528-29-0 Yes Yes
Dinitrotoluene 25321-14-6 Yes Yes
Dioctyl phthalate 117-81-7
Dipentene 138-86-3
48–HazCom 9/12

Tier I/II
SARA TPQ
Diphenylamine 122-39-4 Yes
Dipropylene glycol methyl ether 34590-94-8 Yes Yes
Disulfiram 97-77-8 3
2,6-Di-tert-butyl-p-cresol 128-37-0 3
Epichlorohydrin 106-89-8 1000 lb Yes R 2A Yes
1,2-Epoxybutane 106-88-7 2B
Ethane 74-84-0
Ethanolamine 141-43-5 Yes Yes
2-Ethoxyethyl acetate 111-15-9 Yes Yes
Ethyl acetate 141-78-6 Yes Yes
Ethyl acrylate 140-88-5 Yes 2B Yes
Ethyl amyl ketone 541-85-5 Yes Yes
Ethyl benzene 100-41-4 2B Yes
Ethyl bromide 74-96-4 Yes 3 Yes
Ethylene (gas) 74-85-1 3
Ethylene chlorohydrin 107-07-3 500 lb Yes Yes
Ethylenediamine 107-15-3 10,000 lb Yes Yes
Ethylene dibromide 106-93-4 Yes R 2A Yes
Ethylene dichloride 107-06-2 Yes R 2B Yes
Ethylene glycol 107-21-1
Ethylene glycol diethylene ether 629-14-1
Ethylene glycol dinitrate 628-96-6 Yes Yes
Ethylene glycol monobutyl ether 111-76-2 3 Yes
Ethylene glycol monoethyl ether 110-80-5 Yes Yes
Ethylene glycol monoethyl ether 111-15-9 Yes Yes
acetate
Ethylene glycol monomethyl ether 110-49-6 Yes
acetate
Ethylene glycol monomethyl ether 109-86-4 Yes
Ethyleneimine 151-56-4 500 lb Yes 2B Yes
Ethylene oxide 75-21-8 1000 lb K 1 Yes
Ethyl ether 60-29-7 Yes Yes
2-Ethyl hexanol 104-76-7
2-Ethylhexyl acrylate 103-11-7 3
Ethyl mercaptan 75-08-1 Yes Yes
Ethyl silicate 78-10-4 Yes Yes
Formaldehyde 50-00-0 500 lb 2 1 Yes
Formic acid 64-18-6 Yes Yes
Furfuryl alcohol 98-00-0 Yes Yes
Gasoline 8006-61-9 Yes 2B
Glycidol 556-52-5 Yes R 2A Yes
Glycidyl phenyl ether 122-60-1 Yes 2B Yes
Graphite (natural) 7782-42-5 Yes Yes
n-Heptane 142-82-5 Yes Yes
Hexachlorobenzene 118-74-1 Yes R 2B
9/12 HazCom–49

Tier I/II
SARA TPQ
Hexachloroethane 67-72-1 R 2B Yes
Hexafluoroacetone 684-16-2 Yes
Hexamethylene diisocyanate 822-06-0 Yes
n-Hexane 110-54-3 Yes Yes
Hexone 108-10-1 Yes Yes
sec-Hexyl acetate 108-84-9 Yes Yes
Hexylene glycol 107-41-5 Yes
Hydrazine 302-01-2 1000 lb Yes R 2B Yes
Hydrogen bromide 10035-10-6 Yes Yes
Hydrogen cyanide 74-90-8 100 lb Yes Yes
Hydrogen peroxide (90%) 7722-84-1 1000 lb 3 Yes
Hydrogen sulfide 7783-06-4 500 lb Yes Yes
Hydroquinone 123-31-9 500 lb Yes 3 Yes
Hydroxylamine 7803-49-8
Iodine 7553-56-2 Yes Yes
Iron oxide 1309-37-1 Yes 3 Yes
Iron oxide fume 1309-37-1 Yes 3 Yes
Isoamyl acetate 123-92-2 Yes
Isobutane 75-28-5
Isobutyl acetate 110-19-0 Yes Yes
Isobutyl alcohol 78-83-1 Yes Yes
Isobutyl isobutyrate 97-85-8
Isooctyl alcohol 26952-21-6 Yes
Isophorone 78-59-1 Yes Yes
Isophorone diisocyanate 4098-71-9 500 lb Yes
Isopropyl acetate 108-21-4 Yes
Isopropyl alcohol 67-63-0 3 Yes
Isopropylamine 75-31-0 Yes Yes
Isopropyl ether 108-20-3 Yes Yes
Kaolin 1332-58-7 Yes Yes
Lead 7439-92-1 R 2B Yes
Lead chromate 7758-97-6 Yes
Ligroine (VM & P Naphtha)) 8032-32-4 Yes
Linseed oil 8001-26-1
Magnesium carbonate 546-93-0 Yes Yes
Magnesium oxide fume 1309-48-4 Yes Yes
Magnesium silicate 14807-96-6 3
Malathion 121-75-5 3 Yes
Maleic anhydride 108-31-6 Yes
Manganese and compounds 7439-96-5 Yes Yes
Mercury 7439-97-6 3 Yes
Methane 74-82-8
2-Methoxyethanol 109-86-4 Yes
2-Methoxyethyl acetate 110-49-6 Yes
Methyl 2-cyanoacrylate 137-05-3 Yes
50–HazCom 9/12

Tier I/II
SARA TPQ
Methyl acetate 79-20-9 Yes Yes
Methyl acetylene 74-99-7 Yes Yes
Methyl acrylate 96-33-3 3 Yes
Methylal 109-87-5 Yes Yes
Methyl alcohol 67-56-1 Yes Yes
Methylamine 74-89-5 Yes Yes
Methyl amyl alcohol 108-11-2 Yes Yes
Methyl n-amyl ketone 110-43-0 Yes Yes
Methyl bromide 74-83-9 1000 lb 3 Yes
2-Methyl butanol 137-32-6
Methyl butyl ketone 591-78-6 Yes Yes
Methyl chloride 74-87-3 3 Yes
Methylcyclohexane 108-87-2 Yes Yes
Methylcyclohexanol 25639-42-3 Yes Yes
o-Methylcyclohexanone 583-60-8 Yes Yes
Methylene bisphenyl isocyanate 101-68-8 Yes 3 Yes
Methylene chloride 75-09-2 Yes R 2B Yes
4,4 ’ -Methylene dianiline 101-77-9 Yes R 2B Yes
Methyl ethyl ketone 78-93-3 Yes Yes
Methyl isoamyl ketone 110-12-3 Yes Yes
Methyl isobutyl carbinol 108-11-2 Yes Yes
Methyl isobutyl ketone 108-10-1 Yes Yes
Methyl isocyanate 624-83-9 500 lb Yes Yes
Methyl isopropyl ketone 563-80-4 Yes
Methyl mercaptan 74-93-1 500 lb Yes Yes
Methyl methacrylate 80-62-6 3 Yes
Methyl propyl ketone 107-87-9 Yes
Mica 12001-26-2 Yes Yes
Mineral oil 8012-95-1 Yes Yes
Monoethanolamine 141-43-5 Yes Yes
Morpholine 110-91-8 3 Yes
Naphthalene 91-20-3 R 2B Yes
Nickel and inorganic compounds 7440-02-0 R 2B Yes
Nickel II Carbonate 3333-67-3 R
Nickel oxide 1313-99-1 R
Nicotine 54-11-5 100 lb Yes Yes
Nitric acid 7697-37-2 1000 lb Yes
Nitric oxide 10102-43-9 100 lb Yes Yes
Nitrobenzene 98-95-3 10,000 lb R 2B Yes
p-Nitrochlorobenzene 100-00-5 3 Yes
Nitroethane 79-24-3 Yes Yes
Nitrogen dioxide 10102-44-0 100 lb Yes Yes
Nitroglycerin 55-63-0 Yes Yes
Nitromethane 75-52-5 R 2B Yes
1-Nitropropane 108-03-2 Yes Yes
9/12 HazCom–51

Tier I/II
SARA TPQ
2-Nitropropane 79-46-9 Yes R 2B Yes
Nitrous oxide 10024-97-2 Yes
Nonyl phenol 25154-52-3
Octane 111-65-9 Yes Yes
Oil mist 8012-95-1 Yes Yes
Oxalic acid 144-62-7 Yes Yes
Pentaborane 19624-22-7 500 lb Yes Yes
Pentachlorophenol 87-86-5 Yes Yes
Pentaerythritol, PE 115-77-5 Yes Yes
Pentane 109-66-0 Yes
Perchloroethylene 127-18-4 Yes R 2A Yes
Phenol, crystals 108-95-2 500 lb 3 Yes
Phenophthalein 77-09-8 R 2B
Phenothiazine 92-84-2 Yes
p-Phenylenediamine 106-50-3 3 Yes
Phosgene 75-44-5 10 lb Yes Yes
Phosphine 7803-51-2 500 lb Yes Yes
Phosphoric acid 7664-38-2 Yes Yes
Phosphorus (white/yellow) 7723-14-0 100 lb Yes Yes
Phthalic anhydride 85-44-9 Yes Yes
Picric acid 88-89-1 Yes Yes
Pine oil 8002-09-3
Portland cement 65997-15-1 Yes
Potassium hydroxide 1310-58-3 Yes
Propane 74-98-6 Yes
Propanoic acid 79-10-7 3
beta-Propiolactone 57-57-8 500 lb Yes R 2B Yes
Propionic acid 79-09-4 Yes
n-Propyl acetate 109-60-4 Yes Yes
n-Propyl alcohol 71-23-8 Yes
Propylene dichloride 78-87-5 3 Yes
Propylene glycol monomethyl ether 107-98-2 Yes
Propylene imine 75-55-8 10,000 lb Yes R 2B Yes
Propylene oxide 75-56-9 10,000 lb R 2B Yes
n-Propyl nitrate 627-13-4 Yes
Pseudocumene 95-63-6
Pyrethrum 8003-34-7 Yes Yes
Pyridine 110-86-1 3 Yes
Quartz (silica, crystalline) 14808-60-7 1 Yes
Quinone 106-51-4 Yes 3 Yes
Resorcinol 108-46-3 3
Rotenone 83-79-4 Yes Yes
Selenium and compounds 7782-49-2 3
Silica, amorphous fused 60676-86-0 Yes
Silicon 7440-21-3 Yes Yes
52–HazCom 9/12

Tier I/II
SARA TPQ
Silicon carbide 409-21-2 Yes Yes
Silicon dioxide (amorphous silica pre- 112926-00-8 Yes
cipitated)
Silver and compounds 7440-22-4 Yes
Sodium 7440-23-5
Sodium azide 26628-22-8 500 lb Yes
Sodium bisulfite 7681-57-4 Yes
Sodium borate, decahydrate 1303-96-4 Yes
Sodium hydride 7646-69-7
Sodium hydroxide 1310-73-2 Yes Yes
Sodium nitrate 7631-99-4
Stoddard solvent 8052-41-3 Yes Yes
Strychnine 57-24-9 100 lb Yes Yes
Styrene, (stabilized) 100-42-5 Yes 2 2B Yes
Sulfur dioxide (gas) 7446-09-5 500 lb 3 Yes
Sulfuric acid 7664-93-9 1000 lb Yes Yes
Talc 14807-96-6 1
1,1,2,2-Tetrachlorethane 79-34-5 3
Tetrahydrofuran 109-99-9 Yes
Tetramethyl lead 75-74-1 100 lb Yes
Thallium 7440-28-0 Yes
Tin (Powder) 7440-31-5 Yes Yes
Titanium dioxide 13463-67-7 2B Yes
Toluene 108-88-3 3 Yes
Toluene-2, 4-diisocyanate 584-84-9 500 lb Yes R Yes
Toluene diisocyanate (mixed isomers) 26471-62-5 2B
m-Toluidine 108-44-1 Yes
o-Toluidine 95-53-4 R Yes
p-Toluidine 106-49-0 Yes
1,1,2-Trichloro-1,2, 2-trifluoroethane 76-13-1 Yes Yes
1,1,1-Trichloroethane 71-55-6 Yes 3 Yes
Trichloroethylene 79-01-6 R 2A Yes
2,4,5-Trichlorophenoxyacetic Acid 93-76-5 Yes Yes
1,2,3-Trichloropropane 96-18-4 Yes R 2A Yes
Triethanolamine 102-71-6 3
Triethylamine 121-44-8 Yes Yes
Triethylene tetramine 112-24-3
Trimethyl benzene 25551-13-7 Yes
2,4,6-Trinitrotoluene 118-96-7 Yes 3 Yes
Triphenyl phosphate 115-86-6 Yes Yes
Tungsten and compounds 7440-33-7 Yes
Turpentine 8006-64-2 Yes
Uranium 7440-61-1 Yes
Vinyl acetate 108-05-4 1000 lb Yes 2B
Vinyl chloride 75-01-4 K 1 Yes
9/12 HazCom–53

Tier I/II
SARA TPQ
Vinyl toluene 25013-15-4 3 Yes
Warfarin 81-81-2 500 lb Yes Yes
Xylene 1330-20-7 Yes 3 Yes
Xylidine 1300-73-8 Yes Yes
Zinc chloride 7646-85-7 Yes Yes
Zinc oxide 1314-13-2 Yes Yes
HazCom definitions
Article means a manufactured item other than a fluid or particle: (i) which is formed to a
specific shape or design during manufacture; (ii) which has end use function(s) dependent in
whole or in part upon its shape or design during end use; and (iii) which under normal con-
ditions of use does not release more than very small quantities, e.g., minute or trace
amounts of a hazardous chemical (as determined under paragraph (d) of this section), and
does not pose a physical hazard or health risk to employees.
Assistant Secretary means the Assistant Secretary of Labor for Occupational Safety and
Health, U.S. Department of Labor, or designee.
Chemical means any substance, or mixture of substances.
Chemical manufacturer means an employer with a workplace where chemical(s) are pro-
duced for use or distribution.
Chemical name means the scientific designation of a chemical in accordance with the
nomenclature system developed by the International Union of Pure and Applied Chemistry
(IUPAC) or the Chemical Abstracts Service (CAS) rules of nomenclature, or a name that will
clearly identify the chemical for the purpose of conducting a hazard classification.
Classification means to identify the relevant data regarding the hazards of a chemical;
review those data to ascertain the hazards associated with the chemical; and decide whether
the chemical will be classified as hazardous according to the definition of hazardous chemi-
cal in this section. In addition, classification for health and physical hazards includes the
determination of the degree of hazard, where appropriate, by comparing the data with the
criteria for health and physical hazards.
Commercial account means an arrangement whereby a retail distributor sells hazardous
chemicals to an employer, generally in large quantities over time and/or at costs that are
below the regular retail price.
Common name means any designation or identification such as code name, code number,
trade name, brand name or generic name used to identify a chemical other than by its
chemical name.
Container means any bag, barrel, bottle, box, can, cylinder, drum, reaction vessel, storage
tank, or the like that contains a hazardous chemical. For purposes of this section, pipes or
piping systems, and engines, fuel tanks, or other operating systems in a vehicle, are not con-
sidered to be containers.
54–HazCom 9/12

Designated representative means any individual or organization to whom an employee

gives written authorization to exercise such employee’s rights under this section. A recog-
nized or certified collective bargaining agent shall be treated automatically as a designated
representative without regard to written employee authorization.
Director means the Director, National Institute for Occupational Safety and Health, U.S.
Department of Health and Human Services, or designee.
Distributor means a business, other than a chemical manufacturer or importer, which sup-
plies hazardous chemicals to other distributors or to employers.
Employee means a worker who may be exposed to hazardous chemicals under normal oper-
ating conditions or in foreseeable emergencies. Workers such as office workers or bank
tellers who encounter hazardous chemicals only in non-routine, isolated instances are not
covered.
Employer means a person engaged in a business where chemicals are either used, distrib-
uted, or are produced for use or distribution, including a contractor or subcontractor.
Exposure or exposed means that an employee is subjected in the course of employment to
a chemical that is a physical or health hazard, and includes potential (e.g. accidental or pos-
sible) exposure. “Subjected” in terms of health hazards includes any route of entry (e.g.
inhalation, ingestion, skin contact or absorption.)
Flammable means a chemical that falls into one of the following categories:
Aerosol, flammable means an aerosol that, when tested by the method described in 16
CFR 1500.45, yields a flame projection exceeding 18 inches at full valve opening, or a flash-
back (a flame extending back to the valve) at any degree of valve opening;
Gas, flammable means a gas that, at ambient temperature and pressure, forms a flam-
mable mixture with air at a concentration of thirteen (13) percent by volume or less; or a
gas that, at ambient temperature and pressure, forms a range of flammable mixtures with
air wider than twelve (12) percent by volume, regardless of the lower limit;
Liquid, flammable means any liquid having a flash-point below 100° F (37.8° C), except
any mixture having components with flashpoints of 100° F (37.8° C) or higher, the total of
which make up 99 percent or more of the total volume of the mixture.
Solid, flammable means a solid, other than a blasting agent or explosive as defined
in§1910.109(a) , that is liable to cause fire through friction, absorption of moisture, sponta-
neous chemical change, or retained heat from manufacturing or processing, or which can be
ignited readily and when ignited burns so vigorously and persistently as to create a serious
hazard. A chemical shall be considered to be a flammable solid if, when tested by the method
described in 16 CFR 1500.44, it ignites and burns with a self-sustained flame at a rate
greater than one-tenth of an inch per second along its major axis.
Flashpoint means the minimum temperature at which a liquid gives off a vapor in suffi-
cient concentration to ignite when tested as follows:
(i) Tagliabue Closed Tester (See American National Standard Method of Test for Flash Point
by Tag Closed Tester, Z11.24-1979 (ASTM D 56-79)) for liquids with a viscosity of less than
45 Saybolt Universal Seconds (SUS) at 100° F (37.8° C), that do not contain suspended sol-
ids and do not have a tendency to form a surface film under test; or
(ii) Pensky-Martens Closed Tester (See American National Standard Method of Test for
Flash Point by Pensky-Martens Closed Tester, Z11.7-1979 (ASTM D 93-79)) for liquids with
9/12 HazCom–55

a viscosity equal to or greater than 45 SUS at 100° F (37.8° C), or that contain suspended
solids, or that have a tendency to form a surface film under test; or
(iii) Setaflash Closed Tester (see American National Standard Method of Test for Flash Point
by Setaflash Closed Tester (ASTM D 3278-78)). Organic peroxides, which undergo
autoaccelerating thermal decomposition, are excluded from any of the flashpoint determina-
tion methods specified above.
Foreseeable emergency means any potential occurrence such as, but not limited to, equip-
ment failure, rupture of containers, or failure of control equipment which could result in an
uncontrolled release of a hazardous chemical into the workplace.
Gases under pressure means any potential occurrence such as, but not limited to, equip-
ment failure, rupture of containers, or failure of control equipment which could result in an
uncontrolled release of a hazardous chemical into the workplace.
Hazard category means the division of criteria within each hazard class, e.g., oral acute
toxicity and flammable liquids include four hazard categories. These categories compare haz-
ard severity within a hazard class and should not be taken as a comparison of hazard
categories more generally.
Hazard class means the nature of the physical or health hazards, e.g., flammable solid, car-
cinogen, oral acute toxicity.
Hazard not otherwise classified (HNOC) means an adverse physical or health effect
identified through evaluation of scientific evidence during the classification process that does
not meet the specified criteria for the physical and health hazard classes addressed in this
section. This does not extend coverage to adverse physical and health effects for which there
is a hazard class addressed in this section, but the effect either falls below the cut-off value/
concentration limit of the hazard class or is under a GHS hazard category that has not been
adopted by OSHA (e.g., acute toxicity Category 5).
Hazard statement means a statement assigned to a hazard class and category that
describes the nature of the hazard(s) of a chemical, including, where appropriate, the degree
of hazard.
Hazardous chemical means any chemical which is classified as a physical hazard or a
health hazard, a simple asphyxiant, combustible dust, pyrophoric gas, or hazard not other-
wise classified.
Health hazard means a chemical which is classified as posing one of the following hazard-
ous effects: acute toxicity (any route of exposure); skin corrosion or irritation; serious eye
damage or eye irritation; respiratory or skin sensitization; germ cell mutagenicity; carcinoge-
nicity; reproductive toxicity; specific target organ toxicity (single or repeated exposure); or
aspiration hazard. The criteria for determining whether a chemical is classified as a health
hazard are detailed in Appendix A to §1910.1200-Health Hazard Criteria.
Immediate use means that the hazardous chemical will be under the control of and used
only by the person who transfers it from a labeled container and only within the work shift
in which it is transferred
Importer means the first business with employees within the Customs Territory of the
United States which receives hazardous chemicals produced in other countries for the pur-
pose of supplying them to distributors or employers within the United States.
56–HazCom 9/12

Label means an appropriate group of written, printed or graphic information elements con-
cerning a hazardous chemical that is affixed to, printed on, or attached to the immediate
container of a hazardous chemical, or to the outside packaging.
Label elements means the specified pictogram, hazard statement, signal word and precau-
tionary statement for each hazard class and category.
Mixture means a combination or a solution composed of two or more substances in which
they do not react.
Physical hazard means a chemical that is classified as posing one of the following hazard-
ous effects: explosive; flammable (gases, aerosols, liquids, or solids); oxidizer (liquid, solid or
gas); self-reactive; pyrophoric (liquid or solid); self-heating; organic peroxide; corrosive to
metal; gas under pressure; or in contact with water emits flammable gas. See Appendix B to
§1910.1200-Physical Hazard Criteria
Pictogram means a composition that may include a symbol plus other graphic elements,
such as a border, background pattern, or color, that is intended to convey specific informa-
tion about the hazards of a chemical. Eight pictograms are designated under this standard
for application to a hazard category.
Precautionary statement means a phrase that describes recommended measures that
should be taken to minimize or prevent adverse effects resulting from exposure to a hazard-
ous chemical, or improper storage or handling.
Produce means to manufacture, process, formulate, blend, extract, generate, emit, or
repackage.
Product identifier means the name or number used for a hazardous chemical on a label or
in the SDS. It provides a unique means by which the user can identify the chemical. The
product identifier used shall permit cross-references to be made among the list of hazardous
chemicals required in the written hazard communication program, the label and the SDS.
Pyrophoric gas means a chemical in a gaseous state that will ignite spontaneously in air
at a temperature of 130 degrees F (54.4 degrees C) or below.
Responsible party means someone who can provide additional information on the hazard-
ous chemical and appropriate emergency procedures, if necessary.
Safety data sheet (SDS) means written or printed material concerning a hazardous chemi-
cal that is prepared in accordance with paragraph (g) of this section.
Signal word means a word used to indicate the relative level of severity of hazard and
alert the reader to a potential hazard on the label. The signal words used in this section are
“danger” and “warning.” “Danger” is used for the more severe hazards, while “warning” is
used for the less severe.
Simple asphyxiant means a substance or mixture that displaces oxygen in the ambient
atmosphere, and can thus cause oxygen deprivation in those who are exposed, leading to
unconsciousness and death.
Specific chemical identity means the chemical name, Chemical Abstracts Service (CAS)
Registry Number, or any other information that reveals the precise chemical designation of
the substance.
Substance means chemical elements and their compounds in the natural state or obtained
by any production process, including any additive necessary to preserve the stability of the
product and any impurities deriving from the process used, but excluding any solvent which
9/12 HazCom–57

may be separated without affecting the stability of the substance or changing its
composition.
Trade secret means any confidential formula, pattern, process, device, information or com-
pilation of information that is used in an employer’s business, and that gives the employer
an opportunity to obtain an advantage over competitors who do not know or use it. Appendix
E to §1910.1200-Definition of Trade Secret, sets out the criteria to be used in evaluating
trade secrets.
Use means to package, handle, react, emit, extract, generate as a byproduct, or transfer.
Work area means a room or defined space in a work-place where hazardous chemicals are
produced or used, and where employees are present.
Workplace means an establishment, job site, or project, at one geographical location con-
taining one or more work areas.
Reference information for HazCom/GHS

More information, along with the official text of the completed system, can be found on the
United Nations Economic Commission for Europe (UNECE) website at www.unece.org/trans/
danger/publi/ghs/ghs_rev04/04files_e.html.
Also, the UNECE website for GHS implementation can be found at www.unece.org/trans/
danger/publi/ghs/implementation_e.html.
A PowerPoint® presentation that provides an overview of the GHS is also available (143
KB). The GHS includes harmonized criteria for classification of physical and health hazards;
labeling elements, including harmonized symbols, hazard warning statements, and signal
words for each type of hazard; and a harmonized format for safety data sheets.
The UN has established a Subcommittee of Experts on the Globally Harmonized System for
Classification and Labeling to implement and maintain the GHS. OSHA represents the US
in these discussions. Information about the deliberations of this Subcommittee may be found
at www.unece.org/trans/main/dgdb/dgsubc4/c4age.html.
In addition, the UN has included historical information about the development of the GHS
at www.unece.org/trans/danger/publi/ghs/ghs_welcome_e.html.
Report on Chemicals from the 3rd Joint US/EU Conference on Occupational Safety and
Health (October 2003) which proposes a pilot project related to the GHS at www.useuosh.
org/conference2003/proceedings/topic01.html.
Information on other U.S. agencies’ websites Department of Transportation (DOT) at
hazmat.dot.gov/regs/intl/globharm.htm;
Environmental Protection Agency (EPA) at www.epa.gov/oppfead1/international/
globalharmon.htm.
Other international organizations involved Organization for Economic Cooperation and
Development at www.oecd.org/;
International Labor Organization at www.ilo.org/public/english/protection/safework/ghs/
index.htm.
58–HazCom 9/12

Canadian requirements Canadian Centre for Occupational Health and Safety at www.
ccohs.ca/oshanswers/legisl/intro_whmis.html;
Government of Canada at www.hc-sc.gc.ca/ewh-semt/occup-travail/whmis-simdut/index_e.
html/index.htm;
Manitoba Education and Training at www.edu.gov.mb.ca/k12/docs/support/scisafe/chapter5.
html.
European requirements European Chemical Agency at echa.europa.eu/;
European Agency for Safety and Health at Work at europe.osha.eu.int/legislation/index2.stm;
Government of the United Kingdom at www.hse.gov.uk/chip/index.htm
Classification, packaging and labeling of dangerous substances at europa.eu/legislation_
summaries/consumers/product_labelling_and_packaging/l21276_en.htm.
Australian requirements National Occupational Health & Safety Commission at www.
worksafe.wa.gov.au/newsite/worksafe/default.html.
9/12 HazCom–59

Reserved
60–HazCom 9/12

STORAGE TANKS
CONTENTS
Overview ......................................................................................................... 1
Exemptions from the UST regulation...................................................................... 2
Federal and technical requirements for USTs ........................................................... 2
Financial responsibility regulations ........................................................................ 2
How to demonstrate financial responsibility ....................................................... 3
Records of financial responsibility coverage ........................................................ 3
Costs of demonstrating financial responsibility.................................................... 4
How state financial assurance funds help .......................................................... 4
Operation and maintenance of UST systems............................................................. 4
Correct filling practices ................................................................................. 4
Operation and maintenance of corrosion protection .............................................. 5
Tank and piping installation................................................................................. 6
Leak detection................................................................................................... 7
Leak detection methods ................................................................................. 7
Selecting the proper leak detection method ........................................................ 9
Preventing releases from USTs ............................................................................ 11
Spill protection .......................................................................................... 12
Overfill protection....................................................................................... 12
Corrosion protection .................................................................................... 13
Spill cleanup ................................................................................................... 14
Closing underground storage tanks....................................................................... 14
Temporary closings ..................................................................................... 14
Permanent closings..................................................................................... 15
Recordkeeping requirements ............................................................................... 15
What records must you keep? ........................................................................ 15
40 CFR 280.34 Reporting and recordkeeping..................................................... 16
Operator training requirements ........................................................................... 17
What is operator training?............................................................................ 17
What UST systems do these guidelines apply to? ............................................... 17
How does a state implement these guidelines? .................................................. 17
Who is subject to operator training requirements and what are the requirements?..... 18
Class A operator......................................................................................... 18
Class B operator ........................................................................................ 19
Class C operator ........................................................................................ 20
Phase-in schedule ....................................................................................... 20
What training approaches would meet operator training requirements? .................. 21
How may states ensure all operators are trained? .............................................. 21
What enforcement authority must states have for operator training? ...................... 21
How will states demonstrate compliance with these guidelines? ............................ 22
State UST/LUST program links and operator training links ................................. 22
9/12 Storage tanks TOC–1

Aboveground storage tanks (ASTs) ....................................................................... 24

ASTs and SPCC ......................................................................................... 25
Audit Checklists............................................................................................... 26
UST Audit Checklist ................................................................................... 26
AST Audit Checklist.................................................................................... 26
2–Storage tanks TOC 9/12

Overview
An underground storage tank (UST) system is a tank, and any underground piping con-
nected to the tank, that has at least 10 percent of its combined volume underground. The
federal UST regulations apply only to underground tanks and piping storing either petro-
leum or certain hazardous substances.
The U.S. Environmental Protection Agency (EPA) estimates that there are about 1.2 million
federally regulated USTs buried at over 500,000 sites nationwide. Nearly all USTs at these
sites contain petroleum. These sites include marketers who sell gasoline to the public (such
as service stations and convenience stores), and nonmarketers who use tanks solely for their
own needs (such as fleet service operators and local governments).
EPA estimates there are about 600,000 tanks holding hazardous substances covered by the
UST regulations.
Until the mid-1980s, most USTs were made of bare steel, which is likely to corrode over
time and allow UST contents to leak into the environment. Faulty installation or inadequate
operating and maintenance procedures also can cause USTs to release their contents into
the environment. The greatest potential hazard from a leaking UST is that the petroleum or
other hazardous substance can seep into the soil and contaminate groundwater, the source
of drinking water for nearly half of all Americans. A leaking UST can present other health
and environmental risks, including the potential for fire and explosion.
In 1984, Congress responded to the increasing threat to groundwater posed by leaking USTs
by adding Subtitle I to the Resource Conservation and Recovery Act (RCRA). Subtitle I
required EPA to develop a comprehensive regulatory program for USTs storing petroleum or
certain hazardous substances. Congress directed EPA to publish regulations that would
require owners and operators of new tanks and tanks already in the ground to prevent,
detect, and clean up releases. At the same time, Congress banned the installation of unpro-
tected steel tanks and piping beginning in 1985.
3/12 Storage tanks–1

In 1986, Congress amended Subtitle I of RCRA and created the Leaking Underground Stor-
age Tank Trust Fund, which is to be used for two purposes:
• To oversee cleanups by responsible parties; and
• To pay for cleanups at sites where the owner or operator is unknown, unwilling, or
unable to respond, or which require emergency action.
The 1986 amendments also established financial responsibility requirements. Congress
directed EPA to publish regulations that would require UST owners and operators to demon-
strate they are financially capable of cleaning up releases and compensating third parties for
resulting damages.
Exemptions from the UST regulation

The following USTs are excluded from regulation and, therefore, do not need to meet federal
requirements for USTs:
• Farm and residential tanks of 1,100 gallons or less capacity holding motor fuel used
for noncommercial purposes;
• Tanks storing heating oil used on the premises where it is stored;
• Tanks on or above the floor of underground areas, such as basements or tunnels;
• Septic tanks and systems for collecting storm water and wastewater;
• Flow-through process tanks;
• Tanks of 110 gallons or less capacity; and
• Emergency spill and overfill tanks.
Federal and technical requirements for USTs

In 1988, EPA issued regulations setting minimum standards for new tanks and requiring
owners of existing tanks to upgrade, replace, or close them. The UST regulations are divided
into three sections: technical requirements, financial responsibility requirements, and state
program approval objectives.
EPA’s technical regulations for USTs are designed to reduce the chance of releases from
USTs, detect leaks and spills when they do occur, and secure a prompt cleanup. To meet the
requirements, owners must have upgraded, replaced, or closed existing UST systems by
1998. Tanks remaining in operation must have leak detection and leak prevention
components. UST owners and operators are responsible for reporting and cleaning up any
releases. For more information, refer to the subsections on Preventing Releases, Detecting
Releases, and Cleaning Up Releases in this chapter.
Financial responsibility regulations

The financial responsibility regulations ensure that, in the event of a leak or spill, an owner
or operator will have the resources to pay for costs associated with cleaning up releases, and
for compensating third parties.
2–Storage tanks 3/12

When Congress amended Subtitle I of the Resource Conservation and Recovery Act in 1986,
it directed EPA to develop financial responsibility regulations for owners and operators of
underground storage tanks. Congress wanted owners and operators of USTs to show that
they have the financial resources to clean up a site if a release occurs, correct environmental
damage, and compensate third parties for injury to their property or themselves. The
amount of coverage required depends on the type and size of the business.
How to demonstrate financial responsibility

There are several ways to demosntrate financial responsibility:
Use state financial assurance funds. The state may pay for some cleanup and third-
party liability costs.
Obtain insurance coverage. Insurance may be available from a private insurer or a
risk retention group.
Obtain a guarantee. Secure a guarantee for the coverage amount from another firm.
The provider of the guarantee has to pass a financial test.
Obtain a surety bond. A surety bond is a guarantee by a surety company that it will
meet the UST owner’s financial responsibility obligations.
Obtain a letter of credit. A letter of credit is a contract involving the UST owner, an
issuer (usually a bank), and a third party (such as the implementing agency) that obli-
gates the issuer to help demonstrate financial responsibility.
Pass a financial test. If a firm has a tangible net worth of at least $10 million, it can
prove its financial responsibility by passing one of the two financial tests.
Set up a trust fund. A UST owner may set up a fully-funded trust fund administered by
a third party to demonstrate financial responsibility.
Use other state methods. A UST owner may also use any additional methods of cover-
age approved by the state.
Local governments have four additional compliance methods tailored to their special charac-
teristics: a bond rating test, a financial test, a guarantee, and a dedicated fund.
Records of financial responsibility coverage

Owners must keep at the UST site or place of business the following records of financial
responsibility coverage:
• A current “Certification of Financial Responsibility”
• Any additional documentation that shows your financial responsibility method is
valid and provides details on the method’s coverage, such as signed copies of official
letters, policies, and state fund agreements.
Records must be kept until the UST site is properly closed. in addition, many states require
copies of financial responsibility records with the state agency. EPA does not require UST
owners to report financial responsibity records unless it specifically asks them to do so.

Costs of demonstrating financial responsibility

EPA acknowledges that the cost of complying with the technical and financial responsibility
requirements will be a burden to some owners and operators, especially those with older
tanks. Because underwriting criteria for most private insurance and eligibility requirements
for some state assurance funds require that tanks be in compliance with federal or state
technical standards, many owners and operators are faced with the costs of meeting techni-
cal requirements at the same time they meet financial responsibility costs.
The cost of meeting technical requirements generally accounts for the majority of regulatory
compliance costs incurred by UST owners and operators. Some states have established
financial assistance programs that can provide funds or low-interest loans to help owners
meet technical requirements.
In terms of the costs for meeting financial responsibility requirements, insurance premiums
for a facility with three to five upgraded tanks may range from about $1,000 to $1,500 per
year. Owners and operators who participate in a state financial assurance fund generally
pay annual tank fees of from $100 to $250 per tank.
How state financial assurance funds help

Many states have developed financial assurance funds to reduce the economic hardship of
compliance with financial responsibility requirements, and to help cover the costs of
cleanups. State financial assurance fund programs, which supplement, or are a substitute
for private insurance, have been especially useful for small-to-medium sized petroleum
marketers. Other characteristics of the funds appear below:
• Financial assurance funds are created by state legislation, and must be submitted to
EPA for approval before they can be used as compliance mechanisms.
• In most cases, states generate money for the funds with tank registration and petro-
leum fees.
• Legislatures delegate authority for the fund to a state agency addressing health,
environmental, or insurance issues.
• Some state assurance funds incorporate eligibility requirements, such as demonstra-
tions that facilities are in compliance with technical requirements.
• Most state funds contain some deductible that the owner or operator is responsible
for paying. Details on the funds are specific to each state.
• Nationwide, these state funds raise about $1 billion annually.
Operation and maintenance of UST systems

Proper tank management includes regular performance of operation and maintenance
duties. These duties include operation and maintenance of corrosion protection as well as
ensuring that correct filling procedures are followed.
Correct filling practices

Many releases at UST sites come from spills; spills often occur at the fill pipe when the
delivery truck’s hose is disconnected. Although these spills are usually small, repeated small

releases can cause big environmental problems. Human error causes most spills; these mis-
takes can be avoided by following standard tank filling practices. For example, you must
make sure there is room in the UST for the delivery, and the delivery driver must watch the
delivery at all times. If you and the delivery driver follow standard practices, nearly all
spills can be prevented. For this reason, federal UST regulations require that you follow
standard filling practices.
If a UST never receives more than 25 gallons at a time, the UST does not have to meet the
spill protection requirements. Many small used oil tanks fall into this category.
Operation and maintenance of corrosion protection

Federal regulations (40 CFR Part 280.31) outline what owners and operators must do to
properly comply with requirements for operation and maintenance of corrosion protection.
All owners and operators of steel UST systems with corrosion protection must comply with
the following requirements to ensure that releases due to corrosion are prevented for as long
as the UST system is used to store regulated substances:
• All corrosion protection systems must be operated and maintained to continuously
provide corrosion protection to the metal components of that portion of the tank and
piping that routinely contain regulated substances.
• All UST systems equipped with cathodic protection systems must be inspected for
proper operation by a qualified cathodic protection tester in accordance with the fol-
lowing requirements:
❍ Frequency. All cathodic protection systems must be tested within 6 months
of installation, and at least every 3 years thereafter, or according to another
reasonable time frame established by the implementing agency; and
❍ Inspection criteria. The criteria used to determine that cathodic protection is
adequate as required by this section must be in accordance with a code of
practice developed by a nationally recognized association.
Note: National Association of Corrosion Engineers Standard RP-02-85, Control of External
Corrosion on Metallic Buried, Partially Buried, or Submerged Liquid Storage Systems, may
be used to comply with paragraph (b)(2) of this section.
• UST systems with impressed current cathodic protection systems must also be
inspected every 60 days to ensure the equipment is running properly.
• For UST systems using cathodic protection, records of the operation of the cathodic
protection must be maintained (in accordance with §280.34) to demonstrate compli-
ance with the performance standards in this section. These records must provide the
following:
❍ The results of the last three inspections required in paragraph (c) of 280.31;
and
❍ The results of testing from the last two inspections required in paragraph
(b) of 280.31.

Tank and piping installation

If you installed a UST system after December 22, 1988, it must meet the requirements for
correct installation, leak detection, and spill, overfill, and corrosion protection. UST systems
must be correctly installed. Some states may require that UST installers be certified (in
addition to being qualified) to conduct this type of work. Check with your state or territorial
UST program to be sure that you follow the appropriate regulations.
Installation problems result from careless installation practices that do not follow standard
industry codes and procedures. Improper installation is a significant cause of fiberglass-
reinforced plastic (FRP) and steel UST failures, particularly piping failures. Installation
includes excavation, tank system siting, burial depth, tank system assembly, backfilling
around the tank system, and surface grading.
Many mistakes can be made during installation. For example, mishandling of the tank dur-
ing installation can cause structural failure of FRP tanks or damage to steel tank coatings
and cathodic protection. Improper layout of piping runs, incomplete tightening of joints,
inadequate cover pad construction, and construction accidents can lead to failure of delivery
piping.
You need to make sure that installers carefully follow the correct installation procedures
called for by industry codes. Additional information on these industry codes should be
obtained from the appropriate trade association.
Federal regulations for installation of tanks and piping (40 CFR Part 280.20 (d) and (e))
require that:
1. All tanks and piping must be properly installed in accordance with a code of practice
developed by a nationally recognized association of independent testing laboratory
and in accordance with manufacturer’s instructions; and
2. Certification on a notification form that one or more of the following methods of cer-
tification, testing, or inspection is used to demonstrate compliance with 1. above:
• the installer has been certified by the tank and piping manufacturers; or
• the installer has been certified or licensed by the implementing agency; or
• the installation has been inspected and certified by a registered professional
engineer with education and experience in UST system installation; or
• the installation has been inspected and approved by the implementing
agency; or
• all work listed in the manufacturer’s installation checklists has been com-
pleted; or
• the owner and operator have complied with another method for ensuring
compliance with paragraph (d) of that which is determined by the imple-
menting agency to be no less protective of human health and the
environment.

Leak detection
EPA designed part of the technical regulations for USTs to make sure releases or leaks from
USTs are discovered quickly before contamination spreads from the UST site. Owners and
operators are responsible for detecting leaks from their tanks and piping.
All USTs must now have leak detection. USTs installed after December 22, 1988 must have
leak detection when they are installed. USTs installed before December 22, 1988 had compli-
ance deadlines that varied with the age of the USTs. By December 22, 1993, all of these
older USTs had to be in compliance with leak detection requirements.
Leak detection methods

Owners and operators of petroleum USTs must use at least one of the seven leak detection
methods below (and as illustrated in Figure 1), or other methods approved by their state
agency.
Secondary containment and interstitial monitoring

This involves placing a barrier between the UST and the environment. The barrier provides
“secondary” containment and can be a vault, liner, or double-walled structure. Leaked prod-
uct from the UST is directed toward a monitor located in the “interstitial” space between the
UST and the outer barrier. Interstitial monitoring methods range from a simple dip stick to
automated vapor or liquid sensors permanently installed in the system. New USTs holding
hazardous substances must use this method.
Automatic tank gauging (ATG) systems

ATGs use monitors permanently installed in the tank. These monitors are linked electroni-
cally to a nearby control device to provide information on product level and temperature.
During a test period of several hours when nothing is put into or taken from the tank, the
gauging system automatically calculates the changes in product volume that can indicate a
leaking tank. This method does not work on piping.
Vapor monitoring
Vapor monitors sense and measure product vapor in the soil around the tank and piping to
determine the presence of a leak. This method requires installation of carefully placed moni-
toring wells.
Vapor monitoring can be performed periodically using manual devices, or continuously using
permanently installed equipment.
Groundwater monitoring
Groundwater monitoring devices sense the presence of liquid product floating on the
groundwater. This method requires installation of monitoring wells at strategic locations in
the ground near the tank and along the piping runs. To discover if leaked product has
reached groundwater, these wells can be checked periodically by hand, or continuously with
permanently installed equipment. This method is effective only at sites where groundwater
is within 20 feet of the surface.

Figure 1. Leak Detection Methods for Tanks and Piping

Statistical inventory reconciliation (SIR)
SIR uses sophisticated computer software to determine whether a tank system is leaking.
The computer conducts a statistical analysis of inventory, delivery, and dispensing data col-
lected over a period of time, and provided by the operator to a vendor.
Manual tank gauging

Manual tank gauging can be used only on tanks 2,000 gallons or smaller. This method does
NOT work on tanks larger than 2,000 gallons or on piping. This method requires taking the
tank out of service for at least 36 hours each week to take measurements of the tank’s
contents. Tanks 1,000 gallons or less can use this method alone. Tanks from 1,001 to 2,000
gallons can use this method only when it is combined with periodic tank tightness testing,
and only for 10 years after installation or upgrade of the UST. After 10 years, these USTs
must use one of the leak detection methods.
Tank tightness testing and inventory control

This method can be used temporarily at petroleum UST sites, and is a combination of two
methods. Tank tightness testing requires periodic tests conducted by vendors who temporar-
ily install special equipment that tests the soundness of the tank.
Tank tightness testing must be used in combination with inventory control. Inventory con-
trol is an ongoing accounting system, like a checkbook, kept by the UST owner or operator

to detect leaks. Inventory control requires taking daily accurate measurements of the tank’s
contents, and performing monthly calculations to prove that the system is not leaking. Tank
tightness testing and inventory control can be used only for 10 years after installation or
upgrade of a UST. After 10 years, these USTs must use one of the previously described leak
detection methods.
Selecting the proper leak detection method

There is no one leak detection system that is best for all sites, nor is there a particular type
of leak detection that is consistently the least expensive. Each leak detection method has
unique characteristics. For example, vapor detection devices work rapidly, and are most
effective in porous soils, while liquid detectors are only appropriate for areas with a high
water table.
Identifying the best leak detection choice for your UST depends on a number of factors,
including cost (both initial installation cost and long-term operation and maintenance cost),
facility configuration (such as complexity of piping runs and manifolded tanks), groundwater
depth, soil type, seasonal rainfall and temperature ranges, availability of experienced
installers, and other variables.
Look for experienced, professional vendors and installers of leak detection, and ask ques-
tions that will help you find the most reliable, cost-effective leak detection for your type of
facility. Some possible information sources are: references from fellow UST owners, oil mar-
keters, equipment suppliers, trade journals, trade associations, state and local trade
associations (especially those for petroleum marketers and UST owners), and state and local
regulatory authorities. Your state may also have an assistance fund that may be able to help
you pay for your UST’s leak detection.
Monitoring vapors in the soil

This method samples vapors in the soil gas surrounding the UST. Leaked petroleum pro-
duces vapors that can be detected in the soil gas. The regulations describe several
requirements for using this leak detection method. For example, this method requires using
porous soils in the backfill and locating the monitoring devices in these porous soils near the
UST system.
Features of vapor monitoring systems include the following:
• Vapor monitoring senses or measures vapors from leaked product in the soil around
the tank to determine if the tank is leaking.
• Fully automated vapor monitoring systems have permanently installed equipment
to continuously or periodically gather and analyze vapor samples, and to respond to
a release with a visual or audible alarm.
• Manually operated vapor monitoring systems range from equipment that immedi-
ately analyzes a gathered vapor sample to devices that gather a sample that must
be sent to a laboratory for analysis. Monitoring results from manual systems are
generally less accurate than those from automated systems. Manual systems must
be used at least once a month to monitor a site.
• All vapor monitoring devices should be periodically calibrated according to the
manufacturer’s instructions to ensure that they are properly responding.

• Before installation, a site assessment is necessary to determine the soil type,

groundwater depth and flow direction, and the general geology of the site. This can
only be done by a trained professional.
• The number of wells and their placement is very important. Only an experienced
contractor can properly design and construct an effective monitoring well system.
Vapor monitoring requires the installation of monitoring wells within the tank
backfill. A minimum of two wells is recommended for a single tank excavation.
Three or more wells are recommended for an excavation with two or more tanks.
Some state and local agencies have developed regulations for monitoring well
placement.
Vapor monitoring regulatory requirements

• The UST backfill must be sand, gravel, or another material that will allow the
vapors to easily move to the monitor.
• The backfill should be clean enough that previous contamination does not interfere
with the detection of a current leak.
• The substance stored in the UST must vaporize easily so that the vapor monitor can
detect a release.
• High ground water, excessive rain, or other sources of moisture must not interfere
with the operation of vapor monitoring for more than 30 consecutive days.
• Monitoring wells must be secured and clearly marked.
Before installing a vapor monitoring system, a site assessment must be done to determine
whether vapor monitoring is appropriate at the site. A site assessment usually includes at
least a determination of the groundwater level, background contamination, stored product
type, and soil type. This assessment can only be done by a trained professional.
When installed and operated according to the manufacturer’s instructions, vapor monitoring
meets the federal leak detection requirements for new and existing USTs. Operation of a
vapor monitoring system at least once each month fulfills the requirements for the life of the
tank. Vapor monitoring can also be installed to detect leaks from piping.
Monitoring for liquids on the groundwater

This method monitors the groundwater table near a UST for the presence of released free
product on the water table. Monitoring wells near the UST are checked frequently to see if
petroleum can be detected. The regulations describe several requirements for the use of this
method. For example, this method cannot be used if the water table is more than 20 feet
below the surface of the ground.
Features of groundwater monitoring include the following:
• Groundwater monitoring involves the use of permanent monitoring wells placed
close to the UST. The wells are checked at least monthly for the presence of product
that has leaked from the UST and is floating on the groundwater surface.
• The two main components of a groundwater monitoring system are the monitoring
well (typically a well of 2-4 inches in diameter) and the monitoring device.
• Detection devices may be permanently installed in the well for automatic, continu-
ous measurements for leaked product.
• Detection devices are also available in manual form. Manual devices range from a
bailer (used to collect a liquid sample for visual inspection) to a device that can be

inserted into the well to electronically indicate the presence of leaked product.
Manual devices must be operated at least once a month.
• Before installation, a site assessment is necessary to determine the soil type,
groundwater depth and flow direction, and the general geology of the site. This
assessment can only be done by a trained professional.
• The number of wells and their placement is very important. Only an experienced
contractor can properly design and construct an effective monitoring well system; a
minimum of two wells is recommended for a single tank excavation. Three or more
wells are recommended for an excavation with two or more tanks. Some state and
local agencies have developed regulations for monitoring well placement.
Groundwater monitoring regulatory requirements

• Groundwater monitoring can only be used if the stored substance does not easily
mix with water and floats on top of water.
• If groundwater monitoring is to be the sole method of leak detection, the groundwa-
ter must not be more than 20 feet below the surface, and the soil between the well
and the UST must be sand, gravel, or other coarse materials.
• Monitoring wells must be properly designed and sealed to keep then from becoming
contaminated from outside sources. The wells must also be clearly marked and
secured.
• Wells should be placed in the UST backfill so that they can detect a leak as quickly
as possible.
• Product detection devices must be able to detect one-eighth inch or less of leaked
product on top of the groundwater.
In general, groundwater monitoring works best at UST sites where:
• monitoring wells are installed in the tank backfill; and
• there are no previous releases of product that would falsely indicate a current
release.
A professionally conducted site assessment is critical for determining these site-specific
conditions.
When installed and operated according to the manufacturer’s instructions, a groundwater
monitoring system meets the federal leak detection requirements for new and existing USTs.
Operation of a groundwater monitoring system at least once each month fulfills the require-
ments for the life of a tank. Groundwater monitoring can also be used to detect leaks in
piping.
Preventing releases from USTs

The Environmental Protection Agency designed part of the technical regulations for USTs to
prevent releases from USTs. The regulations require USTs to be protected from spills, over-
fills, and corrosion. Spills and overfills result from bad filling practices, and unprotected
steel tanks and piping corrode and release product through corrosion holes.

Spill protection
Many releases at UST sites come from spills made during delivery. Human error causes
most spills, which can be avoided by following standard tank filling practices. You and your
fuel deliverer must follow industry standards for correct filling practices.
Catchment basins
Your USTs must have catchment basins to contain spills. New USTs must have catchment
basins when they are installed; older tanks can have catchment basins retrofitted to them.
Catchment basins are also called spill containment manholes or spill buckets. Basically, a
catchment basin is a bucket sealed around the fill pipe. To protect against spills, the basin
should be large enough to contain what may spill when the delivery hose is uncoupled from
the fill pipe. Basins range in size from those capable of holding only a few gallons, to those
that are much larger; the larger the catchment basin, the more spill protection it provides.
You need a way to remove liquid from catchment basins. Manufacturers equip catchment
basins with either a pump or drain to remove liquid. You should try to keep water out of
catchment basins because some catchment basins can collect enough water and sediment,
along with spilled product, to make draining this mixture into the tank unwise. If this hap-
pens, you may pump out the catchment basin and dispose of the liquid properly. If the liquid
contains fuel or chemicals, it could be considered a hazardous waste. Contact your state
agency responsible for hazardous waste for information on testing and handling
requirements.
Correct filling practices

Many releases at UST sites come from spills; spills often occur at the fill pipe when the
delivery truck’s hose is disconnected. Although these spills are usually small, repeated small
releases can cause big environmental problems.
Human error causes most spills; these mistakes can be avoided by following standard tank
filling practices. For example, you must make sure there is room in the UST for the delivery,
and the delivery driver must watch the delivery at all times. If you and the delivery driver
follow standard practices, nearly all spills can be prevented. For this reason, federal UST
regulations require that you follow standard filling practices.
spill protection requirements. Many small used oil tanks fall into this category.
Overfill protection
Your UST must have overfill protection. New USTs must have overfill protection devices
when they are installed. The three main types of overfill protection devices include:
1. Automatic shutoff devices;
2. Overfill alarms; and
3. Ball float valves.
When a tank is overfilled, large volumes can be released at the fill pipe and through loose
fittings on the top of the tank or a loose vent pipe. Overfills can be avoided by good filling
practices and the installation of overfill protection devices. USTs installed after December
22, 1988 must have had overfill protection devices when they were installed. USTs installed

before December 1988 must have added overfill protection devices by December 1998; if the
overfill devices were not added by this date, the UST must have been properly closed.
You and your fuel deliverer must follow industry standards for correct filling practices. Over-
fills usually release much larger volumes than spills. When a tank is overfilled, large
volumes can be released at the fill pipe and through loose fittings on the top of the tank or a
loose vent pipe. The tightness of these fittings normally would not be a problem if the tank
were not filled beyond its capacity. You can solve overfill problems by:
• making sure there is enough room in the tank for the delivery before the delivery is
made;
• watching the entire delivery to prevent overfilling or spilling; and
• using overfill protection devices.
overfill protection requirements. Many small used oil tanks fall into this category.
NOTE: If you have pumped delivery where fuel is delivered under pressure, you must make
sure your overfill protection device works compatibly with pumped deliveries. Also, remem-
ber that overfill protection devices are effective only when combined with careful filling
practices.
Corrosion protection
Unprotected steel USTs corrode and release product through corrosion holes. All USTs
installed after December 22, 1988 must meet one of the following performance standards for
corrosion protection:
• Tank and piping completely made of non–corrodible material, such as fiberglass.
• Tank and piping made of steel having a corrosion-resistant coating AND having
cathodic protection. (Cathodic protection is described below.)
• Tank made of steel clad with a thick layer of non–corrodible material (this option
does not apply to piping).
• USTs must also be designed, constructed, and installed in accordance with a
national code of practice.
USTs installed prior to december 1988

USTs installed before December 1988 must have had corrosion protection installed by
December 1998. These USTs must meet one of the corrosion protection standards listed
above, meet one of the upgrade options described below, or close properly. Use ONE of the
following three options to add corrosion protection to existing steel tanks:
1. Add cathodic protection
Add cathodic protection to a tank that has been proven to be structurally sound. Cathodic
protection can be provided by adding an impressed current system that protects the UST by
introducing an electrical current into the soil around the UST. Cathodic protection systems
need to be periodically inspected and tested.
2. Add interior lining
Add a thick layer of non-compatible material to the interior of the tank. This interior lining
must be periodically inspected.

3. Combine cathodic protection and interior lining

Combine cathodic protection and interior lining. USTs using this option are not required to
have the interior lining periodically inspected.
Spill cleanup
In Subtitle I of the Resource Conservation and Recovery Act, Congress directed EPA to
establish regulatory programs that would prevent, detect, and clean up releases from USTs.
EPA regulations require UST owners and operators to respond to a release by:
• reporting a release;
• removing its source;
• mitigating fire and safety hazards;
• investigating the extent of the contamination; and
• cleaning up soil and groundwater as needed to protect human health and the
environment.
EPA developed the UST regulations and program to be flexible, and to be implemented by
state and local agencies. Every state and many local governments now have active UST
cleanup programs.
One of EPA’s top priorities in the UST program is to help state and local governments make
cleanups faster, cheaper, and more effective.
Closing underground storage tanks

Tank closure is one way to help protect human health and the environment, particularly
groundwater, from the threats posed by many older underground storage tanks. You can
close your UST temporarily or permanently.
Temporary closings
You may temporarily close your UST for up to 12 months by following these requirements
for temporary closure:
• Continue to monitor for leaks by maintaining the UST’s leak detection. (If your UST
is empty, you do not need to maintain leak detection.) Also, continue to monitor and
maintain any corrosion protection systems. If a release is discovered, quickly stop
the release, notify your regulatory authority, and take appropriate action to clean up
the site.
• If the UST remains temporarily closed for more than 3 months, leave vent lines
open, but cap and secure all other lines, pumps, manways, and ancillary equipment.
After 12 months of temporary closure, you have three options:
1. You must permanently close your UST if it doesn’t meet the applicable requirements
for new or upgraded USTs (except for spill and overfill).

2. You can ask your regulatory authority for an extension beyond 12 months, if you
provide an assessment that determines whether contamination is present at your
site.
3. Your UST can remain temporarily closed without needing an extension granted by
the regulatory authority if the UST meets the applicable requirements for new or
upgraded USTs (except for spill and overfill) and the requirements noted above for
temporary closure.
Permanent closings
If you decide to close your UST permanently, follow these requirements for permanent clo-
sure:
1. Notify the regulatory authority at least 30 days before you close your UST.
2. Determine if contamination from your UST is present in the surrounding
environment. If there is contamination, you may have to take corrective action. For
at least 3 years, keep a record of the actions you take to determine if contamination
is present at the site (or you can mail this record to your regulatory authority).
3. Either remove the UST from the ground or leave it in the ground. In both cases, the
tank must be emptied and cleaned by removing all liquids, dangerous vapor levels,
and accumulated sludge. These potentially very hazardous actions need to be car-
ried out carefully by trained professionals who follow standard safety practices. If
you leave the UST in the ground, have it filled with a harmless, chemically inactive
solid, like sand.
Recordkeeping requirements
What records must you keep?

You will have to keep records that can be provided to an inspector during an on-site visit
that prove your facility meets certain requirements. These records must be kept long enough
to show your facility’s recent compliance status in five major areas:
1. You will have to keep records of leak detection performance and maintenance:
• The last year’s monitoring results, and the most recent tightness test.
• Copies of performance claims provided by leak detection manufacturers.
• Records of recent maintenance, repair, and calibration of on-site leak detec-
tion equipment.
2. You will have to keep records showing the required inspections and tests of your cor-
rosion protection system.
3. You must keep records showing that a repaired or upgraded UST system was prop-
erly repaired or upgraded.
4. For at least 3 years after closing a UST, you must keep records of the site assess-
ment results required for permanent closure. (These results show what impact your
UST has had on the surrounding area.)
5. You must keep records that document your financial responsibility, as explained in
EPA’s booklet, Dollars And Sense.

Check with your regulatory authority about the particular recordkeeping requirements in
your area. Generally, you should follow this useful rule of thumb for recordkeeping: When
in doubt, keep it.
40 CFR 280.34 Reporting and recordkeeping

Owners and operators of UST systems must cooperate fully with inspections, monitoring,
and testing conducted by the implementing agency, as well as requests for document submis-
sion, testing, and monitoring by the owner or operator pursuant to section 9005 of Subtitle I
of the Resource Conservation and Recovery Act, as amended.
(a) Reporting. Owners and operators must submit the following information to the imple-
menting agency:
1. Notification for all UST systems (40 CFR 280.22), which includes certification of
installation for new UST systems (40 CFR 280.20(e));
2. Reports of all releases including suspected releases (40 CFR 280.50), spills and over-
fills (40 CFR 280.53), and confirmed releases (40 CFR 280.61);
3. Corrective actions planned or taken including initial abatement measures (40 CFR
280.62), initial site characterization (40 CFR 280.63), free product removal (40 CFR
280.64), investigation of soil and ground-water cleanup (40 CFR 280.65), and correc-
tive action plan (40 CFR 280.66); and
4. A notification before permanent closure or change-in-service (40 CFR 280.71).
(b) Recordkeeping. Owners and operators must maintain the following information:
1. A corrosion expert’s analysis of site corrosion potential if corrosion protection equip-
ment is not used (40 CFR 280.20(a)(4); 40 CFR 280.20(b)(3));
2. Documentation of operation of corrosion protection equipment (40 CFR 280.31);
3. Documentation of UST system repairs (40 CFR 280.33(f));
4. Recent compliance with release detection requirements (40 CFR 280.45); and
5. Results of the site investigation conducted at permanent closure (40 CFR 280.74).
(c) Availability and Maintenance of Records. Owners and operators must keep the
records required either:
1. At the UST site and immediately available for inspection by the implementing
agency; or
2. At a readily available alternative site and be provided for inspection to the imple-
menting agency upon request.
3. In the case of permanent closure records required under 40 CFR 280.74, owners and
operators are also provided with the additional alternative of mailing closure
records to the implementing agency if they cannot be kept at the site or an alterna-
tive site as indicated above.

Operator training requirements

Section 1524 of the Energy Policy Act of 2005 required EPA, along with the states, to
develop training guidelines for three distinct classes of operators: Class A, Class B and Class
C. The deadline for developing the training programs for these operators was August 8,
2009.
States that receive federal grant funding for their UST programs were to ensure
that all three classes of operators received training under the new state-specific
training requirements by August 8, 2012.
Since some states missed that date, UST owners will want to check with their state
to find out the status of operator training requirements.
To receive Subtitle I funding for the development of state-specific training, the Energy Policy
Act outlined the minimum requirements a state’s UST program must include in order to
comply. These are:
• A description of the classes of operators;
• Required training for each class of operator;
• Deadlines when operator training is required; and
• Examples of acceptable state approaches to operator training.
What is operator training?

Underground storage tank operator training means any program that meets the require-
ments of these guidelines. Such a program is designed to ensure knowledge regarding
operating and maintaining underground storage tank systems.
What UST systems do these guidelines apply to?

These guidelines apply to underground storage tank systems regulated under Subtitle I,
except those excluded by regulation at 40 CFR Part 280.10(b) and those deferred by regula-
tion at 40 CFR 280.10(c)).
EPA is proposing to add Subpart J to 40 CFR Part 280 to address the training requirements
for Class A, B, and C operators. The final federal rule is anticipated in early- to mid-2013,
which will apply to Indian country and any states or territories that fail to develop and
enforce operator training requirements.
How does a state implement these guidelines?

A state implements these guidelines by:
• Requiring operator training for all operators in each class.
• Developing state-specific operator training requirements consistent with EPA’s
guidelines by August 8, 2009. State-specific operator training requirements must:
❍ Be developed in cooperation with tank owners and operators;
❍ Take into consideration training programs implemented by tank owners and
tank operators; and

❍ Be appropriately communicated to tank owners and operators.

• Establishing a procedure to identify individuals who are required to be trained
under the operator training requirements specified in these guidelines.
• Ensuring all operators are trained in accordance with these guidelines.
States may choose to be more stringent than these minimum requirements.
Who is subject to operator training requirements and what are the requirements?
For purposes of implementing the operator training requirements, these guidelines establish
three classes of operators identified as Class A, B, and C. Each underground storage tank
system or group of underground storage tank systems at a facility must have a Class A, B,
and C operator designated. All individuals designated as a Class A, B, or C operator must,
at a minimum, be trained according to these guidelines. Separate individuals may be desig-
nated for each class of operator described above or an individual may be designated to more
than one of the above operator classes. An individual who is designated to more than one
operator class must be trained in each operator class for which he or she is designated.
Because an individual may be designated for more than one operator class, states may allow
a training approach that encompasses training for more than one operator class.
States must establish a procedure to identify individuals who are required to meet the
operator training requirements specified in these guidelines. For example, a state may
accomplish this by requiring that underground storage tank system owners or operators
identify, for each underground storage tank system or group of underground storage tank
systems at a facility, at least one name for each class of operator outlined in these
guidelines.
These guidelines in no way relieve the owner or operator, as defined in 40 CFR 280, from
any legal responsibility mandated by the federal underground storage tank regulations or
requirements of a state underground storage tank program approved by EPA.
There may be occasions when a Class A, B, or C operator will not be present at the facility.
For example, operators are frequently not present at unmanned facilities, such as emergency
generators at telecommunication towers and card lock/card access facilities. However, these
operators are still responsible for operation and maintenance activities or responding to
emergencies and must be trained according to these guidelines.
Class A operator
Class A operator - The person who has primary responsibility to operate and maintain the
UST system in accordance with applicable requirements established by the implementing
agency. The Class A operator typically manages resources and personnel, such as establish-
ing work assignments, to achieve and maintain compliance with regulatory requirements.
At a minimum, Class A operator training must include the purpose, methods, and function
of:
• Spill and overfill prevention;
• Release detection;
• Corrosion protection;

• Emergency response;
• Product and equipment compatibility;
• Financial responsibility;
• Notification and storage tank registration;
• Temporary and permanent closure;
• Related reporting and recordkeeping;
• Environmental and regulatory consequences of releases; and
• Training requirements for Class B and Class C operators.
Note: Class A operators must receive training from an independent trainer.
In addition, the training program must evaluate Class A operators to make sure they have
the knowledge and skills to make informed decisions regarding compliance and if they are
the right people to fulfill the operation, maintenance, and recordkeeping requirements for
UST systems in accordance with federal law.
Class B operator
The person who has day-to-day responsibility for implementing applicable regulatory
requirements established by the implementing agency. The Class B operator typically imple-
ments in-field aspects of operation, maintenance, and associated recordkeeping for the UST
system.
At a minimum, Class B operator training must cover either: general requirements that
encompass all regulatory requirements and typical equipment used at UST facilities; or site-
specific requirements which address only the regulatory requirements and equipment
specific to the facility. Also, the training program must teach the Class B operator the pur-
pose, methods, and function of:
• Operation and maintenance;
• Spill and overfill prevention;
• Release detection and related reporting;
• Corrosion protection and related testing;
• Emergency response;
• Product and equipment compatibility;
• Reporting and recordkeeping;
• Environmental and regulatory consequences of releases; and
Note: Class B operators must receive training from an independent trainer.
The training program must test Class B operators to make sure they have the knowledge
and skills to implement applicable UST regulatory requirements in the field on the compo-
nents of typical UST systems or, as applicable, site-specific equipment used at a UST facility.

Class C operator
The employee responsible for initially addressing emergencies presented by a spill or release
from an UST system. The Class C operator typically controls or monitors the dispensing or
sale of regulated substances (i.e., a gas station attendant or clerk).
Each designated Class C operator must either be trained by a Class A or Class B operator;
complete a training program; or pass a comparable examination. At a minimum, the train-
ing program for the Class C operator must teach them to take appropriate actions in
response to:
• Emergencies, and
• Alarms caused by spills or releases from the UST system.
The training program must test Class C operators to determine if they have the knowledge
and skills to take appropriate action in response to emergencies (including situations posing
an immediate danger or threat to the public or to the environment and that require immedi-
ate action) or alarms caused by spills or releases from an underground storage tank system.
Comparable examination
A comparable examination must, at a minimum, test the knowledge of the Class A, Class B,
or Class C operators as applicable. The examination must be developed and administered by
an independent organization or the implementing agency or delegated authority.
Phase-in schedule
Owners and operators must ensure that designated Class A, B, and C operators meet the
requirements in §280.242 according to the following schedule:
Criteria Operator training or comparable examination dead-

line
One or more USTs at the facility were installed on or 1 year after the effective date of the final rule
before 12/22/1988
No USTs at the facility were installed on or before 12/22/ 2 years after the effective date of the final rule
1988 and at least one UST at the facility was installed on
or before 12/22/1998
All USTs at the facility were installed after 12/22/1998 3 years after the effective date of the final rule
If a state determines an underground storage tank system is out of compliance, appropriate

operator(s) must be retrained. States may determine whether both Class A and Class B
operators are retrained, or if only one class of operator (either Class A or Class B) is
retrained. At a minimum, an underground storage tank system is out of compliance if the
system:
• Does not meet EPA’s Significant Operational Compliance requirements for release
prevention and release detection measures identified at: www.epa.gov/oust/cmplastc/
soc.htm; or
• Is not in significant compliance with other requirements, such as financial responsi-
bility, as determined by the state.
Operators must be retrained within a reasonable time frame established by the state. At a
minimum, retraining must include training of the areas determined not in significant

compliance. States requiring at least annual operator training that covers all operator class
requirements would meet retraining requirements.
What training approaches would meet operator training requirements?

Operator training must evaluate operator knowledge of the minimum training requirements
described for each class of operator in these guidelines.
The following is a list of acceptable approaches to meet training requirements stated in

these guidelines:
• An operator training program conducted or developed by the state or by a third
party that has received prior state approval. The program may include in-class,
on-line, or hands-on training. Such a program must include an evaluation of opera-
tor knowledge. Examples include testing, practical demonstration, or other tools
determined as acceptable by the state.
• An appropriately administered and evaluated verification of operator knowledge
(i.e., comparable examination). This determination must be accomplished through
an operator examination designed to measure operator knowledge as required in
these guidelines. The state or a third party acceptable to the state may administer
this examination. The examination process must be acceptable to the state and rea-
sonably determine the person tested has the necessary knowledge and skills to be
considered competent to operate underground storage tanks.
• For Class C operator training, the state may accept training conducted by a trained
Class A or Class B operator.
• To address operators responsible for underground storage tank systems in multiple
states, states may develop a program that accepts operator training verification
from other states.
• Any combination of the above listed operator training approaches or comparable
training approaches recognized by the state.
How may states ensure all operators are trained?

States must have a system in place for ensuring all operators are trained in accordance with
these guidelines. The following are some examples for meeting this requirement:
• Require owners or operators maintain records documenting the training received for
all Class A, Class B, and Class C operators either: at the underground storage tank
site and immediately available for inspection by the implementing agency; or at a
readily available alternative site and be provided for inspection to the implementing
agency upon request.
• Require owners or operators report Class A, B, and C operator compliance to the
implementing agency.
What enforcement authority must states have for operator training?

At a minimum, states must have comparable enforcement authorities for their operator
training requirements as they have for current underground storage tank requirements.

How will states demonstrate compliance with these guidelines?

After August 8, 2009, and before receiving future grant funding, states must provide one of
the following to EPA:
• For a state that has met the requirements for operator training, the state must sub-
mit a certification indicating that the state meets the requirements in the
guidelines.
• For a state that has not yet met the requirements for operator training, the state
must provide a document that describes the state’s efforts to meet the requirements.
This document must include:
❍ A description of the state’s activities to date to meet the requirements in the
guidelines;
❍ A description of the state’s planned activities to meet the requirements; and
❍ The date by which the state expects to meet the requirements.
State UST/LUST program links and operator training links

Use the following table to find information about your state UST program and your operator
training requirements.
State (*indicates EPA State UST/LUST program Operator training sites

state program
approval)
AL* adem.state.al.us/programs/water/groundwater. adem.state.al.us/programs/water/waterforms/
cnt USTOperatorProgramMemo.pdf
AK UST: dec.alaska.gov/spar/ipp/tanks.htm dec.alaska.gov/spar/ipp/ust/training.htm
LUST: dec.state.ak.us/spar/csp/leaking.htm
AZ azdeq.gov/environ/waste/ust/index.html azdeq.gov/environ/waste/ust/download/
brochure/op_train_guide_ust.pdf
AR* www.adeq.state.ar.us/rst/ www.adeq.state.ar.us/rst/branch_programs/
ust_cert.htm
CA waterboards.ca.gov/water_issues/programs/ust/ waterboards.ca.gov/water_issues/programs/
ust/training/icc_cert_info.shtml
CO* colorado.gov/cs/Satellite/CDLE-OilPublicSafety/ colorado.gov/cs/Satellite/CDLE-
CDLE/1248095302546 OilPublicSafety/CDLE/1248095303312
CT* www.ct.gov/dep/cwp/view. www.ct.gov/dep/cwp/view.
asp?a=2692&q=322600&depNav_GID=1652 asp?a=2692&q=322600&depNav_GID=1652
DE* www.dnrec.delaware.gov/tanks/Pages/default. www.dnrec.delaware.gov/tanks/Pages/UST-
aspx Operator-Training.aspx
D.C. * ddoe.dc.gov/service/underground-storage- ddoe.dc.gov/service/training-class-b-or-c-
tanks-ust-and-lust operator-usts
FL www.dep.state.fl.us/waste/categories/pss/ www.dep.state.fl.us/waste/categories/tanks/
default.htm pages/op_train.htm
GA* www.gaepd.org/Documents/index_land.html http://www.gaepd.org/Documents/lpb_ust.
html#u1
Guam epa.guam.gov/ epa.guam.gov/programs/hazardous-waste/
HI* hawaii.gov/health/environmental/waste/ust/ http://hawaii.gov/health/environmental/waste/
index.html sw/ust/pdf/summarychanges.pdf

ID* UST: deq.idaho.gov/waste-mgmt-remediation/ deq.idaho.gov/media/511534-_waste_prog_

storage-tanks/underground-storage-tanks.aspx issues_ust_lust_ust_rules_state_fs.pdf
LUST: deq.idaho.gov/waste-mgmt-remediation/
storage-tanks/leaking-underground-storage-
tanks.aspx
IL UST: www.sfm.illinois.gov/commercial/ust/ www.sfm.illinois.gov/commercial/ust/index.
index.aspx aspx
LUST: www.epa.state.il.us/land/lust/index.html
IN* UST: in.gov/idem/4999.htm in.gov/idem/4999.htm
LUST: in.gov/idem/4997.htm
IA* UST: iowadnr.gov/InsideDNR/RegulatoryLand/ iowadnr.gov/InsideDNR/RegulatoryLand/
UndergroundStorageTanks.aspx UndergroundStorageTanks/
LUST: iowadnr.gov/InsideDNR/RegulatoryLand/ USTOwnersOperators.aspx
UndergroundStorageTanks/
LeakingUndergroundTanks.aspx
KS* kdheks.gov/tanks/ kdheks.gov/tanks/download/ust_overview.pdf
KY waste.ky.gov/ust waste.ky.gov/UST/Pages/ot.aspx
LA* deq.louisiana.gov/portal/tabid/2659/Default. deq.louisiana.gov/portal/tabid/2659/Default.
aspx aspx
ME* maine.gov/dep/rwm/ust/index.htm maine.gov/dep/waste/tanksmart/index.html
MD* mde.maryland.gov/programs/land/oilcontrol/ mde.maryland.gov/programs/land/oilcontrol/
undergroundstoragetanks/pages/programs/ undergroundstoragetanks/pages/programs/
landprograms/oil_control/usthome/index.aspx landprograms/oil_control/usthome/index.aspx
MA* UST: mass.gov/dep/toxics/ust mass.gov/dep/toxics/ust/ustoando.htm
LUST: www.mass.gov/dep/cleanup/compliance/
tankpro.htm
MI michigan.gov/deq/0,4561,7-135-3311_4115_ michigan.gov/deq/0,4561,7-135-3311_4115_
4238---,00.html 4238-18058--,00.html
MN* pca.state.mn.us/index.php/waste/waste-and- pca.state.mn.us/index.php/waste/waste-and-
cleanup/waste-management/tank-compliance- cleanup/waste-management/tank-
and-assistance/underground-storage-tanks-ust/ compliance-and-assistance/underground-
underground-storage-tank-ust-systems.html storage-tanks-ust/underground-storage-tank-
operator-requirements.html
MS* deq.state.ms.us/MDEQ.nsf/page/UST_ deq.state.ms.us/MDEQ.nsf/page/UST_
PageHome? OperatorTraining?
MO* dnr.mo.gov/env/hwp/tanks/tanks.htm dnr.mo.gov/env/hwp/tanks/tanks.htm
MT* UST: deq.mt.gov/ust/default.mcpx TankHelper.mt.gov
LUST: deq.mt.gov/LUST/default.mcpx
NE* UST: www.sfm.state.ne.us/programs-services/
fuels/flst/ust.html
LUST: www.deq.state.ne.us/LUST-RA.nsf/
Pages/LUST
NV* UST: ndep.nv.gov/bca/ust_home.htm ndep.nv.gov/bca/ust_training.htm
LUST: ndep.nv.gov/bca/rem_home.htm
NH* des.nh.gov/organization/divisions/waste/orcb/ des.nh.gov/organization/divisions/waste/orcb/
ocs/ustp/index.htm ocs/ustp/operator-training/index.htm
NJ www.state.nj.us/dep/srp/bust/bust.htm
NM* www.nmenv.state.nm.us/ust/ustbtop.html www.nmenv.state.nm.us/ust/
OperatorTraining.htm
NY UST: www.dec.ny.gov/chemical/287.html www.dec.ny.gov/chemical/53278.html
LUST: www.dec.ny.gov/chemical/8428.html

NC* portal.ncdenr.org/web/wm/ust portal.ncdenr.org/web/wm/ust/

operatortraining
ND* ndhealth.gov/wm/ https://secure.apps.nd.gov/doh/operator/
UndergroundStorageTankProgram default.aspx
OH www.com.ohio.gov/fire/bustmain.aspx www.com.ohio.gov/fire/docs/fire_
OpTrainClassFAQ.pdf
OK* occeweb.com/ps/aboutpst1.html occeweb.com/ps/operatortraining1.htm
OR* www.deq.state.or.us/lq/tanks/index.htm www.deq.state.or.us/lq/training.
htm#Contractor
PA* www.portal.state.pa.us/portal/server.pt/ www.portal.state.pa.us/portal/server.pt/
community/storage_tanks/ community/underground_storage_tanks/
20604/ust_operators/
RI* www.dem.ri.gov/programs/benviron/waste/ www.dem.ri.gov/programs/benviron/waste/
topictan.htm topictan.htm
SC* www.scdhec.gov/eqc/ust/index.html www.scdhec.gov/environment/lwm/html/ust_
op_trn.htm
SD* denr.sd.gov/des/gw/tanks/TankSection.aspx denr.sd.gov/des/gw/tanks/
TankOperatorTraining.aspx
TN* www.tennessee.gov/environment/ust/ www.tennessee.gov/environment/ust/
operator_training.shtml
TX* UST: tceq.state.tx.us/nav/permits/pst_cert.html tceq.texas.gov/licensing
LUST: tceq.texas.gov/remediation/pst_rp/pst.
html
UT* undergroundtanks.utah.gov undergroundtanks.utah.gov/optraining.htm
VT* anr.state.vt.us/dec/wastediv/ust/home.htm anr.state.vt.us/dec/wastediv/ust/Training.htm
VA* deq.state.va.us/Programs/ deq.virginia.gov/Portals/0/DEQ/Land/Tanks/
LandProtectionRevitalization/ LPR-SRR-2011-11.pdf
PetroleumProgram/StorageTanks/
undergroundstoragetanks.aspx
WA* ecy.wa.gov/programs/tcp/ust-lust/tanks.html ecy.wa.gov/programs/tcp/ust-lust/tanks.html
WV* dep.wv.gov/WWE/ee/ust/Pages/default.aspx www.dep.wv.gov/WWE/ee/ust/Pages/
USTOperatorTraining.aspx
WI UST: dsps.wi.gov/er/ER-BST-HomePage.html dsps.wi.gov/er/ER-BST-FedRegUST_
LUST: dnr.wi.gov/topic/Brownfields/Petro.html OperatorTraining.html
WY deq.state.wy.us/shwd/stp/ deq.state.wy.us/shwd/stp/Compliance/Pages/
operator.htm
Aboveground storage tanks (ASTs)

An aboveground storage tank (AST) is defined as any tank not meeting the definition of an
underground tank, or in other words, not at least 10 percent underground. It is regulated
based on what the tank contains. There is no comprehensive AST regulation, controlling
AST design, maintenance, operations, and cleanup requirements, such as exist for USTs.
Therefore, you would have to look several different places to piece together AST
requirements. As stated above, if you are storing hazardous waste in an AST, then you must
look in the hazardous waste regulations (under RCRA) for what is necessary.

ASTs and SPCC

If you store oil in an AST, you may be regulated under 40 CFR 112, the Spill Prevention,
Control, and Countermeasure (SPCC) regulations. This rule applies to tanks with aggregate
capacity greater than 1,320 gallons. The SPCC establishes procedures to prevent the dis-
charge of oil into navigable waters. For more information on the SPCC and how it may
apply to your operations, see the SPCC section in the Clean Water chapter of this
book.
Testing and monitoring

The SPCC rule requires each aboveground container to be tested for integrity on a regular
schedule and whenever material repairs are made. The frequency of and type of testing
must take into account container size and design (such as floating roof, skid-mounted,
elevated, or partially buried). In July 2012 EPA released a helpful fact sheet on bulk storage
container inspections. You can find it by browsing for http://bit.ly/bulkAST46M.
EPA explains that a container integrity inspection or testing program may involve one or
more of the following: an external visual inspection of containers, foundations, and supports;
non-destructive testing to evaluate container integrity; and additional evaluations, as
needed, to assess the containers’ fitness for continued service. The type of inspection pro-
gram you choose will depend on site-specific conditions and the application of good
engineering practices along with applicable industry standards.
You must conduct integrity testing and routinely inspect the following ASTs with a capacity
of 55 gallons or more:
• Large (field-constructed or field-erected and small (shop-built) bulk storage
containers;
• Containers located on, partially in (partially buried, bunkered, or vaulted tanks);
and off the ground wherever located; and
• Double-walled containers.
Oil-filled equipment is not a bulk storage container and, therefore, not subject to the integ-
rity testing requirements of the SPCC rule.
ASTs and OSHA

Some ASTs fall under OSHA requirements (29 CFR 1910.106) if they contain flammable or
combustible liquids. The rules apply to liquids with flashpoints below 200 degrees F. In this
case, the regulations aim to protect workers from fires, rather than protecting the environ-
ment from spills.
As always, check with your state agency to see if there are more stringent AST requirements
that you need to know about.

Audit Checklists
UST Audit Checklist

Does your plant have any old unused USTs on the premises?
Does your plant store only non-hazardous materials in USTs?
Does your plant store any hazardous materials in USTs?
Does your plant store any petroleum products in USTs?
Has your plant notified the appropriate state agency about its USTs?
Have you determined and used the proper EPA or state notification form?
Are the USTs on your premises visually inspected on a regular basis?
Has your company instituted a method of release detection for all new and
existing USTs?
Do you know and follow release reporting, investigation, and confirmation
procedures?
Do you follow proper release response and corrective action procedures?
Are you aware of and have you begun to prepare for the financial responsibil-
ity provisions for petroleum USTs?
Have you established a record keeping procedure and files for general operat-
ing requirements, release detection, closure of USTs, and financial
responsibility provisions?
Are you aware of and do you follow required reporting procedures for UST
systems, general operating requirements, releases, closure, and financial
responsibility?
AST Audit Checklist

The following audit points cover general recommendations for responsible AST practices as
well as specific regulatory requirements (regulatory citations are included where applicable):
General
Are there any apparent signs of physical contamination: dead vegetation,
noticeable stains on the ground, standing oil?
Is any leaking occurring around tanks, containment structures and transfer
areas?
Is all leak detection equipment in satisfactory condition?
Is the separator or drainage tank in satisfactory condition?
Are unused tank water bottom draw offs secured?
Are unused tank fill valves secured?
Are valves inspected for signs of leakage or deterioration?
Are inlet and outlet piping and flanges inspected for leakage?

Is containment dike or berm in satisfactory condition?

Is containment area free of excess standing water or oil?
Are gate valves used for emptying containment areas secured?
Is containment area/base of tank free of high grass, weeds and debris?
Is tank shell surface, including any peeling areas, welds, rivets/bolts, seams
and foundation, showing rust and other deterioration?
Stormwater regulations
How close is the nearest building?
property line?
well?
surface water?
Are there any areas (parking lot, excavation area, refuse area) where
stormwater runoff could be contaminated with hazardous pollutants should a
spill occur? 40 CFR 122(b)(14)
State/local requirements
Have you notified the appropriate state/local agencies about your ASTs?
Any labeling required on ASTs under local (fire department or county)
regulations?
Hazard communication labels

Do you store any hazardous materials (including gasoline) in ASTs?
Are tanks containing hazardous materials appropriately labeled with chemi-
cal name and hazard warning? 1910.1200
Hazardous waste storage

Do you store hazardous wastes in any of your ASTs?
Is hazardous waste emergency information posted near the AST? 262.34
Is necessary emergency equipment available (fire extinguishers, spill control
supplies, absorbents, MSDSs)? 265.32
Is there at least one employee either on the premises or on call (i.e., available
to respond to an emergency by reaching the facility within a short period of
time) with the responsibility of coordinating all applicable emergency
response measures? 262.34
Flammable/combustible liquids storage

Do you store flammable or combustible liquids in your AST?
Have you complied with all OSHA storage requirements? 1910.106

Oil pollution prevention 40 CFR 112

Do you store oil in your AST?
What is the maximum tank capacity in gallons?
Of what materials is the tank constructed?
Does the AST have adequate secondary containment safeguards or an oil spill
contingency plan?
Is the containment dike or berm in satisfactory condition?
Is the containment area free of excess standing water or oil?
Are the gate valves used for emptying the containment areas secured?
Is the containment area/base of tank free of high grass, weeds, and debris?
Have you instituted a method of release detection for all new and existing
ASTs?
Do you know and follow release reporting, investigation, and confirmation
procedures?
Fire protection
Are all fire extinguishers accessible, and their locations clearly designated?
1910.157
Are all fire extinguishers inspected and recharged regularly, and noted on the
inspection tag? 1910.157

WASTE
CONTENTS
The Resource Conservation and Recovery Act (RCRA) ................................................ 1

Identify your waste ............................................................................................ 1
What is hazardous waste? .............................................................................. 1
What are the different kinds of hazardous wastes?............................................... 2
Wastes exclusions ........................................................................................ 4
Waste analysis .................................................................................................. 4
Why conduct waste analysis? .......................................................................... 5
Waste analysis plan............................................................................................ 7
Developing the plan...................................................................................... 8
What is your generator status? ............................................................................ 16
Categories of generators............................................................................... 16
Measuring your hazardous waste ......................................................................... 18
Do count .................................................................................................. 18
Don’t count ............................................................................................... 18
Changing generator categories............................................................................. 19
Obtaining an EPA identification number ................................................................ 19
How to fill out the form ............................................................................... 20
One site — one number ............................................................................... 20
Where to submit notification form .................................................................. 20
Used oil ......................................................................................................... 26
What is used oil? ........................................................................................ 26
How is used oil recycled?.............................................................................. 27
What standards should my business follow?...................................................... 28
Mixing used oil and hazardous waste .............................................................. 30
Cleanup practices ....................................................................................... 30
Sample plan .............................................................................................. 30
Used oil management plan ........................................................................... 31
Shop towels and rags ........................................................................................ 37
TCLP and land ban........................................................................................... 38
Waste minimization plans .................................................................................. 39
Waste minimization and reduction best practices ............................................... 40
Waste minimization FAQs ............................................................................ 41
Appendix: EPA hazardous waste numbers for waste streams commonly generated by small
quantity generators........................................................................................... 44
To use this appendix ................................................................................... 44
Storing hazardous wastes ................................................................................... 48
Accumulation: quantities and time limits ......................................................... 48
Handling requirements for stored hazardous wastes ........................................... 50
Treating or disposing of hazardous waste onsite ................................................ 52
Obtaining a TSD permit............................................................................... 53
9/14 Waste TOC–1

Preparing for and preventing accidents............................................................ 53

Planning for emergencies ............................................................................. 54
Release notification requirements under other environmental laws ........................ 55
Make it easy — write it down........................................................................ 56
How to respond to a spill.............................................................................. 57
Hazardous waste containers.......................................................................... 59
Container safety: it’s in your hands ................................................................ 60
Shipping hazardous waste .................................................................................. 61
Choosing a hauler ...................................................................................... 61
Preparing your wastes for shipment................................................................ 62
Biennial reporting ...................................................................................... 64
The Uniform Hazardous Waste Manifest .......................................................... 64
Electronic manifesting and the e-Manifest Act ................................................. 68L
Permit process streamlined for hazardous waste facilities.................................. 68M
Universal Waste ............................................................................................ 68N
What is universal waste? ........................................................................... 68N
The state’s role in universal waste management .............................................. 68N
Universal wastes defined ........................................................................... 68N
Pesticides ................................................................................................. 69
Mercury-containing equipment ...................................................................... 69
Lamps ..................................................................................................... 69
Cathode ray tubes (CRTs)............................................................................. 70
Universal waste rule applicability ........................................................................ 70
Businesses ................................................................................................ 70
Households ............................................................................................... 70
Communities ............................................................................................. 71
Requirements for participants in the universal waste system...................................... 71
Small and large quantity handlers of universal waste ......................................... 72
Universal waste transporters ........................................................................ 74
Destination facilities ................................................................................... 74
Management of batteries.............................................................................. 75
Management of pesticides............................................................................. 76
Management of mercury-containing equipment.................................................. 76
Update labeling/marking .............................................................................. 78
Revise employee training program.................................................................. 78
Notification ............................................................................................... 78
Management of lamps ................................................................................. 78
Import requirements ................................................................................... 79
Export requirements ................................................................................... 79
Labeling and marking ................................................................................. 80
Employee training ...................................................................................... 80
Response to releases ................................................................................... 81
Tracking universal waste shipments ............................................................... 82
2–Waste TOC 9/14

RCRA personnel training ................................................................................... 83

RCRA personnel training tips ........................................................................ 85
RCRA personnel training guidance ................................................................. 87
RCRA-OSHA training crossover ..................................................................... 93
Waste TOC–3
9/14

Reserved
4–Waste TOC 9/14

The Resource Conservation and Recovery Act (RCRA)

In 1976, Congress passed the Resource Conservation and Recovery Act (RCRA), which
directed the U.S. Environmental Protection Agency (EPA) to develop and implement a pro-
gram to protect human health and the environment from improper hazardous waste
management practices. The program is designed to control the management of hazardous
waste from its generation to its ultimate disposal — from “cradle-to-grave.”
In addition, states are empowered to more stringently regulate hazardous waste. Many
states have chosen to do so, some have not. You should check to see if your state follows fed-
eral requirements or state-specific guidelines.
Identify your waste
What is hazardous waste?

Hazardous waste identification begins with an obvious point: in order for any material to be
a hazardous waste, it must first be a waste. But, deciding whether an item is or is not a
waste is not always easy. As a first step in fulfilling the goals of RCRA, EPA developed objec-
tive criteria to define and identify hazardous waste for regulation.
RCRA uses the term “solid waste” in place of the common term “waste.” So, a solid waste is
any solid, liquid, or contained gaseous material that you no longer use. You either recycle it,
throw it away, or store it until you have enough to treat and/or dispose of.
According to EPA, a waste is hazardous when the quantity, concentration, or physical,

chemical, or infectious characteristics may cause, or significantly contribute to, an increase
in mortality or an increase in serious irreversible, or incapacitating reversible, illness; or if
it can be harmful to human health and the environment when treated, stored, transported,
disposed of, or otherwise managed.
9/13 Waste–1

Hazardous wastes come in many forms and can be generated in a variety of industrial and
nonindustrial settings. Specifically, a waste is considered hazardous under RCRA if it meets
either of the following criteria:
1. It is specifically listed, or identified, as a hazardous waste, or
2. It exhibits one or more characteristics of a hazardous waste.
There are over 700 hazardous wastes listed by name. These include wastes derived from
manufacturing processes and discarded commercial chemical products.
These wastes are listed in Part 261 of the EPA regulations. Many of the hazardous wastes
that you are likely to generate are included in the Appendix later in this section. The Appen-
dix groups the substances in general categories, like solvents, acids, etc. For a complete
listing of hazardous wastes, check the EPA regulations at 40 CFR Part 261.
Determining whether or not a waste qualifies as hazardous is important because only haz-
ardous wastes that meet the criteria above are subject to RCRA regulations. EPA requires
wastes identified as hazardous to be handled — stored, treated, and disposed of — according
to the stipulations of the RCRA hazardous waste program.
What are the different kinds of hazardous wastes?

Listed wastes
EPA has specifically identified and listed certain wastes that are known to be hazardous. To
determine if a waste is to be listed, EPA observes different industrial practices at numerous
facilities, noting the common chemicals used, and assessing which wastes pose the greatest
risk to human health and the environment. Listed wastes are always hazardous regardless
of their chemical composition — no testing is required to identify them.
Listed wastes are divided into four categories, according to their origin:
• F list — Wastes from generic industrial processes. For example, certain used sol-
vents used for cleaning or degreasing.
• K list — Wastes from specific industry sectors. For example, certain petroleum
refining wastes.
• P list — Unused, acutely hazardous commercial chemical products. For example
aldrin, a chemical used as an agricultural insecticide.
• U list — Unused, commercial chemical products. For example, DDT and
formaldehyde.
Characteristic wastes
Even if a waste does not appear on one of the EPA lists, it is considered hazardous if the
waste possesses one or more of the following characteristics:
Ignitable — Ignitable wastes can create fires under certain conditions, are spontaneously
combustible, or have a flash point less than 60 °C (140 °F). Examples include waste oils
and used solvents.
Corrosive — Corrosive wastes are acids or bases (pH less than or equal to 2, or greater
than or equal to 12.5) and/or are capable of corroding metal containers, such as storage
tanks, drums, and barrels. Battery acid is an example.
2–Waste 9/13

Reactive — Reactive wastes are unstable under “normal” conditions. They can cause
explosions, undergo violent reactions, generate toxic fumes, gases, or vapors or explosive
mixtures when heated, compressed, or mixed with water. Examples include lithium-sulfur
batteries and explosives.
Toxic — Toxic wastes are harmful or fatal when ingested or absorbed (e.g., containing
mercury, lead, etc.). When toxic wastes are land disposed, contaminated liquid may leach
from the waste and pollute ground water.
The test for EP toxicity is the Toxicity Characteristic Leaching Procedure (TCLP). The
description of this test can be found in Appendix II of 40 CFR Part 261.
Your industry may generate other hazardous wastes beyond the examples mentioned above.
It is your responsibility to determine whether your wastes are hazardous.
NOTE: If you know your waste is hazardous, and what it contains, there is no need to test
it. The regulations state that the generator must determine if the waste is identified in Sub-
part C of 40 CFR 261 by testing, or “Applying knowledge of the hazard characteristic of the
waste in light of the materials or processes used (40 CFR 262.11(c)(2)).” So, if you know you
have a hazardous waste and what its characteristics are, there is no need to spend money on
a test that will tell you what you already know.
Other hazardous wastes

In developing the hazardous waste regulations, EPA recognized that waste management
practices often cause wastes to deviate from their original form. For example, hazardous
wastes can:
• Be mixed with other wastes;
• Be produced from other wastes; or
• Contaminate soil, ground water, and other materials.
Mixtures
In some situations, hazardous wastes are mixed with other hazardous wastes or nonhazard-
ous wastes before proper treatment or disposal. To prevent generators of hazardous wastes
from diluting wastes intentionally in order to bypass regulation, EPA developed require-
ments for hazardous waste mixtures.
A mixture of a listed waste and any other waste will remain regulated as a listed waste
regardless of the percentage of the listed waste in the mixture. A mixture of a characteristic
hazardous waste and any other waste will only be considered hazardous if the resultant
mixture exhibits a hazardous waste characteristic. Even if resultant mixtures do not exhibit
a characteristic of hazardous waste, they may still require further treatment before proper
disposal.
Derived-from wastes
As a result of treatment, storage, or even proper disposal, residues of hazardous waste can
be generated from the original hazardous waste. These are called derived-from wastes.
EPA recognized that these residues might not be rendered nonhazardous by management
activities. The hazardous status of a residue, such as sludge, ash, or filter, depends on the
type of hazardous waste from which it is derived. Just as with mixtures of hazardous waste,
9/13 Waste–3

or exhibits a characteristic of hazardous waste, then it is regulated under RCRA as a haz-

ardous waste.
Acutely hazardous waste

There is a separate category of hazardous waste considered to be “acutely hazardous.”
These are wastes that are so dangerous in small amounts that they are regulated the same
way as large amounts of other hazardous wastes. Acutely hazardous wastes, for example,
may be generated using certain pesticides. They also include dioxin-containing wastes.
If your company produces as little as 1 kilogram (2.2 pounds) of acutely hazardous wastes in
a calendar month or stores more than that amount for any period of time, you are subject to
all of the regulations that apply to generators of more than 1,000 kilograms per calendar
month.
Two pounds is not a very large amount of waste. So if you handle any of these substances in
your company’s operations, you may well produce the allotted amount of acutely hazardous
waste. Check this carefully.
For a complete listing of acutely hazardous wastes, check in the EPA regulations, under
§261.33(e).
Wastes exclusions
Some of the materials that would otherwise fit the definitions of a solid or hazardous waste
under waste identification are specifically excluded from the definitions. Why? Because, EPA
concluded that these materials should not be regulated as solid or hazardous wastes for one
or more of a number of reasons.
You will find that many exclusions are mandated in the statute. However, EPA also selected
other exclusions to provide an incentive to recycle certain materials, because there was not
enough information on the material to justify its regulation as a solid or hazardous waste, or
because the material was already subject to regulation under another statute.
So, after determining that a waste is a solid waste, the next step in every hazardous waste
determination requires the generator to determine if the waste fits any of the six categories
of exclusions identified in §261.4 (§262.11(a)). If the waste fits one of these categories, it is
not regulated as a RCRA hazardous waste, and the hazardous waste determination process
ceases. But, please note that most states are authorized to manage their own hazardous
waste program. Therefore, states may have their own set of regulations that apply in lieu of
federal regulations. While most state hazardous waste regulations are based on the federal
requirements, some states have developed regulations more stringent than the federal
program.
Waste analysis
The cornerstone of RCRA’s program for managing hazardous waste is the ability of facility
personnel to identify properly, through waste analysis, all wastes that they generate, treat,
store, or dispose of. Waste analysis involves identifying or verifying the chemical and physi-
cal characteristics of a waste by performing a detailed chemical and physical analysis of a
representative sample of the waste or, in certain cases, by applying acceptable knowledge of
the waste.
4–Waste 9/13

Why conduct waste analysis?

You must conduct proper waste analysis to determine whether your waste is defined as a
hazardous waste under RCRA, to identify/classify the waste according to RCRA, and to
ensure that your waste is managed properly. How your hazardous waste is classified will
determine the legal methods available to you for treatment, storage, or disposal of the
waste. Waste analysis, therefore, is the pivotal activity that you must conduct properly to
ensure that your facility is in compliance with the myriad applicable regulations for proper
waste treatment, storage, or disposal.
For example, waste analysis is necessary to comply with the Land Disposal Restrictions
(LDR) regulations, which are established treatment standards (expressed as concentration
levels or methods of treatment) for the majority of hazardous wastes regulated under RCRA
and ultimately destined for land disposal. However, it is also advantageous for all facilities
involved including the transfer facility, treatment facility, storage facility, and disposal
facility.
So, as a generator of hazardous waste, you must test the waste, or use knowledge of the pro-
cess generating the waste, to determine if the waste is restricted from land disposal. In
addition, you must notify any subsequent facilities that will treat, store, or dispose of the
waste of its LDR status. A way to do this is with a waste analysis plan.
General waste analysis requirements

The general requirements for conducting waste analysis are included in:
• 40 CFR §262.11 for generators that do not treat, store, or dispose of hazardous
waste
• 40 CFR §268.7(a)(4) for generators treating in tanks, containers, and/or containment
buildings to meet LDR treatment standards
• 40 CFR §264.13 for permitted TSDFs, including 40 CFR §264.13(a)(4) and (c) for all
off-site TSDFs (generators who treat prohibited wastes in tanks, containers, and/or
containment buildings to meet LDR treatment requirements should also follow the
general waste analysis provisions in 40 CFR §§264.13/265.13)
• 40 CFR §265.13 for TSDFs operating under interim status.
To meet the general waste analysis requirements, all TSDFs should, and generators treat-
ing in tanks, containers, and/or containment buildings to meet LDR treatment
standards must, obtain a detailed chemical and physical analysis of a representative
sample of any waste that they generate, treat, store, or dispose of.
For generators that are not treating hazardous waste in tanks, containers, and/or
containment buildings to meet LDR treatment standards, you need only conduct
waste analysis; no formal waste analysis plan is required, although 40 CFR §262.40 imposes
recordkeeping requirements for generators performing waste analysis.
Waste analysis options

You can meet general and specific waste analysis requirements using several methods or
combinations of methods. Wherever feasible, the preferred method to meet the waste analy-
sis requirements is to conduct sampling and laboratory analysis because it is more accurate
and defensible than other options. (The procedures and equipment for both obtaining and
analyzing samples are described in Appendices I and II of 40 CFR Part 261.)
9/13 Waste–5

However, generators and TSDFs also can meet waste analysis requirements by applying
acceptable knowledge. Acceptable knowledge can be used to meet all or part of the waste
analysis requirements.
Acceptable knowledge defined

Process knowledge, whereby detailed information on the wastes is obtained from existing
published or documented waste analysis data or studies conducted on hazardous wastes gen-
erated by processes similar to that which generated the waste. As mentioned previously,
EPA lists (i.e., F, K, P, and U lists) certain hazardous wastes in 40 CFR Part 261. The
K-listed wastes, for example, contain wastes generated from specific sources. Examples of
K-listed wastes include:
• K001 — Bottom sediment sludge from the treatment of waste waters from wood pre-
serving processes that use creosote and/or pentachlorophenol.
• K062 — Spent pickle liquor generated by steel finishing operations of facilities
within the iron and steel industry.
K-listed wastes, therefore, are identified by comparing the specific process that generated
the waste to those processes listed in 40 CFR §261.32 (rather than conducting a chemical/
physical analysis of the waste). Similarly, any waste described in the F, P, or U list has
already been designated as hazardous by EPA. Therefore, with many listed wastes the appli-
cation of acceptable knowledge is appropriate because the physical/chemical makeup of the
waste is generally well known and consistent from facility to facility.
Waste analysis data obtained from facilities which send wastes off site for treatment, stor-
age, or disposal (e.g., generators).
The facility’s records of analysis performed before the effective date of RCRA regulations.
While seemingly attractive because of the potential savings associated with using existing
information (such as published data), the facility must ensure that this information is cur-
rent and accurate.
Option one: Selecting sampling and analysis

Because RCRA is a self-implementing program, the burden is on you, the individual facility
owner/operator, to demonstrate that you are operating in compliance with all applicable
regulations. Any violations that occur at your facility, regardless of any good faith effort you
may have made to obtain information, are your facility’s sole responsibility. For example, if
you own/operate a TSDF, accept waste from an off-site facility, and rely on the information
provided by the generator or TSDF sending you waste, your facility is still responsible for
accurately identifying/ classifying the waste.
Therefore, to ensure compliance with RCRA you should conduct a full-scale, or under certain
circumstances an abbreviated-scale, sampling, and laboratory testing program for all wastes
prior to managing the wastes. Full-scale analysis (e.g., EPA’s SW-846 methods or equiva-
lent) may be necessary when:
• A generator begins a new process or changes an existing process,
• Wastes are received by a facility for the first time,
• A generator has not provided appropriate laboratory information to an off-site TSDF,
• An off-site TSDF has reason to suspect that the wastes shipped were not accurately
identified by the generator, or
6–Waste 9/13

• EPA changes RCRA waste identification/classification rules.

Abbreviated waste analysis, often referred to as “fingerprint analysis,” is conducted
generally for parameters (e.g., specific gravity, color, flash point, presence of more than one
phase, pH, halogen content, cyanide content, percent water) that will give information that
can be used to help verify that the waste generated, or received by an off-site TSDF, matches
the expected characteristics for that waste. For example, at an off-site TSDF, fingerprint
analysis can be used to indicate that the waste received matches the description on the
manifest, and that the waste matches the waste type that the facility has agreed to accept.
Because the owner/operator of a TSDF already knows the detailed chemical and physical
properties of a waste, the appropriate fingerprint or spot check parameters can be chosen
easily, since the purpose of the fingerprint or spot check is only to verify that each waste
arriving at the gate of the TSDF is the actual waste expected. The number and character of
fingerprint parameters and the criteria for acceptance/rejection of the waste will be dis-
cussed in Part Two of this manual.
Option two: Selecting acceptable knowledge

Generators and TSDFs may use acceptable knowledge alone or in conjunction with sampling
and laboratory analysis. As previously stated, an off-site TSDF is not relieved of its responsi-
bility to obtain accurate waste analysis data despite the submission of erroneous information
provided to the TSDF by the generator. As discussed briefly on the previous page, however,
there are situations where it may be appropriate to apply acceptable knowledge, including:
• Hazardous constituents in wastes from specific processes are well documented, such
as with the F-listed and K-listed wastes.
• Wastes are discarded unused commercial chemical products, reagents or chemicals
of known physical, and chemical constituents. Several of these fall into the P-listed
and U-listed categories (40 CFR §261.33).
• Health and safety risks to personnel would not justify sampling and analysis (e.g.,
radioactive mixed waste).
• Physical nature of the waste does not lend itself to taking a laboratory sample.
Acceptable knowledge is not an appropriate substitute for fingerprint or spot check proce-
dures except in the unique case when the TSDF is accepting properly manifested waste from
another site owned by the same company. If you use acceptable knowledge in addition to or
in place of sampling and analysis, EPA, in enforcement cases, looks for documentation that
clearly demonstrates that the information relied upon is sufficient to identify the waste accu-
rately and completely. Documenting both the acceptable knowledge (e.g., knowledge of the
process that generated the F-listed or K-listed waste) as well as any analytical data is essen-
tial for identifying constituents applicable to LDR standards.
Waste analysis plan

A waste analysis plan (WAP) documents the procedures that you use to obtain a representa-
tive sample of the waste and to conduct a detailed chemical and physical analysis of this
representative sample. The WAP also can describe special handling procedures for proper
transportation, treatment, storage, or disposal of the wastes.
9/13 Waste–7

Although it is required for all treatment, storage, and disposal facilities (TSDFs), as well as
generators treating hazardous waste in tanks, containers, or containment buildings to meet
LDR standards, formal documentation of waste analysis procedures in a WAP offers every
facility, whether a generator or TSDF, many advantages, including:
• Allowing for planning and analyzing several waste analysis options before making a
selection;
• Establishing a reliable and consistent internal management mechanism for properly
identifying wastes on site;
• Ensuring that all participants in waste analysis have identical information (e.g., a
hands-on operating manual), thereby promoting consistency and decreasing the like-
lihood that errors will be made;
• Ensuring that facility personnel changes or absences do not lead to lost information;
and
• Reducing your liabilities by decreasing the instances of improper handling or man-
agement of wastes.
Developing the plan

There are six key elements in a WAP; however, you should note that there is no required
format for this plan.
Facility description
The facility description is an important element of an effective waste management program
(including a WAP). The facility description should provide sufficient, yet succinct, informa-
tion so that implementing officials and WAP users can clearly understand the type of:
• Processes and activities that generate or are used to manage the wastes,
• Hazardous wastes generated or managed, and
• Hazardous waste management units.
If your facility has an existing RCRA permit or is in the process of developing a permit
application, the majority of facility description information will be available from other sec-
tions of the permit. However, it is useful to include a summary of this information in the
WAP. At a minimum, the WAP should reference where in the permit (or permit application)
facility description information may be obtained.
Description of facility processes and activities

As a hands-on tool for ensuring compliance with applicable regulatory requirements and/or
permit conditions, the WAP should provide a description of all on-site facility processes and
activities that are used to generate or manage hazardous wastes (or reference applicable sec-
tions of the permit or permit application). This information should include facility diagrams,
narrative process descriptions, and other data relevant to the waste management processes
subject to waste analysis. As stated previously, since many TSDFs, especially off-site facili-
ties, utilize the WAP as an operating manual, it is advisable to incorporate process
descriptions directly into the document.
In addition to describing on-site processes and activities, off-site TSDFs should reference in
their WAPs that a brief description of each generator’s processes contributing wastes to the
facility will be obtained, updated, and kept on file as part of the operating record (which is
8–Waste 9/13

reviewed by EPA/state inspectors). If you own or operate a TSDF, this data will enhance
your knowledge of off-site generation processes and, therefore, improve your ability to deter-
mine the accuracy of generator waste classification.
Identification and quantities of hazardous wastes

Although the major concepts associated with identifying and classifying wastes as RCRA
listed or characteristic hazardous wastes were discussed previously, you should clearly iden-
tify the following in a WAP:
• Each hazardous waste generated or managed at your facility,
• Each process generating these wastes,
• Rationale for identifying each waste as hazardous, and
• Appropriate EPA waste classifications (e.g., EPA waste code, classification under
LDR regulations as wastewater or non-wastewater).
In addition to identifying all listed wastes generated or managed, you may need to conduct
testing and/or analysis to determine whether you also generate or manage any RCRA char-
acteristic wastes. If wastes are identified as characteristic, you may choose to present
relevant information such as the identity of hazardous waste, process generating the waste,
rationale for hazardous waste designation, EPA waste code, and land disposal restriction.
Description of hazardous waste management units

The final component of the facility description portion of the WAP should include a descrip-
tion of each hazardous waste management unit at the facility. As a supplement to generic
facility process and activity discussions, these descriptions should provide more detailed
information regarding the specific operating conditions and process constraints for each haz-
ardous waste management unit.
A hazardous waste management unit is defined in the RCRA regulations as a contiguous
area of land on or in which there is significant likelihood of mixing hazardous waste con-
stituents in the same area. Examples given in the regulations include:
• Container storage areas [Note: A container alone does not constitute a unit; the unit
includes containers and the land or pad upon which they are placed.]
• Tanks and associated piping and underlaying containment systems
• Surface impoundments
• Landfills
• Waste piles
• Containment buildings
• Land treatment units
• Incinerators
• Boilers and industrial furnaces
• Miscellaneous units
9/13 Waste–9

In your WAP, the description of the hazardous waste management units at your facility
should be provided in narrative and schematic form. The narrative description should
include the following:
• A physical description of each management unit, including dimensions, construction
materials, and components;
• A description of each waste type managed in each unit;
• The methods for how each hazardous waste will be handled or managed in the unit;
• Process/design considerations necessary to ensure that waste management units are
operating in a safe manner and are meeting applicable permit-established perfor-
mance standards; and
• Prohibitions that apply to the facility (e.g., PCBs in the incinerator feed, storage of
corrosive basic waste, unpermitted RCRA hazardous waste codes).
Selecting waste analysis parameters

An accurate representation of a waste’s physical and chemical properties is critical in deter-
mining viable waste management options. Accordingly, facility WAPs must specify waste
parameters that provide sufficient information to ensure:
• Compliance with applicable regulatory requirements (e.g., LDR regulations, newly
identified or listed hazardous wastes),
• Conformance with permit conditions (i.e., ensure that wastes accepted for manage-
ment fall within the scope of the facility permit, and process performance standards
can be met), and
• Safe and effective waste management operations (i.e., ensure that no wastes are
accepted that are incompatible or inappropriate given the type of management prac-
tices used by the facility).
Criteria for parameter selection

Waste analysis parameters must be selected to represent those characteristics necessary for
safe and effective waste management. Due to the diversity of hazardous waste operations
and the myriad of operating variables, the identification of the most suitable parameters to
be sampled and analyzed can be complex. To this point, relevant waste analysis parameter
selection criteria can be developed and reviewed systematically to efficiently identify param-
eters of interest. Generally, these selection criteria may be organized into the following
categories:
• Waste identification,
• Identification of incompatible/inappropriate wastes, and
• Process and design considerations.
Parameter selection process

Waste identification — Identify and classify hazardous wastes generated or managed
according to EPA waste codes. Determine any additional responsibilities for waste analysis
under LDR (i.e., verify whether wastes are restricted).
Then, identify incompatible/inappropriate wastes — Identify appropriate waste analy-
sis parameters to measure ignitability, reactivity, and incompatibility, as well as to identify
inappropriate wastes based on facility operations and the profile of waste being managed.
10–Waste 9/13

Then, identify the universe of parameters that may be required to evaluate the range of
process and design limitations — Determine the specific parameters necessary to iden-
tify waste acceptability with respect to process and design limitations, preferably for each
management unit. For pre-process, in-process, and post-process operating variables, select
parameters which indicate changes in waste composition that may affect waste management
(e.g., pH, specific gravity).
Then, evaluate — Eliminate parameters which are duplicate parameters selected during
previous parameter selection process elements or cannot be measured due to technological or
other limitations.
Rationale for parameter selection

Along with identifying waste analysis parameters, the RCRA regulations require that the
WAP provide the rationale for the selection of each parameter. The rationale must describe
the basis for the selection of the waste analysis parameter and how it will measure neces-
sary physical and chemical waste properties to afford effective waste management within
regulatory, permit, process and design conditions. This information will provide EPA permit
reviewers and WAP users with critical information regarding the viability of parameter
selection.
Special parameter selection requirements

WAPs must also include procedures and parameters for complying with the specialized
waste management regulatory requirements established for particular hazardous waste
management units. These regulatory requirements include special waste analyses for the
following:
• Facilities managing ignitable, reactive, or incompatible wastes,
• Landfills,
• Incinerator,
• TSDF process vents and equipment, and
• Boilers and industrial furnaces
Sampling, analytical, and procedural methods that will be used to meet additional waste
analysis requirements for specific waste management units must be included, where appli-
cable, in your WAP.
Selecting sampling procedures

Sampling is the physical collection of a representative portion of a universe or whole of a
waste or waste treatment residual. To be representative, a sample must be collected and
handled by means that will preserve its original physical form and composition, as well as
prevent contamination or changes in concentration of the parameters to be analyzed. For a
sample to provide meaningful data, it is imperative that it reflect the average properties of
the universe from which it was obtained, that its physical and chemical integrity be main-
tained, and that it be analyzed within a dedicated quality assurance program.
Due to the diversity of hazardous wastes and the number of possible waste management sce-
narios (e.g., drums, roll-off boxes, tankers, lugger boxes), the type(s) of sampling procedures
9/13 Waste–11

you will need to employ will be variable. The following subsections discuss the proper proce-
dures and considerations for sample collection, sample preservation, sample shipping,
quality assurance and quality control, and occupational health and safety.
You can choose to use sampling methods specified in the regulations in 40 CFR Part 261,
Appendix I, or you may choose to petition EPA for equivalent testing and analytical
methods.22 To be successful with this petition, you must demonstrate to the satisfaction of
EPA that the proposed method is equal, or superior, to the specified method.
Sampling strategies
The development and application of a sampling strategy is a prerequisite to obtaining a rep-
resentative sample capable of producing scientifically viable data. These strategies should be
selected or prepared prior to actual sampling to organize and coordinate sampling activities,
to maximize data accuracy, and to minimize errors attributable to incorrectly selected sam-
pling procedures. At a minimum, a sampling strategy should address the following:
• Objectives of collecting the samples,
• Types of samples needed (e.g., grab or composite),
• Selection of sampling locations,
• Number of samples,
• Sampling frequency, and
• Sample collection and handling techniques to be used.
In addition, the following factors should also be taken into consideration since they can
influence the sampling development process:
• Physical properties of the wastes to be sampled,
• Chemical properties of the wastes to be sampled, and
• Special circumstances or considerations (e.g., complex multi-phasic waste streams,
highly corrosive liquids).
Based upon the data objectives and considerations addressed in the sampling strategy, two
major sampling approaches may be employed to collect representative samples. These
approaches are summarized as follows:
• Authoritative Sampling — where sufficient historical, site, and process informa-
tion is available to accurately assess the chemical and physical properties of a
waste, authoritative sampling (also known as judgement sampling) can be used to
obtain representative samples. This type of sampling involves the selection of
sample locations based on knowledge of waste distribution and waste properties
(e.g., homogeneous process streams) as well as management units considerations.
Accordingly, the validity of the sampling is dependent upon the accuracy of the
information used. The rationale for the selection of sampling locations is critical and
should be well documented.
• Random Sampling— due to the difficulty of determining the exact chemical and
physical properties of hazardous waste streams that are necessary for using authori-
tative sampling, the most commonly used sampling strategies are random (not to be
confused with haphazard) sampling techniques. Generally, three specific techniques
12–Waste 9/13

-- simple, stratified, and systematic random — are employed. By applying these pro-
cedures, which are based upon mathematical and statistical theories, representative
samples can be obtained from nearly every waste sampling scenario.
Selecting sampling equipment

Three broad criteria relating to the waste should be considered when determining the most
appropriate type of sampling equipment to use for a given sampling strategy:
• Physical parameters — Specific physical parameters affecting this selection
include whether the wastes are free flowing or highly viscous liquids; crushed, pow-
dered, or whole solids; contained in soil or groundwater; and Homogeneous or
heterogeneous, stratified, subject to separation with transport, or subject to other
physical alterations due to environmental factors.
• Chemical parameters — The person collecting the sample should ensure that the
sampling equipment is constructed of materials that are not only compatible with
wastes, but are not susceptible to reactions that might alter or bias the physical or
chemical characteristics of the waste.
• Waste-specific (e.g., oily sludges) or site-specific factors (e.g., accessibility
issues) — In addition to determining the type of sampling equipment used, the
waste- and site-specific factors also may require modification of the chosen equip-
ment so that it can be applied to the waste.
Once the physical, chemical, waste- and site-specific factors associated with the waste
stream to be sampled have been identified and evaluated, appropriate sampling equipment
can be selected. The equipment most typically used in sampling includes:
• Composite liquid waste samplers (coliwasas), weighted bottles, and dippers for liq-
uid waste streams
• Triers, thieves, and augers for sampling sludges and solid waste streams
• Bailers, suction pumps, and positive displacement pumps for sampling wells for
groundwater evaluations.
Maintaining and decontaminating field equipment

Some analyses, such as pH, can be performed at the facility using field equipment. This
equipment must be properly maintained, and where appropriate, calibrated to ensure data
quality from the analyses. Maintenance of equipment can include routine cleaning, oil
changes, or routine replacement of worn equipment components. The guidelines set forth in
the operator’s manual of each piece of equipment should be followed since proper mainte-
nance varies by model manufacturer. At a minimum, the equipment should be inspected,
lubricated, and calibrated prior to any field work to ensure proper operation.
Sample preservation and storage

Once the sample has been collected, sample preservation techniques, if applicable, must be
employed to ensure that the integrity of the waste remains intact while the samples are in
transport to the laboratory and/or while temporarily stored at the laboratory prior to
analysis. Sample preservation is generally not applicable for highly concentrated samples.
However, low concentration samples require preservation.
9/13 Waste–13

Establishing quality assurance/quality control procedures

Quality assurance (QA) is the process for ensuring that all data and the decisions based on
that data are technically sound, statistically valid, and properly documented. Quality control
(QC) procedures are the tools employed to measure the degree to which these quality assur-
ance objectives are fulfilled. As the first component of data acquisition in relation to waste
analysis, sampling techniques should incorporate rigorous QA/QC procedures to ensure the
validity of sampling activities. Thus, it is important for QA/ QC procedures to be established
in the WAP and stringently followed.
Establishing health and safety protocols

Safety and health considerations should be taken into consideration when conducting sam-
pling at your facility. Employees who perform sampling activities must be properly trained
with respect to the hazards associated with waste materials, as well as with any waste han-
dling procedures that will assist in protecting the health and safety of the sampler.
In addition, the employees must be trained in the proper protective clothing and equipment
that must be used when performing sampling activities.
Selecting a laboratory and analytical testing methods

The use of proper analytical procedures is essential to acquiring useful and accurate data.
Obtaining accurate results requires an analytical laboratory that has demonstrated experi-
ence in performing waste sample analyses. When selecting a laboratory, preference should
be given to those that are capable of providing documentation of their proven analytical
capabilities, available instrumentation, and standard operating procedures. Furthermore,
the laboratory should be able to substantiate their data by systematically documenting the
steps taken to obtain and validate the data.
The analytical laboratory that you select should exhibit demonstrated experience and capa-
bilities in three major areas:
• Comprehensive QA/QC programs (both qualitative and quantitative),
• Technical analytical expertise, and
• Effective information management systems.
Selecting testing and analytical methods

To be useful in sustaining regulatory and permit compliance, the WAP must specify testing
and analytical methods which are capable of providing reliable data to ensure safe and effec-
tive waste management. The selection of an appropriate methodology is dependent upon the
following considerations:
• Physical state of the sample (e.g., solid or liquid),
• Analytes of interest (e.g., volatile organics),
• Required detection limits (e.g., 1/5 to ½ of the regulatory thresholds), and
• Information requirements (e.g., detection monitoring, verify compliance with LDR
treatment standards).
Analytical methods consist of two distinct phases — a preparation phase and a determina-
tion phase. The use of an appropriate combination of preparation and determination
14–Waste 9/13

procedures is necessary to ensure the accuracy of data generated from your facility waste
management program.
In addition to SW-846, the following references provide information on approved methods for
analyzing waste samples:
• American Society for Testing and Materials (ASTM)
• “Design and Development of a Hazardous Waste Reactivity Testing Protocol,” U.S.
Environmental Protection Agency, EPA Document No. 600/2-84-057 (February 1984)
• “The Toxicity Characteristic Rule” (55 FR 11862)
• “Methods for Chemical Analysis of Water and Wastes,” EPA Document No. 600/4-
79-020 (Revised March 1983).
Selecting waste re-evaluation frequencies

The RCRA regulations state that “waste analysis must be repeated as often as necessary to
ensure that it is accurate and up to date.” At a minimum, the analysis must be repeated as
follows:
• When the TSDF is notified, or has reason to believe that the process or operation
generating the hazardous wastes has changed,
• When the generator has been notified by an off-site TSDF that the characterization
of the wastes received at the TSDF does not match a pre-approved waste analysis
certification and/or the accompanying waste manifest or shipping paper (the genera-
tor may be requested to re-evaluate the waste), and
• Off-site combustion facilities should characterize all wastes prior to burning to verify
that permit conditions will be met (i.e., fingerprint analysis may not be acceptable).
Although there are no required time intervals for re-evaluating wastes, you must develop a
schedule for reevaluating the waste on a regular basis. You will need to make an individual
assessment of how often the wastes analysis is necessary to ensure compliance with your
interim status or Part B permit operating conditions.
Fingerprint analysis is never a substitute for conducting a complete waste analysis and,
therefore, may not be defensible if a waste is misidentified by the generator and passes the
fingerprint test. Though the generator is responsible for properly identifying and classifying
the waste, the TSDF will be held liable by enforcement authorities if it violates its permit
conditions and any other applicable regulations. The decision to conduct abbreviated cor-
roborative testing using fingerprint analysis on a few select parameters, or to conduct a
complete analysis to verify the profile, is ultimately determined by the off-site facility with
this in mind.
Special procedural requirements

You must also include procedures for receiving wastes generated off-site; procedures for
ignitable, reactive, and incompatible wastes; and provisions for complying with LDR require-
ments, if applicable.
9/13 Waste–15

What is your generator status?
Categories of generators
If you have determined that some of your wastes are hazardous, where do you go from
there? You need to measure the amount of waste you produce per month. The amount of
hazardous waste you generate determines your generator category.
Conditionally-exempt small quantity generator

Conditionally-exempt small quantity generators (CESQG) generate 220 lbs. (100 kilograms)
or less per month of hazardous waste, or 2.2 lbs (1 kilogram) or less per month of acutely
hazardous waste. Requirements for CESQGs include:
• CESQGs must identify all the hazardous waste generated.
• CESQGs may not accumulate more than 1,000 kilograms of hazardous waste at any
time.
• CESQGs must ensure that hazardous waste is delivered to a person or facility who
is authorized to manage it.
Be sure to check the state-level requirements in this area. Remember, any state can pass
more stringent regulations than the federal ones. Many states allow the accumulation of
only 100 kilograms of hazardous waste, some require manifests be used even by the under-
100/kg generator.
You could find your company subject to an overwhelming body of regulations simply because
you stored one drum of hazardous waste.
Small quantity generator

Small quantity generators (SQG) generate more than 220 lbs. (100 kilograms), but less than
2,200 lbs. (1,000 kilograms), of hazardous waste per month. Requirements for SQGs include:
• SQGs may accumulate hazardous waste on site for 180 days without a permit (or
270 days if shipping a distance greater than 200 miles).
• The quantity of hazardous on site waste must never exceed 6,000 kilograms.
• There must always be at least one employee available to respond to an emergency.
This employee is the emergency coordinator responsible for coordinating all emer-
gency response measures. SQGs are not required to have detailed, written
contingency plans.
If you qualify as a small quantity generator, the federal hazardous waste laws require you to
comply with the 1986 and 1987 rules for managing hazardous waste, including accumula-
tion, treatment, storage, and disposal requirements.
Large quantity generators

Large quantity generators (LQG) generate 2,200 lbs. (1,000 kilograms) per month or more of
hazardous waste, or more than 1 kilogram per month of acutely hazardous waste. Require-
ments for LQGs include:
• LQGs may only accumulate waste on site for 90 days. Certain exceptions apply.
• LQGs do not have a limit on the amount of hazardous waste accumulated on site.
16–Waste 9/13

• There must always be at least one employee available to respond to an emergency.

This employee is the emergency coordinator responsible for coordinating all emer-
gency response measures. LQGs must have detailed, written contingency plans for
handling emergencies.
• LQGs must submit a biennial hazardous waste report.
If you qualify as a generator of over 1,000 kg/mo the federal hazardous waste rules require
you to comply with all applicable hazardous waste management rules found in 40 CFR 260-
268.
Hazardous waste generator category comparison chart
The following chart shows the differences in regulatory requirements for the three generator
categories.
CESQGs SQGs LQGs

EPA ID Number N/A See 40 CFR 262.12 See 40 CFR 262.12
On-site accumulation ≤1,000 kg ≤1 kg acute ≤100 ≤6,000 kg See 40 CFR N/A
quantity kg of acute spill residue or 262.34(d)(1)
soil See 40 CFR 261.5(f)(2)
and (g)(2)
Accumulation time limits N/A ≤180 days or ≤270 days (if ≤90 days See 40 CFR 262.
greater than 200 miles) See 34(a)
40 CFR 262.34(d)(2) and
(3)
Consequences of exceed- See 261.5(g) See 40 CFR 262.34(f) N/A
ing quantity limits
Consequences of exceed- N/A See 40 CFR 262.34(e) See 40 CFR 262.34 (b)
ing accumulation time
limits
Storage requirements N/A See 40 CFR 262.34(d)(2) See 40 CFR 262.34(a)
and (3)
Sent To: State approved or RCRA RCRA permitted/interim sta- RCRA permitted/interim sta-
permitted/interim status tus facility See 40 CFR tus facility See 40 CFR
facility See 40 CFR 261. 262.20(b) 262.20(b)
5(f)(3) and (g)(3)
Marking and labeling N/A See 40 CFR 262.34 (a)(2) See 40 CFR 262.34 (a)(2)
and (a)(3) and (a)(3)
Manifest See 40 CFR 261.5 See 40 CFR 262.20 See 40 CFR 262.20
Biennial report N/A See 40 CFR 262.44 See 40 CFR 262.41
Recordkeeping N/A See 40 CFR 262.44 See 40 CFR 262.40
Emergency procedures N/A See 40 CFR 262.34 (d)(5) See 40 CFR 265.50-56
and response (i)-(ii) and (iv)
Personnel training N/A See 40 CFR 262. See 40 CFR 262.34(a)(4)
34(d)(5)(iii) and 265.16
Contingency plan N/A See 40 CFR §62.34(d)(5)(i) See 40 CFR 262.34(a)(4)
Preparedness and pre- N/A See 40 CFR 265.30-37 See 40 CFR 265.30-37
vention
Land disposal restrictions N/A See 40 CFR 268 See 40 CFR 268
Exception reporting N/A See 40 CFR262.42 See 40 CFR 262.42
DOT transport require- Yes (if required by DOT) See 40 CFR 262.30-262.33 See 40 CFR 262.30-262.33
ments
9/13 Waste–17

Air emissions N/A N/A See 40 CFR 265.1030-

Subpart AA 1035
Subpart BB See 40 CFR 265.1050-
1064
Subpart CC
See 40 CFR 265.1080-
1090
Measuring your hazardous waste

To determine which category of hazardous waste generator your business falls into — and
what requirements you must meet — you must measure or “count” the hazardous wastes
your business generates during a month. The total weight will determine your generator
category.
When you begin to count your hazardous wastes each month, it may be confusing at first to
determine what kinds of hazardous wastes you generate and how much. Here are some “dos”
and “don’ts” of what to count in your survey.
Do count
You do count all quantities of “Listed” and “Characteristic” hazardous wastes that you:
• Accumulate onsite for any period of time prior to subsequent management (see the
exception for ‘point of generation accumulation’ listed under the Don’t Count cat-
egory below).
• Package and transport offsite.
• Place directly in a regulated onsite treatment or disposal unit.
• Generate as still bottoms or sludges and remove from product storage tanks.
Don’t count
You do not have to count wastes that:
• Are specifically exempted from counting. Examples of these exempted wastes are:
❍ spent lead-acid batteries that will be sent offsite for reclamation,
❍ used oil that has not been mixed with hazardous waste.
• May be left in the bottom of containers that have been completely emptied through
conventional means, for example, by pouring or pumping. Containers that held an
acute hazardous waste must be more thoroughly cleaned.
• Are left as residue in the bottom of product storage tanks, if the residue is not
removed from the product tank.
• You reclaim continuously onsite without storing the waste prior to reclamation, such
as dry cleaning solvents. (You do have to count any residue removed from the
machine as well as spent cartridge filters.)
• You manage in an elementary neutralization unit, a totally enclosed treatment unit,
or a wastewater treatment unit. An elementary neutralization unit is a regulated
tank, container, or transport vehicle (including ships) which is designed to contain
and neutralize corrosive wastes.
18–Waste 9/13

• Are discharged directly to a publicly-owned treatment works (POTW) without being

stored or accumulated first. This discharge to a POTW must comply with the Clean
Water Act. POTWs are public utilities, usually owned by the city, county, or state,
that treat industrial and domestic sewage for disposal.
• You have already counted once during the calendar month, and treated onsite or
reclaimed in some manner, and used again.
• You accumulate at the point of generation (also known as “satellite accumula-
tion”) before transferring it to the on-site hazardous waste storage area, as long as
the following requirements are met:
❍ the container in which you accumulate the waste does not exceed 55 gallons (or
one quart of acutely hazardous waste);
❍ the container is located at or near the point of generation of the hazardous
waste;
❍ the operator of the process that generates the hazardous waste is in control of
management of the container; and
❍ the container is labeled ‘hazardous waste’ or uses other words which identify
the contents of the container, such as ‘spent petroleum distillates.’
Changing generator categories

Under federal law, you can go in and out of a given generator category, depending upon the
amount of hazardous waste you generate in a specific month.
For example, if, in June, you generate 100 kg or less of hazardous waste, you would be a
conditionally-exempt SQG for June. If, in July, your waste totals more than 100 kg but less
than 1,000 kg, your status changes and your July wastes would be subject to the require-
ments for SQGs.
If, in September, you generate 1,000 kg or more of hazardous waste, your September waste
would be subject to all applicable hazardous waste management regulations, as would all
other hazardous waste that you generated in previous months and mixed with your Septem-
ber wastes.
Again, check your state regulations. Remember, many states have different generator catego-
ries and requirements. For example, in Wisconsin, if you register as a generator (anyone
producing over 100 kg) you must report each month, even if you don’t produce 100 kg in a
given month. You can’t move in and out of the generator category, as the federal rules allow.
Obtaining an EPA identification number

If your business produces more than 100 kilograms of hazardous waste in any one month,
you will need to get an EPA Identification Number. Transporters and facilities that store,
treat, or dispose of regulated quantities of hazardous waste must also have EPA Identifica-
tion Numbers.
These 12-character identification numbers, used by both EPA and the states, are part of a
national data base to track hazardous waste activities. The application for the number
serves the purpose of notifying the state and federal government that your company is
9/13 Waste–19

involved in hazardous waste activity. The ID number that you receive is used on all docu-
ments relating to hazardous waste: manifests, biennial reports, labels.
To get your U.S. EPA Identification Number, call or write your state hazardous waste man-
agement agency or your EPA regional office and ask for a copy of EPA Form 8700-12,
“Notification of Hazardous Waste Activity.” You can also find a form and instructions here:
www.epa.gov/osw/inforesources/data/form8700/forms.htm.
NOTE: A few states use a form that is different from the federal form shown in the sample.
Your state will send you the appropriate form to complete.
How to fill out the form

Fill in the form with the information requested on the sample form. This information covers
your “installation” (your business site) and your hazardous wastes.
To complete Item X on the back of the form, you need to identify your hazardous waste,
using the EPA hazardous waste number. These numbers are a letter, followed by a three
digit number. For instance, D001 is the number for an ignitable waste.
You will need a copy of these hazardous waste numbers, so you can correctly identify what
you produce. The Appendix in this chapter contains some common waste types generated by
small quantity generators, along with their EPA hazardous waste numbers. For a complete
listing of hazardous waste numbers, check in the EPA Regulations under 261.32 – .33.
One site — one number

If you have several plant sites or business locations where you produce or handle hazardous
wastes, you will need to complete one copy of the form for each site. Each site will receive its
own EPA Identification Number.
Where to submit notification form

Make sure your form is filled out completely and correctly, and sign the certification in Item
IX. Send the form to the state hazardous waste agency or if your state requires it, to the
appropriate regional EPA office. Check the state section of this kit for the proper mailing
address. The address is listed in the information booklet you will receive with the form.
The information on the form will be recorded by both EPA and the state. You will be
assigned an EPA Identification Number. This number will be unique to the site identified on
your form. Use this number on all hazardous waste shipping papers. The hazardous waste
manifest, for instance, in space 1, requires you to list your EPA Identification Number.
The EPA Identification Number will stay with the business site or location that you
registered. If you move to another location, you must notify EPA or the state and submit a
new form. If the new location previously handled hazardous waste, and already had an ID
number, you will be assigned that number for the site after you have notified EPA.
20–Waste 9/13

OMB# 2050-0024; Expires 11/30/2011
SEND
COMPLETED
FORM TO: United States Environmental Protection Agency
The Appropriate RCRA SUBTITLE C SITE IDENTIFICATION FORM
State or Regional
Office.
1. Reason for Reason for Submittal:

Submittal To provide an Initial Notification (first time submitting site identification information / to obtain an EPA ID number
for this location)
MARK ALL To provide a Subsequent Notification (to update site identification information for this location)
BOX(ES) THAT As a component of a First RCRA Hazardous Waste Part A Permit Application
APPLY
As a component of a Revised RCRA Hazardous Waste Part A Permit Application (Amendment # )
As a component of the Hazardous Waste Report (If marked, see sub-bullet below)
Site was a TSD facility and/or generator of >1,000 kg of hazardous waste, >1 kg of acute hazardous waste, or
>100 kg of acute hazardous waste spill cleanup in one or more months of the report year (or State equivalent
LQG regulations)
2. Site EPA ID
EPA ID Number
Number
3. Site Name Name: -
4. Site Location Street Address:

Information
City, Town, or Village: County:
State: Country: Zip Code:
5. Site Land Type Private County District Federal Tribal Municipal State Other
6. NAICS Code(s) A. - C. -
for the Site
(at least 5-digit
codes) B. - D. -
7. Site Mailing Street or P.O. Box:

Address
City, Town, or Village:
8. Site Contact First Name: MI: Last:
Person
Title:
Street or P.O. Box:
City, Town or Village:
Email:
Phone: Ext.: Fax:
Date Became
9. Legal Owner A. Name of Site’s Legal Owner: Owner:
and Operator
of the Site Owner Type: Private County District Federal Tribal Municipal State Other
Street or P.O. Box:
City, Town, or Village: Phone:
Date Became
B. Name of Site’s Operator: Operator:
Operator
Type: Private County District Federal Tribal Municipal State Other
EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 11/2009) Page 1 of
9/13 Waste–21

EPA ID Number OMB#: 2050-0024; Expires 11/30/2011
10. Type of Regulated Waste Activity (at your site)

Mark “Yes” or “No” for all current activities (as of the date submitting the form); complete any additional boxes as instructed.
A. Hazardous Waste Activities; Complete all parts 1-7.
Y N 1. Generator of Hazardous Waste Y N 2. Transporter of Hazardous Waste

If “Yes”, mark only one of the following – a, b, or c. If “Yes”, mark all that apply.
a. LQG: Generates, in any calendar month, 1,000 kg/mo a. Transporter
(2,200 lbs./mo.) or more of hazardous waste; or b. Transfer Facility (at your site)
Generates, in any calendar month, or
accumulates at any time, more than 1 kg/mo (2.2
lbs./mo) of acute hazardous waste; or Y N 3. Treater, Storer, or Disposer of
Generates, in any calendar month, or Hazardous Waste Note: A hazardous
accumulates at any time, more than 100 kg/mo waste permit is required for these activities.
(220 lbs./mo) of acute hazardous spill cleanup
material. Y N 4. Recycler of Hazardous Waste
b. SQG: 100 to 1,000 kg/mo (220 – 2,200 lbs./mo) of non-

acute hazardous waste.
c. CESQG: Less than 100 kg/mo (220 lbs./mo) of non-acute Y N 5. Exempt Boiler and/or Industrial Furnace
hazardous waste. If “Yes”, mark all that apply.
a. Small Quantity On-site Burner
If “Yes” above, indicate other generator activities. Exemption
b. Smelting, Melting, and Refining
Y N d. Short-Term Generator (generate from a short-term or one- Furnace Exemption
time event and not from on-going processes). If “Yes”,
provide an explanation in the Comments section.
Y N e. United States Importer of Hazardous Waste Y N 6. Underground Injection Control
Y N f. Mixed Waste (hazardous and radioactive) Generator Y N 7. Receives Hazardous Waste from Off-site
B. Universal Waste Activities; Complete all parts 1-2. C. Used Oil Activities; Complete all parts 1-4.
Y N 1. Used Oil Transporter

Y N 1. Large Quantity Handler of Universal Waste (you If “Yes”, mark all that apply.
accumulate 5,000 kg or more) [refer to your State
regulations to determine what is regulated]. Indicate a. Transporter
types of universal waste managed at your site. If “Yes”,
mark all that apply. b. Transfer Facility (at your site)
a. Batteries Y N 2. Used Oil Processor and/or Re-refiner

If “Yes”, mark all that apply.
b. Pesticides
a. Processor
c. Mercury containing equipment
d. Lamps b. Re-refiner
e. Other (specify)
Y N 3. Off-Specification Used Oil Burner
f. Other (specify)
g. Other (specify) Y N 4. Used Oil Fuel Marketer
If “Yes”, mark all that apply.
Y N 2. Destination Facility for Universal Waste a. Marketer Who Directs Shipment of
Note: A hazardous waste permit may be required for this Off-Specification Used Oil to Off-
activity. Specification Used Oil Burner
b. Marketer Who First Claims the Used
Oil Meets the Specifications
22–Waste 9/13

D. Eligible Academic Entities with Laboratories—Notification for opting into or withdrawing from managing laboratory hazardous
wastes pursuant to 40 CFR Part 262 Subpart K
You must check with your State to determine if you are eligible to manage laboratory hazardous wastes pursuant to 40 CFR Part
262 Subpart K
1. Opting into or currently operating under 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories
See the item-by-item instructions for definitions of types of eligible academic entities. Mark all that apply:
a. College or University
b. Teaching Hospital that is owned by or has a formal written affiliation agreement with a college or university
c. Non-profit Institute that is owned by or has a formal written affiliation agreement with a college or university
2. Withdrawing from 40 CFR Part 262 Subpart K for the management of hazardous wastes in laboratories
11. Description of Hazardous Waste

A. Waste Codes for Federally Regulated Hazardous Wastes. Please list the waste codes of the Federal hazardous wastes handled at
your site. List them in the order they are presented in the regulations (e.g., D001, D003, F007, U112). Use an additional page if more
spaces are needed.
B. Waste Codes for State-Regulated (i.e., non-Federal) Hazardous Wastes. Please list the waste codes of the State-Regulated
hazardous wastes handled at your site. List them in the order they are presented in the regulations. Use an additional page if more
spaces are needed.
9/13 Waste–23

12. Notification of Hazardous Secondary Material (HSM) Activity
Y N Are you notifying under 40 CFR 260.42 that you will begin managing, are managing, or will stop managing hazardous
secondary material under 40 CFR 261.2(a)(2)(ii), 40 CFR 261.4(a)(23), (24), or (25)?
If “Yes”, you must fill out the Addendum to the Site Identification Form: Notification for Managing Hazardous Secondary
Material.
13. Comments
14. Certification. I certify under penalty of law that this document and all attachments were prepared under my direction or supervision in
accordance with a system designed to assure that qualified personnel properly gather and evaluate the information submitted. Based
on my inquiry of the person or persons who manage the system, or those persons directly responsible for gathering the information, the
information submitted is, to the best of my knowledge and belief, true, accurate, and complete. I am aware that there are significant
penalties for submitting false information, including the possibility of fines and imprisonment for knowing violations. For the RCRA
Hazardous Waste Part A Permit Application, all owner(s) and operator(s) must sign (see 40 CFR 270.10(b) and 270.11).
Signature of legal owner, operator, or an Name and Official Title (type or print) Date Signed
authorized representative (mm/dd/yyyy)
24–Waste 9/13

ADDENDUM TO THE SITE IDENTIFICATION FORM:

NOTIFICATION OF HAZARDOUS SECONDARY MATERIAL ACTIVITY
Before filling out this section:

You must check with your State to determine if you are eligible to manage hazardous secondary material under 40 CFR
261.2(a)(2)(ii), 261.4(a)(23), (24), or (25). (See also http://www.epa.gov/epawaste/hazard/dsw/statespf.htm.)
You must be managing hazardous secondary material, which is secondary material (e.g., spent material, by-product, or sludge)
that when discarded, would be identified as hazardous waste under 40 CFR Part 261. Do not include any information regarding
your hazardous wastes in this section.
You must submit a completed Site Identification Form, including this Addendum, prior to operating under the exclusion(s) and by
March 1 of each even-numbered year thereafter to your regulatory authority using the Site Identification Form as pursuant to 40
CFR 260.42. Persons who must staisfy this notification requirement can submit information at the same time as their Biennial
Report (which is also due by March 1 of each even-numbered year).
If you stop managing hazardous secondary material in accordance with the exclusions(s) and do not expect to manage any amount
of hazardous secondary material under the exclusions(s) for at least one year, you must also submit a completed Site Identification
Form, including this Addendum, within thirty (30) days pursuant to 40 CFR 260.42.
1. Indicate reason for notification. Include dates where requested.

Notifying that the facility will begin managing hazardous secondary material as of (mm/dd/yyyy).
Re-notifying that the facility is still managing hazardous secondary material.
Notifying that the facility has stopped managing hazardous secondary material as of (mm/dd/yyyy).
2. Description of hazardous secondary material (HSM) activity. Please list the appropriate codes and quantities in short tons to
describe your hazardous secondary material activity ONLY (do not include any information regarding your hazardous wastes in this
section). Use additional pages if more space is needed.
a. Facility code b. Waste code(s) for hazardous c. Estimated short d. Actual short tons e. Land-based unit
(answer using secondary material (HSM) tons of HSM to be of HSM that was code
codes listed in the managed annually managed during the (answer using codes
Code List section of most recent odd- listed in the Code
the instructions) numbered year List section of the
instructions)
3. Facility has financial assurance pursuant to 40 CFR 261 Subpart H. (Financial assurance is required for reclaimers and
intermediate facilities managing hazardous secondary material under 40 CFR 261.4(a)(24) and (25))
Y N Does this facility have financial assurance pursuant to 40 CFR 261 Subpart H?
EPA Form 8700-12, 8700-13 A/B, 8700-23 (Revised 11/2009) Addendum Page of
9/13 Waste–25

Used oil
Used oil is exactly what its name implies: any petroleum-based or synthetic oil that has
been used. During normal use, impurities such as dirt, metal scrapings, water, or chemicals,
can get mixed in with the oil, so that in time, the oil no longer performs well. Eventually,
this used oil must be replaced with virgin or re-refined oil to do the job correctly.
In 1992, EPA determined that used oil should not be regulated as a hazardous waste unless
the oil exceeds the regulatory limits for toxicity. Separate requirements were created for the
management of used oil, and are described in 40 CFR part 279. The program hinges on the
presumption that most used oil will be recycled instead of disposed.
What is used oil?

EPA’s defines used oil as any oil that has been refined from crude oil or any synthetic oil
that has been used and as a result of such use is contaminated by physical or chemical
impurities. Simply put, used oil is exactly what its name implies — any petroleum-based or
synthetic oil that has been used. During normal use, impurities such as dirt, metal
scrapings, water, or chemicals can get mixed in with the oil, so that in time the oil no longer
performs well. Eventually, this used oil must be replaced with virgin or re-refined oil to do
the job at hand. EPA’s used oil management standards include a three-pronged approach to
determine if a substance meets the definition of used oil. To meet EPA’s definition of used
oil, a substance must meet each of the following three criteria:
• Origin — the first criterion for identifying used oil is based on the origin of the oil.
Used oil must have been refined from crude oil or made from synthetic materials.
Animal and vegetable oils are excluded from EPA’s definition of used oil.
• Use — the second criterion is based on whether and how the oil is used. Oils used
as lubricants, hydraulic fluids, heat transfer fluids, buoyants, and for other similar
purposes are considered used oil. Unused oil such as bottom clean-out waste from
virgin fuel oil storage tanks or virgin fuel oil recovered from a spill, do not meet
EPA’s definition of used oil because these oils have never been “used.” EPA’s defini-
tion also excludes products used as cleaning agents or solely for their solvent
properties, as well as certain petroleum-derived products like antifreeze and
kerosene.
• Contaminants — the third criterion is based on whether or not the oil is contami-
nated with either physical or chemical impurities. In other words, to meet EPA’s
definition, used oil must become contaminated as a result of being used. This aspect
of EPA’s definition includes residues and contaminants generated from handling,
storing, and processing used oil. Physical contaminants could include metal shav-
ings, sawdust, or dirt. Chemical contaminants could include solvents, halogens, or
saltwater.
26–Waste 9/13

Use the following table to determine if the oil you have is used oil.
Used Oil Is*: Used Oil Is Not:

• Synthetic oil — usually derived from coal, shale, or • Waste oil that is bottom clean-out waste from virgin
polymer-based starting material. fuel storage tanks, virgin fuel oil spill cleanups, or
• Engine oil — typically includes gasoline and diesel other oil wastes that have not actually been used.
engine crankcase oils and piston-engine oils for auto- • Products such as antifreeze and kerosene.
mobiles, trucks, boats, air-planes, locomotives, and • Vegetable and animal oil, even when used as a
heavy equipment. lubricant.
• Transmission fluid. • Petroleum distillates used as solvents.
• Refrigeration oil. • Oils that do not meet EPA’s definition of used oil can
• Compressor oils. still pose a threat to the environment when disposed
• Metalworking fluids and oils. of and could be subject to the RCRA regulations for
hazardous waste management.
• Laminating oils.
• Industrial hydraulic fluid.
• Copper and aluminum wire drawing solution.
• Electrical insulating oil.
• Industrial process oils.
• Oils used as buoyants.
*This list does not include all types of used oil.
How is used oil recycled?

Once oil has been used, it can be collected, recycled, and used over and over again. An esti-
mated 380 million gallons of used oil are recycled each year. Recycled used oil can
sometimes be used again for the same job or can take on a completely different task. For
example, used motor oil can be re-refined and sold as motor oil or processed for furnace fuel
oil. Aluminum rolling oils also can be filtered on site and used over again.
Used oil can be recycled in the following ways:
• Reconditioned on site, which involves removing impurities from the used oil and
using it again. While this form of recycling might not restore the oil to its original
condition, it does prolong its life.
• Inserted into a petroleum refinery, which involves introducing used oil as a feed-
stock into either the front end of the process or the coker to produce gasoline and
coke.
• Re-refined, which involves treating used oil to remove impurities so that it can be used
as a base stock for new lubricating oil. Re-refining prolongs the life of the oil resource
indefinitely. This form of recycling is the preferred option because it closes the recycling
loop by reusing the oil to make the same product that it was when it started out, and
therefore uses less energy and less virgin oil.
• Processed and burned for energy recovery, which involves removing water and par-
ticulates so that used oil can be burned as fuel to generate heat or to power
industrial operations. This form of recycling is not as preferable as methods that
reuse the material because it only enables the oil to be reused once. Nonetheless,
valuable energy is provided (about the same as provided by normal heating oil).
9/13 Waste–27

Consider the following:

• Re-refining used oil takes only about one-third the energy of refining crude oil to
lubricant quality.
• It takes 42 gallons of crude oil, but only one gallon of used oil, to produce 2 1⁄2
quarts of new, high-quality lubricating oil.
• One gallon of used oil processed for fuel contains about 140,000 British Thermal
Units (BTUs) of energy.
The following are some of the businesses that handle used oil:
Generators are businesses that handle used oil through commercial or industrial operations
or from the maintenance of vehicles and equipment. Generators are the largest segment of
the used oil industry. Examples of common generators are car repair shops, service stations,
quick lube shops, government motor pools, grocery stores, metal working industries, and
boat marinas. Farmers who produce less than an average of 25 gallons of used oil per month
are excluded from generator status. Individuals who generate used oil through the mainte-
nance of their personal vehicles and equipment are not subject to regulation under the used
oil management standards.
Collection centers and aggregation points are facilities that accept small amounts of used oil
and store it until enough is collected to ship it elsewhere for recycling. Collection centers
typically accept used oil from multiple sources that include both businesses and individuals.
Aggregation points collect oil only from places run by the same owner or operator and from
individuals.
Transporters are companies that pick up used oil from all sources and deliver it to
re-refiners, processors, or burners. Transfer facilities include any structure or area where
used oil is held for longer than 24 hours, but not longer than 35 days. Examples of transfer
facilities are loading docks and parking areas.
Re-refiners and processors are facilities that blend or remove impurities from used oil so
that it can be burned for energy recovery or reused. Included in this category are re-refiners
who process used oil so that it can be reused in a new product such as a lubricant and
recycled again and again. EPA’s management standards primarily focus on this group of
used oil handlers:
• Burners burn used oil for energy recovery in boilers, industrial furnaces, or in haz-
ardous waste incinerators.
• Marketers are handlers who either a) direct shipments of used oil to be burned as
fuel in regulated devices or, b) claim that certain EPA specifications are met for used
oil to be burned for energy recovery in devices that are not regulated. They also
sometimes help move shipments of used oil to burners. By definition, marketers
must also fall into at least one of the above categories.
What standards should my business follow?

If your business generates or handles used oil, there are certain good housekeeping prac-
tices, called “management standards,” that you must follow. The management standards are
common sense, good business practices designed to ensure the safe handling of used oil, to
maximize recycling, and to minimize disposal. The standards apply to all used oil handlers,
regardless of the amount of the oil they handle. Although different used oil handlers may
28–Waste 9/13

have specific requirements, the following requirements are common to all types of handlers.
These requirements relate to storage and to cleaning up leaks and spills.
Storage requirements:
• Label all containers and tanks as Used Oil.
• Keep containers and tanks in good condition. Don’t allow tanks to rust, leak, or
deteriorate. Fix structural defects immediately.
• Never store used oil in anything other than tanks and storage containers. Used oil
may also be stored in units that are permitted to store regulated hazardous waste.
Tanks and containers storing used oil do not need to be RCRA permitted, however,
as long as they are labeled and in good condition. Storage of used oil in lagoons,
pits, or surface impoundments that are not permitted under RCRA is prohibited.
Oil spills and leak requirements:
• Take steps to prevent leaks and spills. Keep machinery, equipment containers, and
tanks in good working condition and be careful when transferring used oil. Have
sorbent materials available on site.
• If a spill or leak occurs, stop the oil from flowing at the source. If a leak from a con-
tainer or tank can’t be stopped, put the oil in another holding container or tank.
• Contain spilled oil. For example, containment can be accomplished by erecting
sorbent berms or by spreading a sorbent over the oil and surrounding area.
• Clean up the oil and recycle the used oil as you would have before it was spilled. If
recycling is not possible, you first must make sure the used oil is not a hazardous
waste and dispose of it appropriately. All used cleanup materials, from rags to
sorbent booms, that contain free-flowing used oil also must be handled according to
the used oil management standards. Remember, all leaked and spilled oil collected
during cleanup must be handled as used oil. If you are a used oil handler, you
should become familiar with these cleanup methods. They may also be part of a spill
response action plan.
• Remove, repair, or replace the defective tank or container immediately.
Recordkeeping requirements:
• EPA uses 12-digit identification (ID) numbers to track used oil. Transporters hauling
used oil must have a valid EPA ID number, and generators, collection centers, and
aggregation points must use transporters with EPA ID numbers for shipping used
oil off site. If you need an ID number, contact your EPA regional office or your state
director. (You also can call the RCRA Hotline for more information.) Generators, col-
lection centers, aggregation points, and any handler that transports used oil in
shipments of less than 55 gallons do not need an ID number, but may need a state
or local permit.
• Used oil transporters, processors, burners, and marketers also must record each
acceptance and delivery of used oil shipments. Records can take the form of a log,
invoice, or other shipping document and must be maintained for three years.
Re-refiners, processors, transfer facilities, and burners must have secondary contain-
ment systems (e.g., oil-impervious dike, berm, or retaining wall and a floor) so that
oil can not reach the environment in the event of a leak or spill. EPA also encour-
ages generators to use a secondary containment system to prevent used oil from
contaminating the environment.
9/14 Waste–29

• Burners of used oil that meets a certain set of quality standards called the used oil
specifications are not regulated under the used oil management standards, as long
as the used oil is burned in appropriate boilers, furnaces, or incinerators. Call the
RCRA Hotline for more information.
Remember that your state regulations governing the management of used oil might be
stricter than EPA’s. Contact your state or local environmental agency to determine your best
course of action.
Mixing used oil and hazardous waste

In addition to EPA’s used oil management standards, your business may be required to com-
ply with federal and state hazardous waste regulations if your used oil becomes
contaminated from mixing it with hazardous waste. If used oil is mixed with hazardous
waste, it probably will have to be managed as a hazardous waste. Hazardous waste disposal
is a lengthy, costly, and strict regulatory process. The only way to be sure your used oil does
not become contaminated with hazardous waste is to store it separately from all solvents
and chemicals and not to mix it with anything. If you believe your used oil might be mixed
with a hazardous waste, you will need to test it. You can also call your state environmental
office, which should be able to answer your questions or direct you to appropriate resources.
Cleanup practices
EPA recommends, but does not require, the following cleanup practices for used oil handlers:
• Maximize the recovery of used oil.
• Minimize the generation of used oil sorbent waste by choosing reusable sorbent
materials.
• Use the spent sorbent materials to produce recycled sorbent materials.
• Buy sorbent materials with recycled content.
Extraction devices (e.g., centrifuges, wringers, and compactors) can be used to recover used
oil from reusable sorbent materials. Sorbent pads can be reused between two and eight
times depending on the viscosity of the used oil. These technologies, while not required, can
be used to reduce the number of sorbent pads ultimately sent for remanufacture, energy
recovery, or disposal. The potential to reduce waste and save money (i.e., lower disposal
costs for spent pads and lower per use cost of sorbent pads) by reusing and recycling sorbent
pads can be substantial.
Sample plan
Provided here is a sample used oil plan. It is only a sample and is not intended to be all-
inclusive. It can, and should, be modified to meet specific EPA requirements and those of
your company.
30–Waste 9/14

Used oil management plan

Properly managing used oil is important for four main reasons:
• To protect the environment.
• To protect human health.
• To protect against liability for environmental damages.
• To reuse, rather than waste, a valuable resource.
Used oil, even when not classified as a hazardous waste under RCRA, can have harmful
effects if it is released into the environment. In addition, people’s health can be affected if
used oil is handled improperly.
Superfund regulations allow the federal government to hold any party that created or con-
tributed to the creation of a hazardous waste site (including some used oil) financially
responsible for cleanup costs.
Used oil is a valuable resource because it has lubrication value and heat value. When
treated to remove contaminants, the used oil can be used as a base stock to produce new
lubricating oil. Because used oil has heat value, it can be burned as fuel. Properly burning
the used oil keeps its heat value from being wasted and saves the virgin heating oil that
would be burned instead.
PURPOSE
__________________ has developed this plan to properly handle used oil. This plan informs
interested persons, including subcontractor employees, about this company’s compliance
with Environmental Protection Agency (EPA) requirements (found at 40 CFR 279) for
used oil generators.
This plan provides a written description of used oil management procedures, disposal
methods, and transportation requirements. We encourage any suggestions that our
employees have for improving our written plan for used oil management, as we are com-
mitted to developing and maintaining an effective protocol. We strive for clear
understanding, environmentally sound practices, and involvement in the plan from every
level of the company.
ADMINISTRATIVE DUTIES
__________________ is responsible for developing the written used oil management plan;
for ensuring that our written plan is complete, kept up to date, and made available to
applicable or required authorities; and for maintaining used oil management records. A
copy of our used oil management plan may be reviewed by employees. It is located (enter
your answer).
9/14 Waste–31

USED OIL MANAGEMENT

At this facility, we generate used oil from __________________ operations. It is likely to
contain the following contaminants __________________.
This company adheres to the following practices. We:

• Never dump or dispose of used oil in the trash, in sewers, or on the ground.
• Make sure our collection and storage set-up is leakproof, spillproof, and that
tanks have lids or are covered to prevent water from entering.
• Use lockable fills to prevent dumping of materials into the tank when it is not
supervised.
• Maintain our collection containers regularly, comply with local fire and safety
regulations, and avoid leaks and spills.
• Label storage tanks “Used Oil.”
• Clean up any used oil spills or leaks. This includes providing soak-up material
(e.g., sawdust, kitty litter, or a commercial product) for minor spills. It keeps the
area clean and helps prevent personal injury.
• Keep records of used oil sent to burners.
• ______________________.
Storing used oil

Our facility stores used oil in ________________. This facility follows these storage
practices. We:
• Never mix used oil with any other material. This facility keeps gasoline, solvents,
degreasers, paints, and so on, from making the used oil a hazardous waste and
increasing collection costs.
• Carefully record the amount of used oil placed into and removed from storage
devices. Recordkeeping plays an important role in leak detection for ASTs, USTs,
and drums.
• Have constructed secondary containment around our drums/tanks with a capacity
for 100 percent of the contents of the drums we store; the base of the containment
area is sloped so that any spilled oil may be recollected and removed.
• Equip storage containers with wide-mouth, long-necked funnels to reduce spills.
• Equip storage containers with a pressure relief valve to reduce a build up of pres-
sure, which could cause leaks.
• Keep sorbent materials such as kitty litter and sawdust to clean up any spills
that occur.
• Keep the area near the storage devices neat and clean.
• ______________________.
32–Waste 9/14

Recycling used oil

Recycling used oil cashes in on either its lubricating value or heat value. We use this
method of management whenever possible because is easier to do and more cost effective
than properly disposing of used oil.
At this facility, we recycle our used oil by the __________________ method because
__________________ .
Our facility generates 220 pounds or less per month of __________________, a hazardous
waste, and is therefore considered a conditionally exempt small quantity generator under
RCRA. Consequently, this facility __________________. Our onsite/offsite facilities satisfy
one of the following criteria:
• It is regulated under RCRA and meets all relevant RCRA requirements.
• It beneficially uses or reuses the waste, or legitimately recycles or reclaims the
waste.
• The facility treats the waste before it is beneficially used or reused, or recycled or
reclaimed.
Responding to releases of used oil

Even though all steps have been taken to prevent leaks or spills from occurring, this com-
pany is also prepared to respond to spills of used oil. We instruct workers to use the
following protocol to manage spills of used oil and provide any necessary equipment:
• Stop the release. This action will vary depending on why the release is occurring.
For example, if the spill occurs because a 55-gallon drum has been knocked over,
the drum should be righted to stop more used oil from being released.
• If the spill occurs because a valve on a storage device has been left open, the
valve should be closed. If a leak is a result of a puncture in the tank or drum,
rags or similar materials should be used to plug the leak.
• Contain the release. We strive to prevent the used oil that has been released from
spreading. For example, a sorbent, such as kitty litter or sawdust, should be
spread over the spilled used oil.
• Clean up the release. Depending on the extent of the release, cleaning up the
used oil can be a simple or a complicated task. For small spills on the ground, the
soil can be dug up and disposed of. (The soil must be tested to determine if it
exhibits hazardous characteristics.) For larger spills where puddles of used oil
have formed, vacuum-type machinery can be used to collect the used oil before the
soil is dug up for disposal. Because releases that contaminate a great deal of soil
or ground or surface water are very difficult to clean up, this company contacts
professionals to conduct the cleanup operation.
• Properly manage the used oil that has been cleaned up. Any leaked or spilled
used oil is managed just like any other used oil under 40 CFR 279.
• Properly manage the solid materials generated during the cleanup. We place solid
materials used to clean up a spill of used oil in a sieve-like container to allow the
used oil to drip from the solid materials into a storage device. In addition, we
9/13 Waste–33

compact the materials to remove the used oil. (Removal is complete when there
are no more signs of free-flowing oil.) Materials contaminated with used oil that
are burned can be managed in the same manner as used oil.
• Contaminated materials that will not be burned for energy are tested to deter-
mine if they exhibit hazardous waste characteristics. If they do not test
hazardous, they are disposed of in a RCRA subtitle D facility. If they are hazard-
ous, they are disposed of in a RCRA subtitle C facility.
• Remove the storage device from service and repair or replace it.
Disposing of used oil

Although recycling is the best management option for used oil, this company has discov-
ered this option is not feasible. Knowledge of how the used oil was generated or testing
has revealed that our used oil is contaminated with __________________. This used oil is
__________________ to be economically recycled. Therefore, we have chosen to properly dis-
pose of our used oil.
Because our used oil is contaminated with halogens in concentrations less than 1,000 ppm
or not considered a hazardous waste, we place the used oil in a landfill that accepts indus-
trial wastes and meets RCRA Subtitle D requirements.
Managing and disposing of used oil filters

Whenever this company changes the oil in a fleet vehicle, the oil filter is also changed to
keep the solid contaminants of the old oil from immediately contaminating the new oil.
Used oil filters can contain 10 to 16 ounces of used oil, therefore proper management of
this source of used oil is a concern of this company. Used oil filters are not considered a
hazardous waste under RCRA if they are not terne-plated and have been properly drained
of oil.
When used oil filters are removed from a warm engine, this company uses the
__________________ method to drain the filter.
We store our drained used oil filters in a covered, rainproof container to prevent used oil
from being washed from the filters to the surrounding environment. Our used oil filters
are then recycled or properly disposed of.
Shipping/Transporting used oil

The used oil management standards define a used oil transporter as any person who
transports used oil, any person who collects used oil from more than one generator and
transports the collected oil, and owners and operators of used oil transfer facilities.
_______________ has chosen __________________ to transport our used oil. Our transporter
has an EPA ID number and complies with all relevant used oil regulations, including
keeping tracking records of where the used oil is collected and where it will be trans-
ported to. When working with our transporter, we:
• Know that the hauler has an EPA ID number.
34–Waste 9/13

• Check our hauler’s qualifications to make sure the hauler takes the oil to a repu-
table recycling operation.
• Measure the level of oil in a tank before and after the hauler collects it to be cer-
tain the oil collected matches the amount the hauler reports collecting.
• Make sure a company representative signs and dates the hauler’s tracking sheet.
• Ask for a receipt from the transporter that states how much used oil was collected
from our facility and where the used oil will be taken. (These records are not
required under the used oil management standards, but may be useful should a
problem arise.)
• Make sure that the hauler maintains storage tanks/containers; labels containers
“Used Oil”; stores used oil over oil-impervious surfaces; has secondary contain-
ment structures in place; stores used oil for no more than 35 days; tests waste in
out-of-service tanks; closes out-of-service tanks containing hazardous waste
according to EPA standards.
• ______________________.
EMPLOYEE TRAINING
Although training is not strictly required under the regulations, we have designated
__________________ to train personnel who will handle used oil. Direct any questions con-
cerning used oil training to this person.
Under this plan, employees are informed of used oil management procedures relevant to
the positions in which they work. This training occurs both in the classroom and on the
job.
We keep records of job titles and written job descriptions for all positions related to used
oil management and the names of employees qualified for each job. We also keep records
describing the type and amount of training provided.
RELATED REQUIREMENTS
Related regulations that we must still comply with include:
• Underground Storage Tank regulations (40 CFR 280)
• Spill Prevention Control and Countermeasures requirements (40 CFR 112)
• Hazardous Materials Transportation Act regulations (49 CFR 130)
• Resource Conservation and Recovery Act requirements (40 CFR 260-268)
• Polychlorinated Biphenyls (PCBs) Manufacturing, Processing, Distribution in
Commerce, and Use Prohibitions (40 CFR 761). This regulation, specifically, 40
CFR 761.20(e), contains restrictions, and testing and recordkeeping requirements
for marketers and burners.
Please see related documents for information on how this company meets these additional
requirements.
9/14 Waste–35

REPORTING
Our company performs the following reporting activity(ies):
• ______________________.
RECORDKEEPING
____________________ is responsible for keeping the following records:
• ______________________.
MAINTAINING THE PLAN

____________________ is responsible for:
• Conducting periodic site audits.
• Keeping records of all inspections and reports.
• Updating the plan as needed by incorporating any necessary changes resulting
from major changes in our facility’s operation or maintenance.
• ______________________.
36–Waste 9/14

Shop towels and rags

In July 2013, EPA issued a final rule that exempts most solvent-
contaminated wipes from being considered hazardous wastes under
RCRA. A solvent-contaminated wipe is a wipe (i.e., shop towel, rag,
pad, or swab made of wood pulp, fabric, cotton, polyester blends, or
other material) that would be considered hazardous waste either
because it is contaminated with a waste listed in the hazardous
waste regulations, or because it exhibits a characteristic of
ignitability. Note that under the definition of solvent-contaminated
wipe, the wipe cannot be contaminated with a hazardous waste
other than a solvent, or a waste that exhibits another characteristic
such as toxicity, corrosivity, or reactivity due to contaminants other
than solvents. In that case, the wipes must be managed as hazard-
ous wastes. The rule takes effect in January 2014.
Under the rule:
• Solvent-contaminated wipes that are laundered and reused are neither solid
wastes nor hazardous wastes, provided certain conditions are met. These reusable
wipes must be sent to laundries or dry cleaners whose discharge is also regulated.
• Solvent-contaminated wipes that are disposed of are not hazardous wastes,
provided certain conditions are met. These wipes may be sent to combustors that
are regulated under the Clean Air Act, municipal solid waste landfills, or hazardous
waste landfills.
Solvent-contaminated wipes that are managed under the conditions listed below will not
need to be manifested when being sent off-site.
Management conditions
In order to be eligible for the exemption, wipes must be managed as follows:
• Store used wipes in closed containers that are labeled “Excluded Solvent-
Contaminated Wipes.” EPA says that managing the wipes in non-leaking, closed
containers ensures that the solvents are unlikely to be released into the
environment. Further, closed and labeled containers serve to minimize emissions,
prevent spills, and reduce the risk of fires, for example, by keeping the wipes away
from potentially incompatible wastes or ignition sources.
• Wipes may not contain free liquids when sent for cleaning or disposal.
Removing free liquids prior to sending the wipes off-site significantly reduces the
potential for the release of solvents into the environment, such as through leaks or
spills. Free liquid solvent removed from the wipes must then be managed as a haz-
ardous waste, as appropriate, and may be recycled.
• Facilities may not accumulate wipes for longer than 180 days. The time limit
ensures that free liquids are removed from the solvent-contaminated wipes and con-
tainers and that they are not stored indefinitely on-site.
9/13 Waste–37

• Facilities must comply with recordkeeping requirements. Generators must

maintain certain documentation on-site so that states and EPA can ensure the gen-
erators are maintaining compliance with the conditions of the exclusion. This
documentation must include:
❍ The name and address of the laundry, dry cleaner, landfill, or combustor,
❍ Documentation that the 180-day accumulation limit is being met, and
❍ Description of the process the generator is using to meet the “no free liquids”
condition.
Note that states may apply their own management requirements to solvent-contaminated
wipes that are stricter than federal requirements. Check with your state to be sure you are
in compliance with the requirements in your area.
TCLP and land ban

Effective September 25, 1990, large quantity generators were required by the U.S. Environ-
mental Protection Agency (EPA) to document that their hazardous waste has been evaluated
for toxicity using the new Toxicity Characteristics Leaching Procedure (TCLP). Small quan-
tity generators (those generating less than 1,000 kilograms or 2,200 pounds of hazardous
waste per month) were to meet the same requirements by March 29, 1991.
The TCLP replaces the Extraction Procedure Toxicity (EP-Tox) test, used by the EPA to
determine if certain metal- and pesticide-bearing wastes had to be managed as hazardous
waste. Both tests simulate the acidic conditions in landfills that can leach toxic metals and
organics into ground water. The TCLP test is significantly more sensitive and accurate than
the EP-Tox test. Therefore, TCLP test results for metal content may be five to ten times
higher than they were using the EP-Tox test. For this reason, wastes which tested nonhaz-
ardous with the EP-Tox may be considered hazardous with the TCLP. Generators will need
to use the TCLP to re-test all wastes which were previously determined by the EP-Tox test
to be non-hazardous.
Generators with an EPA identification number and who have already notified the EPA that
they generate other hazardous wastes are not required by this rule to notify the EPA that
they now generate a toxic waste, based on the new test. They will, however, need to file an
amended hazardous waste disclosure form with the EPA if the TCLP reveals that their com-
pany’s waste is now hazardous for toxicity.
Major industries which are likely to be affected by the new test include:
• Maintenance shops/lubrication centers
• Pulp and paper production
• Wholesale petroleum marketing
• Pharmaceutical production
• Synthetic rubber manufacturing
• Textile production
• Lumber and wood product manufacturing
• Petroleum, rubber, plastics and coal products manufacturing
38–Waste 9/13

• Petroleum refining
• Organic chemical processing
• Plastic material and resin production
• Synthetic fiber manufacturing
• Non-natural gas pipeline maintenance
The leather-processing industry, service stations and fiberglass manufacturers may also be
affected.
The EPA has issued a final rule that puts used oil destined for disposal under the TCLP
method of hazard determination. Used oil destined for recycling is currently regulated by the
TCLP as well, with EPA to issue a final rule soon.
The EPA’s new requirement keeps the existing list of eight metals and six pesticides from
the EP-Tox test and adds 25 new chemicals for analysis. If, after applying the TCLP to a
waste sample, any of these 39 chemicals are present in the extract or leachate at or above
regulatory levels, the waste is hazardous for toxicity.
The newly added chemicals will be incorporated into the EPA’s remaining land ban
regulations. These regulations require that most hazardous wastes be treated before they
are disposed of in hazardous waste landfills. The EPA has yet to establish regulatory treat-
ment standards for all the new chemicals. Until then, generators may manage their newly-
defined hazardous waste according to the basic hazardous waste regulations, including
proper on-site management and use of licensed transporters and authorized disposal
facilities.
For information about industry-specific processes or constituents, contact the Resource Con-
servation and Recovery Act (RCRA) hotline at 800/424-9346. Find EPA’s table listing the
maximum concentration of contaminants for the toxicity characteristic at 1.usa.gov/
maxtox46M.
Waste minimization plans

Waste minimization or reduction is any activity that reduces or eliminates the generation of
hazardous waste at the source, usually within a production process. These source reduction
methods include such activities as improved operating and housekeeping practices, raw
material substitutions, equipment modifications, production process changes, recycling, and
waste segregation.
The federal hazardous waste regulations require certification of having a waste
minimization plan in place whenever a hazardous waste manifest is signed. The
regulations also require a description of steps taken to reduce hazardous waste generation
when submitting biennial reports.
For manifests
Large quantity generators (LQGs) certify they have a waste minimization “program in place
to reduce the volume and toxicity of waste generated to the degree they have determined to
be economically practicable” every time they sign a hazardous waste manifest [40 CFR 262.
23(a)(1)].
9/13 Waste–39

Small quantity generators (SQGs) are not required to have a program in place. However,
every time SQGs sign a manifest, they are certifying that they have “made a good faith
effort to minimize their waste generation” [40 CFR 262.23(a)(1)].
For more information on hazardous waste manifests, see the Uniform Hazardous Waste
Manifest section later in this chapter.
For biennial reports
Federal hazardous waste regulations require biennial reports for all large quantity genera-
tors; treatment, storage and disposal facilities (TSDFs); and interim status TSDFs. EPA
requires biennial reports to include a description of:
• Steps taken during the year to reduce the volume and toxicity of waste generated,
and
• Actual changes in the waste’s volume and toxicity achieved during the year in com-
parison to previous years.
For more information on biennial reporting, see the biennial reporting section later in this
chapter.
Developing a waste minimization plan
When preparing a waste minimization plan, be sure to refer to state hazardous waste regu-
lations in addition to the federal regulations, since EPA has authorized many state
hazardous waste programs. EPA does not specify the criteria a waste minimization plan
must meet or information the plan must include. On the other hand, many states have
developed detailed guidelines for preparing waste minimization plans. Suggested elements of
a written waste minimization plan include, but are not limited to:
• Policy statement
• Goals
• Framework for setting up and evaluating the program
• Provisions for communication
Before developing a waste minimization program, you may wish to contact your regional
EPA office or your state hazardous waste program office for additional assistance.
Waste minimization and reduction best practices

Waste minimization includes good hazardous waste management. Best management prac-
tices include:
• Using and reusing materials as much as possible;
• Recycling or reclaiming waste;
• Treating waste to reduce its hazards; and
• Reducing the amount of waste that you generate.
To reduce the amount of waste that you generate:
• Do not mix nonhazardous wastes with hazardous wastes, because then the entire
contents becomes subject to the hazardous waste regulations.
40–Waste 9/13

For example, by putting nonhazardous cleaning agents and rags in the same con-
tainer as a hazardous solvent, you may have doubled the amount of hazardous
waste you have.
• Avoid mixing several different hazardous wastes. Even though you can mix compat-
ible wastes, it makes recycling difficult, if not impossible and could make disposal
more expensive.
• Avoid spills or leaks of hazardous products because the materials used to clean up
spills become hazardous.
• Make sure the original containers of hazardous products are completely empty
before you throw them away. Use all the product.
• Avoid using more of a hazardous product than you need. For example, use no more
degreasing solvent or pesticide than you need to do the job. Also, do not throw away
a container with unused solvent or pesticide in it.
• Purchase products that are less hazardous when you can. You can switch from
organic solvents to water-based solvents, for instance.
Reducing your hazardous waste makes good sense. You save money on the raw materials.
You save money also on the managing and disposing of your hazardous wastes.
And, in the long run, you save money by not having to clean up the environment.
Waste minimization FAQs

Q. What is Waste minimization?
A. Waste minimization refers to the use of source reduction and/or environmentally sound
recycling methods prior to energy recovery, treatment, or disposal of wastes. Waste mini-
mization does not include waste treatment, that is, any process designed to change the
physical, chemical, or biological composition of waste streams. For example, compacting,
neutralizing, diluting, and incineration are not typically considered waste minimization
practices. EPA’s preferred hierarchical approach to materials management includes
source reduction, recycling, energy recovery, treatment, and finally, disposal.
Source reduction, commonly known as pollution prevention (P2), reduces or eliminates

the generation of waste at the source and refers to any practice that reduces the use of
hazardous materials in production processes.
Common examples of source reduction include:

• Early retirement of equipment such as mercury-containing devices like switches and
thermostats;
• Reformulating or redesigning products, such as creating new PVC compounds with-
out using lead;
• Using less toxic feedstocks, such as switching to the use of lead-free solder in
manufacturing;
• Improving work practices, such as reorganizing paint batches in order to reduce
cleaning operations.
9/13 Waste–41

Recycling, or reclaiming value from production by-products, can often be used when P2
is not economically practical. Recycling includes the reuse or recovery of in-process mate-
rials or materials generated as by-products that can be processed further on-site or sent
offsite to reclaim value. Recycling is a broad term that encompasses the reuse of materi-
als in original or changed forms rather than discarding them as wastes. Recycling can
also be thought of as the collection and reprocessing of a resource so it can be used again,
though not necessarily for its original purpose.
Common examples of recycling include:

• Direct use/reuse of a waste in a process to make a product, such as reusing a purge
product used to clean paint lines rather than disposing of it by incineration.
• Processing the waste to recover or regenerate a usable product, such as collecting
vapor from drycleaning operations, turning it back into liquid, and reusing the liq-
uid to clean more clothes.
• Using/reusing waste as a substitute for a commercial product. When mercury is
recycled from old equipment like switches, it can be used in new products that still
require mercury, such as fluorescent bulbs. Recycling of mercury has been so suc-
cessful that there is now enough recycled mercury in the U.S. that manufacturers
do not need to use new mercury from mines.
Q. What are the benefits of waste minimization?
A. Waste minimization not only protects the environment, it also makes good economic and
business sense. For example, reducing waste generation through waste minimization has
helped some companies change their RCRA regulatory status from large quantity genera-
tor (1000 or more kilograms of hazardous waste generated per month) to small quantity
generator (between 100 and 1000 kg of hazardous waste generated per month), or to con-
ditionally exempt small quantity generator (up to 100 kg of hazardous waste generated
per month). Some have managed to eliminate the generation of hazardous waste and
avoid RCRA regulatory requirements altogether.
Source reduction and/or environmentally sound recycling, reuse, and reclamation prac-
tices have helped many organizations reduce:
• The quantity and toxicity of hazardous and solid waste generation
• Raw material and product losses
• Raw material purchase costs
• Waste management recordkeeping and paperwork burden
• Waste management costs
• Workplace accidents and worker exposure
• Compliance violations
• Environmental liability
At the same time, waste minimization can improve:
• Production efficiency
• Profits
• Good neighbor image
42–Waste 9/13

• Product quality
• Environmental performance
Q. What is the difference between waste minimization and Pollution Prevention?
A. Waste minimization is a term found in the Resource Conservation and Recovery Act
(RCRA) that refers to source reduction and environmentally sound recycling of RCRA
hazardous waste. Pollution Prevention is a term found in the Pollution Prevention Act of
1990 that refers to source reduction of all toxic wastes, including those released to air,
water and land resources. Source reduction includes any practice that reduces the quan-
tity and/or toxicity of pollutants entering a waste stream prior to recycling, treatment, or
disposal. Examples include equipment or technology modifications, reformulation or rede-
sign of products, substitution of less toxic raw materials, improvements in work practices,
maintenance, worker training, and better inventory control.
Environmentally sound recycling includes the use, reuse and/or reclamation of residuals
that may be designated as a hazardous waste, or materials in a hazardous waste. A mate-
rial is “used or reused” if it is used as an ingredient in an industrial process to make a
product or, or if it is used as an effective substitute for a commercial product. A material
is “reclaimed” if it is processed to recover a usable product, or if it is regenerated.
Q. Is Waste minimization required by law?
A. In 1984, amendments to RCRA established the following national policy, making waste
minimization the nation’s preferred hazardous waste management practice: “...the gen-
eration of hazardous waste is to be reduced or eliminated as expeditiously as possible.
Waste that is nevertheless generated should be treated, stored, or disposed of so as to
minimize the present and future threat to human health and the environment.”
RCRA requires facilities that generate or manage hazardous waste to certify that they
have a waste minimization program in place that reduces the quantity and toxicity of
hazardous waste generated to the extent economically practicable.
In 1990, passage of the Pollution Prevention Act expanded the nation’s waste prevention
policy beyond a RCRA-only framework, to minimizing or eliminating toxic releases to all
environmental media and natural resources: “The Congress hereby declares it to be the
national policy of the United States that pollution should be prevented or reduced at the
source whenever feasible; pollution that cannot be prevented should be recycled in an
environmentally safe manner, whenever feasible; pollution that cannot be prevented or
recycled should be treated in an environmentally safe manner whenever feasible; and dis-
posal or other release into the environment should be employed only as a last resort and
should be conducted in an environmentally safe manner.”
The Pollution Prevention Act has encouraged many organizations to expand their focus
from RCRA-only to a multimedia pollution prevention focus. EPA offers a variety of infor-
mation sources on multimedia pollution prevention.
Many states have also enacted laws that require facilities to complete certain waste mini-
mization activities. Most of these states require facilities to complete a waste
minimization plan.
9/13 Waste–43

Appendix: EPA hazardous waste numbers for waste streams

commonly generated by small quantity generators
The Environmental Protection Agency recognizes that generators of small quantities of haz-
ardous waste, many of which are small businesses, may not be familiar with the manner in
which hazardous waste materials are identified. This Appendix has been assembled to aid
100–1000 kg/mo small quantity generators in determining the EPA Hazardous Waste Num-
bers for their wastes. These numbers are needed to complete the “Notification of Hazardous
Waste Activity.” Form 8700-12.
This Appendix contains lists of EPA Hazardous Waste Numbers for each waste stream iden-
tified in Table 1 in this section. Note that acutely hazardous wastes are identified with an
asterisk (*).
To use this appendix

1. Locate your business type in Table 1. This will help you to identify the waste
streams common to your activities.
2. Find each of the waste streams that you identified in Table 1 in the more detailed
descriptions in this Appendix. Review the more detailed descriptions of typical
wastes to determine which waste streams actually result from your activities.
3. If you determine that you actually do generate a particular waste stream, report the
four-digit EPA Hazardous Waste Number in Item X of Form 8700-12, “Notification of
Hazardous Waste Activity.”
The specific instructions for completing Item X (Description of Hazardous Wastes) of the
notification form are included in the notification package. You should note, however, that
specific EPA Hazardous Waste Numbers beginning with:
• “F” should be entered in Item X, Section A.
• “K” should be entered in Item X, Section B.
• “P” or “U” should be entered in Item X, Section C.
• “D” should be entered in Item X, Section E.
The industries and waste streams described here do not provide a comprehensive list, but
rather serve as a guide to potential small quantity generators in determining which of their
wastes, if any, are hazardous. Except for the pesticide and wood preserving categories, this
Appendix does not include EPA Hazardous Waste Numbers for commercial chemical prod-
ucts that are hazardous when discarded unused. These chemicals and their EPA Hazardous
Waste Numbers are listed in Title 40 of the Code of Federal Regulations (40 CFR) in Section
261.33.
If the specific EPA Hazardous Waste Number that should be applied to your waste stream is
unclear, please refer to 40 CFR Part 261. In those cases where more than one EPA Hazard-
ous Waste Number is applicable, all should be used. If you have any questions, or if you are
unable to determine the proper EPA Hazardous Waste Numbers for your wastes, contact
your state hazardous waste management agency, or the RCRA/Superfund Hotline — 1-800-
424-9346.
44–Waste 9/13

Solvents:
Spent solvents, or solvent still bottoms or mixtures containing solvents are often hazardous.
This includes solvents used in degreasing and paint brush cleaning, and distillation residues
from reclamation. The following are some commonly used hazardous solvents (also see ignit-
able wastes for other hazardous solvents, and 40 CFR 261.31 for most listed hazardous
waste solvents):
Benzene ............................................................................................................................ D001
Carbon Disulfide ................................................................................................................. F005
Carbon Tetrachloride ............................................................................................................ F001
Chlorobenzene ................................................................................................................... F002
Cresols ............................................................................................................................. F004
Cresylic Acid ...................................................................................................................... F004
O-Dichlorobenzene .............................................................................................................. F002
Ethanol ............................................................................................................................. D001
Ethylene Dichloride .............................................................................................................. D001
Isobutanol .......................................................................................................................... F005
Isopropanol ........................................................................................................................ D001
Kerosene ........................................................................................................................... D001
Methyl Ethyl Ketone ............................................................................................................. F005
Methylene Chloride (sludges) ................................................................................................. F001
(still bottoms) F002
Naphtha ............................................................................................................................ D001
Nitrobenzene ...................................................................................................................... F004
2-Nitropropane .................................................................................................................... F005
Petroleum Solvents (Flashpoint less than 140°F) ....................................................................... D001
Pyridine ............................................................................................................................. F005
1,1,1-Trichloroethane (sludges) ............................................................................................... F001
1,1, 2-Trichloroethane .......................................................................................................... F002
Tetrachloroethylene
(Perchloroethylene) (sludges) ............................................................................................. F001
Toluene ............................................................................................................................. F005
Trichloroethylene (sludges) .................................................................................................... F001
Trichlorofluoromethane ......................................................................................................... F002
Trichlorotrifluoroethane
(Valclene) ...................................................................................................................... F002
White Spirits ....................................................................................................................... D001
Acids/Bases:
Acids, bases, or mixtures having a pH less than or equal to 2 or greater than or equal to
12.5, are considered corrosive (for a complete description of corrosive wastes, see 40 CFR
261.22, Characteristic of corrosivity). All corrosive materials and solutions have the EPA
9/13 Waste–45

Hazardous Waste Number D002. The following are some of the more commonly used corro-
sives:
Acetic Acid Oleum
Ammonium Hydroxide Perchloric Acid
Chromic Acid Phosphoric Acid
Hydrobromic Acid Potassium Hydroxide
Hydrochloric Acid Sodium Hydroxide
Hydrofluoric Acid Sulfuric Acid
Nitric Acid
Dry Cleaning Filtration Residues:

Cooked powder residue (perchloroethylene plants only), still residues, and spent cartridge
filters containing perchloroethylene or valclene are hazardous and have the EPA Hazardous
Waste Number F002.
Still residues containing petroleum solvents with a flashpoint less than 140°F are considered
hazardous and have the EPA Hazardous Waste Number D001.
Heavy Metals/Inorganics:
Heavy metals and other inorganic waste materials exhibit the characteristic of EP Toxicity
and are considered hazardous if the extract from a representative sample of the waste has
any of the specific constituent concentrations as shown in 40 CFR 261.24, Table 1. This may
include dusts, solutions, wastewater treatment sludges, paint wastes, waste inks, and other
such materials which contain heavy metals/inorganics (note that wastewater treatment slud-
ges from electroplating operations are identified as F006). The following are EP Toxic:
Arsenic .............................................................................................................................. D004
Barium .............................................................................................................................. D005
Cadmium ........................................................................................................................... D006
Chromium .......................................................................................................................... D007
Lead ................................................................................................................................. D008
Mercury ............................................................................................................................. D009
Selenium ........................................................................................................................... D010
Silver ................................................................................................................................ D011
Ignitable Wastes:
Ignitable wastes include any flammable liquids, nonliquids, and contained gases that have a
flash-point less than 140°F (for a complete description of ignitable wastes, see 40 CFR 261.
21, Characteristic of ignitability). Examples are spent solvents (see also solvents), solvent
still bottoms, ignitable paint wastes (paint removers, brush cleaners and stripping agents),
epoxy resins and adhesives (epoxies, rubber cements and marine glues), and waste inks con-
taining flammable solvents. Unless otherwise specified, all ignitable wastes have the EPA
Hazardous Waste Number of D001.
46–Waste 9/13

Some commonly used ignitable compounds are:

Acetone ............................................................................................................................. F003
Benzene ............................................................................................................................ D001
n-Butyl Alcohol .................................................................................................................... F003
Chlorobenzene ................................................................................................................... F0021
Cyclohexanone ................................................................................................................... F003
Ethyl Acetate ...................................................................................................................... F003
Ethylbenzene ..................................................................................................................... F003
Ethyl Ether ......................................................................................................................... F003
Ethylene Dichloride .............................................................................................................. D001
Methanol ........................................................................................................................... F003
Methyl Isobutyl Ketone ......................................................................................................... F003
Petroleum Distillates ............................................................................................................ D001
Xylene .............................................................................................................................. F003
1
Chlorobenzene is listed by EPA as a hazardous waste due to its toxicity and has been assigned EPA Hazardous Waste Number F002.
It has a flashpoint, however, of less than 140°F and is therefore included here as an ignitable waste.
Ink Sludges Containing Chromium and Lead:
This includes solvent washes and sludges, caustic washes and sludges, or waste washes and
sludges from cleaning tubs and equipment used in the formulation of ink from pigments,
driers, soaps, and stabilizers containing chromium and lead. All ink sludges have the EPA
Hazardous Waste Number K086.
Lead-Acid Batteries:
Used lead-acid batteries should be reported on the notification form only if they are not
recycled. Used lead-acid batteries that are recycled do not need to be counted in determin-
ing the quantity of waste that you generate per month, nor do they require a hazardous
waste manifest when shipped off your premises. (Note: Special requirements do apply if you
recycle your batteries on your own premises—see 40 CFR Part 266.)
Lead Dross ........................................................................................................................ D008
Spent Acids ........................................................................................................................ D002
Lead-Acid Batteries ............................................................................................................. D008
Pesticides:
The pesticides listed below are hazardous. Wastes marked with an asterisk (*) have been
designated acutely hazardous. For a complete listing pf pesticides listed as hazardous or
acutely hazardous, as well as other wastes, waste waters, sludges, and by-products from pes-
ticide formulators, see 40 CFR 261.32 and 261.33. (Go to the eCFR at ecfr.gpoaccess.gov/)
Reactives:
Reactive wastes include reactive materials or mixtures which are unstable, react violently
with or form explosive mixtures with water, generate toxic gases or vapors when mixed with
water (or when exposed to pH conditions between 2 and 12.5 in the case of cyanide or sulfide
bearing wastes), or are capable of detonation or explosive reaction when heated or irritated
9/13 Waste–47

(for a complete description of reactive wastes, see 40 CFR 261.23, Characteristic of

reactivity). Unless otherwise specified, all reactive wastes have the EPA Hazardous Waste
Number D003. The following materials are commonly considered to be reactive:
Acetyl Chloride Organic Peroxides
Chromic Acid Perchlorates
Cyanides Permanganates
Hypochlorites Sulfides
Spent Plating and Cyanide Wastes:
Spent plating wastes contain cleaning solutions and plating solutions with caustics, solvents,
heavy metals, and cyanides. Cyanide wastes may also be generated from heat treatment
operations, pigment production, and manufacturing of anti-caking agents. Plating wastes are
generally Hazardous Waste Numbers F006-F009, with F007-F009 containing cyanide. Cya-
nide heat treating wastes are generally Hazardous Waste Numbers F010-F012. See 40 CFR
261.31 for a more complete description of plating wastes.
Wood Preserving Agents:

Compounds or mixtures used in wood preserving, including the wastewater treatment slud-
ges from wastewater treatment operations, are considered hazardous. Bottom sediment
sludges from the treatment of wastewater processes that use creosote and pentachlorophenol
are hazardous and have an EPA Hazardous waste number of K001. Unless otherwise indi-
cated, specific wood preserving components are:
Chromated Copper Arsenate ................................................................................................. D004
Creosote ........................................................................................................................... K001
Pentachlorophenol ............................................................................................................... K001
Storing hazardous wastes
Accumulation: quantities and time limits

Most small businesses have a little of several different wastes. The cost of transportation to
a disposal site can be very expensive for these small amounts of waste.
If you fall into the Small Quantity Generator category, you may want to accumulate your
hazardous waste until you have enough to economically ship it offsite for treatment or
disposal.
A word of caution: Beware of how much you accumulate, and how long you store it.
How long can I store my hazardous waste? (100–1,000 kg/mo generator)

If you generate 100–1,000 kilograms/month, you can store the hazardous waste on your site
for up to 180 days, or 270 days if the waste must be shipped to a treatment, storage, or dis-
posal site more than 200 miles away.
This is a longer storage period than the large generator is allowed. For a regular (over 1,000
kilograms/month) generator, there is only a 90-day accumulation period allowed.
48–Waste 9/13

However, to take advantage of this allowed 180-day (or 270 day) storage period, you can
store no more than 6,000 kilograms of hazardous waste on your site.
If you exceed these storage time or quantity limits, you will be considered a storage facility
and you must obtain a storage permit and meet all of the RCRA storage requirements.
How long can I store my hazardous waste? (under 100 kg/mo generator)
If you generate under 100 kilograms/month, you can store your hazardous waste for an
unlimited period of time. The only restriction is that you must not accumulate at any time
more than a total of 1,000 kilograms.
If you exceed this quantity restriction, your wastes become subject to the regulations appli-
cable to the 100-1,000 kilogram/month generator.
Again, as always, check your state requirements. Many states allow storage for shorter peri-
ods of time, and smaller quantities of hazardous waste.
Hazardous waste accumulation at satellite locations

There is, however, an exception to these accumulation time limits that can be useful for
facilities that accumulate small amounts of hazardous waste on a regular basis. This excep-
tion is known as the “satellite accumulation” rule. Although the words “satellite
accumulation” cannot be found in the actual hazardous waste regulations, the term is com-
monly used to describe the way many facilities accumulate hazardous waste at the point of
generation before transferring it to the on-site hazardous waste storage area. To use the
“satellite accumulation” rule, you must meet the following requirements:
• The container in which you accumulate the waste cannot exceed 55 gallons (or one
quart for acutely hazardous waste);
• The container must be located at or near the point of generation of the hazardous
waste;
• The operator of the process that generates hazardous waste must be in control of
the management of the container; and
• The container must be labeled “Hazardous Waste” or must use other words which
identify the contents of the container, such as “spent petroleum distillates.”
This means that the time involved in collecting small amounts of hazardous waste (either 55
gallons or one quart, depending on the type of waste) at the point of generation may not be
included in the 90 or 180 day time period limitations as long as the management practices
cited above are followed.
It should be noted, however, that states have their own hazardous waste regulations as well.
Some states may have regulations concerning satellite accumulation. Pennsylvania, for
instance, does not permit any satellite accumulation. Others may permit it with different
handling and storage requirements. Check with your state agency to be sure you are com-
plying with both state and federal regulations.
9/13 Waste–49

CHART: CATEGORIES, QUANTITIES, TIME LIMITS
Conditionally Exempt Small Quantity Generator

Produces no more than 100 kilograms per month
Never accumulates more than 1,000 kilograms
No time limit for storage
Small Quantity Generator

Produces between 100 and 1,000 kilograms per month
Never accumulates more than 6,000 kilograms
Accumulation time limit of 180 days, or 270 days if shipped over 200 miles away
Large Quantity Generator

Produces over 1,000 kilograms of hazardous waste per month
No quantity limit on accumulation
Accumulation time limit of 90 days
Handling requirements for stored hazardous wastes

What containers must be used?
There are no requirements as to specific storage containers to be used, as long as the con-
tainer is compatible with the hazardous waste you put in it. In other words, you should not
put a substance that is reactive with metal in a metal container.
You can store several different hazardous wastes in the same container, as long as the
wastes are compatible with each other. If you are using several different solvents, you can
store them all together in one drum if they don’t react with each other. However, there are
economic reasons why this mixing of different wastes may not always be a good idea.
You can store hazardous waste in 55-gallon drums, tanks, or other containers suitable for
the type of waste generated if you follow certain commonsense rules that are meant to pro-
tect human health and the environment, and reduce the possibility of damages or injuries
caused by leaks or spills of hazardous wastes.
50–Waste 9/13

Container management
Owners and operators of all hazardous waste facilities that store containers of hazardous
wastes must make sure:
• All containers are in good condition and are not leaking; if the container begins to
leak, you must transfer the waste from the leaking container to a container that is
in good condition or otherwise manage the waste to meet the regulations at 40 CFR
Parts 264 and 265.
• Owners and operators must make sure the lining of the container is compatible with
the materials that will be stored in it; the lining must not react with the waste to be
stored.
• The container must always be closed — except during times of adding or removing
waste.
• The container must not be opened, handled, or stored in any way that would cause
it to rupture or leak.
• Owners and operators must inspect areas where the containers are stored at least
once per week, looking for leaks and deterioration caused by corrosion or other
factors.
• Each container must be clearly marked with the words “HAZARDOUS WASTE,”
and with the date you started to collect waste in that container.
• Ensure that if you are storing ignitable or reactive wastes, the containers are placed
as far as possible from your facility property line to create a buffer zone.
• Never store wastes in the same container that could react together to cause fires,
explosions, leaks or other releases.
9/13 Waste–51

• Make sure that the stored waste is taken offsite or treated onsite within the 180 (or
270) days.
Storage in tanks
For storage in tanks, you must follow similar common sense rules:
• Do not store hazardous waste in a tank if it may cause rupture, leaks, corrosion, or
otherwise cause the tank to fail.
• Keep a tank covered or provide at least two feet of freeboard (space at the top of the
tank) in uncovered tanks.
• If your tanks have equipment that allow the waste to flow into them continuously,
provide waste feed cutoff or bypass systems to stop the flow in case of problems.
• Inspect any monitoring or gauging systems on each operating day and inspect the
tanks themselves for leaks or corrosion every week.
• Ignitable or reactive wastes must not be placed in a tank unless the waste is stored
or treated in such a way that it is protected from any materials or conditions that
would cause it to ignite or react.
• Use the National Fire Protection Association’s (NFPA) buffer zone requirements for
tanks containing ignitable or reactive wastes. These requirements specify distances
considered as safe buffer zones for various liquids based on the characteristics of all
combustible and flammable liquids. Call your local fire department or EPA regional
office if you need help.
• Hazardous waste must not be placed in an unwashed tank which previously held an
incompatible waste or material unless you are sure that the storage will not result
in the creation of extreme heat, toxic gases, flammable fumes, or any threat to
human health or the environment.
• Again, make sure that the stored waste is taken offsite or treated within 180 (or
270) days.
Treating or disposing of hazardous waste onsite

Treating hazardous waste onsite
You may treat your hazardous wastes on your site without a special permit providing:
• You treat the accumulated hazardous waste within 180 (or 270) days.
• You comply with the container and tank regulations described on the preceding
pages.
• You take steps to prepare for and prevent accidents as described on the next several
pages.
It is very important that you set up your hazardous waste management program carefully
because if you do not meet each of these requirements and you treat your hazardous wastes
on your site, you must obtain a hazardous waste TSD (treatment, storage, or disposal) per-
mit described in this section.
Disposing of hazardous waste onsite

Disposing of hazardous waste onsite is regulated differently than treating hazardous waste.
You may not dispose of your hazardous waste on your site unless you have obtained a dis-
posal permit described in this chapter.
52–Waste 9/13

Under certain limited circumstances, it may be legal to dispose of certain types of hazardous
waste on your site without a permit:
Farmers may dispose of their own waste pesticide provided they triple rinse the empty
pesticide container and dispose of the pesticide residue on their own farm in a manner
consistent with the instructions on the pesticide label.
Even if you are not a farmer, you may be allowed to dispose of certain hazardous wastes by
discharging them directly into your sewer drain. However, this is not considered good man-
agement practice and in many communities it may be illegal.
For more information concerning wastes which may be disposed of in this manner, contact
your local wastewater or sewage treatment office or your state hazardous waste manage-
ment agency (see STATE INFORMATION Section).
Obtaining a TSD permit

If you store, treat, or dispose of your hazardous waste onsite in any manner other than
those permissible ones described in the preceding sections, you must obtain a permit.
This step should not be taken lightly. Obtaining a permit to store, treat, or dispose of your
hazardous wastes on your site can be a costly and very time-consuming process. This process
is described in 40 CFR Part 270. To obtain such a permit you must:
• Notify EPA or your state of your hazardous waste activity.
• Complete Part A of the permit application.
• Comply with the interim status standards as described in 40 CFR Part 265.
• Complete Part B of the permit application.
• Comply with the standards described in 40 CFR Parts 264 and 266.
If you are not sure whether you need such a permit, or if you are interested in finding out
more about it, call your state hazardous waste management agency (see STATE AGENCIES
Section) or EPA regional office (see FEDERAL AGENCY ADDRESS Section) for help.
Preparing for and preventing accidents

Whenever you generate hazardous waste and store it onsite, you must take the precautions
and steps necessary to prevent any sudden or accidental release to the environment. This
means that you must carefully operate and maintain your facility to reduce the possibility of
fire, explosion, or release of hazardous waste.
Your facility must have appropriate types of emergency communication and fire equipment
for the kinds of waste handled at your site. You must also attempt to make arrangements
with local fire, police, or hospital officials as needed to ensure that they will be able to
respond to any potential emergencies that could arise.
Some of the steps you may need to take to prepare for emergencies at your facility include:
Installing and maintaining emergency equipment such as an alarm system to provide
emergency instruction to your facility personnel, a telephone or two-way portable radio to
request emergency assistance, fire extinguishers (using water, foam, inert gas, or dry
9/13 Waste–53

chemicals as appropriate to your waste type), hoses, automatic sprinklers, or spray equip-
ment in your plant so that it is immediately available to your employees if there is an
emergency.
Providing enough room for emergency equipment and response teams to get into any area
in your facility in the event of an emergency.
Writing to local fire, police, and hospital officials or state or local emergency response
teams explaining the types of wastes you handle and asking for their cooperation and
assistance in handling emergency situations.
Planning for emergencies

A contingency plan is a plan that attempts to look ahead and prepare for any accidents that
could possibly occur. It can be thought of as a set of answers to a series of “what if”
questions.
For example: “What if there is a fire in the area where hazardous waste is stored?” or “What
if I have a spill of hazardous waste or one of my containers leaks?”
Emergency procedures are the steps you should follow if you have an emergency, that is, if
one of the “contingencies” or “what ifs” occurs. While EPA does not require a specific written
contingency plan, it may be a good idea to develop a list of every possible “what if” question
that you can foresee and come up with answers for them on paper. These answers, or emer-
gency procedures, should be part of your overall plant safety program, used to inform your
employees about their responsibilities in the event of an emergency.
If you have an emergency in your facility related to your hazardous substances:

1. In the event of a fire, call the fire department or attempt to extinguish it using the
appropriate type of fire extinguisher. Be sure your employees know what is appro-
priate action to take for the type of hazardous substances at your plant.
2. In the event of a spill, contain the flow of hazardous waste to the extent possible
and notify the National Response Center. The Center operates a 24-hour toll free
number: (800) 424-8802, or in Washington D.C.: (202) 267-2675. As soon as possible,
clean up the hazardous waste and any contaminated materials or soil.
3. In the event of a fire, explosion, or other release, immediately notify the
National Response Center as required by Superfund regulations. (Superfund or
CERCLA is the law that deals with the cleanup of spills and leaks of hazardous
waste at abandoned hazardous waste sites.)
Emergency phone numbers and locations of emergency equipment must be posted near
telephones. All employees must know proper waste handling and emergency procedures. You
must appoint an employee to act as emergency coordinator to ensure that emergency pro-
cedures are carried out in the event an emergency arises.
The responsibilities of the emergency coordinator are generally that he/she be available 24
hours a day (at the facility or by phone) and know whom to contact and what steps to follow
in an emergency. For most small businesses, the owner or operator may already perform
these functions. Thus, it is not intended nor is it likely that you will need to hire a new
employee to fill this role.
54–Waste 9/13

Warning
It is important to avoid potential risks in this area. If you have a serious emergency and you
have to call your local fire department or you have a spill that extends outside your plant or
that could reach surface waters, Immediately Call The National Response Center (800-
424-8802) And Give Them The Information They Ask For.
If you didn’t need to call and report your particular episode, they will tell you so. But Any-
one Who Was Supposed To Call And Does Not Is Subject To A $10,000 Fine, A Year
In Jail, Or Both.
An additional zinger is that an owner or manager of a business who fails to report a release
also may have to pay for the entire cost of repairing any damage, even if the facility was not
the single or the main cause of the damage.
Thus, one phone call to the Center can prevent a possible fine, a jail term, and the total bur-
den of cleanup costs.
Release notification requirements under other environmental laws

Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
The National Response Center (800-424-8802) must be notified immediately upon the
release of any hazardous substance, appearing on list 302.4, in an amount equal to or
greater than the reportable quantities.
A release is defined as any spilling, leaking, pumping, pouring, emitting, discharging, escap-
ing, leaching, dumping or disposing into the environment. It does not include releases which
result in exposure to persons solely within the workplace. A spill wholly contained in a
building is not reportable. Releases of oil are not regulated under CERCLA.
Notification is required of the “person in charge,” a term which is broadly defined to be an
individual, a firm, a municipality, etc.
Superfund Amendments Reauthorization Act (SARA)

Facilities must provide emergency notification whenever there is a release of a Reportable
Quantity of an Extremely Hazardous Substance (EHS) or CERCLA hazardous substance.
The release of a reportable quantity (RQ) of an EHS or CERCLA hazardous substance
within any 24-hour period triggers the emergency release notification requirements. RQs for
EHSs are listed in Appendices A and B of 40 CFR 355.33 in the column labeled “reportable
quantity.” RQs for CERCLA hazardous substances are listed in Table 302.4 of 40 CFR 302.4
in the column labeled “final RQ.”
“Release” is defined as any spilling, leaking, pumping, pouring, emptying, discharging, or
disposing into the environment. This includes the abandonment or discarding of barrels or
other closed receptacles.
Any release which results in exposure to persons solely within the boundaries of your facil-
ity does not require notification under this regulation.
Immediate notification must be made to 1) the community emergency coordinator of the
local committee, and 2) the State commission for any area which may be affected by the
release. This notification should be oral (via telephone, radio, or in person).
9/13 Waste–55

This notification should include:

• Chemical name or identity of substance released
• Whether the substance is an Extremely Hazardous Substance
• Estimate of quantity released
• Time and duration of release
• Media into which release occurred
• Any known or anticipated acute or chronic health risks
• Medical advice for exposed individuals, where appropriate
• Precautions to take and evacuation procedures
• Names and telephone numbers of contact person
As soon as possible, a written follow-up notice should be submitted. Included in this written
notice should be additional information with respect to:
• Actions taken to respond to and contain the release
• Any known or anticipated acute or chronic health risks
• Medical advice for exposed individuals, where appropriate
Clean Water Act (CWA)

Releases of harmful quantities of oil or hazardous substances into this country’s waters
must be reported by the “person in charge” to the National Response Center, using the
24-hour phone number 800-424-8802. “Person in charge” may be an individual or a
corporation.
A “harmful quantity” of oil is defined as 1) the amount necessary to cause a sheen to the
water, 2) violates applicable water quality standards, or 3) causes sludge or emulsion to be
deposited beneath the surface of the water or upon the adjoining shorelines. For hazardous
substances, the amount necessary to trigger reporting can be found in 40 CFR 117.3.
Reportable CWA discharges from a vessel, an onshore, or an offshore facility, is defined as
those entering the navigable waters of the U.S., adjoining shoreline, and certain wetland
areas.
Hazwoper and community right to know

Your hazardous waste operations may also be covered under sections of OSHA’s Hazardous
waste operations and emergency response (HAZWOPER) rules. You’ll especially want to pay
attention to the regulations for emergency responses for uncontrolled hazardous waste sites
and rules for treatment, storage, and disposal facilities. For more information, turn to the
HAZWOPER tab in this book.
Make it easy — write it down

If your facility handles hazardous waste, a well-developed program is probably in place to
handle emergencies. Quick and easy access to emergency information is an important part of
that program.
The following emergency measures are required for most hazardous waste facilities. They
are also a good idea for any facility, even those with very small amounts of hazardous waste.
56–Waste 9/13

Emergency coordinator
At least one employee, either on the premises or on call, should be available to respond to an
emergency by reaching the facility within a short period of time. This person is the emer-
gency coordinator and has the responsibility for coordinating all emergency response
measures. Before an emergency occurs, find out who this person is at your facility.
The emergency coordinator must respond to any emergencies that arise. Possible responses
are as follows:
• In the event of a fire, call the fire department or attempt to extinguish it using a
fire extinguisher.
• In the event of a spill, contain the flow of hazardous waste to the extent possible,
and as soon as is practicable, clean up the hazardous waste and any contaminated
materials or soil.
• In the event of a fire, explosion, or other release which could threaten human health
outside the facility or when a spill has reached surface water, the emergency coordi-
nator immediately notifies the National Response Center (using their 24-hour toll
free number (800) 424-8802).
Keep emergency information by the phone

In an emergency, adrenaline may be pumping and everyone may not be thinking clearly. The
following information should be clearly written and posted next to a telephone:
• the name and telephone number of the emergency coordinator;
• location of fire extinguishers and spill control material, and, if present, fire alarm;
and
• the telephone number of the fire department, unless the facility has a direct alarm.
How to respond to a spill

If a spill happens, you’ll want to keep it from spreading. Then it must be removed from the
spill site, and finally, it must be disposed of in some manner. How this can be accomplished
varies with the substance and the amount spilled, and the location of the spill.
It may be as simple as sprinkling “kitty litter” on the spill, and then shoveling it into a dis-
posal container. Probably the majority of in-plant spills can be handled in that fashion. But
as regulations proliferate, it is becoming more and more imperative that you assess your
cleanup procedures. Today’s technology has produced many new products, such as in the bio-
logical treatment area, that are efficient and environmentally sound.
Some of these methods include:
Mechanical containment
Containment is the process of stopping a release, or preventing its spread through mechani-
cal means without adding chemical or biological agents. Containment should be the first
response considered when a spill occurs because it provides the following advantages:
• Minimizes damage to the environment.
• Allows for on-site clean up.
• Prevents spilled material from flowing into the waterways or entering into sewers,
streams, and subsurface water supplies.
9/13 Waste–57

Containment methods may include the following: patching and plugging the leaking con-
tainer; building a substitute container with dikes, berms, and dams; reorientation of the
leaking container; overpacked drums; or portable collection vessels.
Methods of containment
1. Patching and plugging the leaking container:
This should be one of the first procedures attempted, when possible. Cleaning up,
treating, and disposing of hazardous substances already leaked may require some
time — hours or days. You need to prevent further releases from occurring while you
are engaged in the cleanup.
The difficulty in patching a leaking container depends upon the hazards of the sub-
stance involved, the size of the hole, and the location of the leaking vessel.
Several methods to repair the container are to patch with boiler patches or plugs,
solidify or freeze the contents, or to create an internal patch or barrier with mat-
ting, etc.
2. Build a substitute container by:
Forming dikes, berms, or dams, using earth or sand.
Assembling a container such as a plastic swimming pool or inflatable device. Using

collection or confinement devices (booms, curtains, skimmers, etc.).
Digging a pit or trench.
3. Reorientation of the container:
This means changes in position by upending or rotating container. This is one of the
simplest, and most effective containment methods. Just by moving the container’s
position, you may be able to stop the leaking of the hazardous substances. (This
method can’t always be used.)
4. Overpacked drums:
When you have a spill from a 55-gallon drum, or smaller container, it is often pos-
sible to place the leaking container into a larger protective container. This procedure
is called overpacking.
Usually, overpack drums are chemically resistant 85-gallon containers. The leaking
container is placed inside, and any space is filled with absorbent materials. The con-
tents must be secure and not allowed to shift within the container.
There are three drawbacks to this method: 1) the leaking container may be too large
to fit inside of another container; 2) the leaking container must be approachable, not
fuming or presenting a severe hazard if handled; and 3) the movement of the leak-
ing container may cause an uncontrollable release of the material.
5. Portable collection vessels:
Portable collection vessels are usually containers of a size that can be easily trans-
ported to the spill site. The most obvious use is to catch the substance as it spills
out. It is often an interim measure, while the leak is being patched.
58–Waste 9/13

The biggest advantage is that almost any container can be used, big or little, if it is
chemically compatible with the leaking substance. When you have a spill from a
55-gallon drum, or smaller container, it is often possible to place the leaking con-
tainer into a larger protective container.
Hazardous waste containers

If you properly empty hazardous waste containers, the containers are no longer subject to
regulation, even if some residues remain in the container. That way, you can reuse contain-
ers or inner liners since the container is no longer considered to hold hazardous waste. The
trick is understanding the definition of “empty.”
“Empty” versus “RCRA-empty”

To distinguish between the usual meaning of the word “empty” and the strict regulatory
definition, the phrase “RCRA-empty” is sometimes used. (RCRA, the Resource Conservation
and Recovery Act, is EPA’s hazardous waste management program.)
Any hazardous waste remaining in a RCRA-empty container or inner liner is not subject to
hazardous waste rules, including those for labeling or accumulation time limits.
What makes a container RCRA-empty?

For most hazardous wastes, the container or an inner liner removed from the container is
empty when all wastes have been removed using practices commonly employed to remove
wastes from containers or liners.
These methods include:
• pouring,
• pumping,
• aspirating, and
• draining.
Once these methods have been used:
1. no more than one inch of material may remain in the container or liner; or
2. no more than three percent by weight of the container may remain for containers
with a capacity of 110 gallons or less, and no more than 0.3 percent by weight may
remain for containers with a capacity greater than 110 gallons.
Different rules apply for gases and acute hazardous waste.
Is this drum empty?

Your coworker told you she emptied a container and the container held less than one inch of
waste. But you could empty the drum further by inverting the container and pouring out
additional hazardous waste.
Was the container “empty” even though it held under one inch of material?
No, the container was not empty. One inch of waste material may remain in an empty con-
tainer only if it cannot be removed by normal means. This means that a container must be
emptied by pouring, pumping, and aspirating. Then, if the container holds less than one
inch, the container is empty.
9/13 Waste–59

Container safety: it’s in your hands

Working with containers of hazardous substances can be dangerous, but there are ways to
handle the containers safely. The following tips are good practices for handling containers of
any size.
Use the right drum

Drums and other containers are used to store hazardous substances and to collect residues
and cleanup materials from spills. Make sure that containers are appropriate for the wastes
that they contain. Check with your supervisor to make sure you are using the proper con-
tainers for chemicals you work with.
Inspect the containers

When practical, inspect drums and containers to assure their integrity prior to moving them.
Some drums or containers cannot be inspected before moving them because of storage
conditions. Maybe they are stacked behind other drums or stacked several tiers high. Move
these containers to an accessible location and inspect them prior to further handling.
What’s in it?
To be safe, assume that unlabeled drums and containers contain hazardous substances.
Handle them accordingly until the contents are positively identified and labeled.
This situation can be dangerous, expensive, and time-consuming. To avoid this, always iden-
tify the contents of containers at your facility as soon as the arrive, and maintain the labels.
Just in case
Keep salvage drums or containers and suitable quantities of proper absorbent available to
use in areas where spills, leaks, or ruptures may occur.
Where major spills may occur, a spill containment program should be in place to contain and
isolate the entire volume of the hazardous substance being transferred. If you work in these
areas, make sure you understand your responsibilities under your company’s program.
Fire extinguishing equipment should be on hand and ready for use to control incipient fires.
Be sure you know where this equipment is located and how to use it.
Working with containers

When there is a reasonable possibility of flammable atmospheres being present, use material
handling equipment and hand tools that are designed to prevent sources of ignition. Do not
stand on or work from drums or containers.
It is important to follow these common-sense guidelines when working with all sizes of
chemical containers. Remember: Working safely with chemicals starts in your hands.
Aerosol cans
A recurring issue within the container and empty container regulations is the puncturing or
venting of aerosol cans. The issue stems partly from the applicability of the empty container
regulations to aerosol cans and partly from the issue of whether the can itself is considered
to be part of the waste.
60–Waste 9/13

In general, aerosol cans are capable of holding either compressed gas or liquid. If the can is
sent for scrap metal recycling, the can and its contents are exempt from regulation
as scrap metal per §261.6(a)(3)(iii) and the act of emptying the can may be an exempt
recycling activity per §261.6(c). However, any residues from emptying the can would be regu-
lated if they are listed or exhibit a characteristic of hazardous waste.
If the can is sent for disposal, both the contents of the can and the can itself are subject to
hazardous waste regulations and the act of emptying the can may be considered a treatment
activity.
To dispose of the aerosol can as nonhazardous, the can must be RCRA empty according to
§261.7, and the can itself must not qualify as a hazardous waste. If the aerosol can is hold-
ing a compressed gas, it is unclear whether the act of venting to render the can empty would
constitute treatment. This question must be answered by the appropriate EPA Region or
authorized state.
Shipping hazardous waste
Choosing a hauler
At this point, you have identified your hazardous wastes, so you know what you generate.
You have measured or counted your hazardous wastes so you know what generator category
you fall into. You have accumulated some drums of hazardous waste. Now you want to get
rid of it. What do you do?
You must have someone haul it away to a disposal site.

Bear in mind the phrase “cradle-to-grave” responsibility. This means that if you produce the
waste, it is your responsibility forever. You must ensure that it is hauled properly, and dis-
posed of or treated properly.
Therefore, carefully choosing a hauler and designating a waste management facility is very
important. You want to make sure that you are dealing with reputable haulers and
disposers. The hauler will be handling your wastes beyond your control while you are still
responsible for their proper management. Similarly, the waste management facility will be
the final destination of your hazardous waste for treatment, storage, or disposal.
If your transporter takes your drums of hazardous waste and dumps them out on some back
road, he will be fined (if caught) but YOU will have to pay for the cleanup. And cleanup
costs for a simple spill of several drums of hazardous waste that has soaked into the ground
can be hundreds of thousands of dollars.
Therefore, before choosing a hauler and/or designating a facility, check with the following
sources, if possible:
• Friends and associates in the same business as you who may have used a specific
hazardous waste hauler or designated facility in the past and were satisfied.
• Trade associations, which may keep a file on companies that have a good reputation
for handling hazardous wastes.
• Your Better Business Bureau or Chamber of Commerce to find out if any complaints
have been registered against a hauler or facility.
9/13 Waste–61

• Your state hazardous waste management agency or EPA regional office, which can
tell you whether or not the company has a U.S. EPA ID number, and may know
whether or not the company has had any problems.
After checking these sources, make your selection of a hauler and a disposal site. Contact
both the transporter and the designated disposal facility directly to verify that they have
EPA Identification Numbers, and that they can and will handle your waste.
Also, make sure that they have the necessary permits and insurance, and that the hauler’s
vehicles are in good condition.
This process can be time-consuming, so start checking well ahead of the time that you will
need to ship your waste. Careful selection is very important.
Preparing your wastes for shipment

There are relatively few EPA regulations controlling the shipping of hazardous wastes. Pri-
marily, you must comply with the DOT regulations dealing with the shipment of hazardous
wastes and materials.
When you prepare hazardous wastes for shipment, you must put the wastes in containers
acceptable for transportation and make sure the containers are properly labeled. Your hauler
should be able to assist you.
Described below are the EPA and DOT requirements for labels. You do not need two
labels, however. The shipping labels comply with both sets of regulations. Here is a pic-
ture of a typical label that can be used to ship your hazardous waste.
62–Waste 9/13

Marking/Labeling (EPA)
Before offering hazardous waste for transportation offsite, a generator must mark each con-
tainer of 110 gallons or less with the following words and information displayed in
accordance with the requirements of 49 CFR 172.304:
HAZARDOUS WASTE - Federal Law Prohibits Improper Disposal. If found, con-
tact the nearest police or public safety authority or the U.S. Environmental
Protection Agency.
Generator’s Name and Address
Manifest Document Number
Labeling (DOT)
Before shipping out your hazardous waste, you will have some Department of Transporta-
tion (DOT) regulations to comply with in the area of packaging, labeling, and/or placarding.
You should consult the requirements for packaging and labeling hazardous wastes found in
the DOT regulations (49 CFR Part 172).
9/13 Waste–63

To explain all the DOT marking requirements would require another book. What you need
to be concerned with when filling out your labels is the proper DOT shipping name, hazard
class, and identification number (UN or NA) of your hazardous wastes. You will need this
same information for the hazardous waste manifest.
Biennial reporting
A biennial report is required under the regulation at 40 CFR 262.41. The report must be
completed by any generator of 1000 kg or more of hazardous waste who ships any hazardous
waste offsite to a treatment, storage, or disposal facility (TSDF) within the United States.
Biennial reports must be submitted to EPA by March 1 of each even-numbered year, so that
EPA may keep track of a facility’s hazardous waste generator activities.
EPA supplies a pre-printed form for this report: EPA form 8700-13A. Information requested
on the form includes:
• Generator activities for the previous year,
• A description of efforts taken during the year to reduce the volume and/or toxicity of
the wastes generated at the facility, and
• An EPA identification number for the generator of the waste, each transporter, and
each off-site TSD facility used during the amount of time covered by the report.
Find more information on biennial reporting at www.epa.gov/epawaste/inforesources/data/
biennialreport/index.htm.
Annual reporting
Annual reports must be completed by hazardous waste generators that export hazardous
waste to a facility outside of the United States. The report is required by EPA to keep track
of all shipments of hazardous waste leaving the country.
An annual report must be filed no later than March 1 of each calendar year, and must sum-
marize the types, quantities, frequency, and ultimate destination of all hazardous waste
exported during the previous calendar year. The facility’s EPA identification number is also
required on the report. Learn more at www.epa.gov/osw/hazard/international/guide2.htm.
The Uniform Hazardous Waste Manifest

If your company handles hazardous waste – as a generator, a transporter, or a treatment,
storage, and disposal facility – you must use the federal Uniform Hazardous Waste Manifest
as the shipping document when you send your waste offsite.
Hazardous Waste Manifest system

The is a set of forms, reports, and procedures designed to seamlessly track hazardous waste
from the time it leaves the generator facility where it was produced, until it reaches the off-
site waste management facility that will store, treat, or dispose of the hazardous waste. The
system allows the waste generator, and EPA, to verify that the waste has been properly
delivered, and that no waste has been lost or unaccounted for in the process. The key compo-
nent of this system is the Uniform Hazardous Waste Manifest which is a form prepared by
all generators who transport, or offer for transport, hazardous waste for off-site treatment,
recycling, storage, or disposal.
64–Waste 9/13

Currently, the manifest is a paper document containing multiple copies of a single form.
When completed, it contains:
• information on the type and quantity of the waste being transported,
• instructions for handling the waste, and
• signature lines for all parties involved in the disposal process.
The manifest is required by both Department of Transportation and EPA. Each party that
handles the waste signs the manifest and retains a copy for themselves. This ensures critical
accountability in the transportation and disposal processes. Once the waste reaches its desti-
nation, the receiving facility returns a signed copy of the manifest to the generator,
confirming that the waste has been received by the designated facility.
The manifest consists of six copies to provide the generator, the transporter, and the desig-
nated facility with a copy for their records. The notation at the bottom right-hand corner of
the form indicates who should get each copy.
Many people are wondering about the number of plies (or copies) available in the new ver-
sion of the form. Six plies are required by the rules, with each designated for a handler. If
you need a copy for a second transporter, or for other state or facility-level recordkeeping,
EPA says to make photocopies for any additional copies needed. Be sure to duplicate the
most legible page of the form so the resulting copies are legible.
Where to get the forms

Handlers of waste (generators, or treatment, storage or disposal facilities) must obtain the
new forms from any source that has been approved by the EPA Manifest Registry to print
and distribute the form. That list is available at www.epa.gov/epaoswer/hazwaste/gener/
manifest/registry/index.htm.
Who fills out the manifest?

Because of the generator liability, you, as the producer of the waste, should always fill out
the manifest. Do not leave this up to the transporter.
If you use a solvent recovery system or ship waste for recycling, many times the hauler will
fill out the manifest for you, and give it to you to sign. Carefully examine the form you are
signing. Make sure:
• the right substances are listed, and
• that the quantities are listed correctly.
You are the generator of the hazardous waste and have the total responsibility for its
disposal.
State manifest requirements

Look for state-specific manifesting information, such as additional required hazardous waste
codes, under Manifest Information in the State Information tab at the end of this book.
Required training
The training requirements for a person who signs the manifest come from the hazardous
materials (hazmat) regulations under the Department of Transportation, and are located in
49 CFR 172.204 and 172.704.
3/14 Waste–65

The rules say that the person who signs the shipper’s certification on a hazardous materials
shipping paper (including a hazardous waste manifest) must be trained in all phases of
hazmat transport.
The training requirements apply to hazmat employees who perform any function subject to
the requirements of the hazmat rules. This includes employees who are involved in shipping
hazardous waste, because hazardous waste is one sub-category of hazardous materials.
The person signing the shipper’s certification on a manifest certifies that the materials are:
• properly classified, described, packaged, marked, and labeled; and
• in proper condition for shipment.
In order to do that, the person must receive function-specific training that ensures that they
understand all of that information and can determine whether a shipment and the paper-
work complies with the requirements of the hazmat rules.
DOT also requires hazmat employees to have general awareness and safety training.
Transporting your own waste

Federal regulations allow you to haul your hazardous waste to a designated facility yourself.
You must, however, obtain an EPA transporter identification number and comply with appli-
cable DOT requirements for packaging, labeling, marking, and placarding your shipment.
There are also financial responsibility and liability requirements under the Federal Motor
Carrier Act, but you may be exempt from these if you:
1. Use a vehicle with a Gross Vehicle Weight Rating of less than 10,000 pounds (van or
pickup truck).
2. Transport your wastes for commerce within your state in non-bulk shipments (i.e.
containers with capacities of less than 3,500 gallons).
3. Transport hazardous wastes which meet the “limited quantity exclusion” require-
ments of Section 172.101 of the DOT regulations.
If you decide to transport your own hazardous wastes, call your state hazardous waste man-
agement agency (see STATE INFORMATION Section) to find out what state regulations
apply to you.
Not all states will allow you to transport your own hazardous wastes. You should also note
that if you have an accident during transport, you are responsible for the cleanup.
Exception reporting
If you do not receive a signed copy of every manifest back from the disposal site within an
appropriate amount of time, then something is wrong. It is a good idea for you to find out
why you haven’t received it, and, if necessary, let the state or EPA know.
Small quantity generators: Generators of 100-1,000 kg/mo must take action if a signed copy
of the manifest is not received back within 60 days of the date the waste was accepted by
the initial transporter. You must submit a legible copy of the manifest to your state or the
EPA Regional Administrator indicating that you have not received confirmation of delivery.
Large quantity generators: Generators of over 1,000 kg/mo must contact the treatment, stor-
age, and disposal facility if they have not received a signed copy of the manifest within 35
days. The generator must file an exception report with the state within 45 days.
66–Waste 3/14

REMEMBER: Just because you have shipped the hazardous waste off your site and it is no
longer in your possession, your liability has not ended. You are potentially liable under
Superfund for any mismanagement of your hazardous waste.
The Uniform Hazardous Waste Manifest (EPA Form 8700-22)

Here are examples of the Uniform Hazardous Waste Manifest (EPA Form 8700-22) and the
Uniform Hazardous Waste Manifest (Continuation Sheet) (EPA Form 8700-22A). EPA’s
instructions for completing the paper manifests follow.
3/14 Waste–67

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039
4. Manifest Tracking Number
UNIFORM HAZARDOUS 1. Generator ID Number 2. Page 1 of 3. Emergency Response Phone
WASTE MANIFEST
5. Generator's Name and Mailing Address Generator's Site Address (if different than mailing address)
Generator's Phone:
6. Transporter 1 Company Name U.S. EPA ID Number
7. Transporter 2 Company Name U.S. EPA ID Number
8. Designated Facility Name and Site Address U.S. EPA ID Number
D
Facility's Phone:
I
9a. 9b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number, 10. Containers TTotal
11. To 12. Unit
and Packing Group (if any)) 13. Waste Codes
HM No. Type
Ty
T pe Quantity Wt./Vol.
1.
GENERATOR
O
2.
3.
V
4.
14. Special Handling Instructions and Additional Information
15. GENERATOR’S/OFFEROR’S CERTIFICATION: I hereby decl declare

re that the contents of this consignment are fully and accurately described above by the proper shipping name, and are classified, packaged,
marked and labeled/placarded, and are in all respects ts in proper condition for
f transport according to applicable international and national governmental regulations. If export shipment and I am the Primary
fo
Exporter, I certify that the contents of this consignment conform
f rm to the terms of the attached EPA Acknowledgment of Consent.
confo
I certify that the waste minimization statement identified in 40 CFR 262.27(a) (if I am a large quantity generator) or (b) (if I am a small quantity generator) is true.
Generator's/Offeror's Printed/Typed Name Signature Month Day Year
16. International Shipments

■ ■ Export from U.S.
TR ANSPORTER INT'L
Import to U.S. Port of entry/exit: _________________________________________________________

Transporter signature (for exports only): Date leaving U.S.:
17. Transporter Acknowledgment of Receipt of Materials
Transporter 1 Printed/Typed Name Signature Month Day Year
Transporter 2 Printed/Typed Name Signature Month Day Year
18. Discrepancy
18a. Discrepancy Indication Space
■ Quantity ■ Type ■ Residue ■ Partial Rejection ■ Full Rejection
Manifest Reference Number:
DESIGNATED FACILITY
18b. Alternate Facility (or Generator) U.S. EPA ID Number
Facility's Phone:
18c. Signature of Alternate Facility (or Generator) Month Day Year
1.
19. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems)
1. 2. 3. 4.
20. Designated Facility Owner or Operator: Certification of receipt of hazardous materials covered by the manifest except as noted in Item 18a
Printed/Typed Name Signature Month Day Year
EPA Form 8700-22 (Rev. 3-05) Previous editions are obsolete. DESIGNATED FACILITY TO DESTINATION STATE (IF REQUIRED)
68–Waste 3/14

Please print or type. (Form designed for use on elite (12-pitch) typewriter.) Form Approved. OMB No. 2050-0039
UNIFORM HAZARDOUS WASTE MANIFEST 21. Generator ID Number 22. Page 23. Manifest Tracking Number
(Continuation Sheet)
24. Generator's Name
U.S. EPA ID Number

25. Transporter _______ Company Name
U.S. EPA ID Number

26. Transporter _______ Company Name
27a. 27b. U.S. DOT Description (including Proper Shipping Name, Hazard Class, ID Number, 28. Containers 29. Total 30. Unit 31. Waste Codes
HM and Packing Group (if any)) No. Type Quantity Wt./Vol.
O ID
GENERATOR
32. Special Handling Instructions and Additional Information

V
33. Transporter _______ Acknowledgment of Receipt of Materials
TRANSPORTER
34. Transporter _______ Acknowledgment of Receipt of Materials

35. Discrepancy
DESIGNATED FACILITY
36. Hazardous Waste Report Management Method Codes (i.e., codes for hazardous waste treatment, disposal, and recycling systems)
EPA Form 8700-22A (Rev. 3-05) Previous editions are obsolete. DESIGNATED FACILITY TO DESTINATION STATE (IF REQUIRED)
3/14 Waste–68A

(EPA Form 8700–22) and, if necessary, the continuation sheet (EPA Form
8700–22A) for
68B–Waste 3/14

3/14 Waste–68C

.
CF = Fiber or plastic boxes, cartons, cases. DW = Wooden drums, barrels, kegs.
CM = Metal boxes, cartons, cases (including HG = Hopper or gondola cars.
roll-offs).
CW = Wooden boxes, cartons, cases. TC = Tank cars.
CY = Cylinders. TP = Portable tanks
DF = Fiberboard or plastic drums, barrels, TT = Cargo tanks (tank trucks).
kegs.
DM = Metal drums, barrels, kegs.
Item 11. Total Quantity
Enter, in designated boxes, the total quantity of waste. Round partial units to the nearest whole
unit, and do not enter decimals or fractions. To the extent practical, report quantities using
appropriate units of measure that will allow you to report quantities with precision. Waste
quantities entered should be based on actual measurements or reasonably accurate estimates of
actual quantities shipped. Container capacities are not acceptable as estimates.
68D–Waste 3/14

Item 12. Units of Measure (Weight/Volume)
Enter, in designated boxes, the appropriate abbreviation from Table II (below) for the unit of
measure.
Table II - Units of Measure
G = Gallons (liquids only) N = Cubic Meters

K = Kilograms P = Pounds
L = Liters (liquids only) T = Tons (2000 Pounds)
M = Metric Tons (1000 Kilograms) Y = Cubic Yards
Note: Tons, Metric Tons, Cubic Meters, and Cubic Yards should only be reported in connection
with very large bulk shipments, such as rail cars, tank trucks, or barges.
Item 13. Waste Codes
Enter up to six federal and state waste codes to describe each waste stream identified in Item 9b.
State waste codes that are not redundant with federal codes must be entered here, in addition to
the federal waste codes which are most representative of the properties of the waste.
Item 14. Special Handling Instructions and Additional Information
1. Generators may enter any special handling or shipment-specific information necessary

for the proper management or tracking of the materials under the generator’s or other
handler’s business processes, such as waste profile numbers, container codes, bar codes,
or response guide numbers. Generators also may use this space to enter additional
descriptive information about their shipped materials, such as chemical names,
constituent percentages, physical state, or specific gravity of wastes identified with
volume units in Item 12.
2. This space may be used to record limited types of federally required information for
which there is no specific space provided on the manifest, including any alternate facility
designations; the manifest tracking number of the original manifest for rejected wastes
and residues that are re-shipped under a second manifest; and the specification of PCB
waste descriptions and PCB out-of-service dates required under 40 CFR 761.207.
Generators, however, cannot be required to enter information in this space to meet state
regulatory requirements.
3/14 Waste–68E

Item 15. Generator’s/Offeror’s Certifications
1. The generator must read, sign, and date the waste minimization certification statement.
In signing the waste minimization certification statement, those generators who have not
been exempted by statute or regulation from the duty to make a waste minimization
certification under section 3002(b) of RCRA are also certifying that they have complied
with the waste minimization requirements. The Generator’s Certification also contains
the required attestation that the shipment has been properly prepared and is in proper
condition for transportation (the shipper’s certification). The content of the shipper’s
certification statement is as follows: “I hereby declare that the contents of this
consignment are fully and accurately described above by the proper shipping name, and
are classified, packaged, marked, and labeled/placarded, and are in all respects in proper
condition for transport according to applicable international and national governmental
regulations. If export shipment and I am the Primary Exporter, I certify that the contents
of this consignment conform to the terms of the attached EPA Acknowledgment of
Consent.” When a party other than the generator prepares the shipment for
transportation, this party may also sign the shipper’s certification statement as the offeror
of the shipment.
2. Generator or Offeror personnel may preprint the words, ‘‘On behalf of’’ in the signature
block or may hand write this statement in the signature block prior to signing the
generator/offeror certification, to indicate that the individual signs as the employee or
agent of the named principal.
Note: All of the above information except the handwritten signature required in Item 15 may be
pre-printed.
II. Instructions for International Shipment Block
Item 16. International Shipments
For export shipments, the primary exporter must check the export box, and enter the point of exit
(city and state) from the United States. For import shipments, the importer must check the
import box and enter the point of entry (city and state) into the United States. For exports, the
transporter must sign and date the manifest to indicate the day the shipment left the United
States. Transporters of hazardous waste shipments must deliver a copy of the manifest to the
U.S. Customs when exporting the waste across U.S. borders.
68F–Waste 3/14

III. Instructions for Transporters
Item 17. Transporters’ Acknowledgments of Receipt
Enter the name of the person accepting the waste on behalf of the first transporter. That person
must acknowledge acceptance of the waste described on the manifest by signing and entering the
date of receipt. Only one signature per transportation company is required. Signatures are not
required to track the movement of wastes in and out of transfer facilities, unless there is a change
of custody between transporters.
If applicable, enter the name of the person accepting the waste on behalf of the second
transporter. That person must acknowledge acceptance of the waste described on the manifest
by signing and entering the date of receipt.
Note: Transporters carrying imports, who are acting as importers, may have responsibilities to
enter information in the International Shipments Block. Transporters carrying exports may
also have responsibilities to enter information in the International Shipments Block. See above
instructions for Item 16.
IV. Instructions for Owners and Operators of Treatment, Storage, and Disposal
Facilities
Item 18. Discrepancy
Item 18a. Discrepancy Indication Space
1. The authorized representative of the designated (or alternate) facility’s owner or operator
must note in this space any discrepancies between the waste described on the manifest
and the waste actually received at the facility. Manifest discrepancies are: significant
differences (as defined by §§ 264.72(b) and 265.72(b)) between the quantity or type of
hazardous waste designated on the manifest or shipping paper, and the quantity and type
of hazardous waste a facility actually receives, rejected wastes, which may be a full or
partial shipment of hazardous waste that the TSDF cannot accept, or container residues,
which are residues that exceed the quantity limits for “empty” containers set forth in 40
CFR 261.7(b).
2. For rejected loads and residues (40 CFR 264.72(d), (e), and (f), or 40 CFR 265.72(d), (e),
or (f)), check the appropriate box if the shipment is a rejected load (i.e., rejected by the
designated and/or alternate facility and is sent to an alternate facility or returned to the
generator) or a regulated residue that cannot be removed from a container. Enter the
reason for the rejection or the inability to remove the residue and a description of the
waste. Also, reference the manifest tracking number for any additional manifests being
used to track the rejected waste or residue shipment on the original manifest. Indicate the
original manifest tracking number in Item 14, the Special Handling Block and Additional
Information Block of the additional manifests.
3/14 Waste–68G

3. Owners or operators of facilities located in unauthorized states (i.e., states in which the
U.S. EPA administers the hazardous waste management program) who cannot resolve
significant differences in quantity or type within 15 days of receiving the waste must
submit to their Regional Administrator a letter with a copy of the manifest at issue
describing the discrepancy and attempts to reconcile it (40 CFR 264.72(c) and
265.72(c)).
4. Owners or operators of facilities located in authorized states (i.e., those states that have
received authorization from the U.S. EPA to administer the hazardous waste management
program) should contact their state agency for information on where to report
discrepancies involving “significant differences” to state officials.
Item 18b. Alternate Facility (or Generator) for Receipt of Full Load Rejections
Enter the name, address, phone number, and EPA Identification Number of the Alternate Facility
which the rejecting TSDF has designated, after consulting with the generator, to receive a fully
rejected waste shipment. In the event that a fully rejected shipment is being returned to the
generator, the rejecting TSDF may enter the generator’s site information in this space. This field
is not to be used to forward partially rejected loads or residue waste shipments.
Item 18c. Alternate Facility (or Generator) Signature
The authorized representative of the alternate facility (or the generator in the event of a returned
shipment) must sign and date this field of the form to acknowledge receipt of the fully rejected
wastes or residues identified by the initial TSDF.
Item 19. Hazardous Waste Report Management Method Codes
Enter the most appropriate Hazardous Waste Report Management Method code for each waste
listed in Item 9. The Hazardous Waste Report Management Method code is to be entered by the
first treatment, storage, or disposal facility (TSDF) that receives the waste and is the code that
best describes the way in which the waste is to be managed when received by the TSDF.
Item 20. Designated Facility Owner or Operator Certification of Receipt (Except As Noted in
Item 18a)
Enter the name of the person receiving the waste on behalf of the owner or operator of the
facility. That person must acknowledge receipt or rejection of the waste described on the
manifest by signing and entering the date of receipt or rejection where indicated. Since the
Facility Certification acknowledges receipt of the waste except as noted in the Discrepancy
Space in Item 18a, the certification should be signed for both waste receipt and waste rejection,
with the rejection being noted and described in the space provided in Item 18a. Fully rejected
wastes may be forwarded or returned using Item 18b after consultation with the generator. Enter
the name of the person accepting the waste on behalf of the owner or operator of the alternate
facility or the original generator. That person must acknowledge receipt or rejection of the waste
68H–Waste 3/14

described
on the manifest by signing and entering the date they received or rejected the waste in Item 18c.
Partially rejected wastes and residues must be re-shipped under a new manifest, to be initiated
and signed by the rejecting TSDF as offeror of the shipment.
What are the instructions for completing the continuation sheet (EPA Form 8700-22A)?
Read all instructions before completing the form.
The form has been designed for use on a 12-pitch (elite) typewriter; a firm point pen may also be
used—press down hard.
The form must be used as a continuation sheet to U.S. EPA Form 8700-22 if:
• More than two transporters are to be used to transport the waste; or
• More space is required for the U.S. DOT descriptions and related information in Item 9
of U.S. EPA Form 8700-22.
Federal regulations require generators and transporters of hazardous waste and owners or
operators of hazardous waste treatment, storage, or disposal facilities to use the uniform
hazardous waste manifest (EPA Form 8700-22) and, if necessary, the continuation sheet (EPA
Form 8700-22A) for both interstate and intrastate transportation.
I. Generators
Item 21. Generator’s ID Number
Enter the generator’s U.S. EPA twelve-digit identification number or, the state generator
identification number if the generator site does not have an EPA identification number.
Item 22. Page ___
Enter the page number of the continuation sheet.
Item 23. Manifest Tracking Number
Enter the Manifest Tracking Number from Item 4 of the manifest form to which the continuation
sheet is attached.
Item 24. Generator’s Name—
Enter the generator’s name as it appears in Item 5 on the first page of the manifest.
3/14 Waste–68I

Item 25. Transporter—Company Name
If additional transporters are used to transport the waste described on the manifest, enter the
company name of each additional transporter in the order in which they will transport the
waste. Enter after the word “Transporter” the order of the transporter. For example, Transporter
3 Company Name. Also enter the U.S. EPA twelve-digit identification number of the transporter
described in Item 25.
Item 26. Transporter—Company Name
If additional transporters are used to transport the waste described on the manifest, enter the
company name of each additional transporter in the order in which they will transport the waste.
Enter after the word “Transporter” the order of the transporter. For example, Transporter 4
Company Name. Each continuation sheet can record the names of two additional transporters.
Also enter the U.S. EPA twelve-digit identification number of the transporter named in Item 26.
Item 27. U.S. D.O.T. Description Including Proper Shipping Name, Hazardous Class, and ID
Number (UN/NA)
For each row enter a sequential number under Item 27b that corresponds to the order of waste
codes from one continuation sheet to the next, to reflect the total number of wastes being
shipped. Refer to instructions for Item 9 of the manifest for the information to be entered.
Item 28. Containers (No. And Type)
Refer to the instructions for Item 10 of the manifest for information to be entered.
Item 29. Total Quantity
Refer to the instructions for Item 11 of the manifest form.
Item 30. Units of Measure (Weight/Volume)
Item 31. Waste Codes
Item 32. Special Handling Instructions and Additional Information
68J–Waste 3/14

II. Transporters
Item 33. Transporter—Acknowledgment of Receipt of Materials
Enter the same number of the Transporter as identified in Item 25. Enter also the name of the
person accepting the waste on behalf of the Transporter (Company Name) identified in Item 25.
That person must acknowledge acceptance of the waste described on the manifest by signing and
entering the date of receipt.
Item 34. Transporter—Acknowledgment of Receipt of Materials
Enter the same number of the Transporter as identified in Item 26. Enter also the name of the
person accepting the waste on behalf of the Transporter (Company Name) identified in Item 26.
That person must acknowledge acceptance of the waste described on the manifest by signing and
entering the date of receipt.
III. Owner and Operators of Treatment, Storage, or Disposal Facilities
Item 35. Discrepancy Indication Space
Refer to Item 18. This space may be used to more fully describe information on discrepancies
identified in Item 18a of the manifest form.
Item 36. Hazardous Waste Report Management Method Codes
For each field in Item 36, enter the sequential number that corresponds to the waste materials
described under Item 27, and enter the appropriate process code that describes how the materials
will be processed when received. If additional continuation sheets are attached, continue
numbering the waste materials and process code fields sequentially, and enter on each sheet the
process codes corresponding to the waste materials identified on that sheet.
What is the public reporting burden associated with the manifest?
Public reporting burden for this collection of information is estimated to average: 30 minutes for
generators, 10 minutes for transporters, and 25 minutes for owners or operators of treatment,
storage, and disposal facilities. This includes time for reviewing instructions, gathering data,
completing, reviewing and transmitting the form. Any correspondence regarding the Paperwork
Reduction Act burden statement for the manifest must be sent to the Director of the Collection
Strategies Division in EPA’s Office of Information Collection at the following address: U.S.
Environmental Protection Agency (2822T), 1200 Pennsylvania Ave., NW., Washington, DC
20460. Do not send the completed form to this address.
3/14 Waste–68K

Electronic manifesting and the e-Manifest Act

The Hazardous Waste Electronic Manifest Establishment Act, or e-Manifest Act, became law
in 2012. The new law required EPA to develop an electronic hazardous waste manifesting
system within three years. EPA’s Administrator signed the final rule authorizing the devel-
opment of the e-Manifest system in January 2014.
Under the e-Manifest system, hazardous waste generators, transporters, and treatment,
storage, and disposal facilities will have the option to complete, sign, transmit, and store
manifest information electronically.
The e-Manifest system will improve the delivery of waste tracking services to government
officials and to the public for the first time. It is also expected to substantially reduce costs
relative to the paper manifest system now in place — perhaps up to $75 million — and as
much as 300,000 to 700,000 in paperwork burden hours.
Other major benefits include:
1. Better access to higher quality and more timely waste shipment data;
2. Nearly real-time shipment tracking;
3. Enhanced manifest inspection and enforcement capabilities for regulators;
4. Rapid notification and responses to problems or discrepancies with shipments or
deliveries;
5. More accurate and faster information for emergency responders about the types
and sources of hazardous waste that are in transit between generator sites and
waste management facilities;
6. One-stop manifest copy submission to EPA and to all interested states;
7. Greater transparency for the public about completed hazardous waste shipments
to or from their communities; and
8. New data management possibilities that could ultimately simplify RCRA biennial
reporting requirements and consolidate various federal and state reporting require-
ments for domestic and transboundary hazardous waste shipments.
Opt-out option
Once the e-Manifest system is developed, electronic manifest documents will be available to
manifest users as an alternative to the paper manifest forms, although users may elect to
opt out of the e-Manifest system and continue to use paper manifests to track hazardous
waste shipments. The disposal facility will submit any paper manifests to EPA for inclusion
in the e-Manifest system.
Transporters
Transporters will also be able to take advantage of e-Manifesting by using a tablet computer
or other “smart” device. However, where a federal or state law requires the transporter to
carry a paper copy of the manifest (e.g., Hazardous Materials regulations require certain
shippers of hazardous materials to supply a paper document for compliance with 49 CFR
177.817), the generator of the waste must provide the transporter with one printed copy of
the electronic manifest.
68L–Waste 3/14

Fees
The final rule also addresses how the agency will impose “reasonable” user service fees as a
means to fund the development and operation of the e-Manifest system. Fees will apply to
generators, transporters, and storage facilities. In addition, those who opt to use paper
manifests will encounter user fees. EPA will publish a further notice to announce the user
fee schedule for manifest-related activities.
Hazardous waste handlers cannot begin tracking waste shipments electronically

until the system is actually up and running. The Act calls for the system to be
online by October 5, 2015.
Permit process streamlined for hazardous waste facilities

EPA has revised the hazardous waste permitting program to allow for a standardized
permit. The rule potentially affects between 870 and 1,130 private sector and federal
facilities.
The standardized permit is available to hazardous waste treatment, storage, and disposal
facilities (TSDs) that generate and then store or non-thermally treat hazardous waste
on-site in tanks, containers, and containment buildings.
The permit is also available to facilities that receive hazardous waste generated off-site by a
generator under the same ownership as the receiving facility, and then store or non-
thermally treat the hazardous waste in containers, tanks, or containment buildings.
This rule streamlines the permitting process by allowing facilities to obtain and modify per-
mits more easily, while still achieving the same level of environmental protection as
individual permits.
What is a standardized permit?

A standardized permit is a special kind of permit for certain facilities that manage hazard-
ous waste in tanks, containers, and containment buildings.
The permit consists of two parts:
• the uniform portion included in all cases, and
• a supplemental portion included at EPA’s or the state permitting authority’s
discretion.
The requirements finalized in this rule provide the basis for the uniform portion of the
permit. The supplemental portion includes additional provisions deemed necessary to protect
human health and the environment, including any corrective action, and based on site-
specific factors at the facility.
3/14 Waste–68M

Universal Waste
What is universal waste?

The universal waste regulations streamline hazardous waste management standards for
specific, federally designated wastes. The rule is designed to reduce the amount of hazardous
waste items in the municipal solid waste (MSW) stream, to encourage recycling and proper
disposal of certain common hazardous wastes, and to reduce the regulatory burden on busi-
nesses that generate these wastes.
The state’s role in universal waste management

Like most federal environmental legislation, RCRA encourages states to develop and run
their own hazardous waste programs as an alternative to direct EPA management. When
EPA issues a new rule, such as the Universal Waste Rule, states that are authorized to
implement the RCRA program must adopt the rule in a separate state rulemaking for it to
be effective. Because the Universal Waste Rule is less stringent than the current require-
ments under RCRA, state adoption is optional. EPA strongly encourages state adoption,
however, to foster better management of universal wastes in each state. Quick state adop-
tion will make interstate issues less complex. Consistent programs among states will
facilitate implementation of national and regional collection programs.
States may adopt the entire rule or portions of it, including:
• general provisions;
• provisions for batteries, pesticides, thermostats, and lamps; and
• provisions allowing the addition of new universal wastes.
If states adopt the petition provision, they will be allowed to add wastes to their universal
waste programs without EPA having to add the wastes at the federal level.
Universal wastes defined

The federal universal waste regulations are found at 40 CFR 273 and cover four basic waste
areas:
• Batteries
• Pesticides
• Mercury-containing equipment
• Light bulbs (lamps)
Batteries
Specific types of batteries covered under the rule include the following:
• Batteries such as nickel-cadmium (Ni-Cd)
• Small sealed lead-acid batteries, which are found in many common items in the
business and home setting, including:
68N–Waste 3/14

❍ Electronic equipment;
❍ Mobile telephones;
❍ Portable computers; and
❍ Emergency backup lighting.
Pesticides
Waste pesticides that are classified as hazardous waste can qualify as universal wastes at 40
CFR 273.9 when they meet the following conditions:
1. They are recalled pesticides that are:
Part of a voluntary or mandatory recall under FIFRA Section 19(b), including, but
not limited to those owned by the registrant responsible for conducting the recall;
or
Part of a voluntary recall by the registrant.
2. Stocks of other unused pesticide products that are collected and managed as part of
a waste pesticide collection program.
Mercury-containing equipment
A third form of universal waste is mercury-containing equipment. Mercury-containing equip-
ment includes devices, items, or articles that contain varying amounts of elemental mercury,
including several types of instruments that are used throughout electric utilities and other
industries, municipalities, and households. Some commonly recognized devices are:
• Thermostats,
• Barometers,
• Manometers,
• Temperature and pressure gauges, and
• Mercury switches, such as light switches in automobiles.
Other items currently classified as universal waste are batteries, thermostats, pesticides,
and lamps.
Lamps
The regulation defines a universal waste lamp as the bulb or tube portion of an electric
lighting device. Examples of common universal waste electric lamps include, but are not lim-
ited to:
• fluorescent,
• high-intensity discharge,
• neon,
• mercury vapor,
• high-pressure sodium, and
• metal halide lamps.
9/13 Waste–69

Hazardous waste lamps that are not recycled will continue to be treated with the same dis-
posal safeguards that apply to all hazardous wastes.
Cathode ray tubes (CRTs)

A CRT is the glass video display component of an electronic device (usually a computer or
television monitor). Many CRTs that cannot be reused are sent for recycling, which consists
of disassembly to recover valuable materials from the CRTs, such as lead or glass.
The amendments exclude these materials from the definition of solid waste if certain condi-
tions are met. This rule is intended to encourage recycling and reuse of used CRTs and CRT
glass.
Universal waste rule applicability

The universal waste rule applies to businesses, households, and communities.
Businesses
Universal wastes are generated by small and large businesses that are regulated under
RCRA, and have been required to handle these materials as hazardous wastes. The Univer-
sal Waste Rule eases the regulatory burden on businesses that generate these wastes.
Specifically, it streamlines the requirements related to notification, labeling, marking, prohi-
bitions, accumulation time limits, employee training, response to releases, offsite shipments,
tracking, exports, and transportation. For example, the rule extends the amount of time that
businesses can accumulate these materials on site. It also allows companies to transport
them with a common carrier instead of a hazardous waste transporter, and no longer
requires companies to obtain a manifest.
Many industries strongly support this new rule because they have identified easy collection
of universal wastes as a priority to ensure sound environmental management. This rule will
make it easier for companies to establish collection programs and participate in manufac-
turer take-back pro grams required by a number of states. Many large manufacturers and
trade associations are already planning national and regional collection programs for their
products.
The rule does not apply to businesses that generate less than 100 kilograms of universal
wastes per month (Conditionally Exempt Small Quantity Generators). EPA encourages these
businesses to participate voluntarily in collection and recycling programs by bringing these
wastes to collection centers for proper treatment and disposal.
Households
Universal wastes also are generated by individual households, which are not regulated
under RCRA, and are allowed to dispose of these wastes in the trash. While new municipal
solid waste (MSW) landfills are designed to handle small amounts of hazardous wastes,
these wastes can be better managed in a designated program for collection or recycling. EPA
encourages residents to take these items to collection sites located at nearby businesses and
other centers for proper recycling or disposal.
70–Waste 9/13

Communities
Communities in states that adopt this rule can work with both businesses and residents to
facilitate proper recycling or disposal of universal wastes. By easing the regulatory burden
on businesses, more collection sites will be available. Communities can establish collection
programs or assist collection programs set up by area businesses.
Requirements for participants in the universal waste system

There are four types of participants in the universal waste system:
• Small Quantity Handlers of Universal Waste (SQHUW)
• Large Quantity Handlers of Universal Waste (LQHUW)
• Universal Waste Transporters
• Destination Facilities
Although there are 10 basic universal waste management requirements, individual partici-
pants in the universal waste system are not subject to all 10 requirements. Only those
requirements that have been determined to be appropriate for a given type of participant
are included in the regulations for that participant. Throughout the universal waste regula-
tions, each of these 10 basic requirements is addressed in regulatory sections using the same
section headings.
For example, the same requirements are addressed in the off-site shipments section for
SQHUWs as are addressed in the off-site shipments sections for LQHUWs, transporters, and
destination facilities. In some cases, not all issues within a section were determined to be
necessary for each type of participant, so some sections do not address every issue addressed
in other sections with the same heading. Refer to Table 1 for an overview of the universal
waste requirements.
Table 1. Overview of Universal Waste Requirements1
Universal Waste System SQHUW LQHUW Universal Waste Destination Facilities
Participants Transporters
Prohibitions Section 273.11 Section 273.31 Section 273.51 Comply with RCRA,
TSDF requirements
Notification Section 273.12 No Section 273.32 Comply with DOT Comply with RCRA,
requirements requirements TSDF requirements
Waste Management Section 273.13 Section 273.33 Section 273.52 Comply with RCRA,
Requirements Comply with DOT TSDF requirements
requirements
Labeling/Marking Section 273.14 Section 273.34 Comply with DOT Comply with RCRA,
requirements TSDF requirements
Storage time limits Section 273.15 Section 273.35 Section 273.53 Comply with RCRA,
One Year Limit One-year limit Ten-day limit TSDF requirements
Employee training Section 273.16 Section 273.36 Comply with DOT Comply with RCRA,
Distribute info Ensure familiarity requirements TSDF requirements
Response to releases Section 273.17 Section 273.37 Section 273.54 Comply with RCRA,
TSDF requirements
Off-site shipments Section 273.18 Section 273.38 Section 273.55 Section 273.61
Comply with DOT
requirements
Tracking Section 273.19 No Section 273.39 Comply with DOT Section 273.62
requirements requirements
9/13 Waste–71

Table 1. Overview of Universal Waste Requirements1, Continued

Universal Waste System SQHUW LQHUW Universal Waste Destination Facilities
Participants Transporters
Export requirements Section 273.20 Section 273.40 Section 273.56 Section 273.63
1
Gray shading indicates that there is a regulatory section in Part 273 of the universal waste regulations.
RCRA – Resource Conservation and Recovery Act
TSDF – Treatment, storage, and disposal facilities
Small and large quantity handlers of universal waste

There are two types of handlers of universal waste. The first type of handler is a person who
generates, or creates, universal waste. This is a person who uses batteries, pesticides, or
thermostats, and who eventually decides that they are no longer usable, and as a result, are
waste. Contractors or repair people who decide that batteries or thermostats are no longer
usable and remove them from service also generate universal waste, and consequently are
handlers of universal waste.
The second type of handler is a person who receives universal waste from generators or
other handlers, consolidates the waste, and then sends it on to other handlers, recyclers, or
treatment/ disposal facilities. Universal waste handlers accumulate universal waste, but do
not treat, recycle, or dispose of the waste. Each separate location, such as a generating loca-
tion or collecting location, is considered a separate universal waste handler. As a result, if
one company has several locations at which universal waste is generated or collected, each
location is a separate handler.
There are two sets of regulations for handlers of universal waste. Subpart B of part 273
establishes the requirements that small quantity handlers of universal waste must follow.
SQHUWs are those that do not accumulate 5,000 kilograms or more total (all uni-
versal waste categories combined) of universal waste at their location at any time.
Subpart C of part 273 establishes the requirements that large quantity handlers of univer-
sal waste must follow. LQHUWs are those that accumulate 5,000 kilograms or more
total (all universal waste categories combined) of universal waste at any time.
This designation as a large quantity handler of universal waste is retained through the end
of the calendar year in which 5,000 kilograms or more total of universal waste is accumu-
lated at any one time. EPA realizes that some handlers of universal waste who would
generally qualify as a small quantity handler may have a one-time, or infrequent, occasion
to accumulate 5,000 kg of universal waste, at any one time, on-site, a situation that would
require them to comply with the large quantity handler regulations in the rule.
Prohibitions
Small and large handlers of universal wastes are prohibited from disposing of, diluting, or
treating universal waste except in certain circumstances. Exceptions to dilution and treat-
ment under the universal waste regulations include responding to a release as covered in
273.13, or the managing of specific wastes covered in 273.13.
These exceptions include allowing handlers of universal waste batteries to conduct routine
battery management activities as long as the casing of each individual battery is not
breached and remains closed and intact.
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Routine battery management activities include sorting batteries by type, mixing battery
types in one container, discharging batteries, regenerating used batteries, disassembling bat-
tery packs, removing batteries from discarded consumer products, or removing electrolyte
from batteries. The types of battery management activities that are allowed under the
exception, and the requirements that must be met are referenced in the prohibitions section,
and detailed in the waste management section.
Another exception to the treatment prohibition has been added to the final rule that allows
certain thermostat management activities. This exception allows handlers to remove
mercury-containing ampules from thermostats. As with the battery management exception,
these activities must meet certain requirements referenced in the prohibitions section, and
detailed in the waste management section.
Notification
SQHUWs are not required to notify EPA of their universal waste activities, and are not
required to obtain an EPA identification number. LQHUWs are required to notify EPA and
to obtain an EPA identification number. The notification must include:
• The universal waste handler’s name and mailing address.
• The name and business telephone number of the person at the universal waste han-
dler’s site who should be contacted regarding universal waste management
activities.
• The address or physical location of the universal waste management activities.
• A list of all of the types of universal waste managed by the handler, such as batter-
ies, pesticides, and thermostats.
• A statement indicating that the handler is accumulating more than 5,000 kilograms
of universal waste at one time and the types of universal waste, such as batteries,
pesticides, and thermostats) the handler is accumulating above this quantity.
Accumulation time limit

SQHUWs, LQHUWs, and consolidation points are prohibited from accumulating universal
waste for longer than one year from the date the universal waste was generated, or received
from another facility. For any accumulation longer than one year, the handler must be able
to prove that this accumulation is solely for accumulating quantities necessary to facilitate
proper recovery, treatment, or disposal. These requirements are found in sections 273.15 and
273.35.
Handlers and consolidation points must mark or label the container (or use an alternate
method) to document the earliest date any universal waste accumulated at the location
became a waste.
Handlers of universal waste who generate extremely small quantities of hazardous waste
(<100 kg per month) still have the option to manage their wastes under the conditionally
exempt small quantity generator provisions of 40 CFR 261.5 rather than the universal waste
regulations (or the full Subtitle C regulations).
9/13 Waste–73

Universal waste transporters

Transporters are persons who transport universal waste from handlers of universal waste to
other handlers, destination facilities, or foreign destinations. A transporter may be an inde-
pendent shipper contracted to transport the waste, or may be a handler who self-transports
the waste. A universal waste handler who self-transports waste becomes a transporter for
those self-transportation activities, and is subject to the requirements of Subpart D of the
universal waste rule.
The universal waste rule does include some specific requirements for transporters. However,
the basic approach to transportation under the universal waste system is that no hazardous
waste manifests are required, and transporters must comply with the Department of Trans-
portation (DOT) requirements that would be applicable to the waste if it were being
transported as a product.
For example, if transporting universal waste batteries, the transporter must comply with
the appropriate DOT requirements, which are based on whether the particular battery type
is a DOT hazardous material, and if so, which DOT hazardous material requirements apply
to the specific battery type.
If the waste material does not meet the definition in the hazardous materials regulations
(HMR) for hazardous waste or any other type of hazardous material, its shipping description
on shipping papers may not include a hazard class or identification number shown in the
HMR.
If the waste is stored for greater than 10 days, the transporter becomes a small or large
quantity handler of universal waste, and is subject to the applicable regulations under sub-
parts B or C of part 273 while storing the universal waste.
Destination facilities
Destination facility means a facility that treats, disposes of, or recycles a particular category
of universal waste, except those management activities described in paragraphs (a) and ©) of
sections 273.13 and 273.33. A facility at which a particular category of universal waste is
only accumulated is not a destination facility for purposes of managing that category of uni-
versal waste.
The universal waste rules include only two specific universal waste requirements for desti-
nation facilities. In general, however, these facilities are subject to the same requirements
that are applicable to treatment, storage, and disposal facilities under the full hazardous
waste regulations. This includes permitting as well as general facility standards and unit
specific requirements.
In addition to the full hazardous waste requirements, there are three sections specifying
universal waste requirements for destination facilities. For the most part these requirements
simply mirror universal waste handler requirements for receipt of universal waste, since
destination facilities also receive universal waste.
Owners and operators of destination facilities must keep the same records for receipt of uni-
versal waste shipments as those kept by handlers of large quantities of universal wastes.
Section 273.62(a) requires the owner or operator of a destination facility to keep a record of
universal waste received at the facility.
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The record must include information on the name and address of the universal waste han-
dler or foreign shipper from whom the universal waste was sent; the quantity of each type of
universal waste received; and the date of receipt of the shipment of universal waste. Section
273.62(b) requires that these records be retained for at least three years from the date of
receipt of a shipment of universal waste.
This provision will complete the record of universal waste shipments, providing documenta-
tion of receipt, and allowing comparison of outgoing shipments from handlers against
received shipments at destination facilities. No specific form is required for maintaining
these records, and EPA believes that standard business records that would normally be kept
by any business will fulfill this requirement.
Management of batteries
Small quantity handlers of universal waste, and large quantity handlers of universal waste
must manage universal wastes in a way that prevents releases to the environment. They are
required to comply with packaging requirements, implement procedures to follow when han-
dling batteries (e.g., sorting battery types, mixing battery types, disassembling battery
packs, removing electrolyte, etc.), and when removing mercury-containing ampules from
thermostats.
Concerning the prevention of releases, handlers are required to contain any universal waste
battery that shows evidence of leakage, spillage, or damage that could cause leakage under
reasonably foreseeable conditions in a container. The container must be closed, structurally
sound, and compatible with the contents of the battery. This means that the containers must
be in good condition (no severe rusting, apparent structural defects, or deterioration).
Battery types are mixed in containers at collection points to avoid the complexity of requir-
ing those who are dropping off batteries to identify and manage battery types separately.
Collected mixed batteries must be sorted by type in order to send them to the appropriate
destination facilities for proper recycling or treatment.
Batteries must be removed from discarded consumer products to make shipping and han-
dling economical. Discharging batteries may be conducted as a safety precaution prior to
accumulation or shipping. Handlers may conduct the battery management activities listed
above as long as the battery or cell casings are not breached, and remain closed and intact.
EPA has removed the 40 CFR 261.6 exemption for used batteries that are to be regenerated,
and has added a provision specifying that facilities regenerating used batteries are subject
to the Part 273 standards for small or large quantity handlers of universal waste. As a
result, regeneration of used batteries has also been included as part of the management
activities mentioned above for universal waste batteries.
Handlers who generate hazardous waste electrolyte or other hazardous wastes are subject to
the generator requirements of 40 CFR Part 262. If electrolyte or any other generated non-
universal wastes are not hazardous wastes, they may be managed under applicable solid
waste management regulations.
9/13 Waste–75

Management of pesticides
Suspended and/or canceled and recalled pesticides managed under the universal waste regu-
lations must be packaged to meet one of the following four conditions:
• Containers must remain closed, be structurally sound, compatible with the pesticide,
and lack evidence of leakage, spillage, or damage that could cause leakage under
reasonably foreseeable conditions.
• Pesticides managed in a container that does not meet the conditions in condition #1
above must be overpacked in a container that does meet the requirements specified
in condition #1.
• The pesticides must be contained in a tank that meets hazardous waste tank
requirements.
• Handlers must use a transport vehicle or vessel that is closed, structurally sound,
compatible with the pesticide, and that lacks evidence of leakage, spillage, or dam-
age that could cause leakage under reasonably foreseeable conditions.
Any universal waste pesticide that is managed in a container must be managed in a con-
tainer that is in good condition (no severe rusting, apparent structural defects, or
deterioration). The good-condition container may be the primary container (under condition
#1), or if the primary container is not acceptable, a good-condition container may be used to
overpack the primary container (i.e., the primary container is placed into a good-condition
overpack container).
Although the regulations do not require original packaging, original packaging may be used
to contain pesticides as long as the original packaging meets the conditions established in
conditions #1-4 above.
Management of mercury-containing equipment

Handlers of universal waste must manage mercury-containing equipment in a way that pre-
vents release of any universal waste to the environment. Update your written plan to
include the following procedures.
Containers
Place the following in a container:
• any universal waste mercury-containing equipment with non-contained elemental
mercury, and
• mercury-containing equipment that shows evidence of leakage, spillage, or damage
that could cause leakage under reasonably foreseeable conditions.
The container must:
• be closed, structurally sound, and compatible with the contents of the device;
• lack evidence of leakage, spillage, or damage that could cause leakage under reason-
ably foreseeable conditions; and
• be reasonably designed to prevent the escape of mercury into the environment by
volatilization or any other means.
76–Waste 9/13

Equipment with ampules of mercury

You may remove mercury-containing ampules from universal waste mercury-containing
equipment according to the following procedures:
• Remove and manage the ampules in a manner designed to prevent breakage of the
ampules.
• Remove the ampules only over or in a containment device (e.g., tray or pan suffi-
cient to collect and contain any mercury released from an ampule in case of
breakage).
• Ensure that a mercury clean-up system is readily available to immediately transfer
any mercury from spills or leaks of broken ampules from that containment device to
a container that meets the requirements of 40 CFR 262.34.
• Immediately transfer any mercury from spills or leaks from the containment device
to a container that meets the requirements of 40 CFR 262.34.
• Ensure that the area in which ampules are removed is well ventilated and moni-
tored to ensure compliance with applicable OSHA exposure levels for mercury.
• Ensure that employees removing ampules are thoroughly familiar with proper waste
mercury handling and emergency procedures, including transfer of mercury from
containment devices to appropriate containers.
• Store removed ampules in closed, non-leaking containers that are in good condition.
• Pack removed ampules in the container with packing materials adequate to prevent
breakage during storage, handling, and transportation.
Equipment without ampules of mercury

When handling universal waste mercury-containing equipment that does not contain an
ampule, you may remove the open original housing holding the mercury from universal
waste mercury-containing equipment according to the following procedures:
• Immediately seal the original housing holding the mercury with an air-tight seal to
prevent the release of any mercury to the environment.
• Follow all procedures for removing ampules and managing removed ampules (see
previous section).
Waste identification
If you remove mercury-containing ampules from mercury-containing equipment or seal mer-
cury from mercury-containing equipment in its original housing, determine whether the
following exhibit a characteristic of hazardous waste (from 40 CFR part 261, subpart C):
• mercury or clean-up residues resulting from spills or leaks, and
• other solid waste generated as a result of the removal of mercury-containing
ampules or housings (e.g., the remaining mercury-containing device).
If the mercury, residues, and/or other solid waste exhibits a characteristic of hazardous
waste, it must be managed in compliance with all applicable hazardous waste management
requirements.
The handler is considered the generator of the mercury, residues, and/or other waste and
must manage it in compliance with requirements for hazardous waste generators in 40 CFR
part 262.
9/13 Waste–77

If the mercury, residues, and/or other solid waste is not hazardous, you may manage the
waste in any way that is in compliance with applicable federal, state, or local solid waste
regulations.
Update labeling/marking
Universal waste mercury-containing equipment (i.e., each device), or a container in which
the equipment is contained, must be labeled or marked clearly with any of the following
phrases:
• Universal Waste—Mercury-Containing Equipment
• Waste Mercury–Containing Equipment
• Used Mercury–Containing Equipment
A universal waste mercury-containing thermostat or container containing only universal
waste mercury-containing thermostats may be labeled or marked clearly with any of the fol-
lowing phrases:
• Universal Waste—Mercury Thermostat(s)
• Waste Mercury Thermostat(s)
• Used Mercury Thermostat(s)
Revise employee training program

Review your training program for employees who handle universal wastes at your facility.
Revise the program to include procedures from your newly-updated written plan (see above).
Train employees in the proper procedures before they are allowed to handle the waste.
Ensure that all employees are thoroughly familiar with proper waste handling and emer-
gency procedures relative to their responsibilities during:
• normal facility operations, and
• emergencies.
Notification
Review the quantity of universal waste generated at your facility. Compare these quantities
with the limits in 40 CFR 273.32 to be sure your facility is in compliance with the notifica-
tion requirements for hazardous waste management activities.
Note that states may have rules that are more stringent than the federal requirements.
Check with your state agency to verify that you are following the rules that apply to your
operations.
Management of lamps
According to the regulations, large quantity handlers of universal waste must manage lamps
in a way that prevents releases of any universal waste or component of a universal waste to
the environment.
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This includes containing lamps in containers or packages that are structurally sound,
adequate to prevent breakage, and compatible with the contents of the lamps. Such contain-
ers and packages must remain closed and must lack evidence of leakage, spillage, or damage
that could cause leakage under reasonably foreseeable conditions.
A handler of universal waste must immediately clean up and place in a container any lamp
that is broken and must place in a container any lamp that shows evidence of breakage,
leakage, or damage that could cause the release of mercury or other hazardous constituents
to the environment. These containers must be closed, structurally sound, compatible with
the contents of the lamps, and must lack evidence of leakage, spillage, or damage that could
cause leakage or releases of mercury or other hazardous constituents to the environment
under reasonably foreseeable conditions.
Import requirements
Subpart F of the universal waste regulations clarifies the requirements for universal wastes
that are imported. In general, once universal waste enters the United States, it is subject to
the same universal waste requirements it would be if it had been generated in the United
States.
Universal waste that is imported from another country must be managed, upon entry into
the country, in compliance with the appropriate universal waste requirements for transport-
ers, handlers, or destination facilities, depending on the universal waste management
activities conducted within the United States.
For example, if a person imports universal waste into the United States and only transports
the imported waste to a facility owned and operated by someone else, he is subject to the
transporter requirements of Subpart D of Part 273. However, if a person imports universal
waste into the United States and subsequently transports the universal waste to his own
facility, the universal waste handler is subject to the transporter requirements for transport
of the universal waste, and to the small or large handler requirements of subparts B or C
for management at the receiving facility.
To determine whether the handler is a small or large quantity handler, universal waste
imported from a foreign country is counted toward the quantity of waste accumulated as any
other universal waste would be. If the handler is a large quantity handler of universal
waste, he must also comply with the tracking requirements for receipt of shipments specified
in Section 273.39(a).
If a person imports the waste into the United States and subsequently transports the uni-
versal waste to his own destination facility, he is subject to the destination facility Subpart
E requirements for management at the receiving facility.
Export requirements
must follow notification procedures when shipping universal wastes to foreign destinations.
The final export requirements for small and large handlers of universal waste are found in
sections 273.20 and 273.40.
A generator sending universal waste to a foreign destination, without first sending the waste
to a consolidation point or destination facility, would be subject to requirements equivalent
9/13 Waste–79

to the existing hazardous waste export requirements, subpart E of part 262, even though a
manifest would not have been required. These requirements included advance notification to
the receiving country and prior consent by the receiving country before the shipment could
occur.
Labeling and marking

The labeling and marking sections of the rules require handlers to label or mark universal
wastes or containers of universal waste to identify the type of universal waste, such as used
batteries or pesticides.
The labeling requirements vary depending on the type of waste; these requirements are
found in sections 273.14 and 273.34. A universal handler managing batteries at his facility
is required to label each individual universal waste item or container holding the universal
waste with the words “Universal Waste—Battery(ies)” or “Waste Battery(ies)” or “Used
Battery(ies).”
Similarly, a universal waste handler managing used mercury-containing thermostats under
Part 273 must label each universal waste item or container holding these universal wastes
with the words “Universal Waste—Mercury Thermostat(s)” or “Waste Mercury Thermo-
stat(s)” or “Used Mercury Thermostat(s).”
Labeling and marking requirements similar to those described above for universal waste
batteries and thermostats apply also to universal waste pesticides. As a result, a person
managing universal pesticides must mark or label his containers with the words “Universal
Waste—Pesticide(s)” or “Waste—Pesticide(s).” Refer to sections 273.14©)(2) or 273.34©)(2) for
more information.
However, because there are many types of pesticides posing different management issues,
EPA requires more specific labeling for pesticides in addition to the more general label dis-
cussed above. Due to differences in management practices between universal waste
pesticides that are a part of a recall, and pesticides that are a part of a state-approved col-
lection program, the requirements for each type of pesticide are different.
Universal waste handlers managing recalled pesticides are required to mark or label tanks
or containers holding the recalled pesticide with the original Federal Insecticide, Fungicide,
and Rodenticide Act (FIFRA) label that would be required under FIFRA if the pesticide were
a product (refer to Section 273.14(b)(1)) for more information.
Employee training
The employee training rules are somewhat different for SQHUWs and LQHUWs. Small
quantity handlers of universal waste must distribute basic handling and emergency informa-
tion to employees handling universal waste. Large quantity handlers of universal waste
must ensure that employees are familiar with waste handling and emergency procedures as
appropriate based on their responsibilities. The employee training requirements for small
and large handlers of universal waste are found in sections 273.16 and 273.36.
Large quantity handlers of universal waste must ensure that all employees are thoroughly
familiar with proper waste handling and emergency procedures related to their responsibili-
ties during normal facility operations and emergencies. Small quantity handlers of universal
waste, however, are subject to a less burdensome requirement.
80–Waste 9/13

Small quantity handlers of universal waste must inform all employees that handle or have
responsibilities for managing universal waste. The information must include proper han-
dling, and emergency procedures appropriate to the type(s) of universal waste managed at
the facility.
The employee training requirement for large quantity handlers of universal waste does not
require that any records be kept for training provided to employees. It only requires that
employees that have responsibilities for managing universal waste, or have responsibilities
for responding to emergencies be trained, and that these employees be trained as is appro-
priate for their universal waste management responsibilities.
As a result, employees who only minimally handle universal waste need only be trained to
properly carry out that activity, and to carry out their responsibilities, if any, in case of an
emergency. These requirements are analogous to those currently required for hazardous
waste small quantity generators. They basically require that the large quantity handler of
universal waste provide sufficient training to ensure that employees are familiar with proper
handling procedures, and that employees who would have responsibilities during emergen-
cies are familiar with emergency procedures.
Any training provided under other programs that would meet any or all of the Part 273
training requirements may be used to fulfill the RCRA requirements. As long as the sub-
stantive standards of the training provisions are met, the handler has fulfilled the training
requirement. There is no requirement that training provided to meet the RCRA require-
ments be separate from other training given to employees.
Response to releases
are required to immediately contain any releases of universal waste, and to handle residues
appropriately. Release requirements for small and large quantity handlers of universal
waste are found in sections 273.17 and 273.37.
These universal waste collectors are required to immediately contain all releases of, or from,
universal wastes, and to appropriately manage any materials resulting from a release, such
as cleanup equipment or contaminated soils. Specifically, they are required to determine if
any of the resulting materials are hazardous wastes, and if so, manage them under the full
hazardous waste regulations.
Destination facilities are subject to the full hazardous waste regulations applicable to treat-
ment, storage, disposal, and recycling facilities. These regulations include extensive release
response requirements.
In addition, any releases of hazardous substances above reportable quantity (RQ) thresholds
must be reported under the Comprehensive Environmental Response, Compensation, and
Liability Act (CERCLA), also known as Superfund. Because universal wastes are hazardous
wastes, and consequently hazardous substances under CERCLA, reporting for universal
waste releases are required (if over RQs). These reports provide notification to EPA concern-
ing releases, and allow the Agency to take action, if necessary, under either RCRA or
CERCLA.
9/13 Waste–81

Tracking universal waste shipments

The universal waste shipment tracking requirements are different for SQHUWs and
LQHUWs. Small quantity handlers of universal waste do not have any requirements. Large
quantity handlers of universal waste must maintain basic records documenting shipments
received at the facility and shipments sent from the facility.
Manifests are not required for any shipments of universal waste, but a basic recordkeeping
requirement has been added to track waste shipments arriving at, and leaving from, han-
dlers of large quantities of universal waste.
Destination facility requirements specify the retention of basic documentation of universal
waste shipments arriving at destination facilities; this basic tracking requirement is found
in sections 273.39 and 273.62. The required records may take the form of a log, invoice,
manifest, bill of lading, or other shipping document, and are to be maintained for three
years. No specific form is required for maintaining these records, and EPA believes that
standard business records that would normally be kept by any business will fulfill this
requirement.
For each shipment of universal waste received at or by a large quantity handler, the record
must include:
• the name and address of the universal waste handler or foreign shipper from whom
the universal waste was sent;
• the quantity of each type of universal waste received (e.g., batteries, pesticides, ther-
mostats); and
• the date of receipt of the shipment of universal waste.
For each shipment sent from a large quantity handler, the record must include:
• the name and address of the universal waste handler, destination facility, or foreign
destination to whom the universal waste was sent;
• the quantity of each type of universal waste sent (e.g., batteries, pesticides, thermo-
stats); and
• the date the shipment of universal waste left the facility.
Because no manifests will be used for shipments received by destination facilities, the final
rule requires that the owner or operator of a destination facility keep the same records for
receipt of universal waste shipments as those kept by handlers of large quantities of univer-
sal wastes. This will complete the record of universal waste shipments, providing
documentation of receipt and allowing comparison of outgoing shipments from handlers
against received shipments at destination facilities.
EPA has decided to require tracking for all shipments received by and shipped from han-
dlers of large quantities of universal waste, and not to require any tracking for handlers of
small quantities of universal wastes. Figure 1 illustrates the basic structure of the universal
waste system.
82–Waste 9/13

RCRA personnel training

EPA requires both small quantity generators (SQGs) and large quantity generators (LQGs)
to train employees in the safe handling of the hazardous waste. The training must be tai-
lored to the specific situation in the workplace. Conditionally exempt small quantity
generators are not required to train personnel, but it is a best practice to make sure employ-
ees are familiar with proper waste handling and emergency procedures for the wastes they
handle.
Small quantity generator training
The SQG training requirements are found at §262.34(d)(5)(iii): “The generator must ensure
that all employees are thoroughly familiar with proper waste handling and emergency proce-
dures, relevant to their responsibilities during normal facility operations and emergencies.”
The regulation does not address how, or how often, training must be conducted.
Large quantity generator training
For large quantity generators, the personnel training requirements are found at §262.
34(a)(4): “The generator complies with the requirements for owners or operators in subparts
C and D in 40 CFR part 265, with §265.16, and with all applicable requirements under 40
CFR part 268.”
The personnel training requirements at §265.16 say facility personnel must complete class-
room instruction or on-the-job training that teaches them to perform their duties “in a way
that ensures compliance with the hazardous waste regulations.”
The program must be directed by a “person trained in hazardous waste management

procedures.” The instructor must teach facility personnel how to manage the waste, includ-
ing contingency plans, for their specific jobs.
Section 265.16(a)(3) describes the emergency training requirements: “At a minimum, the
training program must be designed to ensure that facility personnel are able to respond
effectively to emergencies by familiarizing them with emergency procedures, emergency
equipment, and emergency systems, including where applicable:
9/13 Waste–83

(a)(3)(i) Procedures for using, inspecting, repairing, and replacing facility emergency and
monitoring equipment;
(a)(3)(ii) Key parameters for automatic waste feed cut-off systems;
(a)(3)(iii) Communications or alarm systems;
(a)(3)(iv) Response to fires or explosions;
(a)(3)(v) Response to ground-water contamination incidents; and
(a)(3)(vi) Shutdown of operations.”
The training needs to be provided by a person who is trained in hazardous waste manage-
ment procedures. In addition, workers must successfully complete the training program
within six months of being hired or after they move to a new position and must take part in
an annual review.
EPA, DOT, OSHA training crossover
Along with the specific training required for your generator category, there is some crossover
between EPA and DOT training requirements. Generators who ship hazardous waste off-site
must comply with both EPA and DOT regulations for hazardous materials. Hazardous waste
is considered a subset of hazardous materials.
These requirements will include providing the proper training for your generator category
and complying with DOT’s mandatory training for hazmat employees in 49 CFR Part 172. A
hazmat employee, including the person who signs the manifest, is defined by DOT as a
worker who:
• Loads, unloads, or handles hazardous materials;
• Designs, manufactures, fabricates, inspects, marks, maintains, reconditions, repairs,
or tests a package, container, or packaging component that is represented, marked,
certified, or sold as qualified for use in transporting hazardous materials in
commerce;
• Prepares hazardous materials for transportation;
• Is responsible for safety of transporting hazardous materials; or
• Operates a vehicle used to transport hazardous materials.
Hazmat employees must be trained in general awareness/familiarization, function-specific
training, and safety training. The training must occur within 90 days of employment and
must be repeated every three years. DOT requires the person signing the manifest to have
first-hand knowledge of the information listed on the manifest and the regulations that
apply to the waste.
The more responsibility an employee has and the more direct contact with the waste, the
more training will be required, both under DOT’s hazmat and EPA’s hazardous waste train-
ing requirements.
OSHA has said that the RCRA personnel training requirements at §165.16 may also meet
some of the HAZWOPER training requirements. See the HAZWOPER chapter in this book
for more information.
84–Waste 9/13

RCRA personnel training tips

Your approach to training — from what you cover to how you present the topic — can
impact the effectiveness of the training. Use the following section to help you prepare, orga-
nize, and present the training efficiently and effectively.
Facility personnel must complete a program of classroom instruction or on-the-job training
that teaches them to perform their duties to ensure compliance.
Evaluate the workplace
Determine what you need to cover (beyond the regulatory basics) by identifying specific
workplace hazards, issues, or affected employees. Deciding what you need to cover might
include reviewing equipment that will be used. Related topics might include working with
other employers or contractors for certain operations.
The training program must be directed by a person trained in hazardous waste management
procedures, and must include instruction which teaches hazardous waste management pro-
cedures (including contingency plan implementation) relevant to the positions of the
employees.
Consider your purpose and audience
During training, emphasize “How this affects you (the employee)” to give the training more
impact. Examples of what could happen during a hazardous waste emergency, not to men-
tion the impact on the company and surrounding community, can illustrate the importance
of the training. Employees need to understand that they have considerable responsibility for
their safety and the safety of the company.
Prepare and gather materials
Review the equipment that will be used, and familiarize yourself with the training content.
Also, review company policies, particularly those that go beyond regulatory requirements.
Trainees will almost certainly ask questions you haven’t considered. Familiarity with the
content will allow you to confidently answer any questions.
Use this list to help you prepare for the class.
• Choose a date and location for training, and reserve a classroom if appropriate.
• If necessary, find a location for hands-on training.
• Arrange to have necessary equipment available.
• Make a list of supplies and materials to have on hand. (Examples include a chalk
board, white board, or easels.)
9/14 Waste–85

What to cover
EPA requires small quantity generators to provide general training in the specific hazardous
waste duties of the job. Section 265.16 for large quantity generators contains more extensive
required training elements. At a minimum, the training program must be designed to ensure
that personnel are able to respond effectively to emergencies by familiarizing them with
emergency procedures, emergency equipment, and emergency systems, including, where
applicable:
• Procedures for using, inspecting, repairing, and replacing facility emergency and
monitoring equipment;
• Key parameters for automatic waste feed cut-off systems;
• Communications or alarm systems;
• Response to fires or explosions;
• Response to ground-water contamination incidents; and
• Shutdown of operations.
Facility personnel must complete the program within six months after the date of their
employment or assignment to a facility, or to a new position at a facility. They must also
take part in an annual review of the initial training.
Areas to review include:
Responses to fires or explosions: The facility must have a contingency plan that describes the
actions personnel are to take in case of fires, explosions, or any unplanned releases of haz-
ardous waste; outlines arrangements with local police departments, fire departments,
hospitals, contractors, and other response authorities; lists the names of emergency coordi-
nators; includes a list of all emergency equipment at the facility; and describes the facility
evacuation procedures.
Communications or alarm systems: Whenever hazardous waste is being poured, mixed,

spread, or otherwise handled, all personnel who are involved with the operation must have
immediate access to an internal alarm or emergency communication device. If there is ever
just one employee present while the facility is operating, he or she must have immediate
access to a device capable of summoning external emergency assistance.
Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring
equipment: All facility communications or alarm systems, fire protection equipment, spill
control equipment, and decontamination equipment, where required, must be tested and
maintained as necessary to assure its proper operation.
Procedures for shutdown of operations: If the facility stops operations in response to a fire,
explosion, or release, the emergency coordinator must monitor for leaks, pressure buildup,
gas generation, or ruptures in valves, pipes, or other equipment, wherever this is
appropriate.
Reporting requirements: If employees are not properly trained, they must not respond to a
leak or spill. Instead, they should follow the company’s emergency action plan for reporting
leaks and spills, and evacuation procedures. The name and telephone number of the compa-
ny’s emergency coordinator and fire department should be listed next to a telephone.
86–Waste 9/14

RCRA personnel training guidance

The following interpretive guidance on RCRA personnel training is used with the permission
of the Colorado Department of Public Health and Environment, and is taken from the guid-
ance document, Personnel Training for Large Quantity Generators of Hazardous Waste.
These interpretations are intended as general guidance for large quantity generators of haz-
ardous waste, but they may also be useful for small quantity generators, or owners and
operators of treatment, storage, and disposal facilities. Note the interpretations, while gen-
eral, are provided by the state of Colorado. Check with your state to make sure they apply
to your operations.
Regulatory Requirement — Section 262.34(a)(4)
“... a generator may accumulate hazardous waste on-site for 90 days or less without a permit
or without having interim status provided that ... the generator complies with the require-
ments for owners or operators in ... Section 265.16 ...”
“Facility personnel must successfully complete a program of classroom instruction and

on-the-job training that teaches them to perform their duties in a way that ensures the
facility’s compliance with the requirements of this part.”
Interpretive Guidance
The primary regulatory areas included in Part 265 with which generators must comply are:
preparedness and prevention, contingency plan and emergency procedures, personnel train-
ing, use and management of containers, tanks, drip pads, containment buildings, and air
emission standards. Your facility can combine hazardous waste personnel training with
other regulatory program training requirements if the specific requirements of Section
265.16 are also met. If your training program combines requirements for different regulatory
programs, a description of how the training meets the hazardous waste requirements is
recommended.
The levels of training needed to meet the requirements of Section 265.16 are:
1) Facility personnel must be familiarized with your facility’s contingency plan so they can
respond effectively in an emergency. This requirement also includes personnel not directly
involved with the management of hazardous waste but who may be affected by a hazardous
waste incident.
2) Facility personnel involved in the management of hazardous waste or the documentation
of hazardous waste activities must have training which is specific to their job duties. It is
expected that the job-specific training necessary will be as varied as the job duties present in
your facility.
“This program must be directed by a person trained in hazardous waste management proce-
dures, and must include instruction that teaches facility personnel hazardous waste
9/13 Waste–87

management procedures, (including contingency plan implementation) relevant to the posi-

tions in which they are employed.”
The training program needs to be managed by a person qualified by either experience or

education in hazardous waste management. This individual should be knowledgeable in haz-
ardous waste regulatory requirements and implementation and needs to be familiar with the
specific hazardous waste issues at your facility. It is likely that your facility environmental
officer will meet this requirement.
For on-the-job training, the instructor should be a supervisor or an individual who is skilled
in the current methods of facility operations and duties of the job. The hazardous waste
training program needs to be specific to the job duties at your facility. Training should be
structured so that it parallels, as realistically as possible, the actual job duties and should
take into account the educational level of the class. Measures of training effectiveness can be
performance-based, or by written or oral test. Facility personnel are responsible for learning
only those hazardous waste management procedures necessary for the positions in which
they are employed. This requirement includes those personnel responsible for the manage-
ment of documentation related to the management of hazardous waste. For example, office
staff responsible for maintaining hazardous waste manifests and LDR records should be
trained on the necessity of this paperwork and appropriate methods for maintenance of
these documents.
On-the job and annual refresher training may be conducted as part of regularly scheduled
meetings such as monthly safety meeting for work groups. Computer-based training, elec-
tronic memos, and read-only training could also meet these training requirements.
“At a minimum, the training program must be designed to ensure that facility personnel are
able to respond effectively to emergencies by familiarizing them with emergency procedures,
emergency equipment, and emergency systems, including where applicable:
(i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitor-
ing equipment;
(ii) Key parameters for automatic waste feed cut-off systems;
(iii) Communications or alarm systems;
(iv) Response to fires or explosions;
(v) Response to ground-water contamination incidents; and
(vi) Shutdown of operations.”
Facility personnel, despite their position, must have emergency response training so they
can respond effectively in an emergency. For example, if there is an evacuation due to vola-
tilization of spilled hazardous waste, most of the employees will be responsible for vacating
88–Waste 9/13

the premises in a predetermined manner. Other properly trained personnel will be respon-
sible for containing the spill, informing local officials, bringing out firefighting equipment,
etc. In addition to the emergency-related training elements described here, the training pro-
gram should contain basic hazardous waste management procedures (e.g., waste
identification and determinations, manifests, packaging, accumulation, container and tank
management, inspections, etc.) for select individuals as necessary [265.16(a)(2)].
Regulatory Requirement — Section 265.16(b)
“Facility personnel must successfully complete the training program required in paragraph
(a) of this section within six months after the date of their employment or assignment to a
facility, or assignment to a new position at a facility. Employees must not work in unsuper-
vised positions until they have completed the training requirements of paragraph (a) of this
section.”
Regulatory Requirement — Section 265.16(c)
“Facility personnel must take part in an annual review of the initial training required in
paragraph (a) of this section.”
This refresher training should be specific to individual employee job duties related to haz-
ardous waste management. (Colorado interprets “annual” to mean within 13 months of the
last training. Your state may have a different interpretation.)
Regulatory Requirement — Section 265.16(d)(1)
“The owner or operator must maintain the following documents and records at the facility:
(1) The job title for each position at the facility related to hazardous waste management,
and the name of the employee filling each job;”
Job title (Section 265.16(d)(1)) — This requirement excludes staff not involved in the man-
agement of hazardous waste at your facility. Job titles used to satisfy this requirement do
not need to match those used for personnel management. For example, your administrative
assistant may be responsible for hazardous waste manifest preparation and retention, and
you may choose to define this job title as “Environmental Clerk.” The job title may describe
a class of employees with specific hazardous waste management duties.
“(2) A written job description for each position listed under paragraph (d)(1) of this section.
The description may be consistent in its degree of specificity with description for other simi-
lar positions in the same company location or bargaining unit, but must include the
requisite skill, education, or other qualifications, and duties of facility personnel assigned to
each position;”
Job description (Section 265.16(d)(2)) — The description of duties and responsibilities for
each job title need only include those duties that are directly related to hazardous waste
9/13 Waste–89

management. It is not necessary to include other duties unless they affect or impact hazard-
ous waste-related duties. For example, the job description for the administrative assistant
who serves as an environmental clerk need only include the manifest preparation and reten-
tion responsibilities, and no other duties that the person may perform in their position.
“(3) A written description of the type and amount of both introductory and continuing train-
ing that will be given to each person filling a position listed under paragraph (d)(1) of this
section;”
Training description (Section 265.16(d)(2)) — Outlines of training programs or training
matrices may be used to fulfill this requirement. See the following table for an example
matrix of personnel training requirements for a hypothetical facility that illustrates the dif-
ferent types of job titles (as earlier described) and the training requirements associated with
each job category.
“(4) Records that document that the training or job experience required under paragraphs
(a), (b), and (c) of this section has been given to, and completed by, facility personnel.”
Employee participation documentation (Section 265.16(d)(4)) — Substantiated performance
measures (tests, etc.), class lists with signatures, individual training logs in personnel files,
or spreadsheets can be used for this documentation. Your system of training documentation
needs to be easily understood and readily accessible.
Regulatory Requirement — Section 265.16(e)
“Training records on current personnel must be kept until closure of the facility. Training
records on former employees must be kept for at least three years from the date the
employee last worked at the facility. Personnel training records may accompany personnel
transferred within the same company.”
The training records required are for those employees who are directly involved with haz-
ardous waste management at your facility. Documentation of training provided to other
employees who may only be affected by a hazardous waste incident could consist of a general
description of “awareness” training, and documented in accordance with the appropriate
regulatory requirement (e.g., OSHA, Fire Code).
90–Waste 9/13

Example Personnel Training Requirements for Large Quantity Generators of Hazardous Waste*
9/14
GENERIC JOB CATEGORY
TRAINING
ELEMENT Environmental Environmental General Office Production Maintenance Haz. Waste Plant Worker General Plant
Manager (1) Clerk (2) Personnel (3) Supervisor (4) Supervisor (5) Technician (6) (Generator) (7) Worker (8)
Hazardous Y
waste
regulations
Making waste Y Y
determinations
Properties of Y Y Y Y Y
facility wastes
Waste Y Y Y Y Y Y Y
Minimization
Reporting and Y Y Y
recordkeeping
Accumulation Y Y Y Y Y Y
(satellite / 90
day)
Container and Y Y Y Y
tank
management
Inspections Y Y Y Y Y
Waste Y Y Y
packaging
procedures
Pre- Y Y Y
transportation
(manifests,
labels)
Contingency Y Y Y Y Y
plan
implementation
Emergency Y Y Y Y Y
response
procedures
Emergency Y Y Y

equipment use,
inspection,
repair
Communications Y Y Y Y Y Y Y Y
and alarms
Evacuation Y Y Y Y Y Y Y Y
routes
Waste–91
Example Personnel Training Requirements for Large Quantity Generators of Hazardous Waste*, Continued
Response to Y Y Y Y Y
fire, explosion,
and ground-
92–Waste
water
contamination
incidents
Site shutdown Y Y Y Y Y
procedures
* Training requirements for a hypothetical manufacturing facility. This table has been developed to be representative of an average facility. Job
categories and associated training requirements will be specific to your facility and may not be identical to those presented in this table.
(1) Responsible for the overall hazardous waste management functions at the facility.
(2) Responsible for hazardous waste paperwork and recordkeeping functions. Has no direct contact with physical hazardous waste activities.
(3) General administrative and clerical personnel. No responsibilities related to hazardous waste management.
(4) Responsible for production activities at the facility. Supervises staff that are hazardous waste generators.
(5) Responsible for maintenance activities at the facility. Supervises staff that are hazardous waste generators and has some environmental
management responsibilities.
(6) Responsible for some hazardous waste management functions. Performs physical waste activities (e.g., moving and labeling containers, collecting
samples, etc.)
(7) Generates hazardous waste as part of production process. May utilize a satellite accumulation container.
(8) Generates no hazardous waste and has no direct contact with physical hazardous waste activities as part of the production process.

9/14
RCRA-OSHA training crossover

In addition to EPA’s RCRA training requirements, you may also need to train employees
according to OSHA’s regulations. For instance, if you have employees who use forklifts to
load hazardous waste, they will need to be trained to handle the hazardous waste and in
how to operate a forklift safely. The following tables describe the differences and similarities
between EPA and OSHA training. In many cases, meeting the training requirements for
EPA will also meet the requirements for OSHA. For example, OSHA says it will accept a
suitably robust RCRA Contingency Plan and training in place of the required emergency
response plan.
Crosswalk Between OSHA and RCRA Training Requirements
(Taken from EPA OSWER, Office of Resource Conservation and Recovery, “RCRA-OSHA Training
Requirements Overlap,” 1999)
RCRA Training Requirement OSHA Training Requirement Comment
264.16(a)(1) Basic Requirement — 1910.120 (p)(7)(I) Basic Requirement OSHA requirement meets or exceeds
Personnel must successfully - Personnel who are exposed to RCRA. Note that non-exposed
complete a program of instruction or health hazards or hazardous employees do not require OSHA
training which meets certain minimum substances at TSD operations must 1910.120 training.
requirements. successfully complete a 24 hr initial
training program which will enable the
employees to safely perform their
assigned duties.
264.16(a)(1) Setting for instruction — 1910.120 App. E — Training OSHA requirement may be more
Program must consist of classroom Curriculum Guidelines - (Non- restrictive than RCRA which allows
instruction or on-the-job training. mandatory) suggests that training on-the-job training.
should be conducted in a facility that
has sufficient resources, equipment,
and site locations to perform didactic
and hands-on training when
appropriate. OSHA does not address
using on-the-job training to meet the
requirements of initial training except
at 1910.120 (p)(7)(ii) which allows
employers who can show by an
employee’s previous work experience
or training that the employee has had
training equivalent to the initial
training.
264.16(a)(2) Training director-The 1910.120(p)(7)(iii) Trainers must have OSHA requirement meets or exceeds
program must be directed by a completed a training course for RCRA.
person trained in hazardous waste teaching the subjects they are
management procedures. expected to teach or they must have
the academic credentials and
instruction experience necessary to
demonstrate a good command of the
subject matter and competent
instructional skills.
264.16(a)(3) Program Design-The 1910.120(p)(7)(I) Training should OSHA requirement meets or exceeds
training program must be designed to enable employees to perform their RCRA.
ensure at a minimum that facility assigned duties in a safe and
personnel are able to respond healthful manner so as not to
effectively to emergencies. endanger themselves or other
employees.
264.16(c) Facility personnel must 1910.120(p) and 1910.120 App E — OSHA requirement more stringent
successfully complete the program Training Curriculum Guidelines (Non- than RCRA.
within six months of their assignment mandatory) Initial training should be
to a facility. provided prior to beginning work.
264.16(c) Facility personnel must 1910.120(p)(7) Refresher training is OSHA requirement is more stringent
take part in and annual review of the required annually. OSHA specifies 8 than RCRA.
training program. hr training.
9/14 Waste–93

Crosswalk Between OSHA and RCRA Training Requirements , Continued

264.16(a)(1) Employees Covered — 1910.120(p)(7) Employees Covered — Some employees may require
Training is required for Facility Only employees exposed to health training under RCRA but not under
personnel. hazards or hazardous substances. OSHA.
264.16(d) Training Records 1910.120 App. E — Training OSHA requirement is the same as
Maintenance — The owner/operator Curriculum Guidelines – (Non- RCRA.
must maintain documentation of mandatory) Records should be
training at the facility. maintained by the training provider.
264.16(e) Training Records Retention 1910.120 App. E — Training OSHA requirement is generally less
— Training records on current Curriculum Guidelines (Non- restrictive than RCRA.
personnel must be kept until facility mandatory) Training records should be
closure; records for former employees maintained for a minimum of five
must be kept for three years. years after an individual participated in
a training program.
264.16(d) Recordkeeping —The 1910.120 App. E — Training RCRA requires more detailed
owner/operator must maintain the Curriculum Guidelines (Non- recordkeeping than OSHA.
following: (1) The job title for each mandatory) Records should list the
position at the facility related to dates courses were presented, the
hazardous waste management, and names of attendees, names of those
the name of the employee filling each students successfully completing each
job; (2) A written job description for course, and the number of training
each position; (3) A description of the certificates issued to each successful
amount and type of both initial and student.
continuing training that will be given
to each person; (4) Documentation
that required training was provided to
appropriate facility personnel.
264.16 (a)(3) Training Course Initial Training Course Content 1910. OSHA allows employers who can
Content. 120(p)(7) and 1910.120 App. E — show by previous experience or
Training Curriculum Guidelines — training that employees have had
RCRAOperations Training for equivalent training do not need to
Treatment, Storage, and Disposal reaccomplish initial training.
Facilities and other OSHA regulations
as specified.

1. Elements of the RCRA 1. Emergency response plan (RCRA OSHA requirement is generally the
Contingency Plan. Contingency Plan is acceptable) same as RCRA.
including emergency alerting and
response procedures, emergency
equipment, pre-emergency planning
and review of emergency contingency
plans.
2. Communications or alarm 2. Emergency response plan OSHA requirement is generally the
Systems. including emergency alerting and same as RCRA.
response procedures.
3. Standard operating procedures for 3. Emergency response plan RCRA requires more detail than
using, inspecting, repairing and including emergency alerting and OSHA.
replacing facility emergency and response procedures, emergency
monitoring equipment. equipment, pre-emergency planning.
4. Key parameters for automatic 4. Not covered in training curriculum. RCRA requires more detail than
waste feed cut-off systems. OSHA.
5. Response to fires, explosions, 5. Emergency Response program OSHA requirement is generally the
groundwater contamination incidents, training; review of fire and explosion same as RCRA.
and shutdown of operations. hazards.
6. Chemical characteristics of wastes. 6. Review of chemical and biological OSHA requirement is generally the
hazards; principles of toxicology. same as RCRA.
94–Waste 9/14

7. Types and limitations of personal 7. Review and hands-on exercise OSHA requires more detail than
protective equipment. with personal protective equipment. RCRA.
Annual refresher training for
respirator wearers is required.
8. Proper operation of industrial 8. Forklift and industrial truck driver OSHA requires more detail than
trucks and other machinery. training program (1910.178(l). RCRA.
9. Basic first aid. 9. Emergency response plan and OSHA requirement is generally the
procedures including first aid. same as RCRA.
9/14 Waste–95

Reserved
96–Waste 9/14

COMMUNITY RIGHT TO KNOW
CONTENTS
Overview ......................................................................................................... 1
Unique aspects of EPCRA .................................................................................... 2
EPCRA organization ..................................................................................... 2
SARA Title III and its purpose ........................................................................ 3
Section 301–303: Emergency planning .............................................................. 3
Emergency response plans ............................................................................. 4
Section 304: emergency notification .................................................................. 4
Section 311–312: Community Right to Know requirements .................................... 6
Section 313: Toxic chemical release reporting and EPA’s Toxics Release Inventory (TRI). 8
Form R...................................................................................................... 9
Electronic reporting .................................................................................... 10
Supplier notification requirements.................................................................. 10
Which chemicals are covered?........................................................................ 12
Chemical qualifiers ..................................................................................... 13
Addition of National Toxicology Program carcinogens .......................................... 15
Minimum threshold levels for reporting ........................................................... 16
Manufacturing and processing uses ................................................................ 17
De minimis concentrations ........................................................................... 18
Data quality.............................................................................................. 19
Recordkeeping ........................................................................................... 20
Addressing terrorist activities in local emergency plans ....................................... 21
Build on current activities ............................................................................ 21
Maintain broad-based membership ................................................................. 21
Update and revise your plans ........................................................................ 22
Release notification under CERCLA and EPCRA ............................................... 27
Reporting procedures .................................................................................. 36
Special issues ............................................................................................ 39
Disposal at RCRA facilities ........................................................................... 42
Substances that change after release .............................................................. 43
Release reporting summary .......................................................................... 44
EPCRA inspection checklist .......................................................................... 44
3/13 Community right to know TOC–1

Reserved
2–Community right to know TOC 3/13

Overview
When Congress amended the Comprehensive Environmental Response, Compensation and
Liability Act (CERCLA) by passing the Superfund Amendments and Reauthorization Act
(SARA), Title III of SARA also authorized the Emergency Planning and Community Right To
Know Act (EPCRA).
This law is based on the premise that citizens have a right to know about chemicals in their
communities. EPCRA has two main purposes: to encourage planning for responses to acci-
dents, and to provide the public and the government with information about possible
chemical hazards in communities.
There are four major provisions of EPCRA:

1. Emergency Planning (Sections 301-303)
2. Emergency Release Notification (Section 304)
3. Hazardous Chemical Storage Reporting (Sections 311-312)
4. Toxic Chemical Release Inventory (Section 313)
The basic requirements of EPCRA are as follows:
• Facility owners/operators that have on their premises chemicals designated under
EPCRA as “extremely hazardous substances” must cooperate with state and local
planning officials in preparing comprehensive emergency plans (Sections 302 and
303);
• Facility owners/operators must report accidental releases of “extremely hazardous
substances” and CERCLA “hazardous substances” to state and local response offi-
cials (Section 304); and
• Facility owners/operators must make Safety Data Sheets (SDSs) available to local
and state officials and must also report, to local and state officials, inventories
(including locations) of chemicals on their premises for which SDSs exist (Sections
311 and 312).
9/12 Community right to know–1

• Toxic chemical release reporting under Section 313 pertains to release and other
waste management reporting. Certain businesses are required to submit reports
each year on the amounts of EPCRA section 313 chemicals their facilities released
into the environment (either routinely or as a result of accidents), or otherwise man-
aged as waste. Section 313 requires facilities to report for each listed chemical the
amount released to air, water, land, underground injection and transferred off-site to
disposal. Facilities also must report the amounts of those EPCRA section 313 chemi-
cals otherwise managed as waste, including on-site treatment, combustion for
energy recovery, recycling and transfers off-site for treatment, combustion for energy
recovery and recycling.
Unique aspects of EPCRA

SARA Title III is significantly different from any other environmental laws, such as the
Clean Air Act, and the Clean Water Act, which set regulatory standards to control the activi-
ties of a specified regulated community. These statutes are restrictive, requiring regulated
facilities to refrain from certain activities, to perform other activities, and to punish non-
compliance under extensive enforcement provisions.
Title III uses a different regulatory model because its goals are different. The statute’s intent
is to provide information about chemicals to the government and the community,
and only requires regulated facilities to submit information to the government, with punitive
measures for non-compliance.
EPCRA organization
The two aspects of EPCRA are implemented by different offices within EPA. The Chemical
Emergency Preparedness and Prevention Office (CEPPO) carries out the emergency plan-
ning, emergency response notification, and inventory reporting provisions of the law. The
Office of Pollution Prevention and Toxics (OPPT) implements the Toxic Release Inventory
(TRI) aspects of EPCRA. Responsibility for the four main elements of the EPCRA program is
apportioned within EPA as follows:
CEPPO: Emergency Planning §302; Emergency Release Notification §304; and Hazardous
Chemical Inventory Reporting §311, and 312.
OPPT: TRI Reporting §313.
CEPPO is part of the Office of Solid Waste and Emergency Response. Its mission is to help
local and state authorities assemble the necessary chemical information for chemical emer-
gency prevention, preparedness, and response activities. OPPT is within the Office of
Prevention, Pesticides, and Toxic Substances. The branches of OPPT that are primarily asso-
ciated with the Hotline are the Toxics Release Inventory Branch (TRIB), and the TRI
Information Management Branch (TRI-IMB). Both CEPPO and OPPT administer right-to-
know components of the program.
2–Community right to know 9/12

SARA Title III and its purpose

SARA Title III created a program with two goals: 1) to facilitate and promote planning for
chemical emergencies at the state and local levels; and 2) to provide information to the pub-
lic about the chemicals used, stored, and released in their communities. To implement these
two goals, EPCRA established a network of entities at the local, state, and federal level, and
set requirements for gathering the needed information.
Together, Title III creates a working partnership, consisting of industry and small business,
state and local government officials, public health and emergency response representatives,
and other interested citizens. Through this interaction and information sharing, a safer com-
munity can result. Indeed, all parties share the responsibility for Title III, and everyone will
benefit.
Section 301–303: Emergency planning

The emergency planning sections are designed to develop state and local governments’ emer-
gency response and preparedness capabilities through better coordination and planning,
especially within the local community. The purpose of emergency planning is to ensure State
and local communities are prepared to respond to potential chemical accidents.
State emergency response commission

The Emergency Planning and Community Right To Know Act required the Governor of each
state to designate a State Emergency Response Commission (SERC). Many SERCs include
public agencies and departments concerned with issues relating to environment, natural
resources, emergency services, public health, occupational safety, and transportation. Also,
interested public and private sector groups and associations with experience in emergency
planning and Community Right To Know issues may be included in the state commission. At
this time, all states have established SERCs.
Local emergency planning committee

Each SERC, in turn, has designated local emergency planning districts. The Local Emer-
gency Planning Committee (LEPC) must include, at a minimum, elected state and local
officials, police, fire, civil defense, public health professionals, environmental, hospital, and
transportation officials as well as representatives of facilities subject to the emergency plan-
ning requirements, community groups, and the media. As soon as facilities are subject to the
emergency planning requirements, they must designate a representative to participate in
the planning process.
The LEPC must, in turn, develop an emergency response plan for its district and review it
annually. The membership of the LEPC includes representatives of public and private orga-
nizations, as well as a representative from every facility subject to EPCRA emergency
planning requirements.
Threshold planning quantity (TPQ)

Determining if a facility is subject to the EPCRA emergency planning requirements is
straightforward. The Environmental Protection Agency (EPA) published a list of “extremely
hazardous substances (EHS).” For each EHS, the list includes the name and chemical
abstract service number of the substance, and a number called a threshold planning quan-
tity (TPQ).

The TPQ, expressed in pounds, is the critical number. If a facility has within its boundaries
an amount of an extremely hazardous substance equal to or in excess of its threshold plan-
ning quantity, the facility is subject to the EPCRA emergency planning requirements, and
must notify both the SERC and the LEPC of this fact. The facility must also appoint an
emergency response coordinator who will work with the LEPC on developing and imple-
menting the local emergency plan at the facility.
The list of extremely hazardous substances and their threshold planning quantities are
found at 40 CFR Part 355, Appendix A and Appendix B.
Emergency response plans

Required elements in a community emergency response plan include:
• Identification of facilities and transportation routes of extremely hazardous
substances
• Description of emergency response procedures, on and off site
• Designation of a community coordinator and facility emergency coordinator(s) to
implement the plan
• Outline of emergency notification procedures
• Description of how to determine the probable affected area and population by
releases
• Description of local emergency equipment and facilities and the persons responsible
for them
• Outline of evacuation plans
• A training program for emergency responders (including schedules)
• Methods and schedules for exercising emergency response plans
Section 304: emergency notification

Facilities must immediately notify the LEPCs and the SERCs likely to be affected if there is
a release into the environment of a hazardous substance that exceeds the reportable quan-
tity (RQ) for that substance.
Emergency notification provides the criteria under which a facility must report the acciden-
tal release of certain substances to the environment. A facility may be subject to these
reporting requirements even if it is not subject to the provisions of §301 to §303. This section
applies to any facility that:
• stores, produces or uses a “hazardous chemical” (any chemical which is a physical
hazard or a health hazard); and
• releases a reportable quantity of a substance contained in either of the following two
tables published by EPA in the Code of Federal Regulations:
1. List of extremely hazardous substances; or
2. List of CERCLA hazardous substances.

The RQ is a number, expressed in pounds, assigned to each chemical in the above-mentioned

tables. If the amount of a chemical released to the environment exceeds the reportable quan-
tity, the facility must immediately report the release to the appropriate LEPC and SERC
and provide a written follow-up as soon as practicable.
A release is defined as any spilling, leaking, pumping, pouring, emptying, discharging, or
disposing into the environment. This includes the abandonment or discarding of barrels or
other closed receptacles. Any release that results in exposure to persons solely within the
boundaries of a facility does not require notification under this regulation.
Requirements for immediate notification

Immediate notification must be made to 1) the community emergency coordinator of the
local committee, and 2) the State commission for any area that may be affected by the
release. This notification should be oral (via telephone, radio, or in person).
This notification should include:
• Chemical name or identity of substance released;
• Whether the substance is an Extremely Hazardous Substance;
• Estimate of the quantity released;
• Time and duration of the release;
• Media into which the release occurred;
• Any known or anticipated acute or chronic health risks;
• Medical advice for exposed individuals, where appropriate;
• Precautions to take and evacuation procedures; and
• Names and telephone numbers of a contact person.
Section 304 also requires that, as soon as possible, a written follow-up notice should be
submitted. Included in this written notice should be additional information with respect to:
• Actions taken to respond to and contain the release;
• Any known or anticipated acute or chronic health risks; and
• Medical advice for exposed individuals, where appropriate.
For a transportation-related release, the owner/operator of a facility can provide the emer-
gency notification information to the 911 operator. “Transportation-related release” means a
release during transportation or storage, when the substance is moving under active ship-
ping papers, and has not reached the final consignee.
CERCLA releases — If an RQ of any hazardous substance is released in a 24-hour period,
immediately notify the National Response Center (800) 424-8802; in Washington D.C. (202)
426-2675. (See §302.6)

Section 311–312: Community Right to Know requirements

There are two Community Right To Know reporting requirements within the Emergency
Planning and Community Right To Know Act: Section 311 and Section 312. Section 311
requires facilities that must prepare Safety Data Sheets (SDSs) (formerly MSDSs) under the
Occupational Safety and Health Administration (OSHA) regulations to submit either copies
of their SDSs or a list of SDS chemicals to:
• The LEPC,
• The SERC, and
• The local fire department with jurisdiction over the facility.
What facilities are covered?

Note: Reporting thresholds are codified in 40 CFR 370.10.
Any facility required under OSHA regulations to maintain material safety data sheets
(MSDSs) (or Safety data sheets (SDSs) for hazardous chemicals stored or used in the work
place. Facilities with chemicals in quantities that equal or exceed the following thresholds
must report:
• For Extremely Hazardous Substances (EHSs) , either 500 pounds or the Threshold
Planning Quantity (TPQ), whichever is lower.
• For gasoline (all grades combined) at a retail gas station, the threshold level is
75,000 gallons (or approximately 283,900 liters), if the tank(s) was stored entirely
underground and was in compliance at all times during the preceding calendar year
with all applicable Underground Storage Tank (UST) requirements at 40 CFR part
280 or requirements of the State UST program approved by the Agency under 40
CFR part 281.
• For diesel fuel (all grades combined) at a retail gas station, the threshold level is
100,000 gallons (or approximately 378,500 liters), if the tank(s) was stored entirely
underground and the tank(s) was in compliance at all times during the preceding
calendar year with all applicable Underground Storage Tank (UST) requirements at
40 CFR part 280 or requirements of the State UST program approved by the Agency
under 40 CFR part 281.
• For all other hazardous chemicals, 10,000 pounds
If a facility is subject to reporting under these sections, it must submit information to the
SERC, the LEPC, and the local fire department with jurisdiction over the facility under two
categories:
• SDS reporting; and
• inventory reporting.
What is a hazardous chemical?

Hazardous chemicals are any substances for which a facility must maintain an MSDS,
which lists the criteria used to identify a hazardous chemical. MSDSs are detailed informa-
tion sheets that provide data on health hazards and physical hazards of chemicals along
with associated protective measures. Over 500,000 products have MSDSs which are nor-
mally obtained from the chemical manufacturer.

What are facilities required to do?

1. Under the Emergency Planning and Community Right-to-Know Act (EPCRA) Sec-
tion 311, facilities must submit the same MSDSs they maintain for OSHA to their
SERC, LEPC, and local fire department. Or, facilities may choose to submit a
detailed list of the same chemicals instead. This is a one-time submittal; facili-
ties have three months after becoming subject to the OSHA regulations to submit
their material.
2. Facilities that need to submit MSDSs or chemical lists under Section 311, also need
to submit an annual inventory report for the same chemicals (EPCRA Section 312).
This inventory report must be submitted to the SERC, LEPC and local fire depart-
ment by March 1 of each year.
Changes to OSHA’s HazCom standard and GHS

OSHA’s March 26, 2012, revision of the Hazard Communication Standard and adoption of
the Globally Harmonized System of Classification and Labeling of Chemicals (GHS) will
affect Sections 311 and 312 of EPCRA. However, questions remain on whether changes made
to an MSDS (SDS) because of the rule change and not because of a change in chemicals or
chemical properties, will be considered ″significant new information″ by EPA.) EPA pub-
lished a fact sheet explaining some of the changes here: www.epa.gov/oem/content/epcra/
index.htm.
Section 312 Tier I/Tier II chemical inventory reporting

Under EPCRA Section 312, if a facility has hazardous chemicals at or above the reporting
threshold specified at 40 CFR Part 370, the facility owner or operator is required to submit
an emergency and hazardous chemical inventory form (Tier I or Tier II) to the State Emer-
gency Response Commission (SERC), the local emergency planning committee (LEPC), and
the local fire department by March 1 each year. The Tier I reporting form requires facilities
to report on the general types and locations of hazardous chemicals present at the facility.
The Tier II inventory form requires facilities to report specific information on the amounts
and locations of hazardous chemicals present at the facility. Currently, all states require
facilities to submit the federal Tier II inventory form or a state equivalent form.
Tier I /Tier II reporting forms

On July 13, 2012, EPA published a final rule to revise Tier I and Tier II reporting
forms. The revisions add some new data elements and revise some existing data
elements. The rule became effective on January 1, 2014. Facilities must comply
with the new requirements on the Tier II inventory form starting with reporting
year 2013, which is due by March 1, 2014, and every year thereafter. Some states
may have specific reporting requirements for reporting and submitting the Tier II inventory
form and/or the state reporting form or format. EPA suggests that facilities contact their
state for reporting requirements for their state. (See State agency contacts in this book.)
Access the reporting forms, instructions, state reporting requirements and proce-
dures, and other information at www.epa.gov/oem/content/epcra/tier2.htm.
Tier2 Submit Software

EPA encourages facilities to prepare and submit Tier I and Tier II reporting forms
electronically. You can find out more about EPA’s Tier2 submit software, which is also
accepted by many states, at www.epa.gov/oem/content/epcra/tier2.htm.

Section 313: Toxic chemical release reporting and EPA’s Toxics Release Inventory
(TRI)
Through EPCRA, Congress mandated that a Toxics Release Inventory, (TRI) be made public.
TRI provides a database of accurate information about potentially hazardous chemicals and
their use in communities.
Section 313 of EPCRA specifically requires manufacturers to report releases of more than
600 designated chemicals to the environment. The reports are submitted to EPA and state
governments and EPA compiles the data.
TRI facilities are required to report releases of toxic chemicals into the air, water, and land.
In addition, they need to report off-site transfers — a transfer of wastes for treatment or dis-
posal at a separate facility. Facilities are also required to report pollution prevention
activities and chemical reporting. Reports must be submitted on or before July 1 each year
and must cover activities that occurred at the facility during the previous year.
Who must report?

Section 313 reports must be filed by owners and operators of facilities that meet all of the
following criteria:
• The facility has 10 or more full-time employees or employee equivalents (i.e. a total
of 20,000 hours or greater; see 40 CFR 372.3); and
• The facility is included in a covered Standard Industrial Classification (SIC) code;
and
• The facility manufactures (defined to include importing), processes, or otherwise
uses an EPCRA Section 313 chemical in quantities greater than the established
threshold in the course of a calendar year.
You must submit a report for any EPCRA section 313 chemical, which is not listed as a per-
sistent bioaccumulative toxic (PBT) chemical, that is otherwise used at your facility in
excess of 25,000 pounds for manufacturing and processing, and 10,000 pounds for any other
uses.
You must submit a report for any EPCRA section 313 chemical, which is listed as a PBT
chemical that is manufactured, processed, or otherwise used at your facility above the desig-
nated threshold for that chemical. Names of PBT chemicals, CAS Registry numbers,
category codes for chemical categories, and reporting thresholds are listed in 40 CFR 372.
PBT chemicals have lower thresholds than other TRI chemicals.
Additionally, EPA has established an alternate threshold [40 CFR 372.27] for those facilities
with low annual reportable amounts of a listed chemical. If a facility meets the current Sec-
tion 313 reporting thresholds, but estimates that the total annual reportable amount of the
chemical does not exceed 500 pounds per year, it can apply a threshold of 1 million pounds
per year, provided that certain conditions are met.
Executive Order 13423 extends these reporting requirements to federal facilities, regardless
of their SIC or NAICS codes.

Form R
The Toxic Chemical Release Inventory Form is better known as Form R. Industries are
required to report on Form R. hazardous substances they have in plant and to provide safety
and health information related to these substances. This data is intended to help communi-
ties focus on the substances and facilities of the most immediate concern for emergency
planning and response. Facilities are required to submit a Form R to EPA by July 1
each year.
EPCRA section 313 reporting is required if threshold quantities are exceeded. Separate
thresholds apply to the amount of the EPCRA section 313 chemical that is manufactured,
processed or otherwise used.
You must submit a report for any EPCRA section 313 chemical, which is not listed as a PBT
chemical, that is manufactured or processed at your facility in excess of the following thresh-
old:
• 25,000 pounds per EPCRA section 313 chemical or category over the calendar year.
You must submit a report for any EPCRA section 313 chemical, which is not listed as a PBT
chemical, that is otherwise used at your facility in excess of the following threshold:
• 10,000 pounds per EPCRA section 313 chemical or category over the calendar year.
You must submit a report for any EPCRA section 313 chemical, which is listed as a PBT
chemical that is manufactured, processed, or otherwise used at your facility above the desig-
nated threshold for that chemical. Names of PBT chemicals, CAS Registry numbers,
category codes for chemical categories, and reporting thresholds are listed in 40 CFR 372.
Form R consists of two parts:

❏ Part I, Facility identification information; and
❏ Part II, Chemical-specific information.
Alternate Form A
Form A is based on an alternate threshold for facilities with small quantities of an EPCRA
section 313 chemical released or otherwise managed as waste. Form A serves to certify that
a facility is not subject to Form R reporting for a specific toxic chemical. Like the Form R
described above, the Form A consists of two parts, but only consists of a total of two pages.
❏ Part I, Facility Identification Information, which also includes the “certification”
regarding the eligibility to use the Form A (page 1); and
❏ Part II, Chemical Identification (page 2).
Since 1998, the Form A may be used to report multiple chemicals. Four chemicals may be
reported on page 2 of the form. If more than four chemicals are to be reported, additional
copies of page 2 can be used to report qualifying chemicals. The Form A must have an origi-
nal certification statement on page 1 and contain an appropriate trade secret designation for
the form. A complete report for Form A consists of at least two pages for each submission.

Electronic reporting
On August 27, 2013, EPA published a rule requiring electronic TRI reporting. Facili-
ties must use EPA’s online reporting application, the TRI-MEweb to report all non-trade-
secret TRI information. Find all online TRI forms at www.epa.gov/tri. First-time users must
register for EPA’s CDX software and add the TRI-MEweb at cdx.epa.gov. This registration
requires the printing, completion, and mailing of an electronic signature agreement.
Further, chemical reporters must use the TRI-MEweb application to file reports.
If you have reported in previous years, EPA will send a facility access key for you to load
your facility data onto TRI-MEweb.
The application can be accessed anywhere you have an Internet connection and assists users
in filling out the Form R or alternate Form A.
To codify the rule, EPA is adding paragraph (c) to 40 CFR 372.85 to require electronic
reporting of TRI information. The agency is also revising §372.85(b) to remove a mention of
magnetic media. The final rule is effective on January 21, 2014.
Supplier notification requirements

Facilities are covered under Subpart C (Supplier Notification Requirements) of this part if
they meet the following criteria:
• Your facility is in a North American Industry Classification System(NAICS) code
that corresponds to Standard Industrial Classification [SIC] codes 20- 39;
• Manufacture, import, or process an EPCRA Section 313 chemical; and
• Sell or otherwise distribute a mixture or other trade name product containing the
EPCRA Section 313 chemical to either:
❍ A facility in a covered NAICS code.
❍ A person that then may sell the same mixture or other trade name product to a
firm in a covered NAICS code.
Note that you may be covered by the supplier notification rules even if
you are not covered by the Section 313 release reporting requirements.
For example, even if you have fewer than 10 full-time employees or do not
manufacture or process any of the EPCRA Section 313 chemicals in sufficient
quantities to trigger the release and other waste management reporting
requirements, you may still be required to notify certain customers.


Which chemicals are covered?

The initial list of “Toxic Chemicals Covered” contained 329 entries, including 20 categories of
chemicals. Numerous additions and deletions have occurred since then. This list can be
found in the regulations at 40 CFR Section 372.65.
EPA makes changes to the TRI chemical list through EPA-initiated review and through the
chemical petitions process. As a result, the TRI list of reportable toxic chemicals can vary
from year to year. Refer to EPA’s webpage listing covered chemicals at www2.epa.gov/toxics-
release-inventory-tri-program/tri-listed-chemicals.
Certain chemicals listed have parenthetic “qualifiers.” These qualifiers indicate that these
chemicals are subject to the Section 313 reporting requirements if manufactured, processed,
or otherwise used in a specific form or when a certain activity is performed. The following
chemicals are reportable only if they are manufactured, processed, or otherwise used in a
specific form(s) listed below:
Chemical CAS Number Qualifier
Aluminum (fume or dust) 7429-90-5 Only if it is in a fume or dust form.
Aluminum oxide (fibrous forms) 1344-28-1 Only if it is a fibrous form.
Ammonium (includes anhydrous ammonia and 7664-41-7 Only 10 percent of aqueous forms. 100
aqueous ammonia from water dissociable ammonium percent of anhydrous forms.
salts and other sources: 10 percent of total aqueous
ammonia is reportable under this listing)
Asbestos (friable) 1332-21-4 Only if it is a friable form.
Hydrochloric acid (acid aerosols including mists, 7647-01-0 Only if it is an aerosol form as defined.
vapors, gas, fog, and other airborne forms of any
particle size)
Phosphorus (yellow or white) 7723-14-0 Only if it is a yellow or white form.
Sulfuric acid (acid aerosols including mists, vapors, 7664-93-9 Only if it is an aerosol form as defined.
gas, fog, and other airborne forms of any particle size)
Vanadium (except when contained in an alloy) 7440-62-2 Except if it is contained in an alloy.
Zinc (fume or dust) 7440-66-6 Only if it is in a fume or dust form.
The qualifier for the following chemicals is based on the chemical activity rather than the
form of the chemical. These chemicals are subject to EPCRA Section 313 reporting require-
ments only when the indicated activity is performed.
Chemical CAS Number Qualifier
Dioxin and dioxin-like compounds (manufacturing; NA Only if they are manufactured at the
and the processing or otherwise use of dioxin and facility; or are processed or otherwise
dioxin-like compounds if the dioxin and dioxin-like used when present as contaminants in a
compounds are present as contaminants in a chemical chemical but only if they were created
and if they were created during the manufacture of that during the manufacture of that chemical.
chemical.)
Isopropyl alcohol (only persons who manufacture by 67-63-0 Onlyif it is being manufactured by the
the strong acid process are subject, no supplier strong acid process. Facilities that
notification) process or otherwise use isopropyl
alcohol are not covered and should not
file a report.
Saccharin (only persons who manufacture are subject, 81-07-2 Only if it is being manufactured.
no supplier notification)

Chemical qualifiers
Some of the EPCRA Section 313 chemicals listed have parenthetic qualifiers listed next to
them. An EPCRA Section 313 chemical that is listed without a qualifier is subject to report-
ing in all forms in which it is manufactured, processed, and otherwise used.
Fume or dust. Two of the metals on the list (aluminum and zinc) contain the qualifier
“fume or dust.” Fume or dust refers to dry forms of these metals but does not refer to “wet”
forms such as solutions or slurries. The term manufacture includes the generation of an
EPCRA Section 313 chemical as a byproduct or impurity. In such cases, a facility should
determine if, for example, it generated more than 25,000 pounds of aluminum fume or dust
in the reporting year as a result of its activities. If so, the facility must report that it manu-
factures “aluminum (fume or dust).” Similarly, there may be certain technologies in which
one of these metals is processed in the form of a fume or dust to make other EPCRA Section
313 chemicals or other products for distribution in commerce. In reporting releases, the facil-
ity would only report releases of the fume or dust.
EPA considers dusts to consist of solid particles generated by any mechanical processing of
materials including crushing, grinding, rapid impact, handling, detonation, and decrepita-
tion of organic and inorganic materials such as rock, ore, and metal. Dusts do not tend to
flocculate, except under electrostatic forces.
EPA considers a fume to be an airborne dispersion consisting of small solid particles created
by condensation from a gaseous state, in distinction to a gas or vapor. Fumes arise from the
heating of solids such as lead. The condensation is often accompanied by a chemical reac-
tion, such as oxidation. Fumes flocculate and sometimes coalesce.
Manufacturing qualifiers. Two of the entries in the EPCRA Section 313 chemical list con-
tain a qualifier relating to manufacture. For isopropyl alcohol, the qualifier is “only persons
who manufacture by the strong acid process are subject, no supplier notification.” For sac-
charin, the qualifier is “only persons who manufacture are subject, no supplier notification.”
For isopropyl alcohol, the qualifier means that only facilities manufacturing isopropyl alco-
hol by the strong acid process are required to report. In the case of saccharin, only
manufacturers of the EPCRA Section 313 chemical are subject to the reporting
requirements. A facility that only processes or otherwise uses either of these EPCRA Section
313 chemicals would not be required to report for these EPCRA Section 313 chemicals. In
both cases, supplier notification does not apply because only manufacturers, not users, of
these two EPCRA Section 313 chemicals must report.
Ammonia (includes anhydrous ammonia and aqueous ammonia from water
dissociable ammonium salts and other sources; 10 percent of total aqueous ammo-
nia is reportable under this listing). The qualifier for ammonia means that anhydrous
forms of ammonia are 100% reportable and aqueous forms are limited to 10% of total aque-
ous ammonia. Therefore when determining threshold and releases and other waste
management quantities all anhydrous ammonia is included but only 10% of total aqueous
ammonia is included. Any evaporation of ammonia from aqueous ammonia solutions is con-
sidered anhydrous ammonia and should be included in threshold determinations and release
and other waste management calculations.

Sulfuric acid and Hydrochloric acid (acid aerosols including mists, vapors, gas,
fog, and other airborne forms of any particle size). The qualifier for sulfuric acid and
hydrochloric acid means that the only forms of these chemicals that are reportable are air-
borne forms. Aqueous solutions are not covered by this listing but any aerosols generated
from aqueous solutions are covered.
Nitrate compounds (water dissociable; reportable only when in aqueous solution).
The qualifier for the nitrate compounds category limits the reporting to nitrate compounds
that dissociate in water, generating nitrate ion. For the purposes of threshold determina-
tions the entire weight of the nitrate compound must be included in all calculations. For the
purposes of reporting releases and other waste management quantities only the weight of
the nitrate ion should be included in the calculations of these quantities.
Phosphorus (yellow or white). The listing for phosphorus is qualified by the term “yellow
or white.” This means that only manufacturing, processing, or otherwise use of phosphorus
in the yellow or white chemical form triggers reporting. Conversely, manufacturing, process-
ing, or otherwise use of “black” or “red” phosphorus does not trigger reporting. Supplier
notification also applies only to distribution of yellow or white phosphorus.
Asbestos (friable). The listing for asbestos is qualified by the term “friable,” referring to
the physical characteristic of being able to be crumbled, pulverized, or reducible to a powder
with hand pressure. Only manufacturing, processing, or otherwise use of asbestos in the fri-
able form triggers reporting. Supplier notification applies only to distribution of mixtures or
other trade name products containing friable asbestos.
Aluminum Oxide (fibrous forms). The listing for aluminum oxide is qualified by the term
“fibrous forms.” Fibrous refers to a man-made form of aluminum oxide that is processed to
produce strands or filaments which can be cut to various lengths depending on the
application. Only manufacturing, processing, or otherwise use of aluminum oxide in the
fibrous form triggers reporting. Supplier notification applies only to distribution of mixtures
or other trade name products containing fibrous forms of aluminum oxide.

Addition of National Toxicology Program carcinogens

On November 26, 2010, EPA finalized a rule to provide communities with additional infor-
mation about toxic chemicals being released into the environment. The rule adds 16
chemicals to the TRI list of reportable chemicals. This action is part of EPA’s ongoing efforts
to examine the scope of TRI chemical coverage and provide more complete information on
toxic chemical releases. Facilities will be required to report on the 16 new chemicals in 2012.
Each chemical that EPA is adding has been classified as “reasonably anticipated to be a
human carcinogen” by the National Toxicology Program (NTP) in their Report on
Carcinogens. EPA has concluded, based on a review of available studies, that these 16
chemicals could cause cancer in humans and therefore must meet the EPCRA Section
313(d)(2)(B) statutory listing criteria.
Four the chemicals are being added to TRI under the polcyclic aromatic compounds (PACs)
category. The PACs category is of special concern because PACs are persistent,
bioaccumulative, toxic (PBT) chemicals, and as such, they are likely to remain in the envi-
ronment for a very long time, are not easily destroyed, and may build up or accumulate in
the body.
What chemicals are included in the final rule?
Individual listings
Chemical name CAS#
1-Amino-2,4-dibromoanthraquinone 81-49-2
2,2-bis(Bromomethyl)-1,3-propanediol 3296-90-0
Furan 110-00-9
Glycidol 556-52-5
Isoprene 78-79-5
Methyleugenol 93-15-2
o-Nitroanisole 91-23-6
Nitromethane 75-52-5
Phenolphthalein 77-09-8
Tetrafluoroethylene 116-14-3
Tetranitromethane 509-14-8
Vinyl Fluoride 75-02-5
Polycyclic Aromatic Compounds (PACs) category
1,6-Dinitropyrene 42397-64-8
1,8-Dinitropyrene 42397-65-9
6-Nitrochrysene 7496-02-8
4-Nitropyrene 57835-92-4

Minimum threshold levels for reporting

EPCRA Section 313 reporting is required if threshold quantities are exceeded. Separate
thresholds apply to the amount of the EPCRA Section 313 chemical that is manufactured,
processed or otherwise used.
You must submit a report for any EPCRA Section 313 chemical, which is not listed as a PBT
chemical, that is manufactured or processed at your facility in excess of the following thresh-
old:

❏ 25,000 pounds per toxic chemical or category over the calendar year.
You must submit a report for any EPCRA Section 313 chemical, which is not listed as a PBT
chemical, that is otherwise used at your facility in excess of the following threshold:
❏ 10,000 pounds per toxic chemical or category over the calendar year.
Manufacturing and processing uses

The term “manufacture” means to produce, prepare, compound, or import an EPCRA Sec-
tion 313 chemical.
Import is defined as causing the EPCRA Section 313 chemical to be imported into the cus-
toms territory of the United States. If you order an EPCRA Section 313 chemical (or a
mixture containing the chemical) from a foreign supplier, then you have imported the chemi-
cal when that shipment arrives at your facility directly from a source outside of the United
States. By ordering the chemical, you have “caused it to be imported,” even though you may
have used an import brokerage firm as an agent to obtain the EPCRA Section 313 chemical.
Do not overlook coincidental manufacture. The term manufacture also includes coinci-
dental production of an EPCRA Section 313 chemical (e.g., as a byproduct or impurity) as a
result of the manufacture, processing, otherwise use, treatment, disposal or other waste
management of other chemical substances. In the case of coincidental production of an impu-
rity (i.e., an EPCRA Section 313 chemical that remains in the product that is distributed in
commerce), the de minimis exemption applies. The de minimis exemption does not apply to
byproducts (e.g., an EPCRA Section 313 chemical that is separated from a process stream
and further processed or disposed). Certain EPCRA Section 313 chemicals may be manufac-
tured as a result of wastewater treatment or other treatment processes. For example,
neutralization of wastewater containing nitric acid can result in the coincidental manufac-
ture of a nitrate compound (solution), reportable as a member of the nitrate compounds
category.
The term “process” means the preparation of a listed Section 313 chemical, after its manu-
facture, for distribution in commerce. Processing is usually the intentional incorporation of a
Section 313 chemical into a product. Processing includes preparation of the EPCRA Section
313 chemicals in the same physical state or chemical form as that received by your facility,
or preparation that produces a change in physical state or chemical form. The term also
applies to the processing of a mixture or other trade name product that contains a listed
Section 313 chemical as one component.
The term “otherwise use” usually means any use of an EPCRA Section 313 chemical,
including an EPCRA Section 313 chemical contained in a mixture or other trade name prod-
uct or waste, that is not covered by the terms “manufacture” or “process.” Otherwise use of
an EPCRA Section 313 chemical does not include disposal, stabilization (without subsequent
distribution in commerce), or treatment for destruction unless:
1. The EPCRA Section 313 chemical that was disposed, stabilized, or treated for
destruction was received from off-site for the purposes of further waste manage-
ment; or
2. The EPCRA Section 313 chemical that was disposed, stabilized, or treated for
destruction was manufactured as a result of waste management activities on mate-
rials received from off-site for the purposes of waste management activities.

Relabeling or redistributing of the EPCRA Section 313 chemical where no repackag-

ing of the EPCRA Section 313 chemical occurs does not constitute an otherwise use
or processing of the EPCRA Section 313 chemical. (See 62 FR 23846 for further
clarification.)
De minimis concentrations
De Minimis Exemption. The de minimis exemption allows facilities to disregard certain
minimal concentrations of non-PBT chemicals in mixtures or other trade name products
they process or otherwise use when making threshold determinations and release and other
waste management calculations. The de minimis exemption does not apply to the manufac-
ture of an EPCRA Section 313 chemical except if that EPCRA Section 313 chemical is
manufactured as an impurity and remains in the product distributed in commerce, or if the
EPCRA Section 313 chemical is imported

ENVIRONMENTAL COMPLIANCE MANUAL
below the appropriate de minimis level. The de minimis exemption does not apply to a byproduct
manufactured coincidentally as a result of manufacturing, processing, otherwise use, or any waste
management activities. The de minimis exemption does not apply to any PBT chemical (except lead
when it is contained in stainless steel, brass or bronze alloy) or PBT chemical category.
When determining whether the de minimis exemption applies to an EPCRA Section 313 chemical,
the owner/operator should consider only the concentration of the non-PBT EPCRA Section 313
chemical in mixtures and other trade name products in process streams in which the EPCRA Sec-
tion 313 chemical is undergoing a threshold activity. If the non-PBT EPCRA Section 313 chemical
in a process stream is manufactured as an impurity, imported, processed, or otherwise used and is
below the appropriate de minimis concentration level, then the quantity of the non-PBT EPCRA
Section 313 chemical in that process stream does not have to be applied to threshold determinations
nor included in release or other waste management determinations. If a non-PBT EPCRA Section
313 chemical in a process stream is below the appropriate de minimis level, all releases and other
waste management activities associated with the EPCRA Section 313 chemical in that stream are
exempt from EPCRA Section 313 reporting. It is possible to meet an activity (e.g., processing)
threshold for an EPCRA Section 313 chemical on a facility-wide basis, but not be required to
calculate releases or other waste management quantities associated with a particular process
because that process involves only mixtures or other trade name products containing the non-PBT
EPCRA Section 313 chemical below the de minimis level.
Once a non-PBT EPCRA Section 313 chemical concentration is at or above the appropriate de
minimis level in the mixture or other trade name product, threshold determinations and release and
other waste management calculations must be made, even if that chemical later falls below the de
minimis level in the same mixture or other trade name product. Thus, all releases and other quan-
tities managed as waste that occur after the de minimis level has been met or exceeded are subject
to reporting. If an EPCRA Section 313 chemical in a mixture or other trade name product at or above
de minimis is brought on-site, the de minimis exemption never applies.
De minimis levels for non-PBT EPCRA Section 313 chemicals and chemical categories are set at
concentration levels of either at 1 percent or 0.1 percent; PBT chemicals and chemical categories
do not have de minimis levels with regard to this exemption. The 0.1 percent de minimis levels are
dictated by determinations made by the National Toxicology Program (NTP), Annual Report on
Carcinogens, the International Agency for Research and Cancer (IARC) Monographs, or 29 CFR
part 1910, subpart Z. Therefore, once a non-PBT chemical’s status under NTP, IARC, or 29 CFR
part 1910, subpart Z indicates that the chemical is a carcinogen or potential carcinogen, the report-
ing facility may disregard levels of the chemical below the 0.1 percent de minimis concentration
provided that the other criteria for the de minimis exemption are met. De minimis levels for chemical
categories apply to the total concentration of all chemicals in the category within a mixture, not the
concentration of each individual category member within the mixture.
Data quality
EPA is placing a renewed emphasis on data quality in TRI reports. Specifically, the agency has found
that many facilities report inaccurate parent companuies and/or DUNS numbers in Sections 4 and
5 of the TRI reporting forms. EPA asks all facilities to verify the accuracy of facility and parent
company information (e.g., Dun and Bradstreet number, parent company name). Some tips for
reporting accurate information follow:
• To verify standardized parent company names for TRI reporting, EPA has provided an
alphabetized list of TRI Reporting Year 2008 Parent Company names as a reference for
COMMUNITY RIGHT TO KNOW–19

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facilities filing their RY 2009 reports using paper forms. See the list at www.epa.gov/tri/
report/index.htm. Your facility may or may not have a parent company. Also, if you do have
a parent company, note that it is not necessarily found in the list EPA has provided.
• To verify the accuracy of your facility, and parent company Dun and Bradstreet number and
name, as required in Section 5 of both Form R and Form A, go to https://www.dnb.com/
product/dlw/form_cc4.htm or call 1-888-814-1435 to verify your information. Callers to the
toll-free phone number should understand that the Dun and Bradstreet support represen-
tatives will need to verify that callers requesting the DUNS number are an agent of the
buisness. Dun and Bradstreet recommends knowing basic information such as when the
buisness originated; officer names; and the name, address, and phone number for the
facility.
• Facilities reporting to TRI should also make sure they are providing the parent company
name and Dun and Bradstreet number of the parent company as of December 31st of the
reporting year.
EPA is also looking at using quick lists to verify the names of publicly owned treatment works
(POTW) and off-site location RCRA ID’s in Form R Part II Seciton 6.1.B and 6.2. These quick lists
will contain accurate facility location data that is registered and maintained by EPA’s Federal Reg-
istry System.
Recordkeeping
Sound recordkeeping practices are essential for accurate and efficient TRI reporting. It is in the
facility’s interest, as well as EPA’s, to maintain records properly.
Facilities must keep a copy of each report filed for at least three years from the date of submission.
These reports will be of use when completing future reports.
Facilities must also maintain those documents, calculations, worksheets, and other forms upon
which they relied to gather information for prior reports. In the event of a problem with data elements
on a facility’s Form R or Form A report, EPA may request documentation from the facility that
supports the information reported.
EPA may conduct data quality reviews of Form R or Form A submissions. An essential component
of this process involves reviewing a facility’s records for accuracy and completeness. EPA recom-
mends that facilities keep a record for those EPCRA section 313 chemicals for which they did not
file EPCRA section 313 reports.
A partial list of records, organized by year, that a facility should maintain include:
❏ Previous years’ EPCRA section 313 reports;
❏ EPCRA section 313 Reporting Threshold Worksheets;
❏ Engineering calculations and other notes;
❏ Purchase records from suppliers;
❏ Inventory data;
❏ EPA (NPDES) permits and monitoring reports;
❏ EPCRA section 312 Tier II Reports;

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❏ Monitoring records;
❏ Flowmeter data;
❏ RCRA Hazardous Waste Generator’s Report;
❏ Pretreatment reports filed by the facility with the local government;
❏ Invoices from waste management companies;
❏ Manufacturer’s estimates of treatment efficiencies;
❏ RCRA manifests;
❏ Process diagrams that indicate emissions and other releases; and
❏ Records for those EPCRA section 313 chemicals for which they did not file EPCRA section
313 reports.
Addressing terrorist activities in local emergency plans

In recent years, the threat of terrorist incidents involving chemical and biological materials has
increased. Local emergency planning committees (LEPCs) should consider the possibility of ter-
rorist events as they review existing plans and consider how to incorporate counter-terrorism (CT)
measures into their plans.
CT planning and preparedness is often an extension of existing activities, rather than a totally new
effort. LEPCs, as well as companies in the community, can incorporate CT issues when they review
and update their emergency plans.
Build on current activities

LEPCs, established under the Emergency Planning and Community Right-to-Know Act (EPCRA),
prepare and maintain comprehensive emergency plans. These plans address the extremely haz-
ardous substances listed under EPCRA as well as thousands of hazardous chemicals for which
OSHA requires material safety data sheets.
Many LEPCs are already addressing CT, even if they do not use the word “terrorism.” If a plan has
been developed for possible accidental releases of chemicals in your community, you can use the
same general planning principles for deliberate releases caused by terrorists. You may need to
spend some time considering biological agents. This article includes some suggestions for how you
can modify your current activities to include deliberate chemical and biological releases.
Maintain broad-based membership

LEPC membership includes a wide variety of stakeholders, such as elected state and local officials;
police; fire, civil defense, public health, environmental, hospital, and transportation officials; repre-
sentatives of facilities where chemicals are stored or used; community groups; public works
departments; and the media. The committee should identify any specific roles each of these groups
might have in the event of a terrorist attack. In addition, a few new members might be added who
would bring specific expertise during a release involving biological agents (e.g., the coroner, mor-
ticians, chemistry and biology labs, university experts).

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Update and revise your plans

LEPCs should review their emergency response plans annually. Before beginning specific consid-
eration of CT issues, ensure that the emergency plan is up-to-date. Simply adding CT materials to
an outdated plan will not create an effective emergency plan. For example, review the plan for
outdated contact information, unique hazards presented by facilities that may have been con-
structed after the emergency response plan was first written, or new public works facilities. Also
review the annual inventory reports filed under EPCRA Section 312 to determine if new chemicals
or hazards are present in the community.

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In addition, check Risk Management Plans submitted by facilities in your community to ensure that
the specific hazards identified by each facility are addressed. After the plan has been generally
updated, consider adding information and procedures related to potential terrorist incidents involv-
ing weapons of mass destruction (WMD).
One overall difference in dealing with a WMD incident is that law enforcement officials will be in-
volved in the response as investigators. Officials from local, state, and federal agencies will be on
the scene of an incident to collect evidence and interview survivors. Their priorities may create
emergency response coordination challenges that your LEPC should address in its plan. The fol-
lowing suggestions detail changes you can make to specific sections of your emergency plan.
Emergency contact information
In the event of a terrorist incident, rapid and secure communications will be crucial to ensure a
prompt and coordinated response. Your plans should include current contact information for fire,
emergency medical services (EMS), law enforcement, medical, and other local departments and
supporting organizations. Contact information for state officials, including those at public health
agencies, the State Emergency Response Commission (SERC), State Police, and emergency
management agencies also should be included.
The emergency assistance telephone roster in your emergency response plan should include reg-
ular phone numbers, cell phone numbers, pager numbers, and other emergency contact informa-
tion for those individuals (federal, state, local, and private sector) who have specific CT functions.
The National Response Center (NRC) continues to be the sole federal point of contact for reporting
oil and chemical spills, and now provides the service of the Chemical and Biological Hotline. The
NRC telephone number (800-424-8802) should be part of your emergency plan.
NRC Duty Officers take reports of actual or potential domestic terrorism and link emergency calls
with the Department of Defense (DOD) for technical advice on dealing with weapons of mass de-
struction and with the FBI to initiate the federal response actions. The NRC also provides reports
and notifications to other federal agencies as necessary. All local plans should also include contact
information for the local FBI Field Office.
Response functions
Incident command/Unified command. Your emergency plan should address direction and control
of responders in the event of terrorist attack. Local responders respond to an incident scene and
should notify local, state, and federal authorities if terrorism appears to be involved. Local re-
sponse authorities should establish control of the incident scene.
The Incident Command System (ICS) that is initially established will likely transition into a Unified
Command (UC). The UC structure used at the scene will expand as mutual-aid partners, and state
and federal responders arrive to assist with response operations.
The FBI is the overall Lead Federal Agency (LFA) for a domestic terrorist incident involving WMD
and will lead the crisis management activities (including law enforcement activities) of the re-
sponse.
The Federal Emergency Management Agency (FEMA) is the lead agency for coordination of fed-
eral support to state and local responders during consequence management activities of the re-
sponse. Although the FBI is always involved in response to a credible terrorist threat or attack,
COMMUNITY RIGHT TO KNOW--23

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FEMA support is provided only after a Presidential declaration, typically after state and local agen-
cies request their assistance.
Consequence management includes measures to protect public health and safety after an explo-
sion or release; restore essential government services; and provide emergency relief to govern-
ments, business, and individuals. When crisis management activities have been completed, the
U.S. Attorney General may transfer the overall Lead Federal Agency role to FEMA.
EPA, the Department of Health and Human Services (DHHS), and DOD also have specific CT-re-
lated functions.
Public information. Rapid and secure communications help to ensure a prompt and coordinated
response to terrorist activities. Therefore, strengthening communications among emergency re-
sponders, law enforcement officials, clinicians, emergency rooms, hospitals, and mass care pro-
viders is extremely important. Your emergency plan should include the use of accurate and timely
public notification measures and warning systems in the event of a terrorist attack.
Work in advance with local news media representatives to ensure their cooperation at the time of
an incident. Ongoing communication of accurate and up-to-date information will help calm fears
and limit the effects of the attack. The FBI will establish a Joint Information Center (JIC) to coordi-
nate the collection and dissemination of public information.
Activities of human services organizations, such as the Red Cross, should be included in the emer-
gency plan.
Public and first responder health and safety. Your emergency plan should address public health
and medical issues as they relate to terrorist events. The plan should include procedures to identify
and treat victims, store and distribute antidotes, and handle fatalities. Mass care issues that may
be different during a terrorist WMD event include decontamination, multihazard/multiagent triage,
mortuary services, and notifying and working with families of any fatalities.
The emergency plan should also consider the personal safety of emergency responders in the
event of a terrorist attack. A terrorist chemical, biological, or radiological release may not be imme-
diately known or apparent. Caregivers, emergency response and law enforcement personnel, and
other first responders are in danger of becoming casualties before anyone realizes that a crime
has occurred. Incidents could escalate quickly from one scene to multiple locations and jurisdic-
tions.
The emergency plan should be flexible enough to accommodate evacuation or in-place sheltering.
Evacuation may be required outside the perimeter of the scene to guard against further casualties
from contamination by a released agent or from the possibility of additional WMD. In-place shelter-
ing may be required if the area must be quarantined or if people are safer in a particular location.
Hazards analysis
The hazards analysis section of an emergency plan should identify potential hazards, determine
the vulnerability of an area as a result of hazards, and assess the risk of a hazardous materials
release or spill. In the identification step, you should consider explosive, chemical, biological, and
nuclear WMD as potential hazards.
As you conduct your hazards analysis, identify potential targets and review their vulnerability to
attack. Consider the population, accessibility, impact on daily life, economic impact, and symbolic

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value of areas at risk. Terrorists and criminals who want to attack a particular group based on a
conflict with their personal beliefs might target federal, state, or local government offices and facili-
ties, health clinics, or religious structures. Those who want to cause maximum casualties might
target public gathering places, modes of transportation, routes of transportation (including
bridges), or transportation facilities (such as airport terminals). In order to damage infrastructure
and interrupt day-to-day functions, a terrorist might target utilities or water and wastewater treat-
ment plants.
LEPCs should also consider emergency procedures in the event of multiple, or simultaneous, ter-
rorist attacks. Terrorists might target first responders (e.g., fire houses, police department offices,
response vehicles, and individuals) to hinder them from responding to another terrorist incident. A
terrorist may seek to transform a target into a weapon by focusing on facilities that handle explo-
sive, toxic, or volatile chemicals.
Because most public buildings and public areas must be accessible to everyone, they are highly
vulnerable to attack. Other facilities, such as water treatment plants and industrial facilities, espe-
cially those with chemical or explosives storage, should have site security measures in place. Fa-
cilities should ask the following questions:
• Is the facility or critical equipment and chemicals protected by fences or buildings?
• Are there systems to detect intruders (e.g., patrols, video surveillance)?
• Are there alarm systems?
• Is access to critical areas controlled?
Do not, however, include details of the security systems in your emergency plan, because it is
available to the general public.
Public works facilities and workers will assume a support role, if so requested by state and local
agencies. This support role might include damage assessment, debris clearance, search and res-
cue, traffic control, restoration of lifeline systems, building inspection, provision of potable water
and sanitation services, and flood control.
Mitigation procedures and ongoing assessment
Mitigation procedures and ongoing assessment involve consequence management activities to
assess and protect the public from further exposure to hazards presented by terrorist activities.
Public health officials, hazmat teams, coroners and/or medical examiners, and criminal investiga-
tors should work together to mitigate residual hazards as well as identify potentially large numbers
of fatalities. Federal assistance should be available to support this task.
Ongoing assessment activities may include environmental sampling of air, water, and soil, and in-
sect and animal screening for chemical, biological, or radiological agents. The criminal investiga-
tion of a terrorist attack will be a joint effort that includes many agencies. In the event of a biological
attack, an epidemiological investigation may also be performed to assess the distribution of cases
and sources of outbreak. The emergency plan could include a checklist of basic questions to ask
when conducting interviews with victims in hospitals, sick officers, and other individuals in affected
population groups. It may be necessary to train people in how to ask such questions appropriately
in stressful circumstances.

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Equipment
Your emergency response plan should include standard operating procedures on when to use
specialized WMD response equipment. Local responders should be trained to use, maintain, and
calibrate this specialized equipment.
Training
The 1996 Nunn-Lugar-Domenici (NLD) legislation authorized funding to form a Domestic Pre-
paredness (DP) training initiative. This initiative was recently transferred from DOD to the Depart-
ment of Justice (DOJ), and includes a range of specialized courses, from basic awareness to disci-
pline-specific advanced level training and exercises.
Training is available for identified cities and is directed at a broad spectrum of emergency respond-
ers from a variety of response disciplines, including fire, hazardous materials, law enforcement,
emergency medical services, public health, emergency management, and public works.
The NLD DP Program also includes three exercises: a chemical weapons tabletop, a biological
weapons tabletop, and a chemical weapons full-scale exercise. Both types of exercises allow par-
ticipants to test their knowledge and training, as well as increase the overall preparedness of re-
sponders across the jurisdiction.
FEMA independently offers the following:
• Course materials on WMD and preparedness and response for terrorist incidents that can
be downloaded from www.fema.gov/emi/termng.htm.
• A terrorism consequence management course at their Mount Weather Emergency Assis-
tance Center. A list of offices and contact information is located at www.fema.gov/emi/
sttrgo.htm.
• Information on the Incident Command System (ICS) training conducted by each State
Training Office of Emergency Services. Visit www.fema.gov/emi/nrcrs.htm for details.
• In conjunction with the National Fire Academy, an independent study course in emergency
response to terrorism, located at www.fema.gov/emi/crslist.htm.
Resources
LEPCs seeking assistance in terrorism-related emergency planning should begin with their
SERCs. The SERC can direct LEPCs to appropriate assistance at the national and state level, and
may be able to facilitate LEPCs in a given region working together to address possible terrorist
activities.
There are currently many federal agencies involved in some aspect of counter-terrorism. Many of
these agencies support websites. Because of the continual changes in the world of CT, however,
many websites become outdated or are even discontinued without warning. EPA’s Chemical
Emergency Preparedness and Prevention Office (CEPPO) website at www.epa.gov/ceppo/cntr-
ter.html is updated every two months and includes the latest links to the following types of informa-
tion: federal departments and agencies, health and medical, technical information and resources,
and international sources.

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Release notification under CERCLA and EPCRA

The release reporting requirements set out in the Comprehensive Environmental Response, Com-
pensation, and Liability Act (CERCLA) and the Emergency Planning and Community Right-to-
Know Act (EPCRA) enable federal, state, and local authorities to effectively prepare for and re-
spond to chemical accidents.
CERCLA requires the person in charge of a vessel or facility to immediately notify the National
Response Center when there is a release of a hazardous substance in an amount equal to or
greater than the reportable quantity (RQ) for that substance (CERCLA §103(a)).
In order to ensure proper and immediate responses to potential chemical hazards, EPCRA also
requires facilities to notify State Emergency Response Commissions (SERCs) and Local Emer-
gency Planning Committees (LEPCs) of releases of hazardous substances and extremely hazard-
ous substances when the release equals or exceeds the RQ (EPCRA §304(a)).
These systems for reporting releases help ensure accountability for cleanup, provide data for regu-
latory and public policy purposes, and promote emergency planning.
The primary purpose of both CERCLA and EPCRA release reporting requirements is to notify vari-
ous levels of government of potential hazards so that the necessary response actions can be tak-
en in a timely fashion to ensure maximum protection of human health and the environment. EPA
does not necessarily take enforcement action against releasers, but may take action against those
who fail to provide the required notification. These notifications assist EPA in identifying releases
that may eventually require a Superfund removal action or a long-term remedial cleanup.
The regulations under CERCLA and EPCRA require the reporting of hazardous substance and
EHS releases. For each hazardous substance and EHS identified, a reportable quantity (RQ) of 1,
10, 100, 1000, or 5,000 pounds has been designated. In the event that there is a release equal to
or greater than the designated RQ within a 24-hour period, a notification must be made to the Na-
tional Response Center (NRC), SERC, and LEPC, as appropriate.
The agencies notified in the event of a reportable release operate as an emergency response net-
work to deploy appropriate emergency assistance in the event of a chemical release. The NRC,
located at the United States Coast Guard (USCG) Headquarters, is the national communications
center continuously manned for handling activities related to response actions. The NRC acts as
the single federal point of contact for all pollution incident reporting. SERCs and LEPCs, estab-
lished under EPCRA, are dedicated to emergency response on the state and local levels. Member-
ship in these entities includes firefighters, law enforcement personnel, elected state and local offi-
cials, environmental specialists, and other emergency response personnel.
Since the goals of CERCLA and EPCRA are not the same, the release reporting requirements
differ slightly between the two laws. CERCLA is a federal program designed to clean up aban-
doned hazardous waste sites. The release notifications provided under CERCLA help EPA identify
sites that potentially warrant a response action. In contrast, EPCRA provides state and local gov-
ernments with the necessary information to develop emergency response plans and to inform citi-
zens of potential risks. Due to these underlying differences in purpose, CERCLA release notifica-
tions are provided to the NRC, whereas EPCRA notifications are provided to SERCs and LEPCs.
In order to fully understand release reporting, however, CERCLA and EPCRA requirements must
be learned concurrently. There are important distinctions between the two programs.

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Definitions
Familiarity with the following terms is key to understanding the reporting requirements.
Facility: CERCLA defines facility as any building, structure, installation, equipment, pipe or pipe-
line, well, pit, pond, lagoon, impoundment, ditch, landfill, storage container, motor vehicle, rolling
stock, aircraft, or any site or area where a hazardous substance has been deposited, stored, dis-
posed of, or placed, or otherwise come to be located. Facility does not include any consumer prod-
uct in consumer use or any vessel.
The definition of facility under EPCRA is not identical to that under CERCLA.
EPCRA defines facility as all buildings, equipment, structures, and other stationary items which are
located on a single site or on contiguous or adjacent sites and which are owned or operated by the
same person. The definition of facility also includes motor vehicles, rolling stock, and aircraft.
Release: A CERCLA release is defined as any spilling, leaking, pumping, pouring, emitting, emp-
tying, discharging, injecting, escaping, leaching, dumping, or disposing into the environment, in-
cluding abandonment or discarding of barrels, containers, and other closed receptacles containing
any hazardous substance, pollutant, or contaminant (40 CFR 302.3). Under EPCRA, a release is
defined similarly to CERCLA’s release definition, except that the EPCRA definition also includes
releases of hazardous chemicals and extremely hazardous substances (EHSs) (40 CFR 355.20).
Reportable quantity (RQ): In order for a release of a hazardous substance or EHS to be report-
able, a certain amount must be released into the environment within a 24-hour period. This
amount, called the “reportable quantity,” triggers emergency release notification requirements.
How reporting is triggered
There are certain criteria that must always be met to trigger notification to the NRC, SERC, and
LEPC. The criteria under CERCLA are slightly different than those under EPCRA because the
goals of the two programs are different. There are conditions applicable to each law that must be
met in order to trigger reporting.
There are five specific conditions that must be met to trigger the CERCLA requirement for notifying
the NRC. There must be a:
• release
• of a hazardous substance
• that equals or exceeds a reportable quantity
• from a vessel or facility
• within a 24-hour period.

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The conditions that trigger notification to the SERC and LEPC under EPCRA are very similar to the
above CERCLA conditions. There are, however, some important differences. To trigger EPCRA
notification there must be a:
• Release with the potential to affect off-site persons
• Of a hazardous substance or extremely hazardous substance
• That equals or exceeds a reportable quantity
• From a facility at which a hazardous substance or extremely hazardous substance is pro-
duced, used, or stored
• Within a 24-hour period.
Step 1: Release
The first step in determining if release reporting requirements are triggered is assessing whether or
not a release has occurred. Both statutes define the term “release” very broadly (as discussed ear-
lier). EPCRA, however, carries the additional requirement that a facility must produce, use, or store
a hazardous chemical in order to have a “reportable release.”
There are several types of releases that are excluded from the requirements of both CERCLA and
EPCRA release reporting. These releases were excluded originally under CERCLA because they
are covered by other regulatory programs. The regulations found at 40 CFR 355.40(a)(2)(v) ex-
tend these statutory exclusions under CERCLA to the release reporting requirements under EP-
CRA.
Exclusions from the definition of release. The definition of release in CERCLA specifically ex-
cludes:
• emissions from engine exhaust of a motor vehicle, rolling stock, aircraft, vessel, or pipeline
pumping station engines,
• releases of source, byproduct, or special nuclear material from a nuclear incident covered
by financial protection under the Nuclear Regulatory Commission, and
• the normal application of fertilizers in accordance with product instructions.
Since these specific scenarios are excluded from the definition of release, they need not be re-
ported to the NRC, SERC, or LEPC, even if an RQ has been equaled or exceeded.
CERCLA also excludes releases in the workplace, but only with respect to a claim asserted against
the employer by a facility worker. Any claims covered by worker compensation through the Occu-
pational Safety and Health Administration regulations cannot be filed under CERCLA. The need
for notification, however, must be determined by whether or not a release from a CERCLA facility
or vessel enters into the environment. If a release does not remain wholly contained within a build-
ing or structure, then it is a release into the environment for CERCLA’s purposes, whether or not it
occurs within a workplace.

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Federally permitted releases. Federally permitted releases are exempt from reporting require-
ments. These exemptions from notification address a range of situations where releases are regu-
lated under another program or are outside the scope of EPCRA’s and CERCLA’s purpose and
• National Pollutant Discharge Elimination System (NPDES) permits;
• dredge and fill permits under the Clean Water Act (CWA);
• RCRA permitted and interim status units;
• underground injection control permits;
• clean dumping and incineration permits;
• air releases under Clean Air Act (CAA) permits;
• injection of fluids to develop crude oil or natural gas supplies;
• discharges to POTWs in accordance with pretreatment standards;
• releases of nuclear materials under the Atomic Energy Act.
Registered pesticides. CERCLA provides an exemption from release reporting for the application
of pesticide products registered under the Federal Insecticide, Fungicide, and Rodenticide Act (FI-
FRA). This exemption includes the handling and storage of a pesticide product by an agricultural
producer. EPA does not, however, consider the spill of a pesticide to be either an “application” of
the pesticide or in accordance with the pesticide’s purpose. Consequently, such spills must be re-
ported if all additional criteria are met.
Step 2: Hazardous substance
Since CERCLA and EPCRA were written to serve different purposes, there are two separate, but
overlapping universes of chemicals reportable under the two laws. Only releases of hazardous
substances are reportable under CERCLA, whereas releases of both hazardous substances and
EHSs are reportable under EPCRA. Because EPA was directed by Congress to compile these
chemical lists using different criteria, some chemicals are on both lists and some chemicals appear
on one list, but not the other.
The term “hazardous substance” is defined in CERCLA to include a compilation of substances
listed in accordance with certain sections of the CAA, CWA, RCRA, and TSCA. When a determina-
tion is made to regulate a substance under the CAA, CWA, RCRA, or TSCA, it automatically be-
comes a CERCLA hazardous substance and will be added to 40 CFR Table 302.4. When a sub-
stance is delisted from the CAA, CWA, RCRA, or TSCA lists, the substance remains on the
hazardous substance list unless EPA determines that there is no independent basis for retaining
the hazardous substance listing. CERCLA grants the Administrator of EPA the authority to auto-
matically add new substances to the list of hazardous substances codified in 40 CFR Table 302.4.
For example, if a substance was identified as potentially dangerous and was not already defined
as a hazardous substance under CERCLA, the Administrator has the authority to designate that
substance as hazardous and place it in the table in 40 CFR 302.4.

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Clean Air Act
All hazardous air pollutants (HAPs) listed under section 112(b) of the CAA are hazardous sub-
stances under CERCLA. When the CAA was amended on November 15, 1990, 189 hazardous air
pollutants were added to the HAP list. Several of these substances were already designated as
CERCLA hazardous substances because of their regulation under other acts. For those that were
new to the list of hazardous substances, a statutory reportable quantity of one pound applied until
EPA made final RQ adjustments on June 12, 1995.
Radionuclides
Radionuclides are considered hazardous substances under CERCLA because EPA designated
them generically as hazardous air pollutants under the CAA. RQs for radionuclides are expressed
in curies, not pounds. A curie is a unit that measures the rate of radioactive decay. Establishing
RQs for radionuclides in mass units such as pounds would be inappropriate because most radi-
ation measurements and standards are activity-based or dose-based.
Clean Water Act
The CWA contains two sets of chemicals that are reportable under CERCLA and EPCRA. Two
sections of the CWA designate:
• toxic pollutants that are subject to pretreatment standards, and
• elements and compounds that present an imminent danger to the public health when dis-
charged into the navigable waters of the United States.
All substances designated pursuant to these two sections are CERCLA hazardous substances.
Toxic Substances Control Act
Toxic Substances Control Act (TSCA) authorizes EPA to commence a civil action for seizure of an
imminently hazardous chemical substance or mixture, or any article containing such substance or
mixture. Any hazardous chemical that EPA has taken action against pursuant to TSCA would auto-
matically become a CERCLA hazardous substance. To date, EPA has not designated any hazard-
ous substances pursuant to TSCA.
Resource Conservation And Recovery Act (RCRA)
Under RCRA, EPA established four separate lists of hazardous wastes in 40 CFR Part 261, Sub-
part D:
• hazardous wastes from nonspecific sources (F list), such as generic wastes produced by
manufacturing and industrial processes;

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• hazardous wastes from specific sources (K list), such as wastes from specifically identified
industries (e.g., wood preserving, petroleum refining, and chemical manufacturing); and
• commercial chemical products (P and U lists) that are chemical substances manufactured
for commercial or manufacturing use and that consist of the commercially pure grade of the
chemical.
RCRA hazardous wastes that are not specifically listed are identified by the characteristics of ignit-
ability (I), corrosivity (C), reactivity (R), and toxicity (TC) (40 CFR Part 261, Subpart C). The release
of a material that exhibits one or more characteristics of hazardous waste, but is not specifically
listed on the 40 CFR 302.4 table, is reportable provided the material becomes a waste upon re-
lease and the amount released meets the RQ.
As with all other hazardous substances, RCRA listed hazardous wastes (i.e., F, K, P, and U) and
characteristic wastes are reportable if the release equals or exceeds the designated RQ.
The petroleum exclusion
Under CERCLA, petroleum products have a statutory exclusion from the definition of hazardous
substance. Not all the exclusions found in CERCLA can be extended to EPCRA. This particular
exclusion applies only to CERCLA hazardous substances, as explained below.
CERCLA excludes certain substances from the definition of hazardous substance, thus exempting
them from CERCLA regulation. These substances include petroleum, meaning crude oil or any
fraction thereof which is not specifically listed as a hazardous substance. Natural and synthetic
gases, or mixtures of natural and synthetic gases are also excluded. If a release of one of these
substances occurs, CERCLA notification is not required.
EPA interprets petroleum as including those amounts of hazardous substances, such as benzene,
that are indigenous to crude oil or its fractions or that are normally added during the refining pro-
cess. Such amounts are part of the petroleum and are excluded from regulation under CERCLA.
Hazardous substances added to the petroleum or increased in concentration solely as a result of
contamination during use are not part of the petroleum and are not excluded from regulation under
CERCLA. Such amounts of hazardous substances are subject to CERCLA response authority, li-
ability, and release reporting requirements.
Although the petroleum exclusion exempts release of petroleum from CERCLA reporting require-
ments, it does not exempt a facility from EPCRA reporting requirements. A release of a petroleum
product containing an EHS is potentially reportable under EPCRA if more than an RQ of an EHS is
released. Unlike those hazardous substances in petroleum that are present in naturally occurring
amounts, or are normally added during refining, EHSs in petroleum products are reportable under
EPCRA even if they are indigenous to the petroleum product. Therefore, a release of a petroleum
product containing an RQ of an EHS is reportable to the SERC and LEPC.
Hazardous substances that are not reportable
There are certain types or forms of hazardous substances that are not reportable under CERCLA
or EPCRA, even though they otherwise meet the hazardous substance listing criteria, as a result of
EPA policy determinations. These types of hazardous substances are not reportable because EPA

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has determined that a release of these substances either does not present a substantial endan-
germent to human health or the environment or would impose an unnecessary burden on the
NRC, SERCs, LEPCs, and regulated community. The types or forms of hazardous substances that
are not reportable to the NRC, SERCs, or LEPCs are listed below.
Metals. Massive forms of metals, meaning those with a particle diameter of at least 100 microme-
ters, are not reportable when spilled. These substances are not reportable under CERCLA or EP-
CRA because EPA has determined that releases of massive forms of metal would normally not
require a response due to the unlikely inhalation of such large particles. A release of a metal classi-
fied as a radionuclide does not qualify for this exemption, even if the particles meet the size param-
eters.
Generic classes of compounds. Broad generic classes of organic and metallic compounds are
listed in Table 302.4 without corresponding RQs. Only a release of those member compounds that
are also specifically listed elsewhere in section 302.4 with a corresponding RQ are reportable.
For example, there is no RQ for the broad category of arsenic and compounds, but there is an RQ of
one pound for arsenic disulfide, which is a member of the generic class. The release of compounds
that are not specifically listed, but fall into one of the broad generic categories, are not reportable be-
cause EPA has determined that assigning an RQ to these particular broad categories may be inap-
propriate for many chemicals that fall into that class. Likewise, none of the broad generic categories
added by the 1990 CAA amendments have an assigned RQ. Keep in mind that while the releaser of
a broad category substance does not need to report the release, “a releaser is liable for the cleanup
of releases of hazardous substances which fall under any of the broad, generic classes.”
Radionuclides. EPA has issued administrative reporting exemptions that apply to certain radionu-
clide releases. EPA granted these administrative reporting exemptions because EPA believed that
reporting radionuclide releases from these source categories would serve no useful purpose.
These exemptions are detailed in 40 CFR 355.40(a)(vi).
Step 3: Extremely hazardous substance (EHS)
The EHS list was first developed as the “acutely toxic chemical” list and is now found in the regula-
tions at 40 CFR Part 355, Appendices A and B. This list identifies chemicals that are most likely to
induce serious acute reactions following short-term airborne exposure.
Figure 1 demonstrates how the EHS and hazardous substances lists are related.

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Figure 1:
CHEMICAL SUBSTANCE INTERFACE
Hazardous
Substances
Substances EHSs
EHSs
on both lists
Step 4: Into the environment
A key factor in determining whether a release has occurred is the interpretation of the phrase “into
the environment” found in the definition of release under both CERCLA and EPCRA. As stated in
CERCLA, “the environment” includes all environmental media (i.e., air, water, land surface and
subsurface strata).
Releases to the environment do not include releases that are wholly contained inside a closed
containment structure, such as a building or an enclosed vehicle. Hazardous substances dis-
charged in buildings or vehicles with active vents or openings, however, may become releases into
the environment.
For example, a spill of a hazardous substance onto a concrete floor of a totally enclosed manufac-
turing facility could be released into the environment if part of that substance seeps into the ground
through cracks in the concrete or volatilizes into the atmosphere via process vents.
When a release exceeds or equals the reportable quantity, the facility is subject to the notification
requirements of CERCLA and EPCRA.
The meaning of the phrase “into the environment” is a controversial issue. The CERCLA definition
of “into the environment” has not been definitively interpreted by EPA. Whether a release is consid-
ered “into the environment” or not is decided on a case-by-case basis. There is limited guidance
that may help in answering situation-specific questions.
Step 5: Vessel or facility
The next step in determining when a release triggers notification is to determine the origin of the
release; that is, whether the release occurred from a facility or vessel.

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Under CERCLA, notification is required for releases of hazardous substances from vessels or facil-
ities. A facility is any building, pipe, landfill, lagoon, motor vehicle, or other structure listed in CER-
CLA. The term “facility” excludes consumer products in consumer use, such as a spill of paint thin-
ner from a private home. A vessel is defined as any watercraft or other artificial contrivance used,
or capable of being used, as a means of transport on water.
Under EPCRA, a facility is defined as all buildings, equipment, structures, and other stationary
items located on a single site, or on contiguous or adjacent sites, and are owned and operated by
the same person. Vessels are not included in the definition of facility found in EPCRA, and thus
releases of hazardous substances from vessels are only reportable to the NRC, not the SERC or
LEPC. Furthermore, EPCRA specifies that a facility must also produce, use, or store a hazardous
chemical to trigger notification.
Step 6: Reportable quantity
EPA has statutory authority to determine an amount for each CERCLA hazardous substance that,
when released into the environment from a facility, requires notification. Until adjusted by EPA,
RQs for CERCLA hazardous substances are fixed by statute at one pound, unless an RQ has
been designated pursuant to a parent statute (i.e., CWA). The RQs for EHSs that are not also
CERCLA hazardous substances are also fixed at one pound until adjusted by a rulemaking.
All reportable quantities are listed in pounds, except those for radionuclides, which are in curies.
RQs for hazardous substances and EHSs are listed in a table at 40 CFR 302.4 and 40 CFR Part
355, Appendices A and B, respectively.
The RQ level does not reflect whether or not a given release is hazardous, but rather acts as a
trigger for possible governmental response action.
All concurrent releases of the same substance from a particular facility into the environment must
be aggregated to determine if an RQ has been exceeded. Releases from separate facilities need
not be aggregated.
Mixture rule
Most hazardous substances and EHSs produced, used, or stored by facilities do not exist in pure
forms, but are found in mixtures or solutions. There are special rules that facilities must follow
when determining the RQ for releases of mixtures or solutions.
If a mixture of hazardous substances or EHSs is released and the concentration of all hazardous
substances and EHSs in the mixture are known, the CWA mixture rule may be used to calculate
whether an RQ of any hazardous substance or EHS has been released.
RQs of different substances are not additive. This means that spilling a mixture containing half an
RQ of one hazardous substance or EHS, and half an RQ of another hazardous substance or EHS
does not add up to trigger reporting requirements.

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To use the CWA mixture rule, the releaser must calculate the amount of each hazardous sub-
stance or EHS that has been released. For instance, a release of 100 pounds of a mixture that is
40 percent acrylonitrile would be equivalent to a release of 40 pounds of acrylonitrile. This release
would not be reportable, since the RQ for acrylonitrile is 100 pounds.
If there is more than one hazardous substance or EHS in a mixture, the releaser must check the
RQ for each substance. The release must be reported if the RQ for any hazardous substance or
EHS has been met or exceeded.
If the concentrations of the hazardous substances or EHSs are unknown, reporting is required
when the total amount of the mixture released equals or exceeds the RQ for the component with
the lowest RQ.
The CWA mixture rule can be particularly confusing when applied to RCRA hazardous wastes. The
following sections explain the application of the mixture rule to listed and characteristic hazardous
wastes.
Determining RQs for RCRA wastes
RCRA has identified listed and unlisted wastestreams that are regulated as hazardous wastes and
thus regulated as CERCLA hazardous substances. The RQ for each RCRA hazardous wastes-
tream is listed in 40 CFR 302.4. RCRA wastes may be treated as mixtures only if all hazardous
components and their concentrations in the mixture are known. Otherwise, the RQ for the wastes-
tream must be used. The CWA mixture rule also applies to unlisted characteristic wastes if the
concentrations of all the constituents in the waste are known.
Step 7: Within 24-hour period
The last element of the trigger indicating when a release is reportable is whether an amount of the
hazardous substance or EHS equaling or exceeding the RQ is released over a 24-hour period.
Under EPCRA, releases of EHSs are only reportable if they occur in a manner that requires, or
would require, notification under CERCLA. EPA has interpreted this provision to mean the 24-hour
period policy under CERCLA is also applicable under EPCRA.
This time frame refers to the time period over which a release is to be measured; it does not mean
that one has 24 hours in which to report the release. Reporting to the NRC, SERC, and LEPC must
occur immediately upon the discovery that an RQ has been exceeded.
Reporting procedures
The NRC, SERC, and LEPC must be notified when there is a release of an RQ of a hazardous
substance or EHS into the environment according to CERCLA and EPCRA.
The purpose of the notification is to alert government officials that an emergency response may be
needed to protect human health and the environment. The decision to respond to a reported re-
lease is made on a case-by-case basis. Reporting a release does not free the responsible party
from liability for cleanup costs.

3/07

Mechanics of notification
CERCLA: To fulfill requirements under CERCLA, the person in charge of the vessel or facility must
report the release of a hazardous substance to the NRC at (800) 424-8802, as soon as it is deter-
mined that an RQ has been released into the environment within a 24-hour period (40 CFR §302.6).
Upon receipt of the report, the NRC will notify the on-scene coordinator (OSC) at the appropriate
EPA Regional office or U.S. Coast Guard district office. The OSC informs state and local officials
and decides on the federal government’s response.
EPCRA: To meet the requirements under EPCRA, the owner or operator of a facility must report
releases of hazardous substances and EHSs to the SERC and LEPC immediately. The notice to
the SERC and LEPC must include (40 CFR 355.40(b)(2)):
• the chemical name or identity of any substance involved in the release;
• an indication of whether the substance is an EHS;
• an estimate of the quantity released into the environment;
• the time and duration of the release;
• the medium or media into which the release occurred;
• any known or anticipated acute or chronic health risks associated with the emergency and,
where appropriate, advice regarding medical attention necessary for exposed individuals;
• proper precautions to take as a result of the release, including evacuation (unless such
information is readily available to the community emergency coordinator pursuant to the
emergency plan); and
• the names and telephone numbers of the person or persons to be contacted for further
information.
EPA strongly recommends that facilities indicate the location of the incident in the initial notice, but
this is not a regulatory requirement.
As soon as practicable after a release that requires notice under EPCRA, the owner or operator of
the facility is required to submit a written follow-up notice (or notices, if necessary) to the affected
LEPCs and SERCs (40 CFR 355.40(b)(3)). This report must contain all information required in the
initial notice, plus:
• any updated and additional information with respect to actions taken to respond to and
contain the release,
• known or anticipated acute or chronic health risks associated with the release, and
• where appropriate, advice regarding medical attention necessary for exposed individuals.
EPA strongly recommends that the cause of the release be reported in the follow-up notice.
Figure 2 depicts the notification requirements under both CERCLA and EPCRA.

3/07

Figure 2:
FACILITY REPORTING UNDER EPCRA §304 AND CERCLA §103(a)
RELEASE REPORTING UNDER RELEASE REPORTING

CERCLA UNDER EPCRA
40 CFR §302.6 40 CFR §355.40
Release Release
Potential to Affect
Hazardous Substance Off-Site Persons
That Equals or Exceeds a Hazardous Substance or

Reportable Quantity EHS
(RQ)
That Equals or Exceeds a

Reportable Quantity
From a Vessel
(RQ)
or Facility
From a
Within a 24-Hour Period Facility
= Hazardous Chemicals
Produced, Used, or Stored
Notify NRC
Immediately
And Within a 24-Hour

Period
Publish Notice in
Local Newspaper
=
Notify NRC,
SERC, and LEPC
Immediately
And
Written
Follow-up

3/07

Newspaper notice
Under CERCLA, the owner or operator of any vessel or facility from which a hazardous substance
has been released must “provide reasonable notice to potential injured parties by publication in
local newspapers serving the affected area” in addition to the NRC notification. This is a statutory
provision that has not yet been clarified in specific regulations.
Emergency response notification system
When a person calls to report a release, the NRC asks a series of questions. The information is
loaded into the Emergency Response Notification System (ERNS). ERNS is a database and re-
trieval system used to track information relating to notifications of oil and hazardous substances.
The database provides a direct source of data that can be used to analyze notifications and spills,
support emergency planning efforts, and assist decision-makers in developing spill prevention pro-
grams.
ERNS data are accessible electronically through NRC’s website at www.nrc.uscg.mil/nrchp.html.
Special issues
There are several issues relating to CERCLA and EPCRA release reporting that need special
attention. These topics augment previously discussed material. Knowledge of these special issues
is essential to fully understanding the two programs.
Continuous releases
When a release of a hazardous substance or an EHS occurs regularly and in relatively stable
amounts, state and local officials do not have to be notified each time such a release occurs.
These reduced reporting requirements relieve the burden on the SERC, LEPC, NRC, and regu-
lated community. This type of release, known as a continuous release, is defined as a release:
• which occurs without interruption or abatement, and is stable in quantity and rate; or
• that is routine, anticipated, intermittent, and incidental to normal operations or treatment
processes.
To qualify a release for reporting as a continuous release, the facility must establish a basis for
asserting that the release is continuous as defined by the statute. A release may be reported for a
period of time necessary to establish that the pattern of the release is continuous and stable. If
sufficient basis is established for the continuity, quantity, and regularity of a release, multiple re-
ports are not necessary. Past release data, engineering estimates, knowledge of a facility’s opera-
tions, and/or best professional judgment may be used to establish the pattern of a release. A
single telephone call to the NRC, SERC, and LEPC will alert authorities of a facility’s intent to re-
port a release as a continuous release.

3/07

Once a facility has determined that a release qualifies as “continuous,” and chooses that reporting
option, there are five kinds of notification required:
• initial telephone notification to the NRC, SERC, and LEPC;
• initial written notification to the appropriate EPA Regional office, SERC, and LEPC within
30 days of initial telephone notification;
• written follow-up report to the EPA Regional office one year after initial written notification;
• immediate reports of any statistically significant increase (SSI) in the release to the NRC,
SERC, and LEPC; and
• notification of changes in the source or composition of the release.
An SSI of a release is defined as an increase in the quantity of the hazardous substance released
above the upper bound of the previously reported normal range of the releases. The normal range is
the range of releases occurring over any 24-hour period under normal operating conditions during the
previous year. The person in charge of a facility must report all SSIs to the NRC, SERC, and LEPC
immediately, and should identify the notice as an SSI. An SSI is an episodic release, and will be
treated as such by the NRC. When releases continually exceed the upper bound, facilities may modify
the range by providing at least one SSI notification indicating the new range to the NRC, SERC, and
LEPC, and providing a written notification to the EPA Regional offices within 30 days.
If there is a change in the composition or source(s) of the release, the release must be treated as
a new release for notification purposes. Such changes require the submission of an initial tele-
phone notification and initial written notification in order to qualify as a continuous release (40 CFR
302.8(g)(1)).
Continuous release reporting applies to both CERCLA hazardous substances and EPCRA EHSs;
however, the notification requirements differ somewhat. Continuous release notifications for CER-
CLA hazardous substances are made to the NRC, the EPA Regional office, the SERC, and the
LEPC as shown in Figure 3. As shown in Figure 4, continuous release notifications for non-CER-
CLA EHSs, including an initial telephone call, the initial written report, and the SSI report, are made
to the SERC and the LEPC.

3/07

Figure 3:
CONTINUOUS RELEASE REPORTING REQUIREMENTS FOR CERCLA HAZARDOUS
SUBSTANCES
EPA
NRC Regional
Office
Follow-up
Initial Initial Report and Statistically
Telephone Written Changed Significant
Call Report Release Increase Reports
Reports*
SERC
and
LEPC
*Reports of changes in information previously submitted, other than a change in source or composition.

3/07

Figure 4:
WHERE TO SUBMIT CONTINUOUS RELEASE REPORTS FOR RELEASES OF NON-CERCLA
EHSs
SERC
and
LEPC
Initial Statistically
Initial
Written Significant
Telephone
Report Increase
Call
Reports
*Reports of changes in information previously submitted, other than a change in source or

composition, are not required. Notificiation to the SERC and LEPC, however, is required if there is
a change in the source or composition of the release.
Disposal at RCRA facilities
There are two types of RCRA land disposal facilities:

• Subtitle C hazardous waste facilities, and
• Subtitle D nonhazardous waste facilities (e.g., municipal solid waste landfills).
The standards to which owners and operators or Subtitle C facilities are subject are much more
stringent than those covering Subtitle D facilities.
EPA has established an administrative exemption from CERCLA release notification requirements
for the disposal of hazardous substances at RCRA Subtitle C hazardous waste facilities. Because
the disposal of wastes into permitted or interim status facilities is properly documented through the
RCRA manifest system, EPA believes that notification under CERCLA does not provide a signifi-
cant additional benefit. Under EPCRA, releases of hazardous substances or EHSs are only report-
able if they require, or occur in a manner which would require, notification under CERCLA. There-
fore, disposal of a hazardous substance or an EHS into a RCRA Subtitle C facility does not require
notification under either CERCLA or EPCRA.

3/07

No such administrative exemption exists for releases to RCRA Subtitle D nonhazardous

waste facilities. Therefore, releases of hazardous substances or EHSs in amounts equal to or
greater than an RQ into one of these facilities are potentially subject to CERCLA and
EPCRA release notification requirements.
Substances that change after release

A release of a substance that rapidly forms a CERCLA hazardous substance upon release is
a reportable event. For example, a metal chloride, which is not specifically listed as a haz-
ardous substance under CERCLA, readily changes to hydrochloric acid when it comes in
contact with water. Hydrochloric acid is specifically listed as a hazardous substance under
CERCLA and, therefore, must be reported if an RQ or more is released in a 24-hour period.
EPA has not clarified the term “rapidly,” nor listed all substances that rapidly form hazard-
ous substances when released.
Transportation-related releases
Under EPCRA, there are unique provisions for reporting that apply to transportation-related
releases. A transportation-related release means “a release during transportation, or storage
incident to transportation if the stored substance is moving under active shipping papers
and has not reached the ultimate consignee.”
The owner or operator of a facility for which there is a transportation-related release of
more than the substance’s RQ may meet the notification requirements of EPCRA by provid-
ing the required information to the local 911 emergency service instead of the SERC or
LEPC. If there is no 911 service, the information may be given to the telephone operator (40
CFR 355.40(b)(4)(ii)). Under CERCLA, however, even transportation-related releases must
be reported immediately to the NRC.
EPCRA 311/312 inspection checklist

The following short checklist will help you make sure you are in compliance with the report-
ing requirements in EPCRA sections 311 and 312.
1. Tier I/II forms filed with LEPC and SERC:
a. copy of most recent filing
b. verify correct filing (e.g., cover letter to LEPC and SERC)
c. facility inventory review (compare with Tier I/II filing)
d. facility inventory inspection
II. Accidental releases w/in last 3 years:
a. in excess of RQ
b. reported to NRC
c. follow-up investigation/report to NRC
III. Permit exceedences w/in last year:
a. in excess of RQ
b. reported to NRC

Release reporting summary

CERCLA and EPCRA both contain release reporting regulations with similar provisions.
However, because the two laws have different goals, the requirements are not exactly the
same. The CERCLA program is designed to promote federal cleanup of hazardous sub-
stances, whereas EPCRA primarily serves to notify state and local governments and citizens
of potential hazards.
The triggers for CERCLA notification to the NRC and EPCRA notification to the SERC and
LEPC are closely linked. Enacted in 1986, EPCRA broadened the notification provisions of
CERCLA, but did not replace notification to the NRC.
Notifying the NRC, SERC, or LEPC does not relieve a responsible party from any possible
liability, nor does it automatically trigger a response action. Failure to report, however, can
result in severe civil and possible criminal penalties.
CERCLA and EPCRA are not the only statutes that address spills and releases. Other laws
may also trigger reporting requirements at the time of a release of a hazardous substance or
material. These include:
• the Hazardous Materials Transportation Act (HMA), administered by the Depart-
ment of Transportation (DOT), which requires reporting of hazardous materials
releases or accidents;
• the Toxic Substances Control Act (TSCA), administered by EPA, which requires
reporting of releases of polychlorinated biphenyls (PCBs); and
• the Clean Water Act (CWA), administered by EPA, which requires reporting of haz-
ardous substance and oil releases into navigable waters. The Spill Prevention
Control and Countermeasures (SPCC) program was created under CWA authority.
EPCRA inspection checklist

The following checklist was created by EPA for agency inspectors to use when conducting an
environmental inspection of a facility. It is included here to give you an idea of what EPA is
looking for in EPCRA compliance.
REVISED EPCRA/DATA QUALITY INSPECTION CHECKLIST
Name of Facility:
Chemicals of Interest:
Reporting Year(s) of Interest:
I. General Information Regarding Facility
1. Describe the industrial process(es) performed at this facility during the reporting year(s)
of interest.(Attach process diagram(s) if possible.

2. Identify which of the following are utilized by the facility in its industrial processing or
chemical handling areas.
• Floor Drains
• Other Drains for Liquids
• Exhaust Fans
• Hoods Vents
• Ducts
• Sumps
• Open tanks, vats, etc.
• Slop Sinks
3. How many full-time equivalent employees did the facility have during the reporting
year(s) of interest?
4. Have the facility’s process operations changed significantly during the reporting year(s) of
interest?(include equipment, production rates, product substitution or elimination, etc.)? yes
no
If yes, describe:
5. Has the facility implemented any new treatment technologies during the reporting year(s)
of interest? yes no
If yes, describe:
6. Has the facility implemented any new pollution prevention initiatives during the report-
ing year(s) of interest? yes no
If yes, describe:
7. Briefly describe the facility’s housekeeping practices, particularly in industrial processing,
receiving/unloading, storage and pollution control areas.
II. General Information Regarding Facility’s Form R’s
1. For what years did the facility submit a Form R?
2. Did the facility submit a Form R every year that it was required to? yes no
If no, explain:
3. Did the facility have the same personnel available to complete all of its Form R’s? yes no
If no, describe changes?

4. Show in the following table the chemicals for which the facility completed a Form R for
the reporting year(s) of interest.
Chemical Name (* if mixture)

Year Year Year
5. Is there any indication that the facility either failed to report a particular chemical when
it should have or mistakenly reported a chemical when it shouldn’t have? yes no
If yes, describe:
6. Has the facility received and provided where appropriate supplier notification material for
all Section 313 chemicals in mixtures or in trade name products? yes no N/A
If no, describe:
7. Did the facility submit any revised Form R reports for the reporting year(s) of interest?
yes no
If yes, answer questions 8 and 9.
8. List the chemical(s) which had revised Form R’s submitted.
9. Describe below the reason(s) that the facility submitted revised Form R’s.
10. Based on findings of this inspection, does the facility need to submit a revised Form R?
yes no
If yes, explain reason:
11. Did the facility use the alternate threshold provision for any of the chemicals or years of
interest (i.e., combined quantity of amounts shown in Sections 8.1 thru 8.7 is less than 500
lbs)? yes no
If yes, was the facility correct in its use of this provision? yes no
If no, describe:

III. Use Threshold Determination

Chemical Name:
Year:
1. How is this chemical used at the facility? (check all that apply)
Manufacture — To produce, prepare, compound or import a listed chemical. Also includes
coincidental production of listed chemical (i.e., as byproduct or impurity) as a result of
manufacture, processing, otherwise use or treatment of other chemical substances. (25,000 lb
threshold)
• Produce for onsite use or processing
• Produce for sale or distribution in commerce
• Import for onsite use or processing
• Import for sale or distribution in commerce
• Produced as by-product or impurity (% = ___) of process
• By-product of waste treatment
Process — Intentional incorporation of listed chemical into a product. Includes preparation
(can produce change in physical or chemical state) of listed chemical after its manufacture
for distribution in commerce. General categories include chemical reactant (raw materials,
intermediates), formulation component, article component and repackage. (25,000 lb thresh-
old)
• Chemical reactant – Chemical used in a chemical reaction that results in the manu-
facture of another chemical substance or a product. Examples include feedstocks,
raw materials, intermediates and initiators.
• Formulation Component – Chemical that is added to a product (or product mixture)
for the purpose of enhancing its performance. Examples include additives, dyes, ini-
tiators, solvents, inhibitors, emulsifiers, surfactants, lubricants and flame
retardants.
• Article Component – A listed chemical that becomes an integral component of an
article.
• Repackage – Processing or preparation of a listed chemical (or product mixture) for
distribution in commerce in a different form, state or quantity.
Otherwise Use — Not intentionally incorporated into a product distributed in commerce.
Includes chemical processing aid, manufacturing aid and ancillary use. (10,000 lb threshold)
• Chemical Processing Aid – A chemical that is added to a reaction mixture to aid in
the manufacturing or synthesis of another chemical substance but is not intended to
remain in or become part of the product or product mixture. Examples include sol-
vents, catalysts, inhibitors, initiators, reaction terminators and solution buffers.
• Manufacturing Aid – A chemical that aids the manufacturing process but does not
become part of the resulting product and is not added to the reaction mixture during
the manufacture or synthesis of another chemical substance. Examples include
lubricants, metalworking fluids, coolants, refrigerants and hydraulic fluids.

• Ancillary or other use – A chemical that is used for purposes other than aiding
chemical processing or manufacturing. Examples include cleaners, de-greasers,
lubricants, fuels, chemicals for treating wastes and solvents in paints or other coat-
ings that volatilize.
• Further management of chemical containing waste received from off-site (includes
disposal, treatment, destruction and stabilization).
2. Is the chemical subject to any of the following exemptions? (check all that apply)
• Contained in an article (article must be a pre-manufactured item (i.e., manufactured
prior to arrival at facility) that is formed to a specific shape or design during its
manufacture and whose end-use functions depend upon its shape or design. It must
not release a listed chemical under normal conditions).
• Concentration of chemical below de minimis level (0.1% for carcinogens, 1.0% for
others)
• Laboratory chemical
• Structural component
• Routine janitorial/facility grounds maintenance
• Personal employee use
• Motor vehicle maintenance
• Intake water component
3. What was the basis of the estimate used by the facility for the amount manufactured, pro-
cessed, or otherwise used during the reporting year of interest? (check all that apply)
• Purchase/inventory records
• Emission factors
• Mass balance
• MSDSs from suppliers
• Process recipes
• Monitoring data
• Production data
• Assumption w/o calculations
• Other (specify)
4. List in the table below the quantities of this chemical that the facility estimated as its use
for the reporting year of interest and any different quantities that the inspector computed
(blanks mean that the inspector agrees with the facility’s estimate). Inspector’s calculations
should be attached to report.
Description of Use Facility’s Estimate Inspector’s Estimate

Amount Manufactured
Amount Processed
Amount Otherwise Used

5. What was the maximum amount of this chemical on-site at any time?
6. Based on the information obtained during this inspection does it appear that this was a
reasonable estimate? yes no
If no, describe:
7. With respect to the threshold determination for this chemical did the inspector identify
any of the following problems? (check as necessary)
• Overlooked use of chemical
• Mis-classified use of chemical
• Incorrectly applied/interpreted exemption(s)
• Failure to use best or all available data
• Required/supporting documentation was missing
• Calculation error
• Supplier information was missing
• Calculated quantity of parent metal not metal compound
• Use threshold determination not based on throughput but amount purchased or
released
• Calculations based on TCLP not total concentration of metals
Comments (note any disagreements):
IV. Release Estimates
Chemical Name:
Year:
1. Type of Release:
2. Is documentation of release estimates, including monitoring data, available? yes
no
3. What was the method of estimating this release? (see table below)
Method Code Release Category

Air Fugitive Air Point Water Release Land Release
Monitoring Data M *** *** *** **
or Measurements
Mass Balance C ** * ** ***
Emission Factors E *** ** N/A N/A
Other Approaches O * * * *
including Engi-
neering
Estimates/
Assumptions
(*** indicates most preferred; * indicates least preferred)

4. Which of the following material does the facility have and use for purposes of estimating
releases? (check all that apply)
• Engineering calculations
• Stack testing
• Outfall monitoring
• Hazardous waste analysis
• Other monitoring data
• Manufacturer’s estimates of treatment efficiencies
• RCRA manifests
• AP-42 or other EPA emission factors
• Non-published emission factors
• Other trade association chemical specific or nonspecific factors
• Spill/release event records
• Inventory records
• Process feed/utilization rates
• Volatilization rates
• Solubilities
• Raoult’s Law constants
• Henry’s Law constants
5. What was the quantity of release estimated by the facility?
6. What was the method preferred by the inspector given the circumstances at this facility?
7. If inspector preferred a different method of release estimation, indicate the quantity of
release that was computed using that method and attach calculations to report.
8. Did the inspector identify any of the following problems relating to the facility’s method of
estimating this release? (check as necessary)
Source of release not considered (i.e., vent, duct, drain, stack, pumps, valves, flanges, volatil-
ization from open units, stormwater runoff, treatment or other residues, accidental spills,
etc.)
• All existing data were not utilized
• Recycled material assumed to be a release
• Quantity based on metal compound not parent metal
• Mistakenly applied de minimus rule
• Neutralized acid mis-reported
• Questionable emission factors assumed
• Questionable treatment efficiency assumed
• Mis-classifying fugitive and stack emissions

• On-site treatment processes not included in release calculations

• Other
V. Off Site Transfers
Chemical Name:
Year:
1. Type of Off Site Transfer:
2. Is documentation of estimates of off site transfers, including monitoring or other data,

available? yes no
3. What was the method of estimating this off site transfer? (some possible methods shown
in table in previous section)
4. What was the quantity of this off site transfer estimated by the facility
5. What was the method preferred by the inspector given the circumstances at this facility?
6. If the inspector preferred a different method of estimating this offsite transfer indicate the
quantity that resulted using that method and attach necessary documentation to report.
7. Did the inspector identify any of the following problems relating to the facility’s method of
estimating this off site transfer? (check as necessary)
• Source of off site transfer not considered (OST’s should include any material sent off
site for purposes of waste treatment, disposal, recycling, or energy recovery after
any on site waste treatment, recycling or removal is completed)
• All existing data were not utilized
• Quantity based on metal compound not parent metal
• Mistakenly applied de minimus rule
• Neutralized acid mis-reported
• Questionable treatment efficiency assumed
Were the following observed during the facility tour? (Check as necessary)
• Floor drains/sumps in chemical use area
• Exhaust fans in chemical use area
• Vents/ducts in chemical use area
• Open tanks/vats/drums containing volatile material
• Chemicals not reported
• Excess chemicals in storage (i.e., inconsistent with facility’s usage or reported ’maxi-
mum on site at any one time’)

• Waste generation not reported

• Releases not reported
• Chemical use inconsistent with Form R report
• Spills, leaks, unexpected releases
• On site recycling
• Poor housekeeping
Comments:

Environmental compliance manual
HAZARDOUS MATERIALS
CONTENTS
Overview ......................................................................................................... 3
Hazardous Materials Regulations .......................................................................... 3
Hazardous Materials Classifications ....................................................................... 4
Class 1 (Explosive) Materials .......................................................................... 4
Class 2 (Gas) Materials ................................................................................. 5
Class 3 (Flammable Liquid) Materials .............................................................. 5
Class 4 (Flammable Solid) Materials ................................................................ 6
Class 5 (Oxidizing & Organic Peroxide) Materials................................................ 6
Class 6 (Poisonous) Materials ......................................................................... 7
Class 7 (Radioactive) Materials ....................................................................... 7
Class 8 (Corrosive) Materials .......................................................................... 7
Class 9 (Miscellaneous) Materials .................................................................... 7
Other Regulated Materials (ORM-D) ................................................................ 8
Packaging ........................................................................................................ 8
Applicability ............................................................................................... 8
Responsibility ............................................................................................. 8
Non-Bulk and Bulk Packagings ....................................................................... 8
Documentation .................................................................................................. 9
Applicability.............................................................................................. 10
Exceptions ................................................................................................ 10
Responsibility ............................................................................................ 10
Retention ................................................................................................. 10
Hazardous Materials Description ................................................................... 10
Emergency Response Information................................................................. 12B
Emergency Response Telephone Number.......................................................... 13
Marking (Section 172.300) .................................................................................. 13
Prohibited Markings (Section 172.303) ............................................................ 14
Specifications (Section 172.304 and 172.308) ..................................................... 14
Non-Bulk Markings (Section 172.301) ............................................................. 14
Bulk Markings (Section 172.302).................................................................... 16
Labeling (Part 172, Subpart E) ............................................................................ 18
Shipper Responsibility ................................................................................. 18
Carrier Responsibility.................................................................................. 18
Determining Labels (Section 172.400) ............................................................. 18
Exceptions (Section 172.400a)........................................................................ 19
Prohibited Labeling (Section 172.401).............................................................. 20
Placarding (Part 172, Subpart F) ......................................................................... 20
Bulk Packagings (Section 172.514) ............................................................... 20A
Freight Containers and Aircraft Unit Load Devices (Section 172.512) ................... 20A
Transport Vehicles (Section 172.506) ............................................................. 20A
3/13 Hazardous materials TOC–1

Rail Cars (Section 172.508) ......................................................................... 20A

Prohibited Placarding (Section 172.502) ......................................................... 20A
Placarding Requirements (Section 172.504) .......................................................... 20B
Table 1................................................................................................... 20B
Table 2................................................................................................... 20C
Exceptions and Placard Substitutions (Section 172.504)..................................... 20C
Handling and Storage...................................................................................... 20E
Registration for Transportation of Hazardous Materials........................................... 20E
Applicability............................................................................................ 20E
Exceptions .............................................................................................. 20F
Registration and Fee Requirements .............................................................. 20F
Recordkeeping ......................................................................................... 20G
Accidents and Incidents ................................................................................... 20G
Carrier Responsibility ............................................................................... 20G
Operator Responsibility ............................................................................. 20G
Responsibility.......................................................................................... 20G
Telephone Report ..................................................................................... 20H
Written Report ......................................................................................... 20I
Updating the Incident Report ...................................................................... 20J
Incidents Not Requiring Report .................................................................... 20J
Hazardous Substance Discharge Notification .................................................. 20K
Insurance Requirements .................................................................................. 20K
Training Requirements .................................................................................... 20L
Training ................................................................................................... 21
Training Categories .................................................................................... 21
Training Record ......................................................................................... 22
Reduce Vehicle Maintenance Shop Wastes .............................................................. 22
ERG Is Quick Guide for Transport Incidents........................................................... 24
What Is an ERG? ....................................................................................... 24
What’s in the Book? .................................................................................... 24
Understand the Guides ................................................................................ 24
Hazardous Materials Audit Checklist .................................................................... 25
2–Hazardous materials TOC 3/13

Overview
The U.S. Department of Transportation (DOT) was created in 1967 to “assure the coordinated,
effective administration of the transportation programs of the Federal Government” and to “develop
national transportation policies and programs conducive to the provisions of fast, safe, efficient, and
convenient transportation.” DOT monitors certain aspects of the transportation of goods over the
highway, by rail, and by marine vessel, and regulates shipments of hazardous materials.
The Pipeline and Hazardous Materials Safety Administration (PHMSA) is the administration respon-
sible for regulating the transport of hazardous materials. The Office of Hazardous Materials Safety
(OHMS), which is a part of PHMSA, is in charge of the Hazardous Materials Regulations.
Hazardous Materials Regulations

The Hazardous Materials Regulations (HMR) are designed to assure the safe transportation of any
substance or material which “...is capable of posing an unreasonable risk to health, safety, and
property when transported in commerce...” With this purpose in mind, it is easy to see that significant
hazards call for detailed and restrictive requirements. A material is considered “hazardous” if it meets
one or more of PHMSA’s hazard class definitions, and/or is a hazardous substance, hazardous
waste, marine pollutant, or elevated-temperature material.
The Hazardous Materials Regulations are found in 49 CFR 105–107, 110, 130, and 171–180. These
regulations are enforced by Office of Hazardous Materials Safety (OHMS); when transport is by
motor vehicle, these regulations are enforced by the Federal Motor Carrier Safety Administration
(FMCSA).
The Federal Motor Carrier Safety Regulations (FMCSR) set vehicle driver and carrier safety stan-
dards, and are administered and enforced by FMCSA, which is a part of DOT. In general, the
FMCSRs apply to all commercial motor vehicles, which are defined as any vehicles used to transport
passengers or property when:
• the vehicle weighs more than 10,000 pounds;
• the vehicle is designed to transport more than 15 passengers (including the driver); or
• the vehicle is used in the transportation of a placardable amount of hazardous materials.
Under the Transportation Safety Act of 1974, the Secretary of Transportation was charged with
designating a quantity and form of materials as hazardous materials if the transportation of such
materials would pose an unreasonable risk to the safety of the community.
The Hazardous Materials Regulations apply to all private, common, and contract carriers transport-
ing hazardous materials in commerce. The regulations are prescribed to minimize the dangers to life
and property incident to the transportation of the hazardous materials. An up-to-date copy of the
complete regulations is essential if you are engaged in transporting or handling any hazardous
materials.
HAZARDOUS MATERIALS–3
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Hazardous Materials Classifications

There are nine hazard classes established by the Hazardous Materials Regulations — some of
which are further subdivided into divisions. There is also a category of hazardous materials known
as “Other Regulated Material” or “ORM-D.”
Before a material can be offered for transportation, the shipper must determine whether it is a
hazardous material. This determination involves referring to HMR’s hazard class definitions, and in
some instances, the Precedence of Hazard Table. Once the appropriate hazard class (or classes)
have been determined, the shipper must use the Hazardous Materials Table and its two appendixes
to locate the applicable shipping information, such as the material’s proper shipping name, appro-
priate labels, special packaging requirements, etc.
Hazardous materials fall under the following classifications:
Class 1 (explosive) materials

A “Class 1 material” is any substance or article — including a device — which is designed to function
by explosion, or which — by chemical reaction within itself —is able to function in a similar manner
even if not designed to function by explosion, unless the substance or article is otherwise classed.
Class 1 is subdivided into six divisions:
Division 1.1
Explosives that have a mass explosion hazard. A mass explosion is one which affects almost the
entire load instantaneously.
Division 1.2
Explosives that have a projection hazard, but not a mass explosion hazard.
Division 1.3
Explosives that have a fire hazard and either a minor blast hazard, a minor projection hazard, or both
— but not a mass explosion hazard.
Division 1.4
Explosives that present a minor explosion hazard. The explosive effects are largely confined to the
package, and no projection of fragments of appreciable size or range is to be expected. An external
fire must not cause virtually instantaneous explosion of almost the entire contents of the package.
Division 1.5
Insensitive explosives which have a mass explosion hazard, but are so insensitive that there is very
little probability of initiation, or of transition from burning to detonation, under normal conditions of
transport.
Division 1.6
Extremely insensitive explosives which do not have a mass explosion hazard. This division is
comprised of articles which contain only extremely insensitive detonating substances and which
demonstrate a negligible probability of accidental initiation or propagation.
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Class 2 (gas) materials

A “Class 2 material” is any material which falls into one of the following three divisions:
Division 2.1 (flammable gas) material

Any material which is a gas at 20°C (68°F) or less and 101.3 kPa (14.7 psi) of pressure, which:
• Is ignitable at 101.3 kPa (14.7 psi) when in a mixture of 13 percent or less by volume with
air, or
• Has a flammable range at 101.3 kPa (14.7 psi) with air of at least 12 percent, regardless
of the lower limit.
Division 2.2 (non-flammable, nonpoisonous compressed gas—including compressed gas,

liquefied gas, pressurized cryogenic gas, compressed gas in solution, asphyxiant gas and
oxidizing gas) material
A non-flammable, nonpoisonous compressed gas (Division 2.2) means any material (or mixture)
that:
• Exerts in the packaging a gauge pressure of 200 kPa (25.9 psig/43.8 psia) or greater at
20°C (68°F), and
• Is a liquefied gas or cryogenic liquid and does not meet the definition of Division 2.1 or 2.3.
Division 2.3 (gas poisonous by inhalation) material

Any material or mixture which is a gas at 20°C (68°F) or less and a pressure of 101.3 kPa (14.7 psi)
and that:
• Is known to be so toxic to humans as to pose a hazard to health during transportation, or
• In the absence of adequate data on human toxicity, is presumed to be toxic to humans
because when tested on laboratory animals it has an LC50 value of not more than 5000
ml/m3(see 49 CFR 173.116(a) for assignment of Hazard Zones A, B, C or D). LC50 values
for mixtures may be determined using the formula in 49 CFR 173.133(b)(1)(i) or CGA P–20.
Class 3 (flammable liquid) materials

A Class 3 material is any liquid having a flash point of not more than 60°C (140°F), or any material
in a liquid phase with a flash point at or above 37.8°C (100°F) that is intentionally heated and offered
for transportation or transported at or above its flash point in a bulk packaging with the following
exceptions:
• Any liquid meeting one of the definitions specified in 49 CFR 173.115.
• Any mixture having one or more components with a flash point of 60°C (140°F) or higher
that makes up at least 99 percent of the total volume of the mixture, if the mixture is not
offered for transportation or transported at or above its flash point.
• Any liquid with a flash point greater than 35°C (95°F) that does not sustain combustion.
• Any liquid with a flash point greater than 35°C (95°F) and with a fire point greater than
100°C (212°F) according to ISO 2592.
• Any liquid with a flash point greater than 35°C (95°F) that is in a water-miscible solution with
a water content of more than 90 percent by mass.
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A combustible liquid is any liquid that does not meet the definition of any other hazard class and has
a flash point above 60°C (140°F) and below 93°C (200°F). A flammable liquid with a flash point at
or above 38°C (100°F) that does not meet the definition of any other hazard class may be reclassed
as a combustible liquid. An elevated temperature material that meets the definition of a Class 3
material because it is heated at or above its flashpoint may not be reclassed as a combustible liquid.
Class 4 (flammable solid) materials

A “Class 4 material” is any material which falls into one of the following three divisions:
Division 4.1 (flammable solid) material

Any material of the following three types:
• Desensitized explosives that, when dry, are explosives of Class 1 — other than those of
compatibility group A — which when wetted suppress the explosive properties, and mate-
rials specifically authorized by name in the Hazardous Materials Table or have been
assigned a shipping name and hazard class by the Associate Administrator for Hazardous
Materials Safety.
• Self-reactive materials that are thermally unstable and that can undergo a strongly exo-
thermal decomposition even without oxygen (air).
• Readily combustible solids that may cause a fire through friction, show a burning rate faster
than 2.2 mm (0.087 inch) per second under specified test procedures, or any metal pow-
ders that can be ignited and react over the whole length of a sample in 10 minutes or less
under specified test procedures.
Division 4.2 (spontaneously combustible) material

Any material of the following two types:
• A pyrophoric material that — even in small quantities and without an external ignition
source — can ignite within 5 minutes after coming in contact with air under specified test
procedures.
• A self-heating material that — when in contact with air and without an energy supply — is
liable to self-heat and which exhibits spontaneous ignition or if the temperature of the
sample exceeds 200°C (392°F) under specified test procedures.
Division 4.3 (dangerous when wet) material

A material which by contact with water:
• Is liable to become spontaneously flammable.
• Gives off flammable or toxic gas at a rate greater than 1 liter per kilogram of material, per
hour, under specified test procedures.
Class 5 (oxidizing & organic peroxide) materials

A “Class 5 material” is any material which falls into one of the following two divisions:
Division 5.1 (oxidizing) material

A material that may, generally by yielding oxygen, cause or enhance the combustion of other
materials.
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Division 5.2 (organic peroxide) material

Any organic compound containing oxygen (O) in the bivalent -O-O- structure and which may be
considered a derivative of hydrogen peroxide, where one or more of the hydrogen atoms have been
replaced by organic radicals, with some exceptions.
Class 6 (poisonous) materials

A “Class 6 material” is any material which falls into one of the following two divisions:
Division 6.1 (poisonous) material

A material, other than a gas, which is known to be so toxic to humans as to afford a hazard to health
during transportation, or which, in the absence of adequate data on human toxicity:
• Is presumed to be toxic to humans because it falls within specified oral, dermal, or inha-
lation toxicity ranges when tested on laboratory animals.
• Is an irritating material, with properties similar to tear gas, which cause extreme irritation —
especially in confined spaces.
Division 6.2 (infectious substance) material

A material known or reasonably expected to contain a pathogen. A pathogen is a microorganism
(including bacteria, viruses, rickettsiae, parasites, fungi) or other agent, such as a proteinaceous
infectious particle (prion), that can cause disease in humans or animals. Infectious substance and
etiologic agent are synonymous.
Class 7 (radioactive) materials

Any material containing radionuclides where both the activity concentration and the total activity in
the consignment exceed the values specified in the table in §173.436 or values derived according
to the instructions in §173.433.
Class 8 (corrosive) materials

A “Class 8 material” is:
• A liquid or solid that causes full thickness destruction of human skin at the site of contact
within a specified period of time.
• A liquid that has a severe corrosion rate on steel or aluminum based on the criteria in 49
CFR 173.137(c)(2).
Class 9 (miscellaneous) materials

A “Class 9 material” is a material which presents a hazard during transportation, but which does not
meet the definition of any other hazard class. This includes:
• Any material which has an anesthetic, noxious, or other similar property which could cause
extreme annoyance or discomfort to a member of a flight crew so as to prevent the correct
performance of assigned duties; or
• Any material that meets the definition in 49 CFR 171.8 for an elevated temperature mate-
rial, a hazardous substance, a hazardous waste, or a marine pollutant.
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Other regulated materials (ORM-D)

An “ORM-D material” is a material, such as a consumer commodity, which although otherwise
subject to the regulations, presents a limited hazard during transportation due to its form, quantity,
and packaging. It must be a material for which exceptions are provided in the Hazardous Materials
Table.
Packaging
The manner in which a hazardous material is packaged can have a significant impact on how safely
that material can be transported in commerce. Because of this fact, the HMR contains very specific
requirements for all packagings — both bulk and non-bulk. These requirements are designed to
ensure that the packaging selected is appropriate for the material, and can withstand the conditions
normally encountered in transport.
Applicability
Unless otherwise stated or exceptions are authorized, the packaging requirements are the same for
all modes of transport. And while most of the non-bulk requirements are based on the UN Recom-
mendations, the regulations do contain some provisions that are only applicable to domestic
transport. This means that compliance with these provisions will not guarantee acceptance by
regulatory bodies outside of the United States.
Responsibility
The responsibility for packaging a hazardous material rests with the individual who offers the
material for transport. This responsibility includes:
• Selecting a packaging appropriate for the material — given its quantity and chemical
composition, and the desired method of transport.
• Complying with the special provisions and/or quantity limitations listed for the material.
• Complying with the general requirements for packaging, as well as with the requirements
for either bulk or non-bulk packaging, as appropriate.
• Ensuring that the selected packaging meets the performance test requirements and
detailed specifications.
• Assembling and securing all components of the packaging in the manner intended.
• Ensuring that the packaging is properly identified (i.e., marked, labeled, and placarded)
before it is offered to the carrier for transport.
Non-bulk and bulk packagings

Throughout the regulations, packaging requirements are separated according to the two general
types of packagings: non-bulk and bulk.
Non-bulk packagings
Non-bulk packagings are those that have:
• A maximum capacity of 450 L (119 gal) or less, as a receptacle for a liquid,
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• A maximum net mass of 400 kg (882 lbs) or less and a maximum capacity of 450 L (119 gal)
or less, as a receptacle for a solid, or
• A water capacity of 454 kg (1,000 lbs) or less, as a receptacle for a gas.
Bulk Packagings
Bulk packaging means a packaging, other than a vessel or a barge, including a transport vehicle or
freight container, in which hazardous materials are loaded with no intermediate form of containment.
A Large Packaging in which hazardous materials are loaded with an intermediate form of contain-
ment, such as one or more articles or inner packagings, is also a bulk packaging. Additionally, a bulk
packaging has:
• A maximum capacity greater than 450 L (119 gal) as a receptacle for a liquid,
• A maximum net mass greater than 400 kg (882 lbs) or a maximum capacity greater than
450 L (119 gal), as a receptacle for a solid, or
• A water capacity greater than 454 kg (1,000 lbs), as a receptacle for a gas.
Example In Column 8 of the Hazardous Materials Table, separate packaging authorization

codes are listed for non-bulk packagings (8B) and bulk packagings (8C).
In Part 173, the majority of authorized non-bulk packagings are listed in Subpart E,
while the majority of authorized bulk packagings are listed in Subpart F.
In Part 178, performance standards and test requirements for non-bulk packagings
are addressed in Subparts L and M. Intermediate bulk container performance stan-
dards and test requirements are covered in Subparts N and O.
NOTE: A new definitionLarge packaginghas been added to the regulations.
Large packagingmeans a packaging that--
• Consists of an outer packaging that contains articles or inner packagings;
• Is designated for mechanical handling;
• Exceeds 400 kg net mass or 450 liters (118.9 gallons) capacity;
• Has a volume of not more than 3 cubic meters (m\3\) (see Sec. 178.801(i) of this
subchapter); and
• Conforms to the requirements for the construction, testing, and marking of Large
Packagings as specified in Subparts P and Q of Part 178 of the HMR, as
applicable.
The preamble(s) to HM-231 may be accessed in the PREAMBLES tab.
Documentation
Although there are a few exceptions, shipping papers are required for each hazardous material
shipment. Shipping papers provide key information about what is being transported, and how
hazardous it is. While the regulations do not mandate the use of a specific form, they do detail what
information must be included, and how the information must be shown. Typically, the general
shipping paper requirement can be met using a waybill, manifest, or bill of lading.
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Applicability
The general shipping paper requirements apply to hazardous material shipments offered for trans-
port by all modes — rail, air, vessel, and highway.
Exceptions
Exceptions to the general shipping paper requirements are authorized for any material identified by
the letter “A” or “W” in Column 1 of the Hazardous Materials Table (Section 172.101), unless the
material is:
• Offered or intended for transportation by air or water, respectively.
• A hazardous waste.
• A hazardous substance (listed in Appendix A to the Hazardous Materials Table).
• A marine pollutant (listed in Appendix B to the Hazardous Materials Table).
The shipping paper requirements do not apply to a limited quantity package unless it is offered or
intended for transportation by air or vessel, and, until December 1, 2013, a package of ORM-D
material authorized by the HMR in effect on October 1, 2010, when offered for transportation by
highway or rail. Shipping papers are also not required for Category B infectious substances pre-
pared in accordance with Section173.199.
Responsibility
Shipping papers must be prepared by the person who is offering the hazardous materials for
transport. However, there may be times when the carrier will be required to make additional
notations.
See Additional Documentation: Rail and Additional Documentation: Highway later in this section.
Retention
The Pipeline and Hazardous Materials Safety Administration (PHMSA), has amended the Hazard-
ous Materials Regulations (HMR) to require shippers to retain a copy of each hazardous material
shipping paper, or an electronic image thereof, for a period of 2 years after the date the hazardous
material is accepted by a carrier. Carriers must retain a copy of each shipping paper for one year
after the material is accepted from the shipper. A year is calculated from the exact date the shipping
paper is provided to the initial carrier until the same date the following year.
It must be accessible at or through the principal place of business and the shipping paper must be
made available, upon request, to an authorized official of a federal, state, or local government
agency at reasonable times and locations.
Hazardous Materials Description

Each hazardous material that will be offered for transport must be clearly described on the shipping
paper using the applicable information from the Hazardous Materials Table. At a minimum, this
shipping description must include the material’s:
• Identification number (Column 4)
• Proper shipping name (Column 2)
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• Hazard class or division number (Column 3)

• The subsidiary hazard class or division number entered in parentheses (The subsid-
iary hazard class or division number is not required to be entered when a
corresponding subsidiary hazard label is not required.) (Column 6)
• Packing group, if any (Column 5)
• Total quantity, by net or gross mass, capacity, or as otherwise appropriate
• Number and type of packages (mandatory October 1, 2007)
The total quantity is not required for empty hazardous material packaging (i.e., one that
has not been purged or refilled with a non-hazardous material), cylinders of Class 2 materi-
als, and bulk packagings.
However, some indication of total quantity must be shown for cylinders of Class 2 materials
and bulk packagings.
Example 10 cylinders or 1 cargo tank

A requirement to include the number and type of packages on shipping papers became man-
datory October 1, 2007. HM-215E amended the HMR to require that the information be
entered before or after the basic description.
Basic Description
The first five (5) items — often referred to as the material’s basic description —must be
shown, with no additional information interspersed unless authorized by the regulations.
The packing group must be shown in Roman numerals and may be preceded by the letters
“PG”.
HM-215I revised the HMR to allow an alternative to the basic description required. Under
the alternate format, the proper shipping name is listed first, followed by the hazard class or
division number, the subsidiary hazard class or division number, the identification number
and packing group number.
Example Gasoline, 3, UN1203, PG II

For domestic shipments, primary and subsidiary hazard class or division names may be
entered following the numerical hazard class or division, or following the basic description.
If the material is described using a generic or n.o.s. entry preceded by the symbol “G” in col-
umn 1 of the Hazardous Materials Table, the technical name(s) of the material’s hazardous
component(s) must be entered in parentheses. The technical name(s) in parentheses can be
placed between the proper shipping name and the hazard class or they may be listed follow-
ing the packing group.
Example UN1760, Corrosive liquid, n.o.s. (Caprylyl chloride), 8, II

UN1760, Corrosive liquid, n.o.s., 8, II, (Caprylyl chloride)
A modifier (such as “contains” or “containing”) and/or the percentage of the hazardous com-
ponent may be included, if appropriate.
3/13 Hazardous materials–11

Example UN1993, Flammable liquids, n.o.s. (contains Xylene, Benzene), 3, II
Hazardous Materials Regulations Aligned With International Requirements

In January 2013, PHMSA revised HM-215K and HM215-L to harmonize the HMR with the
International Maritime Dangerous Goods (IMDG) Code, the International Civil Aviation
Organization’s Technical Instructions for the Safe Transport of Dangerous Goods by Air
(ICAO Technical Instructions), and the United Nations Recommendations on the Transport
of Dangerous Goods--Model Regulations (UN Model Regulations) and address a petition for
rulemaking.
HM-215K
Mandatory compliance is required by January 1, 2013, except for the following:
• The ORM-D classification and markings may be used for domestic vessel, rail, and
highway transport until December 31, 2020. Starting January 1, 2021, they can-
not be used.
• The old limited quantity marking, diamond with identification number inside, may
be used for domestic vessel, rail, and highway transport until December 31, 2015.
Starting January 1, 2016, only the new limited quantity marking may be
used.
HM-215K also allows the use of the Materials of Trade exceptions for limited quantity pack-
ages; allows certain 1.4S explosives, compressed gases, and certain fire extinguishers to be
shipped as limited quantities; and clarifies required markings on overpacks that contain lim-
ited quantities and ORM-D packages.
HM-215-L
Voluntary compliance is authorized January 1, 2013.
Mandatory compliance is required January 1, 2014, except for the following:
1. Minimum size requirements for identification number markings on non-bulk pack-
ages are mandatory January 1, 2017. Reusable non-bulk packages manufactured
and marked before 2017, may continue to be used until the end of their useful life.
The new ID number size requirements are:
• Must be at least 12 mm (0.47 inches) for packages with a capacity greater than
30 L (8 gallons) or 30 kg (66 pounds) net mass, or cylinders with a water capac-
ity greater than 60 L (16 gallons).
• Must be at least 6 mm (0.24 in.), for packages 30 L (8 gal.) or less, or 30 kg (66
lb.) or less, or cylinders 60 L (16 gal.) water capacity or less.
• Size appropriate for package, for packages 5 L (1.32 gal.) or 5 kg (11 lb.) capac-
ity or less.
2. The marking requirements is mandatory for large packagings manufactured,
repaired, or remanufactured after January 1, 2015. Large packagings must be
marked with the appropriate symbol indicating designed for stacking or not for
stacking.
The rule also updates references to international regulations and revises the layout of the
reference material listed in 49 CFR §171.7. HM-215L also includes revisions, additions, and
deletions to the Hazmat at Table at §172.101, including an extensive revisions to vessel
stowage provisions in column 10 of the table.
12–Hazardous materials 3/13

The rule changes some packaging requirements in Part 173 to allow more flexibility when
choosing packaging for certain hazardous materials.
Finally, the rule applies new requirements for Flexible Bulk Containers (FBCs), including a
new packaging definition, operational controls, performance-oriented standards, and testing
requirements.
Total Quantity
The fifth required item — the material’s total quantity — may be placed either before, after,
or both before and after the basic description. In addition, it must include the appropriate
unit of measure (such as pounds, gallons, kilograms, and liters). While the regulations do
not typically allow abbreviations, they are permitted when specifying the material’s weight
or volume (lbs, L) or the type of packaging (cyl.).
Example 1 box, 25 lbs., UN1133, Adhesives, 3, II

UN1133, Adhesives, 3, II, 25 lb. box
1 box, UN1133, Adhesives, 3, II, 25 lbs.
For most shipments, the type of packaging (such as a box or drum) is not a required entry.
However, for bulk packagings and cylinders of Class 2 materials, some indication of total
quantity must be shown.
Additional Description Entries

The regulations specifically permit the addition of class names or subsidiary hazard class or
division numbers — either following the numerical hazard class, or following the basic
description. Any other additional information pertaining to the material may be entered on
the shipping paper provided that:
• It is not inconsistent with the required description.
• It is placed after the basic description.
Emergency Response Information

General Requirements
All hazardous material shipments that require shipping papers must also be accompanied by
emergency response information. At minimum, the following information must be provided
for each hazardous material in the shipment:
• Basic description and technical name of the hazardous material
• Immediate hazards to health
• Risks of fire or explosion
• Immediate precautions to be taken in the event of an accident or incident
• Immediate methods for handling fires
• Initial methods for handling spills or leaks in the absence of fire
• Preliminary first aid measures
How this information is presented is up to the discretion of the shipper. RSPA’s main con-
cern is that the information is complete, printed legibly, and in English.
3/13 Hazardous materials–12A

Location During Transport

The purpose of providing emergency response information is so that emergency personnel
take appropriate response measures in the event of a leak, spill, or other such incident
involving hazardous materials. This information does little good if it cannot be found when
needed. So that it is readily accessible, the carrier must keep the information with the ship-
ping papers, away from
12B–Hazardous materials 3/13

packages containing hazardous materials, and in a location immediately accessible in the event of
an incident.
Emergency Response Telephone Number

Number Requirements
Shipping papers must include a telephone number that can be called in the event of an emergency.
It must be the number of:
• The person offering the material for transportation.
• Any agency or organization (such as CHEMTREC) that is capable of, and accepts respon-
sibility for, providing detailed information on the hazardous material.
The number must be monitored at all times the material is being transported —including storage
incidental to transportation. Monitoring must be by a person who is knowledgeable of the hazards
and characteristics of the material and who has emergency response and incident mitigation infor-
mation for the material, or by someone who has immediate access to such a person. Answering
machines and voice mail are not acceptable!
NOTE: The offeror/shipper name or the emergency response information (ERI) contract number or
unique identifier provided by the ERI service provider must be included on the shipping paper
adjacent to the emergency response telephone number (if a number is used). However, if the
offeror/shipper name or ERI identifier appears elsewhere in a prominent location on the shipping
paper, neither the name nor identifier is required in relation to the emergency response telephone
number listed on the shipping paper.
Refer to the preambles published October 19, 2009 (HM-206F), and September 1, 2010 (HM-244C),
in the PREAMBLES tab for additional information and insight (as well as contact numbers to call)
regarding the new ERI telephone requirements.
Marking (Section 172.300)

PHMSA’s marking requirements apply to non-bulk and bulk packagings transported by rail, air,
vessel, and highway. Certain requirements specifically apply to transport vehicles and freight
containers.
The individual who prepares non-bulk packages of hazardous material for transport is responsible
for marking the package. This responsibility includes:
• Checking that any relevant markings already displayed are in the correct location and meet
PHMSA’s specification requirements.
• Removing or obliterating any markings which are not applicable or which may reduce the
effectiveness of the required markings.
• Applying any new markings in accordance with the regulations.
In most cases, the responsibility for marking bulk packagings, freight containers, and transport
vehicles rests with the individual initiating the shipment. The carrier is responsible for replacing
identification number markings that are lost, damaged, or destroyed during transit.
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Unless otherwise specified in a specific rule, stocks of preprinted packagings marked in accordance
with the HMR prior to the effective date of a final rule may be continued in use until depleted, or for
a one year period subsequent to the compliance date of the marking amendment, whichever is less.
Prohibited Markings (Section 172.303)

No packaging may be marked with a proper shipping name or identification number unless the
packaging contains the identified material or its residue.
Specifications (Section 172.304 and 172.308)

To withstand the conditions normally encountered during transportation, all non-bulk markings must
be:
• Durable,
• In English,
• Printed on, or affixed to, the surface of a package, or on a label, tag, or sign,
• Displayed on a background of sharply-contrasting color,
• Unobscured by labels or attachments, and
• Located away from any other markings — such as advertising — which could substantially
reduce their effectiveness.
Abbreviations are usually not allowed in a proper shipping name marking. Two specific exceptions
include:
• “ORM” in place of “Other Regulated Material”; and
• Abbreviations which appear as part of the authorized description in Column 2 of the Section
172.101 Hazardous Materials Table.
Illustrations of common markings can be found on the Hazardous Materials Marking Chart at the end
of this tabbed section.
Non-Bulk Markings (Section 172.301)

All non-bulk packagings must be “marked” with the following information:
• Proper shipping name;
• Technical names, when required;
• Identification number (preceded by “UN” or “NA” or “ID”, as appropriate);
• Consignee’s or consignor’s name and address;
• DOT-SP when required.
9/11

Proper Shipping Name SODIUM HYDROXIDE, SOLID

Identification Number UN1823
Consignee TO: The XYZ Company

13 Airport Boulevard
Pensacola, FL 32504
Consignor FROM: ABC ChemLabs

520 E. Cervantes
Stafford, VA 22554
Hazard Warning Label
Technical Names
• Any packaging that contains hazardous materials described by a proper shipping name
preceded by the symbol “G” in Column 1 of the Hazardous Materials Table must be marked
with the technical name in association with the proper shipping name.
Example Flammable liquids, n.o.s. (ethanol)
Special Permit Packagings

• DOT-SP (followed by the special permit number) is required if the packaging is authorized
for use under a special permit.
Example DOT–SP 9168
Exceptions
Identification numbers are not required on packages which contain only:
• limited quantities or
• ORM–D materials.
The consignee’s or consignor’s name and address are not required if:
• The package is transported by highway only, and will not be transferred from one motor
carrier to another.
• The package is transported as part of a carload lot, truckload lot, or freight container load,
and the entire contents of the rail car, truck, or freight container are shipped from one
consignor to one consignee.
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Bulk Markings (Section 172.302)

Unless specifically excepted, all bulk packagings of hazardous materials must be marked with the
identification number(s) of the contents. These numbers, unless otherwise provided, must be
marked:
• On each end and each side of a packaging having a capacity of 3,785 L (1,000 gal) or more.
• On two opposite sides of a packaging with a capacity of less than 3,785 L (1,000 gal).
• On each end and each side of a tube-trailer motor vehicle.
There are three ways in which identification numbers may be displayed:

• On an orange panel
• Across the center of a primary hazard placard

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• On a white square-on-point configuration (diamond-shaped) — with the same outside

dimensions as a placard (If the material is in a class that does not allow or require placards)
If the identification number markings on a portable tank or cargo tank are not visible, the transport
vehicle or freight container used to transport the tank must also be marked with the numbers, on
each side and each end.
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When a tank is permanently installed within an enclosed cargo body of a transport vehicle or freight
container, the identification number marking need only be displayed on each side and each end of
the tank that are visible when the enclosed cargo body is opened or entered.
Special Permit Packagings

• DOT-SP (followed by the special permit number) is required if the packaging is authorized
for use under a special permit.
Portable Tanks (Section 172.326)

In addition to displaying the applicable identification number (as described above), portable tanks
must be marked with:
• Material’s proper shipping name — on two opposite sides
• Owner or lessee’s name
Cargo tanks (Section 172.328) The Sides and Ends

In addition to the identification number, cargo tanks — except for certain nurse tanks — which are
used to transport gases must be marked on each side and each end with the proper shipping name
or appropriate common name of the gas.
Example CARBON DIOXIDE, REFRIGERATED LIQUID or REFRIGERANT GAS
Tank Cars (Section 172.330)

In addition to the identification number, tank cars — when required by a special provision to the
Hazardous Materials Table or by Section 172.330 — must be marked on each side with the proper
shipping name or appropriate common name.
Example Special provision “B35” — one of the special provisions listed in Column 7 of the
Hazardous Materials Table for “Hydrogen cyanide, stabilized, UN1051” states:
“Tank cars containing hydrogen cyanide may be alternatively marked “Hydrocyanic

acid, liquefied” if otherwise conforming to marking requirements in Subpart D of this
part. Tank cars marked “HYDROCYANIC ACID” prior to October 1, 1991, do not
need to be remarked.”
In addition to the identification number, multi-unit tank car tanks must be marked on two opposing
sides with the proper shipping name or appropriate common name.
If the proper shipping name for a hazardous material in a bulk packaging has been changed, it may
not need to be remarked if:
• The bulk packaging was marked before October 1, 1991, in conformance with the Haz-
ardous Materials Regulations in effect on September 30, 1991; and
• The marking contains the same key words as the current proper shipping name in the
Section 172.101 Hazardous Materials Table.
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Labeling (Part 172, Subpart E)

PHMSA’s labeling requirements apply primarily to non-bulk packagings —although the following
must also display labels if they are not properly placarded:
• Bulk packagings — other than cargo tanks, portable tanks, or tank cars — with a volumetric
capacity of less than 18 m3 (640 ft3).
• Portable tanks of less than 3,785 L (1,000 gal) capacity.
• DOT Specification 106 or 110 multi-unit tank car tanks.
• Overpacks, freight containers, or unit load devices of less than 18 m3 (640 ft3), which
contain a package for which labels are required.
Shipper Responsibility
The responsibility for labeling rests with the individual who is offering the hazardous material for
transportation. This responsibility includes:
• Determining the appropriate primary and subsidiary labels for the material.
• Removing or obliterating any irrelevant labels already on the package.
• Using labels which meet the specification requirements.
• Affixing labels in the proper location.
Carrier Responsibility
Although the shipper is responsible for the actual labeling, the carrier also has labeling
responsibilities. A carrier must only accept and transport packages that have been properly labeled.
Determining Labels (Section 172.400)

Once a material has been classified and a proper shipping name has been selected, determining the
appropriate hazard warning labels is a fairly easy process.
(1) Locate the selected proper shipping name in Column 2 of the Hazardous Materials Table
(Section 172.101).
(2) Refer to Column 6 of the Table for the appropriate label code(s).
(3) The first label code listed indicates the material’s primary hazard. Any additional label codes
indicate subsidiary hazards.
(4) Using the label codes from Column 6 in the Table, find the name of the label(s) required to
be on the package in the LABEL SUBSTITUTION TABLE in Section 172.101(g).
Except for 6.1, the label codes are the same as the hazard classes or divisions for labels. For
example, a 2.3 label code is a 2.3 (poison gas) label, a 3 label code is a Class 3 (flammable liquid)
label, and a 5.1 label code is a 5.1 (oxidizer) label.
For the label code 6.1, there are two possible labels. The label that must be used depends on if the
material is an inhalation hazard (Zone A or B).
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SAMPLE FROM THE LABEL SUBSTITUTION TABLE

Label code Label name
5.2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ORGANIC PEROXIDE.

6.1 (material poisonous by inhalation
(see §171.8 of this subchapter)) . . . . . . POISON INHALATION HAZARD.
6.1 (other than material poisonous by
inhalation) . . . . . . . . . . . . . . . . . . . . . . . . . . . . POISON.
6.2 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . INFECTIOUS SUBSTANCE.
If the material has more than one hazard, all applicable subsidiary labels may not be listed in the
Table (such as generic or n.o.s. shipping names). If this is the case, subsidiary labels must be
determined according to the regulations, this will be discussed in the following section.
If there is a reasonable doubt as to the class and labeling requirements for a material and this can
only be determined by testing, it may be labeled according to a tentative class assignment. This
assignment must be based on the following:
• Hazard class definitions;
• Hazard precedence found in Section 173.2a; and
• Shipper’s knowledge of the material.
Exceptions (Section 172.400a)

Not all non-bulk packages of hazardous materials will require hazard warning labels. Labels are not
required on the following:
• A cylinder or Dewar flask (§173.320) containing Division 2.1, 2.2, or 2.3 material that is not
overpacked, and is durably and legibly marked in accordance with CGA Pamphlet C-7,
Appendix A.
• A package or unit of military explosives — including ammunition — shipped by or on behalf
of the U.S. Department of Defense (DOD) when:
(1) in freight container-load, car-load or truck-load shipments, if loaded and unloaded
by the shipper or DOD; or
(2) in unitized or palletized break-bulk shipments by cargo vessel under charter to
DOD, if at least one required label is displayed on each unitized or palletized load.
• A package of hazardous materials — other than ammunition — that is loaded and unloaded
under the supervision of DOD personnel and is escorted by DOD personnel in a separate
vehicle.
• A compressed gas cylinder which is permanently mounted in or on a transport vehicle.
• A freight container, aircraft unit load device, or portable tank which is placarded in accor-
dance with Subpart F or conforms to paragraph (a)(3) or (b)(3) of 49 CFR 172.512.
• An overpack or unit load device in or on which labels that represent the hazard(s) inside are
visible.
• A package of low specific-activity radioactive material or surface contaminated objects
when transported under Section 173.427(a)(6).
• Certain exceptions for labeling requirements are provided for small quantities and limited
quantities in Part 173.
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• A package containing a PIH material in a closed transport vehicle or freight container may
be excepted from labeling or placarding under certain conditions in 49 CFR 171.23.
• Notwithstanding the provisions of 49 CFR 172.402(a), a Division 6.1 subsidiary hazard
label is not required on a package containing a Class 8 (corrosive) material that has a
subsidiary hazard of Division 6.1 (poisonous) if the toxicity of the material is based solely
on the corrosive destruction of tissue rather than systemic poisoning. In addition, a Division
4.1 subsidiary hazard label is not required on a package bearing a Division 4.2 label.
Limited Quantities
There are also exceptions to labeling for limited quantities in the following sections:
• Section173.150 - Exceptions for Class 3 (flammable and combustible liquids)
• Section 173.151 - Exceptions for Division 4.1 (flammable solids)
• Section 173.152 - Exceptions for Division 5.1 (oxidizers) and 5.2 (organic peroxides)
• Section 173.154 - Exceptions for Class 8 (corrosives)
• Section 173. 155 - Exceptions for Class 9 (miscellaneous)
Prohibited Labeling (Section 172.401)

No package may be labeled with a hazard warning label specified in the Hazardous Materials
Regulations unless the package contains the hazardous material and the label represents the
hazard of the material in the package.
Packages may not be offered for transportation or transported with a marking or label that could be
confused with or conflicts with the labels that are required unless the package is labeled in confor-
mance with:
• The United Nations Recommendations;
• The IMDG Code;
• The ICAO Technical Instructions;
• The TDG Regulations; or
• The Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Placarding (Part 172, Subpart F)

The placarding requirements apply to each person who offers for transport or transports hazardous
materials. The placarding requirements do not apply to the following materials:
• Infectious substances.
• Materials classed as ORM-D.
• Materials authorized to be transported as “Limited Quantities” (when properly identified on
the shipping papers, in accordance with 49 CFR 172.203 or when marked in accordance
with 49 CFR 172.315).
• Hazardous materials packaged as small quantities under the provisions of 49 CFR 173.4,
173.4a, 173.4b.
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• Materials prepared in accordance with Section 173.13 (Exceptions for Classes 3, 8, 9, and
Division 4.1, 4.2, 4.3, 5.1, 6.1).
• Combustible liquids in non-bulk packagings.
Placards are used to identify the hazard of any quantity of materials contained in bulk packagings,
freight containers, unit load devices, transport vehicles, or rail cars. The responsibility for affixing or
supplying placards varies according to the mode of transport and the type of packaging used to
transport the hazardous material.
Bulk Packagings (Section 172.514)

The person who offers a bulk packaging containing hazardous material for transportation is required
to affix the placards required prior to or at the time the packaging is offered for transportation.
Freight Containers and Aircraft Unit Load Devices (Section 172.512)

Each person who offers for transportation and each person who loads and transports a hazardous
material in a freight container or aircraft unit load device is required to affix the placards specified.
Transport Vehicles (Section 172.506)

When a hazardous material is offered for transport by highway, the individual offering the material
must provide the carrier with the required placards — prior to, or at the same time, the material is
offered for transport — unless the appropriate placards are already affixed to the vehicle.
According to Section 177.823, the carrier may not move the vehicle until he or she has affixed the
required placards — unless it is an emergency situation and one of the following three conditions are
met:
• The vehicle is escorted by a representative of state or local government.
• The carrier has received permission from DOT to move the vehicle.
• Movement of the vehicle is necessary to protect life and property.
Rail Cars (Section 172.508)

When a hazardous material is offered for transport by rail, the individual offering the material must
affix the required placard(s) to the rail car — unless the car is already properly placarded. The rail
carrier may not accept a rail car for transport unless the required placards are affixed.
Prohibited Placarding (Section 172.502)

No person may affix a placard to a packaging, freight container, unit load device, motor vehicle or
rail car unless the material being offered for transportation is a hazardous material and the placard
applied represents the hazard of the material being offered.
Placards must conform to the requirements of Subpart F of the regulations. Signs, advertisements,
slogans, or other devices that could be confused with a prescribed placard are prohibited.
The restrictions above do not apply to the display of a BIOHAZARD marking, a HOT marking, a sour
crude oil hazard marking, or an identification number on a white square-on-point configuration.
HAZARDOUS MATERIALS–20A
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A bulk packaging, freight container, unit load device, transport vehicle or rail car placarded according
to Canada’s Transport Dangerous Goods (TDG) Regulations, the International Maritime Dangerous
Goods (IMDG) Code, or the United Nations (UN) Recommendations are allowed.
Placarding Requirements (Section 172.504)

Placarding requirements vary according to the category of the material (hazard class, division,
packing group or description) being transported and the type of packaging (bulk or non-bulk) con-
taining the material. Each bulk packaging, freight container, unit load device, transport vehicle, or rail
car containing hazardous material must be placarded on each side and each end (with some
exceptions) with the type of placards specified in Table 1 or Table 2 of Section 172.504.
To determine what placards are required, you must know:
• The type of packaging (bulk or non-bulk) containing the hazardous material(s).
• The hazard category (class, division, packing group, or description) and subsidiary haz-
ard(s) of the hazardous material(s) present.
• The weight of non-bulk packages in each hazard category.
Table 1
The most dangerous categories of hazardous materials are located in Table 1 and include Divisions
1.1, 1.2, 1.3 (explosives); Division 2.3 (poison gas); Division 4.3 (dangerous when wet); materials
described by the proper shipping name “organic peroxide, Type B, liquid or solid, temperature
controlled”; Division 6.1 (inhalation hazard, Zone A or B); and Class 7 (radioactive) Yellow III label
only.
Any quantity of material falling within the categories listed in Table 1 must be placarded.
Table 1
Category of material (Hazard class or division number Placard name Placard design section
and additional description, as appropriate) reference (§)
1.1 ........................................................................ EXPLOSIVES 1.1 ................ 172.522
1.2 ........................................................................ EXPLOSIVES 1.2 ................ 172.522
1.3 ........................................................................ EXPLOSIVES 1.3 ................ 172.522
2.3 ........................................................................ POISON GAS ..................... 172.540
4.3 ........................................................................ DANGEROUS WHEN WET 172.548
5.2 (Organic peroxide, Type B, liquid or solid, ORGANIC PEROXIDE ..........
temperature controlled) ............................................. 172.552
6.1 (Material poisonous by inhalation (see §171.8 of this POISON INHALATION 172.555
subchapter))............................................................ HAZARD ............................
1
7 (Radioactive Yellow III label only) ............................. RADIOACTIVE ................... 172.556
1
RADIOACTIVE placard also required for exclusive use shipments of low specific activity material and surface contami-
nated objects transported in accordance with §173.427(b)(4) and (5) of this subchapter.
HAZARDOUS MATERIALS–20B
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Table 2
The remaining hazard categories are assigned to Table 2. Any quantity of these materials also must
be placarded, but the regulations provide some exceptions under certain conditions.
Table 2
Category of material (Hazard class or division Placard design section
number and additional description, as Placard name reference (§)
appropriate)
1.4............................................................. EXPLOSIVES 1.4 ............................ 172.523
1.5............................................................. EXPLOSIVES 1.5 ............................ 172.524
1.6............................................................. EXPLOSIVES 1.6 ............................ 172.525
2.1............................................................. FLAMMABLE GAS ........................... 172.532
2.2............................................................. NON-FLAMMABLE GAS ................... 172.528
3 ............................................................... FLAMMABLE .................................. 172.542
Combustible liquid ........................................ COMBUSTIBLE ............................... 172.544
4.1............................................................. FLAMMABLE SOLID ........................ 172.546
4.2............................................................. SPONTANEOUSLY COMBUSTIBLE 172.547
5.1............................................................. OXIDIZER ...................................... 172.550
5.2 (Other than organic peroxide, Type B, liquid ORGANIC PEROXIDE ......................
or solid, temperature controlled) ...................... 172.552
6.1 (Other than material poisonous by inhalation POISON......................................... 172.554
) ................................................................
6.2............................................................. (None) ........................................... ...................................
8 ............................................................... CORROSIVE .................................. 172.558
9 ............................................................... CLASS 9 (see §172.504(f)(9) ............. 172.560
ORM-D....................................................... (None) ........................................... ...................................
Exceptions and placard substitutions (Section 172.504)

• A transport vehicle or freight container which contains less than 454 kg (1,001 lb) aggregate
gross weight of hazardous materials in non-bulk packages covered by Table 2 is not
required to display placards. (This exception does not apply to bulk packages or materials
with subsidiary hazards that must be placarded according to Section 172.505.)
• If a transport vehicle, rail car, freight container, or unit load device contains non-bulk
packagings of two or more categories of Table 2 materials, the DANGEROUS placard may
be displayed instead of the separate placards specified in Table 2.
When 1,000 kg (2,205 lb) or more of one hazard category is loaded at one facility, on one vehicle,
rail car, freight container, or unit load device, the DANGEROUS placard cannot be used, instead the
placard specified in Table 2 must be displayed.
HAZARDOUS MATERIALS–20C
3/11

If there are three or more different categories of Table 2 materials in one vehicle, rail car, freight
container, or unit load device, and one material is over the 1,000 kg (2,205 lb) and requires an
individual class placard, the DANGEROUS placard may still be used for the other categories of
Table 2 material that fall below the 1,000 kg (2,205 lb) limit.
• Non-bulk packagings that contain only the residue of a Table 2 material are not included
when determining the required placards for a transport vehicle, rail car, freight container, or
unit load device.
• A rail car loaded with a transport vehicle or freight container that is not required to be
placarded is not required to display placards.
• A motor vehicle transporting freight containers or aircraft unit load devices that are not
required to be placarded is not required to display placards.
• Freight containers and unit load devices being transported for delivery to a consignee
immediately after an air or water shipment are also allowed to use the exception for less
than 454 kg (1,001 lb) of Table 2 materials.
• A freight container or aircraft unit load device that is only transported by air and is prepared
according to Part 5, Chapter 2, Section 2.7 of the ICAO Technical Instructions is not
required to be placarded.
• When more than one division placard is required for Class 1 materials on a transport
vehicle, rail car, freight container, or unit load device, only the placard representing the
lowest division number must be displayed.
Example A transport vehicle carrying Division 1.3, 1.4, and 1.5 materials could be placarded for
Division 1.3.
• A COMBUSTIBLE placard is not required on a cargo tank, portable tank, or compartmented
tank car containing both flammable and combustible liquids when placarded FLAMMABLE.
• A NON-FLAMMABLE GAS placard is not required on a motor vehicle containing a non-
flammable gas if the vehicle contains flammable gas or oxygen and is placarded
FLAMMABLE GAS or OXYGEN, as required.
• OXIDIZER placards are not required for Division 5.1 materials on freight containers, unit
load devices, transport vehicles, or rail cars which also contain Division 1.1 or 1.2 materials
and which are placarded with EXPLOSIVES 1.1 or 1.2 placards, as required.
• (For transportation by transport vehicle or rail car only) An OXIDIZER placard is not
required for Division 5.1 materials on a transport vehicle, rail car, or freight container which
also contains Division 1.5 materials and is placarded with EXPLOSIVES 1.5 placards, as
required.
• The EXPLOSIVES 1.4 placard is not required for those Division 1.4 Compatibility Group S
(1.4S) materials that are not required to be labeled 1.4S.
• For shipments of Class 1 (explosive) materials by aircraft or vessel, the applicable com-
patibility group letter must be displayed on the required placards.
• CLASS 9 placards are not required for domestic transportation.
• The OXYGEN placard may be used for domestic shipments of oxygen, compressed, or
oxygen, refrigerated liquid, in place of a NON-FLAMMABLE GAS placard.
HAZARDOUS MATERIALS–20D
3/11

• For domestic transportation, a POISON placard is not required on a transport vehicle or

freight container required to display a POISON INHALATION HAZARD or POISON GAS
placard.
Handling and Storage

The Hazardous Materials Regulations contain specific requirements for the proper loading, unload-
ing, transport, and storage of hazardous materials. These rules, which are modal-specific, are
designed to protect those individuals who are involved with the shipment (i.e., the shipper and
carrier), as well as those who may come into contact with it. They include, among others, provisions
for quantity limitations, segregation, monitoring, load securement, stowage locations, vehicle posi-
tioning, and routing.
Registration for Transportation of Hazardous Materials

The Hazardous Materials Regulations require certain persons engaged in the transportation of
hazardous materials to register with DOT and pay a fee. The Office of Hazardous Materials Safety
issued a final rule in 1992 to establish a national registration program and annual fee collection
system for certain persons offering and transporting certain hazardous materials.
The annual fee funds a nationwide emergency response training and planning grant program for
states and local governments. The requirements for this registration program are found in Part 107,
Subpart G - Registration of Persons Who Offer or Transport Hazardous Materials.
Applicability
The program’s registration and fee requirements apply to any person who offers for transportation
or transports — in foreign, interstate, or intrastate commerce — any of the following:
• Any highway route-controlled quantity of a Class 7 (radioactive) material.
• More than 25 kg (55 lbs) of a Division 1.1, 1.2, or 1.3 (explosive) material in a motor vehicle,
railcar, or freight container.
• More than 1 L (1.06 qts) per package of a material extremely toxic by inhalation (i.e.,
“material poisonous by inhalation,” as defined in §171.8, that meets the criteria for “hazard
zone A,” as specified in §§173.116(a) or 173.133(a)).
• A hazardous material in a bulk packaging having a capacity equal to or greater than 13,248
L (3,500 gals) for liquids or gases, or more than 13.24 m3 (468 ft3) for solids.
• A shipment (offered or loaded at one loading facility using one transport vehicle) in other
than a bulk packaging of 2,268 kg (5,000 lbs) gross weight or more of one class of
hazardous materials for which placarding is required.
• Any shipment of hazardous materials that requires placarding.
HAZARDOUS MATERIALS–20E
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Exceptions
Exceptions from the registration and fee requirements are provided in Section 107.606 for the
following:
• An agency of the federal government.
• A state agency.
• An agency of a political subdivision of a state.
• An employee of any of the above agencies.
• A hazmat employee — including the owner/operator of a motor vehicle which transports
hazardous materials and is leased to a registered motor carrier under a 30-day or longer
lease (or an equivalent contractual relationship).
• A person domiciled outside the U.S., who offers solely from locations outside the U.S.,
hazardous materials for transportation in commerce, provided the country in which the
person is domiciled does not require U.S. persons to register or pay a fee.
Registration and fee requirements

Each person subject to the program must submit a complete and accurate “Hazardous Materials
Registration Statement” on DOT Form F 5800.2 (shown on the following pages) and the required fee
by June 30 of each year. A Certificate of Registration will then be issued.
You may now register for one, two, or three registration years by completing a single registration
statement and paying the appropriate fees. Discounts are available for multiple year registrations.
A single Certificate of Registration with a Registration Number good for one, two, or three years will
be issued for each statement.
The annual registration fee is $250 plus a $25 processing fee for each person meeting the Small
Business Administration’s (SBA) criteria for a small business and for not-for-profit organizations, and
$2,575 plus a $25 processing fee for each person that does not meet those criteria. Questions about
SBA size criteria can be answered by calling the SBA Office of Size Standards at (202) 205-6618.
Internet registration
You may obtain a registration number promptly over the internet. The DOT-recommended process
will enable you to print your Certificate of Registration with the new registration number after credit
card payment is verified. A copy of the certificate will be mailed to you, as well.
Registration methods
You may register by using one of the following methods:
• Complete form DOT F 5800.2 and mail it with payment of the appropriate fee to the address
given on the form. Submit your registration at least four weeks in advance of the date you
will need the registration certificate in order to allow sufficient time for the registration to be
processed and the certificate produced and mailed to you.
• Register on the internet at http://hazmat.dot.gov.register.htm.
Questions on the registration program and its requirements can be answered by calling (202)
366-4109.
HAZARDOUS MATERIALS–20F
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Recordkeeping
Each person subject to the program must maintain the following at his or her principal place of
business for three (3) years from the date of the certificate’s issuance:
• A copy of the registration statement filed with PHMSA, and
• The Certificate of Registration issued by PHMSA.
Motor carriers and persons who transport hazardous materials by vessel that are subject to the
registration requirements must carry on board each vehicle or vessel that is transporting a hazard-
ous material requiring registration:
• A copy of their current Certificate of Registration, or
• Another document bearing the registration number, identified as the “U.S. DOT Hazmat
Reg. No.”
Accidents and Incidents

Even when all possible precautions are taken, accidents and incidents can and will happen. And
when hazardous materials are involved, the risks to health and the environment are that much
greater. Because of this fact, the Hazardous Materials Regulations require hazmat employers to
train their hazmat employees on the proper procedures for responding quickly and safely to leaks,
spills, and other such emergencies. The regulations also require persons in physical possession of
the hazardous material to provide proper notification of hazardous material incidents. The informa-
tion provided by these notifications enhances the standards governing hazardous materials
transportation.
Carrier responsibility
Each carrier who transports or accepts for transportation a hazardous material, for which a shipping
paper is required, must instruct the operator of the vehicle, train, aircraft, or vessel to contact them
(the carrier) in the event of an incident involving the hazardous material.
Operator responsibility
Each operator of a vehicle, train, aircraft, or vessel should contact their employer (carrier) when
there is an incident involving hazardous materials.
Responsibility
The carrier is responsible for reporting any incident that occurs during the course of loading,
unloading, transportation, or temporary storage. An “incident” is any of the situations requiring a
telephone report as specified in Section 171.15 or any unintentional release of hazardous materials
from a package (including a tank). The type of report that must be filed — telephone and/or written
— will be dictated by the incident’s severity. Although it is not required, any interested person
(including the shipper) may file such reports.
HAZARDOUS MATERIALS–20G
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Accidents vs. incidents

It is important to understand that an “incident” may, or may not have been, the result of an accident.
It is also important to understand that each mode of transportation has specific accident reporting
procedures — which may apply to incidents. These procedures will typically be located in the
regulations regarding transportation safety.
Example In the case of highway transportation, accident reporting procedures are detailed in
the Federal Motor Carrier Safety Regulations. According to Section 390.15(b) of
these regulations, the carrier is required to maintain “ ... for a period of one year after
an accident occurs, an accident register containing at least the following information:
A list of accidents containing for each accident:
• Date of accident,
• City or town in which, or most near where, the accident occurred, and the state
in which the accident occurred,
• Driver name,
• Number of injuries,
• Number of fatalities, and
• Whether hazardous materials, other than fuel spilled from the fuel tanks of
vehicles involved in the accident, were released.”
Copies of all accident reports required by state or other governmental entities or insurers must also
be retained.
Telephone report
Incidents requiring report
As soon as practical, but no later than 12 hours after the occurrence of a reportable incident, each
person in physical possession of the hazardous material must notify authorities of each incident that
occurs during the course of transportation (including loading, unloading, and temporary storage)
that:
(1) As a direct result of hazardous materials:
• A person is killed.
• A person receives injuries requiring admittance to a hospital.
• An evacuation of the general public occurs lasting one or more hours.
• One or more major transportation arteries or facilities are closed or shut down for
one hour or more.
• The operational flight pattern or routine of an aircraft is altered.
(2) Fire, breakage, spillage, or suspected radioactive contamination occurs involving a ship-
ment of radioactive material.
(3) Fire, breakage, spillage, or suspected contamination occurs involving an infectious sub-
stance other than a diagnostic speciman or regulated medical waste.
(4) There has been a release of a marine pollutant in a quantity exceeding 450 L (119 gal) for
liquids, or 400 kg (882 lb) for solids.
HAZARDOUS MATERIALS–20H
3/11

(5) A situation exists of such a nature that, in the judgment of the person in possession of the
hazardous material, it should be reported even though it does not meet one of the above
conditions.
(6) During transportation by aircraft, a fire, violent rupture, explosion or dangerous evolution of
heat (i.e., an amount of heat sufficient to be dangerous to packaging or personal safety to
include charring of packaging, melting of packaging, scorching of packaging, or other
evidence) occurs as a direct result of a battery or battery-powered device.
Agency notification
The agency to notify may vary. The applicable telephone numbers are listed below.
Mode or Material Who to Notify

Air, rail, water & highway National Response Center (NRC) at 800-424-8802 (toll free) or 202-267-
2675 (toll call)
Infectious substances NRC at 800-424-8802 or 202-267-2675
or
Director of the Centers for Disease Control (CDC) at 800-232-0124 (toll
free)
To expedite the reporting procedure, the following checklist should be used by the individual making
the report.
HM INCIDENTS
Telephone Notification Checklist
When calling to report a hazardous material incident, be prepared to provide the following:
❏ Your name.
❏ Name and address of person you represent.
❏ Telephone number where you can be reached.
❏ Date, time, and location of the hazardous materials incident.
❏ Extent of injuries, if any.
❏ Class or division, proper shipping name, and quantity of hazardous materials involved, if
available.
❏ Type of incident and nature of hazardous materials involvement.
❏ Whether a continuing danger to life exists.
Written report
Incidents requiring report
Within 30 days of the date of discovery, the person in physical possession of the hazardous material
must submit a Hazardous Materials Incident Report for each incident that:
• Involves an unintentional release of a hazardous material or the discharge of any quantity
of hazardous waste.
• Involves a specification cargo tank with a capacity of 1,000 gallons or more that receives
structural damage to the lading retention system or damage that requires repair to a system
HAZARDOUS MATERIALS–20I
3/11

intended to protect the lading retention system, even if there is no release of hazardous
material.
• Is subject to the telephone reporting requirements.
• Involves the discovery of undeclared hazardous material.
• Results in a fire, violent rupture, explosion or dangerous evolution of heat (i.e., an amount
of heat sufficient to be dangerous to packaging or personal safety to include charring of
packaging, melting of packaging, scorching of packaging, or other evidence) occurs as a
direct result of a battery or battery-powered device.
Updating the incident report

A Hazardous Materials Incident Report must be updated within one year when:
• A death results from injury caused by a hazardous material.
• There was a misidentification of the hazardous material or package information on a prior
incident report.
• Damage, loss or related cost that was not known when the initial report was filed becomes
known.
• Damage, loss, or related cost changes by $25,000 or more, or 10% of the prior total
estimate, whichever is greater.
Incidents not requiring report

Unless a telephone report is required, an incident report is not required for:
• A release of a minimal amount of material from —
– A vent, for materials for which venting is authorized.
– The routine operation of a seal, pump, compressor, or valve.
– The connection or disconnection of loading or unloading lines, provided the
release does not result in property damage.
• An unintentional release of hazardous material when —
– The material is properly classed as ORM-D or a PG III material in Class or Division
3, 4, 5, 6.1, 8, or 9.
– Each package has a capacity of less than 20 liters (5.2 gallons) for liquids or less
than 30 kg (66 pounds) for solids.
– The total aggregate release is less than 20 liters (5.2 gallons) for liquids or less
than 30 kg (66 pounds).
– The material is not offered for transportation or transported by aircraft, a hazardous
waste, or an undeclared hazardous material.
Agency notification
In most instances, with some exception, incident reports may be filed by mail or online (https://
hazmatonline.phmsa.dot.gov/incident/). To submit a report by mail, use the address below. For
online filing, follow the instructions for submitting an incident report.
HAZARDOUS MATERIALS–20J
3/11

The Hazardous Materials Incident Report must be submitted to:

Information Systems Manager, PHH-63
Pipeline and Hazardous Materials Safety Administration
Department of Transportation
Washington, DC 20590-0001
Recordkeeping
A written or electronic copy of the Hazardous Materials Incident Report must be maintained for a
period of two (2) years at:
• The reporting person’s principal place of business, or if maintained somewhere else,
• Made available at the reporting person’s principal place of business within 24 hours of a
request by DOT.
Hazardous substance discharge notification

Any release of hazardous substances must be reported to the National Response Center at (toll
free) (800) 424-8802 or (toll) (202) 267-2675. Only spills of hazardous substances which equal or
exceed the designated reportable quantity are required to be reported, however, it is recommended
that all spills be reported. The report must be made as soon as a person has knowledge of the
discharge.
Releases of reportable quantities of an extremely hazardous substance listed in Title 40, Section
355.40, when they occur in transportation or storage incidental to transportation must be immedi-
ately reported to the local emergency planning committee if available or to the state emergency
planning commission, or as a last resort by dialing 911 or calling the operator.
Insurance Requirements
One of the items looked at during a DOT inspection is compliance with insurance requirements.
Proof of proper levels of insurance for your type of operation is also required (See 49 CFR 387.9).
Minimum insurance level requirements are as follows:
Schedule of Limits (Public Liability)
Type of carriage Commodity transported January 1, 1985
(1) For-hire (In interstate or foreign Property (nonhazardous) ................................................. $ 750,000

commerce, with a gross vehicle weight
rating of 10,001 or more pounds).
(2) For-hire and Private (In interstate, Hazardous substances, as defined in 49 CFR 171.8 transported in
foreign, or intrastate commerce, with a cargo tanks, portable tanks, or hopper-type vehicles with
gross vehicle weight rating of 10,001 or capacities in excess of 3,500 water gallons; or in bulk Division 1.1,
more pounds). 1.2, and 1.3 materials, Division 2.3, Hazard Zone A, or Division
6.1, Packing Group I, Hazard Zone A material; in bulk Division 2.1
or 2.2; or highway route controlled quantities of a Class 7 material,
as defined in 49 CFR §173.403 ......................................... 5,000,000
(3) For-hire and Private (In interstate or Oil listed in 49 CFR 172.101; hazardous waste, hazardous
foreign commerce: in any quantity; or in materials and hazardous substances defined in 49 CFR 171.8 and
intrastate commerce, in bulk only; with a listed in 49 CFR 172.101, but not mentioned in (2) above or (4)
gross vehicle weight rating of 10,001 or below ........................................................................
more pounds). 1,000,000
HAZARDOUS MATERIALS–20K
3/11

Schedule of Limits (Public Liability), Continued

Type of carriage Commodity transported January 1, 1985
(4) For-hire and Private (In interstate or Any quantity of Division 1.1, 1.2, or 1.3 material; any quantity of
foreign commerce, with a gross vehicle Division 2.3, Hazard Zone A, or Division 6.1, Packing Group I,
weight rating of less than 10,000 Hazard Zone A material; or highway route controlled quantities of a
pounds). Class 7 material as defined in 49 CFR 173.403 ....................... 5,000,000
Training Requirements
49 CFR Part 172, Subpart H requires training for all employees involved in the handling and
transportation of hazardous materials. The Hazardous Materials Regulations require training be
given by HAZMAT employers to all their HAZMAT employees regarding the safe transportation of
hazardous materials. This includes emergency response.
You are a HAZMAT employer if you use one or more of your employees in connection with:
• transporting hazardous materials in commerce;
• causing hazardous materials to be transported or shipped in commerce; or
• representing, marking, certifying, selling, offering, manufacturing, repairing, modifying,
reconditioning or testing containers, drums, or packagings for hazardous materials
transportation.
A HAZMAT employer includes an owner-operator of a motor vehicle who transports hazardous

materials in commerce. This term also includes any department, agency, or instrumentality of the
United States, a state, a political subdivision of a state, or an Indian tribe engaged in an activity
described above.
A HAZMAT employee includes an individual who works for a HAZMAT employer and who, in the
course of employment, has a direct effect on hazardous materials transportation safety. The term
includes an owner-operator of a motor vehicle who transports hazardous materials in commerce.
The term also includes an individual, including a self-employed individual, who works for a HAZMAT
employer and who, during the course of employment:
• loads, unloads, or handles hazardous materials;
• manufactures, tests, reconditions, repairs, modifies, marks, or otherwise represents con-
tainers, drums, or packagings as qualified for use in the transportation of hazardous
materials;
• prepares hazardous materials for transportation;
• is responsible for the safety of the transportation of hazardous materials; or
• operates a vehicle used to transport hazardous materials.
The purpose of this rule is to ensure that each HAZMAT employer trains its HAZMAT employees
regarding security, safe loading, unloading, handling, storing, and transporting of hazardous mate-
rials and emergency preparedness for responding to accidents or incidents involving the
transportation of hazardous materials.
HAZARDOUS MATERIALS–20L
3/11

Training
A hazmat employee is an individual, including a self-employed individual, who, during the course of
employment performs any function subject to the Hazardous Materials Regulations. Before any
hazmat employee performs any function subject to the Hazardous Materials Regulations the hazmat
employee must be trained, tested and certified by the hazmat employer. Recurrent training is
required once every three years.
However, if a new regulation is adopted or an existing regulation is changed, that relates to a

function performed by a hazmat employee, that employee must be instructed on the new or revised
regulations. This training must be completed before the employee performs the function and before
the employee’s three year recurrent training. The employee only needs to be instructed on the new
or revised requirements. Testing and recordkeeping for the new or revised requirements are not
required until the employee’s three year recurrent training.
An employee may perform hazmat job functions before completing hazmat training, provided:
• The employee does so under the direct supervision of a properly trained and knowledge-
able hazmat employee; and
• The hazmat training is completed within 90 days of employment or change in job function.
After completion of the training, each HAZMAT employer must certify, with appropriate documen-
tation, that each HAZMAT employee received training and was tested on appropriate areas of
responsibility. By requiring enhanced training, a HAZMAT employee’s awareness of safety consid-
erations and regulatory requirements is increased, thereby reducing the occurrence of hazardous
materials incidents caused by human error.
Training categories
Five specific training categories must be included in HAZMAT employee training.
General awareness/familiarization training

General awareness and familiarization training is intended to raise a HAZMAT employee’s aware-
ness of the HMR, and the purpose and meaning of hazard communication requirements. The result
will be an increased ability to recognize and identify hazardous materials in the workplace. In the
case of employees who recondition or test packagings, for example, such training would increase
their awareness of the importance of the functions they perform.
Function-specific training
Function-specific training is intended to teach the necessary knowledge, skills, and abilities for an
individual’s job function. For example, a HAZMAT employee responsible for executing hazardous
materials shipping papers will receive training on Subpart C of Part 172, including any shipping-
paper requirements that apply for the transportation modes (truck, ship, airplane) that the shipper
will use for the hazardous materials.
Safety training
Safety training is for HAZMAT employees who handle or transport packagings containing hazardous
materials during the course of transportation (e.g. packers and warehouse workers), and persons
who have the potential for exposure to hazardous materials as a result of a transportation accident
(for example, motor vehicle drivers, or members of a train crew).
3/11

This training provides information concerning the hazards posed by materials in the workplace,
under normal conditions, or in likely accident situations; it includes appropriate personal protection
measures. Training on DOT’s emergency response information is required. If applicable, it will also
cover methods, procedures for avoiding accidents, and any remedial actions necessary after a
release of hazardous materials.
This training is not intended to satisfy the training needs and requirements for HAZMAT employees
whose primary responsibilities involve emergency response (see OSHA’s 29 CFR 1910.120). Rath
er, it is intended to address those employees who may have limited responsibilities for emergency
response, such as notifying others of the emergency, using fire extinguishers, or taking immediate
action to mitigate the effects of an unintentional release of hazardous materials.
Employees who repair, modify, recondition, or test packagings may be excepted from safety training.
Security awareness training

This training must provide an awareness of security risks associated with hazardous materials
transportation and methods designed to enhance transportation security. This training must also
include a component covering how to recognize and respond to possible threats.
In-depth security training

Each hazmat employee of a person/company that is required to have a security plan must be trained
on the security plan and its implementation. This training must include company security objectives,
specific security procedures, employee responsibilities, actions to be taken in the event of a security
breach, and the organizational security structure.
In addition to the five training categories, modal-specific training requirements may be required by
the individual modes of transportation (air, rail, highway, or vessel).
For example, by highway, drivers must also be trained on the safe operation of the motor vehicle in
which they operate, or intend to operate, and the applicable requirements of the Federal Motor
Carrier Safety Regulations.
Training record
A record of current training, inclusive of the preceding three years, shall be created and retained by
the HAZMAT employer for each HAZMAT employee for the duration of employment, and for 90 days
thereafter. The record shall include all of the following:
• the HAZMAT employee’s name;
• the most recent training completion date of the HAZMAT employee’s training;
• a description, copy, or the location of the training materials used;
• the name and address of the person providing the training;
• certification that the HAZMAT employee has been trained and tested.
Reduce Vehicle Maintenance Shop Wastes

Vehicle maintenance involves handling and managing a wide variety of materials and wastes. Some
of these wastes can be toxic when improperly managed. No matter the amount of waste produced,
it is to the maintenance shop’s legal and financial advantage to manage the wastes properly and,
even more importantly, to prevent pollution.
3/11

The following tips can help make sure that shop wastes do not end up in the wrong place.
Oil
Recycle used oil. Set up equipment, such as a drip table or screen table with a used oil
collection bucket, to collect oils dripping off parts. Place drip pans underneath vehicles that are leak-
ing fluids onto the storage area.
Do not mix other wastes with used oil, except as allowed by the recycler.
Used oil generated by a shop may be burned on site in a commercial space heater. Also, used oil
(on- and off-specification and hazardous waste fuel) may be burned for energy recovery. Contact
state and local authorities to determine requirements and to obtain necessary permits.
Oil filters
Drain the oil filters for at least 24 hours. Crush and recycle used oil filters whenever possible.
Batteries
Recycle batteries by sending them to reclaimer or back to the distributor. Keeping shipping receipts
can demonstrate that you have recycled.
Store batteries in a water-tight, acid-resistant container. Inspect batteries for cracks and leaks when
they come in. Treat a dropped battery as if it were cracked.
Acid residue is hazardous because it is corrosive and may contain lead or other toxics. Neutralize
spilled acid (e.g., by using baking soda or lime) and dispose of as hazardous waste.
Metal residue from machining
Collect metal filings when machining metal parts. Keep separate and recycle if possible.
Prevent metal filings from falling into a storm drain.
Containers
Cap, label, cover, and properly store aboveground outdoor liquid containers and small tanks within
a diked area and on a paved, impermeable surface to prevent spills from running into surface or
ground water.
Other solids
Store materials such as scrap metal, old machine parts, and worn tires under a roof or tarpaulin to
protect them from the elements and to prevent the potential to create contaminated runoff. Consider
recycling tires by retreading them.
Liquid recycling
Collect and recycle coolants from radiators.
Store transmission fluids, brake fluids, and solvents containing chlorinated hydrocarbons separate-
ly, and recycle or dispose of them properly.
HAZARDOUS MATERIALS--23
9/05

ERG is Quick Guide for Transport Incidents

For most hazardous materials, emergency response information must be with the shipping papers.
This response information can be in any form, as long as all of the required information is present.
While not mandatory, the easiest way to provide this information during transport is to carry a cur-
rent Emergency Response Guidebook (ERG) with the shipping documents. If you ship or receive
loads of hazardous materials, it is important that you know how to find emergency information in this
book.
What is an ERG?
The ERG was developed for use by emergency personnel who may be the first to arrive at the
scene of an incident involving hazardous materials. It is primarily a guide to help first responders:
• quickly identify the specific or generic classification of the materials involved in an incident,
and
• protect themselves and the general public during this initial response phase of an incident.
The guidebook is also a convenient way to satisfy DOT’s emergency response information require-
ments.
What’s in the Book?

The guidebook is divided into sections coded by color. Yellow-bordered pages include a list of
dangerous goods in numerical order by ID number. Blue-bordered pages contain a list of danger-
ous goods in alphabetical order by material name. Once you find the chemical you are looking for,
a number is provided that tells you which “guide” to read for emergency information.
Orange-bordered pages provide safety recommendations for hazardous materials in individual
guides. Each guide provides safety and emergency response information in a two-page format:
• the left-hand page provides safety related information, and
• the right-hand page provides emergency response information for fires, spill or leak inci-
dents, and first aid.
Each guide covers a group of materials with similar chemical characteristics. The guide title identi-
fies the general hazards of the dangerous goods covered.
Understand the Guides

Each guide is divided into three main sections. The first section describes potential hazards the
material may display in terms of fire/explosion and health effects. The highest potential is listed first.
The second section outlines suggested public safety measures based on the situation. It provides
general information about isolation of the incident site, recommended protective clothing, and respi-
ratory protection. Suggested evacuation distances are listed for small and large spills and for fire
situations.
HAZARDOUS MATERIALS--24
9/05

The third section covers emergency response actions, including first aid. It outlines special pre-
cautions for incidents which involve fire, spills, or chemical exposure.
According to requirements of OSHA and EPA, first responders must be trained regarding the use of
this guidebook.
Hazardous Materials Audit Checklist

Are you a shipper of hazardous materials?
When you begin shipping new substances do you have procedures to determine
whether or not they are hazardous materials?
Do you have a person assigned to ensure that hazardous materials shipments
are correct in respect to:
Proper shipping name
Hazard class
Labeling
Packaging
Package marking and labeling
Shipping papers
Placarding
Provision of information to the carrier?
9/09

Reserved
9/09
HAZARDOUS WASTE OPERATIONS AND EMERGENCY

RESPONSE
CONTENTS
What Is HAZWOPER? ........................................................................................ 3

Scope: Does Your Operation Fall Under HAZWOPER? .......................................... 4
Applicability: Which Portions of HAZWOPER Apply?............................................ 7
Emergency Response to Hazardous Substance Releases ........................................ 7
Safety and Health Program ............................................................................ 8
Site Characterization and Analysis ................................................................. 10
Site Control .............................................................................................. 10
Training ................................................................................................... 11
Medical Surveillance ................................................................................... 13
Engineering Controls, Work Practices, and Personal Protective Equipment .............. 14
Monitoring................................................................................................ 14
Information Program................................................................................... 15
Handling and Labeling Drums and Containers .................................................. 16
Decontamination ........................................................................................ 17
Emergency Response for Uncontrolled Hazardous Waste Sites .............................. 17
Illumination .............................................................................................. 18
Sanitation of Temporary Workplaces ............................................................... 19
New Technology Program ............................................................................. 19
Treatment, Storage, and Disposal (TSD) Facilities.............................................. 19
Hazwoper Fact Sheet ........................................................................................ 20
Hazwoper Questions and Answers ........................................................................ 23
Scope....................................................................................................... 23
Safety and Health Program .......................................................................... 32
Emergency Response ................................................................................... 32
Training ................................................................................................... 34
Labels...................................................................................................... 40
Reporting and Recordkeeping ........................................................................ 41
Medical Surveillance ................................................................................... 42
General.................................................................................................... 43
A Closer Look at Training................................................................................... 45
General Training Objectives .......................................................................... 45
Initial and Refresher Training Requirements .................................................... 46
In-Plant Emergency Response ....................................................................... 48
Uncontrolled Hazardous Waste Sites............................................................... 57
Treatment, Storage, and Disposal (TSD) Facilities.............................................. 59
First Receiver Response ............................................................................... 60
Training Tools: Handouts, Tests, Puzzles, Posters, and Cartoons ............................ 66
A Closer Look at Emergency Response .................................................................. 97
Release of Hazardous Materials That Require an Emergency Response ................... 97
3/14 Hazardous waste operations and emergency response TOC–1

In-Plant Emergency Response...................................................................... 101

Spill Response.......................................................................................... 103
Emergency Response Procedures at TSD Facilities 1910.120 ............................... 111
Emergency Response Procedures at Uncontrolled Hazardous Waste Sites 1910.120(I)). 113
Appendix A: Requirements for Employers Who Plan to Evacuate Employees........... 158
Appendix B: Employee Alarm Systems. .......................................................... 160
Appendix C: Sample Emergency Action Plan Outline......................................... 161
Appendix D: Emergency Response Compliance Checklist.................................... 167
HAZWOPER Audit Checklist ............................................................................. 172
Select OSHA Letters of Interpretation ................................................................. 173
2–Hazardous waste operations and emergency response TOC 3/14

What is HAZWOPER?
Are there hazardous substances that could spill at your facility? If so, you are one of thousands
of companies nationwide that must comply with emergency planning, worker training, and other
requirements under OSHA’s Hazardous Waste Operations and Emergency Response
(HAZWOPER) standard.
The HAZWOPER Standard applies to five distinct groups of employers and their employees. This
includes any employees who are exposed or potentially exposed to hazardous substances — not
just hazardous waste — and who are engaged in one of the following operations:
• Emergency response operations for releases of, or substantial threats of release of, haz-
ardous substances regardless of the location of the hazard. This includes spills;
• Clean-up operations — required by a governmental body, whether federal, state, local, or
other involving hazardous substances — that are conducted at uncontrolled hazardous
waste sites;
• Corrective actions involving clean-up operations at sites covered by RCRA as amended
(42 U.S.C. 6901 et seq.);
• Voluntary clean-up operations at sites recognized by federal, state, local, or other govern-
mental body as uncontrolled hazardous waste sites; and
• Operations involving hazardous wastes that are conducted at treatment, storage, and dis-
posal (TSD) facilities regulated by 40 CFR 264 and 265 pursuant to RCRA, or by agencies
under agreement with EPA to implement RCRA regulations.
NOTE: According to the Occupational Safety and Health Administration (OSHA), the term “hazard-
ous waste operation” is not limited to uncontrolled hazardous waste sites, but includes responses
to uncontrolled releases of hazardous substances which become a waste once they are not
contained. HAZWOPER covers all emergency response whether it is performed at uncontrolled
hazardous waste sites or anywhere else, including, but not limited to, chemical and manufacturing
facilities and highways and railways.
The HAZWOPER Standard itself addresses three hazardous waste operation categories including
the following: hazardous waste sites, TSD facilities, and emergency response at any location. The
requirements for each category are specific to the operation each type of worker is to perform.
This chapter discusses OSHA’s requirements for hazardous waste operations and emergency
response and summarizes the steps an employer must take to protect the health and safety of
workers in these environments.
HAZWOPER--3
9/07

Scope: Does Your Operation Fall under HAZWOPER?

Operations and activities conducted at indi- QUESTION #1 QUESTION #2
vidual worksites and locations are evaluated REGULATED WORKSITE REASONABLE POSSIBILITY
to determine if they fall under the HAZWOP- OR LOCATION? FOR EXPOSURE?
ER Standard based on an understanding of Is the actual worksite or

location:
Does the activity:
the scope of the standard as stated in A required cleanup of an Pose a reasonable

29 CFR 1910.120(a) and the possibility for uncontrolled hazardous
waste site, including
possibility for exposure?
worker exposure to safety and health haz- investigation of areas of

known or suspected
OR
ards from hazardous waste or emergency contaminaion to

determine the presence
YES Inherently imply YES
HAZWOPER
response operations. Determining coverage
exposure?
of hazardous susbstances?
under 29 CFR 1910.120(a) can be simpli-

TO
A RCRA corrective action
fied through the use of Figure 1 and two cleanup site? Hazardous wastes or
substances?
implied questions. The answer to each A voluntary cleanup of a
Government-recognized, Safety and health hazards
question must be “yes” for the operation or uncontrolled cleanup site? resulting from hazardous
waste operations?
activity to fall under HAZWOPER. A RCRA TSD facility with
operations that involve
hazardous wastes or
Scope and application of the HAZWOPER

substances?
Standard can be determined by making in- An emergency response

operation involving the NO
formed judgments about the regulatory sta- release (or substantial

threat of release) of
tus of individual worksites, the nature of the hazardous wastes or
substances?
activities being performed, and the possibil- NO
ity of worker exposure.
OPERATION NOT UNDER SCOPE OF HAZWOPER
Figure 1 — Determining OSHA HAZWOPER Scope.

Question 1 Discussion Points:
• If the project is at a worksite or location that is a cleanup of an EPA National Priorities List
(NPL) or State priority list site or within a RCRA-regulated TSD facility, the answer to this
question is “yes.” (The answer would also be “yes” for voluntary or government-required
cleanups or initial investigations to determine the absence or presence of hazardous
wastes or substances.)
• If the project is a corrective action involving cleanup at a RCRA TSD facility where releases
to the environment involving hazardous wastes and substances have occurred, the answer
is “yes.”
• If a facility or site does not meet the criteria to be placed on a priority site list, emergency
response and cleanup is still covered under the HAZWOPER Standard if uncontrolled haz-
ardous wastes or substances are present or suspected of being present. For these types of
worksites the answer is “yes.”
Question 2 Discussion Points:
• HAZWOPER applies only where exposure to hazardous wastes and substances or to
health and safety hazards resulting from operations are likely. This can be determined by
analysis of monitoring date, by hazard characterization or hazard analysis and exposure
assessment by a competent person, or by limiting access. If there is exposure or a reason-
able possibility for exposure, the answer to this question is “yes.”
HAZWOPER--4
9/07

• Some activities are inherently covered by the OSHA HAZWOPER Standard. Emergency
response usually means that contaminants exist in quantities that pose a hazard. Emer-
gency responders thus have a reasonable possibility for exposure. Hazardous waste man-
agement likewise implies HAZWOPER coverage. For these activities, the answer to this
question is “yes.” For example, drum-handling and similar tasks that are controlled by op-
erational safety procedures and that occur within a building’s envelope are generally not
covered. Likewise, small, localized spills (e.g., from a five-gallon pail) that are readily con-
trolled by workers normally assigned to the operation are generally not covered. However,
large, uncontrolled spills or removals of drums that occur outside the building’s envelope
are covered.
Exposure in Relation to Scope
A conceptual understanding that relates expo-
sure to regulatory scope simplifies answering
the above questions. When determining the
scope of the HAZWOPER Standard, exposure
has two elements — the presence of a hazard ACCESS
and worker access to the hazard. See Figure 2.
HAZARD + TO
HAZARD
For example, contaminated areas of a hazard-

EXPOSURE
ous waste site potentially pose health hazards.
For exposure to occur, workers must have ac-
cess to the hazard (e.g., they work in contami-
nated areas). Under normal circumstances, HAZARD +
workers who are prevented from entering con-
taminated areas are not exposed and do not fall
under the standard, provided that they are not NO EXPOSURE
exposed to safety or health hazards resulting
from the hazardous waste operation. Converse-
ly, workers in contaminated areas are covered Figure 2 — The Two Elements of Exposure
because they have access to health hazards
and could be exposed.
Safety hazards are treated in the same manner. Workers who work in trenches in clean areas of
the site would be covered by the OSHA Trenching Standard (29 CFR 1926 Subpart P). Workers
who work in trenches in contaminated areas would fall under both the OSHA Trenching and HA-
ZWOPER Standards. Workers who do not work in trenches fall under the HAZWOPER Standard
only when working in contaminated areas and would not be covered by either standard when work-
ing solely in clean areas, provided they are not exposed to safety hazards resulting from hazard-
ous waste operations.
For example, truck drivers at a plant haul clean clay fill to a clean fill area within the exclusion zone
of a hazardous waste operation. The drivers are under instructions not to leave their trucks, and
they are prevented from driving through contaminated areas. Monitoring data indicate that these
workers have no reasonable possibility for exposure to hazardous wastes or substances. There-
fore, the hauling operation is not covered by OSHA HAZWOPER since the truck drivers are not
exposed to hazardous wastes or substances. The truck drivers are exposed to safety hazards that
are a result of the hauling operation, not the hazardous waste operation. The truck drivers must
successfully complete appropriate training (e.g., the site-specific briefing, general employee train-
HAZWOPER--5
9/07

ing, and defensive driving training), but no core HAZWOPER training is required. The procedures
truck drivers follow are documented in the written Safety and Health Program under 29 CFR
1910.120(b). A competent person should periodically monitor the hauling operation to verify that
the workers continue to have no reasonable possibility for exposure.
Another example is utility workers servicing an electrical
box located in an exclusion zone. Hazard characterization
and exposure assessment performed by a competent per-
son show that the area surrounding the box and an access
corridor leading to the box can be cleaned such that the util-
ity workers can work in the area and transit the corridor
without possible exposure to hazardous wastes and sub-
stances. The work can be carried out as a normal mainte-
nance operation. The area and corridor are free of safety
hazards arising from hazardous waste operations. The
work does not fall under the HAZWOPER Standard. In essence, the area and corridor constitute a
temporary support zone. Since the work involves electrical utilities, it would fall under the OSHA
Electrical standard (29 CFR 1910 Subpart S). Administrative controls such as HAZWOPER-trained
escorts are used to make certain that the utility workers are not exposed to any hazards from the
hazardous waste operation. The proce-dures to be followed are to be documented in the Safety
and Health Program.
This type of analysis excludes many routine activities from the jurisdiction of the OSHA
HAZWOPER Standard while continuing to provide adequate and appropriate worker protection.
The HAZWOPER Standard does not cover clerical or support personnel, workers at the perimeter
of a hazardous waste worksite, or workers engaged in construction activities in uncontaminated
areas, provided they are not exposed or possibly exposed to hazards resulting from hazardous
waste operations.
Once a hazardous waste site or area is characterized, employees are not covered by the standard
if they:
• Work exclusively within uncontaminated areas of the hazardous waste site;
• Do not enter areas where hazardous waste may exist, is stored, or is processed; and
• Are not exposed or potentially exposed to health or safety hazards related to hazardous
waste operations.
If you have employees who are not at risk of exposure, they need not be trained in HAZWOPER.
This is determined by site characterization. Site characterization is to be accomplished by compe-
tent individuals.
HAZWOPER--6
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Applicability: Which Portions of HAZWOPER Apply?

HAZWOPER is a performance-based standard. Once the decision is made that an operation falls
under the Standard, the appropriate paragraphs of the standard are applied to specific activities.
See Table 1:
Table 1 — Applicability of HAZWOPER Standard

If the scope determination is: Scope is also called: Then follow section(s):
1910.120(a)(1)(i) or 1926.65(a)(1)(i) Clean-up operations at government uncontrolled hazard- 1910.120(b) to (o) or
ous waste sites 1926.65(b) to (o)
1910.120(a)(1)(ii) or 1926.65(a)(1)(ii) Corrective actions involving clean-up operations at RCRA 1910.120(b) to (o) or
sites 1926.65(b) to (o)
1910.120(a)(1)(iii) or 1926.65(a)(1)(iii) Voluntary clean-up operations at sites recognized by the 1910.120(b) to (o) or
government as uncontrolled hazardous waste sites 1926.65(b) to (o)
1910.120(a)(1)(iv) or 1926.65(a)(1)(iv) Hazardous waste operations at RCRA TSD facilities 1910.120(p)* or 1926.65(p)*
1910.120(a)(1)(v) or 1926.65(a)(1)(v) Hazardous substance emergency response operations 1910.120(q)** or 1926.65(q)**
* See exceptions listed under 1910.120(a)(2)(iii) or 1926.65(a)(2)(iii). ** See exception listed under 1910.120(q)(1) or 1926.65(q)(1).
When the applicability of the HAZWOPER Standard is being determined, OSHA stipulates that if
there is conflict or overlap with another standard, the provision more protective of worker health
and safety applies. For example, in considering workers in contaminated areas of the site who
work on scaffolds, the OSHA Scaffolding Standards are more protective than the HAZWOPER
Standard for safety hazards resulting from working on scaffolds. The HAZWOPER Standard is
more protective for health hazards resulting from the contamination. The applicable provisions of
both standards would apply to the work.
Here is another example. An environmental remediation planned at an NPL-listed site falls within
the scope of the OSHA HAZWOPER Standard. The worksite includes an abandoned building that
has been slated for renovation for use as a storage facility for later operations. The building con-
tains concrete walls with lead-based paint covering them. The building also contains large quanti-
ties of friable asbestos in the ceiling insulation and pipe wrappings. There are no other hazardous
substances or wastes present in the buildings. For asbestos removal, the provisions of the OSHA
Asbestos Standard are more protective of worker health and safety than are the more general pro-
visions of the OSHA HAZWOPER Standard. The Safety and Health Program, therefore, provides
that the asbestos removal tasks conducted inside the building will be performed in full accord with
the OSHA Asbestos Standard and not HAZWOPER. After the asbestos has been removed, the
lead-based paint will be removed. Again, the provisions of the OSHA Standard for lead removal
are more protective of worker health and safety than are the more general provisions of the OSHA
HAZWOPER Standard. Therefore, the removal of the lead-based paint inside the building will be
performed in full compliance with the OSHA Lead Standard, and not HAZWOPER.
Emergency Response to Hazardous Substance Releases
If an employer plans to evacuate its employees during a hazardous substance release and has a
written Emergency Action Plan in accordance with §1910.38, the employer is exempt from the re-
quirements of §1910.120(q), Emergency Response to Hazardous Substance Releases. If not, the
employer must develop and implement an Emergency Response Plan before taking on any emer-
gency response operations. This plan must be designed to handle anticipated emergencies, in
writing, and available for inspection and copying by employees, their representatives, and OSHA
personnel.
HAZWOPER--7
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An emergency response plan must address at least the following:
• Pre-emergency planning and coordination • Evacuation routes and procedures;

with outside parties;
• Decontamination;
• Personnel roles, lines of authority, training,
and communication; • Emergency medical treatment and first aid;
• Emergency recognition and prevention; • Emergency alerting and response

procedures;
• Safe distances and places of refuge;
• Critique of response and follow-up; and
• Site security and control;
• PPE and emergency equipment.
Employers must have a site-specific incident command system for handling emergency
responses. This system defines the roles of the personnel engaged in emergency response and
their duties. These personnel must have the required training and PPE. If post-emergency
response operations are to be done onsite using workplace employees, they must be appropriate-
ly trained for the tasks involved and have appropriate equipment, including PPE.
Safety and Health Program
An effective and comprehensive safety and health program is essential in reducing work-related
injuries and illnesses and in maintaining a safe and healthful work environment. The HAZWOPER
Standard, therefore, requires each employer to develop and implement a written safety and health
program, in accordance with §1910.120(b) or §1926.65(b), that identifies, evaluates, and controls
safety and health hazards and provides emergency response procedures for each hazardous
waste site or treatment, storage, and disposal facility. Note that paragraph (b) applies only to those
operations that fall under the scope of paragraphs (a)(1)(i), (ii), and/or (iii).
This written program must include specific and detailed information on the topics listed in
§1910.120(b)(1)(ii). See Figure 3 for a complete list of topics.
HAZWOPER--8
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Comprehensive Safety and Health Program Site-Specific Safety and Health Plan
The HAZWOPER regulations at 29 CFR The plan implements certain components

§1910.120(b)(1) require a comprehensive of the safety and health program on a site-
health and safety program that includes: specific basis. The plan includes:
S Safety and health risk analysis

S Site control measures
S Organizational structure S Training assignments
S Comprehensive workplan S Medical surveillance requirements

S Personal protective equipment
S Site-specific safety and
S Air and employee monitoring
health plan
S Spill containment program
S Safety and health training program S Confined space procedures
S Medical surveillance program S Decontamination procedures
S Standard operating procedures S Emergency response plan
S Coordination procedures
Figure 3 — Safety and Health Program: Comprehensive and Site-Specific Components
Let’s go over safety and health program elements briefly:

• Organizational structure — Establishes a chain of command and specifies the overall re-
sponsibilities of supervisors and employees. The organizational structure is reviewed and
updated as necessary to reflect current operations. See §1910.120(b)(2) and
§1926.65(b)(2) for details.
• Comprehensive workplan — Addresses the tasks and objectives of site operations, includ-
ing clean-up activities and normal operations. Also includes methods, logistics, and re-
sources required to perform tasks and reach objectives. See §1910.120(b)(3) and
§1926.65(b)(3) for details.
• Site-specific safety and health plan — Addresses safety and health hazards of each phase
of site operation. Includes the requirements and procedures for employee protection. See
§1910.120(b)(3) and §1926.65(b)(3) for details.
• Safety and health training program — Addresses contents and logistics for initial, equiva-
lent, and refresher training, as well as briefings for visitors and workers. See
§1910.120(b)(1)(ii)(D) and §1910.120(e) and §1926.65(b)(1)(ii)(D) and §1926.65(e).
HAZWOPER--9
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• Medical surveillance program — Ensures that the health of employees is monitored and
documented before, during, and at termination of work on the site. Addresses initial, peri-
odic, illness/injury, and termination examinations. Also addreses information provided to
the physician, the physician’s opinion, and medical records. See §1910.120(b)(1)(ii)(E) and
§1910.120(f) and §1926.65(b)(1)(ii)(E) and §1926.65(f).
• Standard operating procedures — Identify the personnel positions responsible for tasks
and specific instructions for performing those tasks safely. Examples include procedures
for emergency shutdown, PPE selection and use, decontamination, collecting samples,
documenting data, and handling releases and cleanup. See §1910.120(b)(1)(ii)(F) and
§1926.65(b)(1)(ii)(F) for details.
• Coordination between the safety and health program and site-specific activities — Ensures
that the written safety and health plan is revised as necessary and accurate for each site.
See §1910.120(b)(1)(ii)(G) and §1926.65(b)(1)(ii)(G) for details.
While OSHA does not state directly that the written safety and health program must be reviewed
and updated for accuracy and effectiveness, it is a good practice to hold periodic review and revi-
sion. The program must be made available to all affected employees, contractors and subcontrac-
tors. The employer also must inform contractors and subcontractors, or their representatives, of
any identifiable safety and health hazards or potential fire or explosion hazards before they enter
the work site.
Site Characterization and Analysis
Site characterization and analysis, both initial and periodic, is crucial to the safety and health of
workers. A requirement of the standard at §1910.120(c) and §1926.65(c), site characterization and
analysis provides employers with the information needed to identify site hazards so they can select
appropriate protection methods for employees.
It is extremely important — and required — that a trained person con-
duct a preliminary evaluation of an uncontrolled hazardous waste site
before entering the site. The evaluation must include all suspected
conditions that are immediately dangerous to life or health or that may
cause serious harm to employees (e.g., confined space entry, poten-
tially explosive or flammable situation, visible vapor clouds, etc.). As
available, the evaluation must include the location and size of the site,
site topography, site accessibility by air and roads, pathways for haz-
ardous substances to disperse, a description of worker duties, and the
time needed to perform a given task, as well as the present status and
capabilities of the emergency response teams. Periodic reevaluations should also be conducted
as conditions or operations change.
Site Control
Controlling the activities of workers and the movement of equipment is an important aspect of the
HAZWOPER Standard. Effective control of the site will minimize potential contamination of work-
ers, protect the public from hazards, and prevent vandalism. The following information is useful in
implementing the site control program: a site map, site work zones, site communication, safe work
practices, and the name, location and phone number of the nearest medical assistance.
HAZWOPER--10
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The use of a “buddy system” is also required as a protective measure to assist in the rescue of an
employee who becomes unconscious, trapped, or seriously disabled on site. In the buddy system,
two employees must keep an eye on each other and only one should be in a specific dangerous
area at one time, so that if one gets in trouble, the second can call for help.
See §1910.120(d) and §1926.65(d) for more information on site control.
Training
Training makes workers aware of the potential hazards they may encounter and provides the nec-
essary knowledge and skills to perform their work with minimal risk to their safety and health. As
part of the safety and health program, employers are required to develop and implement a pro-
gram to inform workers (including contractors and subcontractors) who are exposed to safety and
health hazards during hazardous waste operations of the level and degree of exposure they are
likely to encounter.
Both supervisors and workers must be trained to:
• Know the names of personnel and alternates
responsible for site safety and health,
• Know and recognize hazards present at the site,
• Use personal protective equipment,
• Understand and apply work practices to minimize
risks from hazards,
• Use engineering controls and equipment safely,
• Understand medical surveillance requirements, including recognition of symptoms and
signs which might indicate overexposure to hazards,
• Use proper decontamination procedures,
• Understand the emergency response plan,
• Use proper confined space entry procedures, and
• Understand the spill containment program.
The amount of instruction differs with the nature of the work operations and the roles and responsi-
bilities of the employee. These levels of training are specified in §1910.120(e), §1926.65(e), and
Table 2.
HAZWOPER--11
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Table 2 — Training requirements for RCRA-licensed sites and

government-mandated uncontrolled hazardous waste operations
Employee type: Training: Training time: §1910.120

or
§1926.65:
General site employees
p y Initial off-site training 40 hours ((e)(3)(i)
)( )( )
Field experience 3 days
Annual refresher 8 hours (e)(8)
Routine site employees
p y (minimal
( ex- Initial off-site training 24 hours ((e)(3)(iii)
)( )( )
posure)) Field experience 1 day
Non-routine site employees
p y Initial off-site training 24 hours ((e)(3)(ii)
)( )( )
Field experience 1 day
Supervisors/Managers
p / g of general
g site Initial training 40 hours ((e)(4)
)( )
employees
l Field experience 3 days
Hazardous waste management training 8 hours
p / g of routine site Initial training 24 hours ((e)(4)
)( )
employees
l ((minimal
i i l exposure)) Field experience 1 day
p / g of non-routine Initial training 24 hours ((e)(4)
)( )
site
it employees
l Field experience 1 day
Emergency response personnel Initial training No minimum training (e)(7)
time specified
Trainers Have either: training course on subjects, and/or cre- No minimum training (e)(5)
dentials and experience to demonstrate competency time specified
NOTE: Table 2 only covers training in accordance with §1910.120(e) and §1926.65(e). The table
does not include training requirements at §1910.120(p) and §1926.65(p) for TSD facilities or
§1910.120(q) and §1926.65(q) for emergency response operations.
Employees at all sites must not perform any hazardous waste operation unless they have been
trained to the level required by their job function and responsibility and have been certified by their
instructor as having completed the necessary training.
Employees who receive the training specified in §1910.120(e) or §1926.65(e) must be given a writ-
ten certificate upon successful completion of that training. That training need not be repeated if the
employee goes to work at a new site; however, the employee must receive whatever additional
training is needed to work safely at the new site. Employees who worked at hazardous waste sites
before 1987 and received equivalent training need not repeat the initial training specified in Table
2, if the employer can demonstrate that in writing and certify that the employee has received such
training.
In August 1994, OSHA issued non-mandatory training guidelines to §1910.120 and §1926.65 in
the form of an appendix. The Appendix E — Training Curriculum Guidelines provides supplemen-
tary information that can be used by employers for program development directed toward training
those employees engaged in hazardous waste operations and emergency response activities.
These guidelines are not site-specific; therefore, additional standards must be consulted to
achieve total compliance.
HAZWOPER--12
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Medical Surveillance
Medical surveillance, in accordance with §1910.120(f) and §1926.65(f), will help to assess and
monitor the health and fitness of employees working with hazardous substances. The employer
must establish a medical surveillance program for the following:
• All employees exposed or potentially exposed to hazardous substances or health hazards
above the permissible exposure limits for more than 30 days per year;
• Workers exposed above the published exposure levels (if there is no permissible exposure
limit for these substances) for 30 days or more a year;
• Workers who wear approved respirators for 30 or more days per year on site;
• Workers who are exposed to unexpected or emergency releases of hazardous wastes
above exposure limits (without wearing appropriate protective equipment) or who show
signs, symptoms or illness that may have resulted from exposure to hazardous sub-
stances; and
• Members of hazardous materials (HAZMAT) teams.
All examinations must be performed under the supervision of a licensed physician, without cost to
the employee, without loss of pay, and at a reasonable time and place. Examinations must include
a medical and work history with special emphasis on symptoms related to the handling of hazard-
ous substances and health hazards and to fitness for duty including the ability to wear any required
personal protective equipment under conditions that may be expected at the work site. These ex-
aminations must be given as follows:
• Prior to job assignment and annually thereafter (or every
two years if a physician determines that is sufficient),
• At the termination of employment, if the employee has not
had an examination within the last six months.
• Before reassignment to an area where medical examina-
tions are not required, if the employee has not had an ex-
amination within the last six months,
• If the examining physician believes that a periodic followup
is medically necessary, and
• As soon as possible for employees injured or becoming ill from exposure to hazardous sub-
stances during an emergency, or who develop signs or symptoms of overexposure from
hazardous substances.
The employer must give the examining physician a copy of the standard and its appendices, a
description of the employee’s duties relating to his/her exposure, the exposure level or anticipated
exposure level, a description of any personal protective and respiratory equipment used or to be
used, and any information from previous medical examinations.
HAZWOPER--13
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The employer must obtain a written opinion from the physician that contains the results of the med-
ical examination and any detected medical conditions that would place the employee at an in-
creased risk from exposure, any recommended limitations on the employee or upon the use of
personal protective equipment, and a statement that the employee has been informed by the phy-
sician of the results of the medical examination. The physician is not to reveal in the written opinion
given to the employer specific findings or diagnoses unrelated to employment.
Engineering Controls, Work Practices, and Personal Protective Equipment

To the extent feasible, the employer must institute engineering
controls and work practices to help reduce and maintain em-
ployee exposure at or below permissible exposure limits. To the
extent not feasible, engineering and work practice controls may
be supplemented with personal protective equipment (PPE).
Examples of suitable and feasible engineering controls include
the use or pressurized cabs or control booths on equipment,
and/or remotely operated materials handling equipment. Exam-
ples of safe work practices include removing all non-essential
employees from potential exposure while opening drums, wetting down dusty operations, and
placing employees upwind of potential hazards.
Personal protective equipment must be selected and appropriate to the requirements and limita-
tions of the site, the task-specific conditions and duration, and the hazards and potential hazards
identified at the site. As necessary, the employer must furnish the employee with positive-pressure
self-contained breathing apparatus or positive-pressure air-line respirators equipped with an es-
cape air supply, and with totally encapsulating chemical protective suits.
OSHA calls for a written personal protective program at §1910.120(g)(5) and §1926.65(g)(5) for all
employees involved in hazardous waste operations. As mentioned earlier, this program is part of
the site-specific safety and health plan. The personal protective equipment program must include
an explanation of equipment selection and use, maintenance and storage, decontamination and
disposal, training and proper fit, donning and doffing procedures, inspection, in-use monitoring,
program evaluation, and equipment limitations.
See §1910.120(g) and §1926.65(g) for more on PPE.
Monitoring
Airborne contaminants can present a significant threat to employee safety and health, thus making
air monitoring an important component of an effective site-specific safety and health plan. The em-
ployer must conduct monitoring before site entry at uncontrolled hazardous waste sites to identify
conditions immediately dangerous to life and health, such as oxygen-deficient atmospheres and
areas where toxic substance exposures are above permissible limits. Accurate information on the
identification and quantification of airborne contaminants is useful for the following:
• Selecting personal protective equipment,
• Delineating areas where protection and controls are needed,
HAZWOPER--14
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• Assessing the potential health effects of exposure, and

• Determining the need for specific medical monitoring.
After a hazardous waste cleanup operation begins, the employer must periodically monitor those
employees who are likely to have higher exposures to determine if they have been exposed to
hazardous substances in excess of permissible exposure limits. The employer must periodically
monitor for any potential condition that is immediately dangerous to life and health or for higher
exposures that may occur as a result of new work operations.
Table 3 — Atmospheric hazard action guides
Monitoring Equipment: Atmospheric Level: Action:

Hazarda:
Combustible gas indicator Explosive < 10% LELb Continue monitoring with caution.
10 2 % LEL
10-25% Continue
C i monitoring,
i i b
but with
i h extreme caution,
i especially
i ll as
higher levels are encountered.
> 25% LEL Explosion hazard! Withdraw from area immediately.
Oxygen level ——— < 19.5% Monitor wearing SCBA. NOTE: Combustible gas readings not
valid in atmospheres with less than 19.5% oxygen.
19.5-25% Continue monitoring with caution. SCBA not needed based
only on oxygen content.
content
> 25% Discontinue monitoring. Fire potential! Consult specialist.
Radiation survey Gamma radiation Above
instrument background:
< 1 mR/hr Continue monitoring. Consult a health physicist.
² 1 mR/hr Withdraw. Continue monitoring only upon the advice of a
Health Physicist.
Colorimetric tubes Organic & inorganic Depends on Consult reference manuals for air concentration vs. PEL/TLV
vapors/gases chemical and toxicity data.
Photoionization detector Organic vapors/gases Depends on Consult reference manuals for air concentration vs. PEL/TLV
chemical and toxicity data.
Flame ionization detector Organic vapors/gases Depends on Consult reference manuals for air concentration vs. PEL/TLV
chemical and toxicity data.
a NOTE: Hazard classes are general and not all compounds in these classes can be measured by realtime instruments.
b LEL = lower explosive limit.
NOTE: The correct interpretation of any instrument readout is difficult. If the instrument operator is uncertain of the significance of a
reading, especially if conditions could be unsafe, a technical specialist should immediately be consulted. Consideration should
be given to withdrawing personnel from the area until approval by the safety officer is given to continue operations.
See §1910.120(h) and §1926.65(h) for more information.
Information Program
According to §1910.120(i), “Employers shall develop and implement a program . . . to inform em-
ployees, contractors, and subcontractors (or their representative) actually engaged in hazardous
waste operations of the nature, level and degree of exposure likely as a result of participation in
such hazardous waste operations. Employees, contractors and subcontractors working outside of
the operations part of a site are not covered by this standard.”
HAZWOPER--15
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Employees will normally be informed as part of their initial and refresher training required under
§1910.120(e). However, §1910.120(i) is intended to cover employees who are exposed to greater
hazards than the general employee population. The information program should concentrate on those
substances which will create the greater risk to the employee, either because of their greater hazards
or because of the likely higher degree of exposure, and for which precautions are most essential.
The identification of exposure level provisions are tied in with the monitoring provision, and there is no
requirement to make risk estimates or to undertake original research on the degree of risks. The re-
quirement is to inform the employee, contractor, or subcontractor of estimates in the literature in order
to manage their operations properly. Therefore, extensive literature searches should not be necessary.
See §1910.120(i) and §1926.65(i).
Handling and Labeling Drums and Containers
Prior to handling a drum or container, the employer must assure that drums or containers meet the
required OSHA, EPA (40 CFR 264 to 265), and Department of Transportation (DOT) regulations
(49 CFR 171 to 180), and are properly inspected and labeled. Damaged drums or containers must
be emptied of their contents, using a device classified for the material being transferred, and must
be properly discarded. In areas where spills, leaks, or ruptures occur, the employer must furnish
employees with salvage drums or containers, a suitable quantity of absorbent material, and ap-
proved fire-extinguishing equipment in the event of small fires.
The employer must also inform employees of the appropriate hazard warnings of labeled drums, the
removal of soil or coverings, and the dangers of handling unlabeled drums or containers without prior
identification of their contents. To the extent feasible, the moving of drums or containers must be kept
to a minimum, and a program must be implemented to contain and isolate hazardous substances
being transferred into drums or containers. In addition, an approved EPA ground-penetrating device
must be used to determine the location and depth of any improperly discarded drums or containers.
The employer must also ensure that safe work practices are instituted before opening a drum or con-
tainer. For example, air-line respirators and approved electrical equipment must be protected from
possible contamination, and all equipment must be kept behind any existing explosion barrier — a
physical barricade, natural or man-made, that has been designed and constructed of sufficient thick-
ness and density to withstand or deflect the impact loads of an adjacent explosion. Only tools or
equipment that prevent ignition shall be used. All employees not performing the operation shall be
located at a safe distance and behind a suitable barrier to protect them from accidental explosions.
In addition, standing on or working from drums or containers is prohibited. Special care also must
be given when an employee handles containers of shock-sensitive waste, explosive materials, or
laboratory waste packs. Where an emergency exists, the
employer must ensure the following:
• Evacuate non-essential employees from the transfer

area;
• Protect equipment operators from exploding
containers by using a barrier, and
HAZWOPER--16
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• Make available a continuous means of communication (e.g., suitable radios or tele-

phones), and a distinguishable and distinct alarm system to signal the beginning
and end of activities where explosive wastes are handled.
If drums or containers bulge or swell or show crystalline material on the outside, they must
not be moved onto or from the site unless appropriate containment procedures have been
implemented. In addition, lab packs must be opened only when necessary and only by a
qualified person. Prior to shipment to a licensed disposal facility, all drums or containers
must be properly labeled and packaged for shipment. Staging areas also must be kept to a
minimum and provided with adequate access and egress routes.
See §1910.120(j) and §1926.65(j) for more information.
Decontamination
Decontamination procedures are a component of the site-specific safety and health plan and,
consequently, must be developed, communicated to employees, and implemented before
workers enter a hazardous waste site. As necessary, the site safety and health officer must
require and monitor decontamination of the employee or decontamination and disposal of
the employee’s clothing and equipment, as well as the solvents used for decontamination,
before the employee leaves the work area.
If an employee’s nonimpermeable clothing becomes grossly contaminated with hazardous
substances, the employee must immediately remove that clothing and take a shower. Imper-
meable protective clothing must be decontaminated before being removed by the employee.
Protective clothing and equipment must be decontaminated, cleaned, laundered, maintained,
or replaced to retain effectiveness. The employer must inform any person who launders or
cleans such clothing or equipment of the potentially harmful effects of exposure to hazardous
substances.
Employees (in general industry or construction) who are required to shower must be pro-
vided showers and change rooms that meet the requirements of 29 CFR 1910.141,
Sanitation. See the OSHA tab for §1910.141. In addition, unauthorized employees must not
remove their protective clothing or equipment from change rooms unless authorized to do so.
See §1910.120(k) and §1926.65(k) for more information.
Emergency Response for Uncontrolled Hazardous Waste Sites

Proper emergency planning and response are important elements of the site-specific safety
and health plan that help minimize employee exposure and injury. The HAZWOPER Stan-
dard requires that the employer develop and implement a written emergency response plan
to handle possible emergencies before performing hazardous waste operations. The plan
must include, at uncontrolled hazardous waste sites, the following elements:*
• Personnel roles, lines of authority, and communication procedures,
• Pre-emergency planning,
*Emergency response to the release of hazardous substances beyond clean-up must also have plans that include these
elements and other specific requirements as indicated in §1910.120(p)(8) and/or §1910.120(q).
3/14 HAZWOPER–17

• Emergency recognition and prevention,

• Emergency medical and first-aid treatment,
• Methods or procedures for alerting onsite
employees,
• Safe distances and places of refuge,
• Site security and control,
• Decontamination procedures,
• Critique of response and follow-up,
• Personal protective and emergency equip-
ment, and
• Evacuation routes and procedures.
In addition to the above requirements, the plan must include site topography, layout, and
prevailing weather conditions; and procedures for reporting incidents to local, state, and fed-
eral government agencies.
The procedures must be compatible with and integrated into the disaster, fire, and/or emer-
gency response plans of the site’s nearest local, state, and federal agencies. Emergency
response organizations may use the local or state emergency response plans, or both, as part
of their emergency response plan to avoid duplication of federal regulations.
See §1910.120(l) and §1926.65(l) for more information.
Illumination
According to §1910.120(m) and §1926.65(m), areas accessible to employees shall be lighted to
not less than the minimum illumination intensities listed in Table 4 while any work is in
progress:
Table 4 — Minimum Illumination Intensities in Foot-Candles
Foot-candles: Area or operations:
5 ............................ General site areas.
3 ............................ Excavation and waste areas, accessways, active storage areas, loading platforms, refueling,
and field maintenance areas.
5 ............................ Indoors: Warehouses, corridors, hallways, and exitways.
5 ............................ Tunnels, shafts, and general underground work areas. (Exception: Minimum of 10 foot-
candles is required at tunnel and shaft heading during drilling mucking, and scaling. Mine
Safety and Health Administration approved cap lights shall be acceptable for use in the
tunnel heading.)
10 .......................... General shops (e.g., mechanical and electrical equipment rooms, active storerooms,
barracks or living quarters, locker or dressing rooms, dining areas, and indoor toilets and
workrooms.)
30 .......................... First aid stations, infirmaries, and offices.
The illumination requirements are designed to ensure that site areas accessible to employ-
ees are adequately lighted. Where night shifts are used, these requirements are particularly
important. Employers should ensure that illumination is adequate during all work shifts.
Employers should also consider the appropriateness of lighting equipment for the location,
especially hazardous locations classified at §1910.307, §1910.399, §1926.407, and §1926.449.
18–HAZWOPER 3/14

Sanitation of Temporary Workplaces

Sanitation facilities reduce the likelihood of exposure to hazardous substances through ingestion
or dermal contact. Each temporary worksite must have a supply of potable water that is stored in
tightly closed and clearly labelled containers and equipped with a tap. Disposal cups and a recep-
tacle for cup disposal must also be provided. The employer must clearly mark all water outlets that
are unsafe for drinking, washing, or cooking. The employer must also ensure that food service fa-
cilities are licensed.
Temporary worksites must be equipped with toilet facilities. If there are no sanitary sewers close to
or on the hazardous waste site, the employer must provide the following toilet facilities unless pro-
hibited by local codes: chemical, recirculating, combustion, or flush toilets.
In addition, washing facilities for all workers must be near the worksite, within controlled work
zones*, and so equipped to enable employees to remove hazardous substances. When hazard-
ous waste operations will exceed six months, showers and change rooms are also required.
When temporary sleeping quarters are provided, for example for workers who guard the worksite,
they must be heated, well-ventilated, and well-lighted.
See §1910.120(n) and §1926.65(n) for details.
New Technology Program
Employers also are required to develop and implement procedures for introducing effective new
technologies that provide improved worker protection in hazardous waste operations. Examples
include foams, absorbents, adsorbents, neutralizers, etc. OSHA’s new technology program re-
quirements are intended to encourage employers to seek improved methods for controlling haz-
ards and to ensure ongoing employee protection. See §1910.120(o) and §1926.65(o) for more
information.
Treatment, Storage, and Disposal (TSD) Facilities

OSHA has a separate section (§1910.120(p) and §1926.65(p)) covering operations involving haz-
ardous wastes that are conducted at TSD facilities regulated by 40 CFR 264 and 265 or by agen-
cies under agreement with the EPA to implement RCRA regulations. This separate paragraph is
appropriate because these operations generally are different from the operations found on a
clean-up site. For example, TSD facilities tend for the most part to be fixed on-going operations
involving the receiving, processing, storage, treatment, and disposal of hazardous wastes or sub-
stances from outside sources. Clean-up operations on the other hand are temporary emergency
operations involving often undefined and substantial quantities of hazardous substances. Conse-
quently, hazards should be better controlled and more routine and stable for the TSDs. So less
extensive requirements are appropriate. OSHA calls for a:
• Safety and health program,
• Hazard communication program,
• Medical surveillance program,
*A designated work area within the worksite.
HAZWOPER--19
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• Decontamination program,
• New technology program,
• Material handling program,
• Training program, and
• Emergency response program,
However, there are some exceptions to having to meet §1910.120(p) or §1926.65(p). Section
§1910.120(a)(2)(iii) and §1926.65(a)(2)(iii) states:
(a)(2)(iii) Operations within the scope of paragraph (a)(1)(iv) of this section must comply only
with the requirements of paragraph (p) of this section.
Notes and Exceptions: (A) All provisions of paragraph (p) of this section cover any treatment,
storage or disposal (TSD) operation regulated by 40 CFR parts 264 and 265 or by state law
authorized under RCRA, and required to have a permit or interim status from EPA pursuant to
40 CFR 270.1 or from a state agency pursuant to RCRA.
(B) Employers who are not required to have a permit or interim status because they are condi-
tionally exempt small quantity generators under 40 CFR 261.5 or are generators who qualify
under 40 CFR 262.34 for exemptions from regulation under 40 CFR parts 264, 265 and 270
(“excepted employers”) are not covered by paragraphs (p)(1) through (p)(7) of this section. Ex-
cepted employers who are required by the EPA or state agency to have their employees en-
gage in emergency response or who direct their employees to engage in emergency response
are covered by paragraph (p)(8) of this section and cannot be exempted by (p)(8)(i) of this
section. Excepted employers who are not required to have employees engage in emergency
response, who direct their employees to evacuate in the case of such emergencies and who
meet the requirements of paragraph (p)(8)(i) of this section are exempt from the balance of
paragraph (p)(8) of this section.
(C) If an area is used primarily for treatment, storage or disposal, any emergency response
operations in that area shall comply with paragraph (p)(8) of this section. In other areas not
used primarily for treatment, storage, or disposal, any emergency response operations shall
comply with paragraph (q) of this section. Compliance with the requirements of paragraph (q)
of this section shall be deemed to be in compliance with the requirements of paragraph (p)(8)
of this section.
HAZWOPER Fact Sheet

A HAZWOPER Fact Sheet, published by OSHA in April 2004, summarizes the program.
HAZWOPER--20
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HAZWOPER--21
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HAZWOPER--22
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HAZWOPER Questions and Answers

Scope
Q. Who is covered by §1910.120 or §1926.65?

A. Only those employees who are exposed or potentially exposed to hazardous substances,
including hazardous waste, and those who are engaged in one of the following operations:
1. Cleanup operations at uncontrolled hazardous waste disposal sites that have been identi-
fied by a governmental health or environmental agency.
2. Any corrective actions taken in cleanup operations conducted under RCRA.
3. Voluntary cleanups at government-designated sites.
4. Routine operations involving storage, treatment, and disposal facilities regulated under 40
CFR 264 and 265, except for small quantity generators (less than 1,000 kilograms/month)
and those employers with less than 90 days of accumulated hazardous waste.
5. Emergency response operations at any workplace when there has been a release or sub-
stantial threat of release of hazardous substances.
These operations are divided into three general categories:
1. Paragraphs (b)-(o) cover workers at hazardous waste sites who are exposed to hazardous
substances [listed in the scope of the regulation in (a)(1)(i) through (a)(1)(iii)];
2. Paragraph (p) covers workers at treatment, storage, and disposal (TSD) facilities who are
exposed to hazardous waste [listed in the scope of the regulation in (a)(1)(iv)];
3. Paragraph (q) covers employees who are engaged in emergency response operations to
releases of hazardous substances without regard to the location of the hazard [listed in the
scope of the regulation in (a)(1)(v)].
Q. What does OSHA mean by the possibility of “employee exposure to safety or health
hazards” in paragraph (a)(1)?
A. Employers must consider all routes of entry (inhalation, ingestion, and skin absorption) with-
out regard to the use of PPE when evaluating employee exposure or the reasonable possibil-
ity of employee exposure to safety or health hazards. The exposure or potential exposure
must be associated with a hazardous substance (see Note below for definition of hazardous
substance) from operations addressed in (a)(1)(i-iv) or with the release of a hazardous sub-
stance during operations addressed in paragraph (a)(1)(v) of the standard. Safety hazards
from a hazardous substance could include fire, explosion, corrosive action, etc., from flam-
mable, corrosive materials, etc. associated with the work site or emergency site. Health haz-
ards from a hazardous substance could include cancer or organ function impairment from
toxic, carcinogenic, or infectious material associated with the work site or emergency site.
Safety hazards from sources not specifically associated with the hazardous substances at
the work site or the emergency site (e.g., trenching, moving machinery, slips, trips, and falls)
do not by themselves require coverage under HAZWOPER. Employees are considered “ex-
HAZWOPER--23
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posed” when they encounter any amount of a hazardous substance in the work environment
that could cause them harm.
Note: (§1910.120(a)(3) and §1926.65(a)(3)) - “Hazardous Substance means any substance
designated or listed under (A) through (D) of this definition, exposure to which results or may
result in adverse effects on the health or safety of employees:
A. Any substance defined under section 101(14) of CERCLA;
B. Any biologic agent and other disease causing agent which after release into the environ-
ment and upon exposure, ingestion, inhalation, or assimilation into any person, either
directly from the environment or indirectly by ingestion through food chains, will or may
reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, ge-
netic mutation, physiological malfunctions (including malfunctions in reproduction) or
physical deformations in such persons or their offspring;
C. Any substance listed by the U.S. Department of Transportation as hazardous materials
under 49 CFR 172.101 and appendices; and
D. Hazardous waste as herein defined.
Q. Are municipal or other sanitary landfills covered by 29 CFR 1910.120 and 1926.65?
A. Not generally. An exception is when they have cleanups for or handle hazardous wastes
meeting the scope provisions of the standard.
Q. Are small quantity generators (less than 1,000 KG/month) and less than 90 days accu-
mulators of hazardous waste excluded?
A. Yes. Examples include routine operations in dry cleaners and gas stations which come within
the purview of the Resource Conservation and Recovery Act (RCRA) but are not hazardous
waste operators in the normal meaning of the term. Only paragraph (q) applies if these com-
panies have emergency response teams that respond to releases of hazardous substances.
Q. Do 29 CFR 1910.120 and 1926.65 expand the agency’s jurisdiction beyond the Occupa-
tional Safety and Health Act of 1970?
A. No. If another federal agency has jurisdiction and is enforcing, for example, MSHA over min-
ing operations, then even though the circumstances of the particular case fall into the defini-
tion of a hazardous waste site operation, OSHA would not enforce.
Q. Must hospitals comply with 29 CFR 1910.120?

A. Hospitals are not specifically exempted from coverage
under §1910.120, so hospital personnel must review
their specific situation and make a determination as to
whether the standard applies.
HAZWOPER--24
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In a June 7, 1991, interpretative letter on the subject, OSHA responded as follows:

After considerable review OSHA interprets the scope of 1910.120 to cover hospitals in at least
three scenarios: 1) when hospitals have an internal release of a hazardous substance which
requires an emergency response, 2) when hospitals respond as an integral unit of a communi-
ty-wide emergency response to a release of hazardous substance, and 3) if a hospital is a
RCRA-permitted Treatment, Storage and Disposal Facility.
The first scenario, albeit rare, includes the accidental release of hazardous substance within a
hospital, that requires an emergency response. Incidental releases that can be safely handled
by the workers who spilled the substance are not considered emergency responses and there-
fore are not covered under 1910.120. However, other training requirements, such as those
found in the Hazard Communication Standard (1910.1200) would apply.
Spills or releases inside a hospital that require emergency response are covered in paragraph
(q) of 1910.120. There are several different levels of training required for emergency respond-
ers. The level of training required is a function of the responsibilities the individual will assume
during an emergency response.
It is pertinent to note that the definition of “hazardous substance” used in the standard was
corrected on April 13, 1990 to include:
“(B) Any biological agent and other disease causing agent which after release into the
environment and upon, exposure, ingestion, inhalation, or assimilation into any person,
either directly from the environment or indirectly by ingestion through food chains, will or
may be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic
mutation, physiological malfunctions (including malfunctions in reproduction) or physical
deformations in such persons or their offsprings.”
Therefore hospitals must include medical wastes in their
effort to comply with paragraph (q) of HAZWOPER.
Your letter mentions the use of the fire department in the
event of an emergency. The employer may enlist out-
side assistance in the event of an emergency. However,
the assistance of outside emergency responders should
be coordinated in the emergency response plan prior to
an emergency response incident. There are other re-
quirements of the plan such as designating personnel
roles, the “senior official” and lines of authority. The
emergency response plan may include evacuation procedures for employees and patients and
may be a part of the hospital’s internal disaster plan.
The second scenario covers hospitals in their role as a part of a community wide emergency
response to the release of a hazardous substance. Under the Superfund Amendments and
Reauthorization Act of 1986, Title III, communities must prepare an emergency response
action plan. It is mandated by the statute that the local hospital participate in the planning
process.
If the community emergency response plan identifies a hospital as having decontamination
facilities in the event of an emergency, designated hospital personnel must have emergency
HAZWOPER--25
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responder training as outlined in 1910.120 paragraph (q). The level of training required for a
particular individual depends on the role he or she will be expected to play in the event of an
emergency response. However, the designated hospital employee who will set up and operate
the decontamination facility must have at least first responder operations level training.
Although, hospitals that may be involved in emergency response are required to designate
emergency responders and train them accordingly, other hospital personnel that may have to
enter the decontamination area may not have to be trained as emergency responders. There
is an exception to paragraph (q) training requirements for “skilled support personnel.” These
employees are not required to have had emergency responder training, however, they must be
given an initial briefing at the time of the incident, including instruction in the wearing of ap-
propriate personal protective equipment, what chemical hazards are involved and what duties
are to be performed. This category might include emergency room personnel as well as doc-
tors and technicians.
Hospitals that employ emergency medical service personnel (i.e. ambulance personnel) may
be required by paragraph (q) to train these personnel depending on the role they will be ex-
pected to play in the event of a hazardous substance release incident.
The third scenario involves hospitals that are RCRA-permitted Treatment, Storage and Dispos-
al Facilities (TSDF) for hazardous waste. If a hospital has a RCRA permitted facility, the em-
ployees working at that facility (the TSD facility, not the entire hospital) must be trained in ac-
cord with 1910.120 paragraph (p).
Q. Are public sector employees in States with an OSHA-approved State plan protected by
the hazardous waste standards adopted by these State plans?
A. Yes. The U.S. Environmental Protection Agency (EPA) promulgated a standard (40 CFR 311)
that adopts 29 CFR 1910.120 to protect employees who work in the public sector where
there is no OSHA approved State program in place. In addition, EPA specifically included
“noncompensated workers” (i.e., volunteer workers) who work for governmental agencies en-
gaged in emergency response, such as volunteer firefighters. Therefore, volunteers who will
take part in operations involving hazardous substances must be trained in accordance with
the applicable sections of 29 CFR 1910.120. States with OSHA-approved State plans are
encouraged both by OSHA Instruction STP 2-1.154C and EPA’s standard, 40 CFR 311, to
cover volunteer workers engaged in hazardous waste operations, including emergency re-
sponse.
Q. Who is responsible for contracted personnel?

A. Both contractors and their clients are responsible for complying with the OSHA regulations.
Clients must ensure that contractors are notified of conditions which may lead to emergen-
cies. OSHA considers personnel providers, who send their own employees to work at other
facilities to be employers whose employees may be exposed to hazards, for example utility
workers.
Since the contractor maintains a continuing relationship with employees, but it is the client who
creates and controls the hazards, there is a shared responsibility for ensuring that employees
are protected from workplace hazards. The client has the primary responsibility for such
HAZWOPER--26
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protection; however, the contractor-employer has a responsibility under the Occupational

Safety and Health Act.
The contractor would be required to provide training and to ensure that employees are pro-
vided with medical surveillance if it is necessary. The client would be responsible for providing
site-specific training, such as the facility’s places of refuge and decontamination areas, and
would have the primary responsibility to control potential exposure conditions.
It is further the responsibility of both employers to ensure that the client employer is fulfilling its
responsibility and is in compliance with the standards.
It is in the interest of the contractor to ensure that all steps required in the OSHA standards
have been taken by the client employer to ensure a safe and healthful workplace for the con-
tracted employees. Written contracts with clients should clearly describe the responsibility of
both parties in order to ensure that all requirements of the standards are met.
Q. Do contracts with other agencies require more stringent health and safety measures?
A. OSHA has general legal authority to regulate worker safety and health. There are exceptions
in which EPA has authority to regulate safety and health.
However, if an entity enters into a contract agreement with an agency such as the EPA or the
New York State Department of Environmental Conservation (DEC) to carry out more stringent
safety and health procedures than those required by OSHA but which meet OSHA’s require-
ments, you would be required by your contract to follow those stricter measures.
Q. How are volunteer firefighters affected by HAZWOPER?

A. Section (3)(5) of the Occupational Safety and Health Act of 1970 specifically excludes Feder-
al OSHA’s authority over employees of state and local government. The Act encourages
states to assume responsibility for occupational safety and health programs under the State’s
own plan, which must be approved by the U.S. Department of Labor. Each state-plan must
include coverage of public employees of the State, and it must be “at least as effective” as
Federal OSHA’s protection of private sector employees.
The applicability of OSHA standards 29 CFR 1910.156 (Fire Brigades), 1910.134 (Respiratory
Protection), and 1910.120 (Hazardous Waste Operations and Emergency Response) to volun-
teer fire departments in a state-plan state depends upon whether volunteer firefighters are
deemed employees of state and local governments under applicable state law.
For volunteers who work in a state that does not cover its
public employees, the U.S. EPA promulgated a standard
identical to 29 CFR 1910.120 to protect employees who work
in the public sector, specifically including volunteers engaged
in emergency response. This EPA standard (40 CFR 311) ap-
plies to employees of state and local governments in each
state which does not have an OSHA approved state plan.
EPA’s purpose for adopting §1910.120 in this standard was
to cover employees who were not otherwise covered by
OSHA.
HAZWOPER--27
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Q. Which governmental agency has enforcement authority over public employees

throughout the United States who are expected to respond to emergencies involving
hazardous materials?
A. Section 126 of the Superfund Amendments and Reauthorization Act (SARA) mandated stan-
dard development from both OSHA and EPA to address the risk of injury to employees at
hazardous waste operations and employees engaged in emergency response to releases of
OSHA has authority over private sector employees, except where there is an OSHA approved
state-plan that covers the private sector. Employees of governmental agencies working at haz-
ardous waste operations or responding to emergencies involving hazardous substances are
protected by either an OSHA approved state-plan or by the EPA.
OSHA promulgated 29 CFR 1910.120, the Hazardous Waste Operations and Emergency Re-
sponse standard. The EPA promulgated a standard (40 CFR 311) identical to 29 CFR
1910.120 to protect employees who work in the public sector. EPA’s standard varies slightly
from OSHA’s standard by including volunteers who work for a governmental agency engaged
in emergency response, such as firefighters. The EPA standard also applies to employees of
state and local governments in each state which does not have an OSHA-approved state plan.
EPA’s purpose for adopting §1910.120 was to cover employees that OSHA could not other-
wise cover.
Q. What is the definition of employee exposure?

A. The term “exposure” for the scope section of this standard is consistent with the definition
used in 29 CFR 1910.1200, Hazard Communication Standard, given below:
“Exposure” or “exposed” means that an employee is subjected to a hazardous chemical in the
course of employment through any route of entry (inhalation, ingestion, skin contact or absorp-
tion, etc.), and includes potential exposure.
NOTE: While the definition of exposure is similar, the scopes of the respective standards cover
different situations and substances.
Q. How does HAZWOPER apply to oil field operations?

A. If there is a potential for an uncontrolled release of hydrogen sulfide (H2S) during oil field
operations, the situation could represent an emergency. Such an emergency release would
be covered under 29 CFR 1910.120, unless it were an incidental release, as defined in the
standard, 29 CFR 1910.120(a)(3), where there is no potential safety or health hazard. Para-
graph (q) of 29 CFR 1910.120 covers emergency responses regardless of location. If sec-
tions of the oil field were considered treatment, storage and disposal facilities or hazardous
waste clean-up operations, other sections of 29 CFR 1910.120 would also apply.
The HAZWOPER standard directs employers to develop an emergency response plan which
includes appropriate safety and health measures, such as monitors, alarms and a written per-
sonal protective equipment (PPE) program. Since respirators may be needed during an emer-
gency response to an uncontrolled release of H2S, the written PPE program developed in com-
pliance with HAZWOPER must address the selection, limitations, maintenance, storage,
HAZWOPER--28
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training, fitting, and donning and doffing procedures for respirators in addition to other PPE. In
addition, all the requirements of §1910.134, including paragraph (e) must be met when em-
ployees are required to use respirators to meet HAZWOPER requirements.
Q. What preliminary activities are done before site characterization, and are those per-
forming duties covered under HAZWOPER?
A. Workers, such as utility workers, who must perform duties at a hazardous waste site that has
not yet been characterized but where contamination is expected, do fall under the scope of
29 CFR 1910.120 or 1926.65. These workers must work under the direction of an on-site
supervisor and a site-specific safety and health plan, and must be fully trained and protected
pursuant to the HAZWOPER standard. When additional information becomes available
through site characterization which verifies that there is minimal or no risk of employee expo-
sure to hazardous substances, a lesser degree of personal protective equipment and worker
training may be acceptable.
When site characterization shows that the area to be serviced by workers is free of potential
exposure, or the proposed work assignments would not expose any of the work crew to haz-
ardous substances, the activity can be carried out as a normal maintenance or construction
operation.
Q. What activities are involved after closure of a site?

A. Employee activity on a hazardous waste site which has gone through closure may or may
not pose a threat to employee safety or health, depending on the site’s characteristics. Ac-
cording to EPA, a site that has submitted a “post-closure plan” must include information on
the maintenance and monitoring of waste containment systems in its plan. EPA feels that a
site that has gone through “closure” is not necessarily “clean,” and usually requires continu-
ing site activity. Employees who are performing activities on a hazardous waste site with a
“post-closure plan” still need to be protected and trained in the hazards of the site.
The scope of the HAZWOPER standard begins by stating “this section covers the following
operations, unless the employer can demonstrate that the operation does not involve em-
ployee exposure or the reasonable possibility for employee exposure to safety or health haz-
ards....” Only employees who are trained in accordance with paragraph (e) may enter areas of
the hazardous waste site where they may be exposed (that may expose them) to hazardous
substances. Employees shall not be permitted to participate in, or supervise, field activities un-
til they have been trained to the level required by their job function.
Q. Do all of the requirements of 1910.120 or 1926.65 apply if a site characterization analy-

sis reveals no hazards?
A. No, the scope and application of 1910.120(a) or 1926.65(a) states that the standard does
not apply to operations where the employer can demonstrate that it does not involve em-
ployee exposure or the reasonable possibility for employee exposure to safety or health
hazards.
Under (a)(1), OSHA indicates that “This section covers the following operations, unless the
employer can demonstrate that the operation does not involve employee exposure or the rea-
sonable possibility for employee exposure to safety or health hazards.” How broadly does
HAZWOPER--29
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OSHA define safety and health hazards in this clause? For instance, while working in the des-
ert there are always the hazards of snake and spider bites, as well as slips, trips, and falls. Is
the exception limited to demonstrating no hazardous waste-related hazards?
For a site recognized as an uncontrolled hazardous waste site, the first step in determining the
applicability of §1910.120 or §1926.65 is site characterization. If the site has not been charac-
terized, then all of the appropriate sections of §1910.120 or §1926.65 would apply. If the site
has been characterized, the employer may designate contaminated areas and uncontaminat-
ed areas, based upon the site characterization.
In an OSHA letter of interpretation, OSHA states “support personnel are administrative staff
who do not enter contaminated areas, are not involved in hazardous waste activities, and are
not exposed to hazardous substances (based on the results of daily monitoring). OSHA con-
curs that they are not covered by the standard and the training requirements of 29 CFR
1910.120 [and 1926.65] do not apply.”
Another OSHA letter of interpretation concerns the applicability of HAZWOPER to “clean
areas” of sites designated for cleanup. This interpretation lays out three criteria for application
of the standard regarding the no exposure clause: entering contaminated areas, involvement
in hazardous waste activities, and exposure to hazardous substances. If none of the above
three criteria exist, then the employer would not be required to comply with §1910.120 or
§1926.65.
The employer’s general duty to ensure a safe and healthful workplace remains however, and
the hazards (slips, trips, falls, and snake bites) should be addressed by the employer to the
extent possible, but not however, within the context of §1910.120 or §1926.65 compliance.
If any of the three criteria fail, for instance, if employees enter an area designated as contami-
nated, then the employer must comply with the provisions of §1910.120 or §1926.65. In the
case described, this training would be met by the 24-hour offsite training and one day field
experience. If the possibility of exposures above the permissible exposure limits may develop,
then the 40-hour training and three days of supervised field experience would be required. The
burden of proof is on the employer to determine and document uncontaminated areas of sites
that have been identified as uncontrolled hazardous waste sites because the presumption is
that all areas of sites designated as uncontrolled hazardous waste sites are contaminated.
Q. Do the HAZWOPER training requirements apply when you are digging in soil which
has a high natural silica content but no hazardous waste, i.e. the only hazardous expo-
sure is coincidental to the operation and not directly related to the hazardous waste
activity?
A. A construction activity taking place at a facility covered by the scope of the HAZWOPER
standard, in which the only exposure hazards are from naturally occurring crystalline silica in
soil, would not fall within the scope of the HAZWOPER standard if all of the following condi-
tions are met:
• The activity does not involve hazardous wastes or the reasonable possibility for exposure
to safety or health hazards from hazardous wastes;
• The work area is uncontaminated, as determined through appropriate characterization and
monitoring; and
HAZWOPER--30
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• The employees work in uncontaminated areas.

Employees involved in such activities must be made aware of the facility’s emergency
response plan (i.e. evacuation procedures). Other pertinent sections of 29 CFR 1926 would
apply.
Q. Is 1910.120 applicable to people who are doing construction work in contaminated soil
that is unrelated to the cleanup activities for the site? For example, are workers who
are trenching in order to lay utility pipes covered by HAZWOPER? The removed soil
will be staged and removed by another contractor and the groundwater, which is con-
taminated, will be pumped out of the excavation to a holding tank.
A. According to a letter of interpretation issued by OSHA, utility workers who enter contami-
nated areas of the site to conduct construction or maintenance activities would require train-
ing under paragraph (e) of HAZWOPER.
Q. Is underground storage tank (UST) remediation work

covered under the HAZWOPER standard? The operation
involves the removal of underground petroleum storage
tanks.
A. In general, removal of underground petroleum storage tanks
is regulated under 29 CFR 1910.120. According to OSHA
interpretation, if the tanks are being removed under the
RCRA regulations that cover petroleum products in USTs,
then, §1910.120 applies, because it is a RCRA corrective
action. If the tank removal is part of a corrective action (re-
quired or voluntary) at a recognized uncontrolled hazardous waste site, then §1910.120 also
applies.
Q. What is meant by a storage facility in §1910.120(p)? If a facility stores waste process

solutions for a few weeks, but is not an EPA permitted storage facility under RCRA,
does this waste storage fall within the scope of §1910.120(p)?
A. The scope of §1910.120(p) relies upon EPA, or the authorized state agency, to identify per-
mitted hazardous waste storage facilities under RCRA. Generators who produce hazardous
wastes and store them for less than 90 days are not storage facilities under RCRA and are
therefore not covered by §1910.120(p). As generators of hazardous wastes, these facilities
are, however, covered by other OSHA standards, including hazard communication,
§1910.1200.
Q. Does HAZWOPER overlap with 29 CFR 1910.1030, Occupational Exposure to Blood-

borne Pathogens?
A. The definition of hazardous substance found in HAZWOPER includes any biological agent or
infectious material that may cause disease or death. Citations for exposures, mishandling,
etc. of biological hazardous wastes will be cited under HAZWOPER. Citations for exposures
to bloodborne pathogens as regulated under the Bloodborne Pathogen Standard will be cited
HAZWOPER--31
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under §1910.1030. Where there is a conflict or overlap of the standards, the provision more
protective of employee safety and health applies.
Q. What is the employer’s responsibility to contractors and subcontractors?

A. An employer who retains contractor or subcontractor services for work in hazardous waste
operations must inform them of the site emergency response procedures and any potential
fire, explosion, health, safety, or other hazards of the operation that have been identified by
the employer, including those identified in the employer’s information program.
The written safety and health program must be made available to any contractor who will be
involved with the hazardous waste operation.
Emergency Response
Q. How is emergency response defined under HAZWOPER?

A. It is a response effort by employees from outside the imme-
diate release area or by other designated responders (i.e.,
mutual aid groups, local fire departments, etc.) to an occur-
rence which results, or is likely to result, in an uncontrolled
release of a hazardous substance.
Responses to releases of hazardous substances where there is no potential safety or health
hazard (i.e., fire, explosion, or chemical exposure) are not considered to be emergency
responses.
Q. How is routine maintenance affected by this standard?

A. Response to routine maintenance problems by maintenance personnel are not considered
an emergency response under §1910.120. For example, you have a small oil puddle from a
forklift, someone throws a little absorbent on it and sweeps it up and discards it. This incident
would not be covered under the HAZWOPER standard.
Q. Who is required to have an emergency response plan?

A. All employers who are covered under the scope of §1910.120 or §1926.65 are required to
have an emergency response plan. This includes companies which have emergency re-
sponse organizations or teams that are expected to respond to hazardous substance inci-
dents, but are not otherwise covered by the standard.
Q. How would OSHA evaluate the emergency response plan?

A. The OSHA inspector would first determine if a plan was necessary. If so, and the employer
did not have a written plan, then the inspector would inquire and obtain a verbal response
HAZWOPER--32
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regarding the various aspects of a plan. The inspector would need to interview employees
to determine if they would be able to respond adequately in the event of an emergency
response situation.
If it was determined that the employees were uninformed, then the employer would be
required to either develop a plan in writing, have an audio-visual presentation, orally
communicate the plan to employees, or use whatever means available to ensure compli-
ance with this portion of the standard.
Q. Is the site safety and health supervisor required to be on site under HAZWOPER?
Is substitution of an alternate acceptable?
A. The definition of site safety and health supervisor provided in §1910.120(a)(3) and §1926.
65(a)(3) states that that individual is located on the hazardous waste site. An alternate to
the site safety and health supervisor must have at least the OSHA mandated training for
a supervisor and meet the qualifications described in the definition. The alternate would
also be required to be on site when acting as the site safety and health supervisor.
Q. Does the HAZWOPER Standard require a “spill kit”?
A. The HAZWOPER Standard does not specifically require “spill kits;” however, the Stan-
dard does call for equipment. According to paragraph (q)(3)(ii) of the Standard, the
individual in charge of the Incident Command System shall address the use of engineer-
ing controls, hazardous substance handling procedures, and the use of any new
technologies. This person shall also assure that the personal protective equipment worn
is appropriate. According to paragraph (q)(3)(iv), “Employee engaged in emergency
response and exposed to hazardous substances presenting an inhalation hazard or poten-
tial inhalation hazard shall wear positive pressure self-contained breathing apparatus
while engaged in emergency response …” According to paragraph (q)(3)(vi), “Backup per-
sonnel shall stand by with equipment ready to provide assistance or rescue. Advance first
aid support personnel, as a minimum, shall also stand by with medical equipment and
transportation capability.”
According to paragraph (o), “The employer shall develop and implement procedures for
the introduction of effective new technologies and equipment developed for the improved
protection of employee working with hazardous waste clean-up operations and the same
shall be implemented as part of the site safety and health program to assure that
employee protection is being maintained. New technologies, equipment or control mea-
sures available to the industry, such as the use of foams, absorbents, adsorbents,
neutralizers, or other means to suppress the level of air contaminates while excavating
the site or for spill control, shall be evaluated by employers or their representatives…”
Q. What equipment makes up a spill kit for emergency response operations?
A. OSHA does not require a “spill kit;” therefore, it does not specify what equipment must be
in a spill kit. OSHA does call for equipment. See the previous question. The National
Institutes of Occupational Safety and Health (NIOSH) published a list of equipment for
site emergencies in Chapter 12 of Occupational Safety and Health Guidance Manual for
Hazardous Waste Site Activities. Employers may wish to refer to it. In general, spill kits
may have, but are not limited to, the following equipment:
3/14 HAZWOPER–33

1. Personal protective equipment — Including duct tape, specific suits, respirators,

gloves, goggles, faceshields, masks, boots, and hard hats;
2. First aid kit;
3. Communication equipment — Including radios and binoculars, phone numbers, haz-
ard or waste labels, writing equipment, caution signs, barricade tape, and the
Emergency Response Guide and other guides;
4. Hand tools — Including hammers, wrenches, vice grips, cutting tools, pliers, crow
bars, flash lights, shovels, brooms, scoops, screwdriver, and manhole cover pry bar;
5. Equipment for stopping leaks in containers — Including a variety of tape, putty and
applicator, patching material, wedges, dowels, plugs, felt, inflatable bags and
patches, clamps, rope, chains, and leak detection;
6. Environmental monitoring equipment — Includes various chemical detectors and
meters and wind and temperature detectors;
7. Spill containment and cleanup — Includes sand, clay, ash, sorbent particulates,
drums, bags, red bags for bloodborne pathogens, pads, mops, buckets, dust pan,
scrub brush, soap, disinfectant, absorbent pillows and socks, pumps, pH paper,
tongs, sharps container, and chlorine leak kits; and
8. Decontamination area equipment.
Training
Q. Does a worker who occasionally visits your facility need the training if there is
no potential for exposure?
A. Employees who are neither exposed nor potentially exposed to hazardous wastes or haz-
ardous substances do not have to meet the training requirements.
Q. Does the training program have to be written?
A. No. The absence of a written training program does not constitute a violation in itself.
However, §1910.120(b)(1) and §1926.65(b)(1) requires a written safety and health plan
which covers the “safety and health training program.” In addition, any employer who is
not able to show by a certificate or list that his or her employee is trained or has equiva-
lent training will not be permitted to engage that employee in hazardous waste cleanup
operations.
Q. How might an OSHA inspector evaluate the training program?
A. Determination of compliance should include questioning the employer and employee
about the training received and consideration of the employee’s ability to safely and
knowledgeably perform his/her duties. This will require observation of work practices and
employee and employer interviews. Training needs to be consistent with the employee’s
job function and responsibilities.
34–HAZWOPER 3/14

Q. Explain the equivalent training provision in §1910.120(e)(9) and §1926.65(e)(9).

A. The employer must be able to show that the employee has had previous training and/or experi-
ence which qualifies the employee to perform his/her duties in a safe and healthful manner.
It is not specified how the equivalent training must be documented. There must be a written
document which clearly identifies the employee, the person certifying, the certifier’s qualifica-
tions, the training and/or past experiences which meet the requirements and some indication
of the time and the training which took place.
One possibility would be to include this information in the employee’s personnel file. Another
method would be to include this information on a master list of employees who qualify under
paragraph (e)(9). The best method is to include this information on a separate certificate for
each employee.
Q. What is meant by “certified”?

A. The rule does not specify what type of certification is necessary to show that employees
have completed the necessary training. Examples include, but are not limited to, a roster of
classroom attendance, diploma, wallet card, or an entry into a personnel folder.
The written documents must identify the worker, the person certifying, the certifier’s qualifica-
tions, and some indication of the time in training and the subject matter covered.
Q. If an employee received HAZWOPER training from employer A, must he/she be trained

again if he/she goes to work for employer B?
A. Workers who have received the required training at one site could use that training to meet
the required training at another site, even if it involved a different employer, provided the
previous training addressed the hazards at the new site.
Q. What training programs must be accredited?

A. OSHA proposed, in January 1990, that certain training programs must be accredited by the
Agency. This proposed requirement, 29 CFR 1910.121, Accreditation of Training Programs
for Hazardous Waste Operations, applied to training found in 29 CFR 1910.120(e) and (p).
This refers to training of employees involved in clean-up operations at uncontrolled hazard-
ous waste sites, and those involved in certain hazardous waste treatment, storage, and dis-
posal (TSD) operations.
It is not proposed to accredit training programs for employees engaged in emergency re-
sponse activities. There is such a large number of emergency response personnel, and so
many universities and organizations have developed training programs for them, that it would
severely deplete OSHA’s resources to try to evaluate all of them.
However, OSHA has since removed the proposed §1910.121 addressing accreditation of
training courses required by HAZWOPER. OSHA does not approve training programs or certi-
fy trainers. Appendix E of the HAZWOPER standard gives non-mandatory guidance for train-
ing programs.
HAZWOPER--35
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Q. What are the qualifications for trainers?

A. Trainers must be qualified to instruct employees about
the subject matter that is being presented. The trainers
should have completed a training program for teaching
the people they are expected to teach, or they must
have the academic credentials and instructional experi-
ence necessary for teaching the subject. They must
demonstrate competent instructional skills and knowl-
edge of the applicable subject matter.
It is a good idea to review the experience, training, and background of trainers to ensure that
they are qualified to instruct employees.
Q. Must drivers hauling hazardous waste that do not interact with the waste other than to
transport it be trained?
A. According to a June 7, 1991, interpretative letter from OSHA, “Employees are not covered by
the standard if they are not exposed to health or safety hazards related to hazardous waste
operations.” The employer should make a determination as to whether the driver’s work activ-
ities meet this exclusion criteria. If the driver could potentially be exposed, training will be
necessary as required by paragraph (e) of 1910.120.
Q. What are the training requirements for underground storage tank (UST) activity?
A. Leak detection, leak prevention, tank cleaning, and closure activity are covered by
§1910.120 if any of the following apply:
1. A government body is requiring the tank to be removed because of the potential threat to
the environment or the public; or
2. The activities are necessary to complete a corrective action;
3. A governmental body has recognized the site to be an uncontrolled hazardous waste site;
4. There is a need for emergency response procedures.
NOTE: It is not a requirement that a release must have occurred in order to meet the above
triggering elements.
Workers who replace piping or tanks where the scope of §1910.120 does not apply must be
trained in accordance with other OSHA standards, such as the hazard communication stan-
dard (29 CFR 1910.1200), storage and handling of liquified petroleum gases (§1910.110(h)),
and specific standards for personal protective equipment. The amount of training depends on
a number of factors such as duties and functions of the employee, site conditions, etc.
Training for workers who remove USTs that store chemicals is similar to that for USTs that store
gasoline. The handling of chemical solvents is likely to put workers in more dangerous situa-
tions than gasoline; therefore, training should be more extensive. Employees who are not per-
forming work that falls under the four activities above, and, therefore, do not fall under the
HAZWOPER--36
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scope of §1910.120, will need to be trained in other OSHA standards for the use of personal
protective equipment and the handling of hazardous materials.
ALSO:
The OSHA standard covers workers employed in clean-up operations at hazardous waste
sites and EPA licensed waste treatment, storage, and disposal facilities as well as workers re-
sponding to emergency releases of hazardous materials. All on-site employees who are ex-
posed to hazardous substances, health hazards, or safety hazards require training.
For UST activities, OSHA’s interpretation of the regulations requires training for any on-site
workers (including state and local inspectors) involved in:
1. Tank closures, tank cleaning, and tank removal;
2. Clean-up operations and corrective actions; and

3. Emergency response operations.
The standard also requires training for on-site workers involved in leak detection and other
prevention activities when:
1. A tank must be removed because of a potential threat to the environment or public health;
or
2. Uncontrolled hazardous wastes are present; or
3. There is a need for emergency response actions.
These workers must complete the training before working on-site and the training must meet
OSHA’s training requirements (29 CFR 1910.120) covering course duration and content.
OSHA standard 29 CFR 1910.120(e)(3)(ii) and (e)(3)(iii) require 24 hours of training plus eight
hours of supervised field work for workers exposed below the permissible exposure limit (PEL)
and where respirators are not necessary. The standard requires 40 hours of training and 24
hours of supervised field work for workers who receive or have the potential to receive expo-
sure above the PEL (29 CFR 1910.120(e)(3)(i)). Emergency response personnel require up to
24 hours of training depending on their level of involvement in the response operation (29 CFR
1910.120(q)(6)). Depending on their level of exposure, on-site managers and supervisors
must meet either the 24 and eight or the 40 and 24 hour training requirements. In addition, they
must receive eight hours of specialized training for supervisors.
Besides the above requirements, all workers must receive an addition-
al eight hours of refresher training annually. Emergency response per-
sonnel need annual refresher training sufficient to maintain their com-
petencies.
These should be considered as the minimum training requirements for
UST workers. The presence of special hazards such as trenches, con-
fined spaces, and fire and explosion may warrant additional UST-spe-
cific training. Managers and supervisors may also want to consider the
HAZWOPER--37
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liability to themselves and their agency in the event of an accident

when determining the level of training to provide their employees.
Training is just one part of the HAZWOPER Standard. It also requires employers to develop a
comprehensive safety and health program. This written program must identify, evaluate, and
control safety and health hazards.
Q. What site characterizations are exempt from training requirements?

A. Employees working on uncontrolled hazardous waste sites are covered whether the work
they do is cleanup or non-cleanup activity. However, employees are not covered if they work
exclusively within uncontaminated areas of the hazardous waste site and are not exposed to
health or safety hazards related to hazardous waste operations.
If the site had not been characterized, an employer would be responsible for conducting an
initial characterization of the site in order to anticipate hazards before commencing with the
maintenance activity. The characterization would have to be of sufficient detail to adequately
characterize the safety and health hazards that would result from the specific operations in
which the employees would be involved. If the site has been characterized and no exposure or
potential exposure exists, any further activity on-site would fall outside the scope of the stan-
dard and the employer would not be required to meet any of the provisions of the standard,
and training may not be required.
Q. Do the HAZWOPER training requirements apply when you are digging in soil which
has a high natural silica content but no hazardous waste, i.e. the only hazardous expo-
sure is coincidental to the operation and not directly related to the hazardous waste
activity?
A. A construction activity taking place at a facility covered by the scope of the HAZWOPER
standard, in which the only exposure hazards are from naturally occurring crystalline silica in
soil, would not fall within the scope the scope HAZWOPER standard if all of the following
conditions are met:
• The activity does not involve hazardous wastes or the reasonable possibility for exposure
to safety or health hazards from hazardous wastes;
• The work area is uncontaminated, as determined through appropriate characterization and
monitoring; and
• The employees work in uncontaminated areas.
Employees involved in such activities must be made aware of the facility’s emergency
response plan (i.e. evacuation procedures). Other pertinent sections of 29 CFR 1926 would
apply.
Q. If a hazardous waste site worker under §1910.120(e)(3)(ii) or (iii) or §1926.65(e)(3)(ii) or

(iii) wears a respirator, how much training is required?
A. The HAZWOPER standard is very clear on when 40 hour training (as opposed to 24 hour) is
required in regards to the use of respirators. In 29 CFR 1926.65(e)(3)(iv) the standard states
“workers with 24 hours training who are covered by paragraphs (e)(3)(ii) and (e)(3)(iii) of this
HAZWOPER--38
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section [these two subparagraphs require 24 hours of training for workers on site occasional-
ly and regular site workers exposed below published exposure limits, respectively] and who
become general site workers or who are REQUIRED to wear respirators SHALL have the
additional 16 hours and two days of training necessary to total the training in paragraph
(e)(3)(i) [the subparagraph requiring 40 hours of training for general site workers].”
The fact that OSHA uses the verb shall clearly identifies this requirement as mandatory. If the
employer requires the worker to wear a respirator to enter an exclusion zone then that worker
would be required to have had 40 hours of training and three days of supervised field experi-
ence.
Q. What does §1910.120 and §1926.65 mean in (e)(5) regarding the qualifications of
instructors?
A. OSHA published a non-mandatory Appendix E to 1910.120 and 1926.65 on August 22,
1994. Included are suggested core criteria, including criteria for the training director and
instructors.
Q. How do you document the 3-day field experience required under §1910.120(e) and
§1926.65(e)?
A. The field supervisor, who must be 40-hour trained, three-day field experienced and eight-
hour supervisor trained, should prepare a written document certifying that he/she supervised
the employee’s three-day field experience. The employee must be provided a copy, per
§1910.120 or §1926.65(e)(6), and a copy should be placed in the employee’s personnel file.
Q. If a worker has not completed the refresher training within 12 months of the initial
training or subsequent annual refresher training, is the worker required to take the
initial training again in order to qualify for field work?
A. It is a reasonable policy to require the initial training again if a worker has not received the
refresher training in three years. This generalization depends upon the individual worker’s
retention of the information and whether the initial or refresher training addressed the safety
and health issues specific to the types of sites at which the worker will be working. OSHA
would look at repeating the initial course on an as-needed basis.
OSHA believes it reasonable for an employee not engaged in hazardous waste operations to be
refreshed after three years of lapsed refresher training. Therefore, your acceptance of the em-
ployee’s past training history seems reasonable if the performance requirements have been ade-
quately addressed.
Q. Can the eight-hour supervisor course be used to fulfill the requirement for eight hours
of refresher training the year a general hazardous waste site worker becomes a super-
visor?
A. OSHA expects a general hazardous waste site worker who is becoming a supervisor or man-
ager to received at least 16 hours of training the year they become a supervisor — eight
hours of supervisory training in addition to the eight hours of employee refresher training.
HAZWOPER--39
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OSHA’s approach is that, due to the specific nature of supervisory training, a supervisor new to
a site would require additional training in the employer-specific plans and programs of the site.
Q. What training does the Hazard Communication Standard (HCS), §1910.1200 and
§1926.59, require and what are its applications?
A. The HCS requires that employers train employees who may be exposed or potentially
exposed to hazardous chemicals. Employers are to train em-
ployees in:
1. Methods to detect a hazardous chemical;
2. The hazards of chemicals in the work area;
3. Measures employees can take to protect themselves; and
4. The details of the hazard communication program (further
clarified in paragraph (h) of the HCS).
It is important to note the objectives of both HAZWOPER and the HCS, especially where the
two standards require training:
1. The HCS does not specifically apply to hazardous waste. The requirement that employers
inform employees of the hazards associated with exposure to hazardous waste or waste-
contaminated material are contained in the HAZWOPER standard (§1910.120(i) or
§1926.65(i)).
2. The HCS does apply to commercial hazardous materials that are stored, used, or han-
dled on the site. Such materials may include motor fuels, decontamination solvents, com-
pressed gases, or acids and caustics used in wastewater treatment, other chemical pro-
cesses, and treatment of hazardous waste performed on the site.
Labels
Q. On a superfund site where drums have been dug up, repacked, numbered and listed
on a manifest, can OSHA require a more hazard-specific label be placed on the drums
in addition to the number and manifest arrangement?
A. Paragraphs §1910.120(j)(1) and (j)(8) and §1926.65(j)(1) and (j)(8) indicate that some form of
labeling is necessary under this standard, but no specifics are given as to the information
required on the label. The intent is to accept the DOT marking and labels that must be done
before taking containers off the site to a RCRA facility.
The labeling information needs to allow the employees to safely handle the drums. This may
also be accomplished through a numbering and manifest system as long as the chemical haz-
ard classification (e.g., corrosive, poison, oxidizer, flammable solid, radioactive, etc.) informa-
tion is available to the employees handling or working near the drums. The EPA manifest re-
quirements of 40 CFR 262.20 are acceptable as well, provided employees are aware of this
information.
HAZWOPER--40
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Q. Does §1910.120(j)(1)(iv) and §1926.65(j)(1)(iv) require that drums be labeled to the

extent required by the hazard communication standard?
A. No. However, it requires that the drums or containers be identified and marked, as discussed
in the previous answer, or otherwise organized in such a manner by chemical hazard or clas-
sification, etc., that employees will know the precautions necessary prior to handling.
For the “positive identification” of drum content, information must be gathered or analyses per-
formed, sufficient for making determinations otherwise required by this standard, e.g., selec-
tion of PPE, medical surveillance, etc.
Q. In 1910.120(j)(1)(vii) and §1926.65(j)(1)(vii), what is meant by “proper absorbent”?

A. Proper absorbent is one which is capable of containing the
spill or reducing its spread in such a manner that employee
exposure is minimized, e.g., neutralizing agent on acid, cov-
ering the spill with absorbent, or solidifying the spill with an
absorbent, as appropriate to the spill. An improper absor-
bent is one which adversely reacts with the spilled material
creating more problems.
Reporting and Recordkeeping
Q. What accessibility do former employees have to HAZWOPER training records?

A. Former employees can request copies of training certificates from former employers, and
current employers can request documentation of an employee’s training from the employee’s
former employer. OSHA regulations, however, do not require former employers to respond to
such requests. Paragraph §1910.120(e)(6) and §1926.65(e)(6) of the HAZWOPER standard
requires that head instructors or trained supervisors provide a written certificate to each em-
ployee that has successfully completed the training and field experience that is specified in
paragraphs (e)(1) through (e)(4) of the standard. It is the employee’s responsibility to keep
copies of the training certificate for themselves and for future employers.
Q. What are the reporting requirements for the National Contingency Plan?
A. Facilities must submit an EPA Tier I or Tier II inventory form to their State Emergency Re-
sponse Commission (SERC), Local Emergency Planning Committees (LEPC) and fire depart-
ment with jurisdiction over the facility. Material safety data sheets (MSDS) must also be sub-
mitted. The MSDSs and Tier II forms are available to anyone who requests the information
from their LEPC. Tier II forms are also available to anyone who requests the information from
their SERC.
Q. What written programs will an OSHA inspector review during an inspection of a haz-
ardous waste clean-up operation?
A. Written programs for hazardous waste clean-up operations that inspectors should review in-
clude the following:
HAZWOPER--41
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1. Safety and health program, as per 29 CFR 1910.120(b)(1) and/or 1926.65(b)(1). The
safety and health program requires other written programs such as an organizational
structure, a work plan, and a site-specific safety and health plan.
2. Site-specific safety and health plan, as per HAZWOPER paragraph (b)(1)(ii)(C). This may
be part of the safety and health program listed above, and need not duplicate the employ-
ers standard operating procedures.
3. Documentation of site characterization and analysis, as per 29 CFR 1910.120(c)(4) and/
or 1926.65(c)(4).
4. Spill containment program, as per 29 CFR 1910.120(j)(1)(viii) and/or 1926.65(j)(1)(viii).
5. Emergency response plan, as per 29 CFR 1910.120(l)(1) and/or 1926.65(l)(1).
6. New technology program, as per 29 CFR 1910.120(o) and/or 1926.65(o), which may be
part of the safety and health program.
7. Other programs that may be needed because of special site conditions or special site
procedures. Examples include programs for benzene, lead, asbestos, heat stress, pro-
cess safety management (PSM), permit-required confined space, and lockout/tagout.
Q. Are firefighters covered under §1910.120 or §1926.65(f), medical surveillance?

A. Some people believe that all firefighters must have the medical surveillance protections of
paragraph (f) since they may wear respirators 30 days or more a year. Firefighters respond-
ing to structural fires will typically wear self-contained breathing apparatus when they enter
burning structures or other hazardous locations, and they may make such responses 30 days
or more a year.
OSHA is not requiring all firefighters who wear respirators 30 days or more a year to have med-
ical surveillance. This requirement applies to cleanup operations, not emergency response op-
erations.
The emergency response section does not contain requirements for medical surveillance of
fire fighters unless they are members of an organized and designated hazardous materials
response team, are hazardous materials specialists, or have been injured due to an overexpo-
sure to health hazards during an emergency incident involving hazardous substances.
Q. Are physicals required to be given annually?

A. Because of variations in employee exposures due to work schedules, annual physicals may
not be medically necessary. OSHA decided that annual medical examinations may not al-
ways be appropriate, so the agency permits the physician to reduce the frequency to not less
than biennially (every two years), or to increase the frequency if it is medically appropriate.
HAZWOPER--42
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Q. How do the medical surveillance requirements of HAZWOPER mesh with other OSHA
standards for respiratory protection and specific chemicals?
A. HAZWOPER requires medical surveillance if an employee covered by the standard is ex-
posed to hazardous sbustances or health hazards in excess of the PEL or published expo-
sure levels for 30 or more days per year, without regard to the use of respirators, or wears
respirators for 30 or more days per year. The requirement is patterned after the medical sur-
veillance requirements for specific chemicals, such as arsenic and benzene. The applicability
of HAZWOPER, §1910.120(a)(2) or §1926.65(a)(2), states that if there is a conflict or overlap
between this standard and other OSHA standards, the provision that is more protective shall
apply. With respect to the respiratory protection standard, §1910.134, it requires that the em-
ployer determine the physical fitness of an employee to wear a respirator, but merely sug-
gests, and does not require, that a physician make that determination.
Q. May an employee waive his/her right to medical surveillance under HAZWOPER?

A. Yes. According to CPL 2-2.59A, “Under 29 CFR 1910.120
employers are obligated to make medical surveillance and
medical consultation available to specific employees without
cost to the employees. However, OSHA does not require
employees to participate. A record should be made in em-
ployees’ personnel files indicating that the employees volun-
tarily chose not to take part in the medical surveillance pro-
gram. The [OSHA inspector] may choose to interview the
employees entitled to medical surveillance whose personnel
files indicate that they waived their right.” If employees who waive medical surveillance, later
request it, employers are required to provide it then.
General
Q. What are liability issues in regard to HAZWOPER?

A. The term liability can have two meanings. Violating §1910.120, §1926.65, or its EPA equiva-
lent will lead to penalties or compliance orders. The enforcement authority for public em-
ployees is the State OSHA for state plan states and EPA in states administered by federal
OSHA. For non-public employees the enforcing authority is federal OSHA or the state if it is
a state-plan state. The party liable is the employer. Secondly, liability can mean liability in
damages under common law or statutory tort remedies. OSHA has no authority in this area.
See Section 4(b)(4) of the OSH Act. You should consult with your corporation’s counsel,
state’s attorney, or state attorney general for the answer in your jurisdiction.
Q. What is the DOT Hazardous Materials Transportation Uniform Safety Act of 1990?
A. The handling of hazardous materials in the transportation industry is regulated by the Haz-
ardous Material Transportation Uniform Safety Act of 1990 (HMTUSA). Training for the safe
handling and safe transportation of hazardous materials is required in Section 7, which states
that for purposes of Section 4(b)(1) of the OSH Act, no action taken by the Secretary of
Transportation pursuant to Section 7 shall be deemed to be an exercise of statutory authority
to prescribe or enforce standards or regulations affecting occupational safety and health.
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On May 15, 1992, DOT published the final rule “Hazardous Materials; Training for Safe Trans-
portation” (49 CFR 171-177) to enhance training requirements for persons involved in the
transportation of hazardous materials. The rule requires employers to train their employees in
the safe loading, unloading, handling, storing, and transportation of hazardous materials. Such
employees are primarily in the private sector, but the DOT rule may apply to public sector em-
ployees if commerce is involved. The rule is also designed to improve emergency prepared-
ness for responding to accidents or incidents involving the transportation of hazardous
materials.
The new DOT rule does not preempt OSHA from enforcing occupational safety and health reg-
ulations, such as 29 CFR 1910.120, when employers fall under the scope of HMTUSA. HA-
ZWOPER applies if transporters are handling hazardous waste that is on the way to a hazard-
ous waste site or to a TSD facility, or when transporters become involved in emergency
responses to the release of hazardous substances.
Training that is performed to satisfy OSHA, EPA, or DOT training requirements may be used to
satisfy the training requirements of the other agency’s rule. Duplicative training is not neces-
sary.
Q. Does OSHA approve consultation and compliance assistance services?

A. OSHA does not “approve” employer programs, although professional staff may be able to
provide consultation to the employer through correspondence and phone conversation. You
may pose compliance questions to the appropriate OSHA area office or, in states operating
their own OSHA approved safety and health programs, to the appropriate state official.
Consultative visits are also provided to small industry and more hazardous operations in the
United States; these visits will probably offer the assistance, or “approval,” that you seek, but
does not ensure full compliance with OSHA’s regulations.
Q. What is meant by a “de minimis citation”?

A. A technical violation, also called a de minimis violation, carries no monetary penalty or re-
quirement for abatement. If an employer complies with the clear intent of a regulation while
deviating from its particular requirements in a manner that has no direct or immediate rela-
tionship to employee safety or health, OSHA’s Field Operations Manual (FOM) directs that
such a violation be characterized as de minimis. Citations are not issued for de minimis con-
ditions, although they are to be documented in the same way as any other violation.
Q. Can an employer modify existing safety and health programs to meet 29 CFR 1910.120 or
1926.65?
A. Yes. OSHA does not intend to require duplicative effort to comply with this standard. Any
effort in response to other federal regulations that involve employee’s safety and health train-
ing, etc., may be used to meet the rule. For example, any training that is related to exposures
to hazardous substances that is required by other federal agencies, such as EPA, may be
used to fulfill the training requirements of 29 CFR 1910.120 or 1926.65.
HAZWOPER--44
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Q. What is the actual language from the Superfund Amendment and Reauthorization Act
that expanded OSHA’s regulatory authority to create the HAZWOPER regulation?
A. Under the authority of Section 126 of the Superfund Amendments and Reauthorization Act of
1986 (SARA Title I), the EPA and OSHA issued identical health and safety standards to pro-
tect workers engaged in hazardous waste operations and emergency response. Section
126(a) required the Secretary of Labor to issue health and safety standards — under Section
6 of the OSH Act for the benefit of private sector employees and through the Executive Order
of public sector employees — engaged in hazardous waste operations or emergency re-
sponse work.
A Closer Look at Training

As with every OSHA regulation, training is very important. What good would it do to have equip-
ment and procedures to protect the worker, if the worker is unaware of how to utilize the safe-
guards?
In this chapter, you will find information on what training must consist of under HAZWOPER. Also
included is the specific course content laid out in OSHA’s proposal to accredit training programs.
Moreover, this chapter offers general guidelines for setting up an effective training program.
Anyone who works with chemicals or hazardous waste must recognize and understand the po-
tential hazards to health and safety associated with exposure to those substances. Personnel
actively involved in cleanup, or members of an emergency response team who have the potential
of involvement, must be thoroughly familiar with programs and procedures contained in the Site
Safety Plan or the Emergency Response Plan and must be trained to work safely in contami-
nated areas.
General Training Objectives
The objectives of training programs for employees involved in hazardous

waste site/emergency response activities are:
• To make workers aware of the potential hazards they may encoun-
ter;
• To provide the knowledge and skills necessary to perform the work
with minimal risk to worker health and safety;
• To make workers aware of the purpose and limitations of safety
equipment; and
• To ensure that workers can safely avoid or escape from emergen-
cies.
The level of training provided should be consistent with the worker’s job function and responsibili-
ties. The training program should involve both classroom instruction in a wide range of health
and safety topics and “hands-on” practice. Hands-on instruction should consist of drills in the
field that simulate site activities and conditions. Any training program for work around hazardous
substances should also incorporate on-site experience under the direct supervision of trained,
experienced personnel.
HAZWOPER--45
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All training information should be presented in clear, concise language. Particularly important
information, such as the Standard Operating Procedures, should be provided in writing. A variety
of teaching aids (i.e., films, tapes, slides, etc.) should be used, and lecture sessions should be
interspersed with class participation and hands-on training. All employees should also complete
refresher training, at least annually, to reemphasize the initial training and to update workers on
any new policies or procedures.
In August 1994, OSHA issued non-mandatory Appendix E: Training Curriculum Guidelines which
provides detailed information that can be used in the development of a HAZWOPER training
program. Training curriculum suggestions cover when to train employees, what the training
should consist of, how to determine the professional competency of an instructor, how to evalu-
ate trainees’ proficiency, and what should be included in course certification. These guidelines
are not site-specific; therefore, additional standards may need to be consulted to achieve total
compliance.
Initial and Refresher Training Requirements

Training requirements will vary with the type of operation involved. The various operations and
their dependent training requirements are specified in the table on the next page. Unless an
employer can demonstrate that the operation does not involve employee exposure or the rea-
sonable possibility for employee exposure to safety or health hazards, the employees for the
operations listed require training.
Operation: Employee type: Training: Training time: §1910.1
20:
Sites licensed under the General site employees
p y 2 Initial off-site training 40 hours ((e)(3)(i)
)( )( )
R
Resource Conservation
C i Field experience 3 days
and Recovery Act (RCRA)
or uncontrolled hazardous Annual refresher 8 hours (e)(8)
waste
aste operations
ope at o s man-
a Routine site employees
p y Initial off-site training 24 hours ((e)(3)(iii)
)( )( )
dated by various levels off ( i i l exposure))3
(minimal Field experience 1 day
government1
Non-routine site employees
p y 4 Initial off-site training 24 hours ((e)(3)(ii)
)( )( )
Field experience 1 day
p / g of Initial training 40 hours ((e)(4)
)( )
generall site
i employees
l Field experience 3 days
)( )
routine
i site
i employees
l (mini-
( i i Field experience 1 day
mal exposure)
)( )
non-routine
i sitei employees
l Field experience 1 day
Emergency response per- Initial training No minimum (e)(7)
sonnel training time spe-
cified
Trainers Have either: training course on subjects, No minimum (e)(5)
and/or credentials and experience to dem- training time spe-
onstrate competency cified
HAZWOPER--46
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Operation: Employee type: Training: Training time: §1910.1

20:
Treatment,, storage,
g , and General site employees
p y Initial or equivalent training 24 hours (p)(7)
di
disposall sites
it regulated
l t d by
b Annual refresher 8 hours (p)(7)(ii)
40 CFR 264 and 265 pur-
suant to RCRA or by agen- Emergency response per- Trained to have a level of competency No minimum (p)(8)(iii)
cies under agreement with sonnel training time spe-
EPA to implement RCRA cified
regulations Annual refresher or demonstrate compe- No minimum (p)(8)(iii)
tency training time spe- (C)
cified
Trainers Have either: training course on subjects, No minimum (p)(7)(iii)
Emergency response op- First responder awareness Sufficient training or proven experience in No minimum (q)(6)(i)
erations at other than level—Witnesses or discov- specific competencies training time spe-
RCRA sites or uncontrolled ers a release of hazardous cified
h
hazardous
d waste
t site
it substance
b t or iis ttrained
i d to
t Annual refresher or demonstrate compe- Duration to main- (q)(8)
clean-ups5 notify the proper authorities tency tain competencies
First responder operations Initial training or proven experience in spe- 8 hours (q)(6)(ii)
level—Responds to releases cific competencies at both the operations
of hazardous substances in a and awareness levels
d f
defensivei manner, without
ith t Annual refresher or demonstrate compe- Duration to main- (q)(8)
trying to stop the releases tency tain competency
Hazardous materials techni- Initial operations level and hazardous ma- 24 hours (q)(6)(iii)
cian—Responds aggressive- terials technician level training and compe-
p the release of haz- tency
lyy to stop
ardous
d substances
b t Annual refresher or demonstrate compe- Duration to main- (q)(8)
tency tain competency
Hazardous materials special- Initial hazardous materials technician level 24 hours (q)(6)(iv)
ist—Responds with and in and hazardous materials specialist level
support to hazardous materi- training and competency
als technicians
technicians, but who have
specific knowledge of various Annual refresher or demonstrate compe- Duration to main- (q)(8)
hazardous substances tency tain competency
On-the-scene incident com- Initial operations level and on-the-scene 24 hours (q)(6)(v)
mander—Assumes control of incident commander level training and
y
the incident scene beyond competency
th first
the fi t responder
d aware- Annual refresher or demonstrate compe- Duration to main- (q)(8)
ness level tency tain competency
Trainer Have either: training course on subjects, No minimum (q)(7)
Any operation above that All employees In addition to the above training require- When plan (l)(1)(ii)
does not permit any of its ments, review Emergency Action Plan and changes or em- (p)(8)(i)
employees to assist in han- what employee needs to know to protect ployee’s responsi- (q)(1)
dling an emergency re- self. Further initial training if designated to bilities or desig- §1910.3
lease assist in safe and orderly emergency evac- nated actions 8(e)-(f)
uation of employees. change
Any operation above that All employees No HAZWOPER training requirements No HAZWOPER (a)(1)
does NOT involve or have training require-
the reasonable possibility ments
for employee exposure to
safety/health hazards
Footnotes to Table
1 The sites licensed under the Resource Conservation and Recovery Act or uncontrolled hazardous waste operations
mandated by various levels of government, which are referred to in the table above, include:
• Clean-up operations required by a governmental body, whether federal, state, local or other involving hazard-
ous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the
EPA’s National Priority Site List (NPL), state priority site lists, sites recommended for the EPA NPL, and initial
investigations of government identified sites which are conducted before the presence or absence of hazardous
substances has been ascertained);
HAZWOPER--47
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• Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act
of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.); and
• Voluntary clean-up operations at sites recognized by federal, state, local or other governmental bodies as un-
controlled hazardous waste sites.
2 General site employees are those engaged in hazardous substance removal or other activities
which expose or potentially expose them to hazardous substances and health hazards. Exam-
ples include equipment operators, general laborers, and supervisory personnel.
3 Routine site workers are those workers on-site who work in areas which have been moni-
tored and fully characterized indicating that exposures are under permissible exposure limits
and published exposure limits where respirators are not necessary, and the characterization
indicates that there are no health hazards or the possibility of an emergency developing.
4 Non-routine site workers are those workers on-site only occasionally for a specific limited
task (such as, but not limited to, groundwater monitoring, land surveying, or geo-physical sur-
veying) and who are unlikely to be exposed over permissible exposure limits and published
exposure limits.
5 The HAZWOPER regulation applies to emergency response operations for releases of, or sub-
stantial threats of releases of, hazardous substances without regard to the location of the hazard.
Emergency response means a response effort by employees from outside the immediate release
area or by other designated responders (i.e., mutual-aid groups, local fire departments, etc.) to an occurrence which results,
or is likely to result, in an uncontrolled release of a hazardous substance. Responses to incidental releases of hazardous
substances where the substance can be absorbed, neutralized, or otherwise controlled at the time of release by employees
in the immediate release area, or by maintenance personnel are not considered to be emergency responses within the
scope of this standard. Responses to releases of hazardous substances where there is no potential safety or health hazard
(i.e., fire, explosion, or chemical exposure) are not considered to be emergency responses.
In-Plant Emergency Response

Emergency Response Training should be based on the duties and function each employee per-
forms within the emergency response system. You, as the employer, must make certain deci-
sions as to what level of involvement you want the worker to have. According to §1910.120(q),
the skill and knowledge levels required for all new responders shall be conveyed through training
before they are permitted to take part in actual emergency operations on an incident.
Scenario: One of the forklifts in the plant leaks a puddle of oil. Max, the maintenance man, sees this, throws
some sweeping compound on the leak and sweeps it up. Does Max require training under this regulation? No,
he doesn’t.
OSHA states that if the response consists of minor actions such as absorbing or neutralizing the
spill by employees in the immediate release area or by maintenance personnel, then it is not con-
sidered an emergency response, as defined by HAZWOPER.
However, employees who participate, or are expected to participate, in emergency response (see
the glossary for the definition of emergency response), must be trained according to
§1910.120(q)(6).
NOTE: Employers may opt to get out of the training at §1910.120(q)(6), by
taking the §1910.120(q)(1) exemption. This exemption states, “Em-
ployers who will evacuate their employees from the danger area
when an emergency occurs, and who do not permit any of their
employees to assist in handling the emergency, are exempt from
the requirements of this paragraph [§1910.120(q)] if they provide an
emergency action plan in accordance with §1910.38 of this part.”
Be aware that §1910.38 also contains some training requirements.
HAZWOPER--48
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First Responder Awareness Level

Scenario: Joe, a warehouse worker, sees a 55-gallon drum leaking. He touches nothing, just goes to get help.
Does he require training? Yes, he requires training to the First Responder Awareness Level according to
§1910.120(q)(6)(ii) if:
• The company does not take the §1910.120(q)(1) exemption;
• Joe is normally likely to witness or discover a hazardous substance release;
• The company expects Joe to initiate an emergency response sequence by notifying the proper
authorities of the release.
First responders at the awareness level are people who are likely to witness or discover a haz-
ardous substance release and who have been trained to initiate an emergency response se-
quence by notifying the proper authorities of the release.
They would take no further action beyond notifying the authorities of
the release. First responders at the awareness level shall have suffi-
cient training or have had sufficient experience to objectively demon-
strate competency in the following areas:
• An understanding of what hazardous materials are, and the
risks
associated with them in an incident;
• An understanding of the potential outcomes associated with an
emergency created when hazardous materials are present;
• The ability to recognize the presence of hazardous materials in
an emergency;
• The ability to identify the hazardous materials, if possible;
• An understanding of their own role in an emergency; and
• The ability to realize the need for additional resources, and to make appropriate notifica-
tions to the communication center.
First Responder Operations Level

Scenario: Joe, the warehouse worker, calls in Fred, his supervisor. Fred looks around, then tosses some spill
control pillows down around the leaking drum, and evacuates the work area. He then calls the plant emergency
response team. How much training must Fred have? Fred must be trained to the First Responder Operations
Level according to §1910.120(q)(6)(ii).
First responders at the operations level are people who respond to releases or potential releases
of hazardous substances as part of the initial response to the site for the purpose of protecting
persons, property, or the environment from the effects of the release.
They are trained to respond in a defensive fashion without actually trying to stop the release.
Their function is to contain the release from a safe distance, keep it from spreading, and prevent
exposures. This level responder must have received at least eight hours of training or have had
sufficient experience to objectively demonstrate competency in the following areas in addition to
those listed for the awareness level:
HAZWOPER--49
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• Knowledge of the basic hazard and risk assessment techniques;

• Know how to select and use proper personal protective
equipment provided to the first responder operational
level;
• An understanding of basic hazardous materials terms;
• Know how to perform basic control, containment and/or
confinement operations within the capabilities of the re-
sources and personal protective equipment available;
• Know how to implement basic decontamination procedures; and
• An understanding of the relevant standard operating procedures and termination proce-
dures.
Hazardous Materials Technician

Scenario: Harry is a member of the plant emergency response team. He is called by Fred to respond to
the leaking drum. He, and his team members, immediately takes steps to stop the leak and develop plans
for the cleanup. How much training does Harry need? Harry must be trained to the Hazardous Materials
Technician Level according to §1910.120(q)(6)(iii).
Hazardous materials technicians are individuals who respond to releases or potential releases for
the purpose of stopping the release. They assume a more aggressive role than a first responder, in
that they will approach the point of release in order to plug, patch or otherwise stop the release of a
hazardous substance.
Hazardous materials technicians must have received at least 24 hours of training equal to the
first responder operations level and in addition have competency in the following areas:
• Know how to implement the employer’s emergency re-
sponse plan;
• Know the classification, identification and verification of
known and unknown materials by using field survey in-
struments and equipment;
• Know how to select and use proper specialized chemical
personal protective equipment provided to them;
• Understand hazard and risk assessment techniques;
• Be able to perform advance control, containment, and/or confinement operations within
the capabilities of the resources and personal protective equipment available;
• Understand and implement decontamination procedures;
• Understand termination procedures; and
• Understand basic chemical and toxicological terminology and behavior.
HAZWOPER--50
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Hazardous Materials Specialist

Hazardous materials specialists are individuals who respond with and provide support to
hazardous materials technicians. Their duties parallel those of the hazardous materials
technicians. However, these duties require a more directed or specific knowledge of the various
substances they may be called upon to contain.
They would also act as the site liaison with federal, state, local and other government authorities
in regards to site activities. Hazardous materials specialists must have received at least 24 hours
of training equal to the technician level, and in addition, have competency in the following areas:
• Know how to implement the local emergency response
plan;
• Understand classification, identification, and verification
of known and unknown materials by using advanced
survey instruments and equipment;
• Know of the state emergency response plan;
• Be able to select and use proper specialized chemical
personal protective equipment provided to the hazardous
materials specialist;
• Understand in-depth hazard and risk techniques;
• Be able to perform specialized control, containment, and/or confinement operations within
the capabilities of the resources and personal protective equipment available;
• Be able to determine and implement decontamination procedures;
• Have the ability to develop a site safety and control plan; and
• Understand chemical, radiological and toxicological terminology and behavior.
On Scene Incident Commander
Incident commanders, who will assume control of the incident scene beyond the first responder
awareness level, must receive at least 24 hours of training equal to the first responder operations
level and in addition have competency in the following areas:
• Know and be able to implement the employer’s
incident command system.
• Know how to implement the employer’s emergency
response plan.
• Know and understand the hazards and risks associat-
ed with employees working in chemical protective
clothing.
• Know how to implement the local emergency re-
sponse plan.
HAZWOPER--51
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• Know of the state emergency response and of the Federal Regional Response Team.
• Know and understand the importance of decontamination procedures.
Vehicle Operators
Most of the responsibility for regulation of over-the-road vehicle operations belongs to the De-
partment of Transportation. However, if you give your employees the responsibility to respond to
emergency spills of hazardous substances or direct them to drive onto hazardous waste sites,
they are covered by OSHA’s HAZWOPER standard. When a truck driver becomes involved in an
emergency response involving hazardous substances, the driver is considered an emergency
responder and is covered by §1910.120(q).
You must have an Emergency Response Plan prior to an acci-
dent if shipping hazardous substances that could cause an
emergency during transportation. For example, an accident on
the road causes barrels containing hazardous materials to split
open. The driver’s part in the employer’s Emergency Response
Plan may be as simple as alerting a designated Hazardous Ma-
terials (HAZMAT) team to clean up the hazardous material.
Most drivers carrying hazardous materials will only need training to
the first responder awareness level or the first responder opera-
tions level specified at §1910.120(q)(6). Training beyond these first
two levels may be more technical than necessary, depending on
the transportation company’s expectations of the driver. OSHA stresses that employees must be
trained to the appropriate level before performing emergency response operations.
Training for the first responder awareness level enables employees who are likely to witness
releases of hazardous substances to recognize emergencies and notify authorities. The training
class would cover an understanding of what their role is in the employer’s Emergency Response
Plan, who to contact in the event of an uncontrolled release, and provide a basic understanding
of hazardous materials and risks associated with them.
Employees with this limited training must not attempt any actions themselves to control or clean
up the release.
Employees trained to the first responder operations level may take defensive action only (such
as diking or placing absorbent socks to prevent the spill from spreading) without trying to stop the
release. The training course would cover basic hazard and risk assessment techniques, the
selection and use of personal protective equipment, basic knowledge of control, containment,
and/or confinement operations, and basic decontamination procedures. If the driver is to drive
into the hot zone (exclusion zone), of a hazardous waste site or to go close enough to actively
fight a spill, additional training is required.
Bloodborne Pathogens Training

If the worker could be called upon to respond to an emergency caused by the uncontrolled re-
lease of a regulated waste, including infectious material, the employee must also receive training
under the bloodborne pathogens standard (§1910.1030). The standard, which became effective
on July 6, 1992, requires specific training and procedures to be implemented where employees
have occupational exposure to blood or other potentially infectious material. If there is a conflict
or overlap in the requirements of the HAZWOPER and the bloodborne pathogens standards,
then the provision that is more protective of the employee’s health and safety would apply.
HAZWOPER--52
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Qualifications of Trainers
According to §1910.120(q)(7), trainers who instruct in any of the HAZWOPER subject areas need to
have satisfactorily completed a training course for teaching the subjects they are expected to cover,
or they should have had training in the actual subject area and hold the appropriate academic
teaching credentials. Proficiency in the subject by itself is not an adequate qualification. Training
instructors must be qualified to deliver the material and have a good command of the subject matter.
Training Certification
Employers of employees at the first responder operations, hazardous materials technician, haz-
ardous material specialist, and on scene incident commander levels shall so certify that those
employees have received required training and have competency in required areas. OSHA does
not mention training certification for first responders at the awareness level. However, certifica-
tion should be provided.
Refresher Training
All employees who receive emergency response training must receive annual refresher training
according to §1910.120(q)(8) to stay current in their knowledge and maintain their competency.
This refresher training can be waived if the employee can demonstrate his/her competency in the
relevant areas.
Keep documentation on the refresher trainer. If demonstrated competency is the criteria rather than
giving refresher training, keep a record of the methodology used to demonstrate the competency.
OSHA suggests using an actual field exercise for the refresher training. A realistic situation can
be simulated in your facility, giving your emergency response team the chance to put what they
know into practice. The exercise should then be critiqued, looking for areas where improvement
may be needed or additional training required.
Interpretations of Emergency Response Training Requirements - CPL 2-2.59A

The following interpretations come from the compliance directive entitled, “Inspection Procedures
for Emergency Response Training Requirements,” CPL 2-2.59A.
(q)(6)(i) Training
Fire fighters and police officers who are expected to be engaged in responding to emergencies
involving hazardous substances are subject to the HAZWOPER training requirement.
• Generally, police officers should be trained to the first responder awareness level, since
they are likely to witness or discover a release of a hazardous substance.
• Fire fighters expected to respond to releases of hazardous substances must be trained to
at least the first responder operations level, since they will respond to releases, or poten-
tial releases, or hazardous substances for the purpose of protecting nearby persons,
property, or the environment.
(q)(6)(ii) First Responder Operations Level
Fire fighters responding to propane and gasoline fires:
• Fire fighters trained to the operations level, who are also trained in the hazards of pro-
pane, may enter the danger area to shut off the valves that will starve the fire and thus
HAZWOPER--53
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extinguish it. Normally, employees trained to the opera-

tions level would be restricted from taking aggressive ac-
tion. This is considered to be a special case. The prin-
ciple hazards from propane are fire and explosion, not
toxicity. Because propane fires are common, most fire
fighters are fully trained and equipped to respond to pro-
pane fires, including taking aggressive action by shutting
off the valves in the danger area.
- If fire fighters are fully trained and equipped (which is a high degree of training), and
have also received first responder operations level training, OSHA believes they have
sufficient training to take aggressive action due to propane’s relatively low toxicity.
However, it would be only a technical violation of 29 CFR 1910.120(q)(6) for not hav-
ing the additional training required of a HAZMAT technician if a fire fighter took
aggressive action in the danger area during a propane fire or leak, was fully trained
and equipped to handle the fire, and had first responder operations level training. In
this circumstance OSHA would not issue a citation.
• Releases of gasoline similar to the example involving propane discussed above may be
addressed by operations level emergency responders if they have the required PPE,
emergency response equipment, and specific training in the safety and health hazards
associated with gasoline.
- Employers who expect fire fighters to shut off a gasoline valve in the danger area, and
who can show that employees are trained to the operations level and adequately trained
in the hazards of gasoline, have committed a technical violation of §1910.120(q)(6)(iii) for
such employees not having the training required of HAZMAT technician.
NOTE: The fire and explosion hazards of propane and gasoline are very substantial.
The interpretations herein are applicable only when fire fighters are fully
trained and equipped to handle the explosion and fire hazards of propane,
gasoline, or similar flammable gases and liquids.
• If an injury occurred during an emergency response involving these responders (opera-
tions level plus additional training) the Compliance Safety and Health Officer (CSHO)
would need to consider whether the responders’ training and experience were sufficient
for the tasks being performed.
- A violation of training requirements that resulted in an actual injury to an employee
during an emergency response by definition cannot be a “technical violation.” Thus, if
an injury occurred and the CSHO determined that the responders’ training and experi-
ence were not sufficient for the tasks being performed, then a citation should be is-
sued noting a violation of 29 CFR 1910.120(q)(6)(iii) and carrying a penalty that re-
quires abatement. Whether abatement should require full training in all of the
competencies of the HAZMAT technician level, or whether certain training require-
ments could safely be omitted, would depend on the training needed to safely per-
form the tasks in question.
HAZWOPER--54
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- If, however, the CSHO determined that the training which had been provided to the
employees in question had been adequate, then the training violation would be con-
sidered a de minimis violation and no citation would be issued for inadequate training.
In this situation the CSHO might determine that the cause of the injury was due to a
violation of some other requirement of 29 CFR 1910.120 or other standards, for which
a citation carrying a fine and requiring abatement would be appropriate.
(q)(6)(iii) Process Operators Responding within a Facility

Process operators who have (1) informed the incident command structure of an emergency (de-
fined in the facility’s emergency response plan), (2) adequate PPE, (3) adequate training in the
procedures they are to perform, and (4) employed the buddy system, may take limited action in
the danger area (e.g., turning a valve) before the emergency response team arrives. The limited
action taken by process operators must be addressed in the emergency response plan.
• Once the emergency response team arrives, these employees would be restricted to the
actions that their training level allows. This limited action assumes that the emergency re-
sponse team is on its way and that the action taken is necessary to prevent the incident
from increasing in severity (i.e., to prevent a catastrophe).
• Employers must inform employees during their training that they are to evacuate when
they lack the capabilities to respond in a safe manner and in accordance with the stan-
dard operating procedures defined in the emergency response plan.
• If the process operator takes action beyond what they have been trained to do, and the
action was comparable to the aggressive role that HAZMAT technician would take,
CSHOs shall cite the employer for a violation of 29 CFR 1910.120(q)(6)(iii). If the operator
takes action beyond that which they have been trained to do, and the action was compa-
rable to the defensive role that a first responder at the operations level would take,
CSHOs shall cite the employer for a violation of 29 CFR 1910.120(q)(6)(ii).
(q)(6)(v) On Scene Incident Commander
The intent of the standard is to provide an incident command system that is headed up by a
single person who is well trained in managing emergencies of differing severity, as well as over-
seeing the HAZMAT team, but does not necessarily have extensive knowledge of certain techni-
cal aspects such as classification and verification of hazardous materials. Appendix C, section 6.,
of the standard explains:
“This enable[s] one individual to be in charge of managing the incident, rather than having
several officers from different companies making separate, and sometimes conflicting, deci-
sions. The individual in charge of the [incident command system] would delegate responsibil-
ity for performing various tasks...”
Consequently, the Incident Commander (IC) requires more training in general matters, plus ex-
tensive training in command and management.
Training for the IC may require more than 24 hours of total training. The 24 hours covers 29 CFR
1910.120(q)(6)(ii)(A)-(F), and additional training would be needed for (6)(v)(A)-(F). The training
hours suggested in the standard are minimums. HAZWOPER training programs often must ex-
ceed the 8, 24, or 40 hours minimums in order to include all of the required subjects.
HAZWOPER--55
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(q)(6) Training.
An employer with a limited range of hazardous substances on-site may opt to supply their per-
sonnel with one type of PPE, and require employees to wear the entire complement of PPE for
any response. This strategy would relieve that particular employer of the requirement of training
HAZMAT technicians to be able to “select appropriate PPE,” if employees are trained in the PPE
which they are required to wear, and which will always provide sufficient protection.
NOTE: If an employer selects a single type of PPE for all releases that require an emergency re-
sponse, the employer must be sure to evaluate the full range of performance criteria that PPE
must meet, such as likely chemical exposures, heat stress, physical constraints, maintenance,
and permeability.
• Another example of requirements specified in the standard that may not be universally
applicable is found in 29 CFR 1910.120(q)(6)(iii)(B), training for HAZMAT technicians,
where knowledge of “the classification, identification, and verification of known and un-
known materials by using field survey instruments and equipment” is required. In many
chemical manufacturing facilities this may not be necessary, because all hazardous sub-
stances that have a potential for being released are known.
- The emergency response plan and training components may cover this by identifying the
known hazardous substances that would cause, or have the potential to cause, an
emergency if released. Where mixtures of hazardous substances may occur in an emer-
gency and/or hazardous byproducts may be formed during an emergency, the plan must
anticipate, identify, and include training components about these mixtures or byproducts.
- Employees trained in this limited manner would only be able to respond to spills on
site that involve the limited range of hazardous substances in which they are trained.
For example, employees trained to respond only to releases of chlorine may not re-
spond to a release of ethylene oxide, without broadening their limited training.
(q)(7) Training Alternatives for Employers
A video-only approach to train employees would not be suffi-
cient, although videos could be used for part of the training if the
employer can fully assure that the employee has sufficient
knowledge and skills. Providing an instructor to respond to the
employees’ questions after the video presentation, and evaluat-
ing employee understanding of the material would be required.
Higher levels of training would require hands-on training and
more interaction with the instructor.
• An in-house training program, among other options, may be developed. Credential re-
quirements for trainers is defined in 29 CFR 1910.120(q)(7).
• Equivalent training for First Responder Awareness Level and First Responder Operations
Level is acceptable, as per §1910.120(q)(6)(i) and (ii), which states that employees must
“have sufficient training or have had sufficient experience to objectively demonstrate com-
petency in the following areas...” However, the employer must ensure that the employee
accomplishes all training objectives.
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(q)(8) Refresher Training

Refresher training is required because employees must stay up-to-date in their skills and knowl-
edge. If the employee has gone without refresher training for more than twelve months, the em-
ployer must evaluate whether the initial comprehensive training may need to be repeated.
Uncontrolled Hazardous Waste Sites
There are often many hazards at a waste site. The employee must be trained to recognize the
hazards and appropriate work practices to minimize those hazards. The employee must also be
well trained in the use of respirators and other forms of personal protective equipment. Without
training, that equipment may not be used effectively and may not provide adequate protection.
An extensive training program is necessary to assure that employees can use personal protec-
tive equipment effectively.
HAZWOPER includes specific provisions at 29 CFR 1910.120(e) for initial and routine training of
employees before they would be permitted to engage in hazardous waste operations that could
expose them to safety and health hazards. The intent of the training provisions is to provide
workers with the knowledge and skills necessary to perform their jobs with minimal risk to their
safety and health.
General Site Worker Training

The requirements ask for a minimum of 40 hours of initial instruc-
tion off the site, and a minimum of three days of actual field expe-
rience under the direct supervision of a trained and experienced
supervisor, at the time of job assignment. This would apply to all
general site workers (such as equipment operators, general la-
borers, supervisory personnel, etc.) engaged in hazardous sub-
stance removal. The exceptions to this general training are dis-
cussed below.
Management and Supervisor Training

Managers and supervisors at regulated facilities, who are directly responsible for the site’s opera-
tions, must have the same training as that of site employees and additional time for specialized
training on managing hazardous waste operations. Since these managers and supervisors are
responsible for directing others, it is necessary to enhance their ability to provide guidance and
to make informed decisions. Therefore, managers and supervisors must have eight additional
hours of training.
Task-Specific Level of Training

During the development of HAZWOPER, it was argued by industry that 40 hours of training was
excessive for general laborers who may be installing perimeter fencing around an unopened site
and who are not exposed to any hazards. This type of employee normally will not be wearing the
type of PPE or be performing the type of tasks associated with removal of hazardous wastes.
On the other hand, employees who will be “digging in the dirt” after the site has been opened in
order to remove hazardous waste may need additional training because of the types of equip-
ment they will be using and the types of hazards to which they will be exposed.
HAZWOPER--57
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Therefore, for certain types of workers, OSHA has decided less training is necessary. For exam-
ple, those workers who visit sites only on occasion and then under the supervision of experi-
enced site workers (such as those doing groundwater monitoring, land surveying, or geophysical
surveying) are required to have 24 hours of training and one day of on-the-job training. This
same level of training is appropriate for those general site workers who work in areas which have
been monitored and fully characterized as safe without respirators.
Workers who have received the 24 hours of training and later become general site workers or
who are required to wear respirators, must have the additional 16 hours and two days of training
to equal what is required.
Equivalent Training
Employees would not need to be retrained at each site at which they work. If an employee re-
ceived the required training at one site, and has a certificate to substantiate this, he could use
that training to meet the requirements at other sites even if it involved a different employer, pro-
vided the previous training addressed the hazards at the new site.
In addition, if the cleanup operations at the hazardous waste site involve regulated waste, includ-
ing infectious material, employees must also receive training under the bloodborne pathogens
standard (§1910.1030). The standard, which became effective on July 6, 1992, requires specific
training and procedures to be implemented where employees have occupational exposure to
blood or other potentially infectious material. If there is a conflict or overlap in the requirements of
the HAZWOPER and the bloodborne pathogens standards, then the provision that is more pro-
tective of the employee’s health and safety would apply.
Emergency Response Training

According to §1910.120(e)(7), employees who are engaged in responding to hazardous emer-
gency situations at hazardous waste clean-up sites that may expose them to hazardous sub-
stances shall be trained in how to respond to such expected emergencies.
Qualifications for Trainers

Trainers who teach initial training must have completed a training course covering the subjects
they are expected to teach. Or they can have the academic credentials and instruction experi-
ence necessary to have a good command of the subjects and also be a competent instructor. In
other words, OSHA wants you to select your trainer and/or training program carefully so that you
are not just meeting the letter of the law but rather producing well trained workers.
The employer must certify that each covered employee has attended and successfully completed
the required training. Any person who has not been certified cannot engage in hazardous waste
operations. Currently OSHA does not certify individuals or approve training programs. It is the
employer who must show, by documentation or certification, that an employee’s work experience
and/or training meets the requirements in HAZWOPER.
There must be a written document that clearly identifies the employee, the person certifying the
employee, and the training and/or past experience which meets the requirements. One possibility
would be to include this information in the employee’s personnel file. The preferred method is to
HAZWOPER--58
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include this information on a separate certificate for each employee. A written certificate must be
given to each person so certified.
Refresher Training
Employees must be retrained on an annual basis on relevant matters such as review of health
hazards and the use of personal protective equipment (PPE). Employees at hazardous waste
operations may face serious health and safety risks. Reminders are needed of this and of work
practices necessary to avoid hazards. PPE provides much of this protection. If there is no retrain-
ing in the use, care, and maintenance of PPE, such equipment is unlikely to be properly utilized
to provide adequate protection.
In all areas of training, whether it be for general site employees, supervisors at the site, or for the
use of specific equipment, the level of training provided must be consistent with the worker’s job
function and responsibilities. Refresher training must be provided to reemphasize the initial train-
ing and to update employees on any new policies or procedures.
Initial Training
In accordance with §1910.120(p), a training program must be
developed which is part of the employer’s safety and health pro-
gram, for employees involved with hazardous waste operations
at TSD facilities. The goal should be to enable the worker to
perform assigned tasks in a safe manner which does not endan-
ger the employee or others. Initial training must be 24 hours,
with annual refresher training of eight hours.
Current Employees and Equivalent Training

If a current employee has had work experience or prior training equivalent to that required by
HAZWOPER, it will be considered that the worker meets the initial training requirements. Equiva-
lent training includes training that was received from actual site work experience. The worker will
still require the eight hours of annual refresher training.

If the TSD facility is involved in treating, storing, or disposing of infectious waste, employees will
also need to receive training as required by the bloodborne pathogens standard (§1910.1030).
The standard, which became effective on July 6, 1992, requires specific training and procedures
to be implemented where employees have occupational exposure to blood or other potentially
infectious material. If there is a conflict or overlap in the requirements of the HAZWOPER and
the bloodborne pathogens standards, then the provision that is more protective of the em-
ployee’s health and safety would apply.
Also, if the TSD facility handles infectious wastes and an employee could potentially be exposed
to the wastes during an emergency response, the employee must also receive training as re-
quired by the bloodborne pathogens standard (§1910.1030).
HAZWOPER--59
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Emergency Response Training

According to §1910.120(p)(8)(iii), training for TSD employees involved in emergency response
must be completed before they are called upon to perform in real emergencies. Such training
must include the elements of the emergency response plan, standard operating procedures for
the job, PPE to be used, and procedures for handling emergency incidents.
There are two exceptions to the general training requirements above.
1. All employees do not need to receive complete training. The employer may divide the
work force so that a sufficient number of employees who have responsibility to control
emergencies have the training specified. All other employees, who might first respond to
an emergency incident, must have sufficient awareness training to recognize that an
emergency response situation exists. They must then summon the fully trained em-
ployees and not attempt control activities for which they are not trained.
2. An employer need not train all employees if arrangements have been made in advance
for an outside fully trained emergency response team to respond in a reasonable period.
All other employees, who might first respond to an emergency incident, must have suffi-
cient awareness training to recognize that an emergency response situation exists. They
must then summon the designated outside fully trained emergency response team for
assistance.
The employer must certify that each covered employee has attended and successfully completed
the required training, or certify the employee’s competence yearly. Keep careful records of what
method was used to demonstrate competency for certification.
Qualifications of Trainers
Trainers who teach initial training must have completed a training course covering the subjects
they are expected to teach. Or they can have the academic credentials and instruction experi-
ence necessary to have a good command of the subjects and also be a competent instructor. In
other words, OSHA wants you to select your trainer and/or training program carefully so that you
are not just meeting the letter of the law but rather producing well trained workers.
Employees who have received the initial training must be given a certification attesting that they
have successfully completed the necessary training.
Refresher Training
According to §1910.120(p)(7)(ii), current employees shall receive eight hours of refresher training
annually. Also, according to §1910.120(p)(8)(iii)(C), employers must certify that each emergency
response personnel member’s competency at least yearly. The method used to demonstrate
competency for certification of training shall be recorded and maintained by the employer.
First Receiver Response

According to the OSHA Best Practices for Hospital-based First
Recievers of Victims from Mass Casualty Incidents Involving the
Release of Hazardous Substances, healthcare workers at a
hospital receiving contaminated victims for treatment may be
termed “first receivers.” This group is a subset of first respond-
ers (e.g., firefighters, law enforcement, HAZMAT teams, and
HAZWOPER--60
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ambulance service personnel). However, most first responders typically act at the site of an inci-
dent (i.e., the location at which the primary release occurred). In contrast, inherent to the defini-
tion of first receivers, is an assumption that the hospital is not itself the primary incident site, but
rather is remote from the location where the hazardous substance release occurred. Thus, the
possible exposure of first receivers is limited to the quantity of substance arriving at the hospital
as a contaminant on victims and their clothing or personal effects.
First receivers typically include personnel in the following roles: clinicians and other hospital staff
who have a role in receiving and treating contaminated victims (e.g., triage, decontamination,
medical treatment, and security) and those whose roles support these functions (e.g., set up and
patient tracking).
The training indicated for first receivers depends on the individuals’ roles and functions, the
zones in which they work, and the likelihood that they will encounter contaminated patients.
OSHA recognizes that hospital staff who decontaminate victims at the hospital are removed from
the site of the emergency. However, letters of interpretation provide that HAZWOPER First Re-
sponder Operations Level and First Responder Awareness Level training meet the requirements
for first receivers in certain roles and positions. For other employees, a briefing at the time of the
incident will be appropriate. In each case, the training must be effective, that is, be provided in a
manner the employee is capable of understanding.
The following sections discuss HAZWOPER training provisions and contemplate levels of train-
ing commensurate with the employees’ designated role within an emergency management plan.
Operations Level Training

OSHA letters of interpretation specify that hospitals must provide HAZWOPER First Responder
Operations Level training to first receivers who are expected to decontaminate victims or handle
victims before they are thoroughly decontaminated. This level of training is appropriate for any-
one with a designated role in the Hospital Decontamination Zone.
Training requirements for First Responder Operations Level appear under 29 CFR
1910.120(q)(6)(ii), which indicates a minimum training duration of eight hours and outlines topics
to be covered (competencies the employee must acquire). Both the required competencies and
training time were recently confirmed in an interpretive letter. OSHA, however, allows these top-
ics (but not the minimum training time) to be tailored to better meet the needs of first responders.
For example, the training might omit topics that are not directly relevant to the employee’s role
(e.g., recognition of Department of Transportation placards), but instead should include alterna-
tive training on hazard recognition (e.g., signs and symptoms of contamination or exposure), on
decontamination procedures provided by the hospital, and on the selection and use of PPE.
Training that is relevant to the required competencies counts toward the eight-hour requirement,
even if the training is provided as a separate course. For example, training on PPE that will be
used during victim decontamination activities may be applied towards the eight-hour minimum
Operations Level training requirement, regardless of whether the PPE training is conducted as
part of a specific HAZWOPER training course or as part of another training program.
First Responder Awareness Level training also counts towards the 8-hour requirement for Opera-
tions Level training. This point is clarified in a recent letter of interpretation issued by OSHA, “...if
you spend two hours training employees in the required competencies for First Responder
Awareness Level as described in §1910.120(q)(6)(i)(A)--(F), then you would need to spend at
least six additional hours training employees in the required competencies for First Responder
HAZWOPER--61
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Operations Level as described in §1910.120(q)(6)(ii)(A)--(F). Depending on the employees’ job

duties and prior education and experience, more than eight hours of training may be needed.”
As an alternative to the 8-hour training requirement, the HAZWOPER Standard allows em-
ployees to demonstrate competence in specific areas, presented in §1910.120(q)(6)(ii) and re-
produced in Section 1.2.3.1 of Appendix A. OSHA reaffirmed this point in a letter of interpreta-
tion, stating, “...employees with sufficient experience may objectively demonstrate the required
competencies instead of completing eight hours of training.” However, it is important to note that
in most hospital settings it might be difficult to ensure that employees have sufficient experience
to waive the training requirement. Most hospital employees do not have extensive experience
with hazardous materials or powered air-purifying respirators (PAPRs), and decontamination ac-
tivities are performed infrequently.
Hospitals must document how training requirements are met. This is particularly important when-
ever hospitals allow employees to satisfy any portion of the training requirement through other
related training or through demonstration of competence. The HAZWOPER Standard requires
and an OSHA letter of interpretation confirms that “the employer must certify in writing the com-
parable training or demonstrated competencies.”
Annual refresher training is specified under §1910.120(q)(8)(i), or the parallel State Plan stan-
dards; however, the length of the refresher training is not specified. Instead, the standard re-
quires that employees trained at the First Responder Operations Level “shall receive annual re-
fresher training of sufficient content and duration to maintain their competencies, or shall
demonstrate competency in those areas at least yearly.” Additionally, the hospital must document
that refresher training was performed, or alternatively, keep a record of how the employee dem-
onstrated competency.
The initial and annual refresher training to the HAZWOPER First Responder Operations Level
must be provided to all hospital personnel who have been designated to provide treatment,
triage, decontamination, or other services to contaminated individuals or who may reasonably be
expected to come in contact with those individuals arriving at the hospital. Training core elements
must include:
• Understanding the hospital emergency operations plan and their roles in the response;
• Site safety, including risks to receiving personnel;
• Appropriate selection and use of PPE; and
• Decontamination procedures.
The Operations Level training related to the use of PPE must include topics such as those speci-
fied by OSHA’s Personal Protective Equipment Standard (29 CFR 1910.132). Under that stan-
dard, training must be provided to each employee who is required to use PPE. At a minimum,
that training must cover the following:
• When PPE is necessary,
• What PPE is necessary,
• How to properly put on, remove, adjust, and wear PPE,
HAZWOPER--62
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• Limitations of PPE, and

• Proper care, maintenance, useful life, and disposal of PPE.
Employees must demonstrate their understanding of the training by showing they can use the
PPE properly, prior to using the protective equipment in the workplace. Refresher training is
warranted when the employee cannot demonstrate proficiency in the proper care and use of
the PPE, when changes in the workplace render the previous training obsolete, or when
changes in the type of PPE to be used render the previous training obsolete. OSHA specifies
that the hospital must maintain a written record of employee PPE training.
Operations Level training also must include training required by OSHA’s Respiratory Protection
Standard (§1910.134), or the parallel State Plan standards. Specifically, any employee who must
wear a respirator must be trained in the proper use and limitations of that device prior to its use
in the workplace. The training must be comprehensive enough that the employee is able to dem-
onstrate knowledge of the seven training topics specified in the standard and outlined below. The
employee also must be able to demonstrate competence in wearing the complete PPE en-
semble, including respirator, protective garment, gloves, boots, and other safety equipment re-
quired for the employee’s role. Refresher training is required at least annually, or sooner if
changes in the workplace or type of respirator render previous training inadequate. Refresher
training is also required if the employee does not demonstrate proficiency in the proper care and
use of the respirator, or any other time when retraining appears necessary to ensure safe respi-
rator use.
At a minimum, training under OSHA’s Respiratory Protection Standard must cover the following
topic areas:
• The nature of the respiratory hazard, and why a respirator is needed;
• Respirator capabilities, limitations, and consequences, if the respirator is not used cor-
rectly;
• How to handle respirator malfunctions and other emergencies;
• How to inspect, put on, remove, use, and check seals on the respirator;
• Maintenance and storage procedures;
• When to change cartridges on air-purifying respirators (APRs);
• How to recognize medical signs and symptoms that may limit or prevent effective use of a
respirator; and
• General requirements of the respiratory protection program.
Note that first receivers who wear respiratory protection must be deemed medically qualified to
do so, following the process required by §1910.134(e)(1) through (e)(6) of OSHA’s Respiratory
Protection Standard. Employees who wear tight-fitting respirators also must be properly fit
tested, as required in §1910.134(f), or the parallel State Plan standards.
HAZWOPER--63
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Awareness Level Training

First Responder Awareness Level training is required for those employees who work in the con-
taminant-free Hospital Post-decontamination Zone, but might be in a position to identify a con-
taminated victim who arrived unannounced. This group includes Emergency Department (ED)
clinicians, ED clerks, and ED triage staff who would be responsible for notifying hospital authori-
ties of the arrival, but would not reasonably be anticipated to have contact with the contaminated
victims, their belongings, equipment, or waste. The group also includes decontamination system
set-up crew members and patient tracking clerks, if their roles do not put them in contact with
contaminated victims, their belongings, equipment, or waste (e.g., setting up the decontamina-
tion system before victims arrive, or tracking patients from a location outside of the decontamina-
tion zone).
First Responder Awareness Level training also is required for hospital security guards who work
away from the Hospital Decontamination Zone, but who may be involved tangentially in a mass
casualty event (specifically, those security personnel who would not reasonably be anticipated to
come in contact with contaminated victims, their belongings, equipment, or waste. Security staff
assigned to roles in the Hospital Decontamination Zone would require a higher level of training
(e.g., First Responder Operations Level).
Training requirements for the First Responder Awareness Level appear under §1910.120(q)(6)(i),
which does not require a specific minimum training duration, but outlines topics to be covered
(competencies the employee must acquire). As with Operations Level training, the HAZWOPER
Standard allows an alternative to the Awareness Level training requirement. Training can be
waived if the employee has had sufficient experience to objectively demonstrate competency in
specific areas. These areas are listed in §1910.120(q)(6)(i), or the parallel State Plan standards.
Annual refresher training is required for employees trained at the Awareness Level. As with Op-
erations Level refresher training, the class content must be adequate to maintain the employees’
competence, and the hospital must document the training or the method used to demonstrate
the employees’ competence.
Briefing for Skilled Support Personnel Whose Participation was Unanticipated

A member of the staff who has not been designated, but is unexpectedly called on to minister to
a contaminated victim, or perform other work in the Hospital Decontamination Zone, is consid-
ered “skilled support personnel.” Examples include a medical specialist or a trade person, such
as an electrician. These individuals must receive expedient orientation to site operations, imme-
diately prior to providing such services. The orientation must include:
• Nature of the hazard (if known),
• Expected duties,
• Appropriate use of PPE, and
• Other appropriate safety and health precautions (e.g., decontamination procedures).
As part of the briefing, these personnel also must be medically cleared for respirator use and
properly fit tested (if wearing a tight-fitting respirator), as required by §1910.134 (Respiratory
Protection), or the parallel State Plan standards.
HAZWOPER--64
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While a “just in time” briefing during the response is the only required training for these person-
nel, time and resource limitations inherent in a crisis likely will diminish the effectiveness of such
training. Thus, hospitals should diligently consider the broad range of skills/capabilities that may
be required within the Decontamination Zone during a mass casualty event and attempt to identi-
fy, and train, all persons who may be called to work in the Decontamination Zone prior to a mass
casualty event.
Hazard Communication Training

Hospitals should consider offering a basic level of training for other em-
ployees in the ED, such as housekeeping staff. This group could include
those personnel who do not have a role in the decontamination process, rea-
sonably would not be expected to encounter self-referred contaminated pa-
tients, and reasonably would not be expected to come in contact with con-
taminated victims, their belongings, equipment, or waste. OSHA’s Hazard
Communication Standard offers a useful model for appropriate training, which
could include general information on the hospital’s emergency procedures
and plans for mass casualty incidents involving contaminated victims, steps
the employees can take to protect themselves (usually by leaving the area),
and the measures the hospital has implemented to protect employees in the
ED. While not required under the OSH Act, such training could help to ensure that all staff in the
ED understand what precautions and actions would (and would not) be expected of them if an
incident occurred.
Summary of First Receiver Training

The table below summarizes OSHA’s current guidance on training first receivers for mass casual-
ty emergencies. References to related OSHA interpretation letters are included. Employees are
categorized according to zone (namely, Hospital Decontamination Zone and Post-decontamina-
tion Zone); whether they have designated roles in the zone; and the likelihood of contact with
contaminated victims, their belongings, equipment, or waste. Hospitals should note that the train-
ing levels presented are minimum training levels and can be increased or augmented, as ap-
propriate, to better protect employees, other patients, and the facility in general.
Mandatory or
First receivers covered: Training:
recommended:
All employees with designated roles in the Hospital Decontamina- First Responder operations lev- Mandatory
tion Zone. This group includes, but is not limited to: (decontamina- el initial training and annual re-
tion staff, including decontamination victim inspectors; clinicians fresher training. Both initial and
who will triage and/or stabilize victims prior to decontamination; se- refresher training may be satis-
curity staff [e.g., crowd control and controlling access to the emer- fied by demonstration of compe-
gency department (ED)]; set-up crew; and patient tracking clerks). tence.
Other employees whose role in the Hospital Decontamination Zone Briefing at the time of the inci- Mandatory
was not previously anticipated (i.e., who are called in incidentally), dent.
e.g., a medical specialist or trade person, such as an electrician.
HAZWOPER--65
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Mandatory or
First receivers covered: Training:
recommended:
Security personnel, set-up crew, and patient tracking clerks as- First Responder awareness lev- Mandatory
signed only to patient receiving areas proximate to the Decon- el initial training and annual re-
tamination Zone where they might encounter, but are not ex- fresher training. Both initial and
pected to have contact with, contaminated victims, their belong- refresher training may be satis-
ings, equipment, or waste. This group includes, but is not limited fied by demonstration of compe-
to: ED clinicians, clerks, triage staff, and other employees asso- tence.
ciated with emergency departments, who might encounter self-
referred contaminated victims (and their belongings, equipment,
or waste) without receiving prior notification that such victims
have been contaminated.
Other personnel in the Hospital Post-decontamination Zone who Training similar to that outlined in Recommended
reasonably would not be expected to encounter or come in contact the Hazard Communication
with unannounced contaminated victims, their belongings, equip- Standard.
ment, or waste. This group includes, but is not limited to other ED
staff, such as housekeepers.
Training Tools: Handouts, Tests, Puzzles, Posters, and Cartoons

The next several pages contain employee training handouts, tests, posters, and cartoons. J. J.
Keller & Associates, Inc., grants permission to reproduce the handouts, tests, puzzles, posters,
cartoons, and overhead transparencies included in this tab provided that Keller’s copyright notice
and imprint, and those of the illustrator (if provided), remain visible on all copies. The copies you
make may not be resold or incorporated in any other publication whether on a profit or non-profit
basis; they are solely for your internal use.
Test Answer keys
General Site Worker Test TSD Facility Worker Test Emergency Response Test 1
1. C 6. C 1. C 6. A 1. D 6. D
2. D 7. A 2. C 7. B 2. A 7. A
3. D 8. C 3. C 8. C 3. B 8. B
4. D 9. A 4. A 9. B 4. D 9. A
5. C 10. D 5. A 10. D 5. D 10. D
Emergency Response Test 2
1. A 11. C 21. B 31. B 41. B

2. B 12. A 22. A 32. A 42. C
3. A 13. A 23. D 33. B 43. B
4. C 14. D 24. D 34. B 44. B
5. C 15. B 25. D 35. B 45. B
6. A 16. D 26. C 36. A 46. B
7. B 17. D 27. D 37. C 47. B
8. C 18. C 28. B 38. A 48. D
9. B 19. C 29. B 39. C 49. A
10. D 20. C 30. D 40. D 50. D
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HAZWOPER—An Overview Handout

Overview
The Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to
all employees who are exposed to or are potentially exposed to hazardous substances:
• At a hazardous waste cleanup site,

• At a hazardous waste treatment, storage, and disposal
facility, and/or
• During emergency response operations.

The standard requires that employees be trained unless:
• There are no hazardous substances in the workplace,

or
• The employee has no access to the hazard.
Required training
Your employer must train you to the level required by your job functions and responsibilities. In
general all employees covered by HAZWOPER must be trained to:
• Recognize and prevent hazards;

• Select, care for, and use respirators properly, as well as other types of personal protective
equipment;
• Understand engineering controls (such as ventilation) and their use;

• Understand the emergency response plan, medical surveillance requirements, confined
space entry procedures, spill containment program, and any appropriate work practices.
Employees must not perform any hazardous waste operation unless they have been trained to
the level required by the job function and responsibility.
HAZWOPER--67
Handouts may be copied and distributed to E Copyright 2002
workers for use during your training session 9/07 Published by J. J. Keller & Associates, Inc.
or as a handy reminder. Please refer to the Neenah, WI 54957-0368
manual’s INTRODUCTION for restrictions.
General Site Worker Handout

The dumping of hazardous waste poses a significant threat to the environment. Hazardous
waste can cause fires, explosions, and pollution of air, water, and land.
Hazardous waste operations and emergency response (HAZWOPER) covers the following opera-
tions, unless the employer can demonstrate that the operation does not involve employee exposure:
• Clean-up operations required by a governmental body, whether
federal, state, or local involving hazardous substances that are
conducted at uncontrolled hazardous waste sites.
• Corrective actions involving clean-up operations at sites cov-
ered by the Resource Conservation and Recovery Act of
1976 (RCRA).
• Voluntary clean-up operations at sites recognized by federal,
state, or local governmental bodies as uncontrolled hazard-
ous waste sites.
• Operations involving hazardous wastes that are conducted at treatment, storage, and dis-
posal (TSD) facilities.
• Emergency response operations for release of, or substantial threats of the release of, haz-
ardous substances without regard to the location of the hazard.
HAZWOPER Training
All employees working on-site (such as equipment operators, general laborers and others) ex-
posed to hazardous substances, health hazards, or safety hazards and their supervisors and
management responsible for the site must receive training on the following elements:
• Names of personnel and alternates responsible for site safety and health.
• Safety, health, and other hazards present on the site.
• Use of personal protective equipment (PPE).
• Work practices by which the employee can minimize risks from hazards.
• Safe use of engineering controls and equipment on-site.
• Medical surveillance requirements, including recognition of symptoms and signs which might
indicate overexposure to hazards.
• Specific elements of the site-specific safety and health plan.
• An emergency response plan for safe and effective responses to emergencies, including the
necessary PPE and other equipment.
• Confined space entry procedures.
• Spill containment program.
Personal Protection
To protect yourself from hazardous substances, it’s important to understand the following infor-
mation:
• Knowing what PPE should be worn.
• Understanding engineering controls and their use.
• Using proper decontamination procedures.
• Understanding the emergency response plan, medical surveillance requirements, confined
space entry procedures, spill containment program, and any appropriate work practices.
HAZWOPER--68
Handouts may be copied and distributed to work- E Copyright 2002
ers for use during your training session or as a 9/07 Published by J. J. Keller & Associates, Inc.
handy reminder. Please refer to the manual’s Neenah, WI 54957-0368
INTRODUCTION for restrictions.
TSD Facility Worker Handout

In order to fully understand the hazards faced when you work with hazardous chemicals, it’s
important to have basic knowledge of commonly used terms related to hazard measurement.
The following information defines some parameters used by OSHA and others when assessing
chemical hazards.
Permissible Exposure Limit (PEL)
Permissible exposure limits are enforceable standards promul-
gated by OSHA. In many cases they are derived from TLVs
published by ACGIH. The PEL for a substance is the 8-hour
time-weighted average or ceiling concentration above which
workers may not be exposed. Although personal protective
equipment may not be required for exposures below the PEL,
its use may be advisable where there is a potential for overex-
posure. See the tables and substance-specific standards in 29
CFR Part 1910, Subpart Z for additional details.
Recommended Exposure Limit (REL)
A NIOSH recommended exposure limit (REL) is the workplace exposure concentration recom-
mended by NIOSH for promulgation by OSHA as a PEL, but is not enforceable as is the OSHA
PEL. In some cases, NIOSH has described time-weighted average concentrations in terms of
10-hour, rather than 8-hour, averages.
IDLH Concentrations
Immediately dangerous to life and health (IDLH) exposure concentrations have been established
by the NIOSH/OSHA Standards Completion Program (SCP) as a guideline for selecting respira-
tors for some chemicals. The definition of IDLH varies depending on the source. For example,
the Mine Safety and Health Administration Standard (30 CFR Part 11.3(t)) defines IDLH condi-
tions as those that pose an immediate threat to life or health or that pose an immediate threat of
severe exposure to contaminants such as radioactive materials that are likely to have adverse
cumulative or delayed effects on health.
The NIOSH Pocket Guide to Chemical Hazards defines IDLH concentration as the “...maximum
level from which one could escape within 30 minutes without any escape-impairing symptoms or
any irreversible health effects...” The American National Standards Institute (ANSI) defines IDLH
as “any atmosphere that poses an immediate hazard to life or produces immediate irreversible
debilitating effects on health...”
Regardless of their exact definition, all IDLH values indicate those concentrations of toxic sub-
stances from which escape is possible without irreversible harm should a worker’s respiratory
protective equipment fail. At hazardous waste sites, IDLH concentrations should be assumed to
represent concentrations above which only workers wearing respirators that provide the maxi-
mum protection (i.e., a positive-pressure, full-facepiece, supplied-air respirator with positive-pres-
sure SCBA) are permitted. Specific IDLH values for many substances can be found in the
NIOSH Pocket Guide to Chemical Hazards.
HAZWOPER--69
Emergency Response Handout

The Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR
1910.120, training requirements covers individuals who respond to emergencies. For example,
first responders, hazardous materials technicians, hazardous materials specialists, fire depart-
ment or law enforcement personnel are all individuals who may respond to emergency response
situations. In addition, there may be employees at your facility who are responsible for respond-
ing to emergencies.
Recognizing a Hazardous Substance Release
Listed below are some examples of hazardous substance release situations which could occur at
your facility:
• A hazardous substance release requires evacuation of em-
ployees in the area.
• The response comes from outside the immediate release
area.
• The release poses, or has the potential to pose, 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 immi-
nent danger.
• There is uncertainty that the personnel in the work area
can handle the severity of the hazard with the personal
protective equipment (PPE) provided.
• The situation is unclear, or data is lacking on important factors.
Emergency responders must be able to recognize a hazardous substance release. In addition,
they should demonstrate a competency in:
• Analyzing an incident to determine the hazardous substances that may be present.
• Having hands-on experience with relevant sources of information that addresses hazardous
substance releases.
• Developing procedures for implementing continuing response actions consistent with the
local emergency response plan, the organization’s standard operating procedures, and the
Department of Transportation’s Emergency Response guide.
• Understanding the potential hazards of a hazardous release site, including fires and explo-
sions, confined space hazards, electrical hazards, powered equipment hazards, motor ve-
hicle hazards, and walking/working surface hazards.
Hazards Involved
Emergency responders may encounter, and possibly be exposed to, several health and safety
hazards including:
• Chemical exposure. • Safety hazards.

• Fire and explosion. • Electrical hazards.
• Oxygen deficient atmospheres. • Heat stress.
• Ionizing radiation. • Cold exposure.
• Biological hazards.
HAZWOPER--70
Emergency Response Plan Handout

Your company is required to have a written plan in place for handling workplace spills and leaks.
This plan is called the Emergency Response Plan (ERP). The plan is designed to handle antici-
pated emergencies prior to the commencement of emergency response operations. You should
know the procedures in your written plan and follow them when an emergency like a spill or leak
occurs in your workplace.
The emergency response plan covers the following areas:
1. Pre-emergency planning and coordination with outside parties;
2. Personnel roles, lines of authority, training, and communication;
3. Emergency recognition and prevention;
4. Safe distances and places of refuge;
5. Site security and control;
6. Evacuation routes and procedures;
7. Decontamination;
8. Emergency medical treatment and first aid;
9. Emergency alerting and response procedures;
10. Critique of response and follow-up; and
11. Personal protective and emergency equipment.
Hazards Involved
Emergency responders may encounter, and possibly be exposed to, several health and safety
hazards including:
• Chemical exposure, • Safety hazards,

• Fire and explosion, • Electrical hazards,
• Oxygen deficient atmospheres, • Heat stress, and
• Ionizing radiation, • Cold exposure.
• Biological hazards,
Because of the hazards, OSHA requires special training and equipment to handle hazardous
spills or leaks. This training is serious business and is called “HAZWOPER” training. HAZWOP-
ER stands for Hazardous Waste Operations and Emergency Response.
If a leak or spill occurs . . .
Knowing proper procedure is important. What you do depends on your company’s emergency re-
sponse plan and what you are trained to do in such an emergency. If you are not trained, your only
responsibility may be to report the spill to your company’s emergency response person and keep
other employees away from the area. Attempting to handle the leak may do more harm than good.
HAZWOPER--71
Emergency Spills and Releases Handout

You could be exposed to chemical spills or hazardous waste. During excavation operations, for
example, many companies have been surprised by the sometimes deadly things they have un-
covered. That’s why OSHA created 29 CFR 1926.65, HAZWOPER. Under this rule, your employ-
er can either (1) participate in the handling of emergencies involving hazardous waste or chemi-
cal spills, or (2) immediately evacuate workers and call in trained hazardous materials (HazMat)
teams.
How can HAZWOPER involve you?
Preparing for accidental chemical releases involves special training. OSHA has set up formal
training for emergency responders under HAZWOPER regulations, with training levels ranging
from awareness training for first response to technical training for those who solve problems
associated with spill cleanup.
What should you do in case of a spill?
Whether it’s a solid or a liquid leak or spill, you can be exposed to toxic dust or vapor without
even knowing it. If you are properly trained, act with care and speed. However, if you have not
received training, do not respond to a chemical leak or spill. Instead, follow your company’s
emergency action plan for reporting leaks and spills and evacuating.
While it is vital to avoid panic, it is equally vital to get people out of
harm’s way as quickly as possible. Assess site hazards and act only
when you do not endanger yourself. You want to help your fellow em-
ployees, but you won’t do that if you become a victim yourself.
Some of the things you can do before help arrives are:
• Determine the potential hazards. (Look at the material safety data
sheet.)
• Know about spill equipment and safety personnel.
• Know the exits and escape routes.
• Know the location of fire extinguishers.
• Know first aid and where to get first aid equipment.
Act responsibly in chemical spill emergencies

Safety becomes extremely important when hazardous chemicals are spilled. A mistake here can
be deadly. Use the buddy system, whether you’re part of the emergency response team or not.
Don’t ever enter a chemical emergency situation alone.
Different chemicals will require different levels of protective clothing or other precautions. Don’t
touch spills without protection. Avoid contaminated clothing of injured persons. Certainly, if the
chemicals involved aren’t hazardous, respond immediately within your abilities.
Do only those things that you possess adequate training to perform. Check the area for potential
hazards such as electrical cords or wires near the spill or obstacles in the path of the emergency
response team. Check for injuries and notify emergency medical personnel. Decontaminate vic-
tims, if possible. Cooperate with emergency personnel when they arrive, and pass on any infor-
mation you’ve gathered.
HAZWOPER--72
Hazardous Waste Handout

Did you know that your work activities may generate hazardous waste? Hazardous waste is a
solid, liquid, or gaseous material with certain properties that could pose dangers to human health
or the environment. Those dangers are often ignitability, corrosivity, reactivity, or toxicity. Take a
look at the table below to find out the typical types of hazardous waste generated by construction
operations:
Operation Materials Hazardous waste generated

Paint preparation and Paint thinners, reducers, paints, Ignitable wastes, toxic wastes, spent
painting enamels, lacquers, epoxies, acrylics, solvents, paint wastes
primers, solvents
Carpentering and floor Adhesives, solvents, polishes and Spent solvents, toxic wastes
work varnishes, treated wood
Other specialty contracting Adhesives, paints, coatings, polishes, Ignitable wastes, toxic wastes, spent
activities varnishes, solvents petroleum prod- solvents
ucts
Heavy construction Motor oil and other petroleum prod- Used oil, asphalt wastes
ucts, asphalt
Wrecking and demolition Degreasers, cleaners, motor oil and Wreckage and debris that may con-
and vehicle/equipment other petroleum products, solvents, tain ignitable or toxic substances,
maintenance rust removers used oil, spent solvents, acid/alkaline
wastes, ignitable wastes, toxic
wastes
Containers of hazardous waste must be marked with the words, “Hazardous Waste,” along with
the date the waste was generated.
Because hazardous waste can be dangerous to humans and the environment, if you work with
hazardous wastes, you need to be trained in proper waste handling and emergency procedures
relevant to your responsibilities.
If applicable, you will find out how to use, inspect, repair, and
replace emergency and monitoring equipment. You will under-
stand communications or alarm systems and be able to prop-
erly respond to fires or explosions and ground-water contami-
nation incidents. And you will be able to shutdown operations.
If you are not properly trained, do not respond to a leak or spill.
Instead, follow your company’s emergency action plan for re-
porting leaks and spills and evacuating. The name and telephone number of the company’s
emergency coordinator and fire department should be listed next to your telephone.
If you manage hazardous wastes properly, there should be fewer hazards for you, your co-work-
ers, your community, and the environment. Recycling and reducing the amounts of waste gener-
ated can also increase safety. In fact, used oil, lead-acid and nickel-cadmium batteries, scrap
metal, pesticides, and mercury-containing thermostats should be recycled where possible.
HAZWOPER--73
Employee: Instructor:
Company/Division: Date:
General Site Worker Test

Directions: Read each statement carefully and circle the response that most fully answers the
question.
1. Minimum training for general site workers includes:

A. 24 hours of instruction off site and a minimum of three days actual field experience
B. 40 hours of instruction off site and a minimum of two days actual field experience
C. 40 hours of instruction off site and a minimum of three days actual field experience
D. 30 hours of instruction off site and a minimum of three days actual field experience
2. What are the most critical types of health and safety concerns for general site workers?
A. Fires and explosions
B. Heat stress
C. Biological hazards
D. All of the above are considered critical health and safety concerns
3. Personal protective equipment:
A. Should be used in conjunction with other protective methods, whenever possible
B. Can also create significant hazards to workers
C. Helps protect workers from chemical, physical, and biological hazards
D. All of the above are correct
4. Decontamination procedures:
A. Remove or neutralize contaminants
B. Protect the safety of employees
C. Protect equipment
D. All of the above are correct answers
5. What kinds of operations does the HAZWOPER standard cover?
A. Corrective actions involving cleanup operations at sites covered by the Resource Conservation and
Recovery Act of 1976
B. Operations involving hazardous wastes that are conducted at treatment, storage, and disposal
facilities
C. Both A and B
D. Neither A nor B
HAZWOPER--74
Tests may be copied and distributed to workers E Copyright 2002
for use during your training session or as a handy 9/07 Published by J. J. Keller & Associates, Inc.
reminder. Please refer to the manual’s Neenah, WI 54957-0368
6. Is a written certificate required when HAZWOPER training is complete?

A. No
B. Yes, depending on what level of training is achieved
C. Yes, a training certificate is given upon successful completion
D. No, it is the employer’s option to issue a certificate
7. What are some OSHA-related safety hazards an employee may encounter on a worksite?
A. Walking-working surface hazards
B. Vermin, rodents, and snakes
C. Water hazards
D. Toxicity hazards
8. Prior to handling a drum or container, the employer must assure that drums or containers meet which
requirements?
A. OSHA
B. OSHA and EPA
C. OSHA, EPA, and DOT
D. EPA regulations only
9. What is the purpose of a medical surveillance program?
A. To assess and monitor the health and fitness of employees working with hazardous substances
B. To ensure employees have received a certified physical before conducting hazardous waste opera-
tions
C. To alleviate any individuals who are not physically qualified to work in hazardous waste operation
worksites
D. To avoid any potential workers’ compensation claims
10. What kinds of items should be used in a spill containment program?
A. Absorbents, foams, and chemical containment materials

B. Long-handled wash brushes, paper or cloth towels
C. Gloves, goggles, respirators and other PPE as required for the area
D. All of the answers are correct
HAZWOPER--75
TSD Facility Worker Test

question.
1. Minimum training for new employees at TSD facilities includes:

A. 24 hours of instruction off-site and a minimum of three days actual field experience
B. 40 hours of instruction off-site and a minimum of two days actual field experience
C. 24 hours of instruction off-site and a minimum of two days actual field experience
D. 30 hours of instruction off-site and a minimum of three days actual field experience
2. Is a written certificate required when HAZWOPER training is complete?
A. No
B. Yes, depending on what level of training is achieved
C. Yes, a training certificate is given upon successful completion
D. No, it is the employer’s option to issue a certificate
3. The potential routes for chemical exposure include:
A. Inhalation and absorption
B. Inhalation, absorption, and injection
C. Ingestion, absorption, inhalation, and injection
D. Ingestion and injection
4. The categorical type(s) of chemical exposures include:
A. Acute and chronic
B. Acute only
C. Chronic only
D. Long term
5. What is the purpose of treatment, storage, and disposal operation facilities?
A. To treat hazardous waste to make it less hazardous or nonhazardous
B. To treat and store solid and hazardous waste for up to six months
C. To handle all hazardous waste which cannot be treated
D. To dispose of hazardous waste from large-quantity generators
HAZWOPER--76
6. Chronic exposure to a hazardous substance refers to:

A. Exposures to low concentrations of a contaminant over long periods of time
B. Exposures to low concentrations of a contaminant over short periods of time
C. Exposures to high concentrations of a contaminant over short periods of time
D. Exposures to high concentrations of a contaminant over long periods of time
7. Symptoms resulting from acute exposures to a hazardous substance:
A. May either occur shortly after or long after the exposure
B. Usually occur during or shortly after the exposure
C. Usually occur weeks after the exposure
D. Usually do not occur
8. What parts of your body are affected by chemicals?
A. Upper extremities
B. Lower extremities
C. All parts of your body can be affected
D. Only the internal organs are affected
9. What is the objective of a time-weighted average measurement?
A. To determine the average exposure of hazardous chemicals in a 24-hour period
B. To determine the average exposure over a typical 8-hour work shift
C. To determine the average exposure over a 12-hour work shift
D. To determine the average exposure for personnel working around all types of chemicals
10. What types of sampling are conducted to determine the severity of health hazards?
A. Personal sampling
B. Water sampling
C. Soil testing
D. All of the above are correct answers
HAZWOPER--77

question.
1. Emergency response refers to:

A. A response effort to a potentially uncontrolled release of a hazardous substance
B. A release that requires immediate attention because of imminent danger
C. Situations that are unclear, or data is lacking on important factors
D. All of the above could be considered emergency response situations
2. Potential routes for chemical exposure include:
A. Ingestion, absorption, inhalation, injection
B. Inhalation and absorption
C. Inhalation, absorption, and injection
D. None of the above
3. The primary purpose of an on-scene commander is to:
A. Oversee the evacuation of people from the incident site
B. Manage the operations of an incident site and delegate tasks to others
C. Ensure that only properly trained workers assist at the scene of an emergency
D. Assist with the emergency medical care of injured workers
4. The most critical types of health and safety concerns for workers involved in emergency response in-
clude:
A. Fire and explosion
B. Heat stress
C. Biological hazards
D. All of the above could be considered critical health and safety hazards
5. Personal protective equipment:
A. Helps protect workers from chemical, physical, and biological hazards
B. Can itself create significant hazards to workers
C. Only A is correct
D. Both A and B
HAZWOPER--78
6. Decontamination procedures help:

A. Remove or neutralize contaminants
B. Protect the safety of personnel
C. Protect and preserve equipment
D. All of the above
7. Chronic exposure to a hazardous substance refers to:
A. Exposures to low concentrations of a contaminant over long periods of time
B. Exposures to low concentrations of a contaminant over short periods of time
C. Exposures to high concentrations of a contaminant over short periods of time
D. Exposures to high concentrations of a contaminant over long periods of time
8. Symptoms resulting from acute exposures to a hazardous substance:
A. May either occur shortly after or long after the exposure
B. Usually occur during or shortly after the exposure
C. Usually occur weeks after the exposure
D. Usually do not occur
9. First responders at the awareness level:
A. Are likely to witness or discover a hazardous substance release
B. Respond passively to stop a hazardous substance release
C. Respond to releases in a defensive manner without trying to stop a release
D. Respond aggressively to stop a hazardous substance release
10. Emergency responders could be:
A. Employees at a facility
B. Firefighters
C. Law enforcement officials
D. All of the above are correct
HAZWOPER--79
question.
1. The four primary exposure routes (ways you may contact a substance) are:
A. Inhalation, Ingestion, Absorption, and Injection
B. Inhalation, Ingestion, Immersion, and Absorption
C. Lungs, Skin, Stomach, and Eyes
D. Breathing, Eating, Touching, and Forced
2. Once a responder determines a release requires emergency response, he/she must:
A. Begin clean-up and containment procedures
B. Initiate the notification process according to the emergency response plan
C. Immediately notify his/her supervisor
D. Call 911
3. Which one of the following is not a hazard related to hazardous substances:
A. MSDS
B. Confined space
C. Psychological
D. Electrical
4. The term “hazardous chemical” includes:
A. Certain EPA substances, biologic agents, flammable substances, and corrosives
B. Hazardous materials, carcinogens, medical waste, and hazardous waste
C. Certain EPA substances, biologic agents, hazardous materials, and hazardous waste
D. Hepatotoxins, nephrotoxins, neurotoxins, and agents that damage the lungs
5. A U.S. Department of Transportation placard will tell you:
A. The specific contents of the package
B. The proper shipping name
C. The hazard of the material
D. Both B and C
HAZWOPER--80
6. An “incidental release” means:

A. A release that can be absorbed, neutralized, or otherwise controlled by employees in the immediate
release area, or by maintenance personnel
B. A release that is not immediately dangerous, but that could become an emergency within a short
time frame
C. A release of a hazardous substance that presents safety or health hazards to employees only tem-
porarily
D. A release that does not require using personal protective equipment
7. This person may only respond to a release defensively:
A. Hazardous Materials Technician
B. First Responder Operations Level
C. First Responder Awareness Level
D. Hazardous Materials Specialist
8. Identifying hazardous substances is not always easy because:
A. Labeling errors
B. Smoke and fog
C. Both A and B
D. Neither A nor B
9. Retreating from a release:
A. Is always the smart thing to do
B. Is sometimes the smart thing to do
C. Is seldom the smart thing to do
D. Is never the smart thing to do
10. These are detailed documents that provide instructions for tasks like valve shutoff:
A. Material safety data sheets
B. Shipping papers
C. Risk assessments
D. Standard operating procedures
11. A physical hazard of a chemical is:
A. Something that causes an immediate, but short-term reaction
B. Something that causes a bodily reaction
C. Something that explodes or catches fire
D. Something that causes either long-term or short-term effects
12. If you only had a placard that did NOT contain a four-digit identification number, what part of the ERG
would you use to determine the emergency guide number:
A. White front pages
B. Yellow-bordered pages
C. Blue-bordered pages
D. Green-bordered pages
HAZWOPER--81
13. Areas surrounding the exclusion zone are controlled during emergencies by:
A. Security procedures
B. Placards
C. Concealed hazardous substances
D. Standard operating procedures
14. Material safety data sheets must be shipped:
A. With the initial shipment of a chemical
B. With the first shipment of a chemical after an MSDS is updated
C. With every chemical shipment
D. Both A and B
15. Injuries, illnesses, and fatalities are:
A. Permissible exposure limits
B. Potential human outcomes
C. Hazard indicators
D. Hazard warnings
16. Hazardous materials are divided into _____ hazard classes:
A. 6
B. 7
C. 8
D. 9
17. To evaluate the consequences of a release, do NOT consider the effects on:
A. People and the community
B. Property and the environment
C. Production and the financial strength of the company
D. The uniform labeling system
18. Which is NOT one of the indicators for identifying a hazardous substance:
A. Container shape
B. Colors
C. Flavor
D. Odors
19. There are nine general requirements under Section 1910.120(q). Select the answer that does NOT
belong:
A. Develop and implement a written emergency response plan
B. Train employees on the duties and function to be performed, and provide refresher training
C. Ensure that all employees can act as Incident Commanders
D. Make sure that HAZMAT team members use proper chemical protective clothing and equipment
HAZWOPER--82
20. To determine the minimum safe distance from a release, you should:
A. Assume 100 feet is okay
B. The safe distance begins where you can no longer smell the release
C. Consider the substance released and the nature of the release
D. Use the Pythagorean theorem to determine the distance
21. A chemical exhibits a health hazard if it:
A. May explode or catch fire
B. Can cause you to become ill
C. Can cause property damage
D. Is an oxidizer
22. Emergency response planning is important for many reasons, EXCEPT:
A. A release will be more hazardous to physical health and safety
B. Responders can proceed with minimal risk to themselves and others
C. There will be less confusion, because people will know what to do
D. There will be less duplication of effort, because people know their responsibilities
23. When assessing the risk of a release consider:
A. The amount of damage a release might cause
B. The probability or likelihood of a release
C. The severity of the release
D. All of the above
24. The hazards of a release include:
A. Physical and health hazards
B. Property hazards
C. Environmental hazards
D. All of the above
25. The term “hazardous chemical” means:
A. All chemicals
B. A substance or material capable of posing an unreasonable risk to health, safety, and property
when transported in commerce, and which has been so designated
C. Only a chemical that can explode
D. Any chemical that is a physical hazard or a health hazard
26. Sheltering in-place is used when:
A. There is enough time for people to leave the area
B. The ERG says to shelter in-place
C. Evacuating would cause greater risk
D. Vandalism and theft is a possibility
HAZWOPER--83
27. The two basic types of respirators are:

A. Self-contained and supplied-air
B. Supplied-air and supplied-oxygen
C. Positive pressure and negative pressure
D. Atmosphere-supplying and air-purifying
28. A positive pressure check:
A. Ensures that the hard hat has a good face to hat seal
B. Is performed by closing the exhalation valve and breathing out gently
C. Is performed by closing the exhalation valve and breathing in gently
D. Both A and C
29. Physical removal is:
A. Used after chemical removal
B. Used for loose or adhering contaminants or volatile liquids
C. Always performed with heat and high pressure
D. A contamination method
30. An air-purifying respirator would NOT be appropriate when:
A. The contaminant levels are unknown
B. The oxygen in the working area is displaced
C. The contaminant is known and levels are low
D. Both A and B
31. When preventing contamination, it is NOT a good idea to:
A. Fully close all fasteners on protective clothing
B. Tuck the hood inside the collar
C. Tuck boots and gloves under sleeves and legs of outer clothing
D. Tape gloves to sleeves and boots to pant legs
32. To determine isolation distances, a responder should identify:
A. Identification number, wind direction, spill size, day or night, highlighted items in ERG
B. Identification number, wind speed, spill size, day or night, highlighted items in ERG
C. Identification number, wind speed, spill movement, day or night, container type
D. Identification number, wind direction, spill movement, day or night, highlighted items in ERG
33. Information shared during debriefing includes:
A. What happened, unsafe conditions, who’s to blame for mistakes
B. How successful the effort was, any injuries, roles played
C. Areas of improvement and precautions such as showering
D. Lessons learned, any illnesses and their treatment
HAZWOPER--84
34. Decontamination is:

A. Always performed, even if a person requires lifesaving techniques
B. Sometimes delayed until a victim requiring immediate medical treatment is stabilized
C. Performed on heat stroke victims
D. Effective and reliable
35. Absorbing, diverting, diking, and damming up a spill are considered:
A. Containment
B. Confinement
C. Isolation
D. Termination
36. Communication devices used in potentially explosive atmospheres must be:
A. Intrinsically safe and not capable of sparking
B. Used only for hazardous substances with physical hazards
C. Used in vapor releases
D. Color coded
37. Which statement is NOT true:
A. All decontamination equipment must be decontaminated
B. Decontamination equipment includes buckets, brushes, and tools
C. Clothing should be hung in direct sunshine before being decontaminated
D. Clothing may be placed in plastic bags until decontaminated or disposed of
38. Level ____ provides the highest available level of respiratory, skin, and eye protection:
A. A
B. D
C. 1
D. 4
39. Heat stress, reduced mobility, vision, and communication are concerns for:
A. Face protection
B. Eye protection
C. Full-body protection
D. All of the above
40. What do operations level responders do before defensively controlling a release:
A. Termination procedures
B. Decontaminate all responders
C. Perform warm-up exercises
D. Form an action plan
HAZWOPER--85
41. Respirators for emergency use should be inspected:

A. Weekly
B. Monthly
C. Every six months
D. Annually
42. The three-digit number in the ERG is the:
A. Isolation distance in meters
B. Protective action distance in meters
C. Emergency response guide number
D. Hazardous material identification number
43. A critique of a response:
A. Is performed as the response effort is going on
B. May affect the ERP
C. Is a session where responders share information without debate
D. Is performed by the first responder at the awareness level
44. Which control zone is the area where decontamination occurs:
A. Exclusion zone
B. Contamination reduction zone
C. Support zone
D. Hot zone
45. Moving people from a threatened area to a safe place is called:
A. Isolation
B. Evacuation
C. Sheltering in-place
D. Action plan
46. The PPE protection level that is recommended for initial response efforts until the hazards have been
further identified is:
A. A
B. B
C. C
D. D
47. Which statement is NOT true about exclusion zones and security:
A. First responders at the operations level may set up safe distances
B. First responders at the awareness level may set up safe distances
C. First responders at the awareness level could assist in preventing unauthorized entry
D. First responders at the operations level can determine how close cars are permitted
HAZWOPER--86
48. Records that should be part of the termination procedures include:

A. Exposure records and evacuation reports
B. MSDSs, shipping papers, and agency-required reports
C. Standard operating procedures and exposure records
D. Exposure records, activity logs, and agency-required reports
49. The entries highlighted in the yellow-bordered pages of the ERG are:
A. Toxic inhalation hazard materials or dangerous water reactive materials
B. Dangerous water reactive materials or weapons of mass destruction
C. Highly explosive materials or biological materials
D. Both A and C
50. Decontamination methods may:
A. Be incompatible with hazardous substances being removed
B. Be incompatible with the clothing or equipment being decontaminated
C. Pose a direct health hazard to workers
D. All of the above
HAZWOPER--87
Emergency action word search

Circle the following emergency action terms as you find them in the puzzle.
The words can be horizontal, vertical, diagonal, and backwards.
ALARM EXIT REPORT

EGRESS FIRE RESPOND
EMERGENCY FLOOD SPILL
EVACUATE PLAN
N L O T R E P R P
E F L O O D L E E
V M G I X I A A L
A R E S P O N D T
C E G R E S S I R
U A F H G X X F O
A C L S V E Y L P
T I P A C F N M E
E R I F R Y A C R
R D A N O M L T Y
HAZWOPER--88
Word puzzles may be copied and distributed to E Copyright 2007
workers for use during training session or as a 9/07 Published by J. J. Keller & Associates, Inc.
HAZWOPER--89
Posters may be copied posted, and distributed to E Copyright 2007
HAZWOPER--90
HAZWOPER--91
HAZWOPER--92
E 2007 J. J. Keller & Associates, Inc., Neenah, WI (800) 327-6868 E 2007 J. J. Keller & Associates, Inc., Neenah, WI (800) 327-6868
“Not that kind of pig!”
Cartoons may be copied, posted, and distributed to workers for use during training sessions or as a handy reminder. Please refer to the manual’s
HAZWOPER--93
9/07

“I vant to clean up the blood” I would have gotten around to eating that
sooner or later.
ZZ Top at their day job
HAZWOPER--94
9/07

“Ahhh! I love the smell of “We use hazardous labels too...”

asbestos in the morning!”
I’m getting worried. That’s our safety manager.
HAZWOPER--95
9/07

“I thought you dialed 911!”
“It’s OSHA again...they say if we don’t let their

inspection team in they’re going ahead
with the air strike.”
HAZWOPER--96
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A Closer Look at Emergency Response

Certain types of work involve constant exposure to hazards. This is certainly true of both han-
dling hazardous waste and responding to chemical emergencies. Thorough, up-front preparation
is your best safeguard.
The nature of work at hazardous waste sites makes emergencies a continual possibility, no mat-
ter how infrequently they may actually occur. Emergencies happen quickly and unexpectedly and
require immediate response. At a hazardous waste site, an emergency may be as limited as a
worker experiencing heat stress, or as vast as an explosion that spreads toxic fumes throughout
a community.
Any hazard at a work site can precipitate an emergency: chemicals, bio-
logic agents, radiation, or physical hazards may act alone or in concert
to create explosions, fires, spills, toxic atmospheres, or other dangerous
and harmful situations.
Site emergencies are characterized by their potential for complexity: un-
controlled toxic chemicals may be numerous and unidentified; their ef-
fects may be synergistic. Hazards may potentiate one another — for ex-
ample, a flammable spill feeding a fire. Rescue personnel attempting to
remove injured workers may themselves become victims.
This variability means that advance planning, including anticipation of
different emergency scenarios and thorough preparation for contingen-
cies, is essential to protect worker and community health and safety.
Under the HAZWOPER standard, there are five distinct areas regulated. Two cover uncontrolled
hazardous waste sites, either required by a governmental body or recognized as such by a gov-
ernmental body. The other three are RCRA-regulated sites; TSD facilities; and any facility with
the possibility of chemical incidents requiring an emergency response action.
This chapter outlines important factors to be considered by all five of the above groups when
planning for and responding to emergencies. It defines the nature of site emergencies, lists the
types of emergencies that may occur, and outlines a Contingency Plan and its components,
which include personnel roles, lines of authority, training, communication systems, site mapping,
site security and control, refuges, evacuation routes, decontamination, a medical program, step-
by-step emergency response procedures, documentation, and reporting to outside agencies.
Release of Hazardous Materials That Require an Emergency Response

An understanding of the distinction between an incidental release of a hazardous substance and
a release that requires an emergency response is fundamental to proper compliance with the
provisions of 29 CFR 1910.120(q). This part of the standard was written to cover a wide array of
facilities and situations: “Emergency response operations for releases of, or substantial threats of
releases of, hazardous substances without regard to the location of the hazard.” (29 CFR
1910.120(a)(1)(v)).
Potential releases of hazardous substances in the workplace can be categorized into three dis-
tinct groups in terms of the planning provisions of 1910.120(q). These groups are:
1. Releases that are clearly incidental regardless of the circumstances,
HAZWOPER--97
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2. Releases that may be incidental or may require an emergency response depending on

the circumstances, and
3. Releases that clearly require an emergency response regardless of the circumstances.
Releases That are Clearly Incidental
The scope of the HAZWOPER standard does not cover the inevitable release of a hazardous
substance that is limited in quantity and poses no emergency or significant threat to the safety
and health of employees in the immediate vicinity. This type of release is referred to as an “inci-
dental release” in 29 CFR 1910.120(a)(3), where “emergency response” is defined.
An incidental release is a release of hazardous substance which does not pose a significant
safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up,
nor does it have the potential to become an emergency within a short time frame. Incidental
releases are limited in quantity, exposure potential, or toxicity and present minor safety or health
hazards to employees in the immediate work area or those assigned to clean them up.
If the hazardous substances that are in the work area are always stored in very small quantities,
then the risks of having a release that escalates into an emergency are minimal. These work
areas include such places as laboratories that handle amounts in pint sizes down to test tubes,
where the hazardous substances do not pose a significant safety and health threat at that vol-
ume. In this setting incidental releases will generally be the norm and employees will be trained
to protect themselves in handling incidental releases per the training requirements of the Hazard
Communication standard (29 CFR 1910.1200).
For example, a tanker truck is receiving a load of hazardous materials at a tanker truck loading
station. At the time of an accidental spill, the product can be contained by employees in the
immediate vicinity and cleaned up utilizing absorbent without posing a threat to the safety and
health of employees. As such, the employer may respond to such incidental releases (as per-
mitted by 1910.120 definition: “Emergency Response” or “Responding to Emergencies”).
This situation describes an “incidental spill” under the HAZWOPER. An incidental spill poses an
insignificant threat to health or safety, and may be safely cleaned up by employees who are
familiar with the hazards of the chemicals with which they are working.
Releases That May Be Incidental or Require an Emergency Response Depending on the Cir-
cumstances
The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness,

corrosiveness, etc., as well as the particular circumstances of the release itself, such as quantity,
confined space considerations, ventilation, etc., will have an impact on what employees can han-
dle safely and what procedures should be followed. Additionally, there are other factors that may
mitigate the hazards associated with a release and its remediation. These would include such
things as the knowledge of the employee in the immediate work area, the response and personal
protective equipment (PPE) at hand, and the pre-established standard operating procedures for
responding to releases of hazardous substances. There are some engineering control measures
that will mitigate the release that employees can activate to assist them in controlling and stop-
ping the release.
HAZWOPER--98
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These considerations (properties of the hazardous substance, the circumstances of the

release, and the mitigating factors in the work area) combine to define the distinction
between incidental releases and releases that require an emergency response. The distinc-
tion is facility-specific and is a function of the emergency response plan.
For example: A spill of the solvent toluene in a facility that manufactures toluene may not
require an emergency response because of the advanced knowledge of the personnel in the
immediate vicinity and equipment available to absorb and clean up the spill. However, the
same spill inside a furniture refinishing shop with personnel that have had only the basic
hazard communication training on toluene, may require an emergency response by more
highly trained personnel. The furniture refinishing shop’s emergency response plan in this
case would call for evacuation for all but the most minor spills, while evacuation and emer-
gency response would be necessary for only much larger spills at the chemical
manufacturing facility.
Releases That Require an Emergency Response Regardless of the Circumstances

There are releases of hazardous substances that pose a sufficient threat to health and safety
that, by their very nature, require an emergency response regardless of the circumstances
surrounding the release or the mitigating factors. An employer must determine the potential
for an emergency in a reasonably predictable worst-case scenario (or “anticipated emergen-
cies,” 29 CFR 1910.120(q)(1)), and plan response procedures accordingly.
For example, a motor carrier is engaged in the transportation of hazardous materials. At the
time of an accidental release, the product cannot be contained by employees in the immedi-
ate vicinity and cleaned up utilizing absorbent. Because of the larger problem, the motor
carrier’s employees evacuate the area and call for outside help, as instructed by employer.
In this instance, if in the event of a spill of a hazardous substance an employer instructs all
of his/her employees to evacuate the danger area, then the employer may not be required to
train those employees under 1910.120. However, the ability to decide whether a spill is an
incidental spill or one requiring an emergency response requires training. Also, any employ-
ees who are expected to become actively involved in an emergency response due to a release
of a hazardous substance are covered by 1910.120 and must be trained accordingly. (Note:
OSHA has limited jurisdiction for over-the-road vehicle operation. In the instance of spills
occurring while the material is on the vehicle or otherwise “in transportation,” OSHA’s
HAZWOPER standard does not cover the operator per se. It does, however, cover emergency
response personnel who respond to the incident. If the operator of the vehicle in transporta-
tion becomes actively involved in an emergency response, then he/she becomes an emergency
responder and is covered by 1910.120(q).)
An emergency response includes, but is not limited to, the following situations:
• The response comes from outside the immediate release area;
• The release requires evacuation of employees in the area;
• The release poses, or has the potential to pose, conditions that are immediately dan-
gerous to life and health (IDLH);
• The release poses a serious threat of fire or explosion (exceeds or has the potential
to exceed the lower explosive limit or lower flammable limit);
• The release requires immediate attention because of imminent danger;
• The release may cause high levels of exposure to toxic substances;
3/14 HAZWOPER–99

• The release may be life threatening or injury provoking;

• There is uncertainty that the employee in the work area can handle the severity of
the hazard with the PPE and equipment that has been provided and the exposure
limit could easily be exceeded; and
• The situation is unclear, or data are lacking on important factors.
Responders From Outside the Immediate Release Area

“Emergency response” is defined in 29 CFR 1910.120(a)(3) as follows:
“Emergency response” means a response effort by employees from outside the immediate
release area or by other designated responders (i.e., mutual-aid groups, local fire depart-
ments, etc.) to an occurrence which results, or is likely to result, in an uncontrolled release
of a hazardous substance. Responses to incidental releases of hazardous substances where
the substance can be absorbed, neutralized, or otherwise controlled at the time of release by
employees in the immediate release area, or by maintenance personnel are not considered to
be emergency responses within the scope of this standard. Responses to releases of hazard-
ous substances where there is no potential safety or health hazard (i.e., fire, explosion, or
chemical exposure) are not considered to be emergency responses.
The standard covers responses “by other designated responders.” The use of the “or” means
that responders are a separate group, different from employees within the immediate release
area, directed to respond to the emergency by the employer. Employees working in the
immediate release area (not just outsiders) are covered if the employer designates them as
emergency responders. The standard, 29 CFR 1910.120(q), uses the term “responders” gener-
ally to refer to employees who respond to emergencies.
The Superfund Amendments and Reauthorization Act (SARA), the statute that mandated
HAZWOPER, directs broad coverage of all employees responding to emergencies with no
limitation on their location. SARA states, “… standards shall set forth responding require-
ments for training of workers who are responsible for responding to hazardous emergency
situations who may be exposed to toxic substances.” (See SARA 126(d)(4)) For an emergency
to be covered by the standard, conditions causing a dangerous situation which involve haz-
ardous substances are sufficient; there need not be both an emergency and a response by
outside responders before the employer prepares for an emergency.
For example: A release of chlorine gas above the IDLH, obscuring visibility and moving
through a facility, is an emergency situation even if the initial responders are from the
immediate release area. Employees who would respond to this hypothetical situation,
whether they work in the immediate area or come from outside, would need to act in accor-
dance with 29 CFR 1910.120(q).
Employees must not be made to respond to releases in the immediate release area that
would otherwise require outside assistance from a trained hazardous materials team merely
because the definition of an emergency response states that an emergency response is “a
response effort by employees from outside the immediate release area.”
100–HAZWOPER 3/14

Conversely, incidental releases of hazardous substances that are routinely cleaned up by those
from outside the immediate release area need not be considered emergency responses solely
because the employee responsible for cleaning it up comes from outside the immediate release
area.
For example: Paint thinner is spilled in an art studio and the janitor is called from outside the
immediate release area to mop it up. The janitor does not have to respond in accordance with 29
CFR 1910.120, although the janitor would be expected to understand the hazards associated
with paint thinner through hazard communication training.
Other OSHA Standards
Other standards that impact emergency response to fires, chemical releases, or other incidents
should be part of an emergency response compliance evaluation. Flammable chemical spills and
other small fires are covered by 29 CFR 1910.156 as well as 29 CFR 1910.157. The “Process
Safety Management for Highly Hazardous Chemicals,” 29 CFR 1910.119, and “Hazard Commu-
nication,” 29 CFR 1910.1200, as well as some of the specific expanded health standards in Sub-
part Z would also apply.
In-Plant Emergency Response

This section covers those emergency response situations that occur at locations other than un-
controlled hazardous waste sites and RCRA TSD facilities. The typical site covered by this sec-
tion would be a transportation accident where hazardous substances are or have the potential
for leaking into the environment.
Other sites covered by this section would include hazardous substance releases at chemical
manufacturing facilities such as the release that occurred at the Union Carbide plants in Bhopal,
India and Institute, West Virginia.
Responders
A typical scenario where this would be applicable would be the
emergency response to a derailed tank car containing a hazard-
ous substance that has begun to leak its contents into the atmo-
sphere.
The emergency response to this type of accident would usu-
ally include the first responders (i.e.,witnesses, police, em-
ployees on the train), the first dispatched-responders (i.e.,
the first due rescue and fire apparatus), any multiple alarm
dispatches (i.e., additional fire and rescue apparatus, HAZMAT teams, state fire marshal,
Coast Guard or EPA national response teams), and the clean-up crew (i.e., initial response
employees of the site owner who clean up the release). Employees of outside clean-up con-
tractors would not be covered by this section.
Emergency Response Plan 1910.120(q)(2)
Every employer who has operations that involve employee exposure to safety and health haz-
ards must develop an emergency response plan. The plan must be designed to handle antici-
HAZWOPER--101
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pated emergencies prior to the commencement of emergency response operations. The plan
must be in writing, and available to employees and to OSHA.
Employers who plan to evacuate their employees from the workplace when an emergency oc-
curs, and who do not permit any of their employees to assist in handling the emergency, do not
have to develop this emergency response plan. However, you must provide an emergency action
plan in accordance with 1910.38. So, one way or the other, you must have a written plan to show
OSHA. For details of the emergency action plan, see Appendix A, at the end of this chapter.
Emergency response organizations may use the local or state emergency response plan as part
of their plan to avoid duplication.
The emergency response plan should cover the following areas:
1. Pre-emergency planning and coor- 7. Decontamination,

dination with outside parties,
8. Emergency medical treatment and
2. Personnel roles, lines of authority, first aid,
training, and communication,
9. Emergency alerting and response
3. Emergency recognition and preven- procedures,
tion, 10. Critique of response and follow-up,
4. Safe distances and places of refuge, and
5. Site security and control, 11. PPE and emergency equipment.
6. Evacuations routes and procedures,
Emergency Response Procedures 1910.120(q)(3)
The senior emergency response official responding shall be in

charge of the site. All activities will be coordinated through this
person. For an onsite incident, this person in charge could well be
a designated employee who has been trained to the accepted
level for incident command.
The incident commander (IC) shall identify all hazardous sub-
stances or conditions present. The IC shall refer to the site analy-
sis, use of engineering controls, maximum exposure limits, haz-
ardous substance handling procedures, and the use of any new
technologies. All of this data should be compiled in the facility’s
Safety and Health Program.
After assessing the hazardous substances and/or conditions present, the IC must implement
appropriate emergency operations, and assure that the PPE worn is appropriate for the hazards
to be encountered. If the PPE is worn while performing fire fighting operations, it must meet the
criteria in 1910.156(e).
If an employee, while responding to an emergency, is exposed to an inhalation hazard, then the
employee must wear positive pressure self-contained breathing apparatus until such time as the
IC determines through air monitoring that it is safe to discontinue.
HAZWOPER--102
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The IC must limit the number of emergency response personnel at the emergency site to those
who are actively performing emergency operations. Operations in hazardous areas should be
performed using the buddy system in groups of two or more.
Back-up personnel must stand by with equipment ready to provide assistance or rescue. Ad-
vance first aid support personnel, as a minimum, must stand by with medical equipment and
transportation capability.
The IC must designate a safety official, who will identify and evaluate hazards and oversee the
safety of the operations. When this safety official judges it to be an IDLH condition and/or to
involve an imminent danger condition, the official must alter, suspend, or terminate the activities.
The IC must be immediately informed of any corrective actions to be taken.
Upon completion of the emergency operations, the IC shall implement appropriate decontamina-
tion procedures.
Decisions regarding the use of self-contained breathing apparatus should be made by someone
knowledgeable in the equipment.
Skilled Support Personnel 1910.120(q)(4)
You never know for certain what will happen during an emergency response incident. You may
require workers who are skilled in the operation of certain equipment, such as mechanized earth
moving or digging equipment, or crane and hoisting equipment. If you have no one in the plant
who can perform these operations, you may have to recruit an outside worker temporarily.
Because this temporary worker may be exposed to hazards, an initial briefing must be given at
the site prior to participation in any emergency response activity. This briefing should include
instruction in the use of appropriate PPE, what chemical hazards are involved, and what duties
are to be performed. Any measures regularly used to protect the safety and health of all workers,
would, of course, be necessary for these temporary employees.
Spill Response
A variety of hazardous chemicals are routinely used in day-to-day industrial operations (e.g.,
paints, inks, solvents, cleaners). Occasionally, hazardous materials may spill, leak, or otherwise
be released into the workplace or the environment. Such events can be categorized as being
either incidental releases or emergency releases.
In the event of any hazardous material release, it is important that trained personnel are able to
quickly assess and determine whether an incidental or emergency release is occurring. The abili-
ty to distinguish between these two categories of releases will largely determine what response
procedures should be followed.
If your employees have not had appropriate HAZWOPER training at either the awareness or
operations level, they should not become involved in responding to a hazardous chemical re-
lease. If an employee should notice a leaking substance, their only duty may be to immediately
notify a trained Hazardous Material First Responder that a potential hazardous chemical release
has occurred.
HAZWOPER--103
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Employees should be aware that a spill does not necessarily mean that only an incidental re-
lease has occurred. Spills can be immediate emergencies, or become emergencies in a very
short time.
What is a Release?
As discussed earlier, an emergency release is a significant event and can result in major risks to
the health and safety of employees, as well as damage to the environment and property. Such
events constitute real or threatened emergency situation, and can involve fire, explosion, or se-
vere chemical exposure. Generally, a coordinated response from an outside emergency re-
sponse organization (e.g., fire department, hazardous material response team) is required to
safely contain, cleanup, or otherwise respond to an emergency release.
An incidental release is a minor or non-emergency event that presents limited risk to the health
and safety of employees. Such events are typically small in quantity, have little potential for hu-
man exposure, and involve materials of low toxicity. Still, incidental releases must be taken seri-
ously. Any hazardous material release has the potential to evolve into a much more serious
emergency if not confined quickly and responded to appropriately.
According to OSHA, an incidental release is one where the substance can be absorbed, neutral-
ized, or otherwise controlled at the time of release by employees in the immediate release area,
or by maintenance personnel [see 1910.120(a)(3)]. An incidental release is, therefore, a release
of a hazardous substance that does not pose a significant safety or health hazard to employees
in the immediate vicinity or to the worker cleaning it up, nor does it have the potential to become
an emergency. For example, a small amount of a substance considered low in toxicity and re-
leased from a valve during a maintenance operation would be considered an incidental release,
not an emergency.
Of course, it first must be determined to be an incidental spill, and not an emergency, and some-
one with appropriate training must make that determination if it is not obvious.
The quantity of product spilled does not by itself determine if an incidental spill has occurred.
Several variables, including the volume of the spill must be considered in evaluating the hazard
of the release to employees. Examples of other variables include the type of material spilled and
the location of the spill. There may be an incident where the substance is unidentified. If so, the
substance shall be considered to be hazardous and handled accordingly until the contents are
positively identified and labeled.
Who Should Respond to a Spill?
Only personnel who have received HAZWOPER training are qualified to respond to spills, leaks,
and other incidental releases of hazardous chemicals.
• HAZWOPER Awareness Level First Responders are trained to recognize and identify
hazardous materials, understand the general risks associated with a release, and know
how to contact or notify an Operations Level First Responder.
HAZWOPER--104
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• HAZWOPER Operations Level First Responders are trained to assess the risks and haz-
ards of a release, respond and contain a release in a safe and defensive manner, and
contact appropriate outside response personnel as necessary.
Other employees should be instructed that if they were to notice a leak, spill, or other incidental
release, their only duty is to immediately notify a trained Hazardous Material First Responder that
a potential hazardous chemical release has occurred. If your company has no trained Hazardous
Material First Responders, other measures must be taken.
What Emergency Response Procedures Must be Followed?
Following appropriate emergency response procedures quickly and correctly can reduce injuries,
help save lives, and prevent property damage and protect the environment. Based on your em-
ployees’ level of training, the following general response guidelines should be followed if some-
one witnesses or is called to respond to a hazardous material release:
HAZWOPER Awareness Level First Responder
1. Consider your and your co-workers’ safety.
2. Contact supervisor who will contact “operations-trained” personnel.
3. Isolate the spill if it is safe to do so.
4. Identify the hazardous materials released if it is safe to do so.
HAZWOPER Operations Level First Responder
1. Consider your and your co-workers’ safety.
2. Contact supervisor who will contact “operations-trained” personnel.
3. Isolate the spill if it is safe to do so.
4. Identify the hazardous materials released if it is safe to do so.
5. Determine if the release is incidental or emergency.
HAZWOPER Specialist Level First Responder
Safety Specialists, Environmental Compliance Coordinators and others have received specialist-
equivalent training and are to be contacted for the following:
1. Assist Operations Level First Responders in determining if a release is incidental or
emergency.
2. Act as liaison between hazmat emergency response personnel and facility personnel.
If the release is determined to be incidental, safe clean-up and disposal measures must be de-
termined along with what PPE and other hazard control measures are needed.
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There are a variety of methods to document what procedures your company will follow during a
spill or leak. These can be in such documents as standard operating procedures or emergency
action plans (EAP).
Your company may have standard operating procedures for spill or leak clean-ups. These may
identify the following:
• Employees trained to manage spills and leaks.
• Specific clean-up teams and contractors.
• Personal protective equipment that must be work-specific.
• Other procedures critical to the safe and effective response to a hazmat incident.
Emergency action plans also cover a wide assortment of potential emergencies such as fire,
explosions, and bomb threats. The EAP should identify the following:
• Address actions to be taken in the event of a hazmat spill or leak.
• Safe evacuation procedures.
• Telephone numbers of outside emergency responders.
• Telephone numbers of your facility’s spill team.
An ordinary spill that can be safely handled by the workers is not an emergency, but such em-
ployees must have proper equipment and training under other OSHA standards such as the
Hazard Communication standard.
Example Spill Containment Program
The spill containment program should address all hazardous substance spill scenarios that are
likely to occur at the site. In addition, the spill containment program should provide procedures to
contain and isolate the entire volume of any hazardous substance spilled in the course of a
transfer, accident, or onsite release.
The overall objectives of the spill containment information include the following:
• Identify the minimum requirements of the spill containment program that may be relevant
to the site and provide methods to contain and isolate the entire volume of any hazardous
substance spilled in the course of a transfer, major spill, or an onsite release; and
• Provide information on the initial spill action, spill response evaluation and organization,
and spill clean-up procedures.
Preplanning
In order to develop a successful spill containment program, an assessment should be conducted
of the site conditions, current operations, and planned activities. The assessment should careful-
ly examine all hazardous materials on site for where and how the materials are:
• Stored (e.g., location, type of container),
HAZWOPER--106
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• Handled (e.g., processed, used, transferred), and

• Transported (e.g., mode, routes).
As part of the assessment, each area or activity should be analyzed for potential accidental re-
leases or spills. Examples of situations that have potential for spill or release are:
• Bulging or corroded containers,
• Transfer line connections (e.g., leaking seals, misaligned connections),
• Metal fatigue of storage tanks,
• Leaking or inoperable valves, and
• Poor housekeeping (e.g., drums improperly staged).
Many potential spills can be avoided through application of proper engineering controls to haz-
ards identified in the assessment. In areas where storage, handling, and transportation activities
occur, preplanning to contain the largest volume of material that could be released in the area
will minimize worker exposure. The containment measures should be appropriate to the hazard-
ous material(s) identified and should be installed in the area or located nearby. The following
examples are measures most frequently used:
• Absorbent materials, (e.g., pads, booms, powders);
• Salvage containers (e.g., overpack drums);
• Bermed, lined pads;
• Concrete pad and dike;
• Inflatable containment (e.g., “kiddie” pools, bladders); and
• Associated equipment (e.g., pumps, hoses, shovels, hoists).
Procedures should be developed to properly maintain and replace, as necessary, all spill con-
tainment equipment and fixtures.
Reporting and Initial Personnel Safety
Upon discovery of a hazardous substance spill, personnel should be instructed to:
• Immediately summon help by notifying the emergency response team or supervisor;
• Take action to ensure the safety of nearby personnel;
• Proceed to a safe location;
• If anyone is seriously injured, immediately contact emergency medical services; and
• Keep unauthorized personnel out of the area.
Initial Spill Action
Factors that limit the employee’s response at the site of a spill are:
• Level of training,
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• Personal safety,
• Available personal protective equipment (PPE), and
• Knowledge of the substance.
Employees should limit their actions to:
• Shutting off equipment or pumps,
• Closing valves,
• Blocking drains within the path of the spill, and
• Using spill kit materials to dam or impede the flow of the spill.
Unauthorized persons should be excluded from the area.
Spill Response Evaluation
The identity and hazards of the spilled material should be determined before decisions regarding
spill containment and control are made. The site safety and health officer or equivalent should
evaluate the hazards associated with the spill and decide whether project employees or external
response organizations should conduct the cleanup. If the site safety and health officer deter-
mines that in-house response personnel cannot safely perform the spill cleanup, the site safety
and health officer should notify and request the assistance of outside emergency response as-
sistance.
Organizing a Spill Response
If the person in charge determines that cleanup can be performed safely with project response
personnel, the site safety and health officer may act as the spill team leader and designate re-
quired procedures. Safety practices for small spill operations closely parallel procedures imple-
mented during routine hazardous materials handling operations. Before work begins, the site
safety and health officer should conduct a hazard identification and assessment with response
personnel. The following should be discussed and established:
• Levels of PPE and safety procedures,
• Safety and work zones,
• All steps of the response activities,
• Most effective procedures or methods for cleanup,
• Means of containment,
• Leak or spill control,
• Decontamination procedures, and
• Emergency decontamination.
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Spill Cleanup Procedures

After care of injured personnel, containment of the released hazardous material should be the
next consideration to limit its effect on the safety of personnel, the public, and the environment.
The site safety and health officer should determine the methods of control, which depend upon
the nature and extent of the spill. Outside emergency responders should also be consulted. De-
contamination should be accomplished and disposal of contaminated materials should meet all
regulatory requirements.
Post Incident Follow-up
The site safety and health officer should implement necessary steps to ensure that the incident
is properly documented and that spill response equipment is replenished. The site safety and
health officer should direct the necessary corrective actions to prevent recurrence and evaluate
the response.
Spill Response Cart
Whether you are in a large or small company, if chemicals are present you should be prepared to
deal with chemical spills or leaks. Even with the most careful handling, accidents happen.
One of the focuses of HAZWOPER is emergency response. Under this regulation, you will do a
careful analysis of your facility, determining what hazards are present and what the potential for
emergency incidents is. Once this hazard determination is made, you will need to evaluate what
equipment you must have available on your premises to respond to every possible emergency.
Response to Small Spills
In most industrial settings, spills can occur in a variety of locations—at the loading docks, in a
chemical storage room, where the substance is used, throughout the facility during its internal
transport. Most spills are minor, requiring minimal, yet timely cleanup. Having one large spill cart
to address the needs of all locations is not a good solution.
Rather, a more logical approach is to have a number of small spill control stations, located in
areas where spills most commonly occur. This way, time will not be lost while someone leaves
the area to bring the large spill cart to the spill site, running the risk of another worker walking
through or slipping in the spill.
Most commercially available spill control stations are compact cabinets, filled with the necessary
cleanup supplies that emergency response personnel would need in a chemical spill emergency.
Suggested contents are:
• A number of universal absorbent pillows, usually will soak up at least a quart of liquid,
• A number of absorbent pads, for small cleanups,
• Several dozen disposal bags, along with labels and tags for proper marking,
• Several TyvekR coveralls,
• Several pair of splash goggles, and
• Several pair of neoprene gloves.
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The above items could be used for the majority of spills. However, many chemicals have specific
properties that require specific cleanup materials. Some companies offer kits that are designed
for specific spill control needs, such as mercury, acid, and base spills, and accidents involving
trucks and terminals, laboratories, and chemical preparatory rooms.
Response to Large Spills
If the potential exists for a large chemical incident, as well as small, easily handled emergencies,
then you should consider a permanent spill response wagon or cart. This would be stocked with
more response equipment than the spill response stations contain. A well equipped spill cart is
not only insurance against the unexpected, but has the added benefit of increasing employee
confidence in the company’s desire to protect the environment they work in.
Spill carts should be selected that fit your operation. They should be easily moved from one site
to another. A permanent central storage location should be chosen. All employees should know
where the cart is kept. Anyone who could be expected to respond to an emergency should have
thorough training in the use of everything on the cart. After every use, the cart should be re-
stocked and returned to its permanent location as soon as possible.
The following items, at a minimum, should be included in a well-stocked spill cart:
• An adequate number of TyvekR suits,
• Gloves,
• Boots,
• Splash aprons,
• Goggles,
• Several types of fire extinguishers,
• Absorbent pads,
• Absorbent pillows,
• Broom and dust pan,
• Disposal bags,
• Mop and plastic bucket,
• Non-sparking shovel,
• “Hazardous Area” warning/barricade,
• Hazardous/Nonhazardous Waste labels,
• Air Purifying respirators, with acid and organic cartridges,
• Containment boom, and
• Overpack drum.
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Obviously, the contents of the spill cart will vary according to the needs of each operation.
When stocking and restocking the supplies, often money can be saved by purchasing items
at a local hardware store. After all, a broom is a broom. Spark resistant equipment is simply
made of plastic or rubber and can be bought locally for a fraction of the price suggested by a
safety equipment outlet.
However, a word of caution. Never compromise safety by substituting equipment or supplies
that do not meet the same safety standards.
For more on spill response and compliance with HAZWOPER, see the selected OSHA Letters
of Interpretation on spill response at the end of this chapter.
Emergency Response Procedures at TSD Facilities 1910.120

Employers conducting operations at treatment, storage, and disposal (TSD) facilities must
provide for emergencies by establishing procedures to be followed.
Emergency Response Plan 1910.120 (p)(8)

An emergency response plan must be developed and implemented to handle anticipated
emergencies prior to the commencement of emergency response operations. EPA requires
that such facilities develop a contingency plan, possibly covering the same information. This
contingency plan can be made a part of the emergency response plan.
The plan must be in writing, and available to employees and to OSHA.
Employers who plan to evacuate their employees from the workplace when an emergency
occurs, and who do not permit any of their employees to assist in handling the emergency,
do not have to develop this emergency response plan. However, you must provide an emer-
gency action plan in accordance with 1910.38. (See Appendix A: Requirements for Employers
Who Plan to Evacuate Employees at the end of this chapter.)
Emergency response organizations may use the local or state emergency response plan as
part of their plan to avoid duplication.
The emergency response plan should cover the following areas:
1. Pre-emergency planning and coordination with outside parties,
2. Personnel roles, lines of authority, training, and communication,
3. Emergency recognition and prevention,
4. Safe distances and places of refuge,
5. Site security and control,
6. Evacuation routes and procedures,
7. Decontamination procedures,
8. Emergency medical treatment and first aid,
9. Emergency alerting and response
procedures,
10. Critique of response and follow-up, and
11. PPE and emergency equipment.
3/14 HAZWOPER–111

Training
Training for TSD employees must be completed before they are called upon to perform in
real emergencies. Such training must include the elements of the emergency response plan,
standard operating procedures for the job, PPE to be used, and procedures for handling
emergency incidents.
There are two exceptions to the general training requirements above.
1. All employees do not need to receive complete training. The employer may divide
the work force so that a sufficient number of employees who have responsibility to
control emergencies have the training specified. All other employees, who might first
respond to an emergency incident, must have sufficient awareness training to recog-
nize that an emergency response situation exists. They must then summon the fully
trained employees and not attempt control activities for which they are not trained.
2. An employer need not train all employees if arrangements have been made in
advance for an outside fully trained emergency response team to respond in a rea-
sonable period. All other employees, who might first respond to an emergency
incident, must have sufficient awareness training to recognize that an emergency
response situation exists. They must then summon the designated outside fully
trained emergency response team for assistance.
The employer must certify that each covered employee has attended and successfully com-
pleted the required training, or certify the employee’s competence yearly. Keep careful
records of what method was used to demonstrate competency for certification.
Procedures For Handling Emergency Incidents(See TRAINING.)
The following elements should be included in the ER plans:
1. Site topography, layout, and prevailing weather conditions;
2. Procedures for reporting incidents to local, state, and federal agencies;
3. The ER plan shall be compatible and integrated with the disaster, fire and/or ER
plans of local, state, and federal agencies;
4. The ER plan must be rehearsed regularly as part of the training;
5. The site ER plan must be reviewed periodically, and amended, as needed;
6. An employee alarm system shall be installed, in accordance with 1910.165 to notify
workers of an emergency situation; to stop work activities, if necessary; to lower
background noise in order to speed communications; and to begin emergency proce-
dures; and
7. Based upon the information available at the time of the emergency, the employer
shall evaluate the incident and take appropriate steps to implement the site ER
plan.
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Emergency Response Procedures at Uncontrolled Hazardous Waste Sites 1910.

120(I))
An emergency response plan must be developed and implemented by all employers within
the scope of this section to handle anticipated emergencies prior to the commencement of
hazardous waste operations.
Employers who plan to evacuate their employees from the
danger area when an emergency occurs and who do not per-
mit any of their employees to assist in handling the
emergency are exempt from the requirements of 1910.
120(l)(1) if they provide an emergency action plan
complying with section 1910.38.
Table 1 — Causes of Emergencies at Hazardous Waste Sites
Worker-Related
• Minor accidents (slips, trips, falls)
• Chemical exposure
• Medical problems (heat stress, heat stroke, aggravation of pre-existing conditions)
• Personal protective equipment failure (air source failure, tearing or permeation of protective clothing, face piece fogging)
• Physical injury (injuries from hot or flying objects, loose clothing entangling in machinery, serious falls, vehicle accidents)
• Electrical (burns, shock, electrocution)
Waste-Related
• Fire
• Explosion
• Leak
• Release of toxic vapors
• Reaction of incompatible chemicals
• Collapse of containers
• Discovery of radioactive materials
Contingency Plan 1910.120 (l)(2)

When an emergency occurs, decisive action is required. Rapidly made choices may have far-
reaching, long-term consequences. Delays of minutes can create life-threatening situations.
Personnel must be ready to immediately rescue or respond; equipment must be on hand and
in good working order. In order to handle emergencies effectively, planning is essential. For
this purpose, a Contingency Plan should be developed.
A Contingency Plan is a written document that sets forth policies and procedures for
responding to site emergencies. It should incorporate the following:
• Personnel:
Roles,
Lines of authority,
Training, and
Communication.
3/14 HAZWOPER–113

Pages 114-120
Reserved
114–HAZWOPER 3/14

• Site:
Mapping,
Security and control,
Refuges,
Evacuation routes, and
Decontamination stations.
• Medical/first aid
• Equipment
• Emergency procedures
• Documentation
• Reporting
Overall, a Contingency Plan should:
• Be designed as a discrete section of the Site Safety Plan;
• Be compatible and integrated with the pollution response, disaster, fire, and emergency
plans of local, state, and federal agencies;
• Be rehearsed regularly using drills and mock situations; and
• Be reviewed periodically in response to new or changing site conditions or information.
Personnel
This component of the plan includes not only onsite and offsite personnel with specific emergency
response roles, but also others who may be on site, such as contractors, other agency representa-
tives,and visitors. Emergency personnel and their responsibilities are summarized in Table 2.
Table 2 — Personnel Involved in Emergency Response
Project Team Leader

• Directs emergency response operations.
• Serves as liaison with appropriate government officials.
Site Safety Officers

• Recommends that work be stopped if any operation threatens worker or public health or safety.
• Knows emergency procedures, evacuation routes, and the appropriate telephone numbers including: the ambu-
lance, medical facility, poison control center, fire department, and police department.
• Notifies local public emergency officials.
• Provides for emergency medical care on site.
Command Post Supervisor

• Notifies emergency support personnel by telephone or radio in case rescue operations are required.
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Table 2 — Personnel Involved in Emergency Response, Continued

• Assists the Site Safety Officer in a rescue, if necessary.
Rescue Team
• An emergency rescue team stands by, partially dressed in protective gear, near the Exclusion Zone ready to
rescue any workers whose health or safety is endangered.
• State emergency response personnel (varies among states).
Decontamination Station Officers

• Perform emergency decontamination.
24-Hour Medical Team

• Transportation and treatment of victims by ambulance personnel, personnel at local clinics or hospitals, and phy-
sicians.
Communication Personnel
• Local Emergency service networks provide communication links for mutual aid.
• Civil Defense organizations and local radio and television stations provide information to the public during an
emergency.
Environmental Scientists
• Predict the immediate and future movement of released hazardous substances through the geologic and hydro-
logic environment and air
• Assess the effect of this movement on groundwater quality, surface water quality, and air quality.
• Determine the probable movement of released toxic gases.
• Estimate the expected concentration of gases in the community and the expected duration of exposure.
• Predict the exposure levels of people and the ecosystem to the materials.
Hazardous Chemicals Experts

• Provide immediate advice to those at the scene of a chemical-related emergency.
Firefighters
• Respond to fires that occur at a site; rescue victims.
Meteorologists
• Provide meteorological information needed by environmental scientists.
Public Safety Personnel

• The county sheriff, industrial security forces, the National Guard, and the police control site access, crowds, and
traffic.
Public Evacuation Personnel

• Civil Defense organizations plan evacuations
• The National Guard and other military, the Red Cross, the Salvation Army, and municipal transportation systems
mobilize transit equipment and assist in evacuations.
On-Scene Coordinator
• Coordinates federal response activities.
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Onsite Personnel
The Contingency Plan should identify all individuals and teams who will participate in emergency
response and define their roles. All personnel, whether directly involved in emergency response
or not, should know their own responsibilities in an emergency. They must also know the names
of those in authority, and the extent of that authority.
Leader
In an emergency situation, one person must be able to assume total control and decision-making
on site. This leader must:
• Be identified in the emergency response plan. This person may be, for example, the Proj-
ect Team Leader, Site Safety Officer, or Field Team Leader.
• Be backed up by a specified alternate(s).
• Have the authority to resolve all disputes about health and safety requirements and pre-
cautions.
• Be authorized to seek and purchase supplies as necessary.
• Have control over activities of everyone entering the site, for example, contractors, fire
departments, and police.
• Have the clear support of management.
Teams
Although individuals (e.g., the Site Safety Officer) may perform certain tasks in emergencies, in
most cases teams provide greater efficiency and safety. Teams composed of onsite personnel
may be created for specific emergency purposes, such as decontamination, rescue, and entry.
Rescue teams can be used during a particularly dangerous operation, or at large sites with multi-
ple work parties in the Exclusion Zone. Their sole function is to remain near hazardous work
areas, partially dressed in protective gear, ready for full suiting and immediate rescue of any
endangered worker. These teams should be capable of administering cardiopulmonary resuscita-
tion (CPR) and emergency first aid. Other teams can be formed for responding to containment
emergencies and fire-fighting until offsite assistance arrives.
Offsite Personnel
These may include individual experts such as meteorologists or toxicologists (see Table 2), and
representatives or groups from local, state, and federal organizations offering rescue, response,
or support (see Table 3 for a listing of typical organizations). As part of advance planning, site
personnel should:
• Make arrangements with individual experts to provide guidance as needed;
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• Make arrangements with the appropriate agencies (e.g., local fire department, state envi-
ronmental agency, EPA regional office) for support;
• Alert these authorities to the types of emergencies that may arise;
• Determine their estimated response time and resources;
• Identify backup facilities;
• Provide training and information about hazards on site and special procedures for han-
dling them; and
• Establish a contact person and means of notification at each agency.
Table 3 — Examples of Agencies and Groups Involved in Emergencies
Agency or Group Rescuea Responseb Supportc

FEDERAL
Army Corps of Engineers D
Coast Guardd D D
Department of Defensed D D
Department of Transportation D
Environmental Protection Agency (EPA)d D D
Federal Aviation Administration (FAA) D
Federal Emergency Management Agency (FEMA) D D
National Institute for Occupational Safety and Health (NIOSH)
Occupational Safety and Health Administration (OSHA) D
STATE
Civil Defense D
Department of Health D
Department of Labor D
Environmental Agency D D
Office of the Attorney General D
State Police D D
LOCAL
Ambulance and rescue services D D D
Cleanup contractor D D D
Disposal companies D D
Fire department D D D
Hospital D
Police D D
Red cross D
Salvation army D
Transporters D
Utility companies (electric, gas, water, phone) D
aRescue = extricating and/or providing on-the-spot emergency treatment to victims.
bResponse = controlling and stabilizing hazardous conditions.
cSupport = providing technical assistance, equipment, and/or resources.
dThis agency may provide an On-Scene Coordinator (OSC), depending on the jurisdiction.
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Federal Response Organizations
Site emergencies involving significant chemical releases should be coordinated with federal re-
sponse organizations. The federal government has established a National Contingency Plan
(NCP) to promote the coordination and direction of federal and state response systems, and to
encourage the development of local government and private capabilities to handle chemical
emergencies involving chemical releases.
To implement the NCP, a national organization was established, including a National Response
Team (NRT), a network of Regional Response Teams (RRTs), a cadre of On-Scene Coordinators
(OSCs), and a National Response Center (NRC). The NRC is the national terminal point for re-
ceipt of notification of significant chemical releases, and the OSCs are the interface between the
onsite personnel and the federal response organizations.
The OSC is the federal official responsible for ensuring that necessary response actions are
taken to protect the public and the environment from the effects at a chemical release. Many
federal agencies have specific technical expertise which is available to assist the OSC.
If a significant chemical release occurs at a hazardous waste site, the National Response Center
in Washington, D.C., should be contacted (Telephone: 800-424-8802). The NRC will activate fed-
eral response under the National Contingency Plan.
Training
Since immediate, informed response is essential in an emergency, all site personnel and others
entering the site (visitors, contractors, offsite emergency response groups, other agency repre-
sentatives) must have some level of emergency training. Any training program should:
• Relate directly to site-specific, anticipated situations,
• Be brief and repeated often,
• Be realistic and practical,
• Provide an opportunity for special skills to be practiced regularly,
• Feature drills frequently (e.g., site-specific mock rescue operations), and
• Ensure that training records are maintained in a training logbook.
Everyone entering the site must be made aware of the hazards and of hazardous actions which
are forbidden or should be avoided (e.g., smoking). They must also know what to do in case of
an emergency.
Visitors should be briefed on basic emergency procedures such as decontamination, emergency
signals, and evacuation routes.
Personnel without defined emergency response roles (e.g., contractors, federal agency repre-
sentatives) must still receive a level of training that includes at a minimum:
• Hazard recognition,
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• Standard Operating Procedures,

• Signaling an emergency: the alarm used, how to summon help, what information to give
and who to give it to,
• Evacuation routes and refuges, and
• The person or station to report to when an alarm sounds.
Onsite emergency personnel, who have emergency roles in addition to their ordinary duties,
must have a thorough understanding of emergency response. Training should be directly related
to their specific roles and should include subjects such as:
• Emergency chain-of-command,
• Communication methods and signals,
• How to call for help,
• Emergency equipment and its use,
• Emergency evacuation while wearing protective equipment,
• Removing injured personnel from enclosed spaces, or
• Offsite support and how to use it.
These personnel should obtain certification in first aid and CPR, and practice treatment tech-
niques regularly, with an emphasis on:
• Recognizing and treating chemical and physical injuries.
• Recognizing and treating heat and cold stress.
Offsite emergency personnel such as local firefighters and ambulance crews often are first re-
sponders and run a risk of acute hazard exposure equal to that of any onsite worker. These
personnel should be informed of ways to recognize and deal effectively with onsite hazards.
Lack of information may inadvertently worsen an emergency by improper actions (e.g., spraying
water on a water-reactive chemical and causing an explosion). Inadequate knowledge of the
onsite emergency chain-of-command may cause confusion and delays. Site management
should, at a minimum, provide offsite emergency personnel with information about:
• Site-specific hazards,
• Appropriate response techniques,
• Site emergency procedures, and
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Emergency Recognition and Prevention
On a day-to-day basis, individual personnel should be constantly alert for indicators of potentially
hazardous situations and for signs and symptoms in themselves and others that warn of hazard-
ous conditions and exposures. Rapid recognition of dangerous situations can avert an emergen-
cy. Before daily work assignments, regular meetings should be held. Discussion should include:
• Tasks to be performed,
• Time constraints (e.g., rest breaks, air tank changes),
• Hazards that may be encountered, including their effects, how to recognize symptoms or
monitor them, concentration limits, or other danger signals, and
• Emergency procedures.
After daily work assignments, a debriefing session should be held to review work accomplished
and problems observed.
Communications
In an emergency, crucial messages must be conveyed quickly and accurately. Site staff must be
able to communicate information such as the location of injured personnel, orders to evacuate
the site, and notice of blocked evacuation routes, even through noise and confusion. Outside
support sources must be reached, help obtained, and measures for public notification ensured, if
necessary.
To do this, two sets of communication systems should be established and rehearsed: internal
communication among personnel onsite, and external communication between onsite and offsite
personnel. External communication systems and procedures should be clear and accessible to
all workers.
Internal Communications
Internal emergency communication systems are used to:

• Alert workers to danger and emergencies;
• Convey safety information such as the amount of air time left before the next rest period,
air change, heat stress check, etc.;
• Communicate changes in the work to be accomplished; and
• Maintain site control.
Verbal communication at a site can be impeded by onsite background noise and the use of per-
sonal protective equipment. For example, speech transmission through a respirator can be poor,
and hearing can be impaired by protective hoods and respirator air flow. For effective commu-
nication, commands must be pre-arranged. In addition, audio or visual cues can help convey the
message. The most important thing is that signals are agreed to in advance.
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When designing and practicing communication systems, remember that:

• Background noise onsite will interfere with talking and listening;
• Wearing personal protective equipment will impede hearing and limit vision (e.g., the
ability to recognize hand and body signals); and
• Inexperienced radio users may need practice in speaking clearly.
Both a primary and backup system are necessary. A set of signals should be established for use
only during emergencies. These should be:
• Different from ordinary signals,
• Brief and exact, and
• Limited in number so that they are easily remembered.
Examples include: stop, evacuate, help, and all clear. Any set of signals may be used to convey
these messages as long as all personnel understand their meaning.
Table 4 — Sample Internal Emergency Communication Signals
Devicesa and Signals Example
Radio (citizen’s band or FM) Established code words.
Noisemakers, including: Compressed air horn.

Bell One long blast: Evacuate area by nearest emergency exit.
Megaphone Two short blasts: Localized problem
Sirens (not dangerous to workers).
Whistles Two long blasts: all clear.
Visual signal, including:

Hand signals Hand clutching throat: Out of air/
Whole body movements can’t breathe.
Hands on top of head: Need assistance.
Thumbs up: OK/I’m alright/I understand
Thumbs down: No/negative
Grip partner’s wrist or both hands around partner’s waist: Leave
area immediately.
aAll devices and equipment used in the Exclusion and Contamination Reduction Zones must be intrinsically safe and
not capable of sparking.
Any effective system or combination may be employed. Radios or field telephones are often
used when work teams are far from the Command Post. Alarms or short clear messages can be
conveyed by audible signals, e.g., bullhorns, megaphones, sirens, bells, whistles; or visual sig-
nals such as colored flags, flares, lights, and hand or whole-body movements. The primary sys-
tem must have a backup. For example, hand signals may be used as a backup if radio commu-
nications fail. All internal systems should be:
• Clearly understood by all personnel,
• Checked and practiced daily, and
• Intrinsically safe (spark-free).
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Effective internal communication also requires the identification of individual workers so com-
mands can be addressed to the right worker. The worker’s name should be marked on the suit
and, for long-distance identification, color coding, numbers, or symbols can be added. Flags may
be used to help locate personnel in areas where visibility is poor due to obstructions such as
accumulated drums, equipment, and waste piles.
All communication devices used in a potentially explosive atmosphere must be intrinsically safe and
not capable of sparking. They should also be checked daily to ensure that they are operating.
External Communications
Offsite sources must be contacted to get assistance or to inform officials about hazardous condi-
tions that may affect public or environmental safety. An external communication system between
onsite and offsite personnel is necessary to:
• Coordinate emergency response,
• Report to management, and
• Maintain contact with essential offsite personnel.
The telephone is the most common mode of offsite communication; phone hook-ups are consid-
ered a necessity at all but the most remote sites. If telephone lines are not installed at a site, all
team members should know the location of the nearest telephone, and the correct change and
necessary numbers should be readily available in the support zone.
• The National Response Center (NRC) (Telephone: 800-424-8802) should be contacted in
the event of a significant chemical release. The NRC will contact the appropriate federal
On-Scene Coordinator.
Site Control
The purpose of site control is to minimize potential contamination of workers, protect the public
from the site’s hazards, and prevent vandalism. Site control is especially important in emergency
situations. Several site control procedures can be implemented to reduce worker and public ex-
posure to chemical, physical, biological, and safety hazards:
• Compile a site map,
• Prepare the site for subsequent activities,
• Establish work zones,
• Use the buddy system when necessary,
• Establish and strictly enforce decontamination procedures for both personnel and equip-
ment,
• Establish site security measures,
• Set up communication networks, and
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• Enforce safe work practices.

The degree of site control necessary depends on site characteristics, site size, and the surround-
ing community. The site control program should be established in the planning stages of a proj-
ect and modified based on new information and site assessments. The appropriate sequence for
implementing these measures should be determined on a site-specific basis. In many cases, it
will be necessary to implement several measures simultaneously.
Site Mapping
Detailed information about the site is essential for advance planning. For this purpose, a site
map is a valuable tool. It serves as a graphic record of the locations and types of hazards, a
reference source, and a method of documentation.
This map can be a duplicate of the one developed for the Safety and Health Program, but it
should focus on the potential areas where emergencies may develop. Pins and colored flags can
be used to mark changes in personnel deployment, hazard areas, and equipment locations. The
map should highlight:
• Hazard areas, especially potential IDLH conditions;
• Site terrain: topography, buildings, containers, pits, ponds, tanks, barriers;
• Evacuation routes;
• Site accessibility by land, sea, and air;
• Prevailing wind direction;
• Drainage;
• Work crew locations;
• Changes (e.g., work activities, vandalism, accidents); and
• Offsite populations or environments at potential risk.
The map can be used for a variety of purposes. It is helpful in:
• Planning activities;
• Training;
• Developing potential emergency scenarios and alternative response strategies;
• Assigning personnel;
• Identifying access routes, evacuation routes, and problem areas;
• Identifying areas of the site that require use of personal protective equipment; and
• Supplementing the daily safety and health briefings of the field teams.
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The map should be prepared before site entry and updated throughout the course of site opera-
tions. You can use overlays to help portray information without cluttering the map. The site map
should reflect:
• Accidents,
• Changes in site activities,
• Emergencies,
• Hazards not previously identified,
• New materials introduced onsite,
• Vandalism, and
• Weather conditions.
When an emergency occurs, the problem areas should be pinpointed on the map. Pertinent in-
formation — such as weather and wind conditions, temperature, and forecast — should be add-
ed. The map can then be used to design the emergency plan, e.g., to define zones; determine
evacuation routes; and identify emergency first-aid, decontamination, and Command Post sta-
tions. When using the map for such purposes, the accuracy of the data obtained and the poten-
tial for over- or underestimating a hazard should be considered.
Even if an emergency develops so fast that the map cannot be used for on-the-spot planning,
prior familiarity with it will aid in making informed decisions.
Safe Distances
No single recommendation can be given for evacuation or safe distances because of the wide
variety of hazardous substances and releases found at sites. For example, a “small” chlorine
leak may call for an isolation distance of only 140 feet (43 meters), while a “large” leak may
require an evacuation distance of one mile (1.6 kilometers) or more, depending on the wind di-
rection.
Safe distances can only be determined at the time of an emergency, based on a combination of
site and incident-specific factors. However, planning and outlining potential emergency scenarios
will help familiarize personnel with points to consider. Factors that influence safe distances in-
clude:
• The toxicological properties of the substance,
• The physical state of the substance,
• The quantity released,
• The rate of release,
• The method of release,
• The vapor pressure of the substance,
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• Vapor density relative to air,

• Wind speed and direction,
• Atmospheric stability,
• The height of release,
• Air temperature and temperature change with altitude, and
• Local topography (e.g., barriers may enhance or retard a cloud or plume, and attenuate a
blast).
Public Evacuation
If an incident may threaten the health or safety of the surrounding community, the public will
need to be informed and possibly evacuated from the area. Site management should plan for
this in coordination with the appropriate local, state and federal groups, such as the Federal
Emergency Management Agency, the Civil Defense, county sheriff, local radio and television sta-
tions, municipal transportation systems, National Guard, and police.
Refuges (Safety Stations)
Onsite refuges (safety stations) can be set up for localized emergencies that do not require site
evacuation. These refuges should only be used for essential needs, such as short rest breaks,
emergency response strategy meetings, or temporary relief during mild cases of muscle strain
and heat stress.
The refuge should be located in a relatively safe, but not necessarily “clean” area, e.g., along the
upwind fence line in specially cleared places or on the periphery of the Exclusion Zone. The
refuge should never be used for activities such as eating, drinking, or air changes. Typical items
located in a refuge area include:
• A sitting/resting area that should be shaded if possible,
• Water for decontamination,
• Wind indicator,
• Communication system with the Command Post,
• First-aid supplies, e.g., eyewash, stretcher, blanket,
• Special monitoring devices (e.g., extra detector tubes and personal monitors),
• Bolt cutters,
• Fire extinguishers, and
• Hand tools.
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Other refuges can be set up in the Support Zone, or in the case of site-wide evacuations, offsite
at the safe exit destination. These will provide for emergency needs such as first aid for injured
personnel, clean dry clothing and wash water for chemical exposure victims, and communica-
tions with the Command Post.
In a site-wide evacuation, they can be used to house evacuation exit equipment, thereby reduc-
ing security problems. These refuges should be stocked with such items as:
• Decontamination supplies,
• Oxygen and/or air,
• Water,
• Special testing equipment (e.g., pH paper, cyanide paper),
• First-aid supplies, and
• Communication system.
Site Security and Control
Site security is necessary to:

• Prevent deliberate acts designed to injure people or harm the environment;
• Prevent theft;
• Avoid the increased hazards from vandals or persons seeking to abandon other wastes
on the site;
• Avoid the human, legal, and loss of production costs associated with a security breach;
• Prevent the exposure of unauthorized, unprotected people to site hazards;
• Keep employees safe and productive;
• Maintain operational integrity and avoid production disruption;
• Protect trade secrets;
• Preserve the company reputation and community goodwill; and
• Improve relationships with local authorities.
Security Assessment
A security risk assessment focuses specifically on whether the existing security measures are
adequate for protecting assets and meeting anticipated threats. The security assessment will
look at all phases of the physical plant, along with geographical factors, to evaluate the extent of
company vulnerability.
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Security audits are often performed by outside experts who are more familiar with security is-
sues. Consultation with experienced security professionals can help employees develop and im-
plement a more comprehensive program.
Potential threats that a chemical facility should consider during a security assessment include all
of the threats and vulnerabilities uncovered during other assessments, along with other issues
such as:
• Loss of containment;
• Bomb threats;
• Sabotage;
• Cyberterrorism;
• Outside infiltration;
• Product contamination or tampering;
• Vandalism of control rooms or equipment;
• Destruction of system documentation;
• Theft of confidential information;
• Deliberate disruption of telephone, electrical, water, or computer service;
• Tampering with fail-safe or chemical transfer mechanism to create hazardous conditions;
and
• Hacking into information systems or disruption of computer-controlled equipment.
The security assessment must also consider:
• Minimum standards and training required for guards/security staff;
• Unique security requirements of all buildings and grounds;
• Employee and visitor ID and access systems;
• Employee pre-employment security screening; and
• Existing security plans and arrangements.
Physical Security
“Physical security” refers to equipment, building and grounds design, and security practices de-
signed to prevent physical attacks against a facility’s employees, property, or information. Physi-
cal security includes access control, perimeter protection, intrusion detection, use of security offi-
cers, and other measures.
Use the concept of “security rings” to protect critical assets. Those assets which are most critical
or most vulnerable should be the most difficult for an intruder to reach. Whether the barriers are
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fences, receptionists, locked doors, or guard posts, make sure that someone would have to pass
through several layers of security to reach the critical location.
Access Control
The measures taken to manage the passage of personnel and vehicles in, out, and within the
facility is called “access control.” Developing an access control plan, and training employees re-
garding the aims of the plan, can help protect the facility while still allowing personnel and ve-
hicles to move around the facility as necessary.
The physical layout and operations of a facility will determine the need for and degree of access
control. Access control will also be dictated by the number of employees, amount of vehicular
traffic, hazards of materials present, attractiveness of the facility as a target, and other factors.
Perimeter Protection
The company’s first line of defense against terrorists, saboteurs, vandals, thieves, protesters, or
disgruntled employees should be at the edge of the property. Good perimeter protection and
control will help stop intruders long before vital assets and operational areas can be reached.
The following ideas for perimeter protection all help make it difficult for intruders to enter your
work site:
• Arranging reception, production, and office space so intruders can be noticed easily;
• Sufficient lighting;
• Setbacks and clear zones which make it difficult for intruders to approach unnoticed;
• Fences and exterior walls;
• If the site is not fenced, post signs around the perimeter and use guards to patrol the
perimeter;
• Traffic islands, bollards, and trenches to control motorized traffic;
• Manned vehicle gates;
• Use of a key control system and electronic locks on exterior and interior doors;
• Use of window locks; and
• Personnel gates and/or turnstiles.
Site Security
There are a variety of things which can help to control access to and from a chemical facility,
including:
• Using a centralized receiving system for packages and mail;
• Having employees open locked doors for visitors;
• Keeping closets and storage rooms locked;
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• Assign responsibility for enforcing authority for entry and exit requirements;
• Use of visitor sign-in/sign-out logs and escorting visitors to and from their destinations;
• Have the Project Team Leader approve all visitors to the site. Make sure they have a valid
purpose for entering the site. Have trained site personnel accompany visitors at all times
and provide them with the appropriate protective equipment;
• Use of surveillance cameras or security personnel at loading docks;
• Installation of penetration-resistant doors and security hinges;
• Installing electronic access control system that requires the use of key cards at main en-
trances and maintains a record of movement within the facility;
• Use of closed-circuit television system to monitor key areas of the facility; and
• Requiring the use of property passes for removal of property from the site.
To maintain site security during off-duty hours:
• If possible, assign trained, in-house technicians for site surveillance. They will be familiar
with the site, the nature of the work, the site’s hazards, and respiratory protection tech-
niques;
• If necessary, use security guards to patrol the site boundary. Such personnel may be less
expensive than trained technicians, but will be more difficult to train in safety procedures
and will be less confident in reacting to problems around hazardous substances;
• Enlist public enforcement agencies, such as the local police department, if the site pres-
ents a significant risk to local health and safety; and
• Secure the equipment.
Security Officers
Security officers are an important part of the security system. Security officers may:
• Tour the site looking for intruders or irregularities;
• Watch for fires and other emergencies;
• Assist with emergency response, or direct first responders;
• Check employee and visitor IDs at pedestrian entrances;
• Staff vehicle entrance gates and maintain entry and exit logs;
• Remind employees and contractors of security and safety policies; and
• Assist in emergencies, evacuations, and summoning and directing of emergency person-
nel.
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Security officers should be:

• Assigned to specific posts or walking routes;
• Properly trained and licensed, based upon anticipated hazards and emergency proce-
dures; and
• Provided with written “general orders” covering overall security concerns, and “post or-
ders” relating to security issues and policies at a specific post.
Training and Security Awareness
Employees are usually in the best position to notice when there is an intruder, or if something
does not seem right. Design training programs to emphasize to employees their role in the secu-
rity plan. Train them to contact a supervisor or security when something or someone is suspi-
cious.
Use training to reinforce security practices, such as:
• Reviewing building security, lockup policy, and security arrangements;
• Whom to report security violations to;
• Reporting suspicious packages;
• Challenging intruders who do not have ID badges;
• Protecting computer passwords and system access—don’t write passwords down; and
• Not propping or tapping open the locks on exterior doors to facilitate smoking.
In order for any security system to work, the employees and contractors working at that facility
must know what the security procedures are and what role the employees play in overall security.
Emergency Security
In an emergency, the Project Team Leader (or designated representative) must know who is
onsite and must be able to control the entry of personnel into the hazardous areas to prevent
additional injury and exposure. Only necessary rescue and response personnel should be al-
lowed into the Exclusion Zone. To maintain site security during working hours maintain security in
the Support Zone and at access control points.
One control technique is a checkpoint or series of checkpoints through which all personnel enter-
ing or exiting the site must pass, e.g., a Support Zone checkpoint and an Exclusion Zone check-
point. Identification or authorization must be presented to a Checkpoint Control Manager, who
records each person’s:
• Name (and affiliation if offsite personnel),
• Status (in or out),
• Time of entry,
• Anticipated exit time,
• Zones or areas to be entered,
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• Team or “buddy,”
• Task being performed,
• Location of task,
• Protective equipment worn; air time left, and
• Rescue and response equipment used.
The emergency area Checkpoint Control Manager should inform the Project Team Leader if a
person remains in the emergency area beyond his or her anticipated exit time.
Personal Locator Systems
In an emergency, it is vital for the Project Team Leader (or designee) and rescue personnel to
rapidly determine where workers are located and who may be injured. A passive locator system
(i.e., a written record of the location of all personnel on site at any time) could be used to help
find personnel in an emergency. Any such system should be:
• Graphic (such as a drawing with a written key);
• Roughly drawn to scale, with the scale and visible landmarks included;
• Kept current;
• Easy to locate; and
• Stored outside the Exclusion Zone.
A good passive locator system is a site map with flags or color-headed pins identifying each
worker.
Active locator systems can also be used. These are worn or carried by individual personnel, and
are activated by actions such as flipping a switch, a decrease in air supply, or a fall. They have
the advantage of precisely locating individuals.
Evacuation Routes and Procedures
A severe emergency, such as a fire or explosion, may cut workers off from the normal exit near
the Command Post. Therefore, alternate routes for evacuating victims and endangered person-
nel should be established in advance, marked, and kept clear. Routes should be directed (1)
from the Exclusion Zone through an upwind Contamination Reduction Zone to the Support Zone,
and (2) from the Support Zone to an offsite location in case conditions necessitate a general site
evacuation. The following guidelines will help in establishing safe evacuation routes.
• Place the evacuation routes in the predominantly upwind direction of the Exclusion Zone.
(At a very large site, or one with any obstacles, some exits may be placed in the down-
wind fenceline, normally an undesirable location. If this is done, workers must know that
they are not “out” until they reach the designated safety area.)
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• Run the evacuation routes through the contamination Reduction Zone. Even if there is
not enough time to process the evacuees through decontamination procedures, there
should be a mechanism for accounting for all personnel.
• Consider the accessibility of potential routes. Take into account obstructions such as
locked gates, trenches, pits, tanks, drums, or other barriers, and the extra time or equip-
ment needed to maneuver around or through them.
• Develop two or more routes that lead to safe areas and that are separate or remote from
each other. Multiple routes are necessary in case one is blocked by a fire, spill, or vapor
cloud. These routes must not overlap because if a common point were obstructed by a
fire or other emergency, all intersecting routes would be blocked.
• Mark routes “safe” or “not safe” on a daily basis according to wind direction and other
factors.
• Mark evacuation routes with materials such as barricade tape, flagging, or traffic cones.
Equally important, mark areas that do not offer safe escape or that should not be used in
an emergency, such as low ground, which can fill with gases or vapors, or routes blocked
by natural barriers, such as cliffs or streams.
• Consider the mobility constraints of personnel wearing protective clothing and equipment.
They will have difficulty crossing even small streams and going up and down banks.
– Place ladders across any cut or excavation that is more than 3 feet (1 meter) deep.
For long cuts, place ladders at least every 25 feet (7.5 meters), and for deep cuts,
place plywood or planks on top of ladders.
– Provide ladders for rapid descent from areas or structures elevated more than 3 feet
(1 meter).
– Use only ladders capable of supporting a 250-lb (114-kg) load.
– Secure ladders to prevent slipping.
– Place standard cleated ramps (“chickenboard”) across ditches and other similar ob-
stacles. Add a railing and toe boards if the board is narrow or steeply sloped.
– Check the toe and body clearance of ladders to make sure that personnel wearing
protective clothing and SCBA can use them.
– Check the clearance of access ports, such as crawl spaces, hatches, manholes, and
tunnels to make sure that personnel wearing a protective ensemble can get through.
In any case, access ports should be at least 3 feet (1 meter) in diameter where pos-
sible. (Standard tank manways are smaller.)
• Consider any disabilities that employees have and the challenges that an evacuation
would pose.
• Make escape routes known to all who go onsite.
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Site Preparation
Time and effort must be spent in preparing a site for the cleanup activity to ensure that response
operations go smoothly and that worker safety is protected. Site preparation can be as hazard-
ous as site cleanup. Therefore, safety measures should be afforded the same level of care at
this stage as during actual cleanup. Following are the major steps in site preparation for any
cleanup activity.
• Construct roadways to provide ease of access and a
sound roadbed for heavy equipment and vehicles;
• Arrange traffic flow patterns to ensure safe and efficient
operations;
• Eliminate physical hazards from the work area as much as
possible, including:
– ignition sources in flammable hazard areas;
– exposed or ungrounded electrical wiring, and low overhead wiring that may entangle
equipment;
– sharp or protruding edges, such as glass, nails, and torn metal, which can puncture
protective clothing and equipment and inflict puncture wounds;
– debris, holes, loose steps or flooring, protruding objects, slippery surfaces, or unse-
cured railings, which can cause falls, slips, and trips;
– unsecured objects, such as bricks and gas cylinders, near the edges of elevated sur-
faces, such as catwalks, roof tops, and scaffolding, which may dislodge and fall on
workers; and
– debris and weeds that obstruct visibility.
• Install skid-resistant strips and other anti-skid devices on slippery surfaces;
• Construct operation pads for mobile facilities and temporary structures;
• Construct loading docks, processing and staging areas, and decontamination pads;
• Provide adequate illumination for work activities. Equip temporary lights with guards to
prevent accidental contact; and
• Install all wiring and electrical equipment in accordance with the National Electric Code.
Site Work Zones
To reduce the accidental spread of hazardous substances by workers from the contaminated
area to the clean area, zones should be delineated on the site where different types of opera-
tions will occur, and the flow of personnel among the zones should be controlled. The establish-
ment of work zones will help ensure that:
• Personnel are properly protected against the hazards present where they are working,
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• Work activities and contamination are confined to the appropriate areas, and
• Personnel can be located and evacuated in an emergency.
Hazardous waste sites should be divided into as many different zones as needed to meet opera-
tional and safety objectives. For illustration, there are three frequently used zones:
• Exclusion Zone, the contaminated area;
• Contamination Reduction Zone (CRZ), the area where decontamination takes place; and
• Support Zone, the uncontaminated area where workers should not be exposed to hazard-
ous conditions.
Delineation of these three zones should be based on sampling and monitoring results and on an
evaluation of potential routes and amount of contaminant dispersion in the event of a release.
Movement of personnel and equipment among these zones should be minimized and restricted
to specific Access Control Points to prevent cross-contamination from contaminated areas to
clean areas.
Estimated boundary
of area with highest
contamination
Hotline
Command Post
Contamination
Control Line
Prevailing wind direction
Support Zone
Access Control Points.
Contamination Reduction Corridor.
Contamination Reduction Zone (CRZ).
Exclusion Zone.
Note: Area dimensions not to scale. Distances between points may vary.
Site Work Zones. (Note that decontamination facilities are located in the Contamination Reduction Zone.)
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Exclusion Zone
The Exclusion Zone is the area where contamination does or could occur. The primary activities
performed in the Exclusion Zone are:
• Site characterization, such as mapping, photographing, and sampling;
• Installation of wells for groundwater monitoring; and
• Cleanup work, such as drum movement, drum staging, and materials bulking.
The outer boundary of the Exclusion Zone, called the Hotline, should be established according to
the criteria listed:
1. Visually survey the immediate site environs;
2. Determine the locations of:
• hazardous substances,
• drainage, leachate, and spilled material, and
• visible discolorations.
3. Evaluate data from the initial site survey indicating the presence of:
• combustible gases;
• organic and inorganic gases, particulates, or vapors; and
• ionizing radiation.
4. Evaluate the results of soil and water sampling;
5. Consider the distances needed to prevent an explosion or fire from affecting personnel
outside the Exclusion Zone;
6. Consider the distances that personnel must travel to and from the Exclusion Zone;
7. Consider the physical area necessary for site operations;
8. Consider meterological conditions and the potential for contaminants to be blown from
the area;
9. Secure or mark the Hotline; and
10. Modify its location, if necessary, as more information becomes available.
The Hotline should be clearly marked by lines, placards, hazard tape and/or signs; or enclosed
by physical barriers such as chains, fences, or ropes. Access Control Points should be estab-
lished at the periphery of the Exclusion Zone to regulate the flow of personnel and equipment
into and out of the zone and to help verify that proper procedures for entering and exiting are
followed. If feasible, separate entrances and exits should be established to separate personnel
and equipment movement into and out of the Exclusion Zone.
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The Exclusion Zone can be subdivided into different areas of contamination based on the known
or expected type and degree of hazard or on the incompatibility of waste streams. This allows
more flexibility in safety requirements, operations, decontamination procedures, and use of re-
sources.
The personnel working in the Exclusion Zone may include the Field Team Leader, the work par-
ties, and specialized personnel such as heavy equipment operators. All personnel within the
Exclusion Zone should wear the level of protection required by the Site Safety Plan. Within the
zone, different levels of protection may be justified based on the degree of hazard presented.
The level of personal protection required in each subarea should be specified and marked.
The required level of protection in the Exclusion Zone varies according to job assignment. For
example, a worker who collects samples from open containers might require Level B protection,
while one that performs walk-through ambient air monitoring might only need Level C protection.
When appropriate, different levels of protection within the Exclusion Zone should be assigned to
promote a more flexible, effective, and less costly operation, while still maintaining a high degree
of safety.
Contamination Reduction Zone
The Contamination Reduction Zone (CRZ) is the transition area between the contaminated area
and the clean area. This zone is designed to reduce the probability that the clean Support Zone
will become contaminated or affected by other site hazards. The distance between the Exclusion
and Support Zones provided by the CRZ, together with decontamination of workers and equip-
ment, limits the physical transfer of hazardous substances into clean areas. the degree of con-
tamination in the CRZ decreases as you move from the Hotline to the Support Zone, due to both
the distance and the decontamination process.
Decontamination procedures take place in a designated area within the CRZ called the Contami-
nation Reduction Corridor (CRC). They begin at the Hotline. At least two lines of decontamina-
tion stations should be set up within the CRC: one for personnel and one for heavy equipment.
A large operation may require more than two lines. Access into and out of the CRZ from the
Exclusion Zone is through Access Control Points: one each for personnel and equipment en-
trance, one each for personnel and equipment exit, if feasible.
The boundary between the Support Zone and the CRZ, called the Contamination Control Line,
separates the possible low contamination area from the clean Support Zone. Access to the CRZ
from the Support Zone is through two Access Control Points if feasible: one each for personnel
and equipment. Personnel entering the CRZ should be required to wear the personal protective
clothing and equipment prescribed for working in the CRZ. To reenter the Support Zone, workers
should remove any protective clothing and equipment worn in the CRZ, and leave through the
personnel exit Access Control Point.
The personnel stationed in the CRZ are usually the Site Safety Officer, a Personnel Decontami-
nation Station (PDS) Operator, and the emergency response personnel. Additional personnel
may assist the PDS Operator by conducting abbreviated decontamination procedures for sample
containers.
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The CRZ must be well designed to facilitate:

• Decontamination of equipment, PDS operators, personnel, and samples;
• Emergency response — transport for injured personnel (such as safety harness, stretch-
er), first aid equipment (such as bandages, blankets, eye wash, splints, and water), con-
tainment equipment (such as absorbent, fire extinguisher);
• Equipment resupply — air tank changes, personal protective clothing and equipment
(such as booties and gloves), sampling equipment (such as tobbles and glass rods), and
tools;
• Sample packaging and preparation for onsite or offsite laboratories;
• Worker temporary rest area — toilet facilities, bench, chair, liquids, and shade. Water and
other potable liquids should be clearly marked and stored properly to ensure that all
glasses and cups are clean. Wash facilities should be located near drinking facilities to
allow employees to wash before drinking. Drinking, washing, and toilet facilities should be
located in a safe area where protective clothing can be removed. Facilities should be
cleaned and inspected regularly. Appropriate protective measures should be taken by
maintenance workers; and
• Drainage of water and other liquids that are used during decontamination.
Personnel within the CRZ should be required to maintain internal communications, line-of-site
contact with work parties, work party monitoring (for things such as air time left, fatigue, heat
stress, hypothermia), and site security.
Support Zone
The Support Zone is the location of the administrative and other support functions needed to
keep the operations in the Exclusion and Contamination Reduction Zones running smoothly. Any
function that need not or cannot be performed in a hazardous or potentially hazardous area is
performed here. The Command Post Supervisor should be present in the Support Zone. Other
personnel present will depend on the functions being performed, and may include the Project
Team Leader and field team members who are preparing to enter or who have returned from the
Exclusion Zone.
Personnel may wear normal work clothes within this zone. Any potentially contaminated clothing,
equipment, and samples must remain in the CRZ until decontaminated.
Support Zone personnel are responsible for alerting the proper agency in the event of an emer-
gency. All emergency telephone numbers, change for the telephone (if necessary), evacuation
route maps, and vehicle keys should be kept in the Support Zone.
Support facilities are located in the Support Zone. To place these facilities, consider factors such
as:
• Accessibility. Topography, open space available, locations of highways and railroad
tracks, and ease of access for emergency vehicles;
• Resources. Adequate roads, power lines, telephones, shelter, and water;
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• Visibility. Line-of-sight to all activities in the Exclusion zone;

• Wind direction. Upwind of the Exclusion Zone, if possible; and
• Distance. As far from the Exclusion Zone as practicable.
Support Zone facilities and activities include:
Facility Activities
Command Post Supervision of all field operations and field teams.
Maintenance of communications, including emergency lines of communica-
tion.
Recordkeeping, including:
- accident reports
- chain-of-custody records
- daily logbooks
- manifest directories and orders
- medical records
- personnel training records
- site inventories
- site safety map
- up-to-date Site Safety Plans
Providing access to up-to-date safety and health manuals and other reference
materials.
Interfacing with the public: government agencies, local politicians, medical
personnel, the media, and other interested parties.
Monitoring work schedules and weather changes.
Maintaining site security.
Sanitary facilities.
Medical Station First-aid administration.
Medical emergency response.
Medical monitoring activities.
Sanitary facilities.
Equipment and Supply Centers Supply, maintenance, and repair of communications, respiratory, and sampling
equipment.
Maintenance and repair of vehicles.
Replacement of expendable supplies.
Storage of monitoring equipment and supplies. Storage may be here or in an
onsite field laboratory.
Administration Sample shipment.
Interface with home office.
Maintenance of emergency telephone numbers, evacuation route maps, and
vehicle keys.
Coordination with transporters, disposal sites, and appropriate federal, state,
and local regulatory agencies.
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Facility Activities
Field Laboratory Coordination and processing of environmental and hazardous waste samples.
Copies of the sampling plans and procedures should be available for quick
reference in the laboratory.
Packaging of materials for analysis following the decontamination of the out-
sides of the sample containers which should be done in the CRZ. This pack-
aging can also be done in a designated location in the CRZ. Shipping papers
and chain-of-custody files should be kept in the Command Post.
Maintenance and storage of laboratory notebooks in designated locations in
the laboratory while in use, and in the Command Post when not in use.
The Buddy System
Most activities in contaminated or otherwise hazardous areas should be conducted with a buddy
who is able to:
• Provide his or her partner with assistance,
• Observe his or her partner for signs of chemical or heat exposure,
• Periodically check the integrity of his or her partner’s protective clothing, and
• Notify the Command Post Supervisor or others if emergency help is needed.
The Access Control Point for personnel entrance to the Exclusion Zone is a convenient location
for enforcing the buddy system for two reasons: enforcement is the responsibility of the Project
Team Leader, who is stationed in the CRZ, and all personnel who enter the contaminated area
must pass through the control point.
The buddy system alone may not be sufficient to ensure that help will be provided in an emer-
gency. At all times, workers in the Exclusion Zone should be in continual line-of-sight or commu-
nications contact with the Command Post Supervisor or backup person in the Support Zone.
Decontamination
When planning for decontamination in medical emergencies, procedures should be developed

for:
• Decontaminating the victim,
• Protecting medical personnel, and
• Disposing of contaminated protective equipment and wash solutions.
These activities should be coordinated. The decision whether or not to decontaminate a victim is
based on the type and severity of the illness or injury and the nature of the contaminant. For some
emergency victims, immediate decontamination may be an essential part of life-saving first aid.
For others, decontamination may aggravate the injury or delay life-saving treatment. If decontam-
ination does not interfere with essential treatment, it should be performed. Figure 1 is a decision
aid for emergency decontamination.
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• If decontamination can be done:

Wash, rinse and/or cut off protective clothing and equipment.
• If decontamination cannot be done:
Wrap the victim in blankets, plastic, or rubber to reduce contamination of other personnel;
Alert emergency and offsite medical personnel to potential contamination; instruct them
about specific decontamination procedures if necessary; and
Send along site personnel familiar with the incident.
Figure 1. Decision Aid for Emergency Decontamination
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Equipment
In an emergency, equipment will be necessary to rescue and treat victims, to protect response
personnel, and to mitigate hazardous conditions on site (e.g., to contain chemicals or fight fires).
Some regular equipment can double for emergency use. Because of its high cost, most heavy
equipment (e.g., bulldozers, drum movers, pumps) employed in emergencies will also be used
for regular work assignments.
All equipment should be in working order, fueled, and available when an emergency occurs.
Provide safe and unobstructed access for all firefighting and emergency equipment at all times.
Consider adopting the following work procedures:
• Refuel all heavy equipment when there is still one-half to one-quarter of a tank of fuel left.
• Require all equipment repairs to take place at the time the problem is discovered.
• Separate two similar pieces of equipment (e.g., two front-loaders or a bulldozer and a
front-loader); park each at a different spot onsite and do not use them at the same time in
a hazardous area unless absolutely necessary. (This will minimize the possibility of both
pieces of equipment being damaged in the same explosion or fire.)
For personal protective equipment:
• Refill all empty self-contained breathing apparatus (SCBA) tanks and prepare them for
emergencies immediately after normal use.
• Stock higher levels of protective equipment than required for anticipated hazards (e.g., a
site where Level C equipment is normally used should have Level A and B equipment
available for emergencies).
Basic equipment that should be available at any site is listed in Table 5. Special equipment
should be obtained depending on the specific types of emergencies that may occur at a particu-
lar site and the capabilities of backup offsite personnel.
For example, if the nearest fire department is small and only carries one bucket of foaming solu-
tion because of its high cost and short shelf-life, a site may need to stock a large quantity of
foam. When determining the type and quantity of special equipment, the following factors should
be considered:
• The types of emergencies that may arise. For each emergency, consider a probable and
worst-case scenario.
• The types of hazards that site personnel may be exposed to and the appropriate contain-
ment, mitigative, and protective measures.
• The capabilities and estimated response times of offsite emergency personnel.
• The number of site personnel who could be victims during an emergency.
• The probable number of personnel available for response.
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Table 5 — Onsite Equipment and Supplies for Emergency Response

Personal Protection Medical Hazard Mitigation
Escape SCBA or SCBA which Air splints Firefighting equipment and supplies
can be brought to the victim to Antiseptics Spill-containment equipment, such as absor-
replace or supplement his or bents and oil booms
her SCBA Blankets
Personal protective equipment Decontamination solutions ap- Special hazardous-use tools such as remote
and clothing specialized for propriate for onsite chemical pneumatic impact wrenches, nonsparking
known site hazards hazards wrenches and picks
Emergency Eye was Containers to hold contaminated materials
Emergency showers or wash
stations
Ice
Reference books containing
basic first-aid procedures and
information on treatment of
specific chemical injuries
Resuscitator
Safety harness
Stretchers
Water in portable containers
Wire basket litter (Stokes litter)
which can be used to carry a
victim in bad weather and on a
difficult terrain, allows easy de-
contamination of the victim,
and is itself easy to decontami-
nate
Medical Treatment/First Aid
In emergencies, toxic exposures and hazardous situations that cause injuries and illnesses will
vary from site to site. Medical treatment may range from bandaging of minor cuts and abrasions
to lifesaving techniques. In many cases, essential medical help may not be immediately avail-
able.
For this reason, it is vital to train onsite emergency personnel in on-the-spot treatment tech-
niques, to establish and maintain telephone contact with medical experts (e.g., toxicologists),
and to establish liaisons with local hospitals and ambulance services. When designing this pro-
gram, these essential points should be included:
• Train a cadre of personnel in emergency treatment such as first aid and CPR. Training
should be thorough, frequently repeated, and geared to site-specific hazards.
• Establish liaison with local medical personnel, for example: 24-hour on-call physician,
medical specialists, local hospitals, ambulance service, and poison control center. Inform
and educate these personnel about site-specific hazards so that they can be optimally
helpful if an emergency occurs. Develop procedures for contacting them; familiarize all
onsite emergency personnel with these procedures.
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• Set up onsite emergency first-aid stations; see that they are well supplied and restocked
immediately after each emergency.
• Designate personnel to notify nearest OSHA office within 8 hours of incident if it results
in:
Death of one or more employees, or
Hospitalization of 3 or more employees.
Emergency Response Procedures
Response operations usually follow a sequence that starts with the notification of trouble and
continues through the preparation of equipment and personnel for the next emergency. This pro-
cess is illustrated in Figure 2.
Notification
Alert personnel to the emergency. Sound a site alarm to:

• Notify personnel.
• Stop work activities if necessary.
• Lower background noise in order to speed communication.
• Begin emergency procedures.
Notify onsite emergency response personnel about the emergency and include essential infor-
mation:
• What happened.
• Where it happened.
• Whom it happened to.
• When it happened.
• How it happened.
• The extent of damage.
• What aid is needed.
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Figure 2. Emergency Response Operations
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Size-Up
Available information about the incident and emergency response capabilities should be evaluat-
ed. The following information should be determined, to the extent possible:
• What happened:
Type of incident,
Cause of incident,
Extent of chemical release and transport, and
Extent of damage to structures, equipment, and terrain.
• Casualties:
Victims (number, location, and condition),
Treatment required, and
Missing personnel.
• What could happen:
Types of chemicals onsite,
Potential for fire, explosion, and release of hazardous substances,
Location of all personnel onsite relative to hazardous areas, and
Potential for danger to offsite population or environment.
• What can be done:
Equipment and personnel resources needed for victim rescue and hazard mitigation,
Number of uninjured personnel available for response,
Resources available onsite,
Resources available from outside groups and agencies,
Time for outside resources to reach the site, and
Hazards involved in rescue and response.
Rescue/Response Action
Based on the available information, the type of action required should be decided and the neces-
sary steps implemented. Some actions may be done concurrently. No one should attempt emer-
gency response or rescue until backup personnel and evacuation routes have been identified.
Rescue/ response actions may include:
• Enforce the buddy system: Allow no one to enter an Exclusion Zone or hazardous area
without a partner. At all times, personnel in the Exclusion Zone should be in line-of-sight
or communications contact with the Command Post Supervisor or designee.
• Survey casualties:
Locate all victims and assess their condition;
Determine resources needed for stabilization and transport.
• Assess existing and potential hazards to site personnel and to the offsite population.
Determine:
Whether and how to respond;
The need for evacuation of site personnel and offsite personnel;
The resources needed for evacuation and response.
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• Allocate resources. Allocate onsite personnel and equipment to rescue and incident re-
sponse operations.
• Request aid. Contact the required offsite personnel or facilities, such as the ambulance,
fire department, and police.
• Control. Bring the hazardous situation under complete or temporary control; use mea-
sures to prevent the spread of the emergency.
• Extricate. Remove or assist victims from the area.
• Decontaminate. Use established procedures to decontaminate uninjured personnel in the
Contamination Reduction Zone. If the emergency makes this area unsafe, establish a
new decontamination area at an appropriate distance. Decontaminate victims before or
after stabilization as their medical condition indicates (see Figure 1 for decision aid).
• Stabilize. Administer any medical procedures that are necessary before the victims can
be moved. Stabilize or permanently fix the hazardous condition (e.g., repack; empty filled
runoff dikes). Attend to what caused the emergency and anything (e.g., drums, tanks)
damaged or endangered by the emergency.
• Transport. Take measures to minimize chemical contamination of the transport vehicle
and ambulance and hospital personnel. Adequately protected rescuers should decon-
taminate the victims before transport. If this is not possible, cover the victims with ade-
quate sheeting. Before transportation, determine the level of protection necessary for
transport personnel. Provide them with disposable coveralls, disposable gloves, and
supplied air, as necessary, for their protection. If appropriate, have response personnel
accompany victims to the medical facility to advise on decontamination.
• Evacuate
Move site personnel to a safe distance upwind of the incident.
Monitor the incident for significant changes. The hazards may diminish, permitting
personnel to reenter the site, or increase and require public evacuation.
Inform public safety personnel when there is a potential or actual need to evacuate
the offsite population. Do not attempt large-scale public evacuation. This is the re-
sponsibility of government authorities (see Table 3).
Post-emergency response operations

In addition to many other requirements, the standard regulates worker safety and health during
post-emergency response operations.
The standard defines post-emergency response as:
“...that portion of an emergency response performed after the immediate
threat of a release has been stabilized or eliminated and clean-up of the site
has begun. If post-emergency response is performed by an employer’s own
employees who were part of the initial emergency response, it is considered
to be part of the initial response and not post-emergency response. However,
if a group of an employer’s own employees, separate from the group provid-
ing initial response, performs the clean-up operation, then the separate group
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of employees would be considered to be performing post-emergency

response and subject to paragraph 1910.120(q)(11) of this section.”
The employer conducting the clean-up must comply with all the requirements in 1910.120(b)-(o) of
the standard (29 CFR 1910.120(q)(11)(i)) unless the clean-up is done on plant property using plant
or workplace employees. The requirements under 1910.120(b)-(o) of the standard specify a mini-
mum of 24 hours of off-site training. If the clean-up is done on plant property using plant or work-
place employees, the employer must comply with the training requirements of 29 CFR 1910.38,
1910.134, 1910.1200, and other appropriate training made necessary by the tasks they are ex-
pected to perform (29 CFR 1910.120(q)(11)(ii)).
During oil spills, or for job duties and responsibilities with a low magnitude of risk, fewer than 24
hours of training may be appropriate for post-emergency clean-up workers. Though the number
of hours may vary, a minimum of four hours would be appropriate in most situations. Moreover,
petroleum spills are unique in that many people who assist in the clean-up operations may not
engage in this activity on a recurring basis. In addition, for maximum protection of the environ-
ment, petroleum spills dictate clean-up must be completed as soon as possible.
The U.S. Coast Guard and other concerned parties have requested flexibility in the amount of em-
ployee training required for petroleum spill clean-ups and other types of clean-up operations which
follow emergency situations.
The person with responsibility for making assessments when fewer than 24 hours of training is
required is the OSHA Regional Response Team representative.
Guidelines
If an employer complies with the clear intent of a standard but deviates from its particular require-
ments in a manner that has no direct or immediate relationship to employee safety or health,
such a violation is characterized as de minimis.
Compliance with the intent of the training requirements of 29 CFR 1910.120(q)(11)(i) is achieved
when an employer provides sufficient training as outlined in the following paragraph, but the
exact specifications of OSHA standards are not met. In such cases, a de minimis violation exists.
All of the following criteria must be met in order for training requirement violations to be classified as
de minimis:
1. Clean-up is performed in an area that has been monitored and fully characterized by a
qualified person indicating that exposures are presently and can be expected to remain
under permissible exposure limits and other published exposure limits;
2. Health risks from skin absorption are minimal;
3. Employees have completed the training requirements of 29 CFR 1910.38 and
1910.1200, including refresher training as appropriate;
4. Employees have completed other safety and health training made necessary by the
tasks they are expected to perform such as, but not limited to, operating procedures,
decontamination procedures, water safety, hypothermia, heat stress, and safety hazard
controls;
5. There is adequate on-site supervision by employees who meet the training requirements
of 29 CFR 1910.120(e)(4).
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Follow-Up
Before normal site activities are resumed, personnel must be fully prepared and equipped to
handle another emergency.
• Notify appropriate government agencies as required. For example, OSHA must be noti-
fied if there have been any fatalities or five or more hospitalizations.
• Restock all equipment and supplies. Replace or repair damaged equipment. Clean and
refuel equipment for future use.
• Review and revise all aspects of the Contingency Plan according to new site conditions
and lessons learned from the emergency response. When reviewing the information, con-
sider typical questions such as:
– Cause: What caused the emergency?
– Prevention: Was it preventable? If so, how?
– Procedures: Were inadequate or incorrect orders given or actions taken? Were these
the result of bad judgment, wrong or insufficient information, or poor procedures? Can
procedures or training be improved?
– Site profile: How does the incident affect the site profile? How are other site cleanup
activities affected?
– Community: How is community safety affected?
– Liability: who is liable for damage payments?
Safe Work Practices
To maintain a strong safety awareness and enforce safe procedures at a site, a list of standing
orders should be developed that state the practices that must always be followed and those that
must never occur in the contaminated areas onsite. Separate standing orders should be devel-
oped for the Contamination Reduction Zone and the Exclusion Zone if the hazards are sufficient-
ly different. To ensure that everyone who enters the site is aware of these orders and that a high
degree of familiarity with their content is maintained, the list should be:
• Distributed to everyone who enters the site;
• Posted conspicuous at the Command Post;
• Posted conspicuous at the entrance Access Control Points into the Contamination Re-
duction Zone and/or the Exclusion Zone;
• Reviewed by the Field Team Leader or Project Team Leader with the field crew at the
beginning of each work day. In this way, personnel are immediately informed of any new
standing orders resulting from a change in site conditions or work activities.
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Sample standing orders include:

For Personnel Entering the Contamination Reduction Zone:
• No smoking, eating, drinking, or application of cosmetics in this zone;
• No matches or lighters in this zone;
• Check in at the entrance Access Control Point before you enter this zone; and
• Check out at the exit Access Control Point before you leave this zone.
For Personnel Entering the Exclusion Zone:
• No smoking, eating, drinking, or application of cosmetics in this zone;
• No matches or lighters in this zone;
• Check in at the entrance Access Control Point before you enter this zone;
• Check out at the exit Access Control Point before you leave this zone;
• Always have your buddy with you in this zone;
• Wear an SCBA in this zone; and
• If you discover any signs of radioactivity, explosivity, or unusual conditions such as dead
animals at the site, exit immediately and report this finding to your supervisor.
In addition to the standing orders, a hazardous substance information form that lists the names
and properties of chemicals present onsite should be prepared and posted conspicuously. Em-
ployees should be briefed on the chemical information at the beginning of the project or whenev-
er they first join the work team. Daily safety meetings should be held for all employees.
Working with tools and heavy equipment is a major hazard at sites. Injuries can result from
equipment hitting or running over personnel, impacts from flying objects, burns from hot objects,
and damage to protective equipment such as supplied-air respirator systems. The following pre-
cautions will help preclude injuries due to such hazards:
• Train personnel in proper operating procedures;
• Install adequate onsite roads, signs, lights, and devices;
• Install appropriate equipment guards and engineering controls on tools and equipment.
These include roll-over protective structures, seat belts, emergency shutoff in case of rol-
lover, and backup warning lights and signals;
• Provide equipment such as cranes, derricks, and power shovels with signs saying “Un-
lawful to operate this equipment within 10 feet of all power lines”;
• Use equipment and tools that are intrinsically safe and not capable of sparking and pneu-
matically and hydraulically driven equipment;
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• Where portable electric tools and appliances can be used, (i.e., where there is no poten-
tial for flammable or explosive conditions), use three-wire grounded extension cords to
prevent electric shocks;
• In hydraulic power tools, use fire-resistant fluid that is capable of retaining its operating
characteristics at the most extreme temperatures;
• At the start of each work day, inspect brakes, hydraulic lines, light signals, fire extinguish-
ers, fluid levels, steering, and splash protection;
• Keep all non-essential people out of the work area;
• Prohibit loose-fitting clothing or loose long hair around moving machinery;
• Keep cabs free of all non-essential items and secure all loose items;
• Do not exceed the rated load capacity of a vehicle;
• Instruct equipment operators to report to their supervisor(s) any abnormalities such as
equipment failure, oozing liquids, and unusual odors;
• When an equipment operator must negotiate in tight quarters, provide a second person to
ensure adequate clearance;
• Have a signalman direct backing as necessary;
• All onsite internal combustion engines should have spark arrestors that meet require-
ments for hazardous atmospheres. Refuel in safe areas. Do not fuel engines while
vehicle is running. Prohibit ignition sources near a fuel area;
• Lower all blades and buckets to the ground and set parking brakes before shutting off the
vehicle;
• Implement an ongoing maintenance program for all tools and equipment. Inspect all tools
and moving equipment regularly to ensure that parts are secured and intact with no evi-
dence of cracks or areas of weakness, that the equipment turns smoothly with no evi-
dence of wobble, and that it is operating according to manufacturer’s specifications.
Promptly repair or replace any defective items. Keep maintenance and repair logs;
• Store tools in clean, secure areas so they will not be damaged, lost, or stolen; and
• Keep all heavy equipment used in the Exclusion Zone in that zone until the job is done.
Completely decontaminate such equipment before moving it into the clean area.
Documentation
The Project Team Leader should initiate the investigation and documentation of the incident. This
is important in all cases, but especially so when the incident has resulted in personal injury,
onsite property damage, or damage to the surrounding environment.
Documentation may be used to help avert recurrences, as evidence in future legal action, for
assessment of liability by insurance companies, and for review by government agencies. Meth-
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ods of documenting can include a written transcript taken from tape recordings made during the
emergency or a bound field book (not a loose-leaf book) with notes. The document must be:
• Accurate: All information must be recorded objectively.
• Authentic: A chain-of-custody procedure should be used. Each person making an entry
must date and sign the document. Keep the number of documentors to a minimum (to
avoid confusion and because they may have to give testimony at hearings or in court).
Nothing should be erased. If details change or revisions are needed, the person making
the notation should mark a horizontal line through the old material and initial the change.
• Complete: At a minimum, the following should be included:
-- Chronological history of the incident;
-- Facts about the incident and when they became available;
-- Title and names of personnel; competition of teams;
-- Actions decisions made and by whom; orders given:
to whom, by whom, and when; and actions taken:
who did what, when, where, and how;
-- Types of samples and test results; air monitoring results;
-- Possible exposures of site personnel; and
-- History of all injuries or illnesses during or as a result of the emergency.
Appendix A: Requirements for Employers Who Plan to Evacuate Employees
As an employer, you may choose to evacuate your employees from the workplace when an
emergency occurs rather than having your employees respond to or assist with a hazardous
substance emergency. If that is the case, the written emergency response plan required un-
der 1910.120(l)(1), (p)(8), and (q)(1) need not be developed if you provide a written emergen-
cy action plan in accordance with 1910.38 (see Appendix C to this section for a sample emer-
gency action plan outline).
The emergency action plan required by 1910.38 should be in writing and should cover the desig-
nated actions employers and employees must take to ensure employee safety from fire and oth-
er emergencies. The plan should, at a minimum, include the following elements:
• Emergency escape procedures and emergency escape route assignments;
• Procedures to be followed by employees who remain to operate critical plant operations
before they evacuate;
• Procedures to account for all employees after emergency evacuation has been com-
pleted;
• Rescue and medical duties for those employees who are to perform them;
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• The preferred means of reporting fires and other emergencies; and

• Names or regular job titles of persons of departments who can be contacted for further
information or explanation of duties under the plan.
In addition, the types of evacuations to be used in emergency circumstances must be estab-
lished in the emergency action plan.
Prior to implementing the emergency action plan, a sufficient number of persons must be desig-
nated by the employer and trained to assist in the safe and orderly emergency evacuation. The
employer is required to review the emergency action plan with each employee covered by the
plan at the time the plan is initially developed, whenever the employee’s responsibilities or desig-
nated actions under the plan change. and whenever the plan itself is changed. In addition, the
employer must review with each employee, upon initial assignment, the parts of the plan which
the employee must know to protect the employee in the event of an emergency.
The written plan must be kept at the workplace and made available to employees for review.
Employers with 10 or fewer employees need not maintain a written plan, as OSHA permits the
plan to be communicated orally to employees in those instances.
OSHA’s general duty clause (section 5(a)(1) of the OSH Act) requires employers to provide a
safe place for all employees to work. This includes employees with disabilities. If your company
has employees with disabilities, include them in developing your emergency action plan.
Different disabilities require different planning needs. Someone with a hearing impairment may
not hear an alarm, but will have no trouble walking down stairs. Someone in a wheelchair may
hear an alarm but cannot get down the stairs without help. A mentally challenged person may
see or hear alarms, but not understand what to do.
Plans should include provisions not only for people using wheelchairs or other mobility assistive
devices, such as walkers and crutches, but also for those who are deaf/hearing impaired, blind/
visually impaired, and those who may have chronic health conditions that may preclude safe
evacuation (an example may be someone using portable oxygen).
Your company may want to keep a current list of individuals needing assistance as part of their
emergency action plan. This list should be accessible to emergency personnel to help with emer-
gency evacuation.
Finally, as part of the emergency action plan, the employer must establish an employee alarm
system which complies with 1910.165 (see Appendix B: Employee Alarm Systems). If the alarm
system is used for alerting fire brigade members or for other purposes, a distinctive signal for
each purpose must be used.
CAUTION: While the regulation provides some specific relief from the emergency response plan
requirements for employers who plan to evacuate their employees, it may not exempt employers
from compliance with the remaining parts of the regulation. Other requirements of the regulation
should be reviewed to determine applicability to the specific workplace. Some employers may
also be required to comply with EPA regulations for contingency plans and emergency proce-
dures.
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Appendix B: Employee alarm systems.

(a) Scope and application. (1) This section applies to all emergency employee alarms installed to
meet a particular OSHA standard. This section does not apply to those discharge or supervisory
alarms required on various fixed extinguishing systems or to supervisory alarms on fire suppres-
sion, alarm or detection systems unless they are intended to be employee alarm systems.
(2) The requirements in this section that pertain to maintenance, testing and inspection shall
apply to all local fire alarm signaling systems used for alerting employees regardless of the other
functions of the system.
(3) All pre-discharge employee alarms installed to meet a particular OSHA standard shall meet
the requirements of paragraphs (b)(1) through (4), (c), and (d)(1) of this section.
(b) General requirements. (1) The employee alarm system shall provide warning for necessary
emergency action as called for in the emergency action plan, or for reaction time for safe escape
of employees from the workplace or the immediate work area, or both.
(2) The employee alarm shall be capable of being perceived above ambient noise or light levels
by all employees in the affected portions of the workplace. Tactile devices may be used to alert
those employees who would not otherwise be able to recognize the audible or visual alarm.
(3) The employee alarm shall be distinctive and recognizable as a signal to evacuate the work
area or to perform actions designated under the emergency action plan.
(4) The employer shall explain to each employee the preferred means of reporting emergencies,
such as manual pull box alarms, public address systems, radio or telephones. The employer
shall post emergency telephone numbers near telephones, or employee notice boards, and other
conspicuous locations when telephones serve as a means of reporting emergencies. Where a
communication system also serves as the employee alarm system, all emergency messages
shall have priority over all nonemergency messages.
(5) The employer shall establish procedures for sounding emergency alarms in the workplace.
For those employers with 10 or fewer employees in a particular workplace, direct voice commu-
nication is an acceptable procedure for sounding the alarm provided all employees can hear the
alarm. Such workplaces need not have a back-up system.
(c) Installation and restoration. (1) The employer shall assure that all devices, components, com-
binations of devices or systems constructed and installed to comply with this standard are ap-
proved. Steam whistles, air horns, strobe lights or similar lighting devices, or tactile devices meet-
ing the requirements of this section are considered to meet this requirement for approval.
(2) The employer shall assure that all employee alarm systems are restored to normal operating
condition as promptly as possible after each test or alarm. Spare alarm devices and components
subject to wear or destruction shall be available in sufficient quantities and locations for prompt
restoration of the system.
(d) Maintenance and testing. (1) The employer shall assure that all employee alarm systems are
maintained in operating condition except when undergoing repairs or maintenance.
(2) The employer shall assure that a test of the reliability and adequacy of non-supervised em-
ployee alarm systems is made every two months. A different actuation device shall be used in
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each test of a multi-actuation device system so that no individual device is used for two consecu-
tive tests.
(3) The employer shall maintain or replace power supplies as often as is necessary to assure a
fully operational condition. Back-up means of alarm, such as employee runners or telephones,
shall be provided when systems are out of service.
(4) The employer shall assure that employee alarm circuitry installed after January 1, 1981,
which is capable of being supervised is supervised and that it will provide positive notification to
assigned personnel whenever a deficiency exists in the system. The employer shall assure that
all supervised employee alarm systems are tested at least annually for reliability and adequacy.
(5) The employer shall assure that the servicing, maintenance and testing of employee alarms
are done by persons trained in the designed operation and functions necessary for reliable and
safe operation of the system.
(e) Manual operation. The employer shall assure that manually operated actuation devices for
use in conjunction with employee alarms are unobstructed, conspicuous and readily accessible.
Appendix C: Sample Emergency Action Plan Outline
Emergency action plans are specifically required by OSHA 29 CFR 1910.38 and referred to in
Part 1910.120. According to OSHA, emergency actions plans “... shall be in writing and shall
cover those designated actions employers and employees must take to ensure employee safety
from fire and other emergencies.” Emergency action plans should define exactly what constitutes
an emergency and what actions are to be taken. Examples of emergencies include injuries, fires,
spills, severe weather, bomb threats, toxic releases, and civil disturbances.
Emergency action plans should contain a detailed description of emergency personnel in the
company. All personnel should know their positions’ responsibilities, who they answer to, and
who they are in charge of. Members and captains of emergency response teams, cleanup
teams, medical teams and others should all be identified. An organization chart is an excellent
way to visually show a plant’s emergency organization.
Of all aspects of emergency planning, communications can be the most important. The methods
of announcing an emergency in a clear, easily understood manner can save time and lives dur-
ing an emergency. A good emergency action plan will detail at least the following: who to contact
for an emergency, or how to sound the alarm; if plant sirens or horns are used, what different
sounds mean; if the plant has a radio system, emergency channels should be identified; how to
contact emergency response team members both in the plant and at home; the methods of plant
communications; if a local radio station is to be used for announcing information; personnel au-
thorized to speak to the media, and methods of speaking; and the location of the emergency
control center and personnel assigned.
An emergency action plan should describe the immediate actions for all personnel within the
plant, including contractors, visitors, and other non-plant personnel. All personnel must know
where to go for counting purposes. All personnel should be accounted for.
Evacuation routes and policies should be specified in the plan. The directions out of the plant
and the required headcount areas should be explained. The use of floorplans or workplace maps
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which clearly show the escape routes should be included in the emergency plan. Color coding
may aid employees in determining their route assignments.
Training methods for the emergency response team should be detailed. Who is required to re-
ceive which kind of training should be defined in the emergency plan. Also, the methods for
testing the plant alarm systems and practice evacuations should be discussed.
PART I: EMERGENCY ACTION PLAN OUTLINE
1. Introduction
A. Emergency Action Plan Manual (manual) Objectives - List the objectives to be filled in the
development and use of the emergency plan.
B. Organizational Statement - Define the composition and objectives of the plant emergency
organization.
C. Definitions of an Emergency - Briefly describe the types of incidents warranting the decla-
ration of an emergency at the facility.
2. Emergency Organization
A. Purpose of the emergency organization.
B. Emergency Organization Chart - Define chain of command for emergency situations.
C. Responsibilities of key personnel who direct the emergency response, including designa-
tions of those individuals included in the emergency organization by title and the responsi-
bilities of each.
D. Emergency Control Center - Detail the location, organization and responsibility of the
emergency control center.
E. Emergency Response Teams - Define the intent, composition and responsibilities of the
fire brigade, hazmat team, first aid team, and all other emergency response teams.
F. Personnel Movement Policies - Provide general guidelines for the movement of refinery
personnel during an emergency.
1. Objectives
2. Personnel having authority to move as necessary to accomplish their function during
an emergency
3. Personnel who should remain at their assigned stations during an emergency unless
there is someone who can assume responsibility for their duties while they are gone
4. Personnel who should move to nearest safe shelter
G. Plans required by OSHA or EPA
Include copies of the following formal written plans if required:
1. Spill prevention control and countermeasure plan
HAZWOPER--162
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2. Pollution incidence prevention plan

H. Letters of agreement with the following:
1. Police department
2. Fire departments
3. Local hospitals/medical facilities
I. Contract with local area industrial mutual aid.
3. Emergency Communications Procedures
A. Emergency Fire Alarm Systems - Description of the emergency fire alarm.
B. Use of Radios and Telephones - Explain who should use telephones and radios and
which channels should be used for a given situation. Also cover general good commu-
nications practices for use in an emergency situation.
C. Emergency call-outs.
1. Call-out procedure — Provide general instructions for call-out procedures including re-
sponsibilities of personnel to initiate call-outs.
a) product control personnel
b) management/professional
D. Media Guidelines — Provide general instructions for interface with media. Include names
of personnel authorized to make press releases and guidelines for the development of
press releases.
4. Training Requirements
A. Responsibilities — Define areas of responsibility for emergency plan/procedure-related
training. Include:
1. Documentation requirements
2. Qualification of instructors
B. Applicability — Identify the employees that should receive each type of training and refer-
ence each training course to applicable federal/state requirements.
C. Scope and Frequency of Training — Define, by course, the scope and sequence of train-
ing associated with emergency procedures/planning and emergency response teams. In-
clude training required for the following:
1. Hazardous materials (29 CFR 1910.120, 29 CFR 1910.1200 and 40 CFR 264.16)
2. Fire (29 CFR 1910.156)
3. Emergency Plan (29 CFR 1910.38)
HAZWOPER--163
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4. First Aid (29 CFR 1910.151)

5. Control and Revision
A. Manual Distribution — List those personnel and/or locations where current revisions of
each manual should be kept.
B. Procedure for Revising the Manual — Specify who may initiate a manual revision and
what steps must be followed, who must approve any revision, and how a revision is to be
incorporated into the manual.
PART II: EMERGENCY CONTROL PLAN PROCEDURES OUTLINE
1. First Aid Emergencies

A. Responsibilities of the emergency coordinator, the shift supervisor and other key person-
nel.
B. Handling injured employees.
1. Treatment of injuries at in-house medical facility
2. Transportation of injured employees to off-site medical
facilities
C. Safety and medical equipment lists.
D. Telephone directories.
1. Hospitals
2. Company medical staff
3. Ambulance service
2. Fire Emergencies
A. Responsibilities of the emergency coordinator, the

shift supervisor and other key personnel.
B. Procedures to handle various types of fires.
1. Process area fires
2. Non-pressurized tank fires
3. Pressurized tank fires
4. Fires at loading facilities
5. Warehouse fires
6. Office building fires Source: U.S. Coast Guard
HAZWOPER--164
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7. Electrical fires
C. Description of fire water system.
D. Outside assistance
1. Mutual aid organizations
2. Local fire departments
E. Fire fighting equipment list.
F. Supplementary information (as applicable).
1. LPG fires
2. Tank fires
3. Boilovers
3. Environmental release procedure
A. Responsibilities of the emergency coordinator, the shift supervisor and other
key personnel.
B. Procedures.
1. Toxic gas releases
2. Flammable gas releases
3. Hazardous liquid spills
4. Oil spills
5. Release of radiation
6. Notification procedure (40 CFR
Part 372 Subpart B, 40 CFR Part
302.6) Source: U.S. Coast Guard
a) EPA notification
b) State environmental agencies
c) Coast Guard notification
d) Local response groups
e) Corporate notification
C. Spill control equipment list.
D. Telephone directories.
1. Company response teams
2. Spill clean-up companies
E. List of hazardous materials or substances found on-site.
4. Severe weather emergency procedure
key personnel.
3/14 HAZWOPER–165

B. Procedures for severe weather emergencies.

1. Hurricanes
2. Tornados
3. Winter storms
4. Flooding
5. Bomb threat/civil disturbance procedure
A. Responsibilities of the emergency coordina-
tor, the shift supervisor and other key
Source: U.S. Coast Guard
personnel.
B. Bomb threat procedures.
1. Telephone operator instructions.
2. Mail room instructions.
3. Bomb search team.
a) Organization.
b) Instructions.
4. Bomb threat check list.
C. Procedures for civil disturbances.
6. Evacuation procedures (29 cfr part 1910.38)
key personnel.
B. Evacuation routes (29 CFR Part 1910, Appendix to subpart E).
C. Office evacuation.
D. Plant evacuation.
E. Evacuation of adjacent industries.
F. Notification of civil authorities.
G. Personnel accounting procedure (29 CFR Part 1910.38(c)) (including contractor
personnel).
166–HAZWOPER 3/14

Appendix D: Emergency Response Compliance Checklist
__________________________________________________________
(Name of Site)
__________________________________________________________
(Street Address or Geographic Location of Incident)
__________________________________________________________
(City, State, Zip)
__________________________________________________________
(Name of Manager/Owner)
__________________________________________________________
(Phone Number)
I. Review of the Emergency Response Plan (ERP).
Paragraph Met Y/N

A. Do the provisions of 29 CFR 1910.120(q) apply? (Would the substances present on-site (q)
require an emergency response if released?)
B. Which compliance strategy does the employer use? Evacuation of all employees in ac- (q)(1)
cordance with 29 CFR 1910.38, or emergency response by employees in accordance
with 29 CFR 1910.120(q)?
C. Does the employer have an emergency response plan or an emergency action plan? (q)(1)
D. Does the employer have an emergency action plan in accordance with 29 CFR 1910.38, 1910.38
if the employer does not have an ERP but expresses an intent to evacuate all personnel
and not allow any employees to respond, (may be communicated orally to employees by
employers with 10 or fewer employees)? If not, then 29 CFR 1910.38 shall be cited. The
determination that the employer intends to evacuate all employees must be documented
on the Narrative, OSHA-1A Form.
E. If the employer does not have an emergency response plan but has an emergency action 1910.38
plan, is the emergency action plan adequate?
HAZWOPER--167
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Paragraph Met Y/N

F. Emergency Action Plan compliance checklist: 1910.38
1. Is the Plan in writing (may be communicated orally to employees by employers with 1910.38(a)
10 or fewer employees)?
2. Are emergency escape procedures and emergency escape routes designated? 1910.38(c)(2)
3. Are procedures established to account for all employees after the emergency evacu- 1910.38(c)(4)
ation has been completed?
4. Has an employee alarm system which complies with 29 CFR 1910.165 been estab- 1910.38(d)
lished?
5. If an employee alarm system is used for other purposes, have distinctive signals for 1910.38(d)
each purpose been developed?
6. Has the employer designated and trained a sufficient number of persons to assist in 1910.38(e)
the safe and orderly evacuation of employees (generally one per 20 employees)?
7. Has the employer reviewed the emergency action plan with each employee covered 1910.38(f)
by the plan initially, and when the plan or the employee’s responsibilities under the
plan change?
8. Is the written plan kept at the workplace (may be communicated orally to employees 1910.38(b)
by employers with 10 or fewer employees) and made available for employee review?
9. Has the plan been effectively communicated and implemented by the employer to
ensure that employees do not assist in handling emergencies, or does the employer
actually intend to have employees respond to emergencies?
10. Does the employer intend to have employees handle incidental releases? If so, are
the training, tools, equipment, and PPE appropriate for handling incidental releases
of the hazardous substance available in the work area?
11. Does the employer have procedures for notifying both inside and outside parties of 1910.38(c)(1)
incidents? Employees may be placed at risk in situations where they are required by
the plan to remain in a temporarily safe area to shut down an operation, and the plan
does not have procedures for the employer to ensure that outside responders are
notified in a timely manner. CSHOs should look closely at emergency action plans
that do not have procedures for immediately contacting the local fire department and
other outside parties in order to determine whether such plans place any workers at
risk.
NOTE: The term “outside parties” means outside responders (fire departments, police,
private hazmat teams, emergency medical service personnel, and other pertinent compo-
nents of the local, state, and federal emergency response system) and other employers
in the surrounding area who could be affected by a hazardous substance emergency inci-
dent.
G. Is the Emergency Response Plan (ERP) in writing? (q)(1)
H. Is the ERP easily accessible to employees? (q)(1)
I. Does the employer make use of the local or State ERP in the company ERP? If so, does (q)(2)(xii)
the local or State ERP adequately provide employee protection for this employer?
NOTE: Emergency response organizations may use the local or State ERP as part of their
ERP to avoid duplication. However, the plan must address all of the provisions listed in 29 CFR
1910.120(q)(2) and (q)(3).
HAZWOPER--168
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Paragraph Met Y/N

J. Does the ERP reflect pre-emergency planning and coordination with outside parties? (q)(2)(i)
1. Does the plan describe procedures or existing agreements addressing how the out- (q)(2)(i)
side parties are to be notified of an potential emergency situation and what role each
should play in an incident?
2. If any response coordination procedures or agreements are included in the plan, are (q)(2)(i)
the local fire department and other selected outside emergency response parties
aware of their roles and responsibilities as described in the plan?
3. Can outside responders identify any reasons that were not considered by the em- (q)(2)(i)
ployer that would delay or prevent them from responding to an incident (e.g., dis-
tance, lack of training, etc.)?
K. Are personnel roles, lines of authority, training, and communication provided in the ERP? (q)(2)(ii)
(Suggestion: review personnel roles and lines of authority with the designated On-Scene
Incident Commander if possible.)
L. Does the ERP address emergency recognition and prevention? (q)(2)(iii)

(Suggestion: Determine if the employer established the kinds of emergencies that could occur
in the workplace, trained employees to recognize potential emergencies, and/or installed mon-
itoring devices to alert employees to an emergency.)
M. Does the ERP address safe distances and places of refuge adequate for all employees (q)(2)(iv)
who may need it?
N. Does the ERP designate equipment, people, and procedures to ensure site security and (q)(2)(v)
control?
O. Are evacuation routes and procedures developed, and do they work well with the meth- (q)(2)(vi)
ods developed for emergency alerting and the designation of places of refuge?(Sugges-
tion: Check the evacuation routes and procedures against the requirements given in 29
CFR 1910.38, emergency action plans.)
P. Does the ERP address the setting up of a decontamination station, and the decontamina- (q)(2)(vii)
tion of personnel and equipment?
Q. Are emergency medical treatment and first aid available to employees during an emer- (q)(2)(viii)
gency response?(Suggestion: Verify that emergency medical personnel are aware of
their roles in an emergency and trained to fulfill their roles.)
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Paragraph Met Y/N

R. Are emergency alerting and response procedures addressed in the ERP? Is there evi- (q)(2)(ix)
dence of an alerting and response system?(Suggestion: If the emergency situation calls
for special instructions, determine if the emergency alerting system indicates the location
of the hazard, the direction employees should evacuate, what the hazard is, and any spe-
cial PPE employees must do.)
S. Does the ERP address the types and uses of PPE and emergency response equipment (q)(2)(xi)
to be used?
T. Does the ERP provide procedures for the critique of emergency responses? (q)(2)(x)
U. Are there any other features that are missing or should be addressed in the employer’s (q)(1)
ERP?
NOTE: The elements listed in 29 CFR 1910.120(q)(2) are minimum requirements. The perfor-
mance-oriented aspect of the ERP is in 29 CFR 1910.120(q)(1), which states that the ERP
“shall be developed and implemented to handle anticipated emergencies prior to the com-
mencement of emergency response operations.”
II. Review of Procedures for Handling Emergencies.
Paragraph Met Y/N

A. Has a single individual been identified as the On-Scene Incident Commander? (q)(3)
B. Is there a system in place that passes the senior official position up the line of authority (q)(3)
as more senior officials arrive on the scene?
NOTE: The senior official assists the On-Scene Incident Commander, “the individ-
ual in charge of the Incident Command System” in 29 CFR 1910.120(q)(3).
C. Has a safety official been identified? (q)(3)(vii)
NOTE: In smaller responses the On-Scene Incident Commander may play this
role.
HAZWOPER--170
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III. Review of Training Requirements.

Paragraph Met Y/N
A. Has the employer certified that the employee has been provided training? (q)(6)
NOTE: The employee does not necessarily have to be provided with a certificate, although the
employer must certify in writing that employees who have successfully completed the first
responder operations, HAZMAT Technician, HAZMAT Specialist, and On-Scene Incident Com-
mander levels are trained.
B. If employee training is done in-house, is training based on the specific duties and functions (q)(6)
to be performed at the site?
NOTE: Keep in mind that OSHA does not endorse training programs, but may offer suggestions
as to their comprehensiveness.
C. Does the employer have a “statement of training” or “statement of competency” for annual (q)(8)
refresher training or competency for all employees trained in emergency response?
NOTE: Methods of demonstrating competency include critiques of actual incidents or “dress

rehearsals” which identify any weakness and effectiveness of the response effort.
D. If employee annual refresher training is done in-house, is training adequate for the site? (q)(8)
NOTE: Keep in mind that OSHA does not endorse training programs, but may offer suggestions
as to their comprehensiveness.
IV. Review of Medical Surveillance.

Paragraph Met Y/N
A. Does the employer furnish the employee with the physician’s written opinion indicating 1910.120(q)
medical results and whether the employee is capable of working with hazardous materials? (9)(I) 1910.1020
B. Is medical recordkeeping done in a manner consistent with 29 CFR 1910.1020, Access 1910.1020
to Employee Exposure and Medical Records?
V. Review of Personal Protective Equipment Program.
NOTE: Subparagraph 29 CFR 1910.120(q)(10) refers to the provisions for PPE in 29 CFR
1910.120(g)(3)-(g)(5).
Paragraph Met Y/N
A. Is the PPE chosen sufficiently protective of employees, based on hazards and potential (q)(10)
hazards?
B. Is the PPE maintained and inspected routinely? (q)(10)
HAZWOPER–171
9/09

Paragraph Met Y/N
C. Does the PPE appear to be in good condition and up to date? (q)(10)
D. Is air monitoring equipment available to assist the Incident Commander in determining (q)(3)(iv)
when to increase or lower the level of PPE?
HAZWOPER Audit Checklist

Do your employees clean up at uncontrolled hazardous waste sites or at EPA-
licensed waste treatment, storage, and disposal facilities?
Do you have employees assigned to respond to emergencies involving
hazardous materials?
Do you need to have the written program that identifies, evaluates, and controls
safety and health hazards and provides emergency response procedures for
each hazardous waste site or treatment, storage, and disposal facility?
Does the written program include the following:
An organizational workplan
Site evaluation and control
A site-specific program
Monitoring
Medical surveillance program
Decontamination procedures
Emergency response program?
Is it periodically updated?
Is it made available to all affected employees, contractors, and subcontractors?
Do you have a workplan that establishes a chain of command and employer and
employee responsibilities?
Have you carried out a site evaluation and established a control plan?
Have employees been provided with the requisite information and training for
their respective positions?
Have employees been trained not to rely solely on material safety data sheets in
the event of an emergency? Individuals calling the emergency number on the
MSDS during a spill have on occasion been unable to reach informed advisors;
chemical companies have delayed returning emergency calls. Also, information
provided on the MSDS may not be accurate.
Is there a Personal Protective Equipment Program?
Is the requisite monitoring carried out?
Is the required medical surveillance of employees carried out?
HAZWOPER–172
9/09

Are emergency response procedures developed?

Does your control plan take into account for potential problems resulting from
interruptions and distractions like: concerned calls from the mayor and
neighboring citizens; well-intentioned persons worried about property or wildlife
damage; insurance adjusters; news media coverage; bystanders communication
breakdowns between the facility and the hazardous materials response team of
the local fire department?
Have security concerns been addressed? Security breaches and theft of trade
secrets have resulted from the vulnerability resulting from industrial accidents or
spills.
Has your facility implemented feasible and useful engineering controls and work
practices?
Are employee exposure and medical records kept for 30 years and made
available to the employee upon request?
Select OSHA Letters of Interpretation

OSHA requirements are set by statute, standards, and regulations. Letters of Interpretation
(LOIs) explain these requirements and how they apply to particular circumstances as
addressed in the letter. They are not necessarily intended to cover all similar situations. As
such, LOIs are published so that other employers can understand OSHA’s interpretation of a
regulation and provide guidance where the regulation may not be specific.
LOIs do not change the law as stated in the OSH Act, or alter OSHA regulations, and are
not designed to create additional employer obligations.
Provided here are LOIs that specifically relate to HAZWOPER spill cleanup activities.
Application of Absorbent Pads for Spill Control; Hazardous Waste

Site Cleanup Training Does Not Qualify Worker as Hazardous
Materials Technician
Standard Number: 1910.120; 1910.120(q)(6); 1910.120(e)
February 26, 2003
Mr. Thomas Johnston
Environmental Analyst
State of Alaska Department of Transportation
PO Box 196960
Anchorage, Alaska 99519-6960
Dear Mr. Johnston:
Thank you for your October 16, 2002, letter to the Occupational Safety and Health Administration’s
(OSHA’s) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA’s interpreta-
tion only of the requirements discussed and may not be applicable to any scenarios not delineated
3/14 HAZWOPER–173

within your original correspondence. You further detailed your concerns and questions regarding 29
CFR 1910.120, the Hazardous Waste Operations and Emergency Response (HAZWOPER) stan-
dard, during a phone conversation on October 30, 2002. As you requested, this letter provides a
written record of our responses to you.
Question 1: Would the application of absorbent pads to control the release of jet fuel or gasoline
from an overturned aircraft constitute an operation that requires emergency response training
under paragraph (q)(6) of HAZWOPER? This activity is conducted only under non-emergency
conditions to limit environmental contamination, and there is a separate emergency response team
to handle the overturned aircraft.
Response 1: Paragraph (q) of 1910.120 covers emergency response operations for releases of,
or substantial threats of releases of, hazardous substances without regard to the location of the
hazard. However, responses to releases of hazardous substances where there is no potential
safety or health hazard are not considered to be emergency responses. Incidental releases of
hazardous substances where the substance can be absorbed, neutralized, or otherwise controlled
at the time of the release by employees in the immediate release area, or by maintenance per-
sonnel, are not considered to be emergency responses within the scope of the standard. Appendix
E of OSHA Directive CPL 02-02-059 [formerly CPL 2-2.59A] —Inspection Procedures for the
Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120 and 1926.
65, Paragraph (q): Emergency Response to Hazardous Substance Releases provides a more
thorough discussion of the distinction between incidental releases of hazardous substances and
releases that require an emergency response, and hence, compliance with the provisions of
1910.120(q).
As we discussed on the phone, if the release of jet fuel or gasoline is covered by 40 CFR 300, the
National Oil and Hazardous Substances Pollution Contingency Plan (NCP), you may be required
by EPA to follow HAZWOPER. Subpart 300.150 requires that response actions under the NCP
comply with the provisions of 29 CFR 1910.120. Your local EPA office could address this in further
detail.
Question 2: Would the training required under 29 CFR 1910.120(e) qualify a worker as a Haz-
ardous Materials Technician under 29 CFR 1910.120(q)(6)(iii)?
Response 2: No, hazardous waste site cleanup training under HAZWOPER paragraph (e) does
not qualify a worker as a hazardous materials technician as described in (q)(6)(iii) of the standard.
The conditions under which these two types of personnel operate and the training they require are
generally quite different.
Typically, the cleanup worker is remediating a site after a hazardous substance release has
occurred and the location and level of hazardous substances on the site are well-characterized. A
hazardous materials technician, however, may operate close to the point of actively releasing
hazardous substances for the purpose of stopping or controlling the release. Therefore, although
some of the topics addressed in paragraph (e) and (q) may sound similar, the content and extent
of the training would be different. For example, your letter suggested that cleanup worker training
that discusses the safe use of engineering controls and equipment on the site, [1910.120(e)(2)(v)],
might be comparable to the 1910.120(q)(6)(iii)(F) competency to “be able to perform advance
control, containment and/or confinement operations...”
We hope it is clear from the discussion above that the cleanup worker will likely be operating in a
more controlled, predictable work environment than the hazardous material technician. Knowledge
of the “safe use of engineering controls and equipment” may involve an understanding of well-
planned standard operating procedures, whereas competency in “advance control and
containment” will require an ability to predict the behavior of actively releasing hazardous
substances.
Hazardous materials technicians must receive at least 24 hours of training equal to the first
responder operations level and in addition have the competencies listed in paragraph 1910.
120(q)(6)(iii)(A) – (I). Employers must certify that their employees have these competencies. For
more detail about training for hazardous substance emergency responders, we recommend that
174–HAZWOPER 3/14

you review NFPA 472, Professional Competence of Responders to Hazardous Material Incidents.
This consensus standard is referenced in Appendix C of HAZWOPER as an excellent resource
document for developing training programs.
As a reminder, the State of Alaska administers its own occupational safety and health program
under a plan approved and monitored by Federal OSHA. Therefore, employers in Alaska must
comply with state occupational safety and health requirements. As a condition of plan approval,
states must adopt and enforce occupational safety and health standards that are at least as
effective as those of Federal OSHA. Further inquiries regarding this or any other health and safety
matter should be addressed to your state office at:
Alaska Department of Labor and Workforce Development
P.O. Box 21149
Juneau, Alaska 99801-1149
Phone: (907) 465-4855
Website: http://www.labor.state.ak.us/lss
Thank you for your interest in occupational safety and health. We hope you find this information helpful.
OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these
requirements and how they apply to particular circumstances, but they cannot create additional employer
obligations. This letter constitutes OSHA’s interpretation of the requirements discussed. Note that our
enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our
guidance in response to new information. To keep apprised of such developments, you can consult OSHA’s
website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of
Health Enforcement at (202) 693-2190.
Sincerely,
Richard E. Fairfax, Director
Directorate of Enforcement Programs
CC: Greg O’Claray, Commissioner
Alaska Department of Labor and Workforce Development
[Corrected 2/27/2004]
3/14 HAZWOPER–175

1910.120 Application to Petroleum Product Spills or Releases

Subject to State Codes
Standard Number: 1910.120
July 17, 1991
Mr. Lawrence M. Sontoski
Radian Corporation
5103 W. Beloit Road
Milwaukee, Wisconsin 53214
Dear Mr. Sontoski:
This is an updated response to your request to Mr. Gerald Cunningham for interpretations of
OSHA’s Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120.
You raised several issues and questions which will be answered in the same order as your
presentation.
First, it is important to clarify some main issues which will aid in your understanding of this standard.
As you probably know, the standard covers three main activities outlined in the scope paragraph:
cleanup site activity; treatment, storage and disposal (TSD) activities; and emergency response
without regard to location. You have directed your questions to petroleum product spills or releases
subject to cleanup under state codes. In order to properly answer your questions we will refer to
various parts of the 1910.120 standard.
In addition, you make reference to cleanup activities under state codes. We can only address
Federal OSHA standards and not any state regulations. However, the 1910.120 standard in the
scope paragraph does reference cleanup operations required by a governmental body which
includes Federal, state, local or other.
You also state that petroleum products are not regulated under RCRA regulations but are covered
by the state. There are specific RCRA regulations which cover petroleum products in underground
storage tanks. These activities may be covered under 1910.120 if they include activity referenced
in 1910.120(a)(1)(i-iii). Petroleum products are covered under 1910.120 under the definition of
“hazardous substance” which references hazardous materials under United States Department of
Transportation’s Regulation 49 CFR 172.101 where petroleum products are listed.
1. What in OSHA’s eyes defines a spill/release?
There are no specific answers to this question because there are too many variables. Individual
employers must assess the hazardous substances in their facility based upon anticipated expo-
sures during an emergency. The criteria for coverage includes toxicity, inhalation, skin absorption,
ingestion, flammability, explosiveness and its reactivity with other substances and the surrounding
environment. An emergency could exist as a result of a spill or release of a small amount of a highly
toxic or explosive substance or a large amount of a less toxic substance.
2. What amount of hazardous chemical/petroleum product would be the minimum classed as a
spill?
There is no specific answer for this question. Please refer to the answer to question 1.
3. What level of training under 1910.120 or other applicable sections is required for:
Your questions refer to several parts of the OSHA 1910.120 standard. There are separate training
requirements in each of the three sections previously discussed in this letter.
176–HAZWOPER 3/14

If there is a hazardous waste site cleanup activity going on, there are 40-hour training or 24-hour
training requirements. The 40-hour training is for workers engaged in hazardous substance
removal or other activities which expose or potentially expose workers to health hazards. The
24-hour training is for workers who are unlikely to be exposed to concentrations above permissible
exposure limits and/or published exposure limits. Both categories of employee are required to have
8 hours of refresher training a year. The employer must decide, based upon work activity, how many
hours of training are required.
Employees at RCRA permitted Treatment Storage and Disposal Facilities are required to have 24
hours of initial training and 8 hours of refresher training per year as described in paragraph (p) of
HAZWOPER.
Employees who are expected to respond in the event of an emergency resulting from the release
of a hazardous substance must meet the requirements outlined in paragraph (q). This paragraph
describes five levels of training requirements for five distinct levels of emergency response activity
and responsibility.
Employees involved in post-emergency response work, i.e. cleaning up a spill which no longer
requires an emergency response, are discussed in paragraph (q)(11), which refers back to para-
graphs (b) through (o). These paragraphs require the training hours discussed above pertaining to
cleanup activities. If the cleanup is done on plant property using plant employees, then the required
training must include 29 CFR 1910.38(a) — Emergency Action Plan; 1910.134 — Respiratory
Protection; 1910.1200 — Hazard Communication Standard and other safety and health training as
required by the tasks to be performed. Attachment C, the OSHA Instruction CPL 2-2.51, provides
further information on training requirements for employees involved in post-emergency response
operations.
It is unclear from your letter to which category of employee you are referring. You speak of
“spill/release sites” which could refer to hazardous waste site remediation or emergency response
to the release of a hazardous substance. Therefore we have answered the questions that follow in
two parts. The first response assumes that the described scenario is an emergency response to the
spill or release of a hazardous substance. The second part of the answer assumes that you are
referring to the characterization and remediation of an uncontrolled hazardous waste site.
3a. Individual identifying the spill:
If we are discussing an individual involved in an emergency response, they would be required to
have had at least first responder awareness level training. This level of training as described in
1910.120(q)(6)(i) has no minimum number of training hours required.
If this scenario is referring to identification of an uncontrolled hazardous waste site then the
procedures to be followed are covered in 1910.120(c) and the training requirements of 40 hours
and three days of supervised field experience are discussed in 1910.120(e).
3b. Individual characterizing the spill site:
If this is an emergency response at a spill site the level of training depends on the job duties and
responsibilities of the individual during the emergency. For emergencies, personnel roles and
training are to be part of the emergency response plan. If the individual characterizing the spill site
is expected to enter the danger area then they would be required to have hazardous material
technician level training as described in 1910.120(q)(6)(iii).
If the individual described above is characterizing an uncontrolled hazardous waste site, then they
would be required to have 40 hours of training and three days of supervised field experience as
described in 1910.120(e).
3c. Individual directing cleanup activity:
During an emergency response this could be the Incident Commander (1910.120(q)(6)(v)) position
requiring 24 hours of Level 2 training (First Responder Operations) and demonstration of additional
competencies.
3/14 HAZWOPER–177

On a cleanup site the required training for “management and supervisors” is 40 hours initial, 24
hours supervised field experience, and at least 8 hours specialized training.
3d. Individual sampling the spill site:
For emergency response activity, please refer to answer to 3b.
For the individual working at a hazardous waste site, the level of training required depends on
exposure or potential exposure to hazardous substances. Either 40 hours, with three days of
supervised field experience or 24 hours with one day of supervised field experience would be
required.
3e. Individual non-intrusively identifying underground/overhead utility or private industry transmis-
sion lines at the spill site:
See answer to 3d.
3f. Surveyors on site to determine property lines, boring locations and monitoring well locations:
See answer to 3d.
3g. Individual operating soil boring equipment to identify extent of spill:
See answer to 3d.
3h. Individual operating an excavation piece of equipment removing contaminated soils or water:
During an emergency response, these workers may be classified as “Skilled Support Personnel” as
described in (1910.120(q)(4).
Workers at hazardous waste site clean-up operations would require 40 hours of training, with three
days of supervised field experience.
3i. Truck driver hauling “special waste” to a landfill:
OSHA and EPA do not use the term “special waste”. If this term meets the definition in 1910.120
of a hazardous substance then the training requirements would depend on the nature of the work
of the truck driver at both ends of the trip. If the truck driver does not leave the vehicle and is not
exposed to the hazardous substance at either end of the trip, this work would not be covered under
this standard. If the driver has a potential for exposure to the hazardous substances during the
loading or unloading, the training requirements would be the same as those for other workers with
a similar exposure to hazards, i.e., 40 hours with 24 hours of supervised field experience or 24
hours with 1 day of supervised field experience.
During an emergency response, this worker may need training under 1910.120(q) depending on
whether the driver becomes actively involved in the response.
If the “special waste” is not considered hazardous waste, Hazard Communication Standard training
may also be required if the truck drivers come under the jurisdiction of Federal OSHA.
3j. Landfill equipment operators receiving the “special waste” at an approved landfill:
If this landfill comes under the scope of the standard as a TSDF, the workers would be required to
receive the 24 hours of training as described in 1910.120(p)(7).
3k. State, local and federal inspectors visiting the spill site:
If this is an emergency response, the inspectors could be considered “Specialist Employees”
requiring annual training in their specialization.
If this is a cleanup site, these workers would be required to have 40 hours or 24 hours of training
again depending upon their level of exposure to the hazards.
3l. The property owner:
Again if this is an emergency response, it would depend upon the function being performed by this
person, i.e., 1910.120(q)(4),(5) or (6).
178–HAZWOPER 3/14

If this is a cleanup site the training would be 40 hours or 24 hours depending upon the level of this
person’s activity and exposure to hazards.
All of the workers addressed in question 3 are required to receive annual refresher training in
accordance with their job duties as described in 1910.120.
4. Would a release from an underground storage tank that has occurred over an extended time then
detected when tank removal is done be classed as a hazardous waste site, a spill site, or a
non-hazardous release?
The answer to this question depends upon the designation of this site as a clean-up operation
involving hazardous substances by a governmental bodies. In general if the site is part of a
corrective action, it would be considered a cleanup activity and compliance must be met with
paragraphs (b)-(o). Therefore workers engaged in remediation of releases of hazardous sub-
stances from leaking underground storage tanks would be expected to meet the training
requirements described in 1910.120(e).
4a. Would this classification be true for: waste motor oil, diesel fuel, gasoline and xylene?
Yes, the same answer would apply. We must refer back to the definition of “hazardous substance”
in the standard and as stated earlier in the introductory paragraphs of this letter. All of these
substances would meet this definition and therefore be covered.
4b. Which of these products would OSHA feel represents an exposure health hazard?
All of these products could present a health hazard to workers depending upon their exposure to
the substance. This would include inhalation, ingestion and skin hazards and all other accompa-
nying safety hazards.
If you find you need further clarification of this letter please contact MaryAnn Garrahan of my staff
at (202) 523-8036.
Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs
3/14 HAZWOPER–179

Fires Involving Spills or Releases of Hazardous Substances

Standard Number: 1910.120
June 17, 1991
MEMORANDUM FOR: MICHAEL G. CONNORS
REGIONAL ADMINISTRATOR
THROUGH: LEO CAREY, DIRECTOR
OFFICE OF FIELD PROGRAMS
FROM: PATRICIA K. CLARK, DIRECTOR
DIRECTORATE OF HEALTH COMPLIANCE PROGRAMS
SUBJECT: Interpretations of 29 CFR 1910.120
This is in response to your inquiry of February 5, concerning paragraph (q) of the Hazardous Waste
Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for
the delay in this reply.
The first scenario described in your memo, the coal fire at a public utility, does fall under the scope
of 1910.120 as defined in paragraph (a). Fire involving spills or releases of substances which
before combustion were defined as a hazardous substance are covered by paragraph (q) of
1910.120. Coal is listed as a hazardous material by the Department of Transportation under 49
CFR 172.101. Conversely, fires involving spills or releases of substances not classified as haz-
ardous substances before combustion are not included in the scope of 1910.120. Similarly,
structural fires, houses, wood etc. burning would not normally be covered by 1910.120.
The second scenario described in your memo, the ammonia leak at a local food processing facility,
would fall under 1910.120 paragraph (q). The contractor activity you described appears to be part
of the emergency response to the leak and could be required that these personnel be given an
initial briefing at the site prior to their participation in any emergency response. The initial briefing
shall include instruction in the wearing of appropriate personal protective equipment, what chemical
hazards are involved, and what duties are to be performed.
In general, the “on scene incident commander” of the emergency response is charged with deciding
when the emergency response is over. The Boggs letter, dated June 20, 1989, is current and
correct in its explanation of the distinction between an emergency response and a post emergency
response. An exception is during some National or Regional Response Team incidents where the
lead federal agency may remain in charge during the entire post emergency clean up phase. Post
emergency response begins when the immediate threat of a release has been stabilized or elimi-
nated and clean up of the site has begun. OSHA concurs with your assessment that the contractors
in the ammonia leak emergency were involved in emergency response activity.
We hope this information is helpful. If you have any further questions please feel free to contact us
at (202) 523-8036.
February 5, 1991
MEMORANDUM FOR: Patricia K. Clark
Director
THROUGH: Leo Carey
Director
Office of Field Programs
180–HAZWOPER 3/14

FROM: Michael G. Connors

Regional Administrator
SUBJECT:
Interpretations of 29 CFR 1910.120
Several questions continue to arise concerning the HAZWOPER standard, in particular paragraph
(q) on emergency response. This memo is requesting answers to questions which have come to
our attention via contested cases and which are enumerated below.
1. In our first case a fire occurred at a public utility plant where large amounts of coal continued to
burn through the day. Both the Fire Department and utility employees were involved in fighting the
fire. Combustion products of burning coal may include carbon monoxide, hydrogen sulfide, meth-
ane, coal dust, carbon dioxide, and acrolein. Would this fire constitute an “emergency” as defined
in 1910.120? Specifically, does combustion equal “an uncontrolled release of a hazardous sub-
stance”? Also, in general, what fires (structural vs. chemical) would be considered an emergency
response under 1910.120, provided all the criteria in the definition of emergency response were
met?
2. In our second case an ammonia leak occurred in the refrigeration system at a vegetable
processing plant. Specifically, a liquid refrigerant return line valve separated from a pipe in the
ammonia compressor room. The Fire Department responded by turning off some valves and
plugging the leak.
Fans were set up to ventilate the area and water was sprayed on the floor to reduce ammonia
vapors. The employer called in their refrigeration contractor, who was very familiar with the plant
system, for assistance during the ammonia leak. When the contractor arrived, the Fire Department
had already plugged the leak and vented the area. This was at least 1/2 hour after the Fire
Department arrived. Ammonia sensors set at 100 ppm were operating in the plant and the alarms
had sounded. No other air monitoring was conducted during the leak to determine air concentra-
tions of ammonia. The firefighters wore totally-encapsulating suits and SCBA’s during this
emergency.
The contractor advised that more valves needed to be shut off to prevent residual bleeding of
ammonia and pressurization of the plug. The contractor employees stuck their heads into the
compressor room, which is where the plug was placed. They also worked on some pipes which
were sixty feet away form the plugged leak. The Fire Department allowed the contractor employees
into the plant as they considered the contractor knowledgeable of the system and associated
hazards.
The contractor does not consider themselves emergency responders although they stated in the
past they have participated in emergency response activity. They felt the Fire Department had
secured the area and that their role was to correct a condition so it does not happen again, close
valves to isolate the area, and get the plant back in operation. They stated they were not part of the
emergency response.
Our questions relating to these circumstances are:
a. Is the contractor activity considered part of the emergency response, or the post-emergency
response? There was no determination that the emergency was considered over by the Fire
Department, HAZMAT team, plant management, or any other party.
b. Who determines when the emergency no longer exists? A letter from your office to Richard F.
Boggs, Ph.D., dated June 20, 1989 (copy attached — see question #2) discussing this issue would
imply that the contractors in our example engaged in emergency response activity. Is the informa-
tion in the Boggs letter current?
We would appreciate prompt answers to our questions as they refer to pending contested cases.
If you need additional information, please contact Cynthia Weaver in our Technical Support Unit at
FTS 353-2220.
3/14 HAZWOPER–181

Attachment
July 28, 1989
Richard F. Boggs, Ph.D
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place N.W.
Washington, D.C. 20036
Dear Dr. Boggs:
This is in response to your inquiry requesting interpretations of OSHA’s final standard for Hazard-
ous Waste Operations and Emergency Response (29 CFR 1910.120).
For the sake of clarity, I will enumerate and respond to your questions in the order you raised them:
1. Generic Plans for Post-Emergency Operations.
We concur with your understanding that it is permissible to develop generic plans for post-
emergency clean-up operations. This would be a plan addressing appropriate elements of
paragraphs (b)-(o), which can be filled in with specific details when an event occurs. It is possible
that some of the elements of (b)-(o) will not be necessary at a particular workplace and others will
have limited applicability. For example, if there are no confined space entry situations or potential
situations then confined space entry procedures do not need to be addressed.
2. Distinction Between Emergency and Post-Emergency Operations.
As long as an emergency response team is still in control of the site and a safety or health hazard
exits, the emergency situation continues to be in effect. For example, if a vacuum truck arrives to
remove spilled gasoline while an emergency response team is managing the activity, the vacuum
truck operator’s activity is part of the emergency response operations. Once the emergency
response team has declared the response activity over or finished and has left the site, any
remaining cleanup would be considered a post-emergency operation.
3. When the Standard Applies.
a. “Emergency Situation” Responses to releases when there are no potential safety or health
hazard are not considered emergency responses even if an alarm is sounded. Team responses to
releases where there are potential safety and health hazards are not considered “emergency
responses” under 29 CFR 1910.120 when the team does not take control of the site (i.e., the
substances can be absorbed, neutralized, or otherwise controlled by employees in the immediate
release area).
b. “Immediate Release Area” For the purposes of 29 CFR 1910.120 “immediate release area” is a
term used in the definition of emergency response to help clarify when an incident is an emergency.
Incidental spills that could be cleaned-up or stabilized by the employees working in the immediate
spill area without the need of a coordinated spill-control response is not considered an emergency
incident. Such employees would have training under the Hazard Communication Standard and
other appropriate training made necessary by the tasks they are expected to perform.
The term “immediate release area” is not meant to either classify something as an emergency if
immediate attention is not warranted, or encourage employees in the immediate work area to
respond to incidental releases without the proper training and equipment.
The “immediate release area” can be the entire geographic boundary of the employee’s assigned
work area. On a case-by-case basis OSHA will determine whether such employees are capable of
responding to incidental releases and will evaluate the emergency response plan, including an
evacuation plan, if an emergency situation is possible.
Maintenance personnel responding to releases or potential releases for the purpose of stopping the
leak are performing emergency response activities under the rule unless the upset condition:
(1.) Results from routine maintenance activity and the small leak can be readily repaired; or
182–HAZWOPER 3/14

(2.) Does not need to be taken care of immediately. That is, the safety and health of the employees
are not threatened if immediate response is not initiated.
c. “General Application” In general, the standard applies to all operations described in the scope (29
CFR 1910.120 (a)) unless the employer can demonstrate that the operation does not involve
employee exposure or the reasonable possibility for employee exposure to safety or health
hazards. Thus, if potential for exposure is extremely unlikely the standard would not apply. The term
“exposure” here has the same definition as in the Hazard Communication Standard.
4. Safety and Health Plan for Multi-Employer Worksite.
Each contractor/subcontractor is responsible for compliance with all safety and health protection
requirements for their employees. An employer’s safety and health plan can be used by
contractors/subcontractors at the site if it appropriately addresses their activity and potential safety
and health hazards. In general, a site plan organized as a single document, with component
sections/appendices covering all tasks, operations, and contractors/subcontractors, may promote
use efficiency; enhance completeness, clarity and coordination among all affected parties.
5. Training Requirements.
The interim final rule does not have a provision regarding training of less than 40 hours for
employees involved in activities at cleanup sites. Prior to the publication of the final rule, OSHA has
stated that for non-cleanup activities at designated cleanup sites the determination of the amount
of training necessary for the workers to safely perform their job duties will be made on a case-by-
case basis. As you are aware, the final standard addresses the issue of when less than 40 hours
of training may be appropriate. It does not, however, provide for less than 24 hours of training.
In general, OSHA will be enforcing the need for a minimum of 24 hours of training regardless of the
nature of the job. There may be isolated cases where OSHA’s variance procedures may be
appropriate or where OSHA would determine that a situation warrants a de minimis violation. (Note:
Depending on the job duties of the workers involved in emergency response, less than 24 hours of
training is allowable under the standard.)
6. Employee Classification.
You mentioned that in many cases companies have a specialist trained and expert in, for example,
tank truck accidents. When an emergency arises, this individual could be called on to provide
guidance and technical assistance. Such an employee would be considered a “specialist
employee” under 29 CFR 1910.120(q)(5) and must receive training or demonstrate competency in
the area of their specialization annually.
7. Training Requirements for Management Personnel.
Management personnel who during an emergency situation stay out of the hazardous area and
who are not taking charge of the incident, and are not a specialist employee under 29 CFR
1910.120(q)(5) are not covered by 29 CFR 1910.120.
8. Marine Operations.
OSHA does not apply its standards to seamen performing work on vessels which have been
inspected and certificated by the U.S. Coast Guard (“inspected vessels”) because the Coast Guard
has issued comprehensive standards regulating the safety and health of these workers. OSHA has
recognized the Coast Guard’s jurisdiction over inspected vessels in a Memorandum of Under-
standing between the two agencies. The Coast Guard has also issued some standards affecting
the safety of seamen on uninspected vessels. OSHA would apply its standards to any working
conditions not addressed by the Coast Guard.
With these exceptions, OSHA has jurisdiction for seamen aboard vessels located on the waters
within the three-mile limit, or in the case of Florida and Texas, within the limit of three marine
leagues (the territorial waters). OSHA also has jurisdiction for workers performing work on shore or
at other locations not aboard a vessel but within the territorial waters of the U.S. OSHA does not
have jurisdiction over vessels outside the territorial waters.
3/14 HAZWOPER–183

9. Covered Substances and Situations.

Example 1.
10,000 lbs of sodium saccharin (artificial sweetener) are spilled from a silo across a plant fence line
into a stream bed. About 4000 lbs reach the water. As a CERCLA Hazardous Substance released
above its Reportable Quantity (one pound) the release is reported to the National Response
Center, which in turn notifies the predesignated Federal On-Scene Coordinator (OSC). The OSC
responds to evaluate the situation and monitors the proper clean up of the sodium saccharin by the
plant owner/operator. What portions of the final rule apply?
Answer: Sections (b) through (o) of the rule are applicable for sites where a Federal OSC is
overlooking the cleanup unless the employer can demonstrate that the operation does not involve
employee exposure or the reasonable possibility for employee exposure to safety or health
hazards.
Example 2.
A company manufacturers ammonium nitrate fertilizer, which is listed and regulated in 49 CFR
172.101 as an Oxidizer. A fire occurs in a corner of the warehouse and is extinguished by a local
fire department. Would the subsequent removal of the ammonium nitrate from the warehouse by
employees of the company be covered by the final rule as a post-emergency response operation?
Answer: A hazard would still be present thus the post-emergency response provisions of the rule
would be applicable.
I hope these responses sufficiently address the concerns you raised. If I can be of further assis-
tance, please feel free to contact me again or Ms. MaryAnn Garrahan of the Office of Health
Compliance Assistance at (202) 523-8036.
Sincerely,
Patricia K. Clark, Acting Director
May 18, 1989
MS. Patricia Clark
Acting Director
Directorate of Compliance Programming
Occupational Safety and Health Administration
U. S. Department of Labor
Room N-3603
200 Constitution Avenue, N. W.
Washington, D.C. 20210
Dear Ms. Clark:
We thank you for making Mary Ann Garrahan available to meet with the Organization Resources
Counselors (ORC) Hazardous Waste and Emergency Response Task Force on April 19, 1989 to
discuss important issues regarding interpretation of OSHA’s final standard for Hazardous Waste
Operations and Emergency Response (published March 6, 1989).
This regulation will affect greatly the hazardous waste and emergency response activities in all
industries. ORC encourages OSHA to develop a comprehensive compliance directive for this rule
so that its compliance officers will be able to enforce it consistently among all industries. In addition,
compliance directives are useful to industry as well.
In order for employers to develop and implement effective compliance programs, it is essential that
they have a clear understanding of the requirements of the Standard. We would appreciate your
comments on the assumptions ORC members are currently using to develop their programs, and
your response to questions of interpretation.
184–HAZWOPER 3/14

1. Generic Plans for Post-Emergency Operations

Paragraph (q)(11) of the Standard addresses “Post Emergency Response Operations.” In the event
of a hazardous substance release resulting in emergency response activities and post emergency
response operations, there is a potential threat to the environment as well as to employees.
Because of this, time is of the essence in eliminating the source of, and containing the environ-
mental contamination. Preparation of the lengthy site-specific plan required by paragraphs (b)-(o)
would take considerable time and resources. Therefore, OSHA should make it clear that it is
permissible for employers to develop a “generic plan” for post-emergency clean-up operations. This
would be a detailed plan addressing appropriate elements of paragraphs (b)-(o), which can be filled
in with specifics when an event occurs. Since these types of operations are not as extensive as
those at hazardous waste sites, it is likely that some elements of (b)-(o) will not be necessary at a
particular workplace and others will have only limited applicability. Inspectors should therefore not
cite employers for including only relevant elements of (b)-(o) in a particular plan.
2. Distinction Between Emergency and Post Emergency Operations
There has been considerable discussion about when an emergency ends and when post-
emergency operations commence. Since the requirements for post-emergency operations are far
more detailed, it is important for employers to understand where the line will be drawn.
It is ORC’s understanding that as long as an emergency response team is still on site, and a safety
or health hazard exists, the emergency situation continues to be in effect. For example, if a vacuum
truck arrives to remove spilled gasoline while an emergency response team is managing the
activity, the vacuum truck operator’s activity is part of the emergency response operations. Once
the emergency response team has left the site, any remaining clean-up would be considered a
post-emergency operation. We would appreciate your confirming this understanding.
3. When the Standard Applies
a. “Emergency Situation”
Most ORC member companies use the conservative approach of instructing operating employees
to sound the alarm as soon as a potential emergency situation arises, before proceeding to stop the
release or take other appropriate action. In many cases, the operating employees are able to
handle the situation, so that no “actual emergency” exists.
ORC understands that in those situations, the requirements of the Standard are not applicable.
Does OSHA agree with this interpretation?
Similarly, do the requirements of the standard apply to situations in which employees are actually
exposed to hazardous substances, where there is potential for exposure, or where a hazardous
substance is merely “present,” as in the Hazard Communication Standard?
ORC understands that the standard applies when there is either actual or potential exposure to
hazardous substances. However, if the potential is extremely unlikely (e.g., contaminated soil is
present eight feet below the surface, but no employee is disturbing it), there is no emergency or
post-emergency response, and it is reasonable that the standard would not apply. Are we correct
in this interpretation?
b. “Immediate Work Area”
There is a question about what situations trigger employer compliance with the requirement of the
Standard. In the proposed rule, if employees were called from outside their normal work area to
respond to an emergency, and they were exposed to a hazardous substance above the PEL they
were covered by the Standard.
In the final rule, no such clear-cut, quantifiable criteria exist for application of the rule. Although the
definition of “emergency response” or “responding to emergencies” is provided, there remains
some question about what is an “immediate work area” and how OSHA will determine that an
employee is outside his or her immediate work area.
3/14 HAZWOPER–185

ORC understands that production or maintenance employees are considered as responding to

releases within their “immediate work area” when they are within the geographic boundary of their
assigned work area, and have the knowledge and necessary personal protective equipment avail-
able so that they are able to stop a release, by performing a task such as turning a valve in a leaking
line; such employees need not be within a few feet or within site of the release when it occurs as
long as they are in their assigned work area. These employees would have been trained in hazard
communication and standard operating procedures for their area, and would not necessarily be
designated emergency responders at the level of hazardous materials technician or higher.
Such releases may warrant evacuation of personnel not working to contain or control the release,
in accordance with 1910.38, but the responses to the releases would not require activation of the
Incident Command System and possibly post emergency response operations in accordance with
1910.120. For releases that are of such a nature that their severity could escalate (such as leaks
in liquid anhydrous ammonia or liquid chlorine lines), the designated emergency responders could
be put on “standby” or could actually be called to the site in anticipation of a full “emergency
response operation.” This approach for responding to releases could apply to facilities that only
have emergency plans in accordance with 1910.38, choosing to have an outside agency respond
to releases beyond their knowledge and ability to control. Is ORC correct in its interpretation of
“immediate work area” for production or maintenance employees?
4. Preparation for Meeting Requirements of Paragraphs (b)-(o)
For hazardous waste sites, detailed plans must be developed to comply with requirements or
paragraphs (b)-(o) of the Standard. In those cases in which a contractor has developed such a
detailed plan, and one or two employees from another company are present at the location, ORC
understands that these individuals would be covered by the contractor’s plan, even though they are
not employees of the contractor. At major Superfund sites, where many employers may be repre-
sented, this would eliminate the problem of overlapping, redundant, and potentially contradicting
plans. This should be specifically addressed as a “multi-employer work site” issue.
5. Training Requirements
ORC understands that OSHA will adopt a case-by-case approach to determine whether employers
have complied with the training requirements. For example, if an employee is cleaning up a single
substance or a limited number of substances at a RCRA or CERCLA facility, it may not take a full
40 hours of training for him or her to be adequately trained. ORC understands that OSHA inspec-
tors will be able to look at the task being performed by the employee (e.g., PCB removal) and
determine whether the full 40 hours of training was necessary before issuing a citation. In addition,
the 24 hour training requirement may be excessive for emergency response training for a single
substance or process. We suggest that guidance be provided to compliance officers to undertake
this case-by-case approach.
6. Employee Classification
In many cases, companies have a specialist trained and expert in, for example tank truck accidents.
When an emergency arises, this individual would be called on to provide guidance and technical
assistance. ORC assumes that this individual would not need additional training.
7. Training Requirements for Management Personnel
In some cases, management staff are present at a location (either hazardous waste site or location
of emergency response operations), and they are not actually engaging in any emergency
response operation, other than providing corporate oversight and administrative support to the
incident commander. If these personnel are serving in such an oversight or administrative capacity,
ORC believes that 24 hours of training is not necessary. Are we correct?
8. Marine Operations
If there is a large spill of petroleum or petroleum products in U.S. territorial waters or beyond U.S.
territorial waters, does the standard apply? Or do Mineral Management Service of the U.S. Depart-
ment of Interior and U.S. Coast Guard regulations govern?
186–HAZWOPER 3/14

9. What are Covered Substances and Situations?

Example 1. 10,000 lbs of sodium saccharin (artificial sweetener) are spilled from a silo across a
plant fence line into a stream bed. About 4000 lbs reach the water. As a CERCLA Hazardous
Substance released above its Reportable Quantity (one pound) the release is reported to the
National Response Center, which in turn notifies the predesignated Federal On-Scene Coordinator
(OSC) The OSC responds to evaluate the situation and monitors the proper clean up of the sodium
saccharin by the plant owner/operator. What portions of the final rule apply?
Example 2. A company manufactures ammonium nitrate fertilizer, which is listed and regulated in
49 CFR 172.101 as an Oxidizer. A fire occurs in a corner of the warehouse and is extinguished by
a local fire department. Would the subsequent removal of the ammonium nitrate from the ware-
house by employees of the company be covered by the final rule as a post emergency response
operation?
Should you or your staff require further information or expansion of the issues we have raised, we
would be pleased to meet with you at your convenience. ORC and its member companies look
forward to your response.
Sincerely,
Richard F. Boggs, Ph.D.
Vice President
Considerations for “Incidental” Spills Cleaned up by Maintenance

Personnel to Satisfy the Definition of “Emergency Response”
Standard Number: 1910.120(a)(3)
July 31, 1990
Mr. Terry A. Noteboom
Environmental Engineer
Rockwell International Avionics Group
400 Collins Road N.E.
Cedar Rapids, Iowa 52498
Dear Mr. Noteboom,
This is in response to your letter of April 12 requesting clarifications of the Occupational Safety and
Health Administration (OSHA) standard for Hazardous Waste Operations and Emergency
Response (29 CFR 1910.120). Please accept my apology for the delay in this reply.
You mentioned that the definition section under emergency response appears to exempt “inciden-
tal” spills cleaned up by maintenance personnel. The intent is that spills without emergency
consequences are not covered by the emergency response provisions of this standard. As you may
be aware, the quantity of product spilled does not by itself determine if an incidental spill has
occurred. Several variables, including the volume of the spill, must be considered in evaluating the
hazard of the release to employees. Examples of other variables include the type of material spilled
and the location of the spill. Other OSHA standards such as the Hazard Communication Standard
(29 CFR 1910.1200) would be applicable for incidental spills.
3/14 HAZWOPER–187

For the definition of “emergency response” to be satisfied:

1. The release or situation must pose an emergency. Examples are: it may cause high levels of
exposures to toxic substances, it is life or injury threatening, employees must evacuate the area,
it poses IDLH conditions, it poses a fire and explosion hazard (exceeds or has potential to exceed
25% of the LEL), it requires immediate attention because of danger, or presents an oxygen deficient
condition. Nuisance spills, minor releases, etc., which do not require immediate attention (due to
danger to employees) are not considered emergencies.
2. An ordinary spill that can be safely handled by the workers is not an emergency. Such employees
must have the proper equipment and training under other OSHA standards such as the Hazard
Communication Standard.
The training requirements for employees responding to control a spill which could result in an
emergency situation are outlined in section (q)(6) of the standard. The amount of training specified
is based on the duties and functions to be performed by each responder. The requirements for
post-emergency clean-ups are set forth in (q)(11) of the standard.
Where applicable, all employees involved in an emergency response must be trained under 29
CFR 1910.120. Thus, your options are to ensure employees are adequately trained to respond or
use emergency response contractors for small and large spills and provide an emergency action
plan in accordance with [29 CFR 1910.38]. To further assist you with the training requirements
under this standard, I have enclosed a copy of the following OSHA article, “Hazardous Waste
Operations and Emergency Response: A Closeup Look at Training.”
I hope this information is helpful.
Sincerely,
Patricia K. Clark, Director Designate
[Directorate of Enforcement Programs]
Enclosure
(Correction 2/10/2003)
188–HAZWOPER 3/14

HAZARDOUS WASTE OPERATIONS AND EMERGENCY RESPONSE:

A CLOSEUP LOOK AT TRAINING
By T.H. Seymour, P.E.
On March 6, 1989, OSHA promulgated a final rule on Hazardous Waste Operations and Emer-
gency Response (29 CFR Part 1910). The rule, which will take effect on March 6, 1990, is a direct
result of the Superfund Amendments and Reauthorization Act of 1986 (SARA).
SARA (42 USC 9601, Titles I-IV) set the nation on a path toward better preparedness in dealing with
emergencies involving the release of hazardous substances. The law also strengthened the
nation’s efforts to clean up hazardous waste and deal with other issues on hazardous chemicals.
SARA required OSHA to develop interim1 and final rules, and Congress identified specific criteria
for the agency to follow in establishing regulations for hazardous waste operations and emergency
response activities.
For example, Title I of SARA specifies safety and health requirements for employers and Title III
deals with local community emergency response plans. These two sections are examined here with
respect to the OSHA standard and, in particular, their training requirements. The training require-
ments are significant because this is the first time that OSHA has mandated a specific number of
training hours in a final rule.
Title I, Section 126 of SARA required OSHA to develop a standard that would set minimum safety
and health requirements for (1) employers in hazardous waste or substance clean-up activities at
government identified sites2; (2) employers involved in storing, treating, or disposing of hazardous
waste; and (3) employers involved in emergency response to the release of hazardous substances.
SARA required that the OSHA standards include, at a minimum, the following areas: site analysis,
training, medical surveillance, protective equipment, engineering controls, maximum exposure
limits, information, hazardous waste handling, new technologies, decontamination procedures, and
emergency response.
Although each of these issues is important in protecting workers, the purpose of this article is to
examine, in some detail, the training requirements of the final rule for each of the three categories
of employers covered.
_________________
1
See Federal Register 51:4564, December 19, 1986.
2
Examples include the National Priority List of sites as well as those listed by other federal
agencies and by state or local governments.
Hazardous Waste Cleanup Operations
Paragraph (e) of the standard establishes the initial training requirements for employees and
supervisors who are or will be involved in hazardous waste/substance cleanup operations at
government-identified sites.
The training requirements are organized in a tiered arrangement (see Table 1). In the first tier are
employees and supervisors who remove or excavate hazardous substances at the site. For
example, this category includes laborers, operating engineers and their supervisors.
Before beginning work, these individuals must have 40 hours of training offsite and then 24 hours
of on-the-job training with a trained and experienced supervisor. All supervisors who will be working
in these operations must have eight additional hours of specialized training in managing hazardous
waste operations.
The required training for supervisors concerns safety and health issues, such as the supervisor’s
role and responsibilities in the employer’s safety and health program, the medical surveillance
program, and the training program.
3/14 HAZWOPER–189

The second tier sets forth the criteria for training employees who are on-site only occasionally to
do a specific job (paragraph (e)(3)(ii)). For example, this would cover employees surveying the
perimeter of a site to make a plat or to mark boundaries.
Workers who are on-site for short periods, and thus are unlikely to be exposed above any per-
missible exposure limit (PEL), are required to have a minimum of 24 hours of training off-site and
then 8 hours of on-the-job training on-site by a trained and experienced supervisor.
Likewise, paragraph (e)(3)(iii) covers workers who will be on-site on a more regular basis, but who
do not risk exposure above the PELs or to any other health hazard and are not subjected to the
possibility of an emergency situation.
For example, such individuals might include those involved in the final work activities in completing
a closure operation on a site before it is removed from the government list.
These workers are required to have 24 hours of training off-site, and then 8 hours of on-the-job
training by a trained and experienced supervisor. In either case, the required training is to be taken
before employees may perform their regular job duties without close supervision.
Supervisors or managers who work at cleanup sites must receive eight hours of training beyond the
initial basic training requirements. This additional training includes areas such as their employer’s
occupational safety and health program and their role in the program.
Workers and supervisors at all three levels of exposure are also required to receive eight additional
hours of annual refresher training.
As appropriate, experienced incumbent employees may substitute prior training and experience for
initial training requirements in the same subject.
Treatment, Storage and Disposal Sites
The next group of employers covered are those who store hazardous waste on their premises for
more than 90 days, or are involved in treating or disposing of hazardous waste. These employers
are covered under paragraph (p) of the standard. The applicable training requirements for employ-
ees of these employers are in paragraphs (p)(7) and (p)(8)(iii). (See Table 2.) Initial training of at
least 24 hours is mandatory for all new employees in this category. The training is expected to cover
the employer’s safety and health program, medical surveillance, decontamination, emergency
response, hazard communication, new technology, and employee training, among others. The
initial training is to inform and instruct new employees about their assigned duties and any related
hazards and about their employer’s safety and health policies and procedures. Moreover, employ-
ees who may be involved in emergency response operations need additional training.
At any rate, all employees on the permitted site area are to be provided eight hours of refresher
training annually. Incumbent employees who are experienced and who have received training
before the standard takes effect may substitute their prior training, where appropriate.
Other Emergency Response Staff
Employers of emergency response personnel are covered by the training requirements of para-
graph (q) of the final rule. These employees respond from their typical work area to an emergency
where hazardous substances are released or may be released (see Table 3).
In promulgating these requirements, OSHA used the National Fire Protection Association’s Stan-
dard3 as a model. OSHA’s final rule also includes training criteria for the on-the-scene incident
commander, specialist employees and skilled support employees. These types of position classi-
fications were not included in the National Fire Protection Association Standard.
The OSHA standard establishes a continuum of training requirements for emergency responders,
progressing from the “first-responder awareness level,” at the lower, or first, level to the “hazardous
materials specialist” and “incident commander” at the higher, or fifth, level.
190–HAZWOPER 3/14

At the first-responder awareness level, the competency level of training is directed toward the
police, guard service personnel, night watchmen, emergency medical responders including ambu-
lance personnel, and others who are likely to discover or respond to emergency incidents involving
hazardous substances.4 The training is targeted at teaching employees to recognize the human
hazards present during these emergencies and how to protect themselves against such hazards.
The required training also includes how to accurately and fully report the necessary information to
an “alarm dispatcher” so that subsequent emergency responders are fully informed. Many first-
responder awareness training courses presently run from 4 to 12 hours, but the standard does not
set a mandatory minimum.
The next level of training is for “first-responder operations.” This is the level at which fire depart-
ments and fire brigade units typically operate. Such firefighting teams usually have complete
ensembles of firefighter protective clothing and positive-pressure respiratory protective equipment
available to them.
Eight hours of training is mandatory for the first-responder operations level, in addition to worker
competency at the first-responder awareness level. The required training is to prepare these
employees to perform diking, ditching, and similar activities of a defensive nature — activities
that do not require chemical protective clothing.
Where a fire occurs at the operations level, offensive actions may be taken to extinguish the fire
provided that no chemical protective clothing is required. For example, in the case of a liquified
petroleum gas fire, personnel at the first-responder operations level would work to shut off the
gas flow and extinguish the fire once it was determined that no other chemicals are present and
that offensive actions are required.
When these employees are expected to handle emergencies involving flammable liquids and
gases in an offensive mode, then additional training is necessary and a minimum of 24 hours of
training at the first-responder operations level is recommended. Such a 24-hour operations level
training course will prepare those wishing to move up to the technician level of the on-scene
commander level.
_________________
3
See NFPA Publication No. 472-1989, Standard for Professional Competence of Responders to
Hazardous Materials Incidents (Quincy, Massachusetts: NFPA, 1989).
4
Section 126 of SARA, paragraph (f), requires that the Environmental Protection Agency (EPA)
promulgate regulations to provide protection equal to that found in OSHA’s standard for state
and local government workers who would not be covered by OSHA-approved state plans. See
Worker Protection Standards for Hazardous Waste Operations and Emergency Response, 40
CFR Part 311, et seq., issued by the EPA on June 23, 1989. Also notice that EPA’s regulations
define covered employees as including “compensated or non-compensated worker[s] ... con-
trolled directly by State or local government” (40 CFR Part 311.2).
_________________
Next in the training hierarchy are the requirements for “hazardous materials technicians” and
“hazardous material specialists.” These are the employees OSHA expects to be used to staff
“hazardous materials teams” (Hazmat teams), spill control teams, and similar groups. Conse-
quently, these employees must have chemical protective clothing available for their use.
The skill requirements for the hazardous material technicians are somewhat lower than those for
the hazardous materials specialists. Hazardous materials technicians must have 24 hours of
training at the first-responder operations level in addition to the knowledge and skills training the
standard sets forth as necessary for these technicians.
The standard requires that hazardous materials technicians know, among other things, how to
implement the employer’s emergency response plan, how to properly select and use specialized
chemical personal protective equipment and clothing, and how to implement proper decontami-
nation procedures for hazardous substances.
3/14 HAZWOPER–191

The more skilled hazardous materials specialists will generally serve as the senior members of
hazmat teams. At this level are the most highly skilled and trained responders having the
broadest knowledge of hazardous substances.
The training required for a hazardous material specialist includes at least 24 hours of training at
the technician level and such additional training or experience as necessary to acquire the
knowledge and skills set forth in the standard.
The necessary skills and knowledge are to include, among other things, (1) how to implement
the emergency response portions of the local emergency response plan developed under SARA
Title III, (2) how to develop a site safety and control plan for hazardous substances emergency
incidents, (3) how to properly use and calibrate hazardous substance sampling instruments
(such as multiple organic vapor analyzers and the photoionization detectors), and (4) an under-
standing of the emergency response portions of the state emergency response plan developed
under SARA Title III.
The on-scene incident commander, or officer in charge of the overall operations at the scene of
an incident, should be a generalist with a broad knowledge of managing emergency incidents.
The commander level requires at least 24 hours of training at the first-responder operations
level, with additional training or experience in how to manage emergency incidents involving
At a minimum, the additional training is to include an understanding of (1) how to implement the
employer’s incident command system and the employer’s emergency response plan, (2) the
hazards and risks that are faced by responders working in chemical protective clothing, (3) how
to implement the relevant parts of the local emergency response plan created under SARA Title
III, and (4) the importance of following decontamination procedures.
Other categories of emergency responders identified in the standard include the “skilled support
person,” and “specialist employee.” Skilled support personnel are those who may occasionally
assist the incident commander by operating cranes, back hoes, or trucks. Since many of these
workers do not expect to help in such incidents and do not have even minimal awareness
training, attention must be given to their proper safety and health protection at the scene before
they participate in the incident. This can be accomplished by an on-site briefing that includes a
discussion of the hazards present, the personal protective clothing and equipment to be used,
how the equipment is used, and the exact task they are expected to perform.
The “specialist employee” is an expert who may assist, counsel, or advise the incident
commander. Specialist employees may provide technical assistance in operations such as
servicing specific valves on a tank car, or in similarly skilled areas, in addition to offering advice.
Specialist employees could also be medical or environmental experts.
Even though specialist employees are experts in their respective areas, they must be trained in
how to interact within the incident command structure, and how to follow the operating proce-
dures established by their employer. Their required training also is to inform them of the hazards
that may be present at an emergency site.
All emergency response personnel covered by paragraph (q) must receive refresher training, at
least annually, to ensure that their skills and competencies do not deteriorate and are not
forgotten. Training that expands the knowledge of emergency responders upward along the
continuum is acceptable to meet the annual refresher training requirements for the year during
which the training was received.
It should be mentioned that the OSHA interim final rule requires 24 hours of training annually for
emergency responders. The emergency responders who received training under the interim final
rule should be able to apply a good portion of that training towards meeting the requirements of
the final rule for their specific level of response.
For example, fire department or fire brigade members who received training at the first-
responder operations level under the interim final rule may use those training hours that are
relevant to their assigned duties to meet their obligations under the final rule. This is also true for
hazardous materials team members and on-scene incident commanders.
192–HAZWOPER 3/14

As a result, some additional training for experienced emergency responders may be necessary
to comply fully with the training requirements for their response level. Newly employed person-
nel, however, will need to comply fully with all the hours of training and related competencies for
the level of work they are expected to perform.
Summary
Title III of SARA, “The Emergency Planning and Community Right to Know Act of 1986,” focuses
on numerous issues that complement OSHA’s standard. This law prescribes in detail the efforts
to be made by states and local planning districts to develop and implement effective emergency
response plans for their communities. The planning efforts are now, and will continue to be, of
major significance in helping employers and emergency response organizations develop com-
plete, quality plans, and to utilize such plans effectively.
Local emergency response plans must include training schedules, and schedules for conducting
drills and exercises of the local district plans. Drills and exercises may be used, in part, to help
meet the annual refresher training requirements for covered employees.
As discussed above, OSHA’s hazardous waste standard requires that various responders be
trained according to their responsibilities so they are knowledgeable of local emergency
response plans, and are able to effectively implement the plan. These OSHA requirements and
those of Title III of SARA interact effectively and support each objective in achieving the ultimate
goals of ensuring the safety and health of emergency responders, as well as providing improved
coordination and protection for local communities.
Thomas Seymour is Deputy Director of OSHA’s Directorate of Safety Standards Programs.
Bibliography
Brunacini, Alan V. Fire Command. Quincy, Massachusetts: NFPA, 1985.
Brunacini, Alan V., and Beageron, J. David. Workbook for Fire Command. Quincy, Massachu-
setts, 1985.
Comprehensive Environmental Response, Compensation, and Liability Act of 1980. Public Law
96-510. 42 United States Code 9601. December 11, 1980.
Incident Command System. Fire Protection Publications. Stillwater, Oklahoma, Oklahoma State
University, 1983.
National Fire Protection Association. Standard for Professional Competence of Responders to
Hazardous Materials Incidents, NFPA No. 471-1989. Quincy, Massachusetts: NFPA, 1989.
Superfund Amendments and Reauthorization Act of 1986. Public Law 99-499. 42 United State
Codes 9601, Titles I-IV. October 17, 1986.
U.S. Environmental Protection Agency. Worker Protection Standards for Hazardous Waste
Operations and Emergency Response — Final Rule. 40 Code of Federal Regulations Part
311.2. In: Federal Register, Vol. 54, No. 120, Part IV. Washington, D.C.: Office of the Federal
Register, June 23, 1989. Pp 26654-62258.
U.S. Department of Health and Human Services. National Institute for Occupational Safety and
Health. Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities.
NIOSH/OSHA/USCG/EPA. Publication No. DHHS (NIOSH) 85-115. Washington, D.C.: U.S.
Government Printing Office, 1985.
U.S. Department of Labor. Occupational Safety and Health Administration. Hazardous Waste
Operations and Emergency Response — Final Rule. 29 Code of Federal Regulations Part
1910.120. In: Federal Register Vol. 54, No. 42, Part III. Washington, D.C.: Office of the Federal
Register, March 6, 1989,. Pp 9294-9336.
Operations and Emergency Response — Interim Final Rule. 29 Code of Federal Regulations
Part 1910.120. In: Federal Register, Vol. 51, No. 244, Part IV. Washington, D.C.: Office of the
Federal Register, December 16, 1986. Pp 45654-45675.
3/14 HAZWOPER–193

and Emergency Response. Publication No. OSHA 3114. Washington, D.C.: U.S. Government
Printing Office, 1989. .
U.S. Department of Transportation. Research and Special Programs Administration. Office of
Hazardous Materials Transportation. 1987 Emergency Response Guidebook. Publication No.
DOT P 5800.4. Washington, D.C.: USDOT, 1987.
Table 1. Training Requirements

Hazardous Waste Clean-Up Sites
Staff
• Routine site employees
❍ 40 hours initial
❍ 24 hours field*
❍ 8 hours annual refresher
❍ 24 hours initial (minimal exposure)
❍ 8 hours field*
• Non-routine site employees
❍ 8 hours field*
Supervisors/Managers of:
❍ 24 hours field*
❍ 8 hours hazardous waste management
❍ 40 hours initial (minimal exposure)
❍ 8 hours field*
• Non-routine site employees
❍ 8 hours field*
*Refers to on-the-job training.
Note: See 29 CFR 1910.120(e).
194–HAZWOPER 3/14

Table 2. Treatment, Storage, and Disposal Sites

Staff
• General permit site employees
❍ 24 hours initial or equivalent

• Emergency response personnel
❍ Trained to a level of competency for assigned
duties
❍ Annual refresher
Note: See CFR 1910.120(p)(7) and (p)(8).
Table 3. Training Requirements for Other Emergency Response Staff

Level 1 — First responder (awareness level)1
• Sufficient training or proven experience in specific
competencies
• Annual Refresher
Level 2 — First responder (operations level)2
• Level 1 competency and 8 hours initial or proven
experience in specific competencies
• Annual refresher
Level 3 — HAZMAT technician3
• 24 hours of Level 2 and proven experience in specific
competencies
Level 4 — HAZMAT specialist4
• 24 hours of Level 3 and proven experience in specific
competencies
•
Level 5 — On-scene incident commander5
• 24 hours of Level 2 and additional competencies
Note: See 29 CFR 1910.120(q)(6).
1
Witnesses or discovers a release of hazardous materials and who are trained to notify the proper authorities.
2
Responds to releases of hazardous substances in a defensive manner, without trying to stop the releases.
3
Responds aggressively to stop the release of hazardous substances.
4
Responds with and in support to HAZMAT technicians, but who have specific knowledge of various hazardous substances.
5
Assumes control of the incident scene beyond the first-responder awareness level.
3/14 HAZWOPER–195

May 10, 1990

MEMORANDUM FOR: Patricia Clark, Acting Director
[Directorate of Health Enforcement]
FROM: Stanley Elliott, Acting Director
[Directorate of Standards and Guidance]
SUBJECT: Review of Standards Interpretation for 29 CFR 1910.120
On May 2, 1990, Ms. MaryAnn Garrahan of your staff requested a review by this office of an
interpretation of 29 CFR 1910.120. The interpretation was requested by Mr. Terry A. Noteboom of
Rockwell International Avionics Group in a letter to you dated April 12, 1990. The following com-
ments are offered by this Directorate:
1. In the second paragraph, after the first sentence, we would suggest language similar to the
following: “The quantity of product spilled does not by itself determine if an incidental spill has
occurred. Several variables, including the volume of the spill, must be considered in evaluating the
hazard of the release to employees.” Many employers are trying to draw a parallel connection
between OSHA’s emergency response definition and EPA’s use of reportable quantities. We need
to emphasize that other factors should play a role in the determination of an emergency.
2. In the fifth paragraph, beginning “The training requirements...”, in the second sentence, the
parenthetical note implies that 24 hours of emergency response training is the upper limit of training
necessary in (q). The highest level of response, the hazardous materials specialist, requires a
minimum of 24 hours of hazardous materials technician training plus competency in nine specific
areas of response. Any attempt to acquire the competencies covered under (q)(6)(iv)(A) through (I)
would require more than 24 hours of training. Experience from the rulemaking, including testimony
at our hearings, shows that employees trained to the levels of competency required in (q)(6)(iv)
have received in excess of 100 hours of training. We suggest adding the phrase, “...plus the training
necessary for the competencies listed”, at the end of the parenthetical note.
196–HAZWOPER 3/14

PROCESS SAFETY MANAGEMENT/RISK MANAGEMENT PLAN
CONTENTS
Introduction to the Process Safety Management (PSM) Standard .................................. 3

Elements of the PSM Standard ....................................................................... 4
Process Safety Management Applicability .......................................................... 4
Process Safety Management Exemptions ........................................................... 5
Process Safety Management Hazards................................................................ 6
Introduction to the Risk Management Plan (RMP) ..................................................... 7
RMP Programs ............................................................................................ 7
Comparison of Program Requirements .............................................................. 8
Risk Management Plan Applicability ................................................................ 9
Risk Management Plan Hazards .................................................................... 10
Risk Management Plan Exemptions................................................................ 10
Contrasting PSM With RMP ............................................................................. 10A
What the PSM Standard Emphasizes .............................................................. 11
What the RMP Rule Emphasizes.................................................................... 11
Comparison of PSM and RMP Provisions ......................................................... 12
Clean Air Act’s General Duty Clause..................................................................... 13
What Is the General Duty Clause Under CAA §112(r)(1)?..................................... 13
What Chemicals Are Covered by the General Duty Clause? .................................. 13
Summary ....................................................................................................... 13
Risk Management Program and Plan Checklist ....................................................... 15
RMP Facility Checklist ................................................................................ 15
3/14 Process safety management/risk management plan TOC–1

Reserved
2–Process safety management/risk management plan TOC 3/14

Introduction to the Process Safety Management (PSM) Standard

In recent years, industrial accidents that involved the release of toxic chemicals have claimed the
lives of hundreds of employees worldwide. The most publicized accident took place in Bhopal, In-
dia in 1984 where more than 2,000 employees died after they were exposed to a deadly chemical.
As a result of the Bhopal, India accident and several others just like it, the safety processes that
govern hazardous chemicals in industry are being scrutinized by the Occupational Safety and
Health Administration (OSHA). Employees have been, and will continue to be, exposed to chemi-
cals in their work areas. The hazards of working in areas where releases of highly hazardous
chemicals (HHCs), which may be toxic, flammable, or explosive, must be communicated to em-
ployees through the Process Safety Management (PSM) standard.
In each industry, PSM applies to those companies that deal with any one of 130 specific toxic and
reactive chemicals in specified threshold quantities. It also includes flammable liquids and gases in
quantities of 10,000 pounds or more. Process safety management is the application of manage-
ment systems to identify, understand, and control process hazards to prevent process-related inju-
ries and property loss. In other words, the main purpose of the PSM standard is to develop guide-
lines for preventing unwanted releases of hazardous chemicals into locations that could expose
employees and others to serious hazards.
The PSM standard is derived from the Hazard Communication (HAZCOM) Standard; the HAZ-
COM standard requires employers to inform their employees about the presence of hazardous
workplace substances that are present in the workplace. For example, chemical containers must
be labeled, a written hazard communications plan must be developed and communicated to em-
ployees, and employees must be trained to protect themselves from exposure to hazardous chem-
icals.
Under the PSM standard, employers must complete a process hazard analysis (PHA) for all pro-
cesses involving any toxic and reactive chemical at or above the threshold quantities. The PHA is
a review of the consequences of a catastrophic chemical release and the steps that should be
taken to prevent a catastrophic chemical release. Using a PHA, employers must identify the pro-
cesses that pose the greatest risks and complete a report that outlines these risks.
As was mentioned earlier, the PSM standard specifies the requirements for preventing or minimiz-
ing the consequences of catastrophic releases of toxic, reactive, explosive, or flammable chemi-
cals. The PSM standard also provides comprehensive information about how to train designated
people about what to do in the event of a catastrophic release of a chemical, how to analyze all
potential problems associated with storage vessels, and how to analyze the integrity of the equip-
ment associated with the storage vessels.
PROCESS SAFETY AND RISK MANAGEMENT--3

8/99

Elements of the PSM Standard

Like some other industry standards, the PSM standard is a performance-oriented standard. Perfor-
mance-oriented means that the PSM standard requires the implementation of comprehensive
management-based programs that address the following 14 elements:
• Process safety information
• Process hazard analysis
• Operating procedures
• Employee participation
• Employee training
• Contractors
• Pre-startup safety review
• Mechanical integrity of equipment
• Hot work permits
• Management of change
• Accident investigations
• Emergency planning and response
• Compliance audits
• Trade secrets and documentation
In February 1992, OSHA designated Code of Federal Regulations (CFR) 29 1910.119 as the final
rule for the PSM of highly hazardous chemicals (HHCs). This regulation focuses on industries that
use, store, manufacture, handle, or move HHCs that have the potential to cause catastrophic inci-
dents like the one mentioned at the beginning of this chapter.
Process Safety Management Applicability
Facilities are subject to the standard if highly hazardous materials are in one area, and any one of
the following conditions are met. These conditions are:
• A process that involves a specified chemical at or above the specified threshold
quantities.
• A process that involves a flammable liquid or gas (as defined in 1910.1200(c)) onsite in one
location, in a quantity of 10,000 pounds or more except for:
• hydrocarbon fuels used solely for workplace consumption as a fuel; and

8/99

• flammable liquids stored in atmospheric tanks or transferred, which are kept below their
boiling point without chilling or refrigeration;
• Manufacture of explosives, pyrotechnics, including fireworks and flares.
As previously mentioned, coverage is triggered by any process that involves a chemical at or
above the threshold quantity or a process that involves a flammable liquid or gas, on site in one
location, in a quantity of 10,000 pounds or more. The presence of a threshold quantity is to be at
one point in time, not aggregated over a period of time.
This standard covers substances that may be harmless in terms of flammability, explosivity, or tox-
icity, but, when mixed with another substance, can produce a highly hazardous substance or situa-
tion. The accidental mixing of some reactive chemicals can cause explosions or the release of tox-
ic vapors, situations that are clearly a threat to the life and health of workers at the site.
Process Safety Management Exemptions
OSHA does not believe that retail facilities or normally unoccupied remote facilities present the
same degree of hazard to employees as workplaces that would require a comprehensive hazard
analysis and management system.
The following operations and facilities are excluded from the PSM standard:
Retail Operations
Certainly, highly hazardous chemicals may be present in this type of work operation. However, re-
garding retail facilities, chemicals are in smaller volume packages, containers, and allotments,
making a massive release unlikely. Conditions of high pressure, excessive heat, or mixing of signif-
icant quantities of chemicals are considered unlikely.
Unoccupied Remote Facilities
In normally unoccupied remote facilities, the likelihood of an uncontrolled release injuring or killing
employees is effectively reduced by isolating the process from employees. OSHA believes that the
present standards, such as those contained in §1910.106, Flammable and Combustible Liquids,
and in part 1910, subpart Z, Toxic and Hazardous Substances, adequately address the chemical
hazards presented in these work operations.
Oil and Gas Well Drilling Operations

OSHA also excluded oil and gas well drilling and servicing operations from the standard because
OSHA has already undertaken rulemaking with regard to these activities and believes these op-
erations should be covered in a standard designed to address their uniqueness.
Storage of Fuels
Facilities that handle or store hydrocarbon fuels, such as gasoline, heating oil, or liquid propane,
solely for onsite consumption, are excluded from the rule because the quantities present would be
almost universally below 10,000 pounds. Furthermore, in situations where the quantity exceeded
5 tons, inventory reduction would allow the site to reduce the potential for hazards to a low enough
level that the standard would not apply.

8/99

Storage of Flammable Liquids

Facilities that store flammable liquids at atmospheric pressure without chilling or refrigeration
would be excluded. Most oil and petroleum products storage facilities would therefore be ex-
cluded, primarily due to lack of refrigeration and relatively low vapor pressure, although natural gas
and propane storage would generally be covered.
Process Safety Management Hazards
Through the development and implementation of operating procedures, work practices, and man-
agement control systems, the rule addresses accidents arising from external (human) influences
on equipment and equipment malfunctions. Other than equipment failure, such as ruptures and
leaks, potential hazards arise from human error.
Hazards with Storage Vessels
Inadvertent mixing and pressure-related accidents are the primary concerns associated with stor-
age vessels. Mixing of reactive chemicals can occur when storage tanks containing various chemi-
cals are connected to a common piping system.
Opening the wrong valve in the piping system, for example, can allow two reactive materials to mix,
resulting in an explosion or creation and release of a toxic material. This type of hazard should be
recognized and protected against in the course of performing a hazard analysis and acting on the
results of that analysis.
Another potential hazard is the direction into the wrong tank of a chemical being unloaded, possi-
bly creating a hazardous reaction.
Pressure-related incidents (other than tank rupture due to construction material failure under nor-
mal conditions) can occur in cooled or refrigerated tanks as well as heated tanks. If the cooling
system fails, the temperature increase will cause the material to expand, thus increasing the pres-
sure in the tank, possibly resulting in structural failure of the tank if the pressure significantly ex-
ceeds the design limitations.
Hazards with Reactors, Mixing Vessels, and Charge Tanks
Hazards associated with reactors, mixing vessels, charge tanks, and other associated equipment
such as preheaters, are all of the same general nature. Activation of a wrong valve, failure of an
automatic controller, or failure of an operator to verify correct conditions can result in serious acci-
dents.
The most common types of accidents in such situations result from operating temperatures being
too high or inadvertent mixing of reactive chemicals. Excessive heat can result in pressure in-
creases, with the same effects as in storage tanks, or an unintended reaction, or a runaway reac-
tion.
A runaway reaction generally occurs when an exothermic reaction (a reaction that gives off heat)
creates more heat than the cooling system removes. As the temperature rises, the reaction rate
increases, releasing more heat, further increasing the rate of reaction, and so on. At some point,
the energy being created must be released, possibly resulting in an explosion or equipment failure.

8/99

Endothermic reactions can also occur. In an endothermic reaction, heat energy is absorbed when
the compound is formed, and the end result can be an endothermic reaction, possibly resulting in
an explosion or equipment failure.
Temperature-related incidents such as these can be largely avoided by operating procedures that
constantly check for the proper conditions, reinforced by equipment improvements. Redundant or
oversized cooling systems can aid in controlling or reducing temperature if employed quickly
enough.
An escape or dump tank equipped with a cooling system can be used to hold the reacting material
in a more tightly controlled, stronger, and better-protected vessel, slowing or stopping the reaction.
Another possible control method for runaway reactions is to have the ability to add an additional
material to the vessel, which retards or halts the reaction.
Hazards with separation or distillation processes

Hazards associated with separation or distillation processes are similar to those that arise from
reactors and related equipment. The same temperature and pressure-related hazards exist, but
additional complications also exist.
In one facility’s situation, a potentially reactive distillation feedstock (a batch of nitroaromatic com-
pounds) was contaminated with other organic materials. Although the contaminated feedstock was
stable at ambient conditions, the effects of heat on the mixture were unknown. The potential hazard
was that, when heated in the distillation column, the materials could react, possibly resulting in an
explosion. Laboratory tests showed that the materials might react at the distillation temperature, so
the batch was disposed of rather than attempting separation of the feedstock.
This situation not only demonstrates how a potential accident can be avoided, it also demonstrates
the less obvious hazards that can exist in some situations.
Introduction to the Risk Management Plan (RMP)

The Clean Air Act (CAA) required the Environmental Protection Agency (EPA) to publish regulations
to help prevent accidental releases of regulated substances and reduce the severity of the releases
that do occur. On May 24, 1996, EPA signed the final rule for the Risk Management Plan (RMP).
The RMP applies to all stationary sources (facilities) with processes that contain more than a
threshold quantity of a regulated substance. Processes will be divided into three categories based
on the following criteria:
• The potential for offsite consequences associated with a worst-case accidental release;
• Previous accident history; or
• Compliance with the prevention requirements under OSHA’s PSM standard.
RMP programs
Under the RMP rule, processes subject to the requirements of the RMP are divided into three
Programs (formally referred to as Tiers). Eligibility for any given Program is based on process criteria
so that classification of one process in a Program does not influence the classification of other
processes at the source.
For example, if a process meets Program 1 criteria, the source need only satisfy Program 1
requirements for that process, even if other processes at the source are subject to the criteria of
PROCESS SAFETY AND RISK MANAGEMENT–7

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Programs 2 or 3. Therefore, a source could have processes in one or more of the three programs.
Program 1 applies to facilities that have not had a significant incidental release within the past 5
years. This program requires facilities to register and certify only that their facility’s worst-case
release would not affect human populations or the environment. In short, processes that have no
potential impact on the public in terms of an accidental release will have minimal requirements, such
as those listed under Program 1.
For other processes, sources will implement a risk management program that includes more
detailed requirements for hazard assessment, prevention, and emergency response, as listed under
Programs 2 and 3.
Program 2 requires facilities to register, conduct an analysis of off-site consequences, and document
a 5-year accident history. These facilities must document the prevention and emergency response
plans for addressing important items, such as maintenance, training, monitoring, and procedures for
informing the public of an emergency situation.
Program 3 requires compliance with the complete RMP rule. Refer to the following charts for
program eligibility criteria, and for a comparison of the program requirements.
Comparison of program requirements

Requirement: Program 1: Program 2: Program 3:
Hazard assessment Worst-case analysis Worst-case analysis Worst-case analysis
Alternative releases Alternative releases
5-year accident history 5-year accident history 5-year accident history 5-year accident history
Management program ---- Document management Document management
system system
Prevention program Certify no additional steps Safety information Process safety information
needed Hazard review Process hazard analysis
Operating procedures Operating procedures
Training Training
Maintenance Mechanical integrity
Incident investigation Incident investigation
Compliance audit Compliance audit
Management of change
Pre-startup review
Contractors
Employee participation
Hot work permits
Emergency response pro- Coordinate with local Develop plan and program Develop plan and program
gram responders

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Requirement: Program 1: Program 2: Program 3:

Risk management plan Confidential business infor- Confidential business infor- Confidential business infor-
contents mation (CBI) mation (CBI) mation (CBI)
Document(s) supporting Document(s) supporting Document(s) supporting
any CBI any CBI any CBI
Executive summary Executive summary Executive summary
Registration Registration Registration
Worst-case data Worst-case data Worst-case data
5-year accident history Alternative release data Alternative release data
Certification 5-year accident history 5-year accident history
Prevention program data Prevention program data
Emergency response data Emergency response data
Certification Certification
Based on the situation of a given facility, the owner or operator of a covered process must:
1. Prepare and submit a single RMP, including registration that covers all affected processes
and chemicals
2. Conduct a worst-case release scenario, review accident history, ensure emergency
response procedures are coordinated with community response organizations to determine
eligibility for Program 1, and, if eligible, document the worst-case scenario and complete a
Program 1 certification for the RMP.
3. Conduct a hazard assessment, document a management system, implement a more
extensive, but streamlined prevention program, and implement an emergency response
program for Program 2 processes.
4. Conduct a hazard assessment, document a management system, implement a prevention
program that is fundamentally identical to the OSHA PSM standard, and implement an
emergency response program for Program 3 processes.
Risk management plan applicability

The RMP rule applies to an estimated 140,000 facilities nationwide that handle regulated sub-
stances in quantities exceeding threshold limits; the rule is not restricted to refineries and chemical
manufacturing plants.
The following facilities with chemicals above the threshold limits must comply with the RMP plan:
• Most manufacturing facilities
• Cold storage facilities that use ammonia as a refrigerant
• Wastewater treatment facilities using chlorine as a biocide
• Public water utilities
• Chemical wholesalers and end-users
• Propane retailers
• Utilities

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Risk management plan hazards

Hazards addressed under the RMP rule include chemicals stored above threshold quantities in
containers, and that create a potential for catastrophic consequences such as:
• Chemical exposure to the surrounding communities
• Explosion of storage vessels
• Degradation of water and air sources
Risk management plan exemptions

The RMP rule does not apply to facilities that handle regulated substances in quantities below the
specified threshold limits.
Exemptions include:
• Flammable fuels used as fuel or held for sale as fuel at a retail facility are not covered by
the RMP program. However, flammable fuels used as a feedstock or held for sale as fuel
at a wholesale facility are still covered. A retail facility is a facility at which more than
one-half of the income is obtained from direct sales to end users or at which more than
one-half of the fuel sold, by volume, is sold through a cylinder exchange program. (Chemi-
cal Safety Information, Site Security and Fuels Regulatory Relief Act, Public Law 106-40)
• Ammonia used as an agricultural nutrient, when held by farmers is exempt. (40 CFR
68.125)
• Gasoline (which includes some of the regulated chemicals) that is used for internal com-
bustion engines is exempt.(40 CFR 68.115 (b) (2) (ii))
• Regulated substances in naturally occurring hydrocarbon mixtures (natural gas con-
densate, crude oil, field gas, and produced water) prior to initial processing in a petroleum
refining process unit or a natural gas processing plant are exempt.(40 CFR 68.115 (b) (2)
(iii))
• Any source located on the outer continental shelf (e.g. oil rigs, production platforms, etc.)
is exempt.(40 CFR 68.10 (f))
• Regulated substances contained in articles are exempt. Articles are defined as manufac-
tured items that are formed to a specific shape or design during manufacture, that have end
use functions dependent in whole or in part upon the shape or design during end use, and
that do not release or otherwise result in exposure to a regulated substance under normal
conditions of processing and use.(40 CFR 68.115 (b) (4))
• A regulated flammable substance that is present in a mixture is exempt if it comprises less
than one percent by weight of the mixture. If the regulated substance comprises more than
one percent by weight of the mixture and the mixture has a flash point greater than 22.8
degrees C (73 F) and a boiling point above 37.8 degrees C (100 F) or the mixture does
not meet the NFPA flammability rating of 4 or higher, then the mixture is exempt.(40 CFR
68.115 (b) (2))
• A regulated toxic substance that is present in a mixture is exempt if it comprises less than
one percent by weight of the mixture. If the regulated substance comprises more than one
percent by weight of the mixture and if the partial pressure of the regulated toxic substance
in the mixture is less than 10mm mercury, then the mixture is exempt*. Four aqueous

3/10

solutions already have specified concentrations that make them subject and therefore
should not be considered in this mixture exemption. These four solutions are ammonia
(20%), hydrochloric acid (37%), hydrofluoric acid (50%) and nitric acid (80%). *Does not
apply to Oleum; toluene 2,4- diisocyanate; toluene 2,6-diisocyanate; toluene
diisocyanate.(40 CFR 68.115 (b) (1))
• Regulated substances used for the following purposes are exempted: (1) use as a struc-
tural component of the stationary source, (2) use of products for routine janitorial
maintenance, (3) foods, drugs, cosmetics, or other personal items containing the regu-
lated substance used by employees, (4) use of regulated substances present in process
water or non-contact cooling water as drawn from the environment or municipal sources or
use of regulated substances present in air used either as compressed air or as part of
combustion.(40 CFR 68.115 (b) (5))
• Regulated substances used in laboratories at a stationary source under the supervision of
a technically qualified individual are exempt. This exemption does not apply to (1) specialty
chemical production, (2) manufacture, processing or use of substances in pilot plant scale
operations and (3) activities conducted outside the laboratory.(40 CFR 68.115 (b) (6))
Contrasting PSM With RMP

According to EPA, the elements and language of the RMP rule are, to the maximum extent possible,
identical to the parallel elements in OSHA’s PSM standard. One important difference between PSM
and RMP is that, under the Clean Air Act (CAA) amendments, OSHA, must protect workers from
chemical incidents at facilities that use highly toxic, reactive, flammable, or explosive substances.
EPA must protect public health and the environment.
PROCESS SAFETY AND RISK MANAGEMENT–10A

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Reserved
PROCESS SAFETY AND RISK MANAGEMENT–10B

3/10
The CAA requires the RMP rule to include several elements in its regulation that are not required
for the PSM standard. Specifically, the RMP rule must include a hazard assessment, an emergen-
cy response program with certain elements, registration, and the submittal and auditing of the
RMP rule.
In addition, the PSM and RMP substances list and their associated threshold quantities are not
identical. Some of the substances appear on one list but not the other, and some appear on both
lists but with different thresholds.
What the PSM Standard Emphasizes
Many facilities covered under the RMP rule will already be regulated under the PSM standard. One
of the main areas the PSM standard emphasizes is PHA. Under the PSM standard, employers
must complete a PHA for all processes involving any toxic and reactive chemical.
The PHA is a review of the consequences of a catastrophic chemical release and the steps that
should be taken to prevent a catastrophic chemical release. Using a PHA, employers must identify
the processes that pose the greatest risks, and complete a report that outlines these risks.
The CAA also requires OSHA to list 14 requirements for employers (listed elsewhere in this sec-
tion). Three of the most important requirements include the following:
• Train employees and contractors in emergency response procedures. Those trained must
have knowledge, skill, and understanding of the procedures.
• Develop and maintain safety information about chemical and process hazards in the
workplace.
• Perform a hazard assessment of workplace activities.
As was mentioned earlier, a key provision of the PSM standard is PHA. A PHA is a thorough review
of the types of chemical releases that could occur in the workplace, and the safeguards that must
be implemented to minimize the consequences of a release.
What the RMP Rule Emphasizes
Under the CAA amendments, Congress mandated risk management plans to detect and prevent
(or at least minimize) accidental releases of regulated substances, and to provide emergency re-
sponse should a release occur.
Similar to the PSM standard, the RMP rule requires owners and operators to document the chemi-
cals and their threshold quantities, that, if released, could result in catastrophic consequences.
While the PSM standard centers on worker safety, the RMP rule focuses on releases that would
pose a hazard to public health and the environment.
The RMP rule also requires owners and operators to develop risk management planning rules that
would require all facilities to develop and implement a risk management program. Three of the
most important requirements include the following:
• A hazard assessment of workplace activities.

8/99

• A prevention program that is based on OSHA’s PSM standard.

• An emergency response program to train employees and contractors in emergency
response procedures.
Comparison of PSM and RMP Provisions

Process Safety Risk Management Plan
Provision
Management (PSM) (RMP)
Safety and Compliance Audits X X
Pre-startup Safety Reviews X X
Mechanical Integrity X X
Standard Operating Procedures X X
Process Safety Information X X
Management-of-Change X X
Incident Investigation X X
Emergency Planning and Response X X
Process Hazard Analysis X X
Training Programs X X
Employee Participation X X
Hot-work Permits X X
Contractor Requirements X X
Management Systems Requirements X
Off-site Analysis X
Five-year Incident History X
Worst-case Release Scenarios X
Coordinate Plans with LEPC X
Provide Information to the Public X
Facility Registration X
Risk Management Plan Requirement X
Recordkeeping Requirements X X
Reporting Requirements X
Response Drills and Exercises X
Regulatory Audit Requirements X
Trade Secrets Clause X

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Clean Air Act’s General Duty Clause

The Environmental Protection Agency estimates that its new risk management rule will impact over
60,000 facilities. However, an obscure but important clause in the Clean Air Act actually extends
risk management planning to many more facilities.
Under the provisions of the Act’s General Duty Clause, found at 112(r), even if a facility handles,
processes, or stores chemicals that are not listed under the risk management rule, it does have
accident prevention responsibilities for these same chemicals if they can be determined to be ex-
tremely hazardous substances.
Note: These substances are not the same as the extremely hazardous substances found in 40
CFR 355, but refer to any substances that could be generally judged to be extremely hazardous.
What is the general duty clause under CAA §112(r)(1)?

The Clean Air Act general duty clause directs owners and operators of stationary sources to identi-
fy hazards that may result from accidental releases, to design and maintain a safe facility, and to
minimize the consequences of releases when they occur.
What chemicals are covered by the general duty clause?

There is no specific list of substances which subject a stationary source owner or operator to the
general duty provisions. The general duty provisions apply to owners and operators of all station-
ary sources which have any “extremely hazardous substances”. Extremely hazardous substances
are not limited to the list of regulated substances listed under section 112(r), nor the extremely
hazardous substances under EPCRA §302 (40 CFR Part 355, Appendices A and B).
Although there is no definition for extremely hazardous, the Senate Report on the Clean Air Act
provides criteria EPA may use to determine if a substance is extremely hazardous. The report ex-
pressed the intent that the term “extremely hazardous substance” would include any agent “which
may or may not be listed or otherwise identified by any Government agency which may as the
result of short-term exposures associated with releases to the air cause death, injury or property
damage due to its toxicity, reactivity, flammability, volatility, or corrosivity” (Senate Committee on
Environment and Public Works, Clean Air Act Amendments of 1989, Senate Report No. 228, 101st
Congress, 1st Session 211 (1989) -- “Senate Report”).
As the Senate makes clear, “the release of any substance which causes death or serious injury
because of its acute toxic effect or as a result of an explosion or fire or which causes substantial
property damage by blast, fire, corrosion or other reaction would create a presumption that such
substance is extremely hazardous.” Senate Report at 211. Revisions to the list of regulated sub-
stances under CAA 112(r) do not affect the applicability of the general duty provisions.
Summary
In summary, the overall goals of the PSM standard and the RMP rule are the same; however, the
PSM and RMP contain a mix of items that are both similar and different. For a detailed comparison
of the elements for the PSM standard and the RMP rule, refer to the table on page 12.

8/00

Similarities between PSM and RMP include the following:

• Training programs
• Incident investigation requirements
• Process hazard analysis
• Emergency response guidelines
• Safety and compliance audits
• Pre-startup safety review requirements
• Mechanical integrity requirements
• Standard operating procedures
• Process safety information systems
• Management-of-change-requirements
• Required employee participation
• Required permits for hot-work operations
• Requirements for contractors
• Recordkeeping requirements
Items found only under the PSM Standard include the following:
• Trade secrets clause
Items found only under the RMP Rule include the following:
• Facility registration
• Management systems requirements
• Regulatory audit requirements
• Five-year accident history
• Worst-case release scenarios
• Analysis of off-site consequences
• Coordinate emergency response plans with a local emergency planning committee (LEPC)
• Risk management plan requirements

8/00

• Requirements for providing public information regarding a chemical release

• Requirements for reporting incident information
• Requirements for emergency response drills
Risk Management Program and Plan Checklist
RMP Facility Checklist

EPA developed the following checklist for use by field inspectors. It will help you ensure that
all aspects of your Risk Management Program are in compliance with Clean Air Act Section
112(r). The regulations cited are located in 40 CFR Part 68.
Applicability [68.1]
1.1 Does the owner or operator of the stationary source have more than a
threshold quantity of a regulated substance in a process? [68.10(a)]
1.2 Has the process had, in the five years prior to submission of the RMP, an
accidental release of a regulated substance where exposure to the substance,
its reaction products, overpressure generated by an explosion involving the
substance, or radiant heat generated by a fire involving the substance led to
any of the following off-site:
(i) Death; (ii) Injury; or (iii) Response or restoration activities for an exposure
of an environmental receptor? [68.10(b)(1)]
1.3 Is the distance to a toxic or flammable endpoint for a worst-case release
assessment less than the distance to any public receptor? [68.10(b)(2)]
1.4 Has the owner or operator coordinated emergency response procedures
between the stationary source and local emergency planning and response
organizations? [68.10(b)(3)]
1.5 Is the covered process subject to OSHA PSM standard, 29 CFR 1910.119?
[68.10(d)(2)]
1.6 Is the covered process in one of the NAICS codes listed in 40 CFR §68.
10(d)(1)? [68.10(d)(1)]
1.7 Has the owner or operator submitted a single RMP, which included a
registration that reflects all covered processes, as provided in 68.150 to 68.
185? [68.12(a)]
1.8 For Program 1 processes, has the owner or operator: [68.12(b)]
1.8.1 Analyzed the worst-case release scenario for the process(es), as provided
in 68.25; [68.12(b)(1)]
1.8.2 Documented that the nearest public receptor is beyond the distance to
an endpoint defined in 68.22(a); and [68.12(b)(1)]
1.8.3 Included the scenario(s) in the RMP as provided in 68.165? [68.12(b)(1)]
1.8.4 Completed the five-year accident history for the process as provided in
68.42 [68.12(b)(2)]; and
1.8.5 Included the history in the RMP as provided in 68.168? [68.12(b)(2)]
3/14 Process safety and risk management–15

1.8.6 Ensured that response actions have been coordinated with local
emergency planning and response agencies? [68.12(b)(3)]
1.8.7 Included the appropriate certification statement for Program 1
processes? [68.12(b)(4)]
1.9 For Program 2 processes, has the owner or operator: [68.12(c)]
1.9.1 Developed and implemented a management system as provided in 68.
15? [68.12(c)(1)]
1.9.2 Conducted a hazard assessment as provided in 68.20 through 68.42?
[68.12(c)(2)]
1.9.3 Implemented the Program 2 prevention steps provided in 68.48 through
68.60 or implemented the Program 3 prevention steps provided in 68.65
through 68.87? [68.12(c)(3)]
1.9.4 Developed and implemented an emergency response program as
provided in 68.90 to 68.95? [68.12(c)(4)]
1.9.5 Submitted, as part of the RMP, the data on prevention program
elements for Program 2 processes as provided in 68.170? [68.12(c)(5)]
1.10 For Program 3 processes, has the owner or operator: [68.12(d)]
1.10.1 Developed and implemented a management system as provided in 68.
15? [68.12(d)(1)]
1.10.2 Conducted a hazard assessment as provided in 68.20 through 68.42?
[68.12(d)(2)]
1.10.3 Implemented the prevention requirements provided in 68.65 through
68.87? [68.12(d)(3)]
1.10.4 Developed and implemented an emergency response program as
provided in 68.90 to 68.95? [68.12(d)(4)]
1.10.5 Submitted, as part of the RMP, the data on prevention program
elements for Program 3 processes as provided in 68.175? [68.12(d)(5)]
Management [68.15] Has the owner or operator:
1.11 Developed a management system to oversee the implementation of the
Risk Management Program elements? [68.15(a)]
1.12 Assigned a qualified person or position that has the overall responsibility
for the development, implementation, and integration of the Risk
Management Program elements? [68.15(b)]
1.13 Documented other persons responsible for implementing individual
requirements of the Risk Management Program and defined the lines of
authority through an organization chart or similar document? [68.15(c)]
RMP Submission (Subpart G) [68.150 – 68.190]

2.1 Did the owner or operator submit an RMP on or before June 21, 1999?
Postmark date of initial submission: [68.10, 68.10(a)(1), 68.150(a) & (b)]
If submission was after June 21, 1999, was submittal required because: [68.
10 & 68.150(b)]
16–Process safety and risk management 3/14

2.1.1 Initial listing of a regulated substance under 68.130 after June 21, 1999
[68.10(a)(2) & 68.150(b)(2)]
2.1.2 A regulated substance was first present at the stationary source above
the threshold quantity in a process [68.10(a)(3) & 68.150(b)(2)]
2.2 Has the owner or operator revised and updated the RMP within 5 years of
initial submission? Date of the last revision and update [68.190(a)]:
2.3 If required, has the owner or operator submitted a revised RMP for any of
the following: [68.190(b)]
2.3.1 Within 3 years after EPA first listed a newly regulated substance? [68.
190(b)(2)]
2.3.2 No later than the date on which a new regulated substance is first
present in an already covered process above a threshold quantity? [68.
190(b)(3)]
2.3.3 No later than the date on which a regulated substance is first present
above a threshold quantity in a new process? [68.190(b)(4)]
2.3.4 Within six months of a change that requires a revised PHA or hazard
review? [68.190(b)(5)]
2.3.5 Within six months of a change that requires a revised off-site
consequence analysis as provided in 68.36? [68.190(b)(6)]
2.3.6 Within six months of a change that alters the Program level that
applied to any covered process? [68.190(b)(7)]
2.4 Has the owner or operator included information submitted as CBI in the
RMP? [68.150(d)]
2.4.1 If so, were the provisions of 68.151 and 68.152 followed?
RMP: Executive Summary [68.155]
2.5 Has the owner or operator included a brief description of the following
elements in the executive summary of the RMP: [68.155]
2.5.1 The accidental release prevention and emergency response policies at
the stationary source? [68.155(a)]
2.5.2 The stationary source and regulated substances handled? [68.155(b)]
2.5.3 The general accidental release prevention program and chemical-specific
prevention steps? [68.155(c)]
2.5.4 The five-year accident history? [68.155(d)]
2.5.5 The emergency response program? [68.155(e)]
2.5.6 Planned changes to improve safety? [68.155(f)]
2.6 Has the owner or operator included a single registration form in the RMP
which covers all regulated substances handled in covered processes? [68.
160(a)]
2.7.8 The number of full-time employees at the stationary source? [68.
160(b)(9)]

2.7.9 Whether the stationary source is subject of 29 CFR §1910.119, OSHA’s

Process Safety Management Standard? [68.160(b)(10)]
2.7.10 Whether the stationary source is subject to 40 CFR Part 355, the
Emergency Planning Requirements of the Emergency Planning and
Community Right-to-Know Act? [68.160(b)(11)]
2.7.11 If the stationary source has a CAA Title V operating permit, its permit
number? [68.160(b)(12)]
2.7.12 The date of the last safety inspection of the stationary source by a
Federal, state, or local government agency and the identity of the inspecting
entity? [68.160(b)(13)]
RMP: Off-site Consequence Analysis [68.165]
2.8 Does the RMP include the following: [68.165(a)]
2.8.1 One worst-case release scenario for each Program 1 process? [68.
165(a)(1)]
2.8.2 For Program 2 and 3 processes, one worst-case release scenario to
represent all regulated toxic substances held above the threshold quantity
and one worst-case release scenario to represent all regulated flammable
substances held above the threshold quantity? [68.165(a)(2)]
2.8.3 For Program 2 and 3 processes, were additional worst-case scenarios
also submitted, if required by 68.25(a)(2)(iii)? [68.165(a)(2)]
2.8.4 For Program 2 and 3 processes, was information submitted on one
alternative scenario for each regulated toxic substance held above the
threshold quantity and one alternative scenario to represent all regulated
flammable substances held above the threshold? [68.165(a)(2)]
2.9 Does the RMP include the following information for each submitted
release scenario: [68.165(b)]
2.9.1 Scenario type (explosion, fire, toxic gas release, or liquid spill and
vaporization)? [68.165(b)(5)]
2.9.2 Chemical name of released substance? [68.165(b)(1)]
2.9.3 Percentage weight of the chemical in a liquid mixture (toxics only)? [68.
165(b)(2)]
2.9.4 Physical state of substance (toxics only)? [68.165(b)(3)]
2.9.5 Basis of results (model name if used)? [68.165(b)(4)]
2.9.6 Quantity released in pounds? [68.165(b)(6)]
2.9.7 Release rate? [68.165(b)(7)]
2.9.8 Release duration? [68.165(b)(8)]
2.9.9 Wind speed and atmospheric stability class (toxics only)? [68.165(b)(9)]
2.9.10 Topography (toxics only)? [68.165(b)(10)]
2.9.11 Distance to endpoint? [68.165(b)(11)]
2.9.12 Public and environmental receptors within the distance? [68.165(b)(12)]
2.9.13 Passive mitigation considered? [68.165(b)(13)]

2.9.14 Active mitigation considered (alternative releases scenarios only)? [68.

165(b)(14)]
RMP: Five-Year Accident History [68.168]
2.10 Has the owner or operator provided the five-year accident history
information in 68.42 on each accident covered by 68.42? [68.168]
2.11 Does the RMP include the following information for each reported
accidental release: [68.42(b)]
2.11.1 Date, time, and approximate duration of the release? [68.42(b)(1)]
2.11.2 Chemical(s) released? [68.42(b)(2)]
2.11.3 Estimated quantity released in pounds and percentage weight in a
mixture (toxics)? [68.42(b)(3)]
2.11.4 NAICS code for the process? [68.42(b)(4)]
2.11.5 The type of release event and its source? [68.42(b)(5)]
2.11.6 Weather conditions (if known)? [68.42(b)(6)]
2.11.7 On-site impacts? [68.42(b)(7)]
2.11.8 Known offsite impacts? [68.42(b)(8)]
2.11.9 Initiating event and contributing factors (if known)? [68.42(b)(9)]
2.11.10 Whether offsite responders were notified (if known)? [68.42(b)(10)]
2.11.11 Operational or process changes that resulted from investigation of the
release? [68.42(b)(11)]
RMP: Prevention Program/Program 2 [68.170]
2.12 Has the owner or operator included the following information for each
covered process in Program 2: [68.170(a)]
2.12.1 The NAICS code for the process? [68.170(b)]
2.12.2 The name(s) of the chemical(s) covered? [68.170(c)]
2.12.3 The date of the most recent review or revision of the safety information
and a list of Federal or state regulations or industry-specific design codes and
standards used to demonstrate compliance with the safety information
requirement. [68.170(d)]
2.12.4 The date of completion of the most recent hazard review or update?
[68.170(e)]
2.12.4.1 The expected date of completion of any changes resulting from the
hazard review or update? [68.170(e)(1)]
2.12.4.2 Major hazards identified? [68.170(e)(2)]
2.12.4.3 Process controls in use? [68.170(e)(3)]
2.12.4.4 Mitigation systems in use? [68.170(e)(4)]
2.12.4.5 Monitoring and detection systems in use? [68.170(e)(5)]
2.12.4.6 Changes since the last hazard review? [68.170(e)(6)]

2.12.5 The date of the most recent review or revision of operating procedures?
[68.170(f)]
2.12.6 The date of the most recent review or revision of training programs?
[68.170(g)]
2.12.6.1 The type of training provided — classroom, classroom plus on the job,
on the job? [68.170(g)(1)]
2.12.6.2 The type of competency testing used? [68.170(g)(2)]
2.12.7 The date of the most recent review or revision of maintenance
procedures and the date of the most recent equipment inspection or test and
the equipment inspected or tested? [68.170(h)]
2.12.8 The date of the most recent compliance audit and the expected date of
completion of any changes resulting from the compliance audit? [68.170(i)]
2.12.9 The date of the most recent incident investigation and the expected
date of completion of any changes resulting from the investigation? [68.170(j)]
2.12.10 The date of the most recent change that triggered a review or revision
of safety information, hazard review, operating or maintenance procedures, or
training? [68.170(k)]
RMP: Prevention Program/Program 3 [68.175]
2.13 Has the owner or operator included in the RMP information addressing
68.175(b) to 68.175(p)? [68.175(a)]
2.13.1 The NAICS code for the process? [68.175(b)]
2.13.2 The name(s) of the substance(s) covered? [68.175(c)]
2.13.3 The date on which the safety information was last reviewed or revised?
[68.175(d)]
2.13.4 The date of completion of the most recent process hazard analysis
(PHA) or update and the technique used? [68.175(e)]
2.13.4.1 The expected date of completion of any changes resulting from the
PHA? [68.175(e)(1)]
2.13.4.2 Major hazards identified? [68.175(e)(2)]
2.13.4.3 Process controls in use? [68.175(e)(3)]
2.13.4.4 Mitigation systems in use? [68.175(e)(4)]
2.13.4.5 Monitoring and detection systems in use? [68.175(e)(5)]
2.13.4.6 Changes since the last PHA? [68.175(e)(6)]
2.13.5 The date of the most recent review or revision of operating procedures?
[68.175(f)]
2.13.6 The date of the most recent review or revision of training programs?
[68.175(g)]
2.13.6.1 The type of training provided — classroom, classroom plus on the job,
on the job? [68.175(g)(1)]
2.13.6.2 The type of competency testing used? [68.175(g)(2)]

2.13.7 The date of the most recent review of revision of maintenance

procedures and the date of the most recent equipment inspection or test and
the equipment inspected of tested? [68.175(h)]
2.13.8 The date of the most recent change that triggered management of
change procedures and the date of the most recent review or revision of
management of change procedures? [68.175(i)]
2.13.9 The date of the most recent pre-startup review? [68.175(j)]
2.13.10 The date of the most recent compliance audit and the expected date of
completion of any changes resulting from the compliance audit? [68.175(k)]
2.13.11 The date of the most recent incident investigation and the expected
date of completion of any changes resulting from the investigation? [68.175(l)]
2.13.12 The date of the most recent review or revision of employee
participation plans? [68.175(m)] [68.175(p)]
2.13.13 The date of the most recent review or revision of hot work permit
procedures? [68.175(n)]
2.13.14 The date of the most recent review or revision of contractor safety
procedures? [68.175(o)]
2.13.15 The date of the most recent evaluation of contractor safety
performance? [68.175(p)]
RMP: Emergency Response Program [68.180]
2.14 Has the owner or operator included the following information in the
RMP on the emergency response program: [68.18]
2.14.1 Does a written emergency response plan exist? [68.180(a)(1)]
2.14.2 Does the plan include specific actions to be taken in response to an
accidental release of a regulated substance? [68.180(a)(2)]
2.14.3 Does the plan include procedures for informing the public and local
agencies responsible for responding to accidental releases? [68.180(a)(3)]
2.14.4 Does the plan include information on emergency health care? [68.
180(a)(4)]
2.14.5 Date of the most recent review of update of emergency response plan?
[68.180(a)(5)]
2.14.6 Date of the most recent emergency response training for employees?
[68.180(a)(6)]
2.15 Has the owner or operator provided the name and telephone number of
the local agency with which emergency response activities and the emergency
response plan is coordinated? [68.180(b)]
2.16 Has the owner or operator listed other federal or state emergency plan
requirements to which the stationary source is subject? [68.180(c)]
RMP: Certification [68.185]
2.17 Has the owner or operator: [68.185]
2.18 For Program 1 processes, submitted the certification statement in 68.
12(b)(4)? [68.185(a)]

2.19 For Program 2 or 3 processes, submitted the appropriate certification

statement that to the best of the signer’s knowledge, information, and belief
formed after reasonable inquiry, the information submitted is true, accurate,
and complete? [68.185(b)]
Hazard Assessment (Subpart B) [68.20 – 68.42]

Hazard Assessment: Applicability [68.20]
3.1 Has the owner or operator prepared a worst-case release scenario analysis
as provided in 68.25 and completed the five-year accident history as provided
in 68.42? [68.20]
Hazard Assessment: Offsite Consequence Analysis Parameters [68.22]
3.2 Has the owner or operator used the following endpoints for offsite
consequence analysis for a worst-case scenario: [68.22(a)]
3.2.1 For toxics: the endpoints provided in Appendix A of 40 CFR Part 68?
[68.22(a)(1)]
3.2.2 For flammables: an explosion resulting in an overpressure of 1 psi? [68.
22(a)(2)(i)]
3.3 Has the owner or operator used the following endpoints for offsite
consequence analysis for an alternative release scenario: [68.22(a)]
3.3.1 For toxics: the endpoints provided in Appendix A of 40 CFR Part 68?
[68.22(a)(1)]
3.3.2 For flammables: an explosion resulting in an overpressure of 1 psi? [68.
22(a)(2)(i)]
3.3.3 For flammables: a fire resulting in a radiant heat/exposure of 5 kw/m2
for 40 seconds? [68.22(a)(2)(ii)]
3.3.4 For flammables: a concentration resulting in a lower flammability limit,
as provided in NFPA documents or other generally recognized sources? [68.
22(a)(2)(iii)]
3.4 In the release analysis, has the owner or operator used appropriate values
for the following parameters:
3.4.1 Wind speed and atmospheric stability class?
3.4.2 Ambient temperature and humidity?
3.4.3 Height of the release?
3.4.4 Surface roughness?
3.4.5 Dense or neutrally buoyant gases?
3.4.6 Temperature of the released substance?
Hazard Assessment: Worst-case Release Scenario Analysis [68.25]
Has the owner or operator of Program 1 processes:
3.5.1 Analyzed and reported in the RMP one worst-case scenario for each
Program 1 process? [68.25(a)(1)]
3.6 Has the owner or operator of Program 2 or 3 processes:

3.6.1 Analyzed and reported in the RMP one worst-case release scenario
estimated to create the greatest distance to an endpoint resulting from an
accidental release of a regulated toxic substance from covered processes under
worst-case conditions? [68.25(a)(2)(i)]
3.6.2 Analyzed and reported in the RMP one worst-case release scenario
estimated to create the greatest distance to an endpoint resulting from an
accidental release of a regulated flammable substance from covered processes
under worst- case conditions? [68.25(a)(2)(ii)]
3.6.3 Analyzed and reported in the RMP additional worst-case release
scenarios for a hazard class if the a worst-case release from another covered
process at the stationary source potentially affects public receptors different
from those potentially affected by the worst-case release scenario developed
under 68.25(a)(2)(i) or 68.25(a) (2) (ii)? [68.25(a)(2)(iii)]
3.7 Has the owner or operator determined the worst-case release quantity to
be the greater of the following: [68.25(b)]
3.7.1 If released from a vessel, the greatest amount held in a single vessel,
taking into account administrative controls that limit the maximum quantity?
[68.25(b)(1)]
3.7.2 If released from a pipe, the greatest amount held in the pipe, taking
into account administrative controls that limit the maximum quantity? [68.
25(b)(2)]
3.8 For toxic substances that are normally gases at ambient temperature and
handled as a gas or liquid under pressure, has the owner or operator: [68.
25(c)(1)]
3.8.1 Assumed the whole quantity in the vessel or pipe would be released as a
gas over 10 minutes? [68.25(c)(1)]
3.8.2 Assumed the release rate to be the total quantity divided by 10, if there
are no passive mitigation systems in place? [68.25(c)(1)]
3.9 For toxic gases handled as refrigerated liquids at ambient pressure, has
the owner or operator: [68.25(c)(2)]
3.9.1 Assumed the substance would be released as a gas in 10 minutes, if not
contained by passive mitigation systems or if the contained pool would have a
depth of 1 cm or less? [68.25(c)(2)(i)]
3.9.2 Assumed the quantity in the vessel or pipe would be spilled
instantaneously to form a liquid pool, if the released substance would be
contained by passive mitigation systems in a pool with a depth greater than 1
cm? [68.25(c)(2)(ii)]
3.9.3 Calculated the volatilization rate at the boiling point of the substance
and at the conditions specified in 68.25(d)? [68.25(c)(2)(ii)]
3.10 For toxic substances that are normally liquids at ambient temperature,
has the owner or operator: [68.25(d)]
3.10.1 Assumed the quantity in the vessel or pipe would be spilled
instantaneously to form a liquid pool? [68.25(d)(1)]

3.10.2 Determined the surface area of the pool by assuming that the liquid
spreads to 1 cm deep, if there is no passive mitigation system in place that
would serve to contain the spill and limit the surface area, or if passive
mitigation is in place, the surface area of the contained liquid shall be used to
calculate the volatilization rate? [68.25(d)(1)(i)]
3.10.3 Taken into account the actual surface characteristics, if the release
would occur onto a surface that is not paved or smooth? [68.25(d)(1)(ii)]
3.10.4 Determined the volatilization rate by accounting for the highest daily
maximum temperature in the past three years, the temperature of the
substance in the vessel, and the concentration of the substance if the liquid
spilled is a mixture or solution? [68.25(d)(2)]
3.10.5 Determined the rate of release to air from the volatilization rate of the
liquid pool? [68.25(d)(3)]
3.10.6 Determined the rate of release to air by using the methodology in the
RMP Offsite Consequence Analysis Guidance? Any other publicly available
techniques that account for the modeling conditions and are recognized by
industry as applicable as part of current practices, or proprietary models that
account for the modeling conditions may be used provided the owner or
operator allows the implementing agency access to the model and describes
model features and differences from publicly available models to local
emergency planners upon request. [68.25(d)(3)]
3.11 For flammables, has the owner or operator:
3.11.1 Assumed the quantity in a vessel(s) of flammable gas held as a gas or
liquid under pressure or refrigerated gas released to an undiked area
vaporizes resulting in a vapor cloud explosion? [68.25(e)]
3.11.2 For refrigerated gas released to a contained area or liquids released
below their atmospheric boiling point, assumed the quantity volatilized in 10
minutes results in a vapor cloud? [68.25(f)]
3.11.3 Assumed a yield factor of 10% of the available energy is released in the
explosion for determining the distance to the explosion endpoint, if the model
used is based on TNT-equivalent methods? [68.25(e)]
3.12 Has the owner or operator used the parameters defined in 68.22 to
determine distance to the endpoints? [68.25(g)]
3.13 Has the owner or operator determined the rate of release to air by using
the methodology in the RMP Offsite Consequence Analysis Guidance, any
other publicly available techniques that account for the modeling conditions
and are recognized by industry as applicable as part of current practices, or
proprietary models that account for the modeling conditions? [68.25(g)]
3.13.1 Modeling technique used: ____________________________
3.14 Has the owner or operator ensured that any passive mitigation system
considered for the worst case analysis is capable of withstanding the release
event triggering the scenario and will still function as intended? [68.25(h)]

3.15 Has the owner or operator considered selecting a scenario involving a

smaller quantity handled at higher process temperature or pressure, or
located closer to the boundary of the stationary source, if such a scenario
would result in a greater distance to an endpoint beyond the stationary
source boundary? [68.25(i)]
Hazard Assessment: Alternative Release Scenario Analysis [68.28]
3.16 Has the owner or operator identified and analyzed at least one
alternative release scenario for each regulated toxic substance held in covered
processes and at least one alternative release scenario to represent all
flammable substances held in covered processes? [68.28(a)]
3.17 Has the owner or operator selected a scenario: [68.28(b)]
3.17.1 That is more likely to occur than the worst-case release scenario under
68.25? [68.28(b)(1)(i)]
3.17.2 That will reach an endpoint off-site, unless no such scenario exists?
[68.28(b)(1)(ii)]
3.18 Has the owner or operator considered release scenarios which included,
but are not limited to, the following: [68.28(b)(2)]
3.18.1 Transfer hose releases due to splits or sudden hose uncoupling? [68.
28(b)(2)(i)]
3.18.2 Process piping releases from failures at flanges, joints, welds, valves
and valve seals, and drains or bleeds? [68.28(b)(2)(ii)]
3.18.3 Process vessel or pump releases due to cracks, seal failure, or drain,
bleed, or plug failure? [68.28(b)(2)(iii)]
3.18.4 Vessel overfilling and spill, or overpressurization and venting through
relief valves or rupture disks? [68.28(b)(2)(iv)]
3.18.5 Shipping container mishandling and breakage or puncturing leading to
a spill? [68.28(b)(2)(v)]
3.19 Used the parameters defined in 68.22 to determine distance to the
endpoints? [68.28(c)]
3.20 Has the owner or operator determined the rate of release to air by using
the methodology in the RMP Offsite Consequence Analysis Guidance, any
other publicly available techniques that account for the modeling conditions
and are recognized by industry as applicable as part of current practices, or
proprietary models that account for the modeling conditions? [68.28(c)]
3.21 Has the owner or operator ensured that the passive and active
mitigation systems, if considered, are capable of withstanding the release
event triggering the scenario and will be functional? [68.28(d)]
3.22 Has the owner or operator considered the following factors in selecting
the alternative release scenarios: [68.25(e)]
3.22.1 The five-year accident history provided in 68.42? [68.25(e)(1)]
3.22.2 Failure scenarios identified under 68.50 or 68.67? [68.25(e)(2)]

Hazard Assessment: Defining Off-site Impacts – Population [68.30]

Has the owner or operator:
3.23 Estimated population that would be included in the distance to the
endpoint in the RMP based on a circle with the point of release at the center?
[68.30(a)]
3.24 Identified the presence of institutions, parks and recreational areas,
major commercial, office, and industrial buildings in the RMP? [68.30(b)]
3.25 Used most recent Census data, or other updated information to estimate
the population? [68.30(c)]
3.26 Estimated the population to two significant digits? [68.30(d)]
Hazard Assessment: Defining Off-site Impacts – Environment [68.33]
3.27 Identified environmental receptors that would be included in the
distance to the endpoint based on a circle with the point of release at the
center? [68.33(a)]
3.28 Relied on information provided on local U.S.G.S. maps, or on any data
source containing U.S.G.S. data to identify environmental receptors? (Source
may have used U.S. Census Bureau LandView® software to obtain
information ] [68.33(b)]
Hazard Assessment: Review and Update [68.36]
3.29 Reviewed and updated the off-site consequence analyses at least once
every five years? [68.36(a)]
3.30 Completed a revised analysis and submit a revised RMP within six
months of a change in processes, quantities stored or handled, or any other
aspect that might reasonably be expected to increase or decrease the distance
to the endpoint by a factor of two or more? [68.36(b)]
Hazard Assessment: Documentation [68.39]
3.31 For worst-case scenarios: a description of the vessel or pipeline and
substance selected, assumptions and parameters used, the rationale for
selection, and anticipated effect of the administrative controls and passive
mitigation on the release quantity and rate? [68.39(a)]
3.32 For alternative release scenarios: a description of the scenarios
identified, assumptions and parameters used, the rationale for the selection of
specific scenarios, and anticipated effect of the administrative controls and
mitigation on the release quantity and rate?[68.39(b)]
3.33 Documentation of estimated quantity released, release rate, and
duration of release? [68.39(c)]
3.34 Methodology used to determine distance to endpoints? [68.39(d)]
3.35 Data used to estimate population and environmental receptors
potentially affected? [68.39(e)]

Hazard Assessment: Five-Year Accident History [68.42]

3.36 Has the owner or operator included all accidental releases from covered
processes that resulted in deaths, injuries, or significant property damage on
site, or known offsite deaths, injuries, evacuations, sheltering in place,
property damage, or environmental damage? [68.42(a)]
3.37 Has the owner or operator reported the following information for each
accidental release: [68.42(b)]
3.37.1 Date, time, and approximate duration of the release? [68.42(b)(1)]
3.37.2 Chemical(s) released? [68.42(b)(2)]
3.37.3 Estimated quantity released in pounds and percentage weight in a
mixture (toxics)? [68.42(b)(3)]
3.37.4 NAICS code for the process? [68.42(b)(4)
3.37.5 The type of release event and its source? [68.42(b)(5)]
3.37.6 Weather conditions (if known)? [68.42(b)(6)]
3.37.7 On-site impacts? [68.42(b)(7)]
3.37.8 Known offsite impacts? [68.42(b)(8)]
3.37.9 Initiating event and contributing factors (if known)? [68.42(b)(9)]
3.37.10 Whether offsite responders were notified (if known)? [68.42(b)(10)]
3.37.11 Operational or process changes that resulted from investigation of the
release? [68.42(b)(11)]
Program 2 Prevention Program (Subpart C) [68.48 – 68.60]

Program 2 Prevention: Safety Information [68.48]
4.1 Compiled and maintained the following up-to-date safety information,
related to the regulated substances, processes, and equipment: [68.48(a)]
4.1.1 Safety Data Sheets (SDSs) that meet the requirements of the OSHA
Hazard Communication Standard [29 CFR 1910.1200(g)]? [68.48(a)(1)]
4.1.2 Maximum intended inventory of equipment in which the regulated
substances are stored or processed? [68.48(a)(2)]
4.1.3 Safe upper and lower temperatures, pressures, flows, and compositions?
[68.48(a)(3)]
4.1.4 Equipment specifications? [68.48(a)(4)]
4.1.5 Codes and standards used to design, build, and operate the process? [68.
48(a)(5)]
4.2 Ensured the process is designed in compliance with recognized and
generally accepted good engineering practices? [68.48(b)]
4.3 Updated information if a major change has occurred that made the
information inaccurate? [68.48(c)]

Program 2 Prevention: Hazard Review [68.50]

4.4 Has the owner or operator conducted a review of the hazards associated
with the regulated substances, processes, and procedures? [68.50(a)]
4.5 Did the review identify:
4.5.1 The hazards associated with the process and regulated substances? [68.
50(a)(1)]
4.5.2 Opportunities for equipment malfunctions or human errors that could
cause an accidental release? [68.50(a)(2)]
4.5.3 The safeguards used or needed to control the hazards or prevent
equipment malfunctions or human error? [68.50(a)(3)]
4.5.4 Any steps used or needed to detect or monitor releases? [68.50(a)(4)]
4.6 Determined by inspecting all equipment that the processes are designed,
fabricated, and operated in accordance with applicable standards or rules, if
designed to meet industry standards or federal or state design rules? [68.
50(b)]
4.7 Documented the results of the review? [68.50(c)]
4.8 Ensured that problems identified were resolved in a timely manner? [68.
50(c)]
4.9 Updated the review at least once every five years or whenever a major
change in the processes occurred? [68.50(d)]
4.10 Resolved all issues identified in the review before startup of the changed
process? [68.50(d)]
Program 2 Prevention: Operating Procedures [68.52]
4.11 Has the owner or operator prepared written operating procedures that
provide clear instructions or steps for safely conducting activities associated
with each covered process consistent with the safety information for that
process? [68.52(a)]
4.12 Do the procedures address the following: [68.52(b)]
4.12.1 Initial startup? [68.52(b)(1)]
4.12.2 Normal operations? [68.52(b)(2)]
4.12.3 Temporary operations? [68.52(b)(3)]
4.12.4 Emergency shutdown and operations? [68.52(b)(4)]
4.12.5 Normal shutdown? [68.52(b)(5)]
4.12.6 Startup following a normal or emergency shutdown or a major change
that requires a hazard review? [68.52(b)(6)]
4.12.7 Consequences of deviations and steps required to correct or avoid
deviations? [68.52(b)(7)]
4.12.8 Equipment inspections? [68.52(b)(8)]

4.13 Has the owner or operator ensured that the operating procedures have
been updated, if necessary, whenever a major change occurred and prior to
startup of the changed process? [68.52(c)]
Program 2 Prevention: Training [68.54]
4.14 Certified that each employee presently operating a process, and each
employee newly assigned to a covered process have been trained or tested
competent in the operating procedures provided in §68.52 that pertain to
their duties? [68.54(a)]
4.15 Provided refresher training at least every three years, or more often if
necessary, to each employee operating a process, to ensure that the employee
understands and adheres to the current operating procedures of the process?
[68.54(b)]
4.16 Determined, in consultation with the employees operating the process,
the appropriate frequency of refresher training? [68.54(b)]
4.17 Certified that each employee was trained in any updated or new
procedures prior to startup of a process after a major change? [68.54(d)]
Program 2 Prevention: Maintenance [68.56]
4.18 Prepared and implemented procedures to maintain the ongoing
mechanical integrity of the process equipment? [68.56(a)]
4.19 Trained or caused to be trained each employee involved in maintaining
the on-going mechanical integrity of the process, in the hazards of the
process, in how to avoid or correct unsafe conditions, and in the procedures
applicable to the employee’s job tasks? [68.56(b)]
4.20 Has every maintenance contractor ensured that each contract
maintenance employee is trained to perform the maintenance procedures
developed? [68.56(c)]
4.21 Has the owner or operator performed or caused to be performed
inspections and tests on process equipment that follow recognized and
generally accepted engineering practices? [68.56(d)]
Program 2 Prevention: Compliance Audits [68.58]
4.22 Has the owner or operator certified that compliance audits are conducted
at least every three years to verify that the procedures and practices are
adequate and are being followed? [68.58(a)]
4.23 Has compliance audit been conducted by at least one person
knowledgeable in the process? [68.58(b)]
4.24 Has the owner operator developed a report of the audits findings? [68.
58(c)]
4.25 Has the owner or operator promptly determined and documented an
appropriate response to each of the findings of the audit and documented that
deficiencies had been corrected? [68.58(d)]

4.26 Has the owner or operator retained the two most recent compliance
audit reports, unless more than five years old? [68.58(e)]
Program 2 Prevention: Incident Investigation [68.60]
4.27 Has the owner or operator investigated each incident which resulted in,
or could reasonably have resulted in a catastrophic release? [68.60(a)]
4.28 Were all incident investigations initiated not later than 48 hours
following the incident? [68.60(b)]
4.29 Was a summary prepared at the conclusion of every investigation, which
included: [68.60(c)]
4.29.1 Date of incident? [68.60(c)(1)]
4.29.2 Date investigation began? [68.60(c)(2)]
4.29.3 A description of incident? [68.60(c)(3)]
4.29.4 The factors that contributed to the incident? [68.60(c)(4)]
4.29.5 Any recommendations resulting from the investigation? [68.60(c)(5)]
4.30 Has the owner or operator promptly addressed and resolved the
investigation findings and recommendations, and are the resolutions and
corrective actions documented? [68.60(d)]
4.31 Has the owner or operator reviewed the finding with all affected
personnel whose job tasks are affected by the findings? [68.60(e)]
4.32 Has the owner or operator retained investigation summaries for five
years? [68.60(f)]
Program 3 Prevention Program (Subpart D) [68.65 – 68.87]
Program 3 Prevention: Process Safety Information [68.65]

5.1 Has the owner or operator compiled written process safety information,
which includes information pertaining to the hazards of the regulated
substances used or produced by the process, information pertaining to the
technology of the process, and information pertaining to the equipment in the
process, before conducting any process hazard analysis required by the rule?
[68.65(a)]
5.2 Does the process safety information contain the following for hazards of
the substances: [68.65(b)]
5.2.1 Toxicity information? [68.65(b)(1)]
5.2.2 Permissible exposure limits? [68.65(b)(2)]
5.2.3 Physical data? [68.65(b)(3)]
5.2.4 Reactivity data? [68.65(b)(4)]
5.2.5 Corrosivity data? [68.65(b)(5)]
5.2.6 Thermal and chemical stability data? [68.65(b)(6)]
5.2.7 Hazardous effects of inadvertent mixing of materials that could
foreseeably occur? [68.65(b)(7)]

5.3 Does the process safety information contain the following for technology of
the process: [68.65(c)(1)]
5.3.1 A block flow diagram or simplified process flow diagram? [68.65(c)(1)(i)]
5.3.2 Process chemistry? [68.65(c)(1)(ii)]
5.3.3 Maximum intended inventory? [68.65(c)(1)(iii)]
5.3.4 Safe upper and lower limits for such items as temperatures, pressures,
flows or compositions? [68.65(c)(1)(iv)]
5.3.5 An evaluation of the consequences of deviations? [68.65(c)(1)(v)]
5.4 Does the process safety information contain the following for the
equipment in the process: [68.65(d)(1)]
5.4.1 Materials of construction? [68.65(d)(1)(i)]
5.4.2 Piping and instrument diagrams? [68.65(d)(1)(ii)]
5.4.3 Electrical classification? [68.65(d)(1)(iii)]
5.4.4 Relief system design and design basis? [68.65(d)(1)(iv)]
5.4.5 Ventilation system design? [68.65(d)(1)(v)]
5.4.6 Design codes and standards employed? [68.65(d)(1)(vi)]
5.4.7 Material and energy balances for processes built after June 21, 1999?
[68.65(d)(1)(vii)]
5.4.8 Safety systems? [68.65(d)(1)(viii)]
5.5 Has the owner or operator documented that equipment complies with
recognized and generally accepted good engineering practices? [68.65(d)(2)]
5.6 Has the owner or operator determined and documented that existing
equipment, designed and constructed in accordance with codes, standards, or
practices that are no longer in general use, is designed, maintained,
inspected, tested, and operating in a safe manner? [68.65(d)(3)]
5.7 Has the owner or operator performed an initial process hazard analysis
(PHA), and has this analysis identified, evaluated, and controlled the hazards
involved in the process? [68.67(a)]
5.8 Has the owner or operator determined and documented the priority order
for conducting PHAs, and was it based on an appropriate rationale? [68.67(a)]
5.9 Has the owner or operator used one or more of the following technologies:
[68.67(b)]
5.9.1 What-If? [68.67(b)(1)]
5.9.2 Checklist? [68.67(b)(2)]
5.9.3 What-If/Checklist? [68.67(b)(3)]
5.9.6 Fault Tree Analysis? [68.67(b)(6)]
5.9.7 An appropriate equivalent methodology? [68.67(b)(7)]
5.9.4 Hazard and Operability Study (HAZOP)? [68.67(b)(4)]
5.9.5 Failure Mode and Effects Analysis (FMEA)? [68.67(b)(5)]

5.10 Did the PHA address: [68.67(c)]

5.10.1 The hazards of the process? [68.67(c)(1)]
5.10.2 Identification of any incident which had a likely potential for
catastrophic consequences? [68.67(c)(2)]
5.10.3 Engineering and administrative controls applicable to hazards and
interrelationships? [68.67(c)(3)]
5.10.4 Consequences of failure of engineering and administrative controls?
[68.67(c)(4)]
5.10.5 Stationary source siting? [68.67(c)(5)]
5.10.6 Human factors? [68.67(c)(6)]
5.10.7 An evaluation of a range of the possible safety and health effects of
failure of controls? [68.67(c)(7)]
5.11 Was the PHA performed by a team with expertise in engineering and
process operations and did the team include appropriate personnel? [68.67(d)]
5.12 Has the owner or operator established a system to promptly address the
team’s findings and recommendations; assured that the recommendations are
resolved in a timely manner and documented; documented what actions are
to be taken; completed actions as soon as possible; developed a written
schedule of when these actions are to be completed; and communicated the
actions to operating, maintenance and other employees whose work
assignments are in the process and who may be affected by the
recommendations? [68.67(e)]
5.13 Has the PHA been updated and revalidated by a team every five years
after the completion of the initial PHA to assure that the PHA is consistent
with the current process? [68.67(f)]
5.14 Has the owner or operator retained PHAs and updates or revalidations
for each process covered, as well as the resolution of recommendations for the
life of the process? [68.67(g)]
Program 3 Prevention: Operating procedures [68.69]
5.15 Has the owner or operator developed and implemented written operating
procedures that provide instructions or steps for conducting activities
associated with each covered process consistent with the safety information?
[68.69(a)]
5.16 Do the procedures address the following: [68.69(a)]
5.16.1 Steps for each operating phase? [68.69(a)(1)]
5.16.1.1 Initial startup? [68.69(a)(1)(i)]
5.16.1.2 Normal operations? [68.69(a)(1)(ii)]
5.16.1.3 Temporary operations? [68.69(a)(1)(iii)]
5.16.1.4 Emergency shutdown including the conditions under which
emergency shutdown is required, and the assignment of shutdown
responsibility to qualified operators to ensure that emergency shutdown is
executed in a safe and timely manner? [68.69(a)(1)(iv)]

5.16.1.5 Emergency operations? [68.69(a)(1)(v)]

5.16.1.6 Normal shutdown? [68.69(a)(1)(vi)]
5.16.1.7 Startup following a turnaround, or after emergency shutdown? [68.
69(a)(1)(vii )]
5.16.2 Operating limits: [68.69(a)(2)]
5.16.2.1 Consequences of deviations? [68.69(a)(2)(i)]
5.16.2.2 Steps required to correct or avoid deviations? [68.69(a)(2)(ii)]
5.16.3 Safety and health considerations: [68.69(a)(3)]
5.16.3.1 Properties of, and hazards presented by, the chemicals used in the
process? [68.69(a)(3)(i)]
5.16.3.2 Precautions necessary to prevent exposure, including engineering
controls, administrative controls, and personal protective equipment? [68.
69(a)(3)(ii)]
5.16.3.3 Control measures to be taken if physical contact or airborne exposure
occurs? [68.69(a)(3)(iii)]
5.16.3.4 Quality control for raw materials and control of hazardous chemical
inventory levels? [68.69(a)(3)(iv)]
5.16.3.5 Any special or unique hazards? [68.69(a)(3)(v)]
5.16.4 Safety systems and their functions? [68.69(a)(4)]
5.17 Are operating procedures readily accessible to employees who are
involved in a process? [68.69(b)]
5.18 Has the owner or operator certified annually that the operating
procedures are current and accurate and that procedures have been reviewed
as often as necessary? [68.69(c)]
5.19 Has the owner or operator developed and implemented safe work
practices to provide for the control of hazards during specific operations, such
as logout/tagout? [68.69(d)]
Program 3 Prevention: Training [68.71]
5.20 Has each employee presently involved in operating a process, and each
employee before being involved in operating a newly assigned process, been
initially trained in an overview of the process and in the operating
procedures? [68.71(a)(1)]
5.21 Did initial training include emphasis on safety and health hazards,
emergency operations including shutdown, and safe work practices applicable
to the employee’s job tasks? (68.71(a)(2) allows in lieu of initial training for
those employees already involved in operating a process on June 21, 1999, an
owner or operator may certify in writing that the employee has the required
knowledge, skills, and abilities to safely carry out the duties and
responsibilities as specified in the operating procedures) [68.71(a)(1)]
5.22 Has refresher training been provided at least every three years, or more
often if necessary, to each employee involved in operating a process to assure
that the employee understands and adheres to the current operating
procedures of the process? [68.71(b)]

5.23 Has owner or operator ascertained and documented in a record that each
employee involved in operating a process has received and understood the
training required? [68.71(c)]
5.24 Does the prepared record contain the identity of the employee, the date
of training, and the means used to verify that the employee understood the
training? [68.71(c)]
Program 3 Prevention: Mechanical integrity [68.73]
5.25 Has the owner or operator established and implemented written
procedures to maintain the on-going integrity of the process equipment listed
in 68.73(a)? [68.73(b)]
5.26 Has the owner or operator trained each employee involved in
maintaining the on-going integrity of process equipment? [68.73(c)]
5.27 Performed inspections and tests on process equipment? [68.73(d)(1)]
5.28 Followed recognized and generally accepted good engineering practices
for inspection and testing procedures? [68.73(d)(2)]
5.29 Ensured the frequency of inspections and tests of process equipment is
consistent with applicable manufacturers’ recommendations, good engineering
practices, and prior operating experience? [68.73(d)(3)]
5.30 Documented each inspection and test that had been performed on
process equipment, which identifies the date of the inspection or test, the
name of the person who performed the inspection or test, the serial number
or other identifier of the equipment on which the inspection or test was
performed, a description of the inspection or test performed, and the results
of the inspection or test? [68.73(d)(4)]
5.31 Corrected deficiencies in equipment that were outside acceptable limits
defined by the process safety information before further use or in a safe and
timely manner when necessary means were taken to assure safe operation?
[68.73(e)]
5.32 Assured that equipment as it was fabricated is suitable for the process
application for which it will be used in the construction of new plants and
equipment? [68.73(f)(1)]
5.33 Performed appropriate checks and inspections to assure that equipment
was installed properly and consistent with design specifications and the
manufacturer’s instructions? [68.73(f)(2)]
5.34 Assured that maintenance materials, spare parts and equipment were
suitable for the process application for which they would be used? [68.73(f)(3)]
Program 3 Prevention: Management of change [68.75]
5.35 Has the owner or operator established and implemented written
procedures to manage changes to process chemicals, technology, equipment,
and procedures, and changes to stationary sources that affect a covered
process? [68.75(a)]
5.36 Do procedures assure that the following consideration are addressed
prior to any change: [68.75(b)]

5.36.1 The technical basis for the proposed change? [68.75(b)(1)]

5.36.2 Impact of change on safety and health? [68.75(b)(2)]
5.36.3 Modifications to operating procedures? [68.75(b)(3)]
5.36.4 Necessary time period for the change? [68.75(b)(4)]
5.36.5 Authorization requirements for the proposed change? [68.75(b)(5)]
5.37 Were employees, involved in operating a process and maintenance, and
contract employees, whose job tasks would be affected by a change in the
process, informed of, and trained in, the change prior to start-up of the
process or affected part of the process? [68.75(c)]
5.38 If a change resulted in a change in the process safety information, was
such information updated accordingly? [68.75(d)]
5.39 If a change resulted in a change in the operating procedures or practices,
had such procedures or practices been updated accordingly? [68.75(e)]
Program 3 Prevention: Pre-startup review [68.77]
5.40 Has the owner or operator performed a pre-startup safety review for new
stationary sources and for modified stationary sources when the modification
was significant enough to require a change in the process safety information?
[68.77(a)]
5.41 Did the pre-startup safety review confirm that prior to the introduction
of regulated substances to a process: [68.77(b)]
5.41.1 Construction and equipment was in accordance with design
specifications? [68.77(b)(1)]
5.41.2 Safety, operating, maintenance, and emergency procedures were in
place and were adequate? [68.77(b)(2)]
5.41.3 For new stationary sources, a process hazard analysis had been
performed and recommendations had been resolved or implemented before
startup? [68.77(b)(3)]
5.41.4 Modified stationary sources meet the requirements contained in
management of change? [68.77(b)(3)]
5.41.5 Training of each employee involved in operating a process had been
completed? [68.77(b)(4)]
Program 3 Prevention: Compliance audits [68.79]
5.42 Has the owner or operator certified that the stationary source has
evaluated compliance with the provisions of the prevention program at least
every three years to verify that the developed procedures and practices are
adequate and are being followed? [68.79(a)]
5.43 Has the audit been conducted by at least one person knowledgeable in
the process? [68.79(b)]
5.44 Are the audits findings documented in report? [68.79(c)]
5.45 Has the owner or operator promptly determined and documented an
appropriate response to each of the findings of the audit and documented that
deficiencies had been corrected? [68.79(d)]

5.46 Has the owner or operator retained the two most recent compliance
audit reports? [68.79(e)]
Program 3 Prevention: Incident investigation [68.81]
5.47 Has the owner or operator investigated each incident which resulted in,
or could reasonably have resulted in a catastrophic release of a regulated
substance? [68.81(a)]
5.48 Were all incident investigations initiated not later than 48 hours
following the incident? [68.81(b)]
5.49 Was an incident investigation team established and did it consist of at
least one person knowledgeable in the process involved, including a contract
employee if the incident involved work of the contractor, and other persons
with appropriate knowledge and experience to thoroughly investigate and
analyze the incident? [68.81(c)]
5.50 Was a report prepared at the conclusion of every investigation? [68.81(d)]
5.51 Does every report include: [68.81(d)]
5.51.1 Date of incident? [68.81(d)(1)]
5.51.2 Date investigation began? [68.81(d)(2)]
5.51.3 A description of the incident? [68.81(d)(3)]
5.51.4 The factors that contributed to the incident? [68.81(d)(4)]
5.51.5 Any recommendations resulting from the investigation? [68.81(d)(5)]
5.52 Has the owner or operator established a system to address and resolve
the report findings and recommendations, and are the resolutions and
corrective actions documented? [68.81(e)]
5.53 Was the report reviewed with all affected personnel whose job tasks are
relevant to the incident findings including contract employees where
applicable? [68.81(f)]
Program 3 Prevention: Employee participation [68.83]
5.54 Developed a written plan of action regarding the implementation of the
employee participation required by this section? [68.83(a)]
5.55 Consulted with employees and their representatives on the conduct and
development of process hazards analyses and on the development of the other
elements of process safety management in chemical accident prevention
provisions? [68.83(b)]
5.56 Provided to employees and their representatives access to process hazard
analyses and to all other information required to be developed under chemical
accident prevention rule? [68.83(c)]
Program 3 Prevention: Hot work permit [68.85]
5.57 Has the owner or operator issued a hot work permit for each hot work
operation conducted on or near a covered process? [68.85(a)]

5.58 Does the permit document that the fire prevention and protection
requirements in 29 CFR 1910.252(a) have been implemented prior to
beginning the hot work operations? [68.85(b)]
5.59 Does the permit indicate the date(s) authorized for hot work and the
object on which hot works to be performed? [68.85(b)]
5.60 Are the permits being kept on file until completion of the hot work
operations? [68.85(b)]
Program 3 Prevention: Contractors [68.87]
5.61 Obtained and evaluated information regarding the contract owner or
operator’s safety performance and programs when selecting a contractor? [68.
87(b)(1)]
5.62 Informed contract owner or operator of the known potential fire,
explosion, or toxic release hazards related to the contractor’s work and the
process? [68.87(b)(2)]
5.63 Explained to the contract owner or operator the applicable provisions of
emergency response program? [68.87(b)(3)]
5.64 Developed and implemented safe work practices consistent with §68.
69(d), to control the entrance, presence, and exit of the contract owner or
operator and contract employees in covered process areas? [68.87(b)(4)]
Emergency Response (Subpart E) [68.90 – 68.95]
Emergency Response: Applicability [68.90]

6.1 Has the owner or operator of a stationary source developed an emergency
response program, unless the source need not comply? [68.90(a)]
If the employees of the stationary source will not respond to accidental
releases of regulated substances:
6.2 For stationary sources with any regulated toxic substance held in a
process above the threshold quantity, is the stationary source included in the
community emergency response plan developed under EPCRA? [68.90(b)(1)]
6.3 For stationary sources with only regulated flammable substances held in
a process above the threshold quantity, has the owner or operator coordinated
response actions with the local fire department? [68.90(b)(2)]
6.4 Are appropriate mechanisms in place to notify emergency responders
when there is a need for a response? [68.90(b)(3)]
Emergency Response Program [68.95]
6.5 Has the owner or operator developed and implemented an emergency
response program for the purpose of protecting public health and the
environment? [68.95(a)]
6.6 Does the program include the following elements: [68.95(a)]
6.6.1 An emergency response plan which is maintained at the stationary
source? [68.95(a)(1)]

6.6.2 Procedures for the use of emergency response equipment and for its
inspection, testing, and maintenance? [68.95(a)(2)]
6.6.3 Training for all employees in relevant procedures? [68.95(a)(3)]
6.6.4 Procedures to review and update, as appropriate, the emergency
response plan to reflect changes at the stationary source and ensure that
employees are informed of changes? [68.95(a)(4)]
6.7 Does the emergency response plan contain the following elements: [68.
95(a)(1)]
6.7.1 Procedures for informing the public and local emergency response
agencies about accidental releases? [68.95(a)(1)(i)(iii)]
6.7.2 Documentation of proper first-aid and emergency medical treatment
necessary to treat accidental human exposures? [68.95(a)(1)(ii)]
6.7.3 Procedures and measures for emergency response after an accidental
release of a regulated substance? [68.95(a)(1)]
6.8 Did the owner or operator use a written plan that complies with other
federal contingency plan regulations or is consistent with the approach in the
National Response Team’s Integrated Contingency Plan Guidance (One Plan)?
If so, does the plan include the elements provided in paragraph (a) of 68.95,
and also complies with paragraph (c) of 68.95? [68.95(b)]
6.9 Has the emergency response plan been coordinated with the community
emergency response plan developed under EPCRA? [68.95(c)]
6.10 Has the owner or operator provided to the local emergency response
officials information necessary for developing and implementing the
community emergency response plan requested by the LEPC or emergency
response officials? [68.95(c)]
Executive Order 13650: Improving Chemical Facility Safety and Security

On October 1, 2013, in response to several high-profile disasters involving chemical facilities
in the United States, President Obama signed Executive Order 13650: Improving Chemical
Facility Safety and Security. The Order calls for the establishment of a Chemical Facility
Safety and Security Working Group made up of several federal agencies and state and local
governments.
Under the Order, EPA and OSHA must review the chemical hazards covered by the Risk
Management Program and the Process Safety Management Standards to determine if either
program can or should be expanded to cover other regulated substances and types of
hazards. Both agencies need to develop a plan, including a timeline and resource require-
ments, to expand, implement, and enforce expanded regulatory programs.
In addition, the Department of Homeland Security must identify a list of chemicals, includ-
ing poisons and reactive substances that should be considered for addition to the Chemical
Facility Anti-Terrorism Standards (CFATS) Chemicals of Interest list.
Find the Executive Order at www.bit.ly/EOchemicals60G.

TSCA
CONTENTS
Overview ......................................................................................................... 3
The Statute ................................................................................................ 4
Subchapter I — Control of toxic substances.............................................................. 4
Chemical Data Reporting Rule .............................................................................. 5
TSCA inventory ........................................................................................... 5
Inventory Update Reporting (IUR) rule ............................................................. 5
2011 amendments — Chemical Data Reporting (CDR) rule .................................... 5
New chemicals program and premanufacture notices (PMNs) ................................. 6
Existing chemicals program.......................................................................... 6B
Chemical Right-to-Know Initiative ................................................................... 7
TSCA enforcement ....................................................................................... 8
TSCA and exports .............................................................................................. 8
Polychlorinated biphenyls (PCBs) .......................................................................... 9
PCBs and fluorescent lighting fixtures............................................................. 10
PCBs, disposal and manifesting requirements ................................................... 10
Subchapter II — Asbestos Hazard Emergency Response ............................................ 13
How are people exposed to asbestos? ............................................................... 14
Where is asbestos commonly found?................................................................ 14
Health effects ............................................................................................ 14
Asbestos regulations ................................................................................... 15
Cross-reference of asbestos regulations ............................................................ 15
Other EPA regulations governing asbestos........................................................ 16
National emission standards for hazardous air pollutants .................................... 16
Subchapter III — Indoor Radon Abatement ............................................................ 17
Indoor radon abatement............................................................................... 17
Subchapter IV — Lead-Based Paint Exposure Reduction Act ...................................... 18
Lead-Based Paint Exposure Reduction Act ....................................................... 18
Effective dates for renovation, repair, and painting program rule ........................... 19
Enforcement dates ...................................................................................... 20
Information for contractors ........................................................................... 20
Fee rule ................................................................................................... 22
Future of TSCA ............................................................................................... 22
9/14 TSCA TOC–1

Reserved
2–TSCA TOC 9/14

Overview
Congress signed the Toxic substances Control Act (TSCA) into law in October 1976. The Act
authorizes EPA to discover and maintain information on all new and existing chemical
substances. EPA must also control any of the substances that are determined to cause an
unreasonable risk to public health or the environment.
All manufacturers, importers, processors, distributors, and users of chemical substances in

the U.S. may be subject to TSCA chemical reporting, recordkeeping, and testing
requirements. Typical industries covered by TSCA include those engaged in chemical produc-
tion and importation, petroleum refining, paper production, and micro-electronics
manufacturing.
TSCA’s two main purposes are to:

• Control, test, regulate, and screen all manufactured, imported, or processed toxic
chemical substances to minimize their risk to health or the environment, and
• Disseminate information and risk assessments to government organizations, the pri-
vate sector, and other interested parties.
The Act authorizes EPA to establish and regulate chemical substances under 40 CFR 700
through 799. TSCA requires that any chemical that reaches the consumer marketplace be
tested for possible toxic effects prior to commercial manufacture. Any existing chemical that
poses health and environmental hazards is tracked and reported under TSCA. Procedures
also are authorized for corrective action under TSCA in cases of cleanup of toxic materials
contamination. TSCA supplements other federal statutes, including the Clean Air Act and
the Toxic Release Inventory under the Emergency Planning and Community Right to Know
Act (EPCRA).
Substances not covered by TSCA include pesticides, tobacco, foods, food additives, drugs, and
cosmetics (these substances are regulated elsewhere).
3/13 TSCA–3

Since the enactment of TSCA, EPA has screened more than 70,000 new toxic chemicals
before they were introduced into commercial uses. As a result of these pre-screening chemi-
cal reviews, more than 500 individual chemicals are subject to specific agency administrative
orders requiring workplace or manufacturing controls.
The Statute
TSCA is divided into four titles:
Subchapter I — Control of Toxic Substances (40 CFR 700-766) This title includes pro-
visions for the testing of existing chemical substances and mixtures, regulation of hazardous
chemical substances and mixtures, and manufacture and processing notices, in addition to
managing imminent hazards and reporting and recordkeeping requirements.
Subchapter II — Asbestos Hazard Emergency Response (40 CFR 763) This title was
added by the Asbestos Hazard Emergency Response Act (AHERA) (P.L. 99-519), which
passed on October 22, 1986. The amendment established asbestos abatement programs in
schools, providing for the promulgation of federal regulations requiring periodic asbestos
inspections and reinspections and the necessary response actions. It also requires the EPA
Administrator to made determinations of the extent of danger to human health posed by
asbestos in public and commercial buildings and the means to respond to the dangers.
AHERA was later amended by the Asbestos School Hazard Abatement Reauthorization Act
(ASHARA) (P.L. 101-637) in 1990. Under this amendment, accreditation requirements were
added for persons conducting asbestos inspections and abatement activities in schools, com-
mercial buildings and public buildings.
Subchapter III — Indoor Radon Abatement (40 CFR 195) In October 1988, Congress
added a third title to TSCA, regulating radon with the Radon Reduction Act (PL 100-551).
This amendment was to assist states in responding to the human health threats posed by
exposure to radon. EPA was required to publish an updated citizen’s guide on the health
risks of radon, and to perform studies of the radon levels in government buildings and
schools.
Subchapter IV — Lead Exposure Reduction (40 CFR 745) In October 1992, TSCA was
again amended to add the Lead-Based Paint Exposure Reduction Act (PL 102-550). This leg-
islation was to reduce environmental exposure to lead contamination and prevent the
adverse health effects caused by it. Exposure of children was the primary concern. Provi-
sions of the Act included exposure studies, determination of lead levels in products,
establishing state programs for monitoring and abatement, and training and certification
requirements for lead abatement workers. It should be noted that under earlier statutes,
EPA had the authority to control toxic substances only if damage was caused. Under TSCA,
the effects on public health and environmental of all new chemicals had to be reviewed
before they could be manufactured for commercial purposes.
Subchapter I — Control of toxic substances

Subchapter I provides for the testing of existing chemical substances and mixtures; regu-
lates hazardous chemical substances and mixtures; requires manufacture and processing
notices; and calls for the managing of imminent hazards. It also includes reporting and
recordkeeping requirements.
4–TSCA 3/13

TSCA allows EPA to track the thousands of chemicals produced or imported into the U.S.
along with thousands more that are developed each year. EPA can:
• Require reporting or testing of those that pose a hazard, or
• Ban the manufacture and import of toxic substances.
Toxic substances are chemicals or mixtures that may present an unreasonable risk of injury
to health or the environment. Toxicity is a chemical’s ability to cause injury after exposure.
Though all things can be toxic, the level and duration of exposure is the key to toxicity. Test-
ing is performed to identify the health effects, as well as the levels of exposure that cause
those effects.
Chemical Data Reporting Rule
TSCA inventory
In 1977, the EPA promulgated a rule TSCA section 8(a), 15 U.S.C. 2607(a), to compile, keep
current, and publish an inventory of chemical substances in commerce in the U.S. This
inventory is called the TSCA Chemical Substance Inventory (TSCA Inventory).
Inventory Update Reporting (IUR) rule

The Inventory Update Reporting (IUR) rule under TSCA requires manufacturers and
importers of certain chemicals substances included on the TSCA Inventory to report current
data on the production volume, plant site, and site-limited status of these substances.
Chemical manufacturers and importers must provide EPA with the relevant information per-
taining to their most recent fiscal year. Manufacturers and importers of chemicals already
on the TSCA Inventory which are being produced at volume levels of 10,000 or more pounds
must report unless their chemical is excluded from the IUR, or they fall under the Small
Business exemption.
Certain exceptions apply to both chemicals and small businesses.
2011 amendments — Chemical Data Reporting (CDR) rule

In August, 2011, EPA issued the TSCA Chemical Data Reporting (CDR) rule. The rule modi-
fies the IUR first by changing its name to the Chemical Data Reporting (CDR) rule. EPA
says the name change is intended to better reflect the distinction between the next data col-
lection and the TSCA Inventory itself.
Major modifications to the rule include:

• New and updated information requirements related to potential exposures to a sub-
set of chemical substances listed on the TSCA Inventory.
• Increased frequency of reporting chemical data. The reporting frequency has
been changed to every four years. After the 2012 submission period, the next
submission period will occur in 2016. Subsequent recurring submission periods are
from June 1 to September 30 at 4–year intervals, beginning in 2016.
9/14 TSCA–5

The 2012 submission period, during which 2011 manufacturing, processing and use, and
2010 production volume information would be reported, is scheduled to occur February 1,
2012, to June 30, 2012.
Other changes to the rule require manufacturers and importers to:

• Use the newly formatted Form U to submit information. The form must be submit-
ted electronically using the e-CDRweb. All other CDR information must be
submitted through the Internet.
• Report if the production volume of a chemical substance meets or exceeds the 25,000
lb threshold during the principal reporting year (i.e., calendar year 2011).
• Provide upfront substantiation for each processing and use data element claimed as
confidential business information (CBI). Submitters cannot claim those data ele-
ments as confidential when they are identified as “not known to or reasonably
ascertainable by.”
EPA will make the CDR electronic reporting tool, e-CDRweb, available through the Central
Data Exchange (CDX) website.
New chemicals program and premanufacture notices (PMNs)

Mandated by section 5 of TSCA, EPA’s New Chemicals Program helps manage the potential
risk to human health and the environment from chemicals new to the marketplace. The pro-
gram functions as a “gatekeeper” that can identify conditions, up to and including a ban on
production, to be placed on the use of a new chemical before it is entered into commerce.
Anyone who plans to manufacture or import a new chemical substance for a non-exempt
commercial purpose is required by section 5 of TSCA to provide EPA with notice before initi-
ating the activity. This premanufacture notice (PMN) must be submitted at least 90 days
prior to the manufacture or import of the chemical. The agency typically receives 1,000 new
chemical notices each year, along with hundreds of pages of supporting material.
Electronic reporting
As of April 6, 2011, EPA requires electronic submissions for new chemical notices under
TSCA. The agency will no longer accept paper notices for new chemicals and their support
documents for review. Notifiers must use the e-TSCA/e-PMN software to prepare new sub-
missions via the Central Data Exchange (CDX).
On Dec. 4, 2013, EPA finalized a rule to require electronic reporting of other TSCA informa-
tion, specifically for TSCA sections 4, 5, 8(a), and 8(d).
Under the final rule, electronic reporting is required for the following information:
Section 4 Test Rules:
• Study plans
• Study results
• Letters of intent to conduct testing
• Extension requests
• Modification requests
• Exemption requests
6–TSCA 9/14

• Hearing requests
• Dioxins/Furans Report Form
Section 4 Enforceable Consent Agreements (ECAs):
• Study plans
• Reports
• Modification of study plans
• Modification of test schedules
Section 5 Notices of Commencement of Manufacture or Import and support documents relat-
ing to TSCA section 5 Notices sent to EPA before April 6, 2010:
• Correspondence
• Amendments
• Test data
Section 8(a) Preliminary Assessment Information:
• Manufacturer’s Report Form 7710-35
Section 8(d) Health and Safety Studies:
• Full study reports
• Ongoing studies
• Initiated studies
• Robust summaries
• Studies previously sent to other federal agencies without confidentiality claims
• Requests for extension of time
• Requests for withdrawal of a chemical from a rule
How to report electronically

Under the final rule, submitters are required to:
• First register to use EPA’s agency wide Chemical Data Exchange (CDX) portal for
submitting information in a secure manner.
• Once registered and in CDX, users will select the Chemical Safety and Pesticide
Programs (CSPP) portion of the site.
• From this area of the site, users will access a Web-based TSCA reporting tool, called
the Chemical Information Submission System (CISS).
• Data submissions pursuant to TSCA sections 4 and 8 will be available under the
CISS reporting tool.
Note: Users who have previously registered with CDX to submit data under TSCA section 5
or for the Toxics Release Inventory TRI-ME Program are able to add “Submission for Chemi-
cal Safety and Pesticide Program (CSPP)” to their current registration.
Find EPA’s CDX eTSCA Registration Guide at www.epa.gov/oppt/newchems/epmn/cdxguide.
pdf.
9/14 TSCA–6A

Register for the CDX at https://cdx.epa.gov/epa_home.asp or https://cdx.epa.gov/Registration/

Terms.
Existing chemicals program

EPA’s existing chemicals program under TSCA addresses pollution prevention, risk assess-
ment, hazard and exposure assessment and characterization, and risk management for
chemical substances in commercial use.
6B–TSCA 9/14

Significant New Use Rules (SNURs) and Significant New Use Notices (SNUNs)
EPA issues Significant New Use Rules (SNURs) on particular chemicals or substances when
it wishes to evaluate the potential risks to human health and the environment. The notifica-
tion required by SNURs allows EPA to prevent or limit potentially adverse exposure to, or
effects from, the new use of the substance. TSCA PMN rule amendments in 1995 expanded
the types of significant new use designations that EPA may promulgate as direct final rules.
This change improved the efficiency of the SNUR procedure for both EPA and the chemical
industry.
Much like PMNs, Significant New Use Notices (SNUNs) call for notifying EPA within 90
days whenever a manufacturer or processor wishes to put a chemical to a significant new
use. Section 5(a) of TSCA and 40 CFR Part 721 call for a SNUN if EPA has promulgated a
SNUR. SNUNs are reported using the standard PMN form and are subject to the same
90-day review process as new chemicals. When submitting a SNUN, the submitter should
include a cover letter that provides the CFR citation of the SNUR and identifies the specific
significant new use. As with new chemical PMNs, SNUNs must be submitted electronically.
Chemical Right-to-Know Initiative

EPA’s Chemical Right-to-Know (ChemRTK) was established in 1998 to supply information to
the public on most of the high production volume (HPV) commercial chemicals made and
used in the U.S. Without this basic hazard information, it is hard to make sound judgments
about what potential risks these chemicals could present to people and the environment.
ChemRTK calls for rapidly testing chemicals and making this data available to scientists,
policy makers, industry, and the public.
The initiative has three components:
HPV Challenge Program — Under the HPV Challenge Program, companies were “chal-
lenged” to make known information on chemicals produced or imported into the U.S. in the
greatest quantities. HPV chemicals are those produced or imported in the U.S. in quantities
of 1 million pounds or more per year. By 2007, companies had sponsored more than 2,200
HPV chemicals.
Scheduled submission of data under the HPV Challenge Program has been completed, and
the focus has now shifted to data use, both by the public and EPA. Access the data through
the High Production Volume Information System (HPVIS) database at www.epa.gov/
chemrtk/hpvis/index.html.
Voluntary Children’s Chemical Evaluation Program (VCCEP) — Under VCCEP, EPA

asked companies that manufactured or imported one or more of 23 chemicals to which chil-
dren have a high likelihood of exposure, to volunteer information on health effects, exposure,
risk, and data needs. VCCEP is currently a pilot program in which 35 companies and 10
consortia have volunteered to sponsor 20 of the 23 chemicals. Access information on the
chemicals along with assessments, reports, and decisions at www.epa.gov/oppt/vccep/pubs/
chemmain.html.
Persistent Bioaccumlators Program — Persistent bioaccumulative toxic (BPT) pollut-

ants are chemicals that pose a threat to health and the environment because they persist in
the environment and bioaccumulate in food chains. Under the PBT program, new chemicals,
3/14 TSCA–7

submitted under the TSCA notification procedure, may need to undergo testing on persis-
tence and bioaccumulation endpoints. EPA’s PBT Profiler webpage is www.bptprofiler.net/.
TSCA enforcement
EPA may issue a civil administrative complaint to any person or company in violation of
TSCA. The complaint may include a civil penalty (including recovery of any economic benefit
from the non-compliance) of up to $27,500 per violation per day. EPA can also require the
correction of the violation.
TSCA and exports

If a person intends to export a chemical that is subject to certain requirements under TSCA,
the person must notify EPA. The agency will then notify the importing country’s government
of the chemical and of EPA’s regulatory action. These export notification requirements can
be found in Section 12(b) of TSCA and 40 CFR 707 Subpart D. There are some TSCA exemp-
tions, under specific and limited circumstances, for chemical substances, mixtures, and
articles being manufactured, processed, or distributed in commerce solely for export from the
U.S.
Substances listed in Section 12(b) are identified by:
• Chemical Abstracts Service (CAS) Registry Numbers for non-confidential chemicals;
• Premanufacture Notification (PMN) numbers/Low Volume Exemption (LVE) num-
bers for new chemicals; and
• Accession Numbers for confidential chemicals.
EPA maintains and updates the TSCA 12(b) chemicals list. Find it here: www.epa.gov/oppt/
import-export/pubs/12_b_listFinal-08-21-2012.pdf.
Other export considerations
No notice of export is required for “articles” except for PBC articles. Anyone who exports or
intends to export PCB articles, for any purpose other than disposal, must notify EPA under
Section 12(b).). Article is defined at Section 704.3 as a manufactured item that:
• is formed to a specific shape or design during manufacture;
• has end use function(s) dependent in whole or in part upon its shape or design dur-
ing end use; and
• has either no change of chemical composition during its end use or only those
changes of composition that have no commercial purpose separate from that of the
article, and that result from a chemical reaction that occurs upon end use of other
chemical substances, mixtures, or articles; except fluids and particles are not consid-
ered articles regardless of shape or design.
8–TSCA 3/14

No notice of export is required for the export of:

• A chemical substance or mixture for which export notification is otherwise required,
where the chemical substance or mixture is present in a concentration of less than
one percent (by weight or volume).
• A chemical substance or mixture that is a known or potential human carcinogen
where such chemical substance or mixture is present in a concentration of less than
0.1 percent (by weight or volume).
• Polychlorinated biphenyl chemicals (PCBs) where such chemical substances are
present in a concentration of less than or equal to 50 ppm (by weight or volume).
EPA can grant exemptions for exporting substances that would otherwise be prohibited
under TSCA, but of course, in that case, the agency would expect a notice of export.
Chemical substances that are subject to the export notification rules “sunset” after a specific
period of time. EPA publishes a table with sunset dates for specific chemicals. Find the lat-
est table here: www.epa.gov/oppt/chemtest/pubs/sunset.html. Note that although a chemical
may have sunset, it may also fall under another TSCA action triggering export notice
requirements.
Polychlorinated biphenyls (PCBs)

TSCA prohibits the manufacture and distribution of PCBs, controls the phase-out of their
existing uses, and ensures their safe disposal. EPA regulates the disposal of PCBs under 40
CFR 761, although there may be some overlap with other environmental laws such as the
Resource Conservation and Recovery Act (RCRA). Requirements for the management of
PCB-containing materials have been developed for the following:
• Quarterly inspection,
• Registration and reporting,
• Location,
• Security,
• Labeling,
• Storage, and
• Emergency response to PCB spills, leaks, or fires.
PCBs were common in the U.S. from 1929 until their manufacture was banned in 1979.
They can be thin, light-colored fluids to yellow or black waxy solids and have a wide range of
toxicity.
While no longer manufactured, PCBs may be present in products and materials produced
before the 1979 PCB ban. Products that may contain PCBs include:
• Transformers and capacitors;
• Other electrical equipment including voltage regulators, switches, reclosers, bush-
ings, and electromagnets;
• Oil used in motors and hydraulic systems;
• Old electrical devices or appliances containing PCB capacitors;
9/13 TSCA–9

• Fluorescent light ballasts;

• Cable insulation;
• Thermal insulation material including fiberglass, felt, foam, and cork;
• Adhesives and tapes;
• Oil-based paint;
• Caulking;
• Plastics;
• Carbonless copy paper; and
• Floor finish.
The PCBs used in these products were chemical mixtures made up of a variety of individual
chlorinated biphenyl components, known as congeners. Most commercial PCB mixtures are
known by their industrial trade names. The most common trade name is Aroclor.
Once in the environment, PCBs take a long time to break down. They can be carried long
distances and have been found all over the world. They can accumulate in plants and food
crops and also in the bodies of small organisms and fish. As a result, people who eat the fish
may be exposed to PCBs. PCBs have been shown to cause cancer, as well as other adverse
health effects on the human immune system, reproductive system, nervous system, and
endocrine system.
PCBs and fluorescent lighting fixtures

TSCA requires the immediate removal and disposal of leaking PCB-containing ballasts and
the disposal of any PCB-contaminated materials at an agency-approved facility; however,
EPA recommends the removal of older fluorescent lighting systems, even if they are not
leaking.
Intact, operational ballasts where PCBs remain in the ballasts and potting material may not
pose a health risk or environmental hazard. However, as they age, the ballasts degrade.
Depending on the number of operating hours, the typical life expectancy of a magnetic fluo-
rescent light ballast is between 10 and 15 years. The failure rate prior to the end of the
useful life of ballasts is about ten percent. After this typical life expectancy, ballast failure
rates increase significantly. All of the pre-1979 ballasts in lighting fixtures that are still in
use are now far beyond this life expectancy, increasing the risk of leaks or even fires, which
would pose a health and environmental hazard. A PCB-containing ballast may also be lack-
ing in thermal overload protection, increasing the possibility of fires or leaks. The hazard
can be worsened by mishandling by personnel who are unaware of the presence of PCBs in
the lighting ballasts.
PCBs, disposal and manifesting requirements

The PCB regulations at 40 CFR Part 761 define the “generator” as being responsible for
handling, storing, transporting, and disposing of PCB wastes. The generator is considered
the party that owns the material. For most construction projects, multiple parties will be
involved and all may be liable if the PCB handling and disposal requirements are not
followed.
10–TSCA 9/13

Before beginning any demolition or remodeling activities, identify and label all PCB-
containing equipment or material that will be disturbed. The following items must be
labeled:
• PCB containers;
• Large PCB transformers, PCB low- and high-voltage capacitors, and equipment con-
taining these transformers or capacitors at the time of removal from use if not
already marked;
• Large PCB high-voltage capacitors at the time of manufacture, at the time of distri-
bution in commerce if not already marked, and at the time of removal from use if
not already marked;
• Electric motors using PCB coolants;
• Hydraulic systems using PCB hydraulic fluid;
• Heat transfer systems (other than PCB transformers) using PCBs;
• PCB article containers containing articles or equipment that must be marked; and
• Each storage area used to store PCBs and PCB items for disposal.
Items containing PCBs cannot be reused or recycled. There is no provision in TSCA
for using, reusing, or recycling items or materials containing PCBs. However, items or mate-
rials containing less than 2 ppm PCBs may be used, reused, or recycled without restriction.
Storage requirements for PCB-containing materials depend on the end use of those
materials. You can store approved materials for reuse for up to five years in an approved,
permanent PCB storage area. But note: The storage-for-reuse provisions at 40 CFR Part
761.35 are meant to capture articles such as transformers. The equipment must be manufac-
tured for a particular use. It is not meant for any item or material containing PCBs. You can
store materials for disposal for up to 30 days in a temporary storage area or for up to one
year in a permanent PCB storage location. In all cases, you must mark the items with the
date they were removed from service and inspect the area every 30 days for any spills or
leaks.
A temporary storage for disposal area must meet the following requirements:
• Be marked with a PCB ML label;
• Have a roof and walls to protect the materials from rain or snow.
You must keep an annual documentation log for certain storage and disposal activities. For
details on the specific requirements of the annual documentation log, see 40 CFR Part 761.
180.
For PCB waste disposal, you must find an approved PCB waste disposer. Transporters do
not need to be approved, but the generator or whoever is offering the waste for shipment
must ensure that the transporter has submitted a Notification of PCB Activity Form and
received an ID number for their PCB activities. In addition to the waste going to an
approved disposer, that disposer must also have notified and received an ID number for
their PCB activities. You must also complete the Uniform Hazardous Waste Manifest.
Marking formats.
When marking PCB-containing items is required, the large mark (ML) is the preferred label.
The small mark (MS) should be used only on items that will not accommodate the ML.
3/13 TSCA–11

According to §761.45, the following formats shall be used for marking:

Large PCB Mark-M L. Mark ML shall be as shown, letters and striping on a white or yellow
background and shall be sufficiently durable to equal or exceed the life (including storage for
disposal) of the PCB Article, PCB Equipment, or PCB Container. The size of the mark shall
be at least 15.25 cm (6 inches) on each side. If the PCB Article or PCB Equipment is too
small to accommodate this size, the mark may be reduced in size proportionately down to a
minimum of 5 cm (2 inches) on each side.
Small PCB Mark-M S. Mark MS shall be as shown, letters and striping on a white or yellow
background, and shall be sufficiently durable to equal or exceed the life (including storage
for disposal) of the PCB Article, PCB Equipment, or PCB Container. The mark shall be a
rectangle 2.5 by 5 cm (1 inch by 2 inches). If the PCB Article or PCB Equipment is too small
to accommodate this size, the mark may be reduced in size proportionately down to a mini-
mum of 1 by 2 cm (.4 by .8 inches).
PCB manifesting
Until recently, the manifesting requirements for PCBs under TSCA and the hazardous waste
manifesting requirements under RCRA had many differences. However, EPA issued a direct
final rule in September 2012 intended to match (as much as possible) the manifesting
requirements for PCBs under TSCA to the manifesting requirements under RCRA. The rule
took effect December 5, 2012. Minor differences remain. For instance, Part 761 does not con-
tain a provision similar to §264.72(a)(3) for container residues. Since there are no relevant
container residue quantity limits for PCB wastes, the final rule does not address them.
PCBs are manifested using the RCRA Uniform Hazardous Waste Manifest (See the chapter
on Waste in this book for more information on hazardous waste manifesting.).
Below is a table of the regulations from 40 CFR Parts 262-264 that EPA has added to 40
CFR Part 761, where the content of the section is new to 40 CFR Part 761.
12–TSCA 3/13

40 CFR Section Brief Description of RCRA Regulation

262.20(c) Designating an alternate facility on the manifest.
262.20(f) Manifesting exemption for the transport of waste on a
public or private right-of-way within or along the border of
contiguous property.
262.23(f) Generator requirements for rejected shipments returned
by the receiving facility back to the generator. (Language
on non-empty containers and residues is not relevant to
PCB waste.)
262.40(b) Three-year exception report retention requirement for
generators.
263.21(a)(2) Alternate designated facility is listed as one of the options
where the transporter must deliver the waste.
263.21(b)(2) Partial and full load rejection requirements if the waste is
rejected while the transporter is on the facility’s premises.
264.71(a)(1) Facility signs and dates the manifest when the waste was
received, except as noted in the discrepancy space of
the manifest, or when the waste was rejected as noted in
the manifest discrepancy space.
264.72(a)(2) Definition of rejected wastes as manifest discrepancies.
264.72(d) Upon rejecting waste, the facility must consult with the
generator prior to forwarding the waste to another facility.
The facility must send the waste to another facility or
back to the generator within 60 days of the rejection.
While making arrangements for the rejected waste, the
facility must ensure that the transporter retains custody or
the facility provides secure, temporary custody of the
waste.
264.72(e) Facility requirements for preparing a new manifest for full
or partial load rejections that are to be sent off-site to an
alternate facility.
264.72(f) Facility requirements for preparing a new manifest for
rejected wastes that must be sent back to the generator.
264.72(g) Facility requirements for amending the manifest for
rejected wastes after the facility has signed, dated, and
returned the manifest to the delivering transporter or to
the generator.
264.76(a)(6) Report on unmanifested waste must include the certifica-
tion signed by the owner, operator, or authorized
representative of the facility.
Subchapter II — Asbestos Hazard Emergency Response

Asbestos is the name given to a variety of mineral fibers that were once commonly used in
construction materials for insulation and as fire-retardants. Asbestos has a high tensile
strength and excellent heat resistant properties, which made it a first choice in many manu-
factured goods, building materials (such as roofing shingles, ceiling and floor tiles, and
cement products), automobile parts (especially friction-prone parts such as brakes, clutches,
and transmission parts), heat-resistance fabrics, packaging, gaskets, and coatings.
Under TSCA, asbestos is defined as the asbestiform varieties of: chrysotile (serpentine);
crocidolite (riebeckite); amosite (cummingtonite/grunerite); anthophyllite; tremolite; and
actinolite.
3/13 TSCA–13

Unfortunately, asbestos fibers are extremely friable, meaning they break apart into micro-
scopic pieces easily and become airborne. When disturbed by repairs, remodeling, or
demolition activities, the friable fibers become airborne and can be inhaled into the lungs
where they can cause serious health effects.
How are people exposed to asbestos?

Everyone is exposed to a little asbestos in the air. Levels range from 0.00001 to 0.0001 fibers
per milliliter of air and is generally higher in cities and industrialized areas. Workers in
industries that manufacture asbestos products or who mine asbestos can be exposed to
higher levels of the substance. Because asbestos fibers can travel great distances in the air,
people living near these industries may also be exposed to higher levels of asbestos.
Any time work is being done to buildings or materials that contain asbestos, the fibers can
be disturbed and become airborne.
Even drinking water may contain asbestos – either from natural sources or from cement
pipes that contain asbestos.
Where is asbestos commonly found?

Although EPA banned asbestos in new products in 1989, asbestos can still be found in prod-
ucts that are being used today. The agency has identified the following product categories:
Asbestos Product Categories
Asbestos-cement corrugated sheet Asbestos-cement flat sheet
Asbestos-cement pipe Asbestos-cement shingle
Asbestos clothing Non-roof coatings
Vinyl-asbestos floor tile Automatic transmission components
Clutch facings Disc brake pads
Drum brake linings Brake blocks
Commercial and industrial asbestos friction products Sheets and beater-add gaskets (except specialty
industrial)
Commercial, corrugated, and specialty paper Millboard
Rollboard
Health effects
Inhaled asbestos increases the chances of developing lung disease and cancer. The risk is
greatly compounded by smoking. In fact, the risk of developing lung cancer is 90 times
greater in those who smoke and are exposed to asbestos than for those who neither smoke
nor are exposed to the substance.
Breathing in friable asbestos may result in asbestos fibers becoming embedded in the lungs.
Over time, diseases that may develop include:
Asbestosis —A serious, progressive, long-term non-cancer disease of the lungs. It is caused
by inhaling asbestos fibers that irritate lung tissues and cause the tissues to scar. The scar-
ring makes it hard for oxygen to get into the blood. Symptoms of asbestosis include
shortness of breath and a dry, crackling sound in the lungs while inhaling. There is no effec-
tive treatment for asbestosis.
14–TSCA 3/13

Plaques in the pleural membranes — Less serious than asbestosis, plaques that develop in
the pleural membrane surrounding the lungs can thicken the membrane and restrict
breathing.
Lung Cancer —The most common symptoms of lung cancer are coughing and a change in
breathing. Other symptoms include shortness of breath, persistent chest pains, hoarseness,
and anemia.
Mesothelioma — A rare form of cancer that is found in the thin lining (membrane) of the
lung, chest, abdomen, and heart and almost all cases are linked to exposure to asbestos.
This disease may not show up until many years after asbestos exposure.
Asbestos regulations
In 1989, EPA banned all new uses of asbestos; uses established before this date are still
allowed. EPA established regulations that require school systems to inspect for damaged
asbestos and to eliminate or reduce the exposure by removing the asbestos or by covering it
up. EPA regulates the release of asbestos from factories and during building demolition or
renovation to prevent asbestos from getting into the environment. The agency has proposed
a concentration limit of 7 million fibers per liter of drinking water for long fibers (lengths
greater than or equal to 5 µm).
EPA is not the only federal agency that regulates asbestos: The substance is regulated by a
number of agencies and across various offices in those agencies. For instance, EPA regulates
asbestos under the Clean Air Act and under TSCA. EPA is mainly concerned about the envi-
ronmental effects of asbestos, while the Occupational Health and Safety Administration
(OSHA) focuses its attention on the possible health effects to workers. OSHA has set limits
of 100,000 fibers with lengths greater than or equal to 5 µm per cubic meter of workplace air
for 8-hour shifts and 40-hour work weeks.
EPA’s Worker Protection rule (40 CFR Part 763, Subpart G) extends the OSHA standards to
state and local employees who perform asbestos work, and who are not covered by the
OSHA Asbestos Standards or by a state OSHA plan. The rule parallels OSHA requirements
and covers medical examinations, air monitoring and reporting, protective equipment, work
practices, and record keeping. In addition, many state and local agencies have more strin-
gent standards than those required by the federal government.
Cross-reference of asbestos regulations

Agency CFR Citation Explanation
EPA 40 CFR part 61, subpart M Protects the public by minimizing the release of asbestos
fibers during activities involving the processing, handling,
and disposal of asbestos-containing material. Specifies
work practices to be followed during demolitions and
renovations of all structures, installations, and buildings.
Require the building owner and/or the contractor to notify
state and local agencies and/or EPA before all
demolitions, or before renovations of buildings that
contain a certain threshold amount of asbestos.
40 CFR part 763, subpart E Requires schools to inspect for asbestos and implement
response actions and submit asbestos management
plans to states. Specifies use of accredited inspectors,
air sampling methods, and waste disposal procedures.
3/13 TSCA–15

Agency CFR Citation Explanation

40 CFR part 427 Sets effluent standards for asbestos manufacturing
source categories.
40 CFR part 763, subpart G Protects public employees performing asbestos
abatement work in states not covered by OSHA asbestos
standard.
OSHA 29 CFR 1910.1001 Requires worker protection measures—engineering
controls, worker training, labeling, respiratory protection,
bagging of waste, permissible exposure level.
29 CFR 1926.1101 Requires worker protection measures for all construction
work involving asbestos, including demolition and
renovation work-practices, worker training, bagging of
waste, permissible exposure level.
MSHA 30 CFR part 56, subpart D Specifies exposures limits, engineering controls, and
respiratory protection measures for workers in surface
mines.
30 CFR part 57, subpart D Specifies exposure limits, engineering controls, and
respiratory protection measures for workers in
underground mines.
DOT 49 CFR parts 171 and 172 Regulates the transportation of asbestos-containing
waste material. Requires waste containment and
shipping papers.
Other EPA regulations governing asbestos

Asbestos hazard emergency response act
In 1986, the Asbestos Hazard Emergency Response Act (AHERA — Asbestos Containing
Materials in Schools, 40 CFR Part 763, Subpart E) was signed into law as Title II of TSCA.
AHERA is more inclusive than the May 1982 Asbestos-in-Schools rule. AHERA requires
Local Education Agencies (LEAs) to inspect their schools for asbestos containing building
materials (ACBM) and prepare management plans that recommend the best way to reduce
the asbestos hazard. Options include repairing damaged ACM, spraying it with sealants,
enclosing it, removing it, or keeping it in good condition so that it does not release fibers.
The plans must be developed by accredited management planners and approved by the
applicable state. LEAs must notify parent, teacher, and employer organizations of the plans,
and then the plans must be implemented. AHERA also requires accreditation of abatement
designers, contractor supervisors and workers, building inspectors, and school management
plan writers. Those responsible for enforcing AHERA have concentrated on educating LEAs
in an effort to ensure that they comply with the regulations. Contractors that improperly
remove asbestos from schools can be liable under both AHERA and the National Emission
Standards for Hazardous Air Pollutants (NESHAP).
National emission standards for hazardous air pollutants

The Clean Air Act (CAA) of 1970 requires EPA to develop and enforce regulations to protect
the general public from exposure to airborne contaminants that are known to be hazardous
to human health. In accordance with Section 112 of the CAA, EPA established NESHAP;
asbestos was one of the first hazardous air pollutants regulated under Section 112. On
March 31, 1971, EPA identified asbestos as a hazardous pollutant, and on April 6, 1973, EPA
promulgated the Asbestos NESHAP in 40 CFR Part 61, Subpart M. The Asbestos NESHAP
has been amended several times, most recently in November 1990.
16–TSCA 3/13

The Asbestos NESHAP is intended to minimize the release of asbestos fibers during activi-
ties involving the handling of asbestos. Accordingly, it specifies work practices to be followed
during renovations of buildings that contain a certain threshold amount of friable asbestos,
and during demolitions of all structures, installations, and facilities (except apartment build-
ings that have no more than four dwelling units).
Most often, the Asbestos NESHAP requires action to be taken by the person who owns,
leases, operates, controls, or supervises the facility being demolished or renovated (the
owner), and by the person who owns, leases, operates, controls, or supervises the demolition
or renovation (the operator). The regulations require owners and operators subject to the
Asbestos NESHAP to notify delegated state and local agencies and/or their EPA Regional
Offices before demolition or renovation activity begins. The regulations restrict the use of
spray asbestos and prohibit the use of wet applied and molded insulation, such as pipe
lagging. The Asbestos NESHAP also regulates asbestos waste handling and disposal.
Subchapter III — Indoor Radon Abatement
Indoor radon abatement

Title III was added to TSCA in October 1998 to regulate radon through the Radon Reduction
Act. The amendment assists states in responding to human health threats posed by expo-
sure to radon. The law required EPA to publish an updated citizen’s guide on the health
risks of radon, and to perform studies of the radon levels in government buildings and
schools.
The Act establishes that the goal of the United States is that indoor air be as free from
radon as the ambient air outside buildings. In addition, the bill authorized:
State grants: $10 million annually in each of three years (FY89-91) for EPA to adminis-
ter grants to help states establish radon programs, conduct radon surveys, develop public
information on radon, and conduct demonstration and mitigation projects.
Technical assistance: $3 million annually in FY 89, 90, and 91 for EPA to provide tech-
nical assistance to states. Among the activities specified in the bill, EPA would assist
states with radon surveys, training seminars, mitigation projects, development of mea-
surement and mitigation methods for non-residential child care facilities, and public
information materials.
Study of schools: $1 million for EPA to conduct a study of radon in the nation’s schools,
and an additional $500,000 to undertake diagnostic and remedial efforts in schools.
Proficiency programs: $1.5 million for EPA to establish proficiency programs for firms
offering radon-related services, including testing and mitigation. The program would later
be funded through a user-fee system.
Regional training centers: $1 million a year in FY 89, 90, and 91 for EPA grants to
universities to establish at least three regional radon training centers.
Modern construction standards: EPA to develop model construction standards and
techniques.
Citizen’s guide: EPA to update the Citizen’s Guide to Radon.(http://www.epa.gov/radon/
pdfs/citizensguide.pdf)
3/13 TSCA–17

Federal building study: Requires all federal departments and Agencies to conduct stud-
ies of radon contamination in federally-owned buildings located in high radon risk areas.
Most states run their own asbestos abatement programs. State contact information for those
programs is found in the State TSCA section of this book.
Subchapter IV — Lead-Based Paint Exposure Reduction Act
Lead-Based Paint Exposure Reduction Act

The Lead-Based Paint Exposure Reduction Act was added to TSCA in October 1992. It called
on EPA to reduce environmental exposure to lead contamination and prevent the adverse
health effects caused by it.
Common renovation activities like sanding, cutting, and demolition can create hazardous
lead dust and chips by disturbing lead-based paint, which can be harmful to adults and
children.
To protect against this risk, on April 22, 2008, EPA issued a rule affecting 40 CFR 745 Sub-
part E that requires the use of lead-safe practices and other actions aimed at preventing
lead poisoning. Under the rule, beginning April 22, 2010, contractors performing renovation,
repair and painting projects that disturb lead-based paint in homes, child care facilities, and
schools built before 1978 must be certified and must follow specific work practices to prevent
lead contamination.
EPA requires that firms performing renovation, repair, and painting projects that disturb
lead-based paint in pre-1978 homes, child care facilities and schools be certified by EPA and
that they use certified renovators who are trained by EPA-approved training providers to
follow lead-safe work practices. Individuals can become certified renovators by taking an
eight-hour training course from an EPA-approved training provider.
Specifically, contractors must now use lead-safe work practices and follow these three simple
procedures:
• Contain the work area.
• Minimize dust.
• Clean up thoroughly.
They should also read about how to comply with EPA’s rule in the EPA Small Entity Com-
pliance Guide to Renovate Right, which is a handbook for contractors, property managers
and maintenance personnel working in homes and child-occupied facilities built before 1978.
The rule affects paid renovators who work in pre-1978 housing and child-occupied facilities,
including:
• Renovation contractors,
• Maintenance workers in multi-family housing, and
• Painters and other specialty trades.
Under the rule, child-occupied facilities are defined as residential, public, or commercial
buildings where children under age six are present on a regular basis. The requirements
18–TSCA 3/13

apply to renovation, repair or painting activities. The rule does not apply to minor mainte-
nance or repair activities where less than six square feet of lead-based paint is disturbed in
a room or where less then 20 square feet of lead-based paint is disturbed on the exterior.
Window replacement is not considered minor maintenance or repair.
Beginning in December 2008, the rule requires that contractors performing renovation,
repair and painting projects that disturb lead-based paint provide to owners and occupants
of child care facilities and to parents and guardians of children under age six that attend
child care facilities built prior to 1978 the lead hazard information pamphlet Renovate Right:
Important Lead Hazard Information for Families, Child Care Providers, and Schools.
Previously, owner-occupants of homes built before 1978 could certify that no child six years
of age or younger or pregnant woman was living in the home and “opt-out” of having their
contractors follow lead-safe work practices in their homes. On April 23, 2010, to better pre-
vent against lead paint poisoning, EPA issued a final rule to apply lead-safe work practices
to most pre-1978 homes, effectively closing the exemption. The rule eliminating the opt-out
provision became effective July 6, 2010.
Effective dates for renovation, repair, and painting program rule

June 23, 2008 Unaccredited renovator or dust sampling technician train-
ing programs may not advertise or provide training
leading to EPA certification.
States, Tribes, and Territories may begin to apply for
authorization.
Persons performing renovations for compensation in pre-
1978 child-occupied facilities (e.g., child care facilities,
kindergarten and pre-kindergarten classrooms) must pro-
vide either Protect Your Family or Renovate Right to the
owners and occupants before beginning renovations.
Modifications to Pre-renovation Education rule take effect:
1. Minor repair and maintenance exception changes to <
6 ft2 for interiors, 20 ft2 for exteriors. To qualify, the
project cannot involve the use of high dust generating
(“prohibited”) practices or window replacement.
2. Emergency renovations specifically include interim
controls performed in response to an elevated blood
lead level in a child.
3. Persons performing renovations for compensation in
pre-1978 housing may use either Protect Your Family
or Renovate Right to comply with the existing require-
ment to provide a lead hazard information pamphlet to
the owners and occupants of target (pre-1978) hous-
ing before beginning renovations.
December 22, 2008 Persons performing renovations for compensation in tar-
get (pre-1978) housing or child-occupied facilities must
provide Renovate Right to the owners and occupants
before beginning renovations.
April 22, 2009 Training providers may begin applying to EPA for accredi-
tation to provide renovator or dust sampling technician
training.
Persons seeking certification as renovators or dust sam-
pling technicians may take accredited training as soon as
it is available.
3/13 TSCA–19

October 22, 2009 Firms may begin applying to EPA for certification to con-
duct renovations.
April 22, 2010 Renovations in target (pre-1978) housing and child-
occupied facilities must be conducted by certified
renovation firms, using renovators with accredited train-
ing, and following the work practice requirements of the
rule.
October 4, 2011 A number of revisions to the Lead RRP go into effect,
including:
1. A provision allowing a certified renovator to collect a
paint chip sample and send it to a recognized labora-
tory for analysis in lieu of using a lead test kit;
2. Minor changes to the training program accreditation
process;
3. Standards for e-learning in accredited training pro-
grams;
4. Minimum enforcement provisions for authorized state
and tribal renovation programs;
5. Minor revisions to the training and certification require-
ments for renovators.
In addition, EPA developed a new insert page to be
added to its 2010 Renovate Right brochure. (http://www.
epa.gov/lead/pubs/insert.pdf)
Enforcement dates
EPA announced that it will provide renovation firms and workers additional time to obtain
necessary training and certifications to comply with the agency’s Lead Renovation, Repair,
and Painting (RRP) regulations due to a growing concern that contractors in some parts of
the country may be having difficulty accessing training classes.
Until October 1, 2010, EPA did not take enforcement action for violations of the regulation’s
firm certification requirement at 40 CFR 745.81. For violations of the regulation’s renovation
worker certification requirement, EPA did not enforce against individual renovation workers
if they enrolled in or applied to enroll in certified renovator classes by September 30, 2010,
and completed the training by December 31, 2010.
Renovators working in AL, GA, IA, KS, MS, MA, NC, RI, OR, UT, WA and WI must
comply with all applicable state laws and state compliance dates. The enforcement
delay does not apply in these states unless those states provide such a delay.
EPA also warns that it will not stop taking enforcement actions against renovation firms
and individuals who do not comply with 40 CFR 745 Subpart E’s work practices and associ-
ated recordkeeping requirements. The lead-safe work practices include dust control, site
cleanup, and work area containment.
Information for contractors

As a contractor, you play an important role in helping to prevent lead exposure. Ordinary
renovation and maintenance activities can create dust that contains lead. By following the
lead-safe work practices, you can prevent lead hazards.
20–TSCA 3/13

Contractors who perform renovation, repairs, and painting jobs in pre-1978 housing and
child-occupied facilities must, before beginning work, provide owners, tenants, and child-care
facilities with a copy of EPA’s lead hazard information pamphlet Renovate Right: Important
Lead Hazard Information for Families, Child Care Providers, and Schools This can be found
at http://www.epa.gov/lead/pubs/renovaterightbrochure.pdf. Contractors must document com-
pliance with this requirement. EPA’s pre-renovation disclosure form may be used for this
purpose and can be found at http://www.epa.gov/lead/pubs/pre-renovationform.pdf
Understand that after April 22, 2010, federal law requires you to be certified and to use
lead-safe work practices. To become certified, renovation contractors must submit an applica-
tion and fee payment to EPA. The Application and Instructions for Firms guidance
document may be useful. This can be found at www.epa.gov/lead/pubs/firmapp.pdf.
EPA began processing applications on October 22, 2009. The agency has up to 90 days after
receiving a complete request for certification to approve or disapprove the application.
Contractors who perform renovation, repairs, and painting jobs should also:
• Take training to learn how to perform lead-safe work practices.
❍ Find a training provider that has been accredited by EPA to provide training
for renovators under EPA’s Renovation, Repair, and Painting (RRP) Program,
http://cfpub.epa.gov/flpp/searchrrp_training.htm.
❍ Please note that if you previously completed an eligible renovation training
course you may take the 4-hour refresher course instead of the 8-hour initial
course from an accredited training provider to become a certified renovator.
Click here for a list of eligible courses. The list of eligible courses can be found
at www.epa.gov/lead/pubs/trainerinstructions.htm#refresher.
• Provide a copy of your EPA or state lead training certificate to your client.
• Tell your client what lead-safe methods you will use to perform the job.
• Learn the lead laws that apply to you regarding certification and lead-safe work
practices beginning April 22, 2010.
• Ask your client to share the results of any previously conducted lead tests.
• Provide your client with references from at least three recent jobs involving homes
built before 1978.
• Keep records to demonstrate that you and your workers have been trained in lead-
safe work practices and that you follow lead-safe work practices on the job. To make
recordkeeping easier, you may use the sample recordkeeping checklist at www.epa.
gov/lead/pubs/samplechecklist.pdf that EPA has developed to help contractors
comply with the renovation recordkeeping requirements that took effect April 22,
2010.
• Read about how to comply with EPA’s rule in the EPA Small Entity Compliance
Guide to Renovate Right at www.epa.gov/lead/pubs/sbcomplianceguide.pdf.
• Read about how to use lead-safe work practices in EPA’s Steps to Lead Safe Renova-
tion, Repair and Painting, www.epa.gov/lead/pubs/steps.pdf.
NOTE: Contractors and training providers working in Alabama, Georgia, Iowa, North Caro-
lina, Mississippi, Kansas, Rhode Island, Utah, Oregon, Massachusetts, Washington and
Wisconsin must contact the state to find out more about its training and certification
3/13 TSCA–21

requirements. These states are authorized to administer their own RRP programs in lieu of
the federal program.
Contractors should also read the EPA Enforcement Alert newsletter titled Compliance with
New Federal Lead-Based Paint Requirements www.epa.gov/compliance/resources/newsletters/
civil/enfalert/leadpaint.pdf.
Fee rule
On March 20, 2009, EPA issued a final rule to establish fees for the new Lead Renovation,
Repair and Painting rule, which affected 40 CFR 745 Subpart L. The rule established fees
that are charged for training programs seeking accreditation, for firms engaged in renova-
tions seeking certification, and for individuals (for example, risk assessors) or firms engaged
in lead-based paint activities seeking certification. The rule applies only in those states and
tribes without their own authorized lead programs. The rule also modified and lowered fees
for the Lead-based Paint Activities regulations. The fees were developed as required by sec-
tion 402 of TSCA to recover the cost of administering and enforcing the law’s requirements.
Future of TSCA
Currently, EPA can only call for safety testing if evidence shows a chemical is dangerous. As
a result, EPA has only been able to require testing for about 200 of the more than 80,000
chemicals registered in the U.S. Additionally, the agency has only been able to ban five dan-
gerous substances.
To address these shortcomings, Congress is considering the “Safe Chemicals Act of 2011” to
modernize TSCA. The Act would require the safety testing of all industrial chemicals, and
would place the burden on industry to prove the chemicals they use are safe. EPA would
gain more power to regulate the use of dangerous chemicals. Key components of the Safe
Chemicals Act of 2011 include:
• Minimum data — Would require manufacturers to develop and submit a minimum
data set for each chemical they produce. EPA would have the authority to request
additional information needed to determine the safety of a chemical.
• Risk-based chemical categories — Would require EPA to take fast action to
reduce risk from chemicals that have already been proven dangerous. EPA would
also have authority to act quickly if a chemical poses an immediate hazard.
• Manufacturer burden of proof — Would place the burden of proof on chemical
manufacturers to prove the safety of their chemicals. All uses would need to be iden-
tified and determined safe for the chemical to be placed on the market or continue
to be used.
• Open access to reliable chemical information — Would establish a public data-
base to catalog the chemical information submitted to EPA by manufacturers, in
addition to the safety determinations made by the agency. EPA would impose data
collection requirements.
• Innovation and green chemistry — Would establish grant programs and
research centers to develop safe chemicals alternatives and bring some new chemi-
cals onto the market using an expedited review process.
22–TSCA 3/13

COMPLIANCE GUIDANCE
CONTENTS
Industry Specific
Industry Specific Compliance Information
Automotive Service and Repair — NAICS Code 8111
Dipping and Coating Operations
Painting Contractors, Renovators, Repairers
Photo Processing
Commercial Printing
Security
Environmental Security
Agency Developments Focus on Security
Use These Tools to Build a Secure Facility
Increase Chemical Facility Site Security
Secure Your Company’s Sensitive Information and Technology
Address Hiring Issues and Personnel Security
ISO 14001
ISO 14001
Frequently Asked Questions
ISO 14001/Environmental Management Systems Audit Checklist
Sustainability
Sustainability — a Focus on the Future
Federal Supply Chain
EPA and Sustainable Materials Management
The Lifecycle Approach to Materials Management
9/14 Compliance guidance TOC–1

Reserved
2–Compliance guidance TOC 9/14

Industry specific compliance information

The information in this Industry Specific chapter is designed to give you brief, focused com-
pliance guidance for a particular industrial sector, Standard Industrial Classification (SIC)
Code, or North American Industry Classification System (NAICS) code. Each update will add
a new sector.
Automotive service and repair — NAICS Code 8111

According to the Bureau of Labor Statistics (BLS), the repair and maintenance subsector is
part of the “other services (except public administration)” sector.
In 2011, there were 93,100 jobs in the automotive body and related repairs industry and
there were 221,860 service technicians and mechanics. Over 200,000 more jobs support the
repairers, technicians, and mechanics. So you could say the automotive service and repair
sector represents a big chunk of the economy!
EPA, along with CCAR-GreenLink®, developed the Consolidated Screening Checklist for
Automotive Repair Facilities Guidebook as a tool to help you evaluate compliance at your
shop. The following is an abbreviated version of the checklist and guide. You can find the
whole thing on EPA’s Automotive Repair and Maintenance Sectors webpage here: www.epa.
gov/lawsregs/sectors/automotive.html. Note also that all the topics in the checklist are
explained more fully in the Environmental Compliance section of this book.
As always, please remember that states can, and do, have stricter environmental regula-
tions, policies, guidelines, and interpretations than the federal. Please check with your state
to make sure you are in compliance with the laws in your area.
9/12 Industry specific–1

Consolidated Screening Checklist for Automotive Repair Facilities

(adapted from the EPA/CCAR® guidebook)
Facility name: Facility Location: Inspected by: Date:
Waste management
Yes (Y) No (N) or not applicable
(NA)
Hazardous waste Does the facility have an EPA hazardous waste
generation, storage, generator ID number?
and transport
Does the facility store hazardous waste in appropriate
storage containers?
Does the facility meet all hazardous waste storage
requirements?
Does the facility have a written contingency plan or
basic contingency procedures in place for responding
to spills and releases of hazardous wastes?
Used oil and filters Are used oil containers/tanks and associated piping
labeled “used oil”?
Are used oil containers/tanks and associated piping
leak free?
Does the facility prevent the mixing of used oil with
hazardous wastes?
Does the facility manage or dispose of used oil by:
Sending it off-site for recycling?
Burning it in an on-site space heater?
Burning it off site?
Other
Does the facility manage or dispose of used oil filters
by:
Recycling them?
Sending them to a service company?
Other
Does the facility manage or dispose or used fuel filters
by:
Recycling them?
Sending them to a service company?
Managing them as hazardous waste?
Used antifreeze When stored, does the facility contain, segregate, and
label used antifreeze?
Has the facility determined if it generated any
antifreeze that is a hazardous waste>
Used battery storage Does the facility protect used batteries from contact
and disposal with stormwater?
Does the facility manage or dispose of used batters
by:
Returning them to the supplier?
Recycling them?
Sending to a service company?
Sending them to a hazardous waste site?
Other
2–Industry specific 9/12

Consolidated Screening Checklist for Automotive Repair Facilities , Continued

Used shop rages/towels Does the facility manage or dispose of used shop rags
and towels by:
Using a laundry service?
Burning them for heat?
Managing them as hazardous waste?
Other
Absorbents Does the facility determine if used absorbents are
hazardous before disposal?
Used tires Does the facility manage or dispose of used tires by:
Reselling them?
Retreading them?
Recycling them?
Other
Brake repair Does the facility dispose of spent brake washing
solvent as a hazardous waste?
Does the facility manage asbestos brake repair by:
Recycling off-site?
Disposing by vendor?
Disposing at an EPA-approved disposal site?
Other
Wastewater and stormwater management
Wastewater and Can the facility identify the final destination of its
stormwater wastewaters?
management
If the facility discharges to waters of the U.S., does it
have an NPDES permit?
If discharging to a municipal sanitary sewer, has the
facility notified the Publicly-Owned Treatment Works
(POTW) and received approval for discharges?
If discharging to an underground injection control (UIC)
well, does the facility comply with IUC program
requirements?
Does the facility manage the sludge from an oil/water
separator by:
Managing as hazardous waste?
Sending off-site for disposal at another facility?
Disposing on-site?
Does the facility have a stormwater permit?
Does the facility have a stormwater pollution
prevention plan (SWPPP)?
Are materials stored outside protected from contact
with stormwater?
Air pollution controls and other requirements
Equipment cleaning If halogenated solvents are used in cleaning
and spent solvents equipment, has the facility submitted a notification
report to the air permitting agency?
9/12 Industry specific–3


Does the facility mange or dispose of spent solvents
by:
Using a third-party vendor?
Disposing off-site?
Disposing in storm sewers or surface waters?
Using a UIC well?
In the sanitary sewer?
In the ground?
Other
Fueling and gas Do fuel delivery records indicate compliance with
stations appropriate fuel requirements?
Does the facility use overfill protection measures, spill
containment methods, and spill response equipment
during fueling?
Automotive Painting Does the facility have air permits?
Does the facility manage stripped paint chips and
baghouse dusts by:
Recycling?
Using a municipal or hazardous landfill?
Other
When not in use, does the facility store paints in
labeled containers?
Does the facility manage used paints and paint waste
by:
Returning to the supplier?
Reusing?
Recycling?
Other
Motor vehicle air Does the facility service and/or retrofit MVACs with
conditioning (MVAC) alternate refrigerants?
If yes, are the alternative refrigerants approved under
the Significant New Alternatives Policy (SNAP)?
Catalytic converters Does the facility replace CC’s that are the correct type
based on vehicle requirements?
Does the facility properly mark and keep replaced CCs
on-site for at least 15 days?
Pesticides Does the facility apply pesticides only as directed by
their labels?
Storage tanks, SPCC, and emergency response
Underground storage Has the facility notified the state or EPA UST program
tanks office of any USTs located on-site?
Does the facility conduct leak detection for tanks and
piping of all on-site USTs?
DO USTs at the facility meet requirements for spill,
overfill, and corrosion protections?
Has the owner/operator completed training or provided
training for Class A, B, and C operators?
Aboveground storage Does the facility inspect ASTs on a periodic basis for
tanks leaks and other hazardous conditions?
SPCC and emergency Does the facility’s storage tank capacity make it
response subject to the Oil Pollution prevention regulations?
4–Industry specific 9/12


Could spilled oil reach waters of the U.S. or adjoining
shorelines?
Recordkeeping
Recordkeeping NPDES: Does the facility keep accurate records of
monitoring information for the minimum requirement of
3 years?
AIR: Does the facility meet the recordkeeping
requirements of its air permits?
If the facility owns/operates appliances that contain
ozone-depleting substances or refrigerants, does the
facility maintain all required records?
RCRA: Does the facility keep copies of its manifests
for the 3-year minimum?
USTs: Does the facility maintain leak-detection
records?
Does the facility maintain corrosion protection records?
Does the facility maintain training records according to
state requirements?
Hazardous wastes
Automotive repair shops are likely to create hazardous wastes. EPA points out that it is
important that the facility identify and properly manage hazardous wastes to protect itself,
coworkers, others in the community, and the environment. As a waste generator, the repair
shop is responsible for hazardous waste management, from generation to final disposal. A
facility can be held liable for any mismanagement of its wastes, even after the wastes leave
the facility. It is important for every facility to know what wastes are created during mainte-
nance and repair and whether they are hazardous wastes or not. The following table
provides information on typical wastes created in an automotive service and repair shop.
Note that if you do generate solid wastes, hazardous wastes, or universal wastes, you can
read up on them in the Waste chapter of this book.
Waste Stream Typical Category If Not Typical Category If Typical Category If Dis-
Mixed With Other Hazard- Recycled posed in Landfill and Not
ous Waste Mixed With a Hazardous
Waste 2 ,3
Used Oil (and Shop Rags Used oil Used oil Hazardous waste
for Used Oil)
Used Oil Filters Nonhazardous solid waste Used oil if not drained Nonhazardous solid waste
IF no free flowing used oil IF no free flowing used oil
Oil Spill Absorbent Mate- Used oil Used oil Depends on used oil char-
rial acterization
Used Brake Fluid Used oil Used oil Hazardous waste
Used Antifreeze Used oil Used oil Hazardous waste
Used Solvents Depends on characteriza- Depends on characteriza- Depends on characteriza-
tion tion tion
Used Citric Solvents Hazardous waste Hazardous waste Hazardous waste
Used Cleaning Agents Nonhazardous solid waste Nonhazardous solid waste Nonhazardous solid waste
and Shop Rags for Parts
Shop Rags and Spill Depends on characteriza- Depends on characteriza- Depends on characteriza-
Material Used for Chemi- tion of cleaning agent tion of cleaning agent tion of cleaning agent
cal Solvent and
3/13 Industry specific–5

Spilled or Unused Fuels Hazardous waste Hazardous waste Hazardous waste

Spilled or Unusable Hazardous waste Hazardous waste Hazardous waste
Paints and Thinners
Abrasive grit blast media Depends on material or Depends on material or Depends on material or
paint being blasted (e.g. paint being blasted paint being blasted
latex v. lead paint)
Batteries (1) Lead acid, (1) If hazardous, universal (1) If hazardous, universal (1) If hazardous, universal
Ni/Cd, Ni/Fe (2) Alkaline waste waste waste
(2) Typically a nonhazard- (2) Nonhazardous waste (2) Typically a nonhazard-
ous waste ous waste
Used tires Nonhazardous solid waste Nonhazardous solid waste Nonhazardous solid waste
Dipping and coating operations

Typical NAICS codes for this industry: 322130, 332813, 326199, 335221,
335222, 335224, 335228, 333312, 333415
Dipping and coating operations, those using dip tanks containing liquids other than water,
must comply with the stringent requirements of both workplace safety and environmental
regulations. Additionally, many state regulations apply to dipping and coating, so be sure to
check with your state for the specific regulations that may apply to you.
This section will explore primarily the environmental rules for the dipping and coating
industry, although there is some overlap with OSHA’s workplace safety requirements.
OSHA’s general requirements for dipping and coating operations

OSHA’s regulations require employers to provide a workplace free from recognized hazards.
Because dipping and coating may involve working around open tanks or enclosed spaces,
employees must be trained in the hazards of their jobs. The rules for dipping and coating
6–Industry specific 3/13

operations at 29 CFR 1910.123 through 1910.126 apply to operations such as paint dipping,
electroplating, pickling, quenching, tanning, degreasing, stripping, cleaning, roll coating,
flow coating, and curtain coating. Molten material dip-tank operations are not covered. The
rules specifically apply when you use the liquid in the dip tank to clean, coat, alter the sur-
face, change the character, drain, or dry an object you have dipped or coated.
The general requirements at 1910.124 require you to inspect hoods and ductwork at least
quarterly and prior to operation after a prolonged shutdown to ensure:
• There is no corrosion or damage, and
• The airflow is adequate.
Further, you must inspect all dipping and coating equipment, including:
• Covers,
• Drains,
• Overflow piping, and
• Electrical and fire extinguishing systems.
Any deficiencies must be promptly corrected.
You must locate an emergency shower and eye-wash station close to the dipping or coating
operation and at least one sink with a hot-water faucet for every 10 employees. Also, consid-
ering the types of injuries that could result from your operations, have plenty of first-aid
supplies on hand.
Ventilation is a major concern with dipping and coating. Employees need to take precautions
to protect themselves from direct contact and from inhalation of toxic vapors and fumes.
OSHA requires you to ventilate and clear any pockets where hazardous vapors may have
accumulated. You may need to provide mechanical ventilation or respirators (selected accord-
ing to OSHA’s Respiratory Protection standard at §1910.134), especially when employees are
exposed to toxic substances released during welding, burning, or open-flame work. Be sure
dip tanks are thoroughly cleaned of solvents and vapors before allowing welding, burning or
open-flame work on them.
Workers should be trained to know the:

• Locations and processes which use dip tanks;
• Hazards of the chemicals used;
• Physical hazards around tanks, such as wet floors from drips and splashes;
• Personal Protective Equipment (PPE) that is necessary for a particular process
including aprons, coats, jackets, gloves, sleeves, boots, goggles, face shields, and/or
respirators;
• Company procedures for reporting emergencies and/or accidents;
• Location and use of first-aid supplies;
• Company’s confined space entry procedures, if applicable; and
• Emergency procedures to follow in case of accident of equipment failure.

The regulations at 1910.125 and 1910.126 describe additional requirements for dipping and
coating operations that use flammable liquids or liquids with flashpoints greater than 199.
4°F or operations involving hardening or tempering tanks.
OSHA’s Hazard Communication Standard

OSHA’s Hazard Communication Standard, also known as HazCom or the Right to Know
Law, says workers have a right to know the chemicals they are working with or around.
Dipping and coating operations involve various chemicals, metals, and solvents that will
require you to train employees on dealing with the chemicals in your workplace. This will
include training employees on how to find and understand the Materials Safety Data Sheets
or Safety Data Sheets (SDSs) for the chemicals they will be exposed to.
Additional requirements for dipping and coating operations that use flammable or
combustible liquids
The regulations at §1910.125(e)(5) for controlling ignition and fuel sources require you to
post “NO SMOKING” signs in a vapor area that must be visible near each dip tank.
The regulations at §1910.126(g)(4) for electrostatic paint detearing say that between goods
being electrostatically deteared and the electrodes or conductors of the electrostatic equip-
ment, you must maintain a minimum distance of twice the sparking distance. This
minimum distance must be displayed conspicuously on a sign located near the equipment.
Additional standards for dipping and coating operations

The National Fire Protection Association (NFPA) 34 Standard for Dip Tanks Containing
Flammable or Combustible Liquids is incorporated by reference into OSHA’s regulations.
The standard applies to processes in which materials are passed through tanks, vats, or con-
tainers of flammable or combustible liquids, including dipping, roll, flow, and certain coating,
finishing, treating, cleaning and similar processes. Organic coating manufacturing facilities
involve flammable and combustible liquids. The standard does not apply to storage of organ-
ics in locations other than the manufacturing environment. Among other things, the
standard requires that:
• Organic coatings operations shall not be conducted in the same building with other
occupancies.
• Areas where unstable liquids are handled or processed shall be cut off from the
remainder of the plant by a wall having a fire resistance rating of at least two
hours, and openings equipped with approved fire doors.
ANSI Z9-1-71 Practices for Ventilation and Operation of Open-Surface Tanks is incorporated
by reference into OSHA’s regulations. It covers ventilation and operation of open surface
tanks. The standard aims to protect operators from contact with hazards, such as gases,
vapors, and mists, caused by open surface tank operations. The standard covers the design
of ventilation systems to control these hazards. Among other things, this standard requires
that:
• Floor/platforms around tanks have measures to prevent them from becoming slip-
pery, and
• Tanks be drained before cleaning the interior.

ANSI Standard Z9.1-2006 Ventilation and Control of Airborne Contaminants During Open-
Surface Tank Operations establishes minimum control requirements and ventilation system
design criteria for controlling and removing air contaminants. Its objectives are to protect
the health and well-being of workers who are engaged in open-surface tank operations, and
advise establishments to conform to local or state air pollution regulations.
Environmental considerations for dipping and coating operations

Clean Air Act
Large dipping and coating operations emit volatile organic compounds (VOCs) into the air
that trigger Clean Air Act (CAA) regulations. CAA section 172 requires states to develop
state implementation plans for areas that are not meeting air quality standards
(nonattainment). These areas must include “reasonably available control measures,” includ-
ing “reasonably available control technology” (RACT) for emissions sources. For some
nonattainment areas, states must revise their plans to include RACT for each category of
VOC sources.
EPA defines RACT as “the lowest emission limitation that a particular source is capable of
meeting by the application of control technology that is reasonably available considering
technological and economic feasibility.”
Further, the CAA directs EPA to list for regulation categories of products that account for at
least 80 percent of the VOC emissions from consumer and commercial products in areas that
violate air quality standards for ozone. Large coating operations are on that list. As such,
EPA provides recommendations for RACT for large appliance coating.
EPA has published Control Technique Guidelines (CTGs) for controlling air pollution from
several different types of dipping and coating operations. States can use the recommenda-
tions in the CTGs to determine what constitutes RACT for VOC for large coating operations
in their particular nonattainment areas, but they must submit their RACT rules to EPA for
review and approval. At least 24 state and local jurisdictions have specific regulations that
control VOC emissions from large coating operations.
This section uses EPA’s guidance for General Industry Surface Coating as an example, but
you can also find guidance for many other coating operations at www.epa.gov/ttn/oarpg/t1ctg.
html, including:
• Other metal coating;
• Paper and other web coating operations;
• Large appliance coating;
• Miscellaneous metal and plastic coating;
• Metal furniture coatings; and
• Automobile and Light-Duty Truck Assembly Coatings.
EPA guidance for general industry surface coating
Surface coating is the application of decorative or protective materials in liquid or powder
form to substrates. These coatings normally include general solvent type paints, varnishes,
lacquers, and water-thinned paints. After application of coating by one of a variety of meth-
ods such as brushing, rolling, spraying, dipping and flow coating, the surface is air and/or

heat dried to remove the volatile solvents from the coated surface. Powder type coatings can
be applied to a hot surface or can be melted after application and caused to flow together.
Other coatings can be polymerized after application by thermal curing with infrared or elec-
tron beam systems.
Coating operations
There are both “toll” (independent) and “captive” surface coating operations. Toll operations
fill orders to various manufacturer specifications, and thus change coating and solvent condi-
tions more frequently than do captive companies, which fabricate and coat products within a
single facility and which may operate continuously with the same solvents. Toll and captive
operations differ in emission control systems applicable to coating lines, because not all con-
trols are technically feasible in toll situations.
Coating Formulations
Conventional coatings contain at least 30 volume percent solvents to permit easy handling
and application. They typically contain 70 to 85 percent solvents by volume. These solvents
may be of one component or of a mixture of volatile ethers, acetates, aromatics, cellosolves,
aliphatic hydrocarbons, and/or water. Coatings with 30 volume percent of solvent or less are
called low solvent or “high solids” coatings.
Waterborne coatings, which have recently gained substantial use, are of several types: water
emulsion, water soluble and colloidal dispersion, and electrocoat. Common ratios of water to
solvent organics in emulsion and dispersion coatings are 80:20 and 70:30.
Two-part catalyzed coatings to be dried, powder coatings, hot melts, and radiation cured
(ultraviolet and electron beam) coatings contain essentially no volatile organic compounds
(VOC), although some monomers and other lower molecular weight organics may volatilize.
Depending on the product requirements and the material being coated, a surface may have
one or more layers of coating applied. The first coat may be applied to cover surface imper-
fections or to assure adhesion of the coating. The intermediate coats usually provide the
required color, texture or print, and a clear protective topcoat is often added. General coat-
ing types do not differ from those described, although the intended use and the material to
be coated determine the composition and resins used in the coatings.
Coating application procedures
Conventional spray, which is air atomized and usually hand operated, is one of the most ver-
satile coating methods. Colors can be changed easily, and a variety of sizes and shapes can
be painted under many operating conditions. Conventional, catalyzed, or waterborne coat-
ings can be applied with little modification. The disadvantages are low efficiency from
overspray and high energy requirements for the air compressor.
Evaporation loss sources
In hot airless spray, the paint is forced through an atomizing nozzle. Since volumetric flow is
less, overspray is reduced. Less solvent is also required, thus reducing VOC emissions. Care
must be taken for proper flow of the coating, to avoid plugging and abrading of the nozzle
orifice.

Electrostatic spray is most efficient for low viscosity paints. Charged paint particles are
attracted to an oppositely charged surface. Spray guns, spinning discs, or bell shaped atom-
izers can be used to atomize the paint. Application efficiencies of 90 to 95 percent are
possible, with good “wraparound” and edge coating. Interiors and recessed surfaces are diffi-
cult to coat, however.
Roller coating is used to apply coatings and inks to flat surfaces. If the cylindrical rollers
move in the same direction as the surface to be coated, the system is called a direct roll
coater. If they rotate in the opposite direction, the system is a reverse roll coater. Coatings
can be applied to any flat surface efficiently and uniformly and at high speeds. Printing and
decorative graining are applied with direct rollers. Reverse rollers are used to apply fillers to
porous or imperfect substrates, including papers and fabrics, to give a smooth uniform
surface.
Knife coating is relatively inexpensive, but it is not appropriate for coating unstable materi-
als, such as some knit goods, or when a high degree of accuracy in the coating thickness is
required.
Rotogravure printing is widely used in coating vinyl imitation leathers and wallpaper, and in
the application of a transparent protective layer over the printed pattern. In rotogravure
printing, the image area is recessed, or “intaglio,” relative to the copper plated cylinder on
which the image is engraved. The ink is picked up on the engraved area, and excess ink is
scraped off the non-image area with a “doctor blade.” The image is transferred directly to
the paper or other substrate, which is webfed, and the product is then dried.
Dip coating requires that the surface of the subject be immersed in a bath of paint. Dipping
is effective for coating irregularly shaped or bulky items and for priming. All surfaces are
covered, but coating thickness varies, edge blistering can occur, and a good appearance is not
always achieved.
In flow coating, materials to be coated are conveyed through a flow of paint. Paint flow is
directed, without atomization, toward the surface through multiple nozzles, then is caught
in a trough and recycled. For flat surfaces, close control of film thickness can be maintained
by passing the surface through a constantly flowing curtain of paint at a controlled rate.
Emissions and controls
Essentially all of the VOC emitted from the surface coating industry is from the solvents
which are used in the paint formulations, used to thin paints at the coating facility, or used
for cleanup. All unrecovered solvent can be considered potential emissions. Monomers and
low molecular weight organics can be emitted from those coatings that do not include sol-
vents, but such emissions are essentially negligible.
Emissions from surface coating for an uncontrolled facility can be estimated by assuming
that all VOC in the coatings is emitted. Usually, coating consumption volume will be known,
and some information about the types of coatings and solvents will be available. The choice
of a particular emission factor will depend on the coating data available. If no specific infor-
mation is given for the coating, it may be estimated from the data in the table that follows.
All solvents separately purchased as solvent that are used in surface coating operations and
are not recovered subsequently can be considered potential emissions. Such VOC emissions
at a facility can result from onsite dilution of coatings with solvent, from “makeup solvents”

required in flow coating and, in some instances, dip coating, and from the solvents used for
cleanup. Makeup solvents are added to coatings to compensate for standing losses, concen-
tration or amount, and thus to bring the coating back to working specifications. Solvent
emissions should be added to VOC emissions from coatings to get total emissions from a
coating facility.
Typical ranges of control efficiencies are given in the table. Emission controls normally fall
under one of three categories: modification in paint formula, process changes, or add-on
controls.
EMISSION FACTORS
VOC Emission Factors for Uncontrolled Surface Coating*
Emission factor Rating: B
Available Information On Coating Emissions Of VOC**
Conventional or waterborne paints: kg/liter of coating Or lb/gal of coating ***
VOC, wt % (d) d • (coating density)/100
or V • (solvent density)/100
VOC, vol % (V) d • X • (coating density)/100
Waterborne paint: V • Y • (solvent density)/100
X = VOC as wt % of total volatiles including water; and
d = total volatiles as wt % of coating
or
Y = VOC as vol % of total volatiles including water; and
V = total volatiles as vol % of coating
* Based on material balance, assuming entire VOC content is emitted.
** For special purposes, factors expressed in kg per liter of coating less water may be desired.
*** If coating density is not known, typical densities are given in Table 4.2.2.1-2. If solvent density is not known, the average density of
solvent in coatings is 0.88 kg/L (7.36 lb/gal).
Typical Densities and Solids Contents of Coatings

Type Of Coating Density Solids (Volume %)
kg/L lb/gal
Enamel, air dry 0.91 7.6 39.6
Enamel, baking 1.09 9.1 42.8
Acrylic enamel 1.07 8.9 30.3
Alkyd enamel 0.96 8.0 47.2
Primer surfacer 1.13 9.4 49.0
Primer, epoxy 1.26 10.5 57.2
Varnish, baking 0.79 6.6 35.3
Lacquer, spraying 0.95 7.9 26.1
Vinyl, roller coat 0.92 7.7 12.0
Polyurethane 1.10 9.2 31.7
Stain 0.88 7.3 21.6
Sealer 0.84 7.0 11.7
Magnet wire enamel 0.94 7.8 25.0
Paper coating 0.92 7.7 22.0
Fabric coating 0.92 7.7 22.0

Control Efficiencies for Surface Coating Operations

Control Option Reduction*(%)
Substitute waterborne coatings 60 - 95
Substitute low solvent coatings 40 - 80
Substitute powder coatings 92 - 98
Add afterburners/incinerators 95
*Expressed as % of total uncontrolled emission load.
Clean Water Act

Dipping and coating operations must meet effluent limits as established in the Effluent
Guidelines and Standards for Metal Finishing at 40 CFR Part 433. In addition, dipping and
coating operations will need to follow the requirements of their National Pollutant Discharge
and Elimination System (NPDES) permits along with any state or local discharge permits.
As authorized by the Clean Water Act, the NPDES permit program controls water pollution
by regulating point sources that discharge pollutants into waters of the United States.
Facilities discharging wastewater to publicly owned treatment works (POTWs) are consid-
ered indirect dischargers and are regulated under the EPA’s pretreatment program. The
General Pretreatment Regulations establish responsibilities of federal, state, and local gov-
ernment, industry, and the public. The objective of pretreatment standards is to control
pollutants from the industrial users which may pass through or interfere with POTW treat-
ment processes or which may contaminate sewage sludge.
States determine the appropriate uses of each water body within the state (e.g., drinking
water supply, fishable/swimmable, agriculture). States then establish water quality stan-
dards, or maximum pollutant levels, for those bodies of water that are necessary to attain or
maintain the designated use. An appropriate standard may be expressed as a numerical
ambient water quality criterion (e.g., a specified amount of dissolved oxygen per unit of
water). State standards also may include a narrative water quality criterion, (e.g., no dis-
charge of toxic pollutants in toxic amounts.) Some states may allow for the attainment of
water quality standards at some point within the receiving water (rather than at the end of
a pipe).
Effluent guidelines are national standards, based on the performance or treatment and con-
trol technologies, for wastewater discharges to surface water and municipal sewage
treatment plants. EPA issues effluent guidelines for industries. For more assistance with
effluent guidelines, go to water.epa.gov/scitech/wastetech/guide/index.cfm.
EPA has existing effluent guidelines for several categories of dipping and coating operations,
including coil coating, electroplating, and metal finishing. The regulations at 40 CFR 433.13
list the effluent limitations representing the degree of effluent reduction attainable by apply-
ing the best practicable control technology currently available (BPT) for metal finishing.
BPT Effluent Limitations
Pollutant or pollutant property Maximum for any 1 day Monthly average shall not exceed
Milligrams per liter (mg/l)
Cadmium (T) 0.69 0.26
Chromium (T) 2.77 1.71

BPT Effluent Limitations, Continued

Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
Oil & Grease 52 26
TSS 60 31
pH (1) (1)
1
Within 6.0 to 9.0.
Important: EPA does not allow you to augment the use of process wastewater or otherwise
dilute the wastewater as a partial or total substitute for adequate treatment to achieve com-
pliance with this limitation.
The following table lists the effluent limitations representing the degree of effluent reduction
attainable by applying the best available technology economically achievable (BAT).
BAT Effluent Limitations
Cadmium (T) 0.69 0.26
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
Pretreatment standards for existing sources (PSES):

PSES for All Plants Except Job Shops and Independent Printed Circuit Board Manufacturers
Cadmium (T) 0.69 0.26
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13

New source performance standards (NSPS)
Any new source subject to this subpart must achieve the following performance standards:
NSPS
Cadmium (T) 0.11 0.07
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
Oil and Grease 52 26
TSS 60 31
pH (1) (1)
1
Within 6.0 to 9.0.
Pretreatment standards for new sources (PSNS).
Except as provided in 40 CFR 403.7, any new source subject to this subpart that introduces
pollutants into a publicly owned treatment works must comply with 40 CFR part 403 and
achieve the following pretreatment standards for new sources (PSNS):
PSNS
Cadmium (T) 0.11 0.07
Copper (T) 3.38 2.07
Lead (T) 0.69 0.43
Nickel (T) 3.98 2.38
Silver (T) 0.43 0.24
Zinc (T) 2.61 1.48
Cyanide (T) 1.20 0.65
TTO 2.13
Solid and hazardous waste

Dipping and coating operations must comply with the solid and hazardous waste regulations
at 40 CFR 262 if they generate and manage listed waste or characteristic hazardous waste.
EPA’s regulations establish two ways of identifying solid wastes as hazardous under the
Resource Conservation and Recovery Act (RCRA). A waste may be considered hazardous if it
exhibits certain hazardous properties (“characteristics”) or if it is included on a specific list
of wastes EPA has determined are hazardous because they pose substantial present or

potential hazards to human health or the environment. EPA’s regulations define four haz-
ardous waste characteristic properties: ignitability, corrosivity, reactivity, or toxicity.
Hazardous waste generators are regulated by category:
• Conditionally exempt small quantity generators (CESQGs) produce 100 kg or less of
hazardous waste per month or 1 kg or less of acutely hazardous waste;
• Small quantity generators (SQGs) produce between 100 kg and 1000 kg of hazard-
ous waste per month AND accumulate less than 6,000 kg of hazardous waste at any
one time; and
• Large quantity generators (LQGs) produce at least 1,000 kilograms (kg) of hazardous
waste per month or 1 kg of acutely hazardous waste per month.
Dipping and coating processes such as chromating, phosphating, metal coloring, and/or
immersion plating can generate listed waste such as wastewater treatment sludge from the
treatment of the rinse and overflow wastewaters from the chemical conversion process and
they also may generate characteristic wastes.
EPA’s regulations covering the generation, storage, treatment, and disposal of hazardous
waste require you to properly mark and label the waste; keep all containers closed unless
you are adding or removing waste; obtain an EPA identification number; and fill out a haz-
ardous waste manifest for transporting hazardous waste for treatment, storage, or disposal.
EPA has issued guidance for LQGs with wastewater treatment sludges from metal finishing.
The agency encourages metal finishers to recycle listed wastes, especially hazardous waste-
water treatment sludge (RCRA listed waste F006), which is generated from the
electroplating process. This waste generally contains recoverable amounts of metals.
Although some of the sludge is recycled for metals recovery, a large percentage used to be
land disposed. An EPA final rule from 2000 encourages recycling F006 waste through metals
recovery. The rule allows LQGs to store F006 waste up to 180 days (or 270 days, if appli-
cable) on site without a hazardous waste storage permit or interim status, provided that
these generators meet certain conditions. (Generally, LQGs are only allowed to store waste
up to 90 days.)
To accumulate F006 waste up to 180 days (or 270 days, if applicable), a generator of F006
waste must:
• Have implemented pollution prevention practices that reduce the amount of any
hazardous substance, pollutant, or contaminant entering F006 or otherwise released
into the environment prior to its recycling;
• Recycle the F006 by metals recovery;
• Accumulate no more than 20,000 kilograms of F006 waste on site at any one time;
and
• Comply with the applicable management standards, such as accumulation in tanks,
containers, or containment buildings, labeling and marking accumulation units, pre-
paredness and prevention, contingency plan and emergency procedures, personnel
training, and waste analysis and recordkeeping.

Community right to know

Under the Community right to know provisions, facilities that produce, import, or store haz-
ardous substances or generate hazardous wastes must report on their activities to EPA,
emergency responders, and the public.
The Emergency Planning and Community Right to Know Act (EPCRA) requires facilities to:
• Cooperate with state and local planning officials in preparing comprehensive emer-
gency plans (Sections 302 and 303);
• Report accidental releases of “extremely hazardous substances” and “hazardous sub-
stances” to state and local response officials (Section 304);
• Make Safety Data Sheets (SDSs) available to local and state officials, and also
report to local and state officials inventories (including locations) of chemicals on
their premises for which SDSs exist (Sections 311 and 312).
Dipping and coating operations may also be required to report under the Toxics Release
Inventory program (TRI) (Section 313). TRI requires certain businesses to submit reports
each year on the amounts of EPCRA section 313 chemicals their facilities released into the
environment (either routinely or as a result of accidents), or otherwise managed as waste.
Section 313 requires facilities to report for each listed chemical the amount released to air,
water, land, underground injection, and transferred off-site for disposal. Facilities also must
report the amounts of those EPCRA section 313 chemicals otherwise managed as waste,
including on-site treatment, combustion for energy recovery, recycling and transfers off-site
for treatment, combustion for energy recovery and recycling.
Painting contractors, renovators, repairers
If you are a painting contractor or renovator, whether for residential or commercial build-
ings, you know you must comply with a number of state and federal regulations, including
standards covering:
• Worker safety
• Air pollution
• Solid and hazardous waste
• Water pollution.

• Lead-based paint abatement programs

• Asbestos and PCBs
Worker safety
Painting contractors may fall under the OSHA regulations for general industry or for
construction. Both sets of standards cover requirements for fall protection, ladder safety,
Hazard Communication, personal protective equipment, hearing conservation, injury and
illness recordkeeping, and much more. Check with your local OSHA office or state worker
protection agency to be sure you are in compliance with the safety regulations that apply to
you.
Air pollution
Indoor work presents special considerations for painting contractors.
Indoor Air Quality
Preparing a surface for painting, including stripping and sanding, can release dust particles
that are hazardous to your health. Inhaling dust particles can trigger asthma and other lung
irritation, and if the surface was painted before 1978, the dust could contain lead.
Paint can give off volatile organic compounds (VOCs) that can also cause health problems
such as eye and throat irritation, headaches, dizziness, and vision problems. If the exposure
occurs over a long period of time, damage can occur to the nervous system, liver, and
kidneys.
EPA recommends:
• Checking to be sure the painted surface is lead-free or following the appropriate
steps for lead-based paint abatement;
• Selecting the correct paint (only use approved indoor paints indoors);
• Notifying neighbors if work is being done in apartment buildings. Harmful gases
can move through shared walls, and gaps around pipes or outlets.
• Minimize exposure to odors and contaminants by using exhaust fans and providing
as much ventilation as possible and taking frequent fresh-air breaks; and
• Using and handling paint strippers properly. Paint stripper can contain caustic and
hazardous chemicals. Use with caution.
Outdoor work
Most painting contracting operations, especially smaller residential jobs, are exempt from
air permitting regulations. Whether or not a painting job is exempt will depend on the size
of the operation and the type of materials being used (e.g., low-VOC paints).
Precautions should always be used to control overspray and fumes from outdoor painting
operations.
Sandblasting is a special consideration. Many states regulate sandblasting through their air
pollution regulations. You may need to acquire a permit to conduct sandblasting.

Solid and hazardous waste

It can be difficult to know what to do with leftover paints and solvents, paint cans, and
painting rags. The following tips may help you minimize paint waste and assist you with
proper disposal.
1. Think small. Buy the smallest amount of paint you need to get the job done.
2. Choose carefully. Whenever possible, choose the paint with the smallest environ-
mental impact. Choose latex paints, which don’t usually contain hazardous
ingredients and don’t require accompanying hazardous substances such as paint
thinners and solvents for cleanup.
3. Give it away. A paint is not considered a waste until you decide to dispose of it. If
you give it to a charity, a local theater group, a high school, church, or reuse store,
you do not have to count it toward your monthly hazardous waste total.
Latex paints, unless they contain certain additives such as metals or fungicides, are
not hazardous wastes in most states. Oil-based paints, because of their high concen-
tration of VOCs, are usually considered to be hazardous wastes.
4. Store it. You can store most paints for a very long time (some sources say up to 15
years). Most paint experts tell you to cover partially full cans with a plastic wrap
and then hammer the lid on tightly. Store paint cans upside-down to keep air from
reaching the paint and drying it out. Also, prevent paint from freezing and thawing.
If you plan to use the paint eventually, it is not a waste. Store paint in the original
can or in a properly marked container.
5. Recycle it. Some states or municipalities offer paint recycling programs, where, for
a small fee, you can drop off your partially full cans of paint and know they will not
end up in the landfill.
Empty paint cans are recyclable through your normal recycling process. Just make
sure to separate cans and lids so the recycler can verify the cans are empty.
6. Dispose it. For small amounts of leftover latex and other water-based paints, you
can let the paint air-dry in the can or you can add a commercial paint hardener.
Other paint-drying methods include adding sawdust or kitty-litter to the paint, or
applying the paint in thin layers to newspaper and allowing it to dry. For larger
amounts, you can try pouring thin layers (up to one-inch thick) into plastic lined
cardboard boxes to dry. Once the paint is dry, most states allow you to dispose it in
the landfill. However, you will want to check with your state, your city, and your
waste hauler to be certain.
Oil-based paints, which include solvents, lacquers, shellacs, stains, sealers, and any
cleanup materials contaminated with hazardous substances, must be disposed of as
hazardous wastes. Never pour any paint down the drain.
* EPA’s July 2013 solvent-contaminated wipes rule may apply to your operations.
The “conditional” exclusion to the definition of hazardous waste does not apply to
wipes that are contaminated with a listed hazardous waste other than a solvent, or
a waste that exhibits the characteristic of toxicity, corrosivity, or reactivity due to
contaminants other than solvents. So if you have a wipe that is contaminated with a
solvent and a paint waste, that wipe must be handed under the solid and hazardous
waste rules (i.e., identified as a solid or hazardous waste). See the Waste chapter in
this book for more information.

7. Know your state rules and exemptions. Some states have progressive recycling
programs that cover all types of paints. Texas regulates paint waste as a universal
waste. Ohio will allow painting contractors who work on residential homes to take
advantage of the federal household hazardous waste exemptions. States such as
Minnesota, Oregon, and California have mandatory manufacturer take-back
programs.
8. Train employees in the proper use of paint, how to avoid spills, and how to handle
paint waste properly.
Water pollution
Many states regulate wastewater that results from cleaning painting equipment (e.g.,
brushes, sprayers, rags) as industrial wastewater. Never discharge industrial wastewater
onto the ground, down drains, into sewers, or into on-site septic systems.
For bigger jobs, you can consider installing a wastewater holding tank that can be hauled to
an industrial waste treatment or waste disposal facility.
You may need to obtain a permit to discharge to the local wastewater treatment plant. Con-
tact your state or the wastewater treatment plant directly for more information.
Lead-based paint considerations

Most homes and businesses built before 1978 contain at least some lead-based paint. That’s
a concern because when ingested, lead can cause serious health effects, especially in
children. Lead can cause permanent brain damage, leading to behavioral and learning prob-
lems, lowered IQ, and hearing problems. Lead can interfere with growth and also cause
anemia, seizures, coma, and even death.
Children and adults can be exposed to lead through the air, water, and soil. In older homes,
lead-based paint easily crumbles or turns to dust when it is disturbed through actions such
as opening and closing windows or doors or during renovation activities.
As a result, any renovation, repair, and painting activity in a pre-1978 home or child-
occupied facility will require the work to be completed by an EPA-certified firm. This
requirement may soon expand to commercial businesses, too.
Certification
EPA’s Lead Abatement Program: Training and Certification rule, mandated under
sections 402 and 404 of the Toxic Substances Control Act (TSCA), covers lead-based paint
activities, including the scope of the program, accreditation of training programs, certifica-
tion of individuals and firms, work practice standards, and enforcement and inspections.
At the same time, EPA’s Lead Renovation, Repair, and Painting (RRP) rule, regulated
at 40 CFR 745 Subpart E, requires that firms performing renovation, repair, and painting
projects that disturb lead-based paint in pre-1978 homes and child-occupied facilities be cer-
tified by the agency and use certified renovators who are trained by EPA-approved training
providers to follow lead-safe work practices. Individuals can become certified renovators by
taking an eight-hour training course from an EPA-approved training provider.
The rule says that firms preforming renovation, repair, and painting projects that disturb
lead-based paint in “target housing” and child-occupied facilities must be certified by EPA.

Individual workers in the firms must be trained by EPA-approved training providers to fol-
low lead-safe work practices.
Anyone doing work on their own home is not covered by the rule; it only applies to work-for-
hire. However, everyone will benefit from using lead-safe work practices. Further, no one is
required to remove the lead-based paint in their homes or businesses. The rule simply states
that contractors must meet specific work practices if they do work that would disturb sur-
faces painted with lead-based paint.
The training and certification requirements contained in both regulations ensure that:
• Lead-based paint professionals are properly trained to conduct lead-based paint
activities in residential dwellings and facilities regularly occupied by young children,
such as day-care centers and pre-schools;
• Lead-based paint inspections, risk assessments, and abatements are conducted reli-
ably, safely, and effectively; and
• Training providers are accredited and capable of providing quality instruction to
lead professionals.
Who has to be certified?
• The federal lead training and certification program establishes five categories or dis-
ciplines of lead-based paint professionals: supervisors, workers, inspectors, risk
assessors, and project designers.
• An individual who conducts inspection services must either be a certified inspector
or a certified risk assessor. An individual who performs risk assessment services
must be a certified risk assessor. The certification requirements for abatement
activities depend on the type of work the individuals will be performing. For
example, workers and supervisors are required to conduct the actual lead abatement
work, while inspectors or risk assessors conduct the clearance testing and supervi-
sors or project designers prepare occupant protection plans and abatement reports.
States and Indian Tribes that receive authorization to run their own programs may
have slightly different certification requirements.
The regulation requires renovation firms to be certified. Individual workers must
be trained by certified renovation contractors in lead-safe work practices.
Under the regulations, a firm is a business made up of more than one person that does work
for hire. Firms that perform renovations for compensation must apply to EPA and obtain
certification to perform the renovations or dust sampling. Firms must complete the “Applica-
tion for Firms,” have an authorized agent of the firm sign it, and pay a fee. Then firms must
be re-certified every five years and must complete an amendment of certification if a change
occurs to information included in the firm’s most recent application.
In addition, firms must ensure that:
• All individuals performing renovation activities for the firm are certified renovators
or have been trained by a certified renovator;
• A certified renovator is assigned to each renovation performed by the firm; and
• It follows the pre-renovation education requirements and recordkeeping
requirements.

Work-practice standards for renovation, repair, and painting

Contractors performing renovation activities such as sanding, cutting, and demolition must
use lead-safe work practices and contain the work area, minimize dust, and clean up thor-
oughly, as outlined in 40 CFR 745.85.
Firms must also post signs clearly defining the work area and warning occupants and others
to remain outside of the work area. Occupants should be able to read the signs in their own
language, to the extent practicable. They must be posted before beginning work and left up
until the work is completed.
In addition, before beginning the work, the firm must isolate the work area using plastic
sheeting or other impermeable material so that no dust or debris escapes while work is
being done and ensure that the material used to contain the area is not torn or moved. Of
course, the containment materials can’t block exits or other means of egress for workers.
Other required work practices include, but are not limited to:
• Indoor work: Firms must remove all objects from the work area or cover every-
thing with plastic sheeting and tape town all seams and edges and ensure that dust
cannot migrate from the work area into other indoor areas.
• Outdoor work: Firms must cover the ground with plastic sheeting extending 10
feet beyond the perimeter of surfaces undergoing renovation or a sufficient distance
to collect falling paint debris and ensure that dust from the outdoor project cannot
blow into the building.
• Prohibited or restricted work: Firms may not use open-flame burning or torch-
ing of painted surfaces or use sanders, grinders, blasters, or other equipment on
painted surfaces unless the machines have shrouds or containment systems and are
equipped with HEPA vacuum attachments to collect dust and debris at the point of
generation. There should be no visible dust outside the containment system.
• Waste: Waste from the renovation work must be contained to prevent releases of
dust and debris before it can be removed from the site and waste must be collected
at the end of each work day and at the end of the project and stored in a way that
prevents the escape of dust and debris.
• Clean-up: The firm must collect all paint chips and debris and seal it all in a
heavy-duty bag, remove any protective sheeting and mist it before folding, and clean
all objects and surfaces in the work area and within two feet of the work area,
cleaning from higher to lower.
• Post-renovation cleaning verification: Once the work is complete, a certified
renovator must perform a visual inspection to determine whether dust, debris, or
residue is still present. If dust or debris is found, it must be removed by re-cleaning.
• Dust clearance testing: The firm must re-clean the work area until all dust
sample results are within the clearance standards at §745.227(e)(8) or any other
standard that applies.

• Recordkeeping and reporting requirements: The recordkeeping and reporting

requirements at §745.86 tells firms performing renovations that they must keep
and, if requested, make available to EPA all records showing they’ve been complaint
with the Lead RRP for a period of three years following the renovation. States and
localities may have longer retention periods. When the final invoice for the renova-
tion is delivered, or within 30 days of the completion of the renovation, the
renovation firm must provide information showing compliance with the regulation
to:
❍ The building owner, and, if different,
❍ An adult occupant of the residential dwelling or child-occupied facility.
Posting and information distribution requirement
Renovation firms must post:
• Signs clearly defining the work area;
• Information, or instructions on how occupants can obtain a copy of the information,
in common areas of multi-unit target housing, or in areas where it is likely to be
seen by the occupants of all the affected units; and
• Dust sampling reports, or information on how to obtain copies of the report, in com-
mon areas of target housing or is areas where they are most likely to be seen by the
occupants of all the affected units.
The regulations at §745.84 say that no more than 60 days before beginning any renovation
in a residential dwelling unit of target housing, the firm must provide the owner of the unit
with the mandatory EPA lead pamphlet, Renovate Right: Important Lead Hazard Informa-
tion for Families, Child Care Providers and Schools. They must get a written
acknowledgment that the owner has received the pamphlet, or certify in writing the pam-
phlet has been delivered to the dwelling and that the firm performing the renovation was
unable to obtain a written acknowledgment from an adult occupant.
Find EPA’s brochures and posters at www2.epa.gov/lead/brochures-and-posters.
Test kits
The federal standard for lead-based paint in target housing and child-occupied facilities is
lead content in paint that equals or exceeds a level of 1.0 million per square centimeter (mg/
cm2) or 0.5 percent by weight.
EPA says that lead-based paint is assumed to be present at renovations covered by
SubpartE; therefore, firms will need to do testing. Recognized test kits are listed at www.
epa.gov/lead/testkit.html .
The RRP rule lists criteria for recognizing test kits that detect lead in paint. Initially, a lead
test kit could be EPA-recognized if it met the negative response criterion of no more than
five percent false negatives, with 95 percent confidence for paint containing lead at or above
the regulated level. EPA will continue to recognize kits that meet the negative response cri-
terion until such time as a test kit meets both the negative response and positive response
criteria outlined in the Lead RRP.
Any newly recognized test kit must meet both the negative and positive response criteria of
no more than five percent false negatives and no more than ten percent false positives, each
with 95 percent confidence, as related to the regulated level of lead in paint. No test kit has
yet been developed to meet these criteria.

Definitions
The following terms related to EPA’s Lead RRP and abatement rules:
Abatement
Permanent removal of lead-based paint and contaminated dust and soil, which can include
the removal of paint and painted surfaces, specialized cleaning of dust along with addressing
the underlying cause, the permanent enclosure of encapsulation of lead-based paint, or the
removal or permanent covering of soil. Abatement of lead can be performed legally only by
certified abatement firms using trained and certified staff. Abatement will result in complete
elimination of lead and lead hazards (or, long-term encapsulation of all lead-based paint).
Child-occupied facility
A building, or portion of a building, constructed prior to 1978, visited regularly by the same
child, under 6 years of age, on at least two different days within any week (Sunday through
Saturday period), provided that each day’s visit lasts at least 3 hours and the combined
weekly visits last at least 6 hours, and the combined annual visits last at least 60 hours.
Child-occupied facilities may include, but are not limited to, day care centers, preschools and
kindergarten classrooms. Child-occupied facilities may be located in target housing or in
public or commercial buildings. With respect to common areas in public or commercial build-
ings that contain child-occupied facilities, the child-occupied facility encompasses only those
common areas that are routinely used by children under age 6, such as restrooms and
cafeterias. Common areas that children under age 6 only pass through, such as hallways,
stairways, and garages are not included. In addition, with respect to exteriors of public or
commercial buildings that contain child-occupied facilities, the child-occupied facility encom-
passes only the exterior sides of the building that are immediately adjacent to the child-
occupied facility or the common areas routinely used by children under age 6.
Inspection
A surface-by-surface investigation to determine whether there is lead-based paint in a home
or child-occupied facility and where it is located. Inspections can be performed legally only
by certified inspectors. Lead-based paint inspections determine the presence of lead in paint,
dust, and soil using precise testing. It is particularly helpful in identifying where lead is
present prior to purchasing, renting, or renovating a home, and to identify potential sources
of lead exposure at any time.
Lead-based paint activities
In the case of target housing and child-occupied facilities, these activities include inspection,
risk assessment, abatement, renovation, and repair.
Risk assessment
An onsite investigation to determine the presence, type, severity, and location of lead-based
paint hazards (including lead hazards in paint, dust, and soil) and to provide suggested
ways to control them. Risk assessments can be performed legally only by certified risk
assessors. Lead-based paint risk assessments are particularly helpful in determining sources
of current exposure and in designing possible solutions. Risk assessments can be combined
with inspections.

Target housing
Includes most private housing, public housing, housing receiving federal assistance, and fed-
erally owned housing built before 1978. Target housing does not include housing built after
1977 because the Consumer Products Safety Commission banned the sale and distribution of
lead-based paint to be used in housing in 1978. Nor does it include “0-bedroom dwellings,”
(such as lofts, efficiencies, and studios) or housing designated for the elderly and the handi-
capped (unless children reside or are expected to reside there).
Renovation
Removing, modifying or repairing painted surfaces or painted components. Examples include
modifying painted doors, surface restoration, window repair, and surface preparation activity
like sanding and scraping that may generate paint dust; Removing building components
such as walls, ceilings, plumbing, or windows; Weatherization projects such as cutting holes
in painted surfaces to install blown-in insulation or to gain access to attics, or planing
thresholds to install weather-stripping; and Interim controls that disturb painted surfaces.
Authorized state requirements
Contractors and training providers working in certain states must contact the state to find
out more about its training and certification requirements. That’s because these states are
authorized to administer their own RRP programs in lieu of the federal program. The latest
list of authorized states is available at www.epa.gov/lead/rrp/lscp-renovation-firm.html.
Lead abatement vs. lead renovation, repair, and painting (RRP)

Lead-based paint inspection, risk assessment, and abatement services are regulated differ-
ently than renovation, repair, and painting jobs, even though, in some cases, the activities
are similar.
Lead abatement projects are designed to permanently eliminate existing lead-based paint
hazards and may be ordered by a state or local government in response to a lead-poisoned or
other reason. Only trained and certified individuals may perform lead abatement.
RRP projects, on the other hand, are typically performed at the option of the property owner
for aesthetic or other reasons, or as an interim control to minimize lead issues. They are not
designed to permanently address lead-based paint. However, RRP projects can disturb lead-
based paint in homes and buildings built before 1978 and cause lead hazards, even when
none existed before. Therefore, they are also regulated (but under 40 CFR 745 Subpart E)
and require certification.
Sample Checklist : Renovation Recordkeeping
Use the following sample checklist to make sure your are in compliance with the
recordkeeping requirements of the Lead RRP. (Source: EPA’s Small Entity Compliance Guide
to Renovate Right)


Other considerations — Asbestos and PCBs

Asbestos
Generally, asbestos-containing materials that are intact and in good condition are not likely
to pose a health risk. EPA recommends leaving asbestos-containing materials alone as long
as they are in good condition. Exposure to asbestos in the air can lead to lung disease,
including lung cancer, mesothelioma, and asbestosis.
Repairs and remodeling (including certain painting activities) can disturb asbestos-
containing materials and release asbestos fibers into the air. Any work that will disturb
asbestos-containing material should be conducted by a trained and accredited asbestos
professional.
The two main types of accredited asbestos professionals are:

• Asbestos Inspectors. These individuals can inspect a home or building, assess condi-
tions, take samples of suspected materials for testing, and advise about what
corrections are needed. If repair or removal of asbestos materials is chosen, inspec-
tors can ensure the corrective-action contractor has followed proper procedures,
including proper clean up, and can monitor the air to ensure no increase of asbestos
fibers.
• Asbestos Contractors. These professionals can repair or remove asbestos materials.
While current federal law does not require persons who inspect, repair, or remove asbestos-
contaminated materials in detached single-family homes to be trained and accredited, many
states do require this.
Regulations and work practices
Air toxics regulations under the Clean Air Act specify work practices for asbestos to be fol-
lowed during demolitions and renovations of all facilities, including, but not limited to,
structures, installations, and buildings (excluding residential buildings that have four or
fewer dwelling units). The regulations require a thorough inspection where the demolition or
renovation operation will occur.
The regulations also require the owner or the operator of the renovation or demolition opera-
tion to notify the appropriate delegated entity (often a state agency) before any demolition,
or before any renovations of buildings that contain a certain threshold amount of regulated
asbestos-containing material. The rule requires work practice standards that control asbes-
tos emissions. Work practices often involve removing all asbestos-containing materials,
adequately wetting all regulated asbestos-containing materials, sealing the material in leak
tight containers, and disposing of the asbestos-containing waste material as expediently as
practicable, as the regulation explains in greater detail.
These work practice standards are designed to minimize the release of asbestos fibers during
building demolition or renovation, waste packaging, transportation, and disposal.
When buildings are under renovation, they are not being demolished, but asbestos-
containing building material is being removed or disturbed. Performing the work in
accordance with clean air rules helps to ensure that areas in use during the renovation are
not contaminated and that the area under renovation, when it is complete, is also free of
contamination.

PCBs
PCBs were manufactured from the late 1920s until 1979 when their manufacture was
banned by the TSCA. Caulk and other PCB containing products like paint and sealants
were used in many buildings in the 1950s through the 1970s. In general, schools and build-
ings built after 1978 do not contain PCBs in caulk or other products. Building owners can
look through historical records to help determine if PCB-manufactured products were used
in the building. However, sampling is the only way to be certain if a building has PCB
contamination.
EPA regulates the cleanup and disposal of PCB-containing wastes as either PCB bulk prod-
uct waste or PCB remediation waste.
A 2012 EPA “reinterpretation” found that waste derived from caulk or paint containing
PCBs at greater than or equal to 50 parts per million (ppm) is defined as PCB bulk product
waste in 40 CFR §761.3. The definition of PCB bulk product waste includes “non-liquid bulk
wastes or debris from the demolition of buildings and other man-made structures manufac-
tured, coated, or serviced with PCBs.” Other PCB bulk product wastes may include, but are
not limited to, mastics, sealants, or adhesives containing PCBs at greater than or equal to
50 ppm.
PCB remediation waste is defined as “waste containing PCBs as a result of a spill, release,
or other unauthorized disposal...” and leaching may be considered a release of PCBs.
Basically, according to the reinterpretation, building material (i.e., substrate) “coated or ser-
viced” with PCB bulk product waste (e.g., caulk, paint, mastics, sealants) at the time of
disposal may be managed as a PCB bulk product waste, even if the PCBs have migrated
from the overlying bulk product waste into the substrate.
EPA has determined PCB bulk product waste can be safely disposed of in certain non-TSCA
approved landfills (those that have been permitted, licensed, or registered by a State as a
municipal or non-municipal non-hazardous waste landfill).
Learn more at www.epa.gov/wastes/hazard/tsd/pcbs/pubs/caulk/reinterpret.htm.

Photo processing
Photo processors face many environmental challenges, from working with hazardous chemi-
cals to storing, disposing, and recycling development wastes. In addition, employers in this
industry must create and maintain a hazard communication program to train employees to
work safely around the chemicals in their workplaces.
One of the main pain points for photo developers is what to do with development waste.
Photo development waste

The following list can help photo processors comply with federal solid and hazardous waste
regulations. As waste is often regulated at the state and local level, be sure to check with
your state for any additional requirements that may apply to your operations.
1. Identify all the wastes in your waste stream according to the regulations at 40 CFR
Part 261. Many chemicals used in during photo processing meet the definition of a
hazardous waste — that is, they are either listed or exhibit a hazardous
characteristic. For example, silver-bearing wastes meet the characteristic of toxicity.
The other characteristics are ignitability, corrosivity, or reactivity.
2. Count the waste toward your monthly totals and manage it for your specific genera-
tor category. Follow all basic hazardous waste management practices at Part 262,
including storing the waste in closed, leak-proof containers and labeling them with
the words “hazardous waste.”
3. Know your exclusions and exemptions. Certain wastes and waste management prac-
tices “exclude” a waste from being considered hazardous. The following photo
processing wastes may be excluded:
• Characteristic sludge (When it is reclaimed),
• “Closed loop recycling” (Secondary materials that are returned to the pro-
cess(es) in which they were generated),
• Domestic sewage (Mixtures of sewage and other wastes that pass through a
sewer system to a publicly owned treatment works [POTW]),
• Precious metals (Recyclable materials from which precious metals are
recovered. “Administrative requirements” such as manifesting may still apply
to these materials),
• Wastewater treatment unit (Hazardous waste tank systems that are used to
store or treat the wastewater that is managed at an onsite wastewater treat-
ment facility with a Clean Water Act permit, or that discharge to a POTW).
4. Keep up your records. If you store recyclable materials, you need to show that you
are not accumulating them to sell (speculative accumulation).
5. Implement emergency procedures and contingency plans, as required by §262.
34(d)(5) and make sure employees who work with or around the waste are trained
in them.
6. Contract with a registered hazardous waste transporter for your hazardous wastes.
A regular transporting company is allowed to carry silver-bearing materials that are
not classified as hazardous to a refiner. Be sure to manifest all hazardous wastes.
7. Manage silver-bearing wastes for recovery as allowed at Part 266 Subpart F.

8. Notify the disposal company with appropriate Land Disposal Restrictions and certi-
fication forms. See Part 268.
9. Work with a permitted hazardous waste treatment, storage, or disposal facility to
dispose of the waste off site.
10. Work to minimize your waste. Photo processors have “developed” a voluntary Code
of Management Practice for Silver Discharge that promotes good environmental
stewardship by encouraging and enhancing silver recovery by processors of photo-
graphic materials. Find the document at www.pmairegs.com/silvercouncil/.
Comply with OSHA’s Hazard Communication Standard

OSHA’s HazCom standard requires all workplaces where employees are exposed to hazard-
ous chemicals to have a written plan that describes how the facility will implement the
standard. Employers must develop, implement, and maintain at the workplace a written,
comprehensive HazCom program that includes provisions for container labeling, collection
and availability of safety data sheets (SDSs), and an employee training program.
1. Your written plan must show how your company has met all of the standard’s
requirements. It also provides necessary hazard information to employees, so they
can participate in, and support, the protective measures in place at their
workplaces.
2. The written program has to reflect what you are actually doing in your workplace,
including training. The written plan must list the chemicals present at the site,
indicate who is responsible for the various aspects of the program at your facility,
and indicate where written materials will be made available to employees.
3. The written program must describe how the requirements for labels and other forms
of warning, SDSs, and employee information and training are going to be met in
your facility.
4. Your plan must list the person who is responsible for conducting HazCom training,
the format of the training to be used, and the elements of the training program. It
must also include how this information and training will be provided to contract
workers.
5. Update your program by June 1, 2016. However, your program should reflect the
training that is currently taking place — including training on container labels and
Safety Data Sheets.
6. Update your chemical inventory. As part of the written plan, you are required to
maintain a list of hazardous chemicals called the chemical inventory. The chemical
inventory should reference chemicals using the name found on the container label
and on the SDS. All three — the chemical inventory, the container label, and the
SDS — should match. The intent is that in an emergency you can look at the label
and quickly locate the correct SDS. The chemical inventory must include:
• All hazardous chemicals used in your company,
• Hazardous chemicals taken off-site for use in other locations, and
• Hazardous chemicals stored away from the main facility.
The list can be compiled for the workplace as a whole or for individual work areas.

Clean water
Your water will either be supplied by a public water system or a private system. In either
case, you’ll want to take measures to keep from contaminating that system.
1. You can work with your state or local water supplier to learn about specific clean
water requirements that apply to you. One such requirement may be a backflow
preventer.
2. Be careful with discharges to the sewer or POTW. You may need a permit for any
discharges — and the wastewater treatment plant may require you to conduct pre-
treatment before sending any wastewaters through the system.
3. Take measures to prevent spills into floor drains and consider installing a sump sys-
tem in areas where spills are likely.
Additional state and federal requirements

There may be other rules and regulations that apply to your waste, water, and chemical
safety processes, as well as other regulatory programs such as clean air permitting
requirements. Many states offer specific guidance for the photo processing industry. In addi-
tion, EPA has published a hazardous waste guidance for photo processors at www.epa.gov/
osw/inforesources/pubs/infocus/photofin.pdf and effluent guidelines for photographic
processing at water.epa.gov/scitech/wastetech/guide/photography.

Commercial printing
The printing industry, including printing types such as screen printing, lithographic,
flexographic, gravure, digital, label printing, web and sheet fed, letter press, and more, has
come a long way in managing its environmental impacts. Over the past few decades, print-
ers have worked to increase their energy efficiency, reduce wastes, and replace toxic
chemicals and solvents with less toxic or even nontoxic materials. But there are still many
environmental challenges for printers.
Printing operations use materials that may adversely affect air, water, and land: certain
chemicals involved in printing volatilize, which contributes to air emissions from the facility;
other chemicals may be discharged to drains and impact surface water or groundwater; and
solid wastes can contribute to existing local and regional disposal problems.
Industry advocate groups such as the Printers’ National Environmental Assistance Center
(PNEAC) and the Sustainable Green Printing Partnership (SGP) work to provide printers
with information on recognizing and mitigating their impacts on the environment. EPA also
provides printers with environmental compliance information and best practices.
Some of the main environmental impacts printers need to keep in mind are:
• Emissions to the air:
❍ Releasing volatile organic compounds into the air due to solvent use.
❍ The printing process and transport contribute to greenhouse gas emissions.
• Releases to land and water:
❍ Handling and disposing hazardous wastes such as solvent wastes and photo-
graphic chemical wastes.

❍ Handling, recycling, and/or disposing solid wastes such as inks, paper, plates
and pallets.
When considering your impact on the environment, it may be helpful to divide your opera-
tions into six different areas:
1. Pre-press:
• Make sure all discharges to the publicly-owned treatment works (POTW) are done
according to your permit.
• Consider converting to newer technologies that are designed to eliminate film waste.
• Be sure to understand customers’ requirements before the job to prevent waste.
• Work with customers on design layout to prevent waste.
2. Press:
• Consider changing your printing process to one that uses fewer (or no) solvents,
such as waterless printing.
• Consider using low VOC ink, such as soy-based or waster-based ink.
• Use solvents efficiently and train staff to use the least amount.
• Install efficient blanket washing systems that use the least amount of blanket wash.
• Use a solvent recycling system.
3. Collating and binding:
• Train staff in cutting techniques, binding techniques, and use of glues to reduce
waste.
• Reduce waste from excess trim.
• Reduce the need for trimming by making sure that jobs fit reel and sheet sizes
accurately.
• Consider using water-based glues for binding and labels.
4. Dispatching and receiving goods:
• Make sure products are packed to minimize damage (but without excessive
packaging).
• Train staff and suppliers in efficient handling and stacking to minimize damage.
• Look into reusing packaging received from suppliers.
• Separate packaging wastes and send them for recycling or return to suppliers.
5. Building/site management:
• Keep premises and grounds free of litter and waste materials.
• Design your chemical storage area to contain any spill or leaks.
• Clearly label all chemical containers.
• Set up spill prevention and management procedures and review them regularly.
• Make sure employees understand the potential hazards of the chemicals they use
and what to do if there is a spill (HazCom, HAZWOPER, and hazardous waste
training).

6. Hazardous waste:
• Store hazardous wastes in appropriate containers. Ensure secondary containment.
• Segregate each waste and clearly label each waste container.
• Keep containers closed.
• Properly prepare wastes for transport, (including correctly filling out the hazardous
waste manifest) and use a waste transporter that has an EPA ID Number. Ensure
waste is disposed of properly. (See the Waste chapter in this manual for more on
proper waste management regulations.)
Environmental inputs and outputs
Different types of printing processes have many common wastes; however, they also each
have inputs and outputs that are process specific. It is important to note that wastes differ
from process to process and the solutions identified to reduce waste in one printing process
may not necessarily apply to other printing processes. The following charts, adapted from
EPA’s Sector Notebook — Printing and Publishing outline the inputs and outputs for these
different processes.

Lithography Process: Inputs, and Outputs

Process Inputs Outputs
Imaging Film Used film and out-of-date film.
Paper Scrap paper.
Developer May be volatile and contribute to air
emissions. Spent developer (sent to
POTW).
Fixer May be volatile and contribute to air
emissions. Silver from film is often
electrolytically recovered from the
fixer prior to discharge of spent fixer
to POTW.
Wash Water Used rinse water.
Cleaning Solutions Rags containing solvents (sent to
laundry service or disposed of as
hazardous waste).
Chemical Storage Containers Empty containers (disposed of or
returned to suppliers).
Platemaking Plates Used plates.
Water Used rinse water (discharged to
POTW).
Developer Spent developer (may contain
alcohol; contributes to air emissions).
Printing Fountain Solution May contain VOCs and contribute to
air emissions.
Ink Waste oil based ink disposed of as
hazardous waste. Solvent-based inks
contribute to air emissions.
Paper Waste paper from bringing press up
to required print quality and from
rejected prints.
Cleaning Solutions Solvents used to clean press and
remove excess ink contribute to air
emissions.
Rags Ink and solvent-laden rags (sent to
laundry service, disposed of as
hazardous waste, or treated to
recover solvents).
Finishing Paper Reject prints and edges from
trimming.
Adhesives Possible losses to the air.
Shipping boxes Waste issue.

Gravure Process: Inputs, and Outputs

Imaging Digital Data Film or engraved image carrier
(cylinder).
Film Used film and out-of-date film
Paper Scrap paper.
Photographic processing solution May be volatile and contribute to air
emissions. Waste solution.
recover solvents).
Cylinder Making Copper-clad Cylinder Used cylinders.
Acid etching solution Waste solution.
Printing Ink Solvent-based inks (toluene-based for
mass-circulation printing and alcohol-
based for packaging) maintain the
required low viscosity and contribute
to air emissions. Waste ink disposed
of as hazardous waste.
Heat Ovens are used to drive off the
solvents to dry the ink. Ink solvents
are recaptured through chillers and
other equipment.
rejected prints.
Cleaning Solutions Solvents used to remove excess ink
trimming.

Flexography Process: Inputs, and Outputs

Paper Scrap paper.
emissions. Spent developer (to
POTW).
emissions. Silver from film is often
electrolytically recovered from the
fixer prior to disposal of spent fixer to
POTW).
recover solvents).
Platemaking Plate mold Used molds, engravings and washes.
Rubber plate Used plates, defective plates, and
photopolymer.
Etching and wash-out solutions Waste solution and spent solvents.
Printing Ink Waste ink disposed of as hazardous
waste. Solvent-based inks contribute
to air emissions.
Paper/film Waste paper and film from bringing
press up to required print quality and
from rejected prints.
Heat Exhaust heat and odor. High alcohol
content of some inks contribute to air
emissions as ink dries. Water-based
inks are used for paper and some
films.
contribute to air emissions and
hazardous wastes.
Finishing Paper/film Waste issue. Reject prints, edges from trimming,
box and bag-making wastes.

Letterpress Process: Inputs, and Outputs

Paper Scrap paper.
emissions. Spent developer to
POTW.
emissions. Spent fixer (silver from
film is often electrolytically recovered
from the fixer prior to disposal of
spent fixer to POTW).
Cleaning Solutions Rags containing cleaning solvents
(sent to laundry service, disposed of
as hazardous waste, or treated to
recover solvents).
Platemaking Plate mold Used molds.
Plate Used plates.
Plate developer solution Waste solution.
Printing Ink Waste ink disposed of as hazardous
wastewater. Solvent-based inks
rejected prints.
trimming.

Screen Printing Process: Inputs, and Outputs

Imaging and Screen Making Emulsion Waste emulsion and out-of-date
product.
Photosensitization solution (needed Waste solution.
for unsensitized films only)
Screen (polyester, nylon or wire Excess screen trimmings; used
mesh) screens.
Frame Reused.
Developer Spent developer (sent to POTW).
Fixer Spent fixer.
Chemical Storage Containers Empty containers.
Printing Ink Waste ink usually disposed of as
hazardous waste. Solvent-based inks
Paper or other printing substrate Waste paper from bringing press up
rejected prints.
Blockout Removed during screen reclamation
and disposed with screen reclaim
chemicals.
Screen Reclamation Chemicals Screen reclamation chemicals and ink
are disposed of in rags and in clean-
up wastewater.
Water Water used for screen reclamation is
discharged to POTW; sometimes it is
filtered prior to discharge.
Finishing Paper or other printing substrate Reject prints and edges from
trimming.
Environmental regulations
Commercial printers are subject to a wide variety of environmental regulation, both at the
state and federal level. Some of these programs include:
EPCRA Section 313 — The Toxic Release Inventory (TRI): According to EPA’s guid-
ance, the primary sources of releases and other waste management quantities of TRI
reportable chemicals and chemical categories are from solvents found in the in formulations
and solvents used in cleanup operations.
Printing facilities will be covered by TRI if all four of the following are true:
1. The facility’s primary SIC Code is on the EPCRA Section 313 list.
2. The facility employs ten or more full-time employees.
3. The facility manufactures, processes, or otherwise used any TRI chemicals or chemi-
cal categories.
4. The facility exceeds any of the activity thresholds for a TRI chemical or chemical
category.
To determine if you use chemicals that are covered by EPCRA Section 313, EPA says you
should prepare a list which includes all chemicals and chemical categories found in mixtures

and trade name products at all establishments at the facility. The list should then be com-
pared to the current list of EPCRA Section 313 chemical and chemicals categories found in
the TRI Forms and Instructions documents for that reporting year. Find it at www2.epa.gov/
toxics-release-inventory-tri-program.
TRI Chemicals Commonly Found in Printing Operations
Process Chemical
Ink solvent Cleaning Toluene, MEK, Methanol, Xylene, Ethylbenzene
Fountain solution Cleaning Certain Glycol Ethers
Cleaning Xylene (mixed), MIBK
Acrylic coatings, gravure inks Zinc Compounds
Copper plating Copper
Red ink pigments Barium Compounds
Green ink pigment Copper Compounds
Adhesive solvent n-Hexane
Ink solvent n-Butyl Alcohol
Fountain solution cleaning Ethylene Glycol
Plasticizer Dibutyl Phthalate
Cleaning solvent Ethylbenzene, 1,2,4-Trimethylbenzene, Hexane
Water-based inks and coatings Ammonia
Cleaning Nitric Acid
Activity thresholds: For purposes of TRI, EPA defines three activity categories for the
listed chemicals and chemical categories:
1. Manufacturing (which includes importing), and
2. Processing,
3. Otherwise used.
The activity thresholds are 25,000 pounds per year for manufacturing, 25,000 pounds per
year for processing, and 10,000 pounds per year for otherwise used. These thresholds apply
to each chemical or chemical category individually. The quantity of chemicals or chemical
categories stored on site or purchased is not counted toward threshold determinations.
Rather, the determination is based solely on the annual quantity actually manufactured (or
imported), processed, or otherwise used. Therefore, TRI chemicals and chemical categories
that are brought on site and stored, but are not prepared in the reporting year for distribu-
tion in that year or subsequent years or are not otherwise used on site during the reporting
year, are not counted toward any activity threshold.

Activity Categories
Activity Category Definition Threshold (lb/yr)
Manufacture To produce, prepare, import, or compound an EPCRA Section 25,000
313 chemical. Manufacture also applies to an EPCRA Section
313 chemical that is produced coincidentally during the
manufacture, processing, otherwise use, or disposal of another
chemical or mixture of chemicals as a byproduct, and an
EPCRA Section 313 chemical that remains in that other
chemical or mixture of chemicals as an impurity during the
manufacturing, processing, or otherwise use or disposal of any
other chemical substance or mixture. An example would be the
production of ammonia or nitrate compounds in a wastewater
treatment system.
Process To prepare an EPCRA Section 313 chemical, or a mixture or 25,000
trade name product containing an EPCRA Section 313
chemical, for distribution in commerce. For example, the
addition of EPCRA Section 313 listed pigments to ink should
be reported if you exceeded the reporting threshold.
Processing includes the preparation for sale to your customers
(and transferring between facilities within your company) of a
chemical or formulation that you manufacture. For example, if
you manufacture an EPCRA Section 313 chemical or chemical
category or product, package it, and then distribute it into
commerce, this chemical has been manufactured AND
processed by your facility.
Otherwise Used Generally, use of an EPCRA Section 313 chemical category 10,000
that does not fall under the manufacture or process definitions
is classified as otherwise used. An EPCRA Section 313
chemical or chemical category that is otherwise used does not
function by being incorporated into a product that is distributed
in commerce, but may be used instead as a manufacturing or
processing aid (e.g., catalyst), in waste processing, or as a fuel
(including waste fuel). For example, xylene used as a carrier
solvent for ink is classified as otherwise used. On May 1, 1997,
EPA revised the interpretation of otherwise use. The following
new otherwise use definition became effective with the 1998
reporting year: Otherwise use means “any use of a toxic
chemical contained in a mixture or other trade name product or
waste, that is not covered by the terms manufacture or
process. Otherwise use of a toxic chemical does not include
disposal, stabilization (without subsequent distribution in
commerce), or treatment for destruction unless: 1) The toxic
chemical that was disposed, stabilized, or treated for
destruction was received from off site for the purposes of
further waste management; OR 2) The toxic chemical that was
disposed, stabilized, or treated for destruction was
manufactured as a result of waste management activities on
materials received from off site for the purposes of further
waste management activities.”
Emergency planning and TIER I/TIER II reporting: For the purposes of emergency
response planning, any facility that has an extremely hazardous substance present or Super-
fund (CERCLA) hazardous substance present at or above threshold planning quantities
needs to notify the state emergency response commission (SERC) and the local emergency
planning commission (LEPC). Any facility producing, using, or storing a hazardous chemical,
as defined by OSHA (29 CFR 1910.1200), that releases a reportable quantity of an extremely
hazardous substance or a Superfund hazardous substance (See 40 CFR 355) must immedi-
ately notify the SERC and LEPC. (See the Community Right to Know chapter for more
information.)

Some states have more stringent requirements than the federal regulations. For example,
California requires businesses that handle “acutely hazardous materials” (at or below fed-
eral thresholds) to file a registration form and may require the business to prepare a risk
management prevention plan.
The minimum threshold quantity for reporting hazardous chemicals present at the facility
at any one time is 10,000 pounds; for extremely hazardous chemicals, the minimum thresh-
old quantity for reporting is the lesser of 500 pounds or the threshold planning quantity
(TPQ). Any facility that is required by OSHA’s Hazard Communication Standard (29 CFR
1910.1200) to have Safety Data Sheets (SDSs) for certain hazardous chemicals, and that has
such chemicals above certain minimum threshold levels, must provide copies of the SDSs for
these substances or a list of the substances to SERC, LEPC, and the local fire department.
In addition, facilities must annually submit to the SERC, the LEPC, and the fire depart-
ment a Tier I report indicating the aggregate amount of chemicals (above threshold
quantities) at their facilities, classified by hazard category. If any agency that receives a Tier
I report requests a Tier II report requiring additional information, facilities must submit
this second report to the agency within 30 days of receiving a request for such a report. Tier
II reports include an inventory of all chemicals at the facility. Since several commonly used
chemicals in the printing industry may be stored in quantities of 10,000 pounds or more, or
above the TPQ, these chemicals will be subject to SDS and Tier I/II reporting requirements
(40 CFR 370). There is no minimum threshold for reporting in response to requests for sub-
mission of an SDS or a Tier II form under 40 CFR 370.21(d) or 370.25(c).
Threshold Planning and Reporting Quantities for Some EPCRA-Designated Extremely Hazardous
Chemicals Used in the Printing Industry
Chemical Name Reportable Quantity (lbs) Threshold Planning
Ammonia 100 500
Formaldehyde 100 500
Hydroquinone 1 500/10,000
Propylene oxide 100 10,000
Sulfuric acid 1,000 1,000
Toluene 2,4-Diisocyanate 100 500
Toxic Substances Control Act (40 CFR 700 to 799) — TSCA

TSCA applies to manufacturers, processors, importers, distributors, users, and disposers of
chemical substances and mixtures. TSCA could apply to commercial printers in the following
ways:
TSCA Section 5, pre-manufacture notice: A business that manufactures or imports a
new chemical substance, or that manufactures, imports, or processes a chemical substance
for a significant new use, must notify EPA at least 90 days before manufacturing, import-
ing, or processing the substance (40 CFR 720-723).
TSCA Section 8, reporting and recordkeeping for identified chemical substances:
A business (except a “small business”) that imports, manufactures, or processes chemical
substances listed in 40 CFR 704.225 by rule must keep records and reports as required.
Small businesses are required to reprint or keep records in some situations. A printing
facility may want to reference this list if it processed film developers or replenishers for
commercial purposes or distribution.

A business that manufactures, imports, processes, distributes, or uses chemical sub-

stances and mixtures must keep records of significant adverse reactions to health or the
environment as specified.
A business that (1) manufactures, imports, processes, or distributes in commerce a
chemical substance or mixture, and (2) obtains information that reasonably supports
the conclusion that such substance or mixture presents a substantial risk of injury to
health or the environment, must report as required to EPA.
TSCA Section 13, general import requirements and restrictions: Importers of
chemical substances and mixtures are responsible for ensuring that chemical importation
complies with TSCA just as domestic manufacturers are responsible for insuring that
chemical manufacturing complies with TSCA. Printers who may be involved in the impor-
tation of inks or other substances should reference 40 CFR 707.20. Printers who import
inks are subject to inventory reporting regulations under TSCA Section 8(a) and should
reference 40 CFR 710.
In addition, Section 8(b) of TSCA requires EPA to compile and maintain a list (the TSCA
Inventory) of all chemical substances manufactured or processed in the United States, and
the printing industry is required to report the information necessary to allow EPA to
develop and maintain the inventory.
Clean Air Act

The Clean Air Act (CAA), with its 1990 amendments, sets the framework for air pollution
control as it affects the printing industry. This framework has several elements. Several por-
tions of Title I of the CAA address requirements for the attainment and maintenance of
National Ambient Air Quality Standards (NAAQS). Of the six recognized NAAQS criteria
pollutants, the NAAQS for ozone, nitrous oxides, and particulate matter are likely to have a
significant impact on the printing industry. EPA says that printing facilities are not major
sources of ozone; however, they are sources of emissions of volatile organic compounds
(VOCs), the precursors of ozone. Thus, although there is a NAAQS for ozone, the relevant
emissions for monitoring purposes are VOCs.
Section 112 of the CAA covers emissions of hazardous substances. For a wide variety of such
substances, Congress directed EPA to base its limits on emissions and technologies rather
than on ambient air quality per se. The National Ambient Air Quality Standards apply only
to a small number of the most common pollutants. Additional requirements that directly
restrict the emission of 189 hazardous air pollutants are established in Part 112 of the
Clean Air Act. EPA is authorized to establish Maximum Achievable Control Technology
(MACT) standards for source categories that emit at least one of the pollutants on the list.
Chemicals listed in Part 112 of the Clean Air Act that are used in the printing industry are
shown below:
Chemicals Used in the Printing Industry That Are Listed as Hazardous Air Pollutants in the Clean
Air Act Amendments
HAZARDOUS AIR POLLUTANT
Benzene Lead compounds
Cadmium compounds Methanol
Carbon tetrachloride Methyl ethyl ketone
Chromium compounds Methyl isobutyl ketone
Cobalt compounds Methylene chloride

Chemicals Used in the Printing Industry That Are Listed as Hazardous Air Pollutants in
the Clean Air Act Amendments, Continued
Cumene Perchloroethylene
Dibutylphthalate Polycyclic organic matter
Diethanolamine Propylene oxide
Ethyl benzene Toluene Ethylene glycol
2,4-Toluene diisocyanate Formaldehyde
1,1,2-Trichloroethane Glycol ethers
Trichloroethylene Hexane
Vinyl chloride Hydrochloric acid
Xylenes Isophorone
Large commercial printers (major sources) may be required to obtain a permit for:
• Pollutants affecting ambient air quality,
• Hazardous air pollutants, and
• New sources.
Also, several solvents used the printing industry are considered to be ozone-depleting chemi-
cals, which are covered by Title VI of the CAA.
Where a facility is located will impact the printing facility’s permit and requirements to
install and maintain air control technologies. Individual states have the ability to require
facilities to meet conditions set forth in the permit.
Clean Water Act
The commercial printing industry produces a number of pollutants that are potentially regu-
lated under the CWA. Applicable provisions of the Clean Water Act (CWA), including Spills
of Oil and Hazardous Substances and the discharge of water into waters of the United
States, publicly owned treatment works (POTWs), stormwater discharges, and storm sewers.
Industrial sources usually need to obtain permitting for both their wastewater and
stormwater discharges. Your facility may be permitted under the National Pollutant Dis-
charge Elimination System (NPDES) or a state equivalent program. Also, industrial
facilities that discharge wastewater to a municipal sewer system could be covered under a
national, state, or even local pretreatment program. If the industrial facility discharges
directly to a surface water, then it may require an individual national or state permit — or
the facility could fall under a national or state general permit.
If a printing facility discharges to surface water or to a municipal system, it will be covered
by effluent limitation guidelines and standards. For more information, see the “Pretreatment
Program” in the Clean Water chapter of this book.
Printing facilities that work with oil and are located near bodies of water, streams, or even
storm sewers, could be affected by the discharge of oil regulations at 40 CFR 110. Prohibited
discharges include certain discharges into or upon the navigable waters of the United States
or adjoining shorelines or into or upon the waters of the contiguous zone, those occurring in
connection with activities under the Outer Continental Shelf Lands Act or the Deepwater
Port Act of 1974, or those that may affect natural resources belonging to or under the exclu-
sive management of the United States.

These regulations define the term “discharge” used in Section 110.11 of the CWA as includ-
ing (but not limited to) any spilling, leaking, pumping, pouring, emitting, emptying, or
dumping into the marine environment of quantities of oil that:
1. Violate applicable water quality standards, or
2. Cause a film or sheen upon or discoloration of the surface of the water or adjoining
shorelines or cause a sludge or emulsion to be deposited beneath the surface of the
water or upon the adjoining shorelines.
The Resource Conservation and Recovery Act (RCRA)
Commercial printing facilities will almost certainly generate hazardous waste. It is impor-
tant to identify each facet of the waste stream and manage hazardous wastes appropriately.
In order to remain as unregulated as possible, facilities should know their hazardous waste
generator category and understand any state requirements that are in addition to the
federal.
Large Quantity Generators —These facilities generate at least 1000 kg (approximately
2200 lbs.) of hazardous waste per month, or greater than 1 kg (2.2 lbs) of acutely hazardous
waste 18 per month.
Small Quantity Generators (SQG) — These facilities generate greater than 100 kg
(approx. 220 lbs.) but less than 1000 kg of hazardous waste per month, and up to 1 kg (2.2
lbs) per month of acutely hazardous waste.
Conditionally exempt small quantity generators (CESQG) — These facilities generate
no more than 100 kg (approx. 220 lbs) per month of hazardous waste and up to 1 kg (2.2 lbs)
per month of acutely hazardous waste.
Most printing industry hazardous wastes are covered by the land disposal restrictions. For
example, spent solvents that are hazardous wastes are banned from land disposal unless
treated to appropriate levels. (See the Waste chapter in this book for more information.)
Common listed wastes found in the printing industry include:
F001 The following spent halogenated solvents used in degreasing: Tetrachloroethylene,
trichloroethylene, methylene chloride, 1,1,1-trichloroethane, carbon tetrachloride, and chlori-
nated fluorocarbons; all spent solvent mixtures/blends used in degreasing containing, before
use, a total of ten percent or more (by volume) of one or more of the above halogenated sol-
vents or those solvents listed in F002, F004, and F005; and still bottoms from the recovery
of these spent solvents and spent solvent mixtures.
F002 The following spent halogenated solvents: Tetrachloroethylene, methylene chloride,
trichloroethylene, 1,1,1-trichloroethane, chlorobenzene, 1,1,2-trichloro-1,2,2- trifluoroethane,
ortho-dichlorobenzene, trichlorofluoromethane, and 1,1,2-trichloroethane; all spent solvent
mixtures/blends containing, before use, a total of ten percent or more (by volume) of one or
more of the above halogenated solvents or those listed in F001, F004, or F005; and still bot-
toms from the recovery of these spent solvents and spent solvent mixtures.
F003 The following spent non-halogenated solvents: Xylene, acetone, ethyl acetate, ethyl
benzene, ethyl ether, methyl isobutyl ketone, n-butyl alcohol, cyclohexanone, and methanol;
all spent solvent mixtures/blends containing, before use, only the above spent non-
halogenated solvents; and all spent solvent mixtures/blends containing, before use, one or

more of the above non-halogenated solvents, and, a total of ten percent or more (by volume)
of one or more of those solvents listed in F001, F002, F004, and F005; and still bottoms from
the recovery of these spent solvents and spent solvent mixtures.
F005 The following spent non-halogenated solvents: Toluene, methyl ethyl ketone, carbon
disulfide, isobutanol, pyridine, benzene, 2-ethoxyethanol, and 2-nitropropane; all spent sol-
vent mixtures/blends containing, before use, a total of ten percent or more (by volume) of
one or more of the above non-halogenated solvents or those solvents listed in F001, F002, or
F004; and still bottoms from the recovery of these spent solvents and spent solvent
mixtures.
Case study of a typical waste stream at a printing facility
John, an employee at ABC Printers, Inc., finished wiping down the press with a solvent
cleaner. Now what should John do?
1. Identify the waste. Use tests or process knowledge to determine if the solvent is a regu-
lated hazardous waste. If it is not an exempted waste, then determine the appropriate waste
code for the solvent (e.g., F001). Keep records of all test results, waste analyses, and any
other determinations for at least three years.
2. Count the solvent waste toward the monthly generator totals. (Don’t count solvent placed
directly into a solvent recovery still; but do count the solvent still bottoms when they are
removed from the still.)
3. Know the facility’s generator status. In this case, John’s company produces more than 220
pounds but less than 2,204 pounds per calendar month, so the facility is a small quantity
generator (SQG).
4. If the company hasn’t notified EPA of their hazardous waste activity, they need to com-
plete EPA form 8700-12 (Notification of Regulated Waste Activity) to obtain an EPA
Identification number. They should also notify the state of their waste activities.
5. Place the waste in an appropriate container. The container must not be rusty or leaking
and must be handled with care to prevent spilling. The container must be marked with the
words “Hazardous Waste.” Keep the container closed except when adding or removing waste
and store in an area with plenty of aisle room and adequate ventilation and drainage.
6. Check to be sure emergency preparedness and prevention requirements are being met.
This includes adequate emergency response systems are in place and local responders are
aware of the wastes being handled at the facility.
7. Check to see that the facility’s contingency plan is adequate and up-to-date. The plan
must be designed to minimize hazards from fires, explosions, and unplanned releases. A copy
of the plan should be kept onsite. A facility emergency coordinator should be on site or on
call at all times.
8. Before handling the solvent waste, John must be trained to work around it safely. He
should be familiar with hazardous waste handling and emergency procedures.
9. The solvent waste must be marked, labeled, placarded, and packed according to both
EPA’s and the federal Department of Transportation’s pre-transport requirements. The

waste must be sent offsite using a registered hazardous waste transporter. SQG waste must
be sent offsite within 180 days (or 270 days if shipping more than 200 miles away).
Note: The waste must be manifested appropriately, using the correct waste codes (in this
case F001). The person who signs the manifest must have both EPA hazardous waste train-
ing and DOT hazardous materials training.
Initial shipments of waste to a treatment, storage, or disposal facility must be accompanied
by the appropriate notifications and certifications.
10. Choose an approved treatment, storage, and disposal facility (TSDF). Optional destina-
tions for solvents could be a hazardous waste incinerator that will landfill the ash, a
hazardous waste fuel blender who will blend the solvent with other wastes and then burn
them for fuel in a boiler or industrial furnace, or a facility that will recycle the solvent.
Waste minimization techniques for the commercial printing industry
EPA provides suggestion on how to recycle, treat, or dispose of typical printing wastes.
(Taken from RCRA in Focus – Printing.)
Process Using ink in lithography, letterpress, screen printing,

flexography, and gravure
Wastes Generated Waste ink with chromium, barium, and lead content; and
waste ink contaminated with cleaning solvents, such as
trichloroethylene, methylene chloride, 1,1,1-
trichloroethane, carbon tetrachloride, 1,1,2-
trichloroethane, 1,2,3-trifluoroethane, chlorobenzene,
xylene, acetone,,methanol, methyl ethyl ketone (MEK),
toluene, carbon disulfide, or benzene.
Possible RCRA Waste Codes D005 (barium), D007 (chromium), D008 (lead), F001 to
F005 (listed solvents), D001 (ignitable waste), D018 (ben-
zene), D019 (carbon tetrachloride), D021
(chlorobenzene), and D040 (trichloroethylene).
Potential Recycling, Treatment, and Disposal Meth- • Recycle inks to make black ink. Reformulated black
ods ink is comparable to lower quality new black inks such
as newspaper ink.
• Dispose of inks by sending them to a fuel blending
service that combines these and other wastes for
burning at industrial boilers or kilns.
• Ship waste using a registered hazardous waste trans-
porter to a hazardous waste TSDF.
Potential Pollution Prevention Methods • Dedicate presses to specific colors or special inks to
decrease the number of cleanings required for each
press.
• Clean ink fountains only when changing colors or
when there is a risk of ink drying.
• Run similar jobs simultaneously to reduce waste
volume.
• Isolate inks contaminated with hazardous cleanup sol-
vents from noncontaminated inks.
• Use organic solvent alternatives wherever possible,
such as detergent or soap, nonhazardous blanket
washes, and less toxic acetic acid solvents.

Process Cleaning printing equipment

Wastes Generated Spent organic solvents might include trichloroethylene,
methylene chloride, 1,1,1 trichloroethane, carbon tetra-
chloride, 1,1,2-trichloroethane, 1,2,3-trifluoroethane,
chlorobenzene, xylene, acetone, methanol, MEK, toluene,
carbon disulfide, or benzene.
Possible RCRA Waste Codes F001 to F005 (listed solvents), D001 (ignitable waste),
D018 (benzene), D019 (carbon tetrachloride), D021
(chlorobenzene), D040 (trichloroethylene), D005 (barium),
D007 (chromium), D008 (lead), D018 (benzene), and
D019 (carbon tetrachloride).
Potential Recycling, Treatment, and Disposal Meth- • Find a legitimate reuse for spent solvents on site. If
ods reused, the solvents are not considered to be wastes
and, therefore, are not regulated. Examples include
reusing solvents in a parts-cleaning unit that is used to
clean dirty press parts.
• Dispose of solvents by sending them to a fuel blend-
ing service, which combines these and other wastes
for burning at industrial boilers or kilns.
• Recycle spent solvents in an onsite solvent still.
• Contract with a solvent recycler or supplier to take the
spent solvent away and replace it with fresh solvent.
porter to a hazardous waste TSDF. Most solvents will
be recycled or incinerated.
• Appropriate management techniques for rags and dis-
posable wipers contaminated with solvents are at the
discretion of your state or EPA regional office. A
wide variety of options are available including sending
them to laundry services after wringing out excess sol-
vent, disposing of them as hazardous waste, treating
them to recover the solvents, or incinerating them as
hazardous waste. (See solvent-contaminated wipes in
the Waste section of this book.)
Potential Pollution Prevention Methods • Print lighter colors first.
• Squeegee or wipe surfaces clean before washing with
solvent.
• Dedicate presses to specific colors or special inks to
decrease the number of cleanings required for each
press.
• Run similar jobs simultaneously to reduce cleanup
waste volume.
• Use organic solvent alternatives wherever possible,
such as detergent or soap, nonhazardous blanket
washes, and less toxic acetic acid solvents.
Process Developing negatives ad prints
Wastes Generated Waste photochemical solutions from fixer and rinsewater
and from alkaline or acid process baths.
Possible RCRA Waste Codes D011 (silver) and D002 (corrosive waste).
Potential Recycling, Treatment, and Disposal Meth- • Ship silver waste using a registered hazardous waste
ods transporter to a hazardous waste TSDF.
• Recover silver from fixing baths using chemical recov-
ery cartridges, electrolytic recovery cells, or ion
exchange resins, and have a commercial recycler pick
it up.
• Neutralize waste on site in an exempt elementary neu-
tralization unit.

Potential Pollution Prevention Methods • Eliminate silver waste by using silver-free films such
as vasicular, diazo, electrostatic, and photopolymer.
• Add ammonium thiosulfate to silver-contaminated
baths to extend the allowable buildup of silver.
• Use an acid stop bath prior to fixing bath to reduce
effect of alkaline developer on fixing bath pH.
• Install waterless paper and film developing units to
reduce volume of fixer waste.
• Employ countercurrent (using water from previous
rinsings in initial film washing stage) rather than paral-
lel rinse techniques.
• Containerize process baths to keep them from
spoiling.
Process Plate processing
Wastes Generated Acid plate etching chemicals for metallic lithographic
plates, and flexographic photopolymer plates.
Possible RCRA Waste Codes D002 (corrosive waste), F002 (perchloroethylene), and
F003 (butynol).
Potential Recycling, Treatment, and Disposal Meth- • Neutralize waste acid on site in an exempt elementary
ods neutralization unit.
porter to a hazardous waste TSDF for treatment and
disposal.
Potential Pollution Prevention Methods • Replace metal etching process with nonhazardous
alternative.
• Check with your state about the use of alternative
plate solvents that may or may not be considered
hazardous.
Process Printing processes
Wastes Generated Unused inks, solvents, and other chemicals used in print-
ing industry.
Possible RCRA Waste Codes D001, D002, U002 (acetone), U019 (benzene), U211 and
D019 (carbon tetrachloride), U055 (cumene), U056
(cyclohexane), U069 (dibutyl phthalate), U112 (ethyl
acetate), U259 (ethanol, 2-ethoxy), U359 (ethylene glycol
monoethyl ether), U122 (formaldehyde), U154 (metha-
nol), U226 (methyl chloroform), U080 (methylene
chloride), U159 and D035 (MEK), U161 (methyl isobutyl
ketone), U210 and D039 (tetrachloroethylene), U220
(toluene), U223 (toluene diisocyanate), U228 and D040
(trichloroethylene), U043 and D043 (vinyl chloride), and
U239 (xylene).
Potential Recycling, Treatment, and Disposal Meth- • Neutralize corrosive wastes on site in an exempt
ods elementary neutralization unit.
• Find a legitimate reuse for unused chemicals on site.
If legitimately reused, the chemicals are not consid-
ered to be waste. Examples include using solvents to
clean dirty press parts.
• Dispose of organics with high fuel value by sending
them to a fuel blending service, which combines these
and other wastes for burning at industrial boilers or
kilns.
porter to a hazardous waste TSDF. Most organics will
be incinerated.
Potential Pollution Prevention Methods Control inventory to avoid overstocking on inks, solvents,
and other printing chemicals.

Resources:
EPA’s Federal environmental regulations potentially affecting the commercial printing
industry (1994): epa.gov/dfe/pubs/printing/fedregs/printreg.pdf.
EPA’sRCRA in Focus - Printing: epa.gov/osw/inforesources/pubs/infocus/printing.pdf.
EPA Sector Notebooks - Profile of the printing industry: epa.gov/compliance/resources/
publications/assistance/sectors/notebooks/print.pdf
Printers’ National Environmental Assistance Center (PNEAC): www.pneac.org/.
Sustainable Green Printing Partnership: sgppartnership.org/.
RCRA Online: epa.gov/epawaste/inforesources/online/index.htm.

Environmental security
The issue of security, defined as “measures taken to guard against espionage, sabotage,
crime, or attack,” affects everyone. Security for a nation means economic prosperity, peace,
and well-being for its citizens. Security for your business means keeping your employees,
your information, your assets, and the community safe from both outside and inside threats.
National security considerations include military defense, border patrols, and protecting
critical infrastructure such as power plants, chemical facilities, stadiums, shopping centers,
cyber networks, municipal water systems, bridges and highways, and government buildings.
Your own site security includes all your efforts to prepare for unexpected events such as
national disasters, terrorist attacks, cyber threats, sabotage, and workplace violence.
There is a close relationship between security and the environment. In fact, “environmental
security” is an emerging term that has global implications. In this context, issues such as
climate change and the distribution of natural resources can lead to economic instability,
increasing conflicts, and international unrest. For the purposes of this section, however,
“environmental security” will not take on a global scale, but will refer to the potential threat
a facility’s operations may pose to the environment and the nation. Severe environmental
and economic harm can result from attacks on chemical facilities, oil and gas refineries,
power plants, and water systems. It’s more important than ever to protect these facilities.
This section will focus on steps you can take to secure your business and protect the envi-
ronment from inside and outside threats as well as how you can comply with the federal
regulations that apply to your operations. Certain federal and state rules and regulations
apply to you if you manufacture or store chemicals, operate a public drinking water or
wastewater treatment facility, or operate a biological or nuclear laboratory. These rules
include OSHA’s Process Safety Management program, EPA’s Risk Management Program,
aspects of the Emergency Planning and Community Right to Know Act, the Department of
Homeland Security’s (DHS’s) Chemical Facility-Anti-Terrorism Standards, and more.
3/13 Security–1

Basic site security

Whether you employee thousands of workers, or only a few, you need to keep your facilities
safe and secure. The first item on your security list should be a risk assessment. A risk
assessment identifies the threats and vulnerabilities your business faces, ranks them in
order of seriousness, and plans for how to mitigate them. This means taking a look at every-
thing from your parking lots to how people access your building to employee background
checks.
Risk assessment
DHS published its Threat and hazard identification and risk assessment guide in April 2012.
The guide offers five steps to identify and assess risks that can be applied to a single facility
or to an entire region.
Step 1: Identify threats and hazards to your facility.
Step 2: Assess the vulnerability of your facility to those hazards using different time, sea-
son, location, and community factors. (Give the threats and hazards context.)
Step 3: Estimate the consequences of those threats and hazards in light of your core
capabilities or main business activities.
Step 4: Establish “capability targets” or define the desired outcome. (e.g., Reestablish
communications within 24 hours of an incident.)
Step 5: Plan and prepare for the threats and hazards.
Five core capabilities

DHS says there are five core capabilities that a business (or community) must be ready to
address. These are:
• Prevent: Prevention includes screening, search and detection, and intelligence and
information sharing;
• Protect: Protection means controlling access to facilities, verification procedures,
cybersecurity, intelligence and information sharing, physical protective measures,
risk management programs, screening, search, and detection, and supply chain
integrity;
• Mitigate: Mitigation covers resilience, long-term vulnerability reduction, identifying
threats and hazards;
• Respond: Response can involve transportation, environmental, health and safety
responses, facility management, infrastructure systems, mass care services, search
and rescue operations, and communications;
• Recover: Recovery includes finances, health and social services, facilities, infra-
structure, and natural and cultural resources.
The following risk assessment checklist will help you evaluate your current security.
2–Security 3/13

SECURITY RISK ASSESSMENT CHECKLIST

Location:
Name:
Date:
Threat preparedness
Has your facility been evaluated for its potential as a target of vandalism, terrorism, bur-
glary, etc.?
Does your company work with local law enforcement to evaluate security risks at the facil-
ity?
Do you have a contingency plan that covers all foreseeable security risks been established?
Is the contingency plan reviewed periodically?
Is a disaster recovery policy/procedure in place to ensure safe and secure continuation of
business?
Have you evaluated the potential for catastrophic releases from your facility?
Policies and procedures
When possible, are hazardous processes located in the center of the facility, away from the
facility fence line or perimeter?
Are employees trained not to leave transportation vehicles near the fence line or unpro-
tected?
If possible, are hazardous processes shut down or controlled when they are not in use?
Is the inventory of hazardous equipment, chemicals, and materials monitored so the com-
pany is aware of anything missing?
Is the amount of hazardous inventory on site limited to that which is needed?
Are procedures in place to protect the facility during off work times (if the building is unoc-
cupied at night, during weekends, or holidays and shutdowns)?
Is the security system periodically evaluated to make sure it is adequate to limit access to
the site?
Are plans for new construction or physical changes to the facility or workplace evaluated to
eliminate or reduce security hazards?
Do you have procedures in place (e.g., change locks) when you have reason to believe a secu-
rity threat exists (e.g., disgruntled employee, verbal threats)?
Do you have a mandatory drug screening program?
Employment
Is a clear policy of zero-tolerance for workplace violence, verbal and nonverbal threats, and
related actions created and disseminated?
Are background checks conducted before hiring employees?
Are background checks conducted in accordance with applicable laws and regulations?
3/13 Security–3

Are contractors evaluated before allowing them to come on-site?

Are employees briefed on security issues if they must travel, especially to a foreign country?
In interview rooms, or places where employee terminations occur, do you limit the number of
pictures, vases, ashtrays, or other items that can be used as weapons?
Is a procedure in place to recover keys and remove security access from workers whose
employment ends?
Training
If your company has security officers, are they instructed on who is authorized to enter the
grounds and who has access to various areas?
Are security officers trained on the level of response they are allowed to participate in? (Are
they allowed to use force to restrain a potential intruder? Are they to secure suspicious
packages?)
Are appropriate employees (security officers, etc.) trained to recognize, report, and respond
to suspicious activities and suspicious packages?
Are mailroom employees given special training on recognizing suspicious packages and mea-
sures to follow?
Are all employees trained on general awareness of suspicious activities and suspicious mail,
along with actions they should take?
Are employees encouraged to promptly report incidents, and suggest ways to reduce or
eliminate risks?
Equipment
Are measures in place to prevent intruders from entering the grounds or building?
Are fences, walls, windows, and doors maintained properly?
Is bright, effective lighting installed indoors and outdoors?
Is there good lighting around key areas on the grounds (i.e., storage tanks, garages, etc.)?
Are measures in place (access badges, traffic control, etc.) to keep unauthorized persons from
entering your facility through normal entrances?
Are layers of security provided (valves and lids on barrels/containers, fences and alarms,
etc.) around the property?
Are alarm systems and other security devices (panic buttons, hand-held alarms or noise
devices, cellular phones, and private channel radios) installed and maintained where risk is
apparent or may be anticipated?
Is there a reliable response system when an alarm is triggered?
Computers
Are measures in place to prevent computer systems from being hacked?
Is virus protection installed and maintained on computers?
Is access to confidential or critical areas limited through passwords or other means?
4–Security 3/13

Is a procedure in place to keep information about the company’s processes that could aid ter-
rorists or others in doing harm from being placed on company websites?
Threats and hazards

Threats and hazards come in three categories:
• Natural,
• Technological, and
• Man-made.
Examples of natural disasters include earthquakes, floods and tornadoes as well as wildfires,
tsunamis, and even disease outbreaks. Technological disasters include airplane crashes,
dam/levee failures, power failures, train derailments, radiation events, or releases of hazard-
ous chemicals.
Man-made disasters include riots, cyber-terrorism, sabotage, workplace violence, and other
terrorist acts.
You can prepare for these threats by creating an emergency action plan and a disaster recov-
ery plan, which will help you to safely resume normal operations as soon as possible after a
natural, technological, or man-made disaster.
Emergency action plans

A number of OSHA’s regulations require planning for emergency response. Two in particular
apply to operations that affect environmental security. These are 29 CFR 1910.119 Process
Safety Management of highly hazardous chemicals and 1910.120 Hazardous waste opera-
tions and emergency response (HAZWOPER).
SAMPLE EMERGENCY ACTION PLAN
[Your company name] is dedicated to the protection of its employees from emergencies.
When emergencies do occur, our Emergency Action Plan (EAP) is initiated. This EAP is in
place to ensure employee safety from emergencies during regular hours and after hours. It
provides a written document detailing and organizing the actions and procedures to be fol-
lowed by employees in case of a workplace emergency.
The EAP communicates to employees, policies and procedures to follow in emergencies. This
written plan is available, upon request, to employees, their designated representatives, and
any OSHA officials who ask to see it.
Administrative Duties
The EAP administrator, who has overall responsibility for the plan, is: [Name]
This responsibility includes the following:
• Developing and maintaining a written Emergency Action Plan for regular and after
hours work conditions;
• Notifying the proper rescue and law enforcement authorities, and the building
owner/superintendent in the event of an emergency affecting the facility;
3/13 Security–5

• Taking security measures to protect employees;

• Integrating the Emergency Action Plan with any existing general emergency plan
covering the building or work area occupied;
• Distributing procedures for reporting emergencies, the location of safe exits, and
evacuation routes to each employee;
• Conducting drills to acquaint employees with emergency procedures and to judge
the effectiveness of the plan;
• Training designated employees in emergency response such as the use of fire extin-
guishers and the application of first aid;
• Deciding which emergency response to initiate (evacuate or not);
• Ensuring that equipment is placed and locked in storage rooms or desks for
protection;
• Maintaining records and property as necessary; and
• Ensuring that our facility meets all local fire codes, building codes, and regulations.
The person responsible for reviewing and updating the plan as necessary is: [Name]
Copies of this plan may are found:
This person has full authority to decide to implement the EAP if he/she believes an emer-
gency might threaten human health: [Name]
The following potential emergencies might reasonably be expected at this facility and thus
call for the implementation of this EAP:
The following personnel can be contacted regarding further information about the written
Emergency Action Plan or an explanation of duties under this plan: [Names and telephone
numbers]
Key management personnel home telephone numbers are kept in a safe place for immediate
use in the event of an emergency. These telephone numbers include: [Key management
member telephone number]
These telephone numbers of key management personnel have been distributed to the follow-
ing persons to be retained in their homes for use in communicating an emergency occurring
during non-work hours: [Names and titles]
We have informed employees of their duties and responsibilities under the plan. The stan-
dardized plan is kept by [name] and is accessible by affected employees at:
If, after reading this plan, you find that improvements can be made, please contact the Plan
Administrator. We encourage all suggestions because we are committed to the success of our
Emergency Action Plan. We strive for clear understanding, safe behavior, and involvement
in the program from every level of the company.
6–Security 3/13

Alarms
Different emergencies call for different alarms to indicate what actions employees should
take. The alarm system includes:
Because we use a communication system as an alarm system, all emergency messages have
priority over all non-emergency messages.
We have posted the following emergency telephone numbers near telephones, or emergency
notice boards, and other conspicuous locations for use when telephones serve as a means of
reporting emergencies: [Emergency responder] [Contact information]
Emergency Reporting and Weather Monitoring Procedures
In the Event of an Emergency Requiring Evacuation
When employees detect an emergency that requires an evacuation, such as a fire or hazard-
ous release, they should take the following action:
[Name of employee] is responsible for contacting the Fire Department.
Our backup method for reporting emergencies that require evacuation includes the follow-
ing: [List method]
In the Event of a Tornado Watch
We monitor tornadoes by:
Other emergency reporting or weather monitoring procedures include:
Evacuation Procedures
Some emergencies require evacuation or escape procedures, while some require employees to
stay indoors, or in a safe area. Our emergency escape procedures are designed to respond to
many potential emergencies, depending on the degree of seriousness. Nothing in these proce-
dures precludes the Plan Administrator’s authority in determining whether employees
should remain inside or evacuate.
At this company, the following types of emergency evacuations exist:
Our emergency evacuation procedures and assignments are designed to respond to many
potential emergencies that require them, including:
Employees need to know what to do if they are alerted to a specific emergency. After an
alarm is sounded to evacuate, employees should take the following steps:
See the appendices for a copy of the building plans with exit route assignments for each
group evacuating an area or building.
Once evacuated, employees are to head toward their designated exterior or safe area, where
a head count will be performed, and further instructions given. The following is a list of
exterior refuges/safe zones:
Departmental group:
3/13 Security–7

Designated safe area:
Procedures to Account for Employees
Trained evacuation personnel assist in safe and orderly evacuation for all types of emergen-
cies that require evacuation. Once evacuation is complete, they conduct head counts. The
employees selected are trained in the complete workplace layout and the various alternative
escape routes from the workplace. Before leaving, these employees check rooms and other
enclosed spaces in the workplace for employees who may be trapped or otherwise unable to
evacuate the area. A list of trained personnel appears below:
Name and title:
Department:
Shift:
This list indicates a sufficient number of employees who have been designated by the com-
pany and trained to:
• Direct and assist in safe and orderly emergency evacuation,
• Provide guidance and instruction for all types of emergency situations,
• Be aware of employees with special needs who may require extra assistance,
• Use the buddy system, and
• Avoid hazardous areas during an emergency evacuation.
The list of trained personnel includes at least one person from every area for every shift.
This means that every trained evacuation person is responsible for seeing to approximately
[fill in the blank] evacuated employees. The trained personnel also serve as a resource of
information about emergency procedures and conduct head counts once evacuation is
complete.
Frontline supervisors must be aware of the locations of those employees working on a par-
ticular day when an emergency occurs, as well as suppliers, customers, and other non-
employees on the premises, when an emergency occurs, and be aware of who is absent or
otherwise away from the premises. Accounting for employees and non-employees will aid
local responding fire/rescue departments in determining whether rescue efforts are
necessary. We have described each frontline supervisor’s employee/non-employee tracking
method below:
Name of supervisor:
Department:
Shift:
Tracking method:
Each department reports to their respective representative as follows:
Once each evacuated group of employees have reached their evacuation destinations, each
trained evacuation employee:
8–Security 3/13

• Takes roll of his or her group,

• Makes sure all persons are accounted for,
• Reports in to a central checkpoint managed by [name], and
• Assumes role of department contact to answer questions.
Head count results should be given to the Fire Chief or firefighter, if requested.
Other duties provided by the trained personnel during an emergency evacuation include the
following:
No employees are to return to the buildings until the determination has been made that
such re-entry is safe. If anyone is injured or contaminated, the Plan Administrator will acti-
vate rescue and first aid actions. If an emergency incident expands, the EAP Administrator
may send employees home by normal means or provide them with transportation to an
offsite location.
Non-Evacuation Emergency Procedures
Our company has the following non-evacuation procedures:
Responding to a tornado alarm
In the event of a tornado, it is corporate policy to provide emergency warning and shelter.
Once employees are made aware of a tornado situation, they are to follow these procedures:
Employees should stay away from windows, but stay inside the building they are in. The
following is a table with shelter assignments listed:
Group or department:
Assigned shelter:
Employees are not to leave the shelter or return to their regular duties until the all clear is
given.
The person responsible for determining when it is safe for employees to leave their tornado
shelter and return to work is: [Name]
At that time, the Plan Administrator will:
If there is structural damage, the Plan Administrator will:
If anyone is injured, the Plan Administrator will activate rescue and first aid actions.
Critical Operations
Our company has critical operations that cannot be shut down for emergencies. These
operations include the following:
The employees who are designated to remain behind during evacuation to care for critical
plant operations include the following:
Name and title:
3/13 Security–9

Department:
Plan system operated:
The procedures to be taken by those employees who have been selected to remain behind to
care for essential plant operations until their evacuation becomes absolutely necessary
Plan Administrator Duties
During an emergency, The Plan Administrator will do the following:
Rescue and First Aid
Rescue and first aid may be necessary during emergency situations. Circumstances calling
for rescue and/or first aid include:
Circumstances:
Procedures:
Emergency Response Team (ERT) members are responsible for performing rescue duties in
case of an emergency requiring rescue. Members of the ERT include: [Names]
Designated first aid responders are to provide first aid assistance within their capabilities to
employees requiring it during emergency situations. Designated first aid responders include
the following individuals: [List designated first aid responders]
Appropriate first-aid supplies have also been provided.
Professional emergency services responding in an emergency will help with and direct all
rescue and medical duty assignments upon their arrival on site.
Training
Our Plan Administrator reviews the Emergency Action Plan at the following times with each
employee covered by the plan:
• Initially when the plan is developed,
• Whenever a new employee is hired,
• Whenever the employee is assigned initially to a job,
• Whenever an employee’s responsibilities or designated actions under the plan
change,
• Whenever new equipment, materials, or processes are introduced into the
workplace,
• Whenever the layout or design or the facility changes, and
• Whenever the plan is changed.
The training includes the following:
We present the material for training in the following manner:
10–Security 3/13

We communicate the contents of this plan through a briefing delivered by supervisors fol-
lowed by a demonstration.
Or
We communicate the contents of this plan through a presentation followed by a drill.
Our company performs drills for the following emergencies:
We hold these drills at least [number of times] per year:
After a drill, the Plan Administrator judges the effectiveness of the plan and reviews any
employee input concerning the drill. Employees performing the drill may identify something
that did not follow procedure or was ineffective. For example, they may discover doors that
would not open; they may enter storage closets instead of exiting; they may get lost and con-
fused or they may carry a suspicious package through the facility. These are the types of
things the Plan Administrator needs to hear about after a drill. That way, issues can be
addressed before a real emergency.
Emergency Equipment and Support
Our company provides the following equipment and support for use by our trained personnel
during emergencies:
Appendices
We have attached to this Emergency Action Plan, the following documents for reference to
ensure a better understanding of our written program:
Employees designated to remain behind to operate critical plant operations during an emer-
gency include the following:
The types of emergency action plans we have at this facility include the following:
Disaster recovery plans

SAMPLE DISASTER RECOVERY PLAN
Company Name:
Plan completed by:
Completion date:
Purpose
[Company name] is dedicated to the protection of its employees, facilities, and resources and
to ensuring that our company can continue all aspects of its core business processes and
safely resume normal operations as quickly as possible after any natural, weather-related,
man-made, or technological disaster affecting our facility. We place a high priority on devel-
oping, validating, and, if necessary, implementing our company’s Disaster Recovery Plan. If
after reading this plan, you find that improvements can be made, please contact [name]. We
encourage all suggestions because we are committed to the success of this written plan.
3/13 Security–11

Administrative Duties
[Name of employee], our Disaster Recovery Plan Administrator, is responsible for establish-
ing and implementing our written Disaster Recovery Plan. This person has full authority to
make necessary decisions to ensure the success of this plan. Copies of this written plan may
be obtained from: [Name] [Contact information]
Core Business Processes
The core business processes to keep functioning during a recovery process include:
Business process(es):
Departments affected:
Capability targets (must be functioning within the following timeframe: [Number of days]:
Disaster Threats
We have identified the following potential disaster threats, their severity, and their probabil-
ity of occurrence, as well as their risk level:
Disaster threat:
Severity:
Probability:
Business risk:
Risk to the environment:
Analyzing the severity and probability, the disaster(s) with the highest risk is/are:
Business Impact Analysis
The level of impact a disaster has on our company, depends on the disaster type. Here is our
business impact analysis:
Disaster threat:
Human impact:
Environmental impact:
Property impact:
Business impact:
Totaling the scores going across the business impact analysis table, the disaster(s) with the
worst, combined, possible impact is/are:
Factoring in probability with the combined, possible impact, the worst, probable disaster(s)
is/are:
12–Security 3/13

Risk Reduction and Elimination
While the threats and impacts can be great, our company has established and implemented
the following strategies to reduce or eliminate risks:
Emergency Plans
Please refer to the following emergency plan(s), in the event of an emergency:
Emergency action plan:
Location of plan:
Plan administrator:
Contact information:
We have posted the following emergency telephone numbers for use when telephones serve
as a means of reporting emergencies:
Emergency responder:
Recovery Goals and Objectives
Based on our business impact analysis, our immediate goals and objectives for disaster
recovery include:
Our long-term goals and objectives for disaster recovery include:
Roles and Responsibilities
To achieve our recovery goals and objectives, the following people will have the roles and
responsibilities listed below:
Individual, team, department, or agency:

Backup individual, team, department, or agency:
Post-Disaster Assessment
Once a disaster has occurred, we will assess the damage and determine our needs and recov-
ery strategies as follows:
Recovery Procedures
The procedures provided below assume that the entire facility has been destroyed or is oth-
erwise not operational. If the entire facility is not destroyed or is partially operational, then
adjustments to these procedures will be made.
Within 24 Hours
Within 24 hours after a disaster, our company will take the following steps:
List steps:
3/13 Security–13

Person responsible:
Backup person:
Within 48 Hours
Within 48 hours after a disaster, our company will take the following steps:
List steps:
Person responsible:
Backup person:
Within 72 Hours
List steps:
Person responsible:
Backup person:
General Procedures
Other ongoing recovery procedures include the following:
Actions:
Person responsible:
Backup person:
Disaster Recovery Supplies

For disaster cleanup, we will need the following supplies:
Supply item(s):
Model:
Supplier:
Quantity:
To keep core business processes operational, we will need the following supplies and soft-
ware:
Supply item(s):
Model:
Supplier:
Quantity:
To keep core business processes operational, we will need the following backed-up databases
and electronic and paper documents:
14–Security 3/13

Database(s):
Document(s):
Network(s):
Backup(s)
Who can access:
Disaster Recovery Services
We have selected the following alternative site(s), in the event it is needed:
We estimate that in a worst-case scenario we shall occupy this site for:
To obtain supply items, we have provided a list of supply services below:
Supply type:
Supplier:
Other service vendors include:
Service type:
Vendor:
Training
Due to the complexity of disasters and the recovery process, all employees will be trained by
the following person(s):
Employees will be trained to:
Our training program includes:
We perform recovery drills for the following disasters:
We hold these drills at least:
After a recovery drill, the Plan Administrator evaluates the effectiveness of the plan and
reviews any employee input concerning the drill.
After an actual disaster, further training may be necessary.
Security
To protect the company, property, and employees, certain security measures will be in place
during disaster recovery:
3/13 Security–15

Media Relations
Once briefed on the post-disaster analysis, the following person will prepare a public state-
ment and, if necessary, will communicate with and/or escort media, as well as keep records
of any information released to the media:
(Under no circumstances shall an employee speak to the media unless authorized.)
Plan Evaluation
We will thoroughly evaluate and, as necessary, revise our plan to ensure our program’s effec-
tiveness and prevent or eliminate any problems. Plan evaluation involves the following:
Appendices
We have attached to this Disaster Recovery Plan, the following documents for reference:
Planning for shutdowns

Planning for emergencies is especially important for chemical facilities that need to conduct
complicated shutdown operations. EPA requires these facilities to minimize chemical
releases during process shutdown operations and report any chemical releases in a timely
manner. Shutdown operations can require special care beyond normal operations. Automated
systems or process controls may need to be bypassed, disconnected, or placed under manual
control. These procedures may be unfamiliar to operators and difficult to control.
The Clean Air Act establishes that owners/operators have a general duty to prevent acciden-
tal releases of certain listed substances and other extremely hazardous substances and to
minimize the consequences of accidental releases which do occur. (These substances are
listed at 40 CFR 68.130.) This duty involves assessing the potential hazards of such
releases, designing and maintaining a safe facility, and taking the steps necessary to prevent
accidental releases and minimize their consequences.
Also, facilities subject to the national emission standards for hazardous air pollutants gen-
eral duty clause at 40 CFR 63.6 (e)(1)(i) are required at all times, including periods of
startup, shutdown, and malfunction, to operate and maintain any affected source in a man-
ner consistent with safety and good air pollution control practices for minimizing emissions
of hazardous air pollutants.
Section 103 of the Comprehensive Environmental Response, Compensation, and Liability Act
(CERCLA), as amended, requires facilities to immediately notify the National Response Cen-
ter of any release of a hazardous substance in an amount equal to or greater than the
reportable quantity (RQ) for that substance.
Finally, Section 304 of the Emergency Planning and Community Right-to-Know Act
(EPCRA) requires owners/operators to immediately notify both their respective State Emer-
gency Response Commissions and Local Emergency Planning Committees whenever their
facility has released an RQ of a CERCLA hazardous substance or an EPCRA extremely haz-
ardous substance.
16–Security 3/13

Chemical facility security

EPA is concerned about chemical releases, air quality, and water pollution, and hazardous
wastes from facilities that manufacture, import, or store large quantities of chemicals. But
the federal agency in charge of regulating chemical facility security is the Department of
Homeland Security (DHS). Section 550 of the DHS Appropriations Act of 2007 requires the
DHS to regulate facilities that present high levels of security risk. The Department’s main
tool is the Chemical facilities anti-terrorism standards (CFATS), found at 6 CFR Part 27.
The standards give DHS the authority to levy civil penalties and the ability to shut down
non-compliant facilities.
CFATS may cover facilities that engage in:

• Chemical manufacturing, storage, and distribution;
• Energy and utilities;
• Agriculture and food;
• Paints and coatings;
• Explosives;
• Mining;
• Electronics;
• Plastics; and
• Healthcare.
Areas of concern
Facilities that handle chemicals are actively engaged in managing risks to ensure the safety
of their workers and the community. Most of their efforts focus on ensuring that the facility
is designed and operated safely on a day-to-day basis, using well-designed equipment, pre-
ventive maintenance, up-to-date operating procedures, and well-trained staff. Because of
today’s increased concern about terrorism and sabotage, companies are also paying
increased attention to the physical security of facility sites, chemical storage areas, and
chemical processes.
Threats may come in different forms and from different sources. Threats from outside the
facility could affect people and the facility itself, and may involve trespassing, unauthorized
entry, theft, burglary, vandalism, bomb threats, or terrorism.
Threats from inside the facility may arise from inadequate designs, management systems,
staffing or training, or other internal problems. These may include theft, substance abuse,
sabotage, disgruntled employee or contractor actions, and workplace violence, among others.
Threats are not restricted to people and property, but could also involve sensitive facility
information. Both facility outsiders and employees or contractors could pose threats to data
storage and data transmission of, for example, confidential information, privacy data, and
contract information. They could also pose a threat to computer-controlled equipment.
Common security measures

Most security measures are intended to prevent intruders from gaining access to the site or
to limit damage. The following sections present a number of design and procedural
approaches that facilities have successfully implemented. The appropriateness of these
3/13 Security–17

depends on site-specific conditions that you would need to consider in assessing any security
needs for your facility.
Preventing intrusion
Most chemical facilities have some measures intended to prevent intruders from entering
the grounds or buildings. These measures may include fences, walls, locked doors, or alarm
systems. The location of the facility and the types of structures determine how much and
what type of protection a facility needs. In addition to basic measures, some facilities also
provide physical protection of site utilities at the fence perimeter. Security lighting (good
lighting around buildings, storage tanks, and storage areas) can also make it very difficult
for someone to enter the facility undetected.
Some facilities augment these measures with intrusion detection systems — video surveil-
lance, security guards at fixed posts, rounds/mobile patrols, alarm stations, and detectors for
explosives and metal. If you have guards, consider their training in detection and response
and the availability of equipment for appropriate protective force.
To protect against unauthorized people coming in through normal entrances, security clear-
ances, badges, procedures for daily activities and abnormal conditions, as well as vehicular
and pedestrian traffic control, can provide efficient access for employees while ensuring that
any visitors are checked and cleared before entering.
Limiting damage
In addition to protecting a facility from intruders, establish programs to limit the damage
that an intruder (whether physically at the site or “hacking” into the company’s computers)
or an employee could do. Most of the steps to limit damage are probably things you already
do as part of good process safety management, because they also limit the loss of chemicals
if management systems or equipment fails or an operator makes a mistake. These steps can
be related to either the design of the facility and its processes or to procedures implemented.
Facility design
A well-designed facility, by its layout, limits the possibility that equipment will be damaged
and, by its process design, limits the quantity of chemical that could be released. Facility
and process design (including chemicals used) determine the need for safety equipment, site
security, buffer zones, and mitigation planning. Eliminating or attenuating to the extent
practicable any hazardous characteristic during facility or process design is generally prefer-
able to simply adding on safety equipment or security measures.
Locating processes with hazardous chemicals in the center of a facility can thwart intruders
and vandals who remain outside the facility fence line. Transportation vehicles, which are
usually placarded to identify the contents, may be particularly vulnerable to attack if left
near the fence line or unprotected.
Where feasible, providing layers of security will protect equipment from damage. These lay-
ers could include, for example, blast resistant buildings or structures. Enclosing critical
valves and pumps (behind fences or in buildings) can make it less likely that an intruder
will be able to reach them, a vehicle will be able to collide with them, or that releases are
compounded because of damage to neighboring equipment.
If equipment is located where cars, trucks, forklifts, or construction equipment could collide
with it or drop something on it, the equipment should be constructed from materials that
18–Security 3/13

could stand some abuse. Consider collision protection for any equipment containing hazard-
ous chemicals. Well-designed equipment will usually limit the loss of materials if part of a
process fails. Excess flow check valves, for example, will stop flow from an opened valve if
the design flow rate is exceeded. Fail-safe systems can ensure that if a release occurs, the
valves in the system will close, shutting off the flow. Breakaway couplings shut off flow in
transfer systems, such as loading hoses, to limit the amount released to the quantity in the
hose.
If you store hazardous liquids, you may want to consider containment systems (e.g., build-
ings, dikes, and trenches) that can slow the rate at which the chemical evaporates and
provide time to respond. Double-walled vessels can also protect against attempts to rupture
a tank.
The installation of chemical monitors that automatically notify personnel of off-hour releases
could be important if your facility is not staffed during certain periods (e.g., overnight).
Procedures and policies

Your facility’s policies and procedures can also limit the damage caused by a release. As with
design issues, the procedural steps you routinely take to operate safely also help protect
your facility from attacks. Following are several examples of specific areas where procedures
and policies can prevent or limit the damage of a release.
As a matter of good practice, as well as site security, consider disconnecting storage tanks
and delivery vehicles from connecting piping, transfer hoses, or distribution systems when
not in use. Leaving the tanks linked to the process or pipeline increases the chance of a
release because the hoses or pipes are often more vulnerable than the tanks.
In addition to accurately monitoring your inventory, you may want limit the inventory of
hazardous materials to the minimum needed for your process. Also consider actions such as
substituting less hazardous substances when possible to make processes inherently safer.
Your written procedures are also an important tool in protecting your facility. As part of your
regular operating procedures, you probably have emergency shutdown procedures. These
procedures, and workers trained in their use, can limit the quantity released.
As you review your contingency plan, consider revisions to address vandalism, bomb threats,
burglary — including evaluating the desirability of your facility as a target — working with
local law enforcement, and providing extra security drills and audits.
Site-specific decisions
The steps you take to operate safely often address security concerns as well. Considering
inherent safety in the design and operation of any facility will help to prevent and/or mini-
mize the consequences of any release. Before taking steps to improve site security, evaluate
your current system and determine whether it is adequate. Factors you might consider
include:
• The chemicals stored at your site; some chemicals may be particularly attractive
targets because of the potential for greater consequences if released.
• The location of the site; sites in densely populated areas may need more security
than those at a distance from populations.
• The accessibility of the site; are the existing security systems (e.g., fences, security
lighting, security patrols) adequate to limit access to the site?
3/13 Security–19

• The age and type of buildings; older buildings may be more vulnerable because they
have more windows; some newer building are designed for easy access.
• Hours of operation; a facility that operates 24-hours day may need less security
than a facility that is unoccupied at night.
Decisions about improving site security should be made after evaluating how vulnerable
your site is to threats and what additional measures, if any, are appropriate to reduce your
vulnerability. Each facility should make its own decision based on its circumstances.
Agency developments focus on security

Since the events of September 11, the chemical industry and governing agencies have been
seeking a practical method to assess the security of chemical facilities within the United
States. Industry associations and the government have developed various additional pro-
grams and guidance materials to help facilities address the increased threat.
Vulnerability Assessment Model (VAM)

In 2002, the Department of Justice published a tool for assessing the potential security risks
at chemical facilities, focusing on terrorist or criminal actions that could have significant
national impact or could cause the airborne release of hazardous chemicals resulting in
deaths and contamination. The method is designed to guide the chemical facility industry in
making security improvements.
The twelve-step assessment methodology was developed by the National Institute of Justice
in partnership with the U.S. Department of Energy’s Sandia National Laboratories, with the
cooperation and assistance of chemical industry representatives.
The prototype Vulnerability Assessment Model (VAM) is a systematic, risk-based approach
where risk is a function of the severity of consequences of an undesired event, the likelihood
of adversary attack, and the likelihood of adversary success in causing the undesired event.
While the focus of the VAM is likely to be on chemical facilities that are required to submit
risk management plans or a subset of those facilities, the VAM was developed so it is usable
for undesired events of lesser consequence than those found in risk management plans.
The VAM has 12 basic steps:
• Screen for need for a vulnerability assessment
• Define the project
• Characterize facility
• Derive severity levels
• Assess threat
• Prioritize cases
• Prepare for analysis
• Survey site
• Analyze system effectiveness
• Analyze risk
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• Make recommendations
• Prepare final report
Chemical Facility Anti-Terrorism Standards

Who’s covered?
Facilities that manufacture chemicals are not the only ones subject to this rule: It applies to
facilities that use, store, or otherwise handle many common chemicals.
Appendix A to the rule includes the list of chemicals and Screening Threshold Quantities
(STQs) covered by the rule. DHS will use that list to determine whether to further assess
whether a chemical facility presents a high risk.
If a facility possesses or plans to possess, at any relevant point in time, a quantity of a
chemical listed in Appendix A to Part 27, the facility must complete and submit a Top-
Screen. Covered facilities will largely fall into the following categories:
• Chemical manufacturing, storage, and distribution
• Energy and utilities
• Agriculture and food
• Paints and coatings
• Explosives
• Mining
• Electronics
• Plastics
• Healthcare
There are five facility exemptions:
• Facilities regulated under Maritime Transportation Security Act (MTSA)
• Public water systems (Safe Drinking Act)
• Water treatment works facilities (Water Pollution Control Act)
• Facilities owned/operated by Departments of Defense or Energy
• Facilities regulated by the Nuclear Regulatory Commission
There a several chemical exemptions listed at 27.203(a). Facilities should review these
exemptions when determining coverage under these standards.
What’s a Top-Screen?
Top-Screen means an initial screening process through which chemical facilities provide
information to DHS. DHS will then use the information to determine whether the facility
“presents a high level of security risk.”
If a facility possesses any of the chemicals listed in Appendix A of the rule at the correspond-
ing Screening Threshold Quantities, it must complete and submit a Top-Screen via the
online Chemical Security Assessment Tool (CSAT).
3/13 Security–21

The deadline for going through the screening process is as follows:

• Unless otherwise notified, the deadline was January 22, 2008, for facilities that pos-
sessed any of the chemicals listed in Appendix A at the corresponding STQs at the
time the rule was finalized; or
• Within 60 calendar days for facilities that come into possession of any of the chemi-
cals listed in Appendix A at the corresponding STQs; or
• Within the time frame provided in any written notification from DHS or specified in
any subsequent Federal Register notice.
Three steps to Top-Screen compliance

Step one is to register for use of DHS’s Chemical Security Assessment Tool (CSAT). CSAT is
the online tool that will be used for most of the compliance process. Approximately two
weeks after registration, you will receive a username and password to use for secure login.
You can access the CSAT through http://www.dhs.gov/chemicalsecurity.
If you don’t have a current chemical inventory, now would be a good time to evaluate the
chemicals in your facility as you will need this information to complete the second step.
Step two is to complete and submit the Top-Screen, which is the initial screening process
and the method used to provide basic information to DHS. They want to know:
• Who are you?
• What do you do?
• What chemicals do you have?
• How much of the chemicals and in what condition?
In Step three, DHS will notify your facility of one of three things:
• DHS needs more information in order to determine your level of risk;
• Your facility is exempt and in compliance with the regulation; or
• Your tier rating and deadlines for completion of a security vulnerability assessment
(SVA) and Site Security Plan (SSP).
After the Top-Screen process, your next steps will only be completed when notified to do so
by DHS.
If you have questions on the new rule or need assistance with the CSAT, contact the CSAT
help-desk at (866) 323-2957 or email at CSAT@stafftechs.com.
Determining “high risk”

In determining whether a facility is “high risk,” DHS will assess vulnerabilities of a facility
and the consequences of an explosion on the surrounding region. There will be significant
interest in the location of a facility (e.g., middle of the desert vs. a Chicago suburb). DHS
will also consider the methods in which chemicals move from plant to plant or location to
location.
In order to determine the security risk posed by chemical facilities, DHS may, at any time,
request information from chemical facilities that may reflect potential consequences of or
vulnerabilities to a terrorist attack or incident, including:
• Questions specifically related to the nature of the business and activities conducted
at the facility;
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• Information concerning the names, nature, conditions of storage, quantities, vol-

umes, properties, customers, major uses, and other pertinent information about
specific chemicals or chemicals meeting a specific criterion;
• Information concerning facilities’ security, safety, and emergency response practices,
operations, and procedures;
• Information regarding incidents, history, funding, and other matters bearing on the
effectiveness of the security, safety and emergency response programs; and
• Other information as necessary.
Do you need to comply?

Not many companies will need to comply with these regulations beyond the Top-Screen.
DHS estimates that as many as 7,000 facilities will fall into the high-risk category, with 300
to 400 of them falling within the top two regulatory tiers.
The majority of covered chemical facilities will be contacted by the DHS and given addi-
tional deadlines to:
• Prepare Security Vulnerability Assessments (SVAs), which identify facility security
vulnerabilities; and
• Develop and implement Site Security Plans (SSPs), which include measures that
satisfy the identified risk-based performance standards.
The department will provide technical assistance to facility owners and operators as needed.
Security standards will be required to achieve specific outcomes, such as:
• Secure the perimeter and critical targets,
• Control access,
• Deter theft of potentially dangerous chemicals, and
• Prevent internal sabotage.
The rule contains associated provisions addressing inspections and audits, recordkeeping,
and the protection of information that constitutes Chemical-terrorism Vulnerability Informa-
tion (CVI).
Security Vulnerability Assessment (SVA)

Only high-risk facilities notified in writing by DHS are required to complete and submit an
SVA via CSAT. Facilities that receive a letter are initially considered high risk and prelimi-
nary assigned to Tier 1, 2, 3, or 4.
Deadlines to submit the SVA are specified in the notification letter. In general, the deadlines
for completing and submitting an SVA are:
• Preliminary Tier 1 (highest risk) — 90 days
• Preliminary Tier 2 — 120 days
• Preliminary Tier 3 — 150 days
• Preliminary Tier 4 — about 180 days
Tier 4 facilities also have the option of submitting an Alternative Security Program (ASP) in
lieu of an SVA
3/13 Security–23

Site Security Plan (SSP)

Only facilities that submitted a Security Vulnerability Assessment (SVA) and were subse-
quently notified in writing by the Department they have been finally determined to be high-
risk have access to complete and submit the CSAT Site Security Plan (SSP), which is the
third stage of compliance.
Unless otherwise notified by the Department, high-risk facilities have 120 days from the
time of written notification to complete and submit a CSAT SSP or a Department-approved
ASP.
SVA and SSP extensions

If a facility received a notification letter indicating facility coverage and would like to
request an extension of either the SVA or SSP deadline, formal letters can be sent via regu-
lar mail to: Department of Homeland Security, Chemical Security and Compliance Division,
Mail Stop 8100, Washington, D.C. 20528-8100
For more information, guidance, and technical support, visit: www.dhs.gov/chemicalsecurity.
State laws
Some states have existing laws for regulating chemical facilities. Only state laws and
requirements that conflict or interfere with these regulations, or the purpose for the regula-
tions, will be preempted. Currently, the department has no reason to conclude that any
existing state laws are applied in a way that would impede the federal rule.
Other regulations
This rule does not intend to displace other federal requirements administered by the Envi-
ronmental Protection Agency, U.S. Department of Justice, U.S. Department of Labor, U.S.
Department of Transportation, or other federal agencies.
Use these tools to build a secure facility

All of these programs, new and old, are aimed at decreasing the potential for disaster posed
by terrorists, thieves, or vandals. Many companies have already implemented at least some
of the strategies to reduce risk and provide a secure facility. The tools provided in the follow-
ing sections will be valuable to:
• Companies that are only now finding a need to develop a formal security program,
and
• Those that want to review and bolster their existing programs.
Several different components must be included in a comprehensive facility security program:
• Physical security. Physical security is the process of permitting access to the facility
or systems by authorized persons while denying access to others.
• Information security. Information security is protecting sensitive information, pre-
venting sabotage and disruption, and keeping critical business processes
operational.
• Personal security. People (employees, contractors, customers, and visitors) are a
company’s largest assets. Consider these as part of your security plan. Background
checks help ensure that you hire trustworthy employees.
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• In-transit security. People, products, property, cash, and information are especially
vulnerable while being transported or transmitted from one location to another.
Increase chemical facility site security
Overview
The natural place to start security planning and evaluation is the physical site where your
facility and operations are located.
Physical site security refers to efforts made to keep a facility safe and secure. Those efforts
include everything from controlling access by vehicles and pedestrians to the strategic use of
lighting and motion detection alarms to detect intruders. The following physical security
measures are commonly employed:
❏ Use access control measures to direct and restrict access to a facility. Include walls,
fences, bushes, gates, sidewalks, ponds, and traffic islands as necessary.
❏ Implement perimeter security measures to protect the approaches and access to the
grounds, including such things as adequate illumination and signs detailing access
rights and entrance locations. Control access to pedestrian entrances using security
personnel, gates or turnstiles, locked keycard gates or doors, and surveillance
cameras.
❏ Control vehicle traffic through landscaping, gates, and manned security points.
Ditches, bollards, and traffic islands can restrict or direct traffic flow. Loading dock
areas can be patrolled by security guards or monitored via surveillance cameras.
❏ Use uniformed security staff at strategic posts or walking specified patrols to moni-
tor low traffic, sensitive, or unoccupied areas for fires, break-ins, environmental
problems, or other unauthorized access.
❏ Arrange building layout and views to eliminate blind spots and to provide views of
the approaches or other vulnerable areas.
❏ Improve parking lot security by restricting pedestrian access with fences, gates or
entrance barriers, and security guards; ensuring adequate lighting and providing
emergency backup lighting; and using assigned parking, either by individual or
department, to help employees stay safe.
❏ Control and monitor interior movements of employees and visitors using ID/visitor
badges, department receptionists, electronic keycard doors, security posts, and sur-
veillance cameras.
The first step in creating a secure facility is assessing the current status at a site. Once a
risk assessment has been performed, vulnerabilities can be identified and additional mea-
sures implemented to increase security. A written site security plan provides a central
location to detail security issues and policies.
Finally, site security depends upon the employees and security staff’s knowledge of safety
and security protocols and procedures. Adequate training is needed so that all employees
understand the need for and workings of the site security procedures.
3/13 Security–25

Conduct a risk assessment

When considering the need for implementing or upgrading a safety and security program,
assess your current situation. This assessment should address the following issues:
❏ Identify the specific risks and threats. Consider not only external threats from ter-
rorists, criminals, extremists, vandals, etc., but also internal threats such as
disgruntled employees.
❏ Analyze the likelihood (potential) of a specific risk or threat actually occurring.
❏ Determine what safety and security policies and procedures are needed to decrease
the risk and increase the security of the company’s equipment, facilities, and
personnel. Consider measures that are already in place.
❏ Plan for communicating the safety and security policies and procedures effectively to
all employees.
Identifying potential internal and external risks and threats requires a critical look at the
organization’s entire operation — how daily tasks and activities are performed, how and
where important/ sensitive records and documents are stored, how employees are hired and
managed, and so on. The threats identified, and the procedures needed to reduce risk, will
vary with each location. Regular safety and security self-audits using detailed checklists are
recommended as a sound and prudent business practice.
The success of a company’s safety and security program depends on how well it is developed,
implemented, monitored, and revised when necessary. Is there a manager charged with over-
all safety and security responsibilities? Is there a person charged with safety and security
responsibilities in each department? Do all employees in the company know who these desig-
nated people are and what their responsibilities are?
Implement measures for physical site security

The following common measures can be implemented to increase security at your facility.
Visitors
Consider taking the following steps, depending on the level of security required, before
allowing a visitor to proceed into the facility.
Screen visitors as they drive onto the property. Have employees use vehicle stickers for easy
identification, and require visitors to sign in at a checkpoint and proceed to a visitor parking
space. If theft is a problem or concern, conduct random, periodic inspections of vehicles as
they leave.
Make sure all visitors register with a designated receptionist and/or security guard. Depend-
ing on the level of security needed, they should question all visitors, be trained in security
and emergency procedures, know how to identify fake IDs, and report any suspicious
activity.
Require all visitors to present a photo ID. Make sure the photo matches the face, and that
the ID doesn’t appear to be falsified. Require employees to wear photo ID badges that are
easily distinguished from visitor badges.
26–Security 3/13

Keep a written log that includes:

• the name of each visitor and who they represent,
• their arrival and departure times,
• who approved their entry, and
• who they came to see or the purpose of their visit.
Provide all visitors with temporary ID badges to wear throughout the visit.
Do not allow visitors to wander off alone. They should be met at the entrance by the
employee they have come to visit, or should be escorted to their destination.
If the company is at high risk, consider searching all bags and packages that enter the
facility. If outside maintenance or construction personnel will be working at the facility,
screen and register them each day, and require them to wear ID badges while on company
property.
Train all employees to take notice of and report suspicious activities and people. For
example, they should be wary of people who are:
• trying to access restricted, sensitive areas or materials, such as classified docu-
ments, computers, locked areas, hazardous materials, and so on;
• carrying a weapon without authorization;
• carrying a piece of company equipment, whether concealed or not;
• behaving in a strange manner; or
• making unusual requests or demands.
Pay particular attention to custodial/janitorial personnel and repairmen. They may be the
least-well-screened personnel at the facility, but may have the most access, and they tend to
generate little suspicion. If possible, develop a rigid screening process for such persons. If
they are not per manent employees of the company, they should be treated like other visitors
and be escorted and observed.
Once visitors and other outside personnel leave, make sure they return the ID badges and
indicate on the record that they have left the facility.
Don’t develop a false sense of security just because you have a fence, a security camera, or
good lighting. One or two security measures do not provide total protection. An integrated
system of defenses is needed to prevent unauthorized persons from entering the facility and
causing damage and/or leaving with valuable materials.
The best defense starts with the physical layout and condition of the facility. Questions to
ask include:
• Can receptionists see people approaching?
• Are all entrances and parking lots well lit and controlled?
• Are storage areas for sensitive or valuable materials located deep within the facility
instead of in remote, dark areas?
• Could a criminal break into the facility without being seen, whether sneaking over
the fence or driving a car straight through it?
3/13 Security–27

Doorways and entryways

In the case of a smaller company, a securely locked door may be the only defense. Obviously,
all entrances and exit gates and doors should be secured when not in use.
Make sure all gates and doors are structurally sound, locks are substantial enough to pre-
vent unauthorized entry, and latches close securely. If an entrance needs maintenance, have
it done as soon as possible.
Examine all doors and replace parts or entire doors if they provide inadequate protection. A
door is only as strong as its composition and points of attachment (i.e., what it’s made of and
how strong the locks and hinges are).
Generally, an intruder hoping to break through a door will start with the locks, but then
may move to the hinges, glass panels, or other areas of the actual door itself. Doors with sig-
nificant amounts of glass should be equipped with additional security measures such as an
alarm system, steel bars, or wire mesh, or should be under constant guard. Hollow-core or
paneled doors should be reinforced, such as with a steel plate inside.
Never allow “just anyone” into the buildings. Require each employee to use his/her own ID
to enter the building. Instruct employees not to hold the doors open for others unless they
are recognized as current employees. Visitors should be instructed to use a designated visi-
tor entrance.
To control who enters the facility, install a security checkpoint, either manned or unmanned.
Consider a security guard or receptionist at the door screening those who enter the building,
or a device that automatically scans employee identification cards or badges and only
unlocks the door for authorized personnel.
Establish set hours during which employees may enter the building(s). If access is necessary
after hours, employees should be instructed to contact a security guard who can screen the
employee and provide access if authorized. If an automated access card system is in place,
program the cards to limit access during non-business hours.
Prepare a written policy that includes immediate reporting of lost or stolen security badges
or IDs, because most unmanned systems are unable to tell if the person entering the build-
ing is the same person originally issued the ID.
Require each employee to use his/her own ID to enter the building. If possible, IDs should
have the employee’s picture, name, and department or function, but remember that it’s rela-
tively easy to fake an ID.
Key control
The best locks in the world don’t protect against someone who has a key. Entrance security
depends on key control. Have a facility-wide key control system that ensures the security of
keys, access cards, combinations, key-making equipment, and key codes.
The security office or another secure location should be used to store all spare keys, access
cards, and other lock-related equipment or information, and the personnel who work in
those areas should have limited access to the equipment and information. Do not store com-
binations or other lock information on a computer. Conduct periodic inventories and
inspections to make sure nothing has been stolen or misplaced.
Only provide lock combinations or keys to those who must have them. Keep the number of
copies to a minimum.
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When not in use or under personal control, store extra keys in a locked container. Keys to
sensitive areas should be signed out to supervisors on an as-needed basis, and turned in at
the end of each day. Keep accurate records of who signed out which keys, when, for how
long, and who authorized the keys to be signed out. Account for all keys at the end of each
day.
If employees are allowed to retain certain facility keys, their access rights should be
restricted. Don’t allow employees to retain keys to areas containing valuable equipment or
hazardous materials unless absolutely necessary.
If keys are given to contractors on a temporary basis, make sure the keys are returned once
work is complete, or render them useless by changing the locks.
Do not use a master key system, under which a single key can open multiple locks. If a mas-
ter key system is necessary, limit its use to non-sensitive areas and limit the ability to copy
the keys. Use pick-resistant locks whenever possible.
Consult with a locksmith or security professional for key and lock systems that best suit the
needs of the company.
Pay particular attention to hazardous materials storage areas. Consider using some form of
electronic key or badge that will allow the company to control and monitor access to these
areas.
If combination locks are used, change the combinations on a periodic basis or whenever a
combination code is lost or misplaced (even temporarily), or an employee who knows the
combination(s) leaves the company or is transferred.
Designate one person to be in charge of the key control system. He/she should maintain
records, know who has which keys, investigate the loss of keys, conduct lock and key inven-
tories and inspections, oversee company policies related to keys and access rights, and
purchase keys and locks as needed.
Make sure personnel responding to an emergency will have access to the necessary keys.
Re-key all door locks on a periodic basis, at least once every other year.
Windows
Check all windows — after doors, they’re the easiest way into a building. A window that is
easily reached with a ladder, is large enough for a person to crawl through, or could allow
someone to reach and open a lock should be considered vulnerable.
If the facility has windows that can be opened, evaluate and reinforce the locks if necessary,
and make sure employees are closing and locking the windows.
Consider installing alarms on windows located on the first and second floors of each
building. If you use window air conditioners, make sure they can’t be removed from the
outside.
Cameras
Consider closed-circuit cameras or other video recording devices for all entrances, exits, and
other vulnerable areas. Cameras can help reduce the number of security personnel required
to monitor a given facility because a guard in a central location can use them to monitor
several remote locations at once. They can be focused on hallways, doors, gates, fences,
remote buildings, hazmat storage areas, or other high-risk areas.
3/13 Security–29

Make sure the cameras are protected from tampering and theft, and place them so that they
can identify people in all lighting conditions. Monitor them constantly, and keep camera
tapes for at least one month.
Alarms
Alarm systems offer significant security benefits. While such systems offer almost no physi-
cal barriers to entry, they do provide a psychological one. Audible alarms draw attention,
and even in a remote area, the intruder will likely flee — or flee sooner than expected —
after the alarm activates.
So-called silent alarms can allow police or security personnel to apprehend an intruder
before he/ she realizes that an alarm has been activated. An alarm system can be especially
useful to secure a hazardous materials storage area.
The more complex the alarm system, the harder it is to disable. A variety of intrusion detec-
tion systems are available, employing a variety of sensor types, from magnetic contacts for
doors or windows to motion sensors that detect movement. An alarm installer can help
determine the system that is right for any carrier or operation. The system may be self-
sufficient or could be monitored by an outside company.
Perimeter walk-around procedures

A periodic walk-around or audit of the external areas of the facility and surrounding
grounds will provide useful information, keep the company aware of the security at the facil-
ity, and highlight any security holes.
The frequency with which you conduct security self-audits depends on the size of the opera-
tion and its relative level of risk. The assessment should be done under varying light
conditions (a burned-out light bulb would be invisible during the daylight hours, just as a
hole in the fence may not be visible at night). A checklist is provided below.
Remember to obtain employee input. Since they are closest to the issues, they might be able
to alert management to security concerns that go unnoticed during a walk-around audit.
Perimeter Walk-Around Inspection Checklist
Inspector: Date of inspection:
Lighting
Is lighting adequate?
Are there many shadowed areas?
Are all lights functional?
Does the lighting allow security personnel to see all sensitive areas, including the
perimeter?
Are there significant dark areas where an intruder could pass unnoticed?
Access Points
Are there any unsecured access points, either on the perimeter of the property or on any
buildings? (For example, open windows, unlocked gates, roof vents or skylights, culverts
that pass under the fence line, utility tunnels, etc.)
Visibility
Does vegetation obscure lights, walkways, entrances, or the fence line, or otherwise
compromise security?
Is there vegetation in which an intruder could hide? (Trees, vines, shrubs, etc., should be
trimmed regularly.)
30–Security 3/13

Perimeter Walk-Around Inspection Checklist, Continued

Inspector: Date of inspection:
Barriers/Deterrents
Are all fences and walls in good shape? Pay special attention to any trees, buildings, or
materials located near the fence line or next to a building; you may need to increase the
height of the fence in those areas to prevent someone from climbing over, or remove the
tree(s) or material(s).
Are all locks secured and do they offer adequate protection?
Are all gates and doors secured?
Are doors leading to sensitive areas locked? Could an intruder easily get through a door
by breaking a glass panel, removing hinge pins, or breaking right through the middle of
the door?
Are gates at least as secure as the fencing or barriers around them?
Are all security cameras aimed and operating properly?
Are all company security measures in place? Are they being enforced?
Are there any sensitive or valuable goods stored in unsecured outdoor areas?
Are alarm systems working properly?
Are ladders and other long, climbable objects secured or stored out of sight?
If the company handles hazardous materials on site, are they adequately secured and
protected? Hazmat storage areas should be secured with fences, walls, or placed inside
buildings.
Does the company have a secure employee parking lot located away from the main
terminal building(s)?
The written site security plan

Your company should prepare a written Site Security Plan to detail the security measures in
place, allow for evaluation of those measures, and provide contact information within the
company (response personnel) and outside the company (police, fire, medical).
The person responsible for distributing copies must be aware of who may and who may not
have access to the Site Security Plan, especially if it contains sensitive information. You may
prefer not to distribute paper or electronic copies of your written Site Security Plan to any-
one other than a select few, or you may prefer to write a secondary, less detailed plan that is
acceptable for distribution.
Your company should have contingency plans and procedures that consider the protection of
assets during a threatening event. Good contingency plans can help to lessen the risks and
speed up recovery. If nothing else, calling the proper emergency telephone numbers within a
contingency plan will bring in the appropriate emergency responders who have the best
chance of lessening the risk to people, property, information, and other assets.
You should have procedures for:

• reporting threats and incidents,
• handling suspicious packages,
• handling threats over the telephone,
• handling violence in the workplace,
• dealing with other workplace security crises.
3/13 Security–31

If your company assigns roles and responsibilities for security for activities before, during,
and after a security incident, people will know their duties and the risk of loss of assets may
be reduced or eliminated. You will want to consider all internal and external individuals,
teams, departments, and agencies and be sure to assign the lines of authority. Ask yourself
who will be in command, who will lead operations, who will plan strategies, and who will
determine logistics. Finally, be sure you indicate who will be the backup persons if the pri-
mary responsible persons are not available.
Site security topics should encompass the roles and responsibilities of employees. People are
more prone to feel dedicated to the security plan if they understand why there is a need for
a program, what their involvement will be, and particularly, what their part is. Generally,
topics may include, but are not limited to:
• potential threats;
• major risks of a security incident;
• controlled access entrances to the facility;
• employee identification badges or cards;
• visitor security procedures;
• how to report a security threat or suspicious activity;
• signs of terrorist or criminal activity;
• location and sound of alarms;
• how to deal with hostile persons;
• parking lot security;
• travel security;
• security policies, including those regarding confidential information;
• disciplinary action, training, and counseling those who threaten security or who do
not follow security policies; and
• who to contact for more information.
A Site Security Plan may require changes, or may need to be updated. Define and document
the Site Security Plan evaluation procedures. Review the evaluation procedures and make
needed changes. Ensure that management approves the evaluation procedures. Disseminate
the documents, provide guidance, and establish a help desk. Evaluation procedures should
address:
• evaluation objectives,
• evaluation approach,
• required equipment and resources,
• necessary personnel,
• schedules and locations,
• specific evaluation procedures, and
• expected results and exit criteria.
32–Security 3/13

Establish evaluation teams responsible for preparing and executing the Site Security Plan
evaluation procedures and acquire resources. Assign responsibilities to team members,
including executives, observers, and contractors.
Validate the capability of the Site Security Plan. Examine evaluation results for accuracy
and consistency and note discrepancies. Update the Site Security Plan based upon lessons
learned. Resolve shortcomings and problems. Ongoing changes in systems, software, applica-
tions, communications, and operations will also trigger updates to the plan. A re-test may be
required to ensure that the problems do not recur and that the updated plan provides the
specified capability.
Evaluate the facility

A security plan starts with an evaluation of the physical facility, its operations, its level of
risk, and its current state of security. Ask some basic questions about the operation to deter-
mine the level of security necessary.
What areas need to be secured? Are these high-traffic or highly visible areas? Are controls in
place to limit access?
What materials at the facility or in the possession of employees could be useful to a terrorist
group? What materials are valuable, and likely targets for theft?
Does the company know who and what is coming and going from various areas and depart-
ments of the facility? Is a printed record or log kept?
Are visitors logged in and out, and escorted throughout their visit?
Do you have adequate staff to sufficiently monitor access points leading to secure or sensi-
tive areas?
Do you have a key control system in place to prevent the unauthorized use of keys or access
to restricted areas?
Do you have a system in place to periodically inspect, maintain, and replace physical barri-
ers (doors, windows, fences, concrete barriers, etc.)?
The security system that’s right for each company will be unique to its specific operation.
Consider hiring a professional to conduct the evaluation and needs assessment, then get pro-
posals from several sources. If the budget allows, have a security presence in place 24 hours
a day, 7 days a week.
3/13 Security–33

Site security plan checklist

Use the following checklist as you are developing your written Site Security Plan, to ensure
that you cover all of the areas you want.
Before you start writing or revising your written plan:

❏ Read and understand any regulations, laws, and/or standards related to security for
your industry.
❏ Determine if your company needs a new or revised written Site Security Plan.
❏ Identify company assets and threats to those assets.
❏ Analyze any previous security incidents.
When writing the procedures:
❏ Meet with upper management to determine the content you may want the written
Site Security Plan to include.
❏ Determine who will have access to your written Site Security Plan.
❏ Document who provides input to the development of the plan.
❏ Document who will receive training.
Determine which of the following elements you want to include in your plan:
❏ Purpose — This section is a statement of the plan’s purpose.
❏ Administrative Duties — This section assigns responsibility for developing and
maintaining this plan.
❏ Risk Analysis — This section lists assets; threats; the probability, severity, and dol-
lar loss of those threats; and the relative risk of loss.
❏ Target Areas — This section lists areas of the company where criminals/terrorists
are likely to strike, as well as access points.
❏ Prevention Measures — This section describes physical, information, people, and
in-transit security measures.
❏ Security Policies —This section lists security policies.
❏ Contingency Plans and Procedures — This section lists any company plans and pro-
cedures relating to emergencies and security.
❏ Incident Aftermath — This section describes how the company will handle the
events that occur after a security incident.
❏ Roles and Responsibilities — This section lists the individuals, teams, departments,
or agencies responsible for security and their roles and responsibilities.
❏ Training — This section lists trainers, topics, and formats.
❏ Plan Evaluation — This section describes how the plan will be evaluated and
updated.
❏ Glossary of Terms — This section provides definitions and examples of various secu-
rity terms used in the plan.
❏ Appendices — This section lists documents attached to the plan.
34–Security 3/13

Sample plan: Physical site security program

Company Name: Contact Person:
Purpose
(enter company name) is dedicated to the protection of its employees,
visitors, information, facilities, and other assets from any security threat affecting our com-
pany in order to eliminate or reduce company losses. We place a high priority on developing,
validating, and, if necessary, implementing our company’s Site Security Plan. (enter any
company-specific goals, objectives, and policy statements). If after reading this plan, you find
that improvements can be made, please contact (enter name/title of
person(s) responsible). We encourage all suggestions because we are committed to the success
of this written plan.
Administrative duties
(enter name/title of person(s) responsible), our Site Security Plan
Administrator, is responsible for establishing and implementing our written Site Security
Plan. This person has full authority to make necessary decisions to ensure the success of
this plan. Copies of this written plan may be obtained from (enter
contact person/telephone number). (Note: The person responsible for distributing copies must
be aware of who may and may not have access to the plan, especially if it contains sensitive
information. You may prefer not to distribute copies, or you may prefer to write a secondary,
less detailed plan that is acceptable for distribution.)
Risk analysis
This written plan is designed to protect our company assets from threats. Assets include
people, property, and information. Our specific company assets, threats, and the probability
and severity of threats include the following:
Asset: Threat: Probability: Severity: Loss in dollars: Risk rating:
Analyzing the factors above, the assets with the highest risk of loss include: (enter assets).
Moreover, tallying the risk of loss for each threat, the threats causing the highest risk
include: (enter threats).
Target areas
We consider the following areas to be either directly related to assets or threats with a high
risk of loss, or to be likely access points for criminals or terrorists:
(list target areas and access points). We have considered these target areas when developing
our prevention measures, security policies, and incident procedures.
Prevention measures
Based on our risk analysis and target areas, our company has a clear picture of its critical
assets, significant threats, and primary targets. These have helped us determine the coun-
termeasures to offset them.
3/13 Security–35

Physical security
Physical security is the process of permitting access to the facility, systems, or information
by authorized persons while denying access to others. We have the following physical secu-
rity measures in place: (list measures).
Information security
Information security is protecting sensitive information, preventing sabotage and disruption,
and keeping critical business processes operational. We have the following information secu-
rity measures in place: (list measures).
Employee, contractor, customer, and visitor security

People — employees, contractors, customers, and visitors — are our largest assets. For this
reason, we have implemented a number of security measures to protect people: (list
measures).
In-transit security
It is important to protect assets such as people, product, property, cash, and information
while they are being transported or transmitted from one location to another. Here are our
in-transit security measures: (list measures).
Security policies
Our security effort has upper management’s support, as demonstrated by its implementation
of the following official company policies relating to security: (list poli-
cies, such as those for access, hiring/firing, disciplinary, sensitive information, privacy,
workplace violence, harassment, weapons, substance abuse, working alone, reporting,
responding to a security incident, media relations, and investigations).
Contingency plans and procedures

Despite careful use of preventive measures and security policies, there is always some likeli-
hood that events will occur which could put our assets at risk. For this reason, our company
has the following contingency plans and procedures: (List procedures,
such as those for reporting threats or handling suspicious packages, threats over the tele-
phone, violence, or security crises. List plans such as those required by 29 CFR 1910.38, .119,
and .120; 40 CFR 68, 112.3, and 355; and 49 CFR 130.31. Also, consider listing Workplace
Violence and Disaster Recovery Plans.)
Incident aftermath
A number of events can occur after an actual incident. We intend to handle these possibili-
ties as follows: (explain how you intend to assess the loss, reexamine
risks, prevent further loss, perform recovery activities, document actions to secure assets,
counsel employees, protect legal and financial interests, protect public image, report to law
enforcement, investigate the incident, and prosecute criminals).
36–Security 3/13

Roles and responsibilities

To meet our security measures, policies, and procedures, the following people will have the
roles and responsibilities listed below:
Individual, team, department, or Backup individual, team, department, Role and responsibility:
agency: or agency:
(Consider all internal and external people and assign the lines of authority. Indicate who will
be in command, lead operations, plan strategies, and determine logistics.)
Training
Many security measures have been presented, but without the dedication of employees, the
effectiveness of our Site Security Plan will be greatly diminished and some measures may
not work at all. Our goal is to raise employee dedication to and involvement in our plan by
providing security awareness training.
(enter name/title of person(s) responsible) trains all employees (enter
frequency) in the following: (list topics, i.e., potential threats, risks,
security measures/policies, signs of criminal/terrorist activity, visitor security, incident proce-
dures, reporting procedures, aftermath procedures, managing anger/stress, personnel with
security roles, employee assistance programs, parking lot security, disciplinary policy, and
who to contact for more information). Our training program includes
(list training formats, i.e., classroom instruction that uses lecture, discussion, videotape, con-
ference, and/or safety meeting formats; practical instruction that uses demonstration,
practical exercises and drills, hands-on instruction, and/or mentor formats; message instruc-
tion that uses handout, memorandum, e-mail, and/or poster formats; and/or performance
review formats).
We perform drills for the following security threats: (list threats). We
hold these drills at least (enter frequency). After a drill, the Plan
Administrator evaluates the effectiveness of the plan and reviews any employee input con-
cerning the drill. After an actual incident, further training may be necessary.
Plan evaluation
By having (enter name/title of person(s) responsible) thoroughly
evaluate and, as necessary, revise our plan, we ensure our program’s effectiveness and pre-
vent or eliminate any problems. Plan evaluation involves the following:
. (Describe your evaluation method, i.e., drills, tests, tabletop exercises,
audits, post-incident assessments, legal reviews, and other evaluation methods. Describe your
evaluation objectives, approach, resources, personnel, schedules and locations, specific proce-
dures, expected results, and exit criteria. Ongoing changes may affect the plan. Retesting may
be necessary to ensure problems do not recur.)
Glossary of terms
(Define any terms from the plan that require clarification.)
Appendices
We have attached the following documents for reference: (list appen-
dices, i.e., map, checklists, timesheets, incident data, written plans, or reference material).
3/13 Security–37

Secure your company’s sensitive information and technology

Protection of sensitive information — proprietary, trade secret, and strategic data — is also
an important component of a comprehensive security program. More and more critical busi-
ness data is being stored electronically, and that means more and more criminals are
becoming cyber criminals. In the wrong hands, a company’s electronic data could be used to
track and steal materials, transfer funds, obtain financial information (including credit card
numbers), and create fake orders. Are your company’s electronic files and technical data pro-
tected as well as the physical assets?
Strategic technology
Businessmen who are involved in any aspect of high technology research, development,
and/or production are potential acquisition targets for theft of technological information. A
company or corporation may consider a high-technology product that they are developing to
be small in significance when compared to more publicized, sought after technologies.
Remember, however, that the “small” technological project could easily be the necessary com-
ponent to a major technological development.
Businesses should consider four major areas:

❏ Identify inquiries and orders for production parts or technology, which are likely to
be shipped outside the United States, and see that these transactions are handled
by export specialists.
❏ Ensure that your export specialists are sufficiently knowledgeable about export con-
trols and that appropriate screening and licensing procedures are followed.
❏ Make certain that employees — whether they live, travel, or transmit information
abroad, or merely come in contact with foreigners visiting the United States — fully
understand restrictions on the flow of certain technical data or know-how, whether
it be written, oral, or visual.
❏ Identify major customers who request to pay cash or who otherwise exhibit suspi-
cious behavior when seeking to obtain sensitive merchandise and advise appropriate
authorities as soon as possible.
Strategic technology is an important asset to our national defense and could be an instru-
ment of intimidation or destruction in the hands of adversaries.
Conduct a risk assessment

Electronic equipment and files are not just vulnerable to theft and unauthorized access:
they’re vulnerable to accidental loss (e.g., hard-drive crashes, accidental file deletion, etc.).
Compare your computer security measures with the following recommended practices, and
take the steps necessary to protect data and equipment.
First, determine the risks and security needs and plan for the worst-case scenario. Ask these
questions:
• What data is being stored electronically?
• Who has access?
• Is the backup system adequate to prevent accidental data loss?
38–Security 3/13

• Does the company have sensitive data on a website or elsewhere on the internet?
How is it protected?
• Are computers and their components and peripherals secured against theft?
• Can someone outside the company (even outside the country) access the company’s
network through the internet?
• Is the malicious destruction of data a possibility? Can data be easily recovered from
such an attack?
• How is the information protected from unauthorized use and accidental loss?
• Finally, what would happen if someone gained access to all of the organization’s
electronic data and either destroyed it or used it to their advantage (for example, to
steal materials, share confidential company data with others, or even blackmail)?
To help plan, create a written blueprint of the computer equipment, software, network, and
data, and the people who must have access. Limit employee access to data and hardware.
Back up data frequently — every day (or night) if possible. Keep all original software media
and file backups in a secure, locked location.
Protect electronic files from computer viruses. At a minimum, install virus-checking software
on all computers and obtain updates regularly.
Limit access to critical records and files

From order forms to financial records, every company has valuable or confidential files that
need to be kept secure. Consider the following information security issues when developing
your program.
Begin with an evaluation of all files and current security measures. Where are the files
stored now? Are they in one secure location or spread out around the company? Are those
areas accessible to people who shouldn’t see the files? Who has access? How is the area
monitored?
Keep all critical files in a secure location that is inaccessible to unauthorized people, includ-
ing employees and visitors. A locked file cabinet, by itself, is generally not enough.
Make sure that all doors leading to the file storage area are locked after hours. Janitorial
staff should be closely supervised in these areas.
Minimize access to records concerning hazardous materials or other materials that may be
targeted.
If using a locked filing cabinet or a safe, evaluate its level of security. Would it survive a
crowbar? A fire or flood?
Consider storing important but seldom-used documents off-site, such as in a safe deposit
box.
Establish a policy for disposal of unwanted, sensitive documents. These may be extra copies
that otherwise might be thrown in the trash next to the copier, or old files that have been
discarded. Thetrash bin has proven to be a dangerous method for disposing of ultra-sensitive
files. At a minimum, sensitive documents should be shredded.
3/13 Security–39

Information security is protecting sensitive information, preventing sabotage and disruption,

and keeping critical business processes operational. Information security may involve, but is
not limited to the following practices:
❏ Lock filing cabinets and trash receptacles.
❏ Label documents confidential, if applicable.
❏ Shred sensitive documents.
❏ Determine appropriate document retention procedures (retaining only necessary
data).
❏ Develop policies for distributing sensitive information.
❏ Disallow employees to store documents on top of their desks.
❏ Hold sensitive conversations face to face.
❏ Protect all fax transmissions.
❏ Secure computer rooms, archives, and other records and information storage areas.
❏ Install intrusion detection systems.
❏ Secure all data delivery vehicles.
❏ Use virus scanners.
❏ Install network firewalls.
❏ Hire trustworthy employees.
❏ Keep backups off-site.
❏ Use password protection and update passwords regularly.
❏ Use cryptographic keys.
❏ Monitor computer and network system use.
❏ Use modems that require dial-back verification.
❏ Verify the authenticity of data, messages, and users.
❏ Detect and correct corrupted data transmissions.
❏ Provide e-commerce security.
❏ Consider home computer security.
❏ Secure email.
❏ Authorize information access to as few users as is necessary.
❏ Supervise visitors.
❏ Do not share passwords, keys, entry cards, or combinations with unauthorized
persons.
❏ Do not post signs to information storage or computer areas.
❏ Locate information storage or computer areas where risks are reduced or
eliminated.
40–Security 3/13

Security tips for small business computer users

The National Infrastructure Protection Center (NIPC) recently published a list of sugges-
tions for protecting computer networks from cyberattacks.
The NIPC suggests that to limit the potential damage from any cyber attacks, system
administrators follow best practices to ensure the security of their networks. Some of the
most basic measures are:
❏ Increase user awareness.
❏ Update anti-virus software.
❏ Stop hostile attachments at the email server.
❏ Utilize ingress and egress filtering.
❏ Establish policy and procedures for responding and recovery.
❏ The NIPC also suggests the following practices for small business and home comput-
ers users:
❏ Use strong passwords. Choose passwords that are difficult or impossible to guess.
Give different passwords to all accounts.
❏ Make regular backups of critical data. Backups must be made at least once each
day. Larger organizations should perform a full backup weekly and incremental
backups every day. At least once a month backup media should be verified.
❏ Use virus protection software. That means three things: having it on your computer
in the first place, checking daily for a new virus signature updates, and then actu-
ally scanning all the files on your computer periodically.
❏ Use a firewall as a gatekeeper between your computer and the Internet. Firewalls
are usually software products. They are essential for those who keep their comput-
ers online through the popular DSL and cable modem connections but they are also
valuable for those who still dial in.
❏ Do not keep computers online when not in use. Either shut them off or physically
disconnect them from Internet connection.
❏ Do not open e-mail attachments from strangers, regardless of how enticing the Sub-
ject Line or attachment may be. Be suspicious of an unexpected e-mail attachment
from someone you do know because it may have been sent without that person’s
knowledge from an infected machine.
❏ Regularly download security patches from your software vendors.
Identity theft
Another major concern of information security is that of identity theft. A criminal or extrem-
ist with a fake ID could have access to a company’s equipment and facility, so confidential
and sensitive employee information, such as Social Security numbers, must be protected.
How identity theft occurs

Individuals wishing to steal critical information use a variety of methods to accomplish their
goals.
3/13 Security–41

Common methods for stealing information from the employees include:

• stealing wallets containing personal identification numbers and credit and banking
information;
• sifting through trash for personal data such as old credit card or bank statements;
• stealing personal mail, including bank and credit card statements, pre-approved
credit offers, telephone bills, and tax information;
• filling out a change of address form to divert a person’s mail to another location.
This method is surprisingly easy;
• fraudulently posing as a landlord or employer to obtain a credit report;
• using personal information an employee might share on the Internet.
Common methods for stealing information from the company include:
• sifting through company trash to obtain such things as old payroll statements, order
forms, purged records, and so on;
• buying personnel records from an inside source. An identity thief may try to estab-
lish a relationship with an employee who has access to personnel records and other
targeted information;
• hacking into a computer system in an effort to gather driver information.
Minimizing the risk for employees

Employees should be trained not to give out any personal or business information. If it’s
unavoidable, then they should first find out who is asking for the information, how it will be
used, and whether or not the information will be shared with others. Instruct employees to
never give personal or corporate information out over the phone or Internet unless they
know exactly who they are dealing with.
Employees should pay close attention to their regular billing cycles. If credit card bills, bank
statements, or other important mail does not show up on time, follow up with creditors or
the financial institution immediately.
Take steps to guard your mail from theft. Outgoing mail should be placed in post office col-
lection boxes, and arrangements should be made to have incoming mail removed promptly
from their mailboxes.
Minimize the number of identifying information documents employees carry, and keep items
with personal information in a safe place. Destroy or shred old charge receipts, copies of
credit card and bank statements, insurance forms, physician statements, etc., that are des-
tined for the trash.
Employees should provide their Social Security number only when absolutely necessary.
Minimizing the risk for the company

Conduct thorough background checks on all employees to reduce the risk of insider identity
theft.
Understand that any employee, vendor, or supplier can pose a potential security threat.
Develop and implement communication policies that limit information exchanges to only
data that is essential for conducting business.
42–Security 3/13

All purged and expired documents from personnel and medical files should be shredded or
otherwise destroyed.
Numbers other than Social Security numbers should be used for the purpose of employee
identification.
Train all employees about security procedures in handling personal data by fax or email.
Driver qualification and other confidential files should be maintained in a secure area of the
building with very limited access.
The written information security plan

To help you plan, create a written blueprint of the computer equipment, software, network,
and data, and the people who must have access.
Once the strengths and vulnerabilities have been determined, consider including the follow-
ing practices in a written policy:
❏ Limit employee access to data by password-protecting files and operating systems.
Only allow as much access as necessary (for example, don’t give someone full access
to read, delete, and/or make changes to files if they really only need to be able to
read from them). Put some thought into the appropriate level of data security
needed. Severely limiting access to files can cost time, while free and open access
can be dangerous.
❏ If the company has one or more computer networks, limit physical and electronic
access to the servers and the rooms containing them.
❏ When an employee leaves the company, make sure that no electronic files are taken,
and remove the employees access rights immediately.
❏ Back up data frequently — every day (or night) if possible. A backup can be used to
restore an entire computer’s data, or just a single file. At least some of the tapes or
disks used to back up files should be stored off-site (for example, one set of backups
per week or month could be taken off-site). This helps ensure their security and pre-
vents them from being damaged in a fire or other disaster. If the company has a lot
of electronic data, it could make daily backups of critical data only and weekly back-
ups of the entire collection. Periodically test the backups to make sure the system is
working properly.
❏ Keep all original software media and file backups in a secure, locked location. Not
only does this prevent theft, but the software will be there if the company ever
needs to reinstall it.
❏ If possible, consult with an expert on specific vulnerability to intrusion through the
internet (i.e., the possibility that someone, from virtually anywhere in the world,
could break into the computer system or website and access critical data). If the
company can’t afford a strong level of security, consider changing or removing the
connection to the internet or removing sensitive data.
❏ Protect electronic files from computer viruses, which can virtually destroy a com-
puter and all its data. At a minimum, install virus-checking software on all
computers and obtain updates regularly (weekly, if possible). As a further step, limit
employee access to email and limit the amount of disk and file sharing that occurs
(i.e., the transferring of disks and files from one computer to another, which can lead
to the spread of a virus).
3/13 Security–43

❏ A loss of power can destroy data as well. Protect computer systems from power prob-
lems (power loss, spikes, brownouts, etc.) by installing an uninterruptible power
supply, which stores electricity until needed.
Questions to consider when formulating the policy and assigning duties:
• What measures will be implemented to ensure that all reported threats are
investigated?
• What guidelines will be followed to determine the validity of a threat?
• If a crisis does arise, what steps will be taken?
• What information should be disclosed? To whom?
• Who will be responsible for ensuring the data is properly restored?
Define and document the Information Security Plan evaluation procedures. Review the
evaluation procedures and make needed changes. Ensure that management approves the
evaluation procedures. Disseminate the documents, provide guidance, and establish a help
desk. Evaluation procedures should address:
• evaluation objectives,
• evaluation approach,
• required equipment and resources,
• necessary personnel,
• schedules and locations,
• specific evaluation procedures, and
• expected results and exit criteria.
Establish evaluation teams responsible for preparing and executing the Information Security
Plan evaluation procedures and acquire resources. Assign responsibilities to team members,
including executives, observers, and contractors.
Address hiring issues and personnel security

Another important component of a comprehensive security program is hiring and training
personnel at your company. This section provides tools that cover two types of employee and
personnel security: making sure that you hire and maintain a trustworthy workforce, and
making your employees part of the security force through individual awareness.
An employee, or even a prospective employee, can pose a substantial security risk. There-
fore, personnel security issues begin with the hiring process. Employers need to have a
documented hiring process in place, including conducting thorough background checks.
Once the employee is hired, employers need to have personal safety and security training
programs in place.
Finally, employers need to document and communicate security procedures, including disci-
plinary actions, regarding restricted areas, use of company equipment, and sensitive and
confidential documents.
44–Security 3/13

Hiring issues
The following steps can help reduce the risk that an unauthorized person becomes an
employee:
❏ Ask managers to recognize that employees can be substantial security risks.
❏ Ensure that background checks have been performed. Recommend more detailed
background checks for suspicious individuals. Look at the following for indicators:
gaps in employment, frequent job shifts, all names used by the applicant, type of
military discharge, citizenship, present and prior residence information, personal
references, criminal history, verify U.S. citizenship for all employees.
❏ For those employees who are not U.S. citizens, verify that all immigration papers
are on file and properly documented.
❏ Conduct interviews when hiring new employees. Obtain information that will help
to appraise the personality, character, motivation, honesty, integrity, and reliability
and to judge appearance and personnel characteristics face to face.
❏ Any information or suspicious activity discovered during the review of these files
should be reported immediately.
Be aware of personal identify theft such as using stolen social security numbers, references,
etc.
Consider running criminal background checks on individuals with access to very sensitive
materials (explosives, poison gases, biological agents). An effective background check may
include a number of elements:
• Criminal—must be made with each state and only goes back so many years.
• Employment—verifies elements on an applicant’s resume, but also gives you an
opportunity to learn about any former criminal behavior.
• Personal reference—provides information about an applicant’s values, sense of
responsibility, and strengths. If the applicant chose a poor reference, that reference
may also provide information about weaknesses.
• Court records—indicates an applicant’s character and financial disputes.
• Workers’ compensation—allowed after offering employment, this gives your company
reason to take back a job offer if a claim is missing from an application. It can be
difficult to determine whether workers’ compensation has been used fraudulently.
• Driving record—verifies a social security number and address, but any driving viola-
tions may also reveal a lack of responsibility.
• Credit history—a good source to verify the name, address, and social security
number. It shows financial history. Signed permission required.
• Social security number—verifies not only the number, but addresses which can be
used for other background checks.
• Education—verifies degrees claimed and the honesty of the person.
3/13 Security–45

Avoid background check backfire. Certain laws protect the privacy of people. Also, if used
improperly, background checks can be ammunition in a discriminatory lawsuit against your
company. Therefore, these checks must be done carefully. To avoid background check prob-
lems:
❏ Have applicants sign an agreement to allow former employers to give your company
or its representative information relating to the applicant, no matter how positive or
negative the information is.
❏ Only search for information relating to the prospective employee’s job. For example,
a credit check for an editor position might not be relevant.
❏ Consider using an outside source for performing background checks. This may
ensure that the checks are done consistently for all employees.
❏ Obtain legal advice before implementing your own internal background checking
process.
Employee training
Improving overall company security is really all about increasing each employee’s individual
awareness and alertness. It means making sure doors and windows that should be locked
are. It means not leaving sensitive or confidential documents on a desktop for anyone to see
or take. It means keeping your eyes and ears open. In other words, being more secure at
work takes work and attention to every detail. Train all employees to take notice of suspi-
cious activities and people and report them.
Consider implementing security training for employees that includes:
• company security objectives,
• specific security procedures,
• employee responsibilities, and
• organizational security structure.
Workplace security training topics should encompass the roles and responsibilities of
employees. In this way, employees will watch for workplace security threats. People are
more prone to feel dedicated to the plan if they understand why there is a need for a plan,
what their involvement will be, and particularly, what their part is. Generally, topics may
include, but are not limited to:
1. potential threats,
2. major risks of a security incident,
3. importance of the company’s strategies to prevent threats and lessen the risks to
assets,
4. incident procedures,
5. how to report a security threat or suspicious activity,
6. signs of terrorist or criminal activity,
7. personnel assigned to security duties,
8. the hazards associated with security efforts,
46–Security 3/13

9. security policies, including those regarding confidential information, and

10. who to contact for more information.
The following provides a brief outline of topics that you might cover to help increase your
employee’s awareness of security at your facility.
1. Talk about the changing security concerns. Briefly lay out the elements of the pro-
gram that you plan to cover.
2. Discuss perimeter defenses around a building. Talk about the perimeter defenses
around your company’s facilities.
3. Talk about the controlled access entrances to your facilities.
• Discuss the procedures that are in place at entrances to your facilities.
• Show trainees the type of employee access cards they will be issued and how to
use the card scanner.
• Discuss security requirements for having and using the access cards. Use a dia-
gram to show trainees where security cameras are located.
4. Introduce the need for security inside company facilities.
5. Discuss suspicious activities trainees should look for.
• Explain what employees should do if they notice any suspicious activities.
• Talk about any special security procedures your company has implemented.
6. Discuss employee identification badges or cards. Show trainees the type of
employee identification badges or cards that your company issues.
7. Discuss the security procedures that visitors to your company must follow. Talk
about your company’s security procedures for visitors, contractors, and the public.
Critical infrastructure security

USA Patriot Act
On October 26, 2001 President Bush signed the “Uniting and Strengthening America by Pro-
viding Appropriate Tools Required to Intercept and Obstruct Terrorism (USA PATRIOT ACT)
Act of 2001” into law. Listed below are some of the sections that could impact the environ-
ment and how we respond to terrorism that effects the America’s air, water, land, and
natural resources.
(Sec. 1005) First Responders Assistance Act — Directs the Attorney General to make grants
to State and local governments to improve the ability of State and local law enforcement,
fire department, and first responders to respond to and prevent acts of terrorism. Authorizes
appropriations.
(Sec. 1012) Amends the Federal transportation code to prohibit States from licensing any
individual to operate a motor vehicle transporting hazardous material unless the Secretary
of Transportation determines that such individual does not pose a security risk warranting
denial of the license. Requires background checks of such license applicants by the Attorney
General upon state request.
3/13 Security–47

(Sec. 1013) Expresses the sense of the Senate on substantial new U.S. investment in bioter-
rorism preparedness and response.
(Sec. 1014) Directs the Office for State and Local Domestic Preparedness Support of the
Office of Justice Programs to make grants to enhance state and local capability to prepare
for and respond to terrorist acts.
(Sec. 1016) Critical Infrastructures Protection Act of 2001 — Declares it is U.S. policy: (1)
that any physical or virtual disruption of the operation of the critical infrastructures of the
U.S. be rare, brief, geographically limited in effect, manageable, and minimally detrimental
to the economy, human and government services, and U.S. national security; (2) that actions
necessary to achieve this policy be carried out in a public-private partnership involving cor-
porate and non-governmental organizations; and (3) to have in place a comprehensive and
effective program to ensure the continuity of essential federal government functions under
all circumstances. In addition, Sec. 1016:
• Establishes the National Infrastructure Simulation and Analysis Center to serve as
a source of national competence to address critical infrastructure protection and con-
tinuity through support for activities related to counterterrorism, threat assessment,
and risk mitigation.
• Defines critical infrastructure as systems and assets, whether physical or virtual, so
vital to the United States that their incapacity or destruction would have a debili-
tating impact on security, the economy, national public health or safety, or any
combination of those matters. Authorizes appropriations.
The Public Health Security and Bioterrorism Preparedness and Response Act of 2002 (Bio-
terrorism Act) — promotes the security and preparedness of the nation’s water
infrastructure. EPA is the agency primarily tasked with overseeing the nation’s water
security.
Section 1433 of the Safe Drinking Water Act — addresses chemical security at drinking
water systems “to a degree.” Section 1433 requires community water systems providing
drinking water to more than 3,300 persons to conduct a vulnerability assessment, certify its
completion, and submit a copy of the assessment to EPA. The assessment must specifically
include the use, storage, and handling of chemicals. Plus, the section requires each water
system to prepare or revise and emergency response plant that incorporates the findings of
the vulnerability assessment and to certify to EPA that the system has completed such a
plan.
Since 2003, EPA has received 100 percent of the Vulnerability Assessments and emergency
response plan certifications from large and medium community water systems. Plus over 99
percent of smaller community water systems serving between 3,300 and 50,000 people have
submitted their assessments and certifications.
EPA says its role in drinking water security is to promote the voluntary adoption of counter-
measures by water facilities.
How EPA oversees water security
EPA Chemical accident prevention provisions — (40 CFR 68.1- .220) under the CAA
section 112(r) requires utility processes containing certain levels of specific hazardous sub-
stances to implement an accident prevention program, conduct a hazard assessment,
prepare and implement and emergency response plan and submit to EPA a summary report
48–Security 3/13

known as a risk management plan (RMP). The RMP must describe the facility’s accidental
release prevention and emergency response policies, the regulated substances handled at the
facility, the worst-case release scenario(s) and alternative release scenarios(s), the 5-year
accident history of the facility the Emergency Response Plan, and planned changes to
improve safety at the facility (40 CFR Part 68). Hazardous chemicals of most relevance to
the Water Sector, including gaseous chlorine, ammonia, sulfur dioxide, and chlorine dioxide
trigger RMP regulatory requirements if they exceed certain threshold quantities.
Drinking water system security act of 2009 — Under the bill, these assessments and
plans are not limited to chemical security, but cover the full array of potential water system
vulnerabilities, from pipes and constructed conveyances to storage facilities and electronic
systems. As such, the bill provides statutory authority for EPA to continue to promote the
risk reduction goals of the 2002 Bioterrorism Act.
These directives and laws supplement existing legislation, such as the Safe Drinking Water
Act and the Clean Water Act, which have always had the goals of promoting a clean and
safe supply of water for the nation’s population and protecting the integrity of the nation’s
waterways. These directives and laws affect the actions and obligations of EPA, the Water
Security Division, and water utilities.
The Bioterrorism Act:
• Mandates a vulnerability assessment for all public water systems serving 3,300 or
more and requires its submission to EPA.
• Mandates an emergency response plan informed by the findings of the vulnerability
assessment and requires a letter of verification to EPA.
• Makes tampering with a drinking water system a federal offense with maximum
civil penalty of $1,000,000 and/or up to 20 years in prison.
The Patriot Act lists water as one of several “critical infrastructure” sectors, which are
defined as “systems and assets, whether physical or virtual, so vital to the United States
that the incapacity or destruction of such systems and assets would have a debilitating
impact on security, national economic security, national public health or safety or any combi-
nation of those matters.”
EPA’s Office of Homeland Security (OHS) oversees the agency’s planning, prevention, pre-
paredness, and response for homeland security-related incidents. OHS serves as the agency’s
liaison for homeland security matters. The office works closely with the White House Home-
land Security Council, Department of Homeland Security, and other federal agencies as it
coordinates overall EPA homeland security strategy.
Programs administered by OHS include:
• Criminal Enforcement & Forensics
• Decontamination, Cleanup, and Recovery
• Emergency Preparedness & Response
• Food and Agriculture Protection
• Homeland Security Research & Science
• Pandemic Flu Preparedness
• Waste Management
3/13 Security–49

• Water Security
• Regional Programs
The agency has developed two major programs under Homeland Security Presidential Direc-
tive 9, which states EPA must “develop robust, comprehensive, and fully coordinated
surveillance and monitoring systems, including international information for… water quality
that provides early detection and awareness of disease, pest, or poisonous agents.”
The first program is the Water Laboratory Alliance (WLA). Its purpose is to provide the
drinking water sector with an integrated nationwide network of laboratories with the capa-
bilities and capacities to support the monitoring and surveillance efforts of water utilities in
preventing and detecting drinking water supply contamination events.
The second program is the Water Security (WS) Initiative. This program addresses the risk
of intentional contamination of drinking water systems. The WS consists of three phases:
Phase 1: Designs the methods of detection and plans appropriate responses to mitigate pub-
lic health and economic impacts;
Phase 2: Tests and demonstrates contamination warning systems; and
Phase 3: Develops guidance to promote voluntary national adoption of contamination warn-
ing systems.
EPA’s objectives for a contamination warning system include the ability to:
• Detect a broad spectrum of contaminants;
• Achieve spatial coverage of the entire distribution system;
• Detect contamination early enough to have an effective response;
• Maintain operational reliability;
• Minimize false positives; and
• Provide a sustainable way to daily monitor the distribution system for water quality.
There are two major operations phases associated with a contaminant warning system:
1. Routine monitoring and surveillance
2. Consequence management
The day-to-day monitoring and surveillance components include:
• Online water quality monitoring. Stations located throughout the distribution
system measure parameters for chlorine, total organic carbon, conductivity, etc. Soft-
ware analyzes the data to establish baseline parameters. Possible contamination can
be detected when significant changes from the baseline occur.
• Public health surveillance. Keeps watch on public health data such as over-the-
counter drug sales, hospital admissions reports, infectious disease reports, 911 calls,
Emergency Medical Services reports, and poison control calls for signs of waterborne
diseases or drinking water contamination.
50–Security 3/13

• Sampling and analysis. Analyzes water distribution system samples for classes of
contaminants and specific contaminants. Sampling includes routine analysis to
establish a baseline and analysis that is triggered by an indication of possible
contamination. Analyses are conducted for chemicals, radionuclides, pathogens, and
toxins.
• Enhanced security monitoring. Uses equipment and procedures to detect and
respond to security breaches at water system facilities. Security equipment can be
cameras, motion sensing lights, door contacts, ladder and window motion detectors,
and access hatch detectors.
• Customer complaint surveillance. Collects and analyzes customer calls for water
quality problems that may indicate possible contamination. Customers may detect
contaminants characterized by changes in odor, taste, or clarity.
Consequence management provides a decision-making framework for establishing credibility,
mobilizing effective responses, and ultimately returning the system to normal operations.
EPA recognizes that developing a contaminant warning system will involve a significant
amount of time, effort, and finances for a water utility. Development phases include:
• Planning;
• Designing;
• Implementing;
• Testing;
• Operating and maintaining; and
• Evaluating and refining.
In the planning phases, utilities should define their objectives for the warning system and
conduct an assessment and gap analysis to identify their capabilities for each monitoring
and surveillance component of the system. Water utilities should also identify and engage
local partners that may play a significant role in routine operations, such as the local health
department and environmental laboratories.
3/13 Security–51

Reserved
52–Security 3/13

ISO 14001
ISO’s environmental management standards

ISO 14000 is a series of voluntary standards and guideline reference documents, being
developed through the International Organization for Standardization (ISO) since 1993,
which will help organizations of any size and level of environmental performance establish
an environmental management system or improve an existing one.
The standards and guideline reference documents cover environmental management systems
(EMS), eco-labeling, environmental auditing, life cycle assessment, environmental perfor-
mance evaluation, and environmental aspects in product standards. The focus on
“management” distinguishes these standards from “performance” standards.
EMS helps an organization to establish and meet its own policy goals through objectives and
targets, organizational structures and accountability, management controls and review func-
tions all with top management oversight. EMS do not set requirements for environmental
compliance nor do these standards establish requirements for specific levels of pollution pre-
vention or performance. The Environmental Management Systems specification document
calls for environmental policies that include a commitment to both compliance with environ-
mental laws and pollution prevention.
The ISO standards do not directly require environmental compliance nor do they establish
specific performance levels. Instead, the standards will guide an organization through the
essential steps of implementing an environmental management system, including:
• Developing internal commitment and an environmental policy.
• Establishing objectives and targets.
• Implementing the system through organizational structures and accountability.
• Measuring and evaluating progress.
• Review and continuous improvement.
9/12 ISO 14001–1

At the heart of the ISO 14000 series are two documents. The “ISO 14001 Environmental
Management Systems; Specification with Guidance for Use” contains the core auditable ele-
ments of an EMS program. The broader companion document is “ISO 14004, Environmental
Management Systems - General Guidelines on Environmental Management Principles, Sys-
tems and Supporting Techniques.” These two documents were adopted and published in
September 1996.
International scope
These standards are expected to be embraced by the international community, and U.S.
businesses that seek to maintain or develop international markets will very likely be
required to become certified. The focus of these new standards will be on integrating envi-
ronmental management decision making into existing management systems.
As companies have become more and more integrated into a world market, there has been
concern that businesses in countries with more stringent environmental regulations face a
competitive disadvantage. ISO 14000 attempts to address these concerns by establishing a
uniform set of standards agreed upon by the international business community.
The International Organization for Standardization (ISO)

ISO is a private international standards body based in Geneva, Switzerland. Founded in
1947, ISO promotes the international harmonization and development of manufacturing,
product, and communications standards through its Technical Committees. More than 8,000
ISO standards have been promulgated, for everything from paper sizes to film speeds. More
than 120 countries belong to ISO as full voting members, including the United States. The
official U.S. representative to the ISO is the American National Standards Institute (ANSI),
located in New York.
ISO 14000 standards

The standards and guideline reference documents cover:
• Environmental management systems (EMS).
• Environmental management systems (EMS).
• Environmental auditing.
• Environmental labeling.
• Environmental performance evaluation.
• Life-cycle assessment.
• Environmental aspects in product standards.
The standards focus on management. The basic structure of the standards is partially
derived from the ISO 9000 quality management standards.
Environmental management systems help an organization to establish and meet its own
policy goals. They use top management oversight of objectives and targets; organizational
structures and accountability; management controls and review functions.
Environmental management systems do not set requirements for environmental compliance.
These standards do not establish requirements for specific levels of pollution prevention or
2–ISO 14001 9/12

performance. The environmental management systems specification document calls for envi-
ronmental policies that include a commitment to both compliance with environmental laws
and pollution prevention.
How to participate
The process is completely open and any interested party may participate. Industry, govern-
ment, small and medium-sized businesses, academia and environmental groups currently
make up the U.S. Technical Advisory Group (TAG) membership. To learn more about partici-
pating, see the contacts listed under “For More Information” at the end of this chapter.
ANSI’s role
The American National Standards Institute (ANSI) maintains policies and procedures for
the development, review and coordination of voluntary standards that are designated as
American National Standards. However, ANSI is not a standards developer. ANSI, head-
quartered in New York, is the official U.S. member body to ISO, and its membership derives
from organizations, companies, and government agencies.
How ISO 14000 relates to TC-207

ISO assigns a document numbering system to each Technical Committee. Standards pro-
duced by TC-207 are assigned the 14000 designation. For example, the Environmental
Management Systems (EMS) Guidance Standard will become ISO 14000. The EMS specifi-
cation document will become ISO 14001. Each subsequently completed ISO standard from
this TC will have an ISO 14000 designation.
ISO 14000 documents

The following outline shows the different subcommittees or work groups under TC-207 and
the standards they are currently developing:
Subcommittee 1 — environmental management systems (EMS)

Objective: To establish standards for setting environmental policy, objectives, and responsi-
bilities and to implement them through planning, measures of effectiveness and control of
environmental impact.
ISO 14001 Environmental Management Systems; Specification with Guidance for Use (pub-
lished and adopted)
ISO 14004 Environmental Management Systems; General Guidelines on Principles, Sys-
tems, and Supporting Techniques (published and adopted)
Subcommittee 2 — Environmental auditing

Objective: To standardize environmental auditing and related environmental investigations.
ISO 14010 Guidelines for Environmental Auditing; General Principles of Environmental
Auditing (published and adopted)
ISO 14011 Guidelines for Environmental Auditing; Audit Procedures, Auditing of Environ-
mental Management Systems (published and adopted)
9/12 ISO 14001–3

ISO 14012 Guidelines for Environmental Auditing; Auditor Qualifications (published and
adopted)
Subcommittee 3 — Environmental labeling

Objective: To develop standard terminology, definitions, symbols, test methods, test sum-
mary, and reporting standards. Note: This document is currently at the ISO draft
international standards (DIS) voting stage. It is expected to be completed and pub-
lished by ISO by the end of the third quarter of 1998.
ISO 14020 Environmental Labeling; Guiding Principles for Environmental Labeling Pro-
grams
ISO 14021 Environmental Labeling; Self-Declaration Claims
ISO 14024 Environmental Labeling; Guiding Principles for Practitioner Programs
Subcommittee 4 — Environmental performance evaluation

Objective: To develop guidance for evaluating environmental effects of products and services
and the effect of business operations on the environment. Note: This document is cur-
rently at the ISO draft international standards (DIS) voting stage, and is expected
to be advanced for ISO/CEN parallel voting to also become a European standard. It
is expected to be completed and published by ISO by the end of the second quarter
of 1999.
ISO 14031 Environmental Performance Evaluation
Subcommittee 5 — Life-cycle assessment

Objective: To develop standardized programs for analyzing environmental impacts of prod-
ucts, processes and services during their life cycle, including the production and utilization
of raw materials, manufacturing practices, distribution methods and options related to dis-
posal or recycling.
ISO 14040 Life-Cycle Assessment (published and adopted)
Subcommittee 6 — Terms and definitions

Objective: To standardize terminology and coordinate use of standards with other commit-
tees within ISO. Note: This document is currently at the ISO draft international
standards (DIS) voting stage. It is expected to be completed and published by ISO
by the end of the first quarter of 1998.
ISO 14050 Terms and Definitions
Workgroup 1 — Environmental aspects in product standards

Objective: To develop guidance for use by other technical committees for including environ-
mental elements in existing or forthcoming product standards.
ISO 14060 Environmental Aspects in Product Standards (committee draft status)
4–ISO 14001 9/12

Certification issues
“ISO 14001 Environmental Management Systems; Specification with Guidance for Use” is a
standardized, auditable set of procedures that companies can use to implement their envi-
ronmental policies and to obtain certification of conformance through national or
international registration/certification systems. Certified conformance to the system stan-
dard may eventually become a requirement for international trade.
ISO 14001 is the one standard out of the ISO 14000 series to which businesses can choose to
certify their environmental management programs. As ISO 14000, overall, is a voluntary set
of standards, they can also choose to implement ISO 14001 without seeking certification. For
example, they can implement ISO 14001 and self-declare that they are in compliance with
the standard. Or, they can implement it and have their EMS audited by a customer, based
on an earlier contractual agreement.
Again, businesses should keep in mind that ISO 14000 is a set of standards, not regulations,
and certification is completely voluntary. The incentive for companies to obtain certification
is that it will help provide access to international markets, particularly in instances where
companies require that their suppliers be certified.
Also, these standards will very likely impact even smaller, domestic businesses. A commonly
held view is that as large multi-nationals engaged in international trade implement ISO
14000, they will in turn require that their suppliers do the same.
Additionally, another strong incentive for certification will be situations where the standards
are referenced in bilateral or trade agreements. In these cases, the standards may well
become virtual requirements for conducting trade.
ISO 14000 certification will present a challenge to most U.S. companies. However, for busi-
nesses that have already incorporated the concepts of waste reduction into their
management systems, the certification process should be easier.
Waste reduction
Waste reduction requires that companies think holistically and consider the environmental
impacts of design decisions, raw material choices, process line changes, and plant operation
decisions. These are all important components of ISO 14000. ISO 14000 provides an addi-
tional incentive for adopting waste reduction strategies and reinforcing the link between
environmental and economic health.
EPA involvement
EPA has taken an active role in the development of the ISO 14000 standards. Following a
mandate from EPA Administrator Carol Browner, the Agency has established the EPA Stan-
dards Network, through which it tracks and participates in the work of TC-207. EPA’s
involvement with the ISO 14000 standards to date includes:
• Negotiating tougher pollution prevention requirements for ISO 14001 Environmen-
tal Management Systems Specification.
9/12 ISO 14001–5

• Evaluating ways in which implementation and adherence to ISO 14000 could be a

mitigating factor in an enforcement situation. For example, a company that had
implemented the standards but later found itself in violation of regulations could
possibly receive a reduced penalty because of its implementation of the standards.
• Experimenting with various, voluntary compliance scenarios, using ISO 14000 as a
starting point, in which participating organizations that successfully meet certain
minimum criteria would in exchange benefit from flexible, streamlined monitoring,
reporting and permitting requirements.
• Issuing the new Code of Environmental Management Principles (CEMP), which will
be implemented by federal agencies. In addition, private contractors for these agen-
cies will be encouraged to adopt these, or as an alternative, other management
systems, such as ISO 14000.
Relationship to ISO 9000

The ISO 9000 series of documents on quality management were first published less than a
decade ago. Since then, industries worldwide have invested time and money in bringing
their manufacturing and quality systems into conformance with the ISO documents.
Companies that have already implemented ISO 9000 will have a head start in the process of
implementing ISO 14000 because of the common elements shared by these standards,
including such areas as training, documentation, monitoring and measurement, and man-
agement review. Other important common points shared by the two standards are
similarities involving implementation and documentation.
For many companies, it is the cost-effective implementation synergies afforded by ISO 9000
certification that is compelling them to seek ISO 14000 certification. In addition, many com-
panies that are ISO 9000 certified and that are moving ahead with plans to become ISO
14000 certified view ISO 14000 as an extension of their overall quality management efforts.
State response
Many states, such as Pennsylvania, Texas, Wisconsin, and California, are considering allow-
ing progressive companies that have received ISO 14000 certification to operate under
streamlined regulatory requirements. By extending regulatory flexibility and reduced over-
sight to these kinds of organizations, states could then better allocate their resources by
shifting more funds and staff toward companies requiring stronger environmental measures
to come into compliance.
6–ISO 14001 9/12

Frequently asked questions

Q. What are ISO, ISO 14000, and ISO 14001?
A. ISO stands for the International Organization for Standardization, located in Geneva,
Switzerland. ISO promotes the development and implementation of voluntary interna-
tional standards, both for particular products and for environmental management issues.
ISO 14000 refers to a series of voluntary standards in the environmental field under
development by ISO. Included in the ISO 14000 series are the ISO 14001 EMS Standard
and other standards in fields such as environmental auditing, environmental performance
evaluation, environmental labeling, and life-cycle assessment. The EMS and auditing
standards are now final. The others are in various stages of development.
Q. How are these standards developed?
A. All the ISO standards are developed through a voluntary, consensus-based approach.
Each member country of ISO develops its position on the standards and these positions
are then negotiated with other member countries. Draft versions of the standards are
sent out for formal written comment and each country casts its official vote on the drafts
at the appropriate stage of the process. Within each country, various types of organiza-
tions can and do participate in the process including industry, government (Federal and
State), and other interested parties, including various government organizations (NGOs).
For example, EPA and States participated in the development of the ISO 14001 standard
and are now evaluating its usefulness through a variety of pilot projects.
Q. What must a community do to have an EMS that meets the ISO 14001 standard?
A. The ISO 14001 standard requires that a community or organization put in place and
implement a series of practices and procedures that, when taken together, result in an
environmental management system. ISO 14001 is not a technical standard and as such
does not in any way replace technical requirements embodied in statutes or regulations.
It also does not set prescribed standards of performance for organizations. The major
requirements of an EMS under ISO 14001 include:
• A policy statement which includes commitments to prevention of pollution, continual
improvement of the EMS leading to improvements in overall environmental perfor-
mance, and compliance with all applicable statutory and regulatory requirements.
• Identification of all aspects of the community organization’s activities, products, and
services that could have a significant impact on the environment, including those
that are not regulated.
• Setting performance objectives and targets for the management system which link
back to the three commitments established in the community or organization’s
policy (i.e. prevention of pollution, continual improvement, and compliance).
• Implementing the EMS to meet these objectives. This includes activities like train-
ing of employees, establishing work instructions and practices, and establishing the
actual metrics by which the objectives and targets will be measured.
• Establishing a program to periodically audit the operation of the EMS.
• Checking and taking corrective and preventive actions when deviations from the
EMS occur, including periodically evaluating the organization’s compliance with
applicable regulatory requirements.
9/12 ISO 14001–7

• Undertaking periodic reviews of the EMS by top management to ensure its con—
tinuing performance and making adjustments to it, as necessary.
Q. Is an EMS Under ISO 14001 Relevant to Communities?
A. Yes. Because ISO 14001 is essentially a system designed to help communities and other
types of organizations meet their environmental obligations and reduce the impact of
their operations on the environment, it is relevant to all types of organizations. Counties,
municipalities, towns, and townships typically oversee a number of separate facilities and
operations. EMSs can be used as a framework to help these operations improve their
environmental performance and make greater use of pollution prevention approaches.
Use of the standard by counties is not well established at this point, but some are begin-
ning to use it. For example, Washtenaw County, Michigan is implementing an EMS based
on 14001 for its Sheriff’s Department and participated in an earlier series of demonstra-
tion projects funded by EPA. EPA now wants to expand this approach and work with
additional counties and municipalities.
Q. What are some of the potential benefits of an EMS based on ISO 14001?
A.
• Improvements in overall environmental performance and compliance
• Provide a framework for using pollution prevention practices to meet EMS
objectives
• Increased efficiency and potential cost savings when managing environmental
obligations
• Promote predictability and consistency in managing environmental obligations
• More effective targeting of scarce environmental management resources
• Enhance public posture with outside stakeholders
Q. Can existing environmental management activities be integrated into the EMS
under 14001?
A. Yes. The standard is flexible and does not require organizations to necessarily “retool”
their existing activities. The standard establishes a management framework by which an
organizations’ impacts on the environment can be systematically identified and reduced.
For example, many organizations, including counties and municipalities, have active and
effective pollution prevention activities underway. These could be incorporated into the
overall EMS under ISO 14001.
Q. Why is the U.S. EPA interested in promoting and testing EMSs under ISO 14001?
A. Like a number of States, EPA believes EMSs, if implemented properly, could serve as a
valuable tool to help organizations improve their environmental performance, increase
the use of pollution prevention, and improve compliance. However, this premise needs to
be evaluated closely, working with a variety of organizations, including those in the pub-
lic sector. EMSs could, in the future, serve as the basis for providing regulatory flexibility
to organizations that successfully implement them.
8–ISO 14001 9/12

Q. How is the demonstration program for counties and municipalities actually

working?
A. EPA’s Office of Water and Office of Compliance are working with a non-profit organiza-
tion with expertise in EMSs and ISO 14001, to provide training and ongoing technical
assistance to counties and municipalities selected to participate in the demostration
projects. Participating organizations are also receiving a variety of written and electronic
materials to assist them as they put place their EMSs, using ISO 14001 as a baseline.
Periodic meetings of the participants will be held to compare progress, share and discuss
problems and issues, and gain greater understanding of specific parts of the 14001
standard. Between meetings, participants will receive assistance and advice on-line,
through additional written materials, and through other means as they put their EMS in
place.
The period of the demonstration program would be approximately 2 years concluding in
September 1999. EPA hopes that all participants will be able to have all of the elements
of an EMS in place at the end of this two year period. A final report on the project,
including short case studies on each participating organization will be prepared at the
end of the project and given to the participants. Finally, participating organizations will
be asked to collect and share common sets of data related to the establishment and
implementation of their EMS. EPA will work with the participants to reach agreement on
these data sets.
ISO 14001/Environmental Management Systems audit checklist
ISO 14001: Environmental Policy

Yes No N/A
1. Have you developed a statement/policy of your organization’s
commitment to the environment?
2. Is the policy simple and understandable? Related to your
products and services, as well as supporting activities?
3. Is the statement revised periodically to keep it current?
4. Do you use this statement as a framework for planning and

action?
5. Have you addressed the following issues: continual
improvement, pollution prevention, and compliance with
relevant laws and regulations?
6. Have you effectively communicated the environmental policy
to all employees and to the public?
9/12 ISO 14001–9

ISO 14001: Environmental Aspects

Yes No N/A
1. Have you identified environmental attributes of your products,
activities, and services?
2. Have you determined those that could have significant
impacts on the environment?
3. Have you documented a procedure for evaluating
environmental impacts?
ISO 14001: Legal and Other Requirements

Yes No N/A
1. Have you identified applicable rules and other requirements
and determined their impacts?
2. Have you communicated those rules to appropriate people
within your organization?
3. Have you established and documented a process for keeping
up-to-date?
ISO 14001: Objectives and Targets

Yes No N/A
1. Have you documented objectives and targets at relevant
functions and levels within the organization?
2. Are objectives and targets consistent with the environmental
policy (including commitments to pollution prevention,
continual improvement, and compliance)?
3. Are objectives and targets set by the people in the functional
area involved?
4. Are all objectives and targets realistic?
5. Have you ensured consistency with your business plan/

mission?
6. Has a process been established for tracking and reporting
progress?
ISO 14001: Environmental Management Program

Yes No N/A
1. Is there an action plan on how the organization will meet its
objectives and targets?
10–ISO 14001 9/12

2. Have you included responsibilities, means, and time frames?
3. Have you incorporated environmental concerns in your change

management process?
4. Do you communicate the plan and track progress internally?
5. Do you modify the program when (a) objectives and targets

are revised or added, (b) progress in achieving objectives and
targets is made — or not made, and (c) products, processes, or
facilities change?
6. Are employees involved early in establishing and carrying out
the program?
ISO 14001: Structure and Responsibility

Yes No N/A
1. Are roles for environmental management defined
2. Have the roles been communicated internally
3. Have resource needs been assessed
4. Has a management representative been designated?
5. Have you integrated environmental management with other

business functions wherever possible and practical?
ISO 14001: Training, Awareness, and Competence

Yes No N/A
1. Have training needs been identified?
2. Has a training plan been developed?
3. Have you provided required training at all levels?
4. Have training responsibilities been communicated?
5. Have you examined existing training methods to see if they

satisfy the requirements for an EMS?
6. Have you tracked and documented training?
9/12 ISO 14001–11

ISO 14001: Communication

Yes No N/A
1. Have processes been established for internal and external
communications on environmental management issues?
2. Have you determined who is responsible for responding to
external inquiries?
3. Have target audiences been identified?
4. Have you determined what the audiences’ concerns are?
5. Have you determined the proper communications methods for

each audience?
6. Are all communications clear, concise, and accurate?
ISO 14001: EMS Documentation

Yes No N/A
1. Have the environmental policy, organization, key procedures,
and other system elements been documented?
2. Does your Environmental Management Systems (EMS)
documentation contain descriptions of how your company
meets ISO 14001 requirements (e.g. how you identify
environmental aspects and conduct EMS Audits)?
3. Does the documentation provide direction to other related
documents (such as emergency response plans, and training
plans)?
4. Have you described where appropriate documents are located?
ISO 14001: Document Control

Yes No N/A
1. Have you developed a procedure to control EMS documents?
2. Have you established responsibilities and authorities for

document preparation, revision, management, and disposition?
12–ISO 14001 9/12

ISO 14001: Operation Control

Yes No N/A
1. Have you developed procedures to control key operations/
activities?
2. Trained employees on these procedures?
3. Have you covered normal operations, abnormal operations,

and emergencies?
ISO 14001: Emergency Preparedness and Response

Yes No N/A
1. Have operations been reviewed for potential emergency
situations?
2. Have plans/procedures been developed for managing these
situations?
3. Have you trained personnel and obtained any necessary
emergency equipment?
ISO 14001: Monitoring and Measurement

Yes No N/A
1. Have you identified key process characteristics and how to
measure/monitor them?
2. Has a process been set up to regularly evaluate (through
internal audits) compliance with laws and regulations?
3. Have you determined how to measure performance against
objectives and targets?
4. Have you established procedures to maintain and calibrate
key monitoring equipment?
ISO 14001: Nonconformance and Corrective and Preventive Action

Yes No N/A
1. Have you developed procedures for investigating, correcting,
and preventing system deficiencies?
2. Has a process been set up for assigning responsibilities for
and tracking completion of corrective actions?
3. Is there a process to revise procedures or other EMS
documents based on corrective/preventive actions?
9/12 ISO 14001–13

ISO 14001: Records

Yes No N/A
1. Have you identified records to be maintained?
2. Determined their retention times?
3. Set up a good storage retrieval system?
ISO 14001: EMS Audit

Yes No N/A
1. Have you developed an audit program?
2. Have you determined appropriate audit frequency?
3. Have you selected and trained EMS auditors?
4. Have EMS audits been conducted as described in the

program?
5. Do you have a process to keep records of these audits?
ISO 14001: Management Review

Yes No N/A
1. Have you established a process for periodic reviews of your
EMS?
2. Have results of such reviews been documented?
3. Have you followed up on action items to ensure closure?
ISO 14001: General

Yes No N/A
1. Have you established an environmental management system
(EMS) as described in ISO 14001?
2. Is the system maintained?
14–ISO 14001 9/12

Sustainability — a focus on the future

Sustainability is defined by the World Commission on Environment and Development as
“meeting the needs of the present without compromising the ability of future generations to
meet their own needs.”
Sustainability does not mean “no growth,” but instead considers the environmental impact of
every stage of development, whether on a national, local, or individual business level.
Sustainability looks at the interaction between environmental considerations and social and
financial impacts.
In addition, sustainability is a holistic concept, and not the same thing as “going green.”
While green ideas can be sustainable, they are usually only applied to the environmental or
health impacts of a single product rather than a system, which can include energy, transpor-
tation and logistics, waste and recycling, water, wastewater, and supplies.
Benefits of developing a sustainability program

EPA has identified 10 benefits of reducing your environmental impacts. They are:
1. Saving money from reduced waste and increased efficiency
2. Reducing concerns about health and safety liability
3. Improving public relations
4. Improving employee pride and morale
5. Attracting green consumers
6. Attracting motivated employees
7. Differentiating your business from competitors
8. Providing flexibility in uncertain times
9. Minimizing risk, financial and otherwise, from the impacts of climate change
10. Demonstrating leadership and commitment
3/13 Sustainability–1

What makes a company sustainable?

A sustainable business includes the following characteristics:
• Incorporates “green thinking” into the company culture
• Eliminates inefficiencies
• Minimizes its impact on the environment
• Streamlines its processes
• Thinks long-term
• Evolves and adapts to new information in a changing world
• Seeks continual improvement
Identify the key environmental issues

Areas where your company may impact the environment include water use, energy use, and
waste produced. Also, your processes may involve emissions of air pollutants, wastewater, or
stormwater runoff. Basically, anytime you use a resource, or anywhere you need to comply
with federal or state environmental regulations can be an area where you can apply prin-
ciples of sustainability.
Assess the impact

In order to avoid an abstract notion of “greenness” in sustainability, you’ll want to identify
achievable and measurable goals. For example, instead of saying your company wants to
reduce waste, you can set a realistic goal of reducing spent solvents by ten percent.
Also, you’ll want to estimate a realistic return-on-investment for undertaking a

sustainability project. Will becoming more sustainable improve your company’s image and
entice more customers to buy your product or use your services?
Discover opportunities
The growth in technology has the potential to help today’s businesses become more
sustainable. Areas technology can play a role include:
• Logistics and just-in-time deliveries;
• Virtual meetings; and
• Pollution reduction equipment.
Steps to sustainability
(adapted from EPA’s Smart Steps Greening Guide)
So what are the practical steps you can take to implement a sustainability program?
The 5-step strategy

This section presents a five-step strategy to help you create a more environmentally-
responsible company and lay the foundation for a sustainable future.
2–Sustainability 3/13

After completing the five step strategy to sustainability, how can you be sure you’ve achieved
success and are a more sustainable business? When:
• “Green thinking” is part of your company culture.
• Minimization of environmental impact is just the way business is done.
• Green is routine.
• You are committed to seeking a better way.
Here’s a quick overview of the five steps:
Step 1. Get ready helps you lay the groundwork for success.
Step 2. Get started helps you decide how green you want your business to be, select the
best approach to get there, and assess the impact your business has on the environment.
Step 3. Set goals helps you choose your greening goals and identify the actions to achieve
them.
4. Go green presents a discussion on what to keep in mind as you move forward.
5. Ensure continual improvement discusses how to make sure your company continues
to reduce its environmental impact and flourish at the same time. This final step includes
ideas for measuring progress and updating goals.
Step 1. Get Ready

Step 1 will help you:
• Assess your compliance.
• Engage your employees.
• Find support.
• Build your environmental knowledge.
• Plan appropriately.
Assess Your Compliance

Your first step would be to identify and meet any regulatory requirements. How embarrass-
ing to say you are a green company and then be hit with an environmental violation.
Knowing your regulatory requirements can also help you identify your environmental impact
and set goals that reduce the impact and regulatory liability.
Engage your employees

Sustainability may require a cultural shift for your company and that can only happen with
the support of your employees. Share your vision of what you want your business to become
with your employees, involve them up front, and ask for suggestions on how to green their
activities.
Employees may have great ideas on how to reduce environmental impacts and implement
your vision. They may recognize where waste and inefficiencies occur better than upper
management. For instance, the employees responsible for trash are probably the best source

for ideas on establishing a recycling program. You may find that some of your employees are
already familiar with greening strategies and even practice them at home or have experi-
ence from a previous job.
There are many ways to encourage employee participation. Depending on the size of your
business, consider creating a green team to head up sustainability initiatives. Provide
rewards for good ideas and incentives for environmentally-friendly behavior. Perhaps most
important, as the owner or manager, it is vital that you “walk the talk” and demonstrate
green behavior as an example to your employees.
Find support
There are many sustainable business organizations that can provide information on environ-
mental practices, partner to strengthen lobbying efforts, and create a network of green
product and service providers. If one does not exist in your area, consider partnering with
other small businesses that are going green and support each other with discounts and
advertising. Environmental committees and workgroups in trade associations and other
business organizations can also be helpful, and many local and state regulatory agencies
have initiatives to help small businesses go green.
Build your knowledge

Being familiar with environmental issues will help you understand the environmental
impact of your businesses and make better decisions for the future. You can start with the
resources in this guide and then build your knowledge by reading some of the many books,
articles, and websites on environmental issues. Your interests may range from environmen-
tal philosophy to technical information to finding out more about business and the
environment. The more informed you are, the easier it is to develop a successful strategy
and stay motivated.
You are not alone! Sustainable business support

The EPA offers a variety of voluntary programs to assist individuals, schools and businesses reduce
their consumption of resources and environmental impacts. The Office of Small Business Programs
provides a comprehensive list of EPA sustainability programs that can help save resources and
reduce utility costs. for the list, click on the OSBP Greening your Business, Partnership Programs
site at www.epa.gov/osbp/greening.htm.
National sustainability groups

There are many national groups devoted to sustainable business; some are focused on small
businesses and others on specific sectors. Conduct a web search for groups that fit your business
and interests.

State and local groups

There are many state and local sustainability groups with small business members. There are also
an increasing number of small business development centers and local Chambers of Commerce
that provide free assistance on greening. Conduct a web search or contact your state business
association for groups near you.
Plan appropriately
Like any business decision, careful planning can help you gain maximum success. If your
employees don’t share your vision or if you decide to roll out your greening plan during your
busiest time of the year, it’s going to be difficult to make progress. Be sure to allocate suffi-
cient resources to ensure success and include greening initiatives in your budget planning.
Step 2. Get Started

• Create a long-term vision of your sustainable business.
• Choose your approach to greening.
• Identify the environmental impacts of your business.
This step includes several forms that will help you plan strategically. Check the EPA website
at www.epa.gov/osbp/greening.htm to download forms that can be filled out electronically.
Define your green vision

A clearly defined vision of what you want your business to become will help you set goals,
motivate employees, and gain support from customers. What does sustainability mean to
you? What does an environmentally friendly version of your business look like? You may not
know the answers to these questions yet, but Step 2 will help your sustainable business
vision become a little clearer.
Look at the Environmental Performance Ruler below and think about where you want to
position your business. Do you want to pollute less and use fewer resources than companies
in the same sector? This will make you a greener than average company. Maybe you want to
be truly sustainable and move toward using only renewable resources, producing zero waste,
and advocating for greening your community. Use the Environmental Performance Ruler to
help guide your vision.

Environmental Performance Ruler
Environmental Performance Ruler
Worse Than Greener Than

Average Average Sustainable
Average
Higher energy costs High energy costs Low energy costs Renewable energy
Serious compliance and Some compliance and Few compliance and safety Minimal compliance
safety issues safety issues issues and safety issues
High environmental Potential environmental No or limited environmental No environmental liabilities
liabilities liabilities liabilities Viewed as a sustainability
Poor public perception Neutral to poor public High public perception on leader
on environment and perception on environment environment and Carbon neutral, primarily
sustainability and sustainability sustainability sustainable natural
May be involved in Big carbon footprint, non- Lower carbon footprint, resource use, zero waste,
litigation sustainable natural sustainable natural no pollution releases
Big carbon footprint, resource use, high waste, resource use, low waste,
non-sustainable natural and pollution releases low pollution releases
resource use, high waste,
and pollution releases
As you define your vision, consider how outside environmental issues, like regulatory
changes, will affect your business. For instance, if you are a dry cleaner, is your state likely
to follow California and phase-out perchloroethylene (PERC)? Is your local government get-
ting serious about enforcing stormwater rules? Also, think about marketplace trends. Are
your customers interested in greener companies or your corporate clients looking to green
their supply chain? Awareness of these issues will better inform your greening decisions. The
Environmental and Regulatory Issues Chart that follows will help you identify relevant out-
side issues.
A dry cleaner may fill the chart out like this:

Example Environmental and Regulatory Issues Chart
Environmental
and Potential Impact on Your Positive or Negative Level of Concern/ Time Period
Regulatory Company Likelihood
Issues
Climate change Not sure, depends on Don’t know Low/high Short for regs;
regulations long term for
env. changes
High Energy Higher costs Neg. Medium/medium Not sure
Price
New PERC phase out would Neg. – high initial cost High/not sure Need to find
regulations require new machines/ Positive – levels playing out more about
(including GHG approaches field, reduces env. liability, possible state
regulations) compliance & safety issues or federal
regulations and
timing.
Research
alternatives

Example Environmental and Regulatory Issues Chart, Continued

Environmental
and Potential Impact on Your Positive or Negative Level of Concern/ Time Period
Regulatory Company Likelihood
Issues
Market Greener consumers Depends on our response High/medium Current? Need
pressures to research
trends & look at
response of
competition
Here is a chart for you to fill out:

Environmental and Regulatory Issues Chart
Environmental and Potential Impact on Positive or Negative Level of Concern/ Time Period
Regulatory Issues Your Company Your Company Likelihood
Climate change
High Energy Prices
new regulations
(including GHG
regulations)
Market pressures
Now consider your motivations. What are the top reasons you want to go green? Knowing
what is driving your efforts will help you select goals, set priorities, and communicate your
vision. Perhaps most important, understanding your underlying motivations will help you
know when you have achieved your goals.
Putting It All Together Chart
Vision (where you want to be on the
Environmental Performance Ruler)
Top Environmental and Regulatory Issues of
Concern (in order of priority)
Motivators with highest importance
Write a sentence or two describing your vision
of sustainability and long-term objectives for
the business.
Approach formal EMS (ISO 14001 style)
Other formal approach ____________
Greening Guide steps
Ad hoc
Other _______________
You should now have a good idea of where you want to see your company in the long term,
the environmental issues that are likely to affect your company, and the internal values
driving your effort.

Choose your approach

A successful approach to greening can be simple or complex. Larger organizations may ben-
efit from a formal approach, while a smaller company can make major improvements with
informal policies or an ad hoc style. There are many approaches in between. What is impor-
tant is to select the approach that will help you reach your long-term objectives.
The Environmental Management System (EMS) is a widely used approach that provides a
formalized structure for planning and implementing a comprehensive environmental man-
agement program. Many companies, particularly large multi-nationals, certify their EMS
with the International Organization for Standardization (ISO). Certification provides cred-
ibility, and some companies require their suppliers to be ISO14001 certified. for more
information on EMS and ISO14001 visit www.epa.gov/OW-OWM.html/iso14001/index.htm.
An EMS, even an ISO-certified EMS, does not automatically make your company green or
sustainable.
There are other formalized approaches to greening. For example, EPA Region 9 used ele-
ments of The Natural Step framework to help identify and rank the environmental impacts
of their office. Greening can also be a part of another management approach such as lean, a
business methodology that streamlines manufacturing to eliminate waste and reduce cost
(www.epa.gov/lean). You may prefer a less formal approach. The steps in this guide provide
the same focus on strategic planning and continual improvement as an EMS, but are sim-
pler and less formal. If you decide to go with a formal EMS, you can still use the steps
presented here to help identify your impacts, objectives and targets.
Assess your impact

Once you know where you want to go, you need to understand the impact your business has
on the environment so that you can identify the actions with the greatest benefit for the
environment. You probably already have a good understanding of your largest impacts. Envi-
ronmental permits or regulations that apply to your business usually indicate areas of
environmental impact. For example, an air permit means that you are releasing air
pollution. Use the Environmental Impact Assessment Chart below to identify the environ-
mental impacts of your business, and evaluate the relative contribution of all your business
activities to your overall environmental impact.
Environmental Impact Assessment Chart—Instructions

This chart will help you identify the specific environmental impacts of your company. It
already includes information on impacts for common business functions. You need to custom-
ize it to reflect your company’s unique situation. The individual columns are described below.
1. Activity area – The chart is organized by functional area—transportation, office, ware-

house, manufacturing, business processes, and building and grounds. Business process refers
to non-manufacturing processes that are specific to your business like food preparation in a
restaurant, the working area of an auto repair shop, or a retail store’s sales operations. You
will need to customize the rows under Business Process to fit your business.
The links under sector-specific resources can help identify impacts from your specific
industry.

Environmental Impact quick reference

Air pollution—The release of harmful matter like particulates, and gases like sulfur dioxide,
nitrogen oxides, carbon monoxide, and volatile organic compounds into the air. Ozone, a harmful
air pollutant, is created by sunlight interacting with other air pollutants.
Erosion—The wearing away of soil. The increased flow of stormwater from impervious surfaces
like rooftops and pavement erodes land, scours stream banks, adds silt that carries contaminants
to water bodies and degrades habitat.
GHG emissions—The release of heat-trapping gases such as carbon dioxide, methane, and
nitrous oxide into the air. Greenhouse gases keep the earth warm, but increased concentrations
contribute to climate change.
Water pollution—Sewage, fertilizers, pesticides, oil, silt, and other pollutants that are discharged,
spilled or washed into water, including contaminants from air pollution that settle onto land and are
washed into water bodies.
Habitat loss—Loss and degradation of the natural conditions that animals and plants need to
survive. Caused by activities like development, deforestation, and contamination from stormwater
runoff and other pollution. It can occur directly from activities like road building, or indirectly, such
as contamination from vehicle exhaust.
Toxics—exhaust. Chemicals which pose a severe health risk such as chlorine, formaldehyde, and
dioxins. Toxics can be poisonous, cause cancer, and harm reproductive systems, and may be
present in pollution, manufacturing by-products, and chemical products like cleaning solvents.
Resource use—Using, extracting or harvesting natural and manufactured resources can deplete
ecosystems and destroy habitat. Associated activities like transportation and processing can cause
air and water pollution. Excessive withdrawal of water from lakes and rivers, or aquifers can
damage habitats by drying wetlands, creating low flow rivers, and stopping natural springs.
Hazardous waste—Waste that is considered toxic or flammable. Because it is strictly regulated,
there are formal regulatory definitions of hazardous waste.
Waste disposal—Removing and eliminating discarded materials. Disposal of non-toxic waste
material has environmental impacts from transportation, landfill space requirements, and leaching,
or incineration.
Energy use—The production and use of energy from fossil fuels like coal and petroleum creates
air pollution (carbon monoxide, carbon dioxide, and toxics like mercury and benzene) and hazard-
ous solid waste (from coal) and destroys habitat.
2. Environmental impacts: This column captures how each activity area can impact the
environment. Air and water pollution, waste, toxics, habitat loss, use of natural resources,
and GHGs are typical environmental impacts. Impacts can be direct, such as emissions from
the tailpipe of your delivery van, or indirect, such as GHG emissions from the power plant
that produces your electricity, or toxics released during the manufacturing of the bleached
white paper you purchase.
3. Impacts of your company: Describe, or if possible quantify, each activity’s impact at

your company. For example, under Paper use, list the main uses for paper in your company
and how much you use. You might enter “printing reports and invoices, two reams a day.”
Alternatively, under Delivery services, you might record “two gas-powered company vans
that drive about 100 miles a week with an average mileage of 20 miles per gallon (MPG).”

Permits or other regulatory requirements will tell you about some of these impacts. If pos-
sible, include costs. This information will help you set and evaluate goals so be as detailed
as possible.
4. Impact contribution: What is the relative contribution of each activity area to the over-
all environmental impact of your company? You may want to have a short description for the
contribution and then rate it as: very low, low, medium, high, or very high. Consider factors
such as:
• Volume or size (e.g., amount of trash generated, or number of miles driven by com-
pany vehicles).
• Toxicity (a very hazardous chemical versus a non-hazardous chemical).
• Direct releases to the environment (e.g., delivery truck exhaust, releases of an ozone
depleting substance, or discharge of industrial wastewater to the sewer).
• The potential for harm, either to employees or the environment (the high possibility
of gasoline spills from refueling a lawn mower, or asthma from air pollution from
diesel trucks).
• Indirect harm to the environment (air pollution from the generation of electricity or
the loss of habitat from road building).
• Frequency of an activity (e.g., pesticide applications probably occur infrequently,
business travel may occur frequently, and heating, ventilation, and air conditioning
(HVAC) use occurs very frequently).
Environmental Impact Assessment Chart
1. Activity Area 2. Environmental Impacts 3. Impacts of your 4. Impact Contribution

company
TRANSPORTATION
Employee commuting Air pollution
Energy use
GHG emissions
Habitat loss
Water pollution
Business travel Air pollution
GHG emissions
Energy use
Habitat loss
Water pollution
Shipping/receiving Air pollution
GHG emissions
Energy use
Resource use
Waste disposal
Water pollution
Delivery services/fleets Air pollution
GHG emissions
Energy use
Habitat loss
Water pollution

Environmental Impact Assessment Chart, Continued

company
OFFICE AREA
Paper use Air pollution
GHG emissions
Habitat loss
Resource use
Toxics
Waste disposal
Water pollution
Water use
Solid waste Air pollution
Energy use
GHG emissions
Waste disposal
Water pollution
Lighting Air pollution
Energy use
GHG emissions
Habitat loss
Toxics
HVAC Air pollution
Energy use
GHG emissions
Toxics
Water pollution
Water use
Other equipment (copiers, Air pollution
computers, etc.)
Energy use
GHG emissions
Habitat loss
Toxics
Water pollution
Water use Habitat loss
Resource use
Water pollution
Purchasing Air pollution
Resource use
Toxics
Waste disposal
Water pollution
Cleaning Air pollution
Resource use
Toxics
Waste disposal
Water pollution
Water use


company
MANUFACTURING
Paper use Air pollution
GHG emissions
Habitat loss
Resource use
Toxics
Waste disposal
Water pollution
Water use
Solid waste Air pollution
Energy use
GHG emissions
Waste disposal
Water pollution
Hazardous waste Air pollution
Toxics
Waste disposal
Water pollution
Lighting Air pollution
Energy use
GHG emissions
Habitat loss
Toxics
HVAC Air pollution
Energy use
GHG emissions
Toxics
Waste disposal
Water use
Resource use
Water pollution
Raw material Air pollution
GHG emissions
Resource use
Waste disposal
Toxics
Water pollution
Releases Air pollution
GHG emissions
Habitat loss
Water pollution


company
BUSINESS PROCESS
Meetings Energy use
GHG emissions
Resource use
Waste disposal
Other
BUILDING AND GROUNDS
Resource use
Water pollution
Mowing, leaf blowing, etc. Air pollution
Energy use
GHG emissions
Stormwater run off – roof Erosion
Habitat loss
Water pollution
Stormwater run off – paved Erosion
areas
Habitat loss
Water pollution
Pest control Habitat loss
Water pollution
Toxics
The government develops environmental regulations to ensure that the most significant
environmental impacts are monitored, controlled and minimized. If any of your business
activities require a permit, these activities most likely have a significant impact on the
environment. Explore EPA’s online compliance assistance resources for small businesses at
www.epa.gov/compliance/incentives/smallbusiness/index.html to better understand the regu-
lations that affect your industry, to make sure you are not violating any regulations, and to
identify impacts from your business.
There are industry-specific resources that will help you identify impacts. The web-based
Compliance Assistance Centers that EPA developed in partnership with third parties have
information on specific sectors such as construction, healthcare, and transportation (www.
epa.gov/compliance/assistance/centers/) and pollution prevention resources often include
information on environmental impacts (www.epa.gov/p2/pubs/p2rx.html). You can also check
with your local or state regulatory agency or trade association. Some voluntary environmen-
tal programs, like EPA’s WasteWise, also provide tools and information to help identify
environmental impacts.

Step 3. Set Goals

• Identify SMART goals.
• Select and prioritize goals that will help you reach your objectives.
• Define responsibilities.
A clear set of goals can turn the vision you developed in Step 2 into reality. The right goals
will help determine the future direction of your company, and motivate your employees. So
how do you choose the right goals? For starters, make sure your goals are SMART: specific,
measurable, actionable, relevant, and time-bound.
Specific. Perhaps you envision a carbon neutral company. This is a specific long-term goal.
To reach it, you will also need to set specific short-term goals. An initial short-term goal
could be to measure your GHG emissions to determine a starting point, and a subsequent
goal might be to reduce the company’s carbon footprint by 10 percent a year.
Measurable. If you can’t measure your goal, it is hard to know when it has been reached or
how to evaluate your efforts. Consider the difference between a goal to be a green company
and a goal to use 100 percent renewable energy. Without a precise definition, it is hard to
measure “greenness,” but the source of your energy is easy to measure.
Attainable. Your goals need to be ambitious enough to make a difference but not impossible
to achieve. The right balance will motivate your employees without discouraging them. You
may want to be a zero-emissions company within one year, but it is probably impractical. A
more realistic goal is to cut emissions by 20 percent in the first year with zero emissions as
a long-term goal.
Relevant. Your goals need to relate to what you are trying to achieve. Make sure that your
goals will meaningfully reduce your environmental impact and align with your vision.
Time-bound. Goals need to have a defined timeframe. A deadline provides incentive to take
action and move forward. Choose realistic timelines for your goals, and include milestones
and periodic assessments to measure your progress and stay motivated.
Select and prioritize goals

1. Review your long-term business objectives
Where do you want your business to be in five or ten years? Before deciding on your goals,
identify long-term business objectives to ensure that your goals will help you achieve your
vision. Review the Putting It All Together Chart from Step 2 and then write down several
long-term objectives. Be sure the objectives are specific and clear enough for others to
understand.
2. List goals and activities
Taking your long-term objectives into account, list all the sustainability goals you can think
of on a separate piece of paper, you will prioritize the goals in the next step. You may want
to first read through Section 3, Opportunities for ideas. Also discuss the goals with your
employees and review them against the SMART list to make sure you have goals that will
take you where you want to be.

Once you have identified goals, list the activities needed to reach the goal. The Environmen-
tal Impact Assessment Chart from Step 2 can help with this. for example, if your goal is to
reduce electricity use by 25 percent, you can use the chart to identify where you can get that
savings—from lighting, changing a business process to use less energy, or replacing old inef-
ficient appliances.
3. Prioritize
After listing sustainability goals and activities, focus on the ones that will help achieve your
vision for the future, that are based on your most significant environmental impacts, and
that will make the most sense for your business. Choose the goals that will address the
greatest impacts (see impacts from the Environmental Impact Assessment Chart) and where
you can make the biggest strides. For example,
• Do you run a retail store with piles of cardboard packing boxes leftover after a ship-
ment arrives?
Your goals may include working with vendors to find alternatives to cardboard pack-
ing boxes, such as reusable wooden crates, and asking vendors to minimize empty
truck moves and transportation of empty crates.
• Is your dry cleaning store using toxic chemicals?
Your goals may include exploring options to become a green cleaner or minimize the
amount used.
• Does your restaurant throw away large amounts of food waste daily?
Your goals may include donating or composting food waste.

Like any business decision, you need to consider the costs and benefits of your goals – finan-
cial and environmental. Evaluate your goals based on feasibility, payback period, financial
return on investment, and social return on investment. Think about how much money you
are willing to invest in sustainability measures, what changes you can afford to make, and
the effort that will be required from your employees. While it may not be easy to put an
exact dollar value on environmental benefits, it might help to think about prioritizing goals
in terms of the following grid:
You can use the benefit axis to consider benefits to your company or to the environment.
Obviously, a project that is low cost and high benefit for your company or the environment is
a good one to choose. But what about a project that is high cost and has a high benefit for
the environment, but a lower benefit for the company? This project may take more thought
before making a decision. Don’t automatically dismiss a goal because of the initial cost and
be sure to consider intangible benefits like customer perceptions and employee pride. Ana-
lyze the costs over time and factor in all the components, including the intangibles, before
making a final decision.
When setting priorities, consider which of the possible goals:

• Will make you the most competitive.
• Includes low-hanging fruit, like reducing or recycling office paper, that is important
and easy.
• Will have the biggest impact on the environment or on your bottom line, like install-
ing an on-site wind turbine.
• Contributes to the growth or longevity of your business.
• Has other benefits, like toxics reduction that also improves worker safety and
reduces compliance issues.
• Relate to your vision and long-term objectives.

Environmental Goals Chart

Goal 1
Timeframe Who Metric
Activities for Goal 1 Timeframe Who Metric

1.
2.
3.
4.
5.

Goal 2

1.
2.
3.
4.
5.

Goal 3

1.
2.
3.
4.
5.
Goal 4

1.
2.
3.
4.
5.


Goal 5

1.
2.
3.
4.
5.
Plan implementation
Once you know your goals, think about the activities that are needed to achieve the goals.
Then enter the activities in the Environmental Goal Chart. The chart also has space for the
timeframe /milestones for each activity, who will be responsible for implementation, and how
it will be measured. Clearly defining this information will help ensure that your goals are
achieved. Identifying employee responsibilities for implementing the actions is particularly
important. Consider including environmental performance in employee appraisals. Employ-
ees are more likely to make sustainability a priority if management makes it a priority and
performance reviews communicate this clearly.
Step 4. Go green
• Implement your greening strategy.
Turn your strategy into action

At this point, you are ready to turn your greening strategy into action. It’s your business,
and you and your employees know best how to make a strategy work. Steps 2 and 3 helped
you develop a vision and a plan, and now you just have to bring that plan to life.
Check to make sure your company goals are clearly translated into specific activities, that
the activities are reasonable, and that employees understand their responsibilities. Employ-
ees should also understand the company’s vision for sustainability, be aware of the
company’s greening goals, and be assigned responsibility for specific goals.
Leadership and communication are key to success. If greening your business means major
changes to the company culture, much of your success depends on managerial skill. As you
know, managers have to communicate effectively, “walk the talk,” and set a positive
example.
It’s important to reinforce responsibilities and green thinking on a regular basis. Educate
your employees on why greening is important, e-mail relevant online articles, leave environ-
mental magazines in the lunchroom, and talk about the underlying issues. Send out regular
e-mails or post signs reminding your team of the company’s green goals and vision for

sustainability. It is important to communicate progress toward goals so everyone can see

how their actions make a difference.
Step 5. Ensure continual improvement

• Measure progress.
• Develop a strategy for updating your goals.
• Become more sustainable over time.
Sustainability is an on-going commitment to reduce environmental impacts for the benefit of
future generations. The goal of Step 5 is to help your company continue to make progress
towards sustainability. This step will give you strategies for keeping your commitment going
and making your company greener every year.
Measure Progress
Step 5 checks to see if the strategy is working. Good measures will tell you if you’re moving
along the Environmental Performance Ruler in the right direction and are on track to reach
your goals. Measures will also help you evaluate your efforts so that you can keep doing
what works and change what is not effective. Seeing results will also help motivate you and
your employees.
There are different approaches to measurement. If you plan to participate in a program that
requires reporting to an external organization, it is important to have detailed information
and reliable metrics. If you don’t plan on external reporting, you still will want to know how
you are doing; you just don’t need to be as rigorous.
In selecting measures, focus on the outcomes of your initiatives, not just your activities. If
you have started a recycling program, measure the increase in materials recycled rather
than number of recycling bins. If energy efficiency is your focus, track the change in
kilowatt-hours rather than incandescent light bulbs replaced.
Stick to the milestones for activities you identified along with your goals in Step 3. By track-
ing progress along the way, you can make changes to correct your course early on. This is
particularly important for more ambitious goals such as reducing GHG emissions. By break-
ing down a large goal into manageable pieces, you can periodically measure your progress,
assess what’s working and what’s not, and make needed adjustments.
Communication
Communication, both top-down and bottom-up, is important for keeping momentum and
ensuring continual improvement. It is useful to get feedback from your employees. Ask them
about the impact of new environmental initiatives on their day-to-day work, whether new
initiatives are burdensome and if “green thinking” is being integrated into their daily
routine. Asking for this information and providing employees with feedback on their environ-
mental performance also communicates management’s interest and commitment to
sustainability.

Update goals and activities

Periodically reevaluate your goals and activities. If goals are being met or exceeded, consider
setting more stringent goals (and don’t forget to recognize your employees for getting you
there). If your team is not meeting the stated goals, try to determine the root cause. It may
be that your implementation strategy is not clear, staff responsibilities need to be redefined,
or perhaps the goals themselves are not realistic. Over time, greening activities should
become part of everyday work responsibilities. When this integration occurs, greening activi-
ties should be included in your Best Management Practices (BMPs) and standard operating
procedures or work instructions. You can then move on to create new greening activities.
Moving forward
Leadership and management support will remain crucial to the on-going success of your
sustainability initiatives. Continue to educate yourself and your employees about environ-
mental issues. Revisit your vision at least annually, and update your goals as your business
grows or changes. Encourage and empower your employees to always look for
environmentally-friendly ways to accomplish their jobs. Join voluntary programs to develop
and strengthen your greening efforts. Remember to include greening in all decisions and try
to anticipate the environmental impact of any new activities or decisions.
Continual improvement means being proactive, not reactive. Periodically refer back to Steps
1 and 2 and ask:
• Have we learned more?
• Has our vision changed?
• Are we satisfied with our progress?
Supply chain sustainability and greenhouse gas emissions

Supply chain management is how a business links its inputs with its outputs. It begins with
the procurement of raw materials, proceeds through transportation and delivery of the raw
materials and the manufacturing process, and ends with delivery of products and even the
return of those products. The growing costs of transportation, waste disposal, and other
environmental impacts are just a few of the challenges businesses face in their supply chain.
One of the most controversial, yet public, challenges companies face in their supply chain is
the “carbon footprint” of their goods or services, especially because supply chain emissions
can easily exceed a company’s individual operations. According to a 2010 EPA report, Man-
aging Supply Chain Greenhouse Gas Emissions, many leading companies are requiring their
suppliers to manage greenhouse gas (GHG) emissions. While some companies are asking
suppliers to report directly to them, others are using third-party reporting programs such as
the Global Reporting Initiative, the Climate Registry, and the Carbon Disclosure Project.
These third-party organizations provide tools to measure carbon outputs throughout a busi-
nesses’ entire supply chain and provide a way for leading companies to report their
sustainability efforts to a wide audience.

Measuring your carbon footprint

A carbon footprint has three components:
1. Direct emissions from onsite combustion and mobile sources. These are emissions
from sources a company owns or controls, such as natural gas-fired boilers or vehicle
fleets.
2. Indirect emissions from purchased electricity and steam. These are emissions that
are a consequence of the operations of the company, but occur at sources owned or
controlled by another company, such as electricity, heat, or steam.
3. Optional emissions including transport, employee business travel, and employee
commuting.
Also, many industrial sectors, such as pulp and paper, cement, chemicals, and iron and steel,
will have sector-specific emission sources. These industries can find additional help in calcu-
lating their carbon footprints at epa.gov/climateleaders/resources/sector-specific.html.
EPA has developed a system for a small business to calculate its carbon footprint. Find it at
www.epa.gov/climateleadership/smallbiz/footprint.html. Before you begin, you’ll want to:
• Set a starting and ending date (base year); and
• Identify your organizational boundaries.
For choosing your base year, collect data for a full calendar year of operations. The emis-
sions calculated from this data will then serve as the base year data. A recent year will
likely provide you with more meaningful, relevant data.
Organizational boundaries are used to determine which facilities or operations are included
in the GHG inventory. There are two approaches to setting boundaries: an equity share or a
control approach.
• Using an equity share approach, account for GHG emissions based on the company’s
share of equity (typically by percentage ownership) in a facility or operation.
• A control approach is divided into either financial or operational control:
❍ Under financial control, include operations for which the company has the abil-
ity to direct financial and operating policies with a view to gaining economic
benefits from those activities.
❍ Under operational control, include operations for which the company has full
authority to implement operating policies.
After you’ve completed your GHG calculations, EPA recommends you:
• Document your GHG inventory (your list of GHG emissions and sources);
• Create an inventory management plan;
• Set a greenhouse gas reduction goal; and
• Establish a procedure for tracking your progress.
There are three main steps to completing a GHG inventory. They are:
• Define: Determine the boundaries and emissions sources included within those
boundaries.

• Collect data: This step is typically the most time consuming, since the data can be
difficult to gather.
• Quantify: Calculate your emissions using an online calculator.
GHG calculations account for all six major GHGs: carbon dioxide, methane, nitrous oxide,
hydroflurocarbons, perfluorocarbons, and sulfur hexafluoride.
GHG emissions can come from any of the following sources at your organization or in your
supply chain:
• Stationary combustion
• Mobile sources
• Refrigeration and AC
• Fire Suppression
• Purchased Gases
• Waste gases
• Electricity
• Steam
• Business travel
• Commuting
• Product transport
You can choose from a number of free online carbon footprint calculators to help you deter-
mine the size of your greenhouse gas emissions. See the table below for a list of third-party
reporting programs and GHG measuring tools.
Website URL Description

Sustainable Supply www.data.gov/communities/ An interactive community for sharing and discussion sustain-
Chain Community of supplychain able supply chains- including tools and best practices for
Practice engaging and training suppliers, and opportunities for devel-
oping industry-specific codes of conduct.
GHG/Carbon Footprint www.epa.gov/ A tutorial, developed by EPA, and the Simplified Greenhouse
Tools for Small Busi- climateleadership/smallbiz/ Gas (GHG) Emissions Calculator for developing a GHG
ness footprint.html inventory and management plan.
Green Suppliers Net- www.greensuppliers.gov/ Voluntary, on-site, in-person reviews to help small and
work index.html medium manufacturing companies assess and reduce GHG
emissions, energy use, water use and other drivers of excess
costs and environmental impacts. A collaboration between the
EPA and the U.S. Department of Commerce, the Network was
established to help small and medium-sized manufacturers
stay competitive and profitable, while reducing their impact on
the environment.
Guidelines for Energy www.energystar.gov/index. An EPA strategy for energy management with tools and
Management cfm?c=guidelines. resources to help each step of the way. Based on the suc-
guidelines_index cessful practices of ENERGY STAR partners, these
guidelines for energy management can assist your organiza-
tion in improving its energy and financial performance.
Green Power Locator apps3.eere.energy.gov/ In many areas, green power options are available directly
greenpower/buying/buying_ through your local utility. This Department of Energy tool
power.shtml helps locate providers of renewable electricity by state.

Climate Change Adap- www.fedcenter.gov/ This page provides a framework and guidance to understand-
tation programs/climate/ ing and planning for climate-related risks and opportunities.
Carbon Disclosure https//www.cdproject.net/en- An independent not-for-profit organization providing a global
Project US/Pages/HomePage.aspx system for companies to measure, disclose, manage, and
share environmental information.
The Climate Registry www.theclimateregistry.org A nonprofit collaboration among North American states, prov-
inces, territories and tribes that sets consistent and
transparent standards to calculate, verify, and publicly report
GHG emissions into a single registry.
GHG Protocol www.ghgprotocol.org/ An international accounting tool for government and business
leaders to understand, quantify, and manage GHG emissions.
It provides the accounting framework for nearly every GHG
standard and program in the world.
Global Reporting Initia- https://www.globalreporting. A non-profit organization that provides sustainability reporting
tive org/Pages/default.aspx guidance and maintains a database of sustainability reports.
GRI has pioneered and developed a comprehensive
Sustainability Reporting Framework that is widely used
around the world.
Federal supply chain

In 2009, the Executive Order on Federal Leadership in Environmental, Energy, and Eco-
nomic Performance called on federal agencies to set and meet specific sustainability-related
targets. In response, The U.S. General Services Administration (GSA), the federal govern-
ment’s procurement office, implemented a sustainable procurement program.
GSA partnered with EPA and the Department of Defense to incorporate a contractor’s green-
house gas (GHG) emissions in the federal procurement process to make the government’s
supply chain more sustainable.
In June 2010, a GSA working group issued a report, “Recommendations for Vendor and Con-
tractor Emissions,” stating that sustainability considerations, especially GHG emissions
data, should be used in the procurement process. Further, GSA set up the Federal Supply
Chain Emissions Program Management Office. This office runs the Sustainability in Pro-
curement Fellowship program, the Sustainable Supply Chain Community of Practice on
www.data.gov, and the Use of Vendor and Contractor GHG Emissions Considerations in Pro-
curements Initiative, and the Small Business Greenhouse Gas Emissions Inventory Pilot.
These programs could affect your business if you contract with the federal government.
EPA and sustainable materials management

EPA has developed a system it calls sustainable material management (SMM), which it
defines as an approach to serving human needs by using and reusing resources most produc-
tively and sustainably throughout their life cycles, from the point of resource extraction
through material disposal. This approach seeks to minimize the amount of materials
involved and all the associated environmental impacts, as well as account for economic effi-
ciency and social considerations.
EPA says it is advancing SMM by providing sound science and information to the public and
establishing challenges to specific sectors to achieve shared goals.
The agency has issued sustainability challenges to federal agencies, the food industry, and
the electronics industry.

Other EPA programs in the SMM include:

• Sustainable financing for municipal recycling examines options on sustainable
financing for municipal recycling programs with an initial focus on packaging;
• WasteWise promotes the prevention and recycling of municipal solid waste and select
industrial materials;
• Re-Trac tracks an organizations’ waste generation and reduction activities; and
• SMM Web Academy presents key sustainability issues, successful projects, and best
management practices for creating effective waste management programs.
According to EPA, SMM represents a change in how society thinks about the use of natural
resources and environmental protection. By examining how materials are used throughout
their lifecycles, an SMM approach seeks to:
• Use materials in the most productive way with an emphasis on using less;
• Reduce toxic chemicals and environmental impacts throughout the material life
cycle;
• Assure sufficient resources to meet today’s needs and those of the future.
The lifecycle approach to materials management

How society uses materials is fundamental to our economic and environmental future.
Global competition for finite resources will intensify as world population and economies
grow. More productive and less impactful use of materials helps society remain economically
competitive, contributes to prosperity, and protects the environment in a resource-
constrained future.
Both U.S. and global consumption of materials has been increasing rapidly. People have con-
sumed more resources in the last 50 years than all previous history. And of all the materials
consumed in the U.S. over the last 100 years, more than half were consumed in the last 25
years. This increasing consumption has come at a cost to the environment, including habitat
destruction, biodiversity loss, overly stressed fisheries and desertification. Materials con-
sumption is also associated with an estimated 42 percent of total U.S. greenhouse gas
emissions. Failure to find more productive and sustainable ways to extract, use, and manage
materials, and change the relationship between material consumption and growth, has
grave implications for our economy and society.
By looking at a product’s entire lifecycle, we can find new opportunities to reduce environ-
mental impacts, conserve resources, and reduce costs. For example, a product is re-designed
so it is manufactured using different, fewer, less toxic and more durable materials. It is
designed so that at the end of its useful life it can be readily disassembled. The manufac-
turer maintains a relationship with the customer to ensure best use of the product, its
maintenance and return at end-of-life. This helps the manufacturer identify changing needs
of their customers, create customer loyalty, and reduce material supply risk. Further, the
manufacturer has a similar relationship with its supply chain, which helps the manufac-
turer respond more quickly to changing demands, including reducing supply chain
environmental impacts.

A Lifecycle Perspective
Materials have environmental impacts throughout their lifecycles. The major stages in a
material’s lifecycle are raw material acquisition, materials manufacture, production, use/
reuse/maintenance, and waste management.
Applying a life cycle perspective can help identify opportunities and lead to sustainable solu-
tions that help improve environmental performance, societal image, and economic benefits.
Businesses do not always consider their supply chains or the use and end-of-life processes
associated with their products. Government actions often focus on a specific country or
region, and not on the impacts or benefits that can occur in other regions or that are attrib-
utable to their own levels of consumption. Currently, EPA is researching lifecycle
perspectives in the following areas of application:
• Nanotechnology
• The Li-ion Battery Project
• Biofuels
• Consumer Products
• Impact Assessment
• Emergy Analysis (Note: Emergy is a measure of all the direct and indirect energy of
the material, services, and information required to make a product or sustain a
system.)
• Sustainable Materials Management

Green building
Green building is the practice of creating structures and using processes that are environ-
mentally responsible and resource-efficient throughout a building’s lifecycle from siting to
design, construction, operation, maintenance, renovation and deconstruction. This practice
expands and complements the classical building design concerns of economy, utility, durabil-
ity, and comfort. Green building is also known as a sustainable or high performance
building.
Impacts of the Built Environment
Aspects of built Consumption: Environmental effects: Ultimate effects:
environment:
Siting Energy Waste Harm to health
Design Water Air pollution Environment degradation
Construction Materials Water pollution Loss of resources
Operation Natural resources Indoor pollution
Maintenance Heat islands
Renovation Stormwater runoff
Deconstruction Noise
Green buildings are designed to reduce the overall impact of the built environment on
human health and the natural environment by:
• Efficiently using energy, water, and other resources
• Protecting occupant health and improving employee productivity
• Reducing waste, pollution and environmental degradation
For example, green buildings may incorporate sustainable materials in their construction
(e.g., reused, recycled-content, or made from renewable resources); create healthy indoor
environments with minimal pollutants (e.g., reduced product emissions); and/or feature land-
scaping that reduces water usage (e.g., by using native plants that survive without extra
watering).
On the federal level, the Energy Policy Act of 2005 and the Energy Independence and Secu-
rity Act of 2007 included energy efficiency and sustainable design requirements for federal
and other buildings. Additionally, there have been a series of Executive Orders and agency-
specific rules promoting green building since the early 1990s and the federal government
has instituted sustainable practices at many of its buildings. The Federal Commitment to
Green Building: Experiences and Expectations (PDF) (89 pp, 2.1 MB, About PDF), a report
from the Office of the Federal Environmental Executive, provides a history of these rules
and the greening of federal facilities.
Many state and local governments also have green building laws, mainly applying to public
buildings, though an increasing number are applicable to private buildings as well. Two
third-party organizations maintain lists of green building legislation:
• American Institute of Architects’ State Legislation Tracking:
www.aia.org/adv_st_legislativetracking
• U.S. Green Building Council’s Leadership in Energy and Environmental Design
(LEED) www.usgbc.org/DisplayPage.aspx?CMSPageID=1496

There are many voluntary consensus-based standards organizations are developing stan-
dards for green buildings. The two main recognized standards in the U.S. are:
• ASTM International’s Technical Subcommittee E06.71 on Sustainability and Perfor-
mance of Buildings has developed several green building standards.
• The American Society for Heating, Refrigeration and Air Conditioning Engineers
(ASHRAE) is partnered with the U.S. Green Building Council (USGBC) and Illumi-
nating Engineering Society of North American (IESNA) to develop Standard 189,
Standard for the Design of High-Performance Green Buildings Except Low-Rise
Residential Buildings.
Waste minimization
Reducing, reusing, and eliminating waste is a major component of corporate sustainability.
All organizations generate waste. Waste can range from food wrappers, to fluorescent lamps,
to ink cartridges, to cardboard boxes . . . the list is endless.
Under the Resource Conservation and Recovery Act (RCRA), facilities that generate or man-
age hazardous waste must certify that they have a waste minimization program in place
that reduces the quantity and toxicity of hazardous waste generated to the extent economi-
cally practicable.
A waste minimization plan can help your company meet goals for sustainability — even if
your operations do not generate hazardous waste. Even better, pollution prevention plans
can identify areas to reduce or eliminate waste at the source.
Waste Minimization refers to the use of source reduction and/or environmentally sound
recycling methods prior to energy recovery, treatment, or disposal of wastes. Waste minimi-
zation does not include waste treatment, that is, any process designed to change the
physical, chemical, or biological composition of waste streams. For example, compacting,
neutralizing, diluting, and incineration are not typically considered waste minimization
practices. A sound hierarchical approach to materials management includes source reduc-
tion, recycling, energy recovery, treatment, and finally, disposal.
Source reduction, commonly known as pollution prevention, reduces or eliminates the
generation of waste at the source and refers to any practice that reduces the use of hazard-
ous materials in production processes.
Common examples of source reduction include:
• Early retirement of equipment such as mercury-containing devices like switches and
thermostats;
• Reformulating or redesigning products, such as creating new PVC compounds with-
out using lead;
• Using less toxic feedstocks, such as switching to the use of lead-free solder in
manufacturing;
• Improving work practices, such as reorganizing paint batches in order to reduce
cleaning operations.

Recycling, or reclaiming value from production by-products, can often be used when source
reduction is not economically practical. Recycling includes the reuse or recovery of in-process
materials or materials generated as by-products that can be processed further on-site or sent
offsite to reclaim value. Recycling is a broad term that encompasses the reuse of materials
in original or changed forms rather than discarding them as wastes. Recycling can also be
thought of as the collection and reprocessing of a resource so it can be used again, though
not necessarily for its original purpose.
Examples of recycling include:
• Direct use/reuse of a waste in a process to make a product, such as reusing a purge
product used to clean paint lines rather than disposing of it by incineration.
• Processing the waste to recover or regenerate a usable product, such as collecting
vapor from dry cleaning operations, turning it back into liquid, and reusing the liq-
uid to clean more clothes.
• Using/reusing waste as a substitute for a commercial product. When mercury is
recycled from old equipment like switches, it can be used in new products that still
require mercury, such as fluorescent bulbs. Recycling of mercury has been so suc-
cessful that there is now enough recycled mercury in the U.S. that manufacturers
do not need to use new mercury from mines.
A material is “recovered” if it is processed to recover a usable product, or if it is regenerated.
This is known as materials recovery. In energy recovery, waste is converted into usable fuel.
Benefits of Waste Minimization

Waste minimization not only protects the environment, it also makes good economic and
business sense. For example, reducing waste generation through waste minimization has
helped some companies change their RCRA regulatory status from large quantity generator
(1000 or more kilograms of hazardous waste generated per month) to small quantity genera-
tor (between 100 and 1000 kg of hazardous waste generated per month), or to conditionally
exempt small quantity generator (up to 100 kg of hazardous waste generated per month).
Some have managed to eliminate the generation of hazardous waste and avoid RCRA regula-
tory requirements altogether.
Source reduction and/or environmentally sound recycling, reuse, and reclamation practices
have helped many organizations reduce:
• The quantity and toxicity of hazardous and solid waste generation
• Raw material and product losses
• Raw material purchase costs
• Waste management recordkeeping and paperwork burden
• Waste management costs
• Workplace accidents and worker exposure
• Compliance violations
• Environmental liability

At the same time, waste minimization can improve:

• Production efficiency
• Profits
• Good neighbor image
• Product quality
• Environmental performance
• Chemical waste
Waste minimization, particularly recycling activities, may also allow you to meet less strin-
gent requirements in RCRA. Always check with your state and local environmental agencies
to be sure you are in compliance with the regulations. Also, refer to the chapter on Waste in
this book for more information.

Reserved

STATE INFORMATION
CONTENTS
State contacts ................................................................................................... 1
9/12 State information TOC–1

Reserved
2–State information TOC 9/12

State contacts
Most environmental programs are implemented on the state level. States are required to
have regulations that are at least as strict as the federal regulations – but they may be
more stringent and cover more industries than the federal. While we have endeavored to
include the most up-to-date information from the states in this book, it would be impossible
to include every state regulation. Make use of the listed state contacts to be sure you are in
full compliance with your state laws.
Alabama
Alabama Department of Environmental Management (ADEM)
Montgomery Office
1400 Coliseum Boulevard
Montgomery, AL 36110-2400
P.O. Box 301463
Birmingham Field Office
110 Vulcan Road
Birmingham, AL 35209
(205) 942-6168
Mobile Central Field Office
2204 Perimeter Road
Mobile, AL 36615
(251) 450-3400
Central Laboratory/Field Operations
1350 Coliseum Boulevard
9/12 State information–1

Decatur Field Office

2715 Sandlin Road , S.W.
Decatur, AL 35603
(256) 353-1713
Mobile Coastal Field Office
4171 Commanders Drive
Mobile, AL 36615
(251) 432-6533
Air
Alabama Department of Environmental Management Air Division
P.O. Box 301463
Phone: (334) 271-7861
Website: www.adem.state.al.us/
Water
Alabama Department of Environmental Management Water Division
Phone: (334) 271-7823
Website: www.adem.state.al.us/
Stormwater/NPDES permitting information: adem.alabama.gov/programs/water/
permitting.cnt
Spill Information
Hazardous materials emergency (800) 843-0699
Manifest Information
If submittal of a copy of the Hazardous Waste Manifest is required through Treatment,
Storage, or Disposal facility requirements or by Alabama Hazardous Wastes
Management and Minimization Act (AHWMMA) Permit, please submit to the following
address:
Alabama Department of Environmental Management Waste Programs Branch
P.O. Box 301463
At this time there are no state-specific waste code requirements.
The Alabama information contact regarding state manifest requirements is:
Brad Curvin — Industrial Hazardous Waste Branch AL DEM
P.O. Box 301463
Phone: (334) 271-7744
Storage Tanks
Aboveground storage tanks (ASTs) and Underground Storage tanks (USTs)
ADEM Attn: Groundwater Branch
P.O. Box 301463
Phone: (334) 270-5655
Website: adem.alabama.gov/programs/water/groundwater.cnt
Operator training information: www.adem.state.al.us/programs/water/waterforms/
USTOperatorProgramMemo.pdf
2–State information 9/12

Emergency Planning/ Community Right to Know

Section 313 (Form R submissions)
Kirk Chandler
Alabama Department of Environmental Management
Alabama Emergency Response Commission
P.O. Box 301463
Phone: (334) 271-7700
Email: kfc@adem.state.al.us
Tier I/Tier II reporting
Alabama requires the use of a federal Tier II form and is requesting facilities submit
electronically. Website: www.adem.state.al.us/moreInfo/saraIII.cnt
HazCom
Alabama follows federal OSHA safety and health program requirements.
Alabama Department of Labor
RSA Union, 6th Floor, PO Box 303500
Phone: 334-242-3460
Website: www.alalabor.state.al.us/ or www.state.al.us/.
Transportation
Alabama Department of Transportation
P.O. Box 303050
Montgomery, Alabama 36130-3050
ALDOT Office of Environmental Coordination
Website: stronge@dot.state.al.us
Alabama Department of Public Safety Highway Patrol Division Motor Carrier Safety
Unit
Phone: (334) 242–4395
Website: www.dps.state.al.us/
Alaska
Alaska Department of Environmental Conservation
P.O. Box 111800
410 Willoughby Ave., Ste. 303
Juneau, AK 99811-1800
Phone: 907-465-5066
Website: dec.alaska.gov/
Air
ADEC Division of Air Quality
Anchorage Office
619 E. Ship Creek, Ste. 249
Anchorage, AK 99501
Phone: (907) 269-7577

ADEC Division of Air Quality

Juneau Office
410 Willoughby Avenue, Suite 303
P.O. Box 111800
Juneau, AK 99811-1800
Phone: (907) 465-5100
Website: www.state.ak.us/dec/air/
Water
ADEC Division of Water Quality
Anchorage Office,
555 Cordova St.
Anchorage, AK 99501-2617
Phone: (907) 269-7601
ADEC Juneau Office
P.O. Box 111800
Juneau, AK 99811-1800
Phone: (907) 465-5143
ADEC Fairbanks Office
610 University Dr.
Fairbanks, AK 99709-3643
Phone: (907) 451-2726
Website: www.state.ak.us/dec/water/
Stormwater/NPDES permitting information:
Jim Rypkema, Storm Water and Wetlands Manager
Division of Water - Alaska Department of Environmental Conservation
555 Cordova Street
Anchorage, AK 99501
Telephone: 907-334-2288
Email: jim.rypkema@alaska.gov
Website: www.dec.alaska.gov/water/wnpspc/stormwater/index.htm
Solid Waste
Alaska Department of Environmental Conservation
Division of Environmental Health
Solid Waste Program
555 Cordova St.
Anchorage, Alaska 99501-2617
Phone: (907) 269-7802
Website: www.dec.state.ak.us/eh/sw/index.htm
Hazardous Waste
Alaska Division of Environmental Health
Solid Waste Program
Compliance Assistance Office
555 Cordova Street
Anchorage, Alaska 99501
Phone: (907) 269-7590
Website: www.dec.state.ak.us/spar/csp/

Spill information:
During normal business hours, contact the nearest DEC Response Team:
Anchorage: (907) 269-3063
Juneau: (907) 465-5340
After hours: (800) 478-9300
Use the federal Uniform Hazardous Waste Manifest form. For more information, contact
Diane Richardson.
Phone: (907) 271-6329
Storage Tanks
Underground storage tanks (USTs):
Department of Environmental Conservation
AK Division of Spill Prevention and Response
410 Willoughby Ave.
Ste. 302 P.O. Box 111800
Juneau, AK 99811-1800
UST Manager: Larry Brinkerhoff
(907) 269-3055
Website: dec.alaska.gov/spar/ipp/tanks.htm
Operator training information: dec.alaska.gov/spar/ipp/ust/training.htm
Aboveground storage tanks (ASTs):
AK Department of Environmental Conservation
Storage Tank Program 555 Cordova Anchorage, AK 99501
Website: www.state.ak.us/dec/spar/ipp/tanks.htm
Emergency Planning/Community Right to Know
Section 313 (Form R Submissions)
Department of Environmental Conservation
Division of Spill Prevention and Response
P.O. Box 111800
Juneau, AK 99811-1800
Phone: (907) 465-5250
E-mail: email: Camille.Stephens@alaska.gov
Website: dec.alaska.gov
Tier I/Tier II Reporting:
Alaska requires the use of an Alaska Tier II form (available on the Website listed above),
except in Anchorage where local ordinance prevails.www.dec.state.ak.us/divs_contacts/
index.htm#spar.
HazCom
Alaska incorporates by reference the federal regulations for hazard communication
(HAZCOM); however, the state adds further requirements. Find more at www.legis.state.
ak.us/basis/folioproxy.asp?url=http://wwwjnu01.legis.state.ak.us/cgi-bin/folioisa.dll/aac.

Transportation
AK Department of Transportation
Department of Transportation & Public Facilities PO Box 112500 3132 Channel Drive
Juneau, Alaska 99811-2500 Phone: 907-465-3900
AK Department of Transportation & Public Facilities
Division of Measurement Standards and Commercial Vehicle Enforcement
Phone: 907/345-7750
Website: www.dot.state.ak.us/
Arizona
Arizona Department of Environmental Quality
1110 West Washington Street
Phoenix, Arizona 85007
Phone: (602) 771-2300
Toll-free: (800) 234-5677 -
TDD: (602) 771-4829
Southern Regional Office (SRO)
400 West Congress Street, Suite 433
Tucson, Arizona 85701
Phone: (520) 628-6733
Toll-free: (888) 271-9302
Website: www.azdeq.gov/index.html
Air
ADEQ Air Quality Division
1110 W. Washington St.
Mail Code 3415 A-3
Phone: (602) 771-2308
Website: www.azdeq.gov/environ/air/index.html
Water
ADEQ Water Quality Division
Phone: (602) 771-2303 or (602) 771-4416
Website: www.azdeq.gov/environ/water/index.html
Stormwater/ NPDES permitting information: Call (602) 771-4449 or (602) 771-4376 or
visit www.azdeq.gov/environ/water/permits/index.html.
Solid Waste
Waste Program Division
Phone: (602) 771-2300
Northern Regional Office:
1801 W. Route 66, Suite 117
Flagstaff, AZ 86001
Phone: (928) 779-0313

Southern Regional Office:

400 W. Congress, Suite 433
Tucson, AZ 85701
Phone: (520) 628-6733
Website: www.azdeq.gov/environ/waste/solid/index.html
Hazardous Waste
Waste Program Division
Inspections and Compliance Section
Mail code 4415A-2
Phone: (602) 771-4673
Website: www.azdeq.gov/environ/waste/hazwaste/index.html
Spill information:
To report spills, call (602) 771-2330 or (800) 234-5677 ext. 2330 (in-state toll free).
Use the federal Uniform Hazardous Waste Manifest form
For more information, contact: David Alamillo
Phone: (602) 771-4743
Phone: (907) 271-6329
Storage Tanks
Arizona has not yet obtained approval from EPA to run its own UST/LUST program in
place of the federal program.
ADEC Waste Programs Division Underground Storage Tank Section 1110 W. Washington
St. Phoenix, Arizona 85007
Phone: (602) 771-4255
Website: www.azdeq.gov/index.html
Operator training information: www.azdeq.gov/environ/waste/ust/download/brochure/
op_train_guide_ust.pdf
Aboveground storage tanks
ADEQ dos not regulate the installation, operation, maintenance or closure of ASTs.
There are situations where ASTs may be regulated. For instance, if a drywell drains an
area that includes an AST, you may need to obtain a permit from ADEQ.
Mark Howard
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix, Arizona 85008-3495
Phone: (602) 231-6346
Email: mark.howard@azdema.gov AND
Bill Quinn
Arizona Department of Environmental Quality
Pollution Prevention Unit Manager
Mail Stop 4415 A-1
Phoenix, AZ 85007
Phone: (602) 771-2955


Mark Howard
Arizona Emergency Response Commission 5636 East McDowell Road Phoenix, Arizona
85008-3495
Phone: (602) 231-6346
Email: mark.howard@azdema.gov
Website: http://www.azserc.org/
Arizona requires the use of a state Tier II form. The Commission and the Pollution
Prevention Unit will both accept Tier II forms electronically.
HazCom
Arizona follows the federal requirements for hazard communications.
Industrial Commission of Arizona
800 West Washington
Phoenix, AZ 85007-2922
Phone: 602-542-5795
Website: www.ica.state.az.us/
Transportation
AZ Department of Transportation
Mail Drop 555M Motor Vehicle Division
PO Box 2100
Phoenix AZ 85001-2100
Toll-free: (800) 251-5866
Website: www.azdot.gov/
Arkansas
Arkansas Department of Environmental Quality
5301 Northshore Drive
North Little Rock, AR 72118-5317
ADEQ Helpline: (501) 682-0923
Website: www.adeq.state.ar.us/
Contact page: www.adeq.state.ar.us/home/topic_index.asp
Air
Air Division
Mailing Address:
P.O. Box 8913
Little Rock, AR 72219-8913
Phone: (501) 682-0730
Website: www.adeq.state.ar.us/air/default.htm
Water
Water Division
North little Rock, AR 72118-5317
Phone: (501) 682-0655
Website: http://www.adeq.state.ar.us/water/default.htm

Stormwater/NPDES permitting information: For information on NPDES permitting and

stormwater in Arkansas, contact the NPDES Branch at (501) 682-0616, or visit: www.
adeq.state.ar.us/water/ for permits, or www.adeq.state.ar.us/water/ for storm water
information.
Solid Waste
Solid Waste Management Division
Phone: (501) 682-0600
Website: www.adeq.state.ar.us/solwaste/default.htm
Hazardous Waste
AR Department of Environmental Quality
Hazardous Waste Division
Mailing Address:
P.O. Box 8913
Phone: (501) 682-0833
Website: www.adeq.state.ar.us/hazwaste/default.htm
Spill information
Contact the Arkansas Department of Emergency Management at (800) 322-4012.
Use the federal Uniform Hazardous Waste Manifest form. Arkansas does not require
submission of the state copy of the manifest to ADEQ. Arkansas does not have state-
specific waste codes.
Website: www.adeq.state.ar.us/hazwaste/ .
Storage Tanks
Aboveground storage tanks (ASTs) and Underground storage tanks (USTs)
Regulated Storage Tanks Division
Mailing Address:
P.O. Box 8913
Phone: (501) 682-0988
Arkansas Office of Emergency Services
North Little Rock, Arkansas 72118-5317
Phone: (501) 682-0833
Arkansas requires the use of a state Tier II form. There is a fee for filing.
Phone: (501) 682-0833

HazCom
Arkansas follows the federal OSHA safety and health program requirements for hazard
communication.
Transportation
Arkansas State Highway and Transportation Department
10323 Interstate 30,
Little Rock, AR 72209
California
Cal/EPA
Joe Serna Jr. Cal/EPA Headquarters Building
1001 I Street
P.O. Box 2815
Sacramento, CA 95812-2815
Phone: (916) 323-2514
Website: www.calepa.ca.gov/
Air
CA Air Resources Board (CARB)
1001 I Street
Sacramento, CA 95812
Phone: (916) 322-2990
Website: www.arb.ca.gov/homepage.htm
Water
State Water Resources Control Board
1001 I Street
Sacramento, California 95814
Phone: (916) 341-5250
Website: http://www.swrcb.ca.gov/
Stormwater/NPDES permitting information: For information on California’s storm water
requirements, visit www.waterboards.ca.gov/water_issues/programs/stormwater/ or call
toll-free (866) 563-3107.
Solid Waste
Cal/EPA
Integrated Waste Management Board
1001 I Street
P.O. Box 4025
Sacramento, California 95812-4025
Phone: (916) 341-4027
Website: www.calrecycle.ca.gov/
Hazardous Waste
Cal/EPA
Department of Toxic Substances Control
Hazardous Waste Management Program
1001 I St.

Mailing address:
Department of Toxic Substances Control
Hazardous Waste Management Program
P.O. Box 806
Phone: (800) 728-6942 Hotline
Website: www.dtsc.ca.gov/HazardousWaste/index.cfm
Spill information
24-hour number for spills or uncontrolled releases: (800) 852-7550 or (916) 845-8911.
Use the federal Uniform Hazardous Waste Manifest form
For more information, contact: David Alamillo
Phone: (602) 771-4743
Phone: (907) 271-6329
Storage Tanks
1001 I Street
Sacramento, CA 95814
Mailing Address
P.O. Box 100
Phone: (916) 341-5455
Website: www.waterboards.ca.gov/water_issues/programs/ust/
John Paine — Unified Program Section
1001 I Street
P.O. Box 2815
Sacramento, California 95812-2815
Phone: (916) 327-5092
E-mail: jpaine@calepa.ca.gov
Website: waterboards.ca.gov/water_issues/programs/aboveground_tanks/Cal/EPA or www.
calepa.ca.gov/CUPA/Aboveground/
Note: Facilities in CA no longer need to submit a copy of their TRI reports to the Dept. of
Toxic Substances in Control. DTSC has established a State TRI data exchange with
federal EPA. CA facilities must submit TRI reports by using the TRI-MEweb software or
by hard copy. (Be aware, however, that EPA is phasing out hard copy submitting to the
TRI program.)
Website: www.dtsc.ca.gov/database/CALTRIP/index.cfm
Direct questions on submitting TRI reports to:
Ron Troyer, Chief Applications Development and Support Office of Environmental
Information Management, Phone: 916-445-9547 E-mail:rtroyer@dtsc.ca.gov


California has developed a single comprehensive hazardous materials inventory form for
businesses to use to submit their hazardous materials inventories. The state form
contains all state and federally required inventory information. The use of this form will
meet state and federal reporting requirements.
Facilities may also be required to submit local level forms to local agencies (Certified
Unified Program Agencies (CUPA’s) and/or Administering Agencies (AA’s)). The local
forms must contain identical content to the state and federal forms. A business may
choose to use the state single comprehensive hazardous material inventory form to
report their hazardous material inventories to a local agency.
If a business chooses to use the federal Tier II form to meet its inventory reporting
requirements, it must also submit a state or local form. Again, submittal of the state
standard form will meet state and federal reporting requirements.
Office of Emergency Services
Hazardous Materials Unit
3650 Schriever Ave.
Mather, CA 95655
Phone: (916) 845-8510
Website: www.oes.ca.gov/
HazCom
California’s state requirements regarding Hazard Communication include a substantial
amount of regulatory information beyond the federal requirements.
Website: www.dir.ca.gov/
For Proposition 65 information: www.oehha.org/prop65.html
Transportation
CA Department of Transportation
1120 N Street Sacramento Phone: 916-654-5266
Website: www.dot.ca.gov/
CA Department of Motor Vehicles Phone: (800) 777-0133 Website: www.dmv.ca.gov
California Highway Patrol - 062
Hazardous Materials Section Phone: (916) 445-1865 Website: www.chp.ca.gov
Colorado
Colorado Department of Public Health and Environment
4300 Cherry Creek Drive South
Denver, CO 80246-1530
Phone: 303.692.2000
Website: http://www.cdphe.state.co.us/
Air
CO Department of Public Health and Environment
Air Pollution Control Division
Denver, CO 80246-1530
Phone: (303) 692-3100
Email: comments.apcd@state.co.us
Website: www.cdphe.state.co.us/ap/index.html

Water
Water Quality Control Division
Denver, CO 80246-1530
Phone: (303) 692-3500
E-mail: comments.wqcd@state.co.us
Northwestern Regional Office
222 S. 6th St., Room 232
Grand Junction, CO 81501
(970) 248-7150
Southern Regional Office
4718 N. Elizabeth St., Ste. B
Pueblo, CO 81008
(719) 545-4650
Website:www.cdphe.state.co.us/wq/index.html
Stormwater/NPDES permitting information: For information on Colorado’s storm water
program requirements, visitwww.cdphe.state.co.us/wq/permitsunit/stormwater/ orwww.
cdphe.state.co.us/wq/PermitsUnit/index.html
Solid Waste
HMWMD-SW-B2
Denver, Colorado 80246-1530
Phone: 303-692-3300 or (888) 569-1831
E-mail: comments.hmwmd@state.co.us
Customer Technical Assistance Line: (303) 692-3320
Website: www.cdphe.state.co.us/hm
Hazardous Waste
EDO-OEP-A5 4300 Cherry Creek Drive South
Phone: (303) 692-3467
E-mail: cdphe.hwcrequests@state.co.us
Customer Technical Assistance Line: (303) 692-3320
Website: www.cdphe.state.co.us/op/hwc/index.html
Spill information
For environmental release and incident reporting, call
24-hour toll-free number
1-877-518-5608.
Colorado does not require the use of State-specific waste codes on hazardous waste
shipping manifests. The only State-specific waste codes for Colorado are related to waste
chemical weapons, including mustard gas and Sarin, and associated treatment residues
and contaminated materials that came in contact with chemical weapons.
For more information, contact:
Edward Smith
Phone: 303-692-3386
Email: comments.hmwmd@state.co.us (Use “Ed Smith” in the subject line.)

Storage Tanks
Division of Oil and Public Safety
633 17th Street Suite 500
Denver, CO 80202-3610
Phone: 303-318-8525
Website: www.colorado.gov/cs/Satellite/CDLE-OilPublicSafety/CDLE/1248095302546
Operator Training information: www.colorado.gov/cs/Satellite/CDLE-OilPublicSafety/
CDLE/1248095303312
Division of Oil & Public Safety
CO Department of Labor and Employment
633 17th St., Suite 500
Denver, CO 80202-3660
Phone: (303) 318-8500
Email: oil.Inspection@state.co.us or https://www.coworkforce.com/email.asp
After hours leak report: 1-877-518-5608
Website: www.colorado.gov/cs/Satellite/CDLE-OilPublicSafety/CDLE/1251588738334
CO Emergency Planning Commission, CO DPHE
SARA Title III Report DEHS - B2
Denver, CO 80246-1530
EPCRA Hotline: (800) 424-9346 or (703) 412-9810
E-mail: cdphe.ppsaratitle3@state.co.us
Website: www.cdphe.state.co.us/oeis/SARA/tierIIreports.html
Colorado Emergency Planning Commission c/o Colorado Department of Public Health &
Environment SARA Title III -- Tier II Reports
DEHS - B2
Phone: (303) 692-2977
Website:www.cdphe.state.co.us/oeis/sara/index.html
Colorado now requires Tier II reporting be done electronically using Tier2Submit file
format. Reporting can be done by Email, CD, or diskette. See the website for instructions
and follow instructions exactly. The Federal Tier II form sent by mail will only be
accepted if electronic reporting cannot be done. See website for additional required
language to accompany paper Tier II Form.
HazCom
Colorado follows federal OSHA safety and health program requirements for hazard
communication.
Website: www.cdphe.state.co.us/dc/oh/index.html

Transportation
Colorado Department of Transportation
Headquarters Office
4201 E Arkansas Ave
Denver CO 80222
Phone: 303-757-9011
Website: http://www.coloradodot.info/
Connecticut
Connecticut Department of Energy & Environmental Protection
79 Elm Street
Hartford, CT
06106-5127
Phone: (860) 424-3000
Website: www.ct.gov/deep/site/default.asp
Air
Connecticut Department of Environmental Protection
Bureau of Air Management
79 Elm Street
Hartford, CT 06106-5127
Phone: (860) 424-3026 or (860) 424-4152
Website: www.dep.state.ct.us/air2/index.htm
Water
Bureau of Water Management 79 Elm Street Hartford, CT 06106-5127
Phone: (860) 424-3704
Website: www.dep.state.ct.us/wtr/index.htm
Stormwater/NPDES permitting information: To view details of Connecticut’s stormwater
management programs, including industrial, construction, commercial, and municipal
permitting, visit www.ct.gov/dep/cwp/view.asp?a=2721&q=325702&depNav_GID=1654 .
Solid Waste
CTDEEP
Bureau of Materials Management and Compliance Assurance
Waste Engineering and Enforcement Division (WEED)
Solid Waste Program
79 Elm Street
Phone: (860) 424-3023 or (860) 424-3366
Website: www.ct.gov/dep/site/default.asp
Hazardous Waste
Waste Engineering and Enforcement Division
Hazardous Waste Program
79 Elm Street
Phone: (888) 424-4193 or (860) 424-3023
Website: www.ct.gov/dep/site/default.asp

Spill information:
Hazardous materials emergency: (860) 424-3338 or Toll Free (866) 337-7745
Use the federal Uniform Hazardous Waste Manifest form. Contact DEEP staff at (860)
424-3023 for further information.
Storage Tanks
Bureau of Materials Management and Compliance Assurance Storage Tank and PCB
Enforcement Unit 79 Elm Street Hartford, CT 06106-5127
Phone: (860) 424-3374 or (860) 424-3329 E-mail:lori.saliby@ct.gov
Website: www.ct.gov/dep/cwp/view.asp?a=2692&q=322600&depNav_GID=1652
Connecticut does not regulate aboveground storage tanks above the federal
requirements. However, the state has adopted NFPA standards for ASTs.
Department of Energy and Environmental Protection
Bureau of Materials Management and Compliance Assurance
Emergency Response and Spill Prevention
79 Elm Street
Phone: (860) 424-3024
Water protection information: www.ct.gov/dep/lib/dep/aquifer_protection/
municipalassistance.pdf
Connecticut State Emergency Response Commission (SERC Administrator)
c/o Department of Environmental Protection
79 Elm Street, 4th Floor
Phone: (860) 424-3373
Website: www.ct.gov/serc
For general questions about filing, call the hotline at (800) 424-9346.
At this time, submissions are not accepted on disk or online. Forms need to have original
signatures and be sent as hard copy.
Connecticut State Emergency Response Commission (SERC Administrator) c/o
Department of Environmental Protection 79 Elm Street - 4th Floor Hartford, CT 06106-
5127
Phone: (860) 424-3373 or (860) 424-3024
E-mail: dep.ctepcra@ct.gov
Website: www.ct.gov/serc
Connecticut requires the use of a federal Tier II form. The state prefers, but does not
require, facilities to file using Tier2 Submit software (www.epa.gov/emergencies/content/
epcra/tier2.htm#tierii). Submit Tier II forms to SERC at deep.ctepcra@ctgov and the
LEPC and the fire department with jurisdiction over the facility.

HazCom
Connecticut follows the federal OSHA safety and health program requirements for
private sector employees. Public sector employees are covered under the Conn-OSHA
state plan.
Connecticut Department of Labor
Occupational Safety and Health Division
38 Wolcott Hill Rd.
Wethersfield, CT 06109
Telephone: (860) 263-6900
Website: www.ctdol.state.ct.us/osha/osha.htm
Transportation
Connecticut Department of Transportation
2800 Berlin Turnpike,
Newington, CT 06131-7546
Phone: (860) 594-2878
Website: www.ct.gov/dot/site/default.asp
Delaware
Delaware’s Department of Natural Resources and Environmental Control
89 Kings Highway
Dover, DE 19901
Telephone: 302-739-9000
Website: http://www.dnrec.delaware.gov/Pages/Divisions.aspx
Air
Division of Air Quality
Blue Hen Corporate Center
655 S. Bay Road, Suite 5N
Dover, DE 19901
Phone: 302-739-9402
Website: www.dnrec.delaware.gov/whs/awm/AQM/Pages/default.aspx
Water
Division of Water
89 Kings Highway
Dover, DE 19901
Phone: 302-739-9950
Website: www.dnrec.delaware.gov/wr/Pages/DivisionManagement.aspx
Stormwater/NPDES permitting information: For information on storm water in
Delaware, contact the Division of Soil and Water Conservation at (302) 739-9921 or visit
www.swc.dnrec.delaware.gov/Pages/SedimentStormwater.aspx .
Solid Waste
Delaware Department of Natural Resources and Environmental Control
Division of Air and Waste Management
Solid and Hazardous Waste Management Branch
89 Kings Hwy
Dover, DE 19901
Phone: (302) 739-9403
Website: http://www.awm.delaware.gov/

Hazardous Waste
Delaware Department of Natural Resources and Environmental Control
Solid and Hazardous Waste Management Branch
89 Kings Hwy
Dover, DE 19901
Phone: (302) 739-9403
Website: www.dnrec.state.de.us/DNREC2000/Divisions/AWM/hw/indexhw.htm
Spill information:
Call (800) 662-8802 both within and outside Delaware or (302) 739-9401 or -9404.
Use the federal hazardous waste manifest.
The State of Delaware requires that Page 1 (“Designated facility to destination State”)
and Page 2 (“Designated facility to generator State”) be submitted to the Department of
Natural Resources and Environmental Control (DNREC). Manifests may be mailed to:
Delaware DNREC
Attn: Manifest Clerk
89 Kings Highway
Dover, DE 19901
Delaware does not have any State-specific waste codes.
Nicole E. Hill
nicole.hill@state.de.us
Phone: (302) 739-9403
For more information, refer to www.dnrec.state.de.us/DNREC2000/Divisions/AWM/hw/
hw/pdf/manifest.pdf.
Storage Tanks
Aboveground and underground storage tanks
Tank Management Branch
391 Lukens Drive
New Castle, DE 19720
Phone: (302) 395-2500
Website: www.dnrec.state.de.us/dnrec2000/Divisions/AWM/ust/
http://www.epa.gov/oem/content/epcra/statetier2.htm
John Parker
Division of Air & Waste Management
655 South Bay Rd., Suite 5N
Dover, Delaware 19901
(302) 739-9405
E-mail: John.Parker@state.de.us
Website: www.dnrec.delaware.gov/whs/awm/Info/Pages/TRI.aspx and www.dnrec.
delaware.gov/SERC/Services/Pages/ToxicsReleaseInventoryReporting.aspx
Note: TRI reports submitted to the EPA TRI-MEweb CDX reporting system will be
automatically forwarded to DNREC and do not require additional certifications. There
are no fees associates with state reporting in DE.


EPCRA Reporting Program Emergency Prevention & Response Branch, DNREC Blue
Hen Corporate Center 655 South Bay Rd, Suite 5N Dover, DE 19901
Phone: (302) 739-9405
Website: www.dnrec.delaware.gov/SERC/Services/Pages/DownloadFormsorSoftware.aspx
Delaware uses its own Tier II forms. There is a fee for filing.
For electronic submission information, go to https://tierii.dnrec.delaware.gov/tier2/submit/
.
HazCom
Delaware follows federal OSHA safety and health program requirements for hazard
communications.
Delaware Department of Labor
Division of Industrial Affairs
Occupational Safety and Health
4425 N. Market Street
Wilmington, DE 19802
Phone: (302) 761-8200
Website: www.delawareworks.com/industrialaffairs/welcome.shtml
Transportation
DE Department of Transportation
800 Bay Road
Dover, DE 19901
P.O. Box 778
Dover, DE 19903
Phone: (800) 652-5600 or (302) 760-2080
District of Columbia
District of Columbia Department of the Environment
1200 First Street NE, Washington, DC 20002
Phone: (202) 535-2600
TTY: (800) 855-1000
Email:ddoe@dc.gov
Website: www.green.dc.gov
Air
Air Quality Division
District Department of the Environment
Government of the District of Columbia
1200 First Street, NE, 5th Floor
Washington, DC 20002
(202) 535-2250
Website: http://ddoe.dc.gov/

Water
Water Quality Division
Government of the District of Columbia
Phone: (202) 535-2600
Storm water/NPDES permitting information:
Storm Water Management Division
Phone: (202) 535-1722
Solid & Hazardous Waste
1200 First Street, NE 5th Floor
Washington, DC 20002 (202) 535-2600
Website: http://ddoe.dc.gov
For spill information, use the same contact as for solid and hazardous waste.
At this time there are no state-specific waste code requirements. For more information,
contact:
DC District Department of the Environment
1200 First Street, NE 5th Floor
Phone: (202) 535-2600
Storage Tanks
Aboveground Storage Tanks (ASTs) are primarily regulated by the DC Fire BOCA codes.
The Fire Prevention Branch of DC Fire and Emergency Medical Services (DC FEMS) is
charged with regulating ASTs in the District. DDOE does not have authority to regulate
AST operations or the release of petroleum products from ASTs.
General Inquiries
E-mail: ust.ddoe@dc.gov
Phone: (202) 535-2600


Michele Penick, Environmental Planning Specialist
Emergency Response Commission for Title III
2000 14th Street, NW, 8th Floor
Phone: (202) 673-2101, extension 1159
Email: michele.penick@dc.gov
Website: http://dc.gov/index.asp
Tier II Administrator
Homeland Security and Emergency Management Agency
2720 Martin Luther King Jr. Avenue, SE
Phone: (202) 727-6161
Website: http://hsema.dc.gov/
HazCom
District of Columbia follows federal OSHA safety and health program requirements.
Transportation
District of Columbia Department of Transportation
55 M Street, SE, Suite 400
Phone: (202) 673-6813
Website: www.ddot.dc.gov
Florida
Florida Department of Environmental Protection
3900 Commonwealth Boulevard M.S. 49
Tallahassee, FL 32399
Phone: (850) 245-2118
Website: www.dep.state.fl.us
Air
FDEP Division of Air Resources Management
2600 Blair Stone Road, M.S. 5500
Tallahassee, FL 32399-2400
Phone: (850) 717-9000
Website: www.dep.state.fl.us/air/
Water
FDEP Division of Water Resources Management
Phone: (850) 245-8336
Website: www.dep.state.fl.us/water/
Website: www.dep.state.fl.us/water/stormwater/npdes/index.htm


FDEP Division of Waste Management
Bureau of Solid and Hazardous Waste
2600 Blair Stone Road MS #4550
Phone: (850) 245-8705 or (850) 245-8707
E-mail: Linda.Frohock@dep.state.fl.us
Website:www.dep.state.fl.us/waste/default.htm
Spill information:
24-hour reporting of oil and hazardous substances spills:
(800) 3230-0519 or (850) 245-2010; http://www.dep.state.fl.us/law/ber/
(800) 424-8802 ( National Response Center); or
(404) 562-8700 ( U.S. Region 4 EPA 24-hour spill reporting number).
The State of Florida does not require that you submit manifest copies to the Florida
Department of Environmental Protection. However, if your state requires that such
copies be submitted, they should be submitted to:
Hazardous Waste Manifest Coordinator
MS 4550, Division of Waste Management
2600 Blair Stone Road
There are no State-specific waste codes for the State of Florida.
Contact Jack Griffith at (850) 245-8748 for further information.
Storage Tanks
FDEP Division of Waste Management
Bureau of Petroleum Storage Systems
Phone: (850) 245-8839
Website: www.dep.state.fl.us/waste/categories/tanks/default.htm
For information on the Florida regulations regarding Aboveground storage tanks, visit
this website: www.dep.state.fl.us/waste/quick_topics/rules/documents/62-762.pdf
Florida Emergency Response Commission
Compliance Verification Unit
2555 Shumard Oak Blvd.
Phone: (850) 413-9969 or (850) 413-9928
E-mail: www.floridadisaster.org/contact/contact.asp
Website: www.hazmat.floridadisaster.org/


Florida Emergency Response Commission, Compliance Planning Section
2555 Shumard Oak Blvd.
Florida ERC numbers: (850) 413-9969
Website: www.hazmat.floridadisaster.org/
Florida requires the use of a state Tier II form. An annual registration fee and form are
also required.
HazCom
Florida follows federal OSHA safety and health program requirements.
Transportation
Florida Department of Transportation
605 Suwannee Street
Tallahassee, FL 32301
Phone: (850) 414-5205
Website: www.dot.state.fl.us
Georgia
Georgia Environmental Protection Division
2 Martin Luther King Jr. Drive, Suite 1152 East Tower
Atlanta, GA 30334
Phone: 404.657.5947 or 888.373.5947
Website: www.gaepd.org
Air
Georgia Department of Natural Resources
Environmental Protection Division
Air Protection Branch
4244 International Parkway, Suite 120
Atlanta, Georgia 30354
Phone: (404) 363-7000
Website: www.gaepd.org/Documents/index_air.html or http://www.georgiaair.org
Water
Watershed Protection Branch
Phone: (404) 675-6232
Website: www.gaepd.org/Documents/index_water.html
For information on stormwater and the Georgia Watershed Protection Nonpoint Source
Program, call (404) 675-6240.

Hazardous Waste
Hazardous Waste Management Branch
2 Martin Luther King Jr. Drive,
Suite 1152, East Tower
Atlanta, GA 30334-9000
Phone: (404) 657-8600
Website: www.gaepd.org/Documents/index_haz.html
Spill information:
Hazardous materials emergency: (800) 241-4113 (statewide) or (404) 656-4863.
Georgia does not require copies of manifests be submitted to the state regardless of
whether the waste originates or is disposed of in the state.
Georgia does not have any state specific waste codes.
Storage Tanks
Land Protection Branch
Underground Storage Tank Program
Atlanta, GA 30354-3906
Phone: (404) 362-2687
Website: www.gaepd.org/Documents/index_land.html
Aboveground storage tanks in Georgia are regulated by the State Fire Marshall and by
the EPA. Aboveground tanks containing 1,100 gallons or less do not require any
secondary containment, according to NFPA Code 395.
Georgia Program Coordination Branch
Georgia Emergency Response Team
7 Martin Luther King Jr. Drive, Suite 643
Atlanta, GA 30334
Phone: (404) 656-6905
Website: www.gaepd.org/Documents/gartk312.html
Georgia Emergency Response Team
7 Martin Luther King Jr. Drive, Suite 643
Atlanta, GA 30334
Phone: (404) 656-6905
Georgia requires the use of EPA’s Tier II Submit software.
Website: www.gaepd.org/Documents/tier2.html
HazCom
Georgia follows federal OSHA safety and health program requirements.
Transportation
Georgia Department of Transportation
One Georgia Center
600 West Peachtree NW
Phone: (404) 631-1990 Main Office

Hawaii
Hawaii Office of Environmental Quality Control
235 S Beretania St #702
Honolulu, HI 96813
Phone: 586-4185
Email: oeqc@doh.hawaii.gov
Air
Clean Air Branch
919 Ala Moana Blvd., Suite 203
Honolulu, Hawaii 96814
Phone: (808) 586-4200
Website: www.hawaii.gov/health/environmental/air/cab/index.html
Water
Clean Water Branch
919 Ala Moana Blvd., Room 301
Honolulu, Hawaii 96814-4920
Phone: (808) 586-4309
Website: www.hawaii.gov/health/environmental/water/cleanwater/index.html
Solid and Hazardous Waste Branch
Hawaii Department of Health
919 Ala Moana Blvd., #212
Phone: (808) 586-4226
Website: http://www.hawaii.gov/health/environmental/waste/index.html
Spill information:
24-hour hotline: (808) 247-2191
Hawaii does not require copies of hazardous waste manifests to be submitted to the
State unless specifically requested by the Solid & Hazardous Waste Branch (for example,
as a follow-up to a hazardous waste inspection).
Hawaii does not require the use of State-specific waste codes on hazardous waste
shipping manifests.
Website: http://healthuser.hawaii.gov/health/environmental/waste/hw/index.html
Storage Tanks
Hawaii Department of Health
919 Ala Moana Blvd., #212
Phone: (808) 586-4226
Website: www.hawaii.gov/health/environmental/waste/index.html


Hawaii State Department of Health
Emergency Response Commission
919 Ala Moana Blvd., Rm 206
Phone: (808) 586-4249
Website: www.hawaii.gov/health/environmental/hazard/index.html
Hawaii State Department of Health
Emergency Response Commission
919 Ala Moana Blvd., Rm 206
Phone: (808) 586-4249
Website: www.hawaii.gov/health/environmental/hazard/index.html
Hawaii requires the use of a federal Tier II form, a Hawaii Chemical Inventory Form,
and Site Map. There is a fee for filing.
HazCom
Hawaii incorporates by reference the federal regulations for hazard communication;
however, the state adds further requirements. To learn more, go to: hawaii.gov/labor/
hiosh/pdf/standards/2-13-12-update/part-2-general-industry-standards/12-60.pdf
Transportation
Hawaii Department of Transportation
Aliiaimoku Building
869 Punchbowl Street
Honolulu, HI 96813
Idaho
Idaho Department of Environmental Quality
Idaho DEQ Regional Office
Boise Regional Office
1445 N. Orchard
Boise, ID 83706
Phone: (208) 373-0550
Toll-free: (888) 800-3480
Air
Idaho DEQ Air Quality
1410 North Hilton
Boise, Idaho 83706
Phone: (208) 373-0502
Website: www.deq.state.id.us/
Water
Idaho DEQ Water Quality
1410 N. Hilton
Boise, Idaho 83706
Phone: (208) 373-0502

Stormwater/NPDES permitting information: To view details of the Idaho program for

stormwater and NPDES permits, visit http://www.deq.state.id.us/water/prog_issues/
storm_water/overview.cfm.
Idaho DEQ Waste Management and Remediation
1410 N. Hilton
Boise, Idaho 83706
Phone: (208) 373-0502
Spill information:
24-hour emergency release reporting: (800) 632-8000
Idaho does not require copies of manifests to be submitted to it regardless of whether the
waste originates or is disposed of in the state. The only exception is when Idaho DEQ is
the generator of the waste.
Idaho does not have any state-specific waste codes.
Website: www.deq.idaho.gov/waste/assist_business/haz_waste/status.cfm
Storage Tanks
1410 N. Hilton
Boise, Idaho 83706
Phone: (208) 373-0502
ASTs in Idaho are regulated by EPA, under the federal Spill Prevention, Control, and
Countermeasure (SPCC) rule. Although DEQ does not regulate ASTs in Idaho, state
rules require that the agency be notified within 24 hours of the time of release if an AST
has a release to the environment. Local fire districts, cities, and counties may have
additional AST ordinances or best management practices.
Bureau of Homeland Security
4040 Guard Street, Bldg 600
Boise, Idaho 83705-5004
Phone: (208) 422-3040
Website: www.bhs.idaho.gov/
Send forms to:
Bureau of Homeland Security 4040 Guard Street, Bldg 600
Boise, Idaho 83705-5004
Phone: (208) 422-3040
Website: www.bhs.idaho.gov/
Idaho requires the use of a state Tier II form.
HazCom
HazCom Idaho follows the federal OSHA safety and health program requirements for
HazCom.

Transportation
Idaho Department of Transportation
3311 W. State Street
P.O. Box 7129
Boise, ID, 83707-1129
Phone: (208) 334-8000
Website: itd.idaho.gov
Illinois
Illinois Environmental Protection Agency
Illinois Environmental Protection Agency Headquarters
1021 North Grand Avenue East
P.O. Box 19276
Springfield, Illinois 62794-9276
Phone: (217) 782-3397
Website: www.epa.state.il.us
Air
IEPA Bureau of Air
Springfield, IL 62794-9276
Phone: Manager-(217) 785-4140
Helpline: (888) 372-1996
Website: www.epa.state.il.us/air/index.html
Water
IEPA Bureau of Water
P.O. Box 19276
Phone: (217) 782-1654
Website: http://www.epa.state.il.us/water/index.html
Stormwater/NPDES permitting information: For Illinois storm water and NPDES
permitting program details, visit www.epa.state.il.us/small-business/storm-water/
For more information on NPDES permits or SWPP Plans, call the Illinois EPA Division
of Water Pollution Control Permit Section at (217) 782-0610 or the Office of Small
Business toll-free at (888) EPA-1996.
1410 N. Hilton
Boise, Idaho 83706
Phone: (208) 373-0502
Website: http://www.deq.state.id.us/
Spill information:
24-hour emergency release reporting: (800) 632-8000
Use the federal Uniform Hazardous Waste Manifest form. For more information, call
Hope Wright at (217) 785-2361.

Storage Tanks
Illinois EPA Leaking Underground Storage Tank Section
Phone: (217) 782-6762
Website: www.epa.state.il.us/land/lust/index.html
For information on Illinois regulations regarding aboveground storage tanks, visit the
following website: www.sfm.illinois.gov/commercial/ast/faq.aspx
Illinois Emergency Management Agency
2200 S. Dirksen Parkway
Springfield, IL 62703
Phone: (217) 782-2700
Website: www.state.il.us/iema/disaster/serc.htm
Send forms to:
Attn: Tier 2 Reporting
2200 South Dirksen Parkway
Phone: (217) 782-2700
Website: www.state.il.us/iema/disaster/serc.htm or
Illinois requires the use of a federal Tier II form by electronic submission. Use IEMA’s
Tier 2 Manager software program. Inquiries should be made to Ms. Lori Canterbury or
Ms. Carlita D. Crockett, IEMA, at 217-558-0559 or ema.tier2mgr@illinois.gov
HazCom
Illinois follows the federal OSHA safety and health program requirements for this topic
for private sector employees.
Transportation
Idaho Department of Transportation
Illinois Department of Transportation
2300 S. Dirksen Parkway
Phone: (217) 782-7820
Website: http://www.dot.state.il.us/
Indiana
Indiana Department of Environmental Management
IDEM
Indiana Government Center North 100 N. Senate Ave.
Indianapolis, IN 46204
Phone: (317) 232-8603
Website: www.in.gov/idem

Air
IDEM Office of Air Quality
100 North Senate Avenue Mail Code 61-50 IGCN 1003
Indianapolis, IN 46204-2251
Phone: (317) 232-8603
Toll-free in Indiana: (800) 451-6027
Website: www.in.gov/idem/4652.htm
Water
IDEM Office of Water Quality
Phone: (317) 232-8603
IDEM Office of Water Quality
Phone: (317) 232-8603
For information on Indiana stormwater regulation, visit the website at www.in.gov/idem/
6451.htm.
IDEM Office of Land Quality
100 North Senate Avenue Mail Code 65-45
Phone: (317) 232-8603
Spill information:
To report chemical spills and environmental emergencies outside of the U.S., call (317)
233-7745 or toll-free 24 hours a day at (888) 233-SPIL (7745), inside U.S.
You are not required to submit copies of your Uniform Hazardous Waste Manifest to the
State of Indiana. Please retain the extra copies of the manifest in your files.
I001 is the only Indiana state specific waste code. This code is for chemical munitions.
The definition of this waste code can be found at 329 IAC 3.1-6-3.
Contact Michelle Weddle at (317) 233-4624 for more information.
Storage Tanks
IDEM Underground Storage Tank Program UST Program
100 North Senate Avenue
Phone: (317) 232-8900
Toll-free: (800) 451-6027, Ext 2-8900 (general help number)
Leaking UST Section phone:(317) 308-3024


For information on Indiana regulations regarding aboveground storage tanks, see the
following PDF: http://www.in.gov/idem/files/small_bus_chap04.pdf
IDEM OPPTA
100 N. Senate Ave., Mail Code 60-00
Toll-free: (800) 988-7901
Phone: (317) 232-8172
Department of Homeland Security — Indiana Emergency Response Commission — Sara
Title III
302 W. Washington St., Room E-208
Phone: (317) 234-6796
E-mail: SARATR2@dhs.IN.gov
Website: www.in.gov/dhs/2362.htm
Indiana requires the use of a federal or state Tier II form. If a federal form is used, the
facility must include ID number. There is a fee for filing.
HazCom
Indiana incorporates by reference the federal regulations for hazard communication;
therefore, the state requirements are identical to the federal requirements.
Transportation
Indiana Department of Transportation
Crawfordsville District
Website: westcentralindiana@indot.in.gov
Fort Wayne District
Website: NEinformation@indot.in.gov
LaPorte District
Website: LaPorteDistrictCommunicatations@indot.in.gov
Iowa
Iowa Department of Natural Resources
Iowa Department of Natural Resources Central Office
Wallace State Office Building, 502 E. 9th Street
Des Moines, IA 50319-0034
Phone: (515) 281-5918
Website: www.iowadnr.gov
Air
IDNR Environmental Protection Division — Air Quality Bureau
7900 Hickman Rd., Suite 1
Windsor Heights, IA 50324
Phone: (515) 242-5100
Website: www.iowadnr.com/air/index.html

Water
IDNR Environmental Protection Division — Water Quality Bureau
Henry A. Wallace Building 502 E 9th Street
Phone: (515) 725-0281
Website: www.iowadnr.com/water/index.html
Stormwater/NPDES permitting information: For assistance with storm water issues, call
(515) 281-7017 or (515) 281-6782 and ask for “storm water general permit assistance.”
Details of Iowa’s program can be viewed at http://www.iowadnr.com/water/stormwater/
index.html
IDNR Environmental Services Division — Energy and Waste Management
Bureau
Henry A. Wallace Building 502 E. 9th St.
Phone: (515) 281-5918
Website: www.iowadnr.com/waste/sw/index.html
Spill information:
24-hour number for Release Reporting: (515) 281-8694.
You are not required to submit copies of your Uniform Hazardous Waste Manifest to the
State of Iowa. Iowa does not have any state specific waste codes. For more information,
see: www.iowadnr.com/land/consites/hwmanifest.html.
Storage Tanks
IDNR Land and Waste Management Division — Land Quality Bureau — Underground
Storage Tanks
Wallace Building 502 East 9th St.
Des Moines, IA 50319
Phone: (515) 281-5918
Website: www.iowadnr.com/land/ust/index.html
The State Fire Marshal requires notification of the existence of any aboveground
flammable and combustible liquid storage tank and specific information including age,
size, type, location and uses.
For more information, contact: Kyle Gorsch
State Fire Marshal’s Office
Wallace State Office Building 502 East 9th Street
Des Moines, IA 50319
Phone: (515) 725-6145
E-mail: miller@dps.state.ia.us
IDNR
Henry A. Wallace Building 502 E. 9th Street
Phone: (515) 281-5918


Elonda Bacon, EPCRA Coordinator Emergency Response and Homeland Security Unit
Emergency Response and Homeland Security Unit — IDNR
502 East 9th Street
Phone: (515) 725-0302
Website: www.iowaworkforce.org/labor/serc.htm
Iowa requires the use of either a federal or state Tier II form.
HazCom
Iowa incorporates by reference the federal regulations for hazard communications;
Transportation
Iowa Department of Transportation
800 Lincoln Way
Ames, Iowa 50010
Phone: (515) 239-1101
Website: www.iowadot.gov
Kansas
Kansas Department of Health and Environment
Curtis State Office Building 1000 SW Jackson
Topeka, KS 66612
Phone (785) 296-0461
Website: www.kdheks.gov
Air
Kansas Department of Health and Environment — Bureau of Air and Radiation
1000 SW Jackson Suite 310
Phone: (785) 296-1593
Website: www.kdheks.gov/bar/index.html
Water
Kansas Department of Health and Environment — Bureau of Water
Phone: (785) 296-5500
Website: www.kdheks.gov/water/
Stormwater/NPDES permitting information: For information on Kansas’ nonpoint source
pollution program, visit www.kdhe.state.ks.us/stormwater/index.html
Kansas Department of Health and Environment — Bureau of Waste
Management
Topeka, KS 66612-1366
Phone: (785) 296-1600
Website: www.kdhe.state.ks.us/waste/
Spill information:
Spills can be reported to KDHE by calling (785) 296-1679.

Kansas does not require copies of manifests be submitted to it regardless of whether the
waste originates or is disposed of in the state. Copies of manifests are required when
submitting Biennial Reports.
Kansas does not have any state specific waste codes.
Contact Rebecca Wenner at (785) 296-1604 for information regarding hazardous waste
manifests.
Storage Tanks
Kansas Storage Tank Section
Topeka, KS 66612-1367
Phone (785) 296-1678
Website: www.kdheks.gov/tanks/
Randy Carlson, Section Chief
1000 SW Jackson, Suite 410
Topeka, KS 66612
Phone: (785) 296-1678
Topeka, KS 66612-1366
Phone: (785) 296-1500
Website: www.kdheks.gov/radiation/indexRTK.html
Kansas Department of Health and Environment — Right-to-Know Section
Topeka, KS 66612-1366
Phone: (785) 296-1500
Website: www.kdheks.gov/radiation/indexRTK.html
Kansas requires the use of a state Tier II form. There is a fee for filing.
HazCom
Kansas follows the federal OSHA safety and health program requirements for hazcom.
Transportation
Kansas Department of Transportation
700 SW Harrison
2nd Floor West
Topeka, KS, 66603-3754
Phone: (785) 296-3585

Kentucky
Kentucky Department for Environmental Protection
Kentucky Department for Environmental Protection
300 Fair Oaks Ln.
Frankfort, KY 40601
Phone: 502-564-2150
E-mail: envhelp@ky.gov
Website: www.dep.ky.gov
Air
KDEP Natural Resources and Environmental Protection Cabinet
Division for Air Quality
200 Fair Oaks Lane, 1st Floor
Frankfort, KY 40601
Phone: (502) 564-3999
E-mail: Candy.Montgomery@ky.gov
Website: www.air.ky.gov/
Water
Division of Water
200 Fair Oaks Lane, 4th Floor
Frankfort, KY 40601
Phone: (502) 564-3410
E-mail: water@ky.gov
Website: www.water.ky.gov/
Stormwater/NPDES permitting information: For information on storm water discharge
permits in Kentucky, visit www.water.ky.gov/permitting/
Division of Waste Management — Solid Waste Branch
200 Fair Oaks Lane, 2nd Floor
Frankfort, KY 40601
Phone: (502) 564-6716
Website: waste.ky.gov/Pages/default.aspx
Spill information:
To report a hazardous materials emergency, call (502) 564-2380, (800) 928-2380, or
Kentucky Emergency Management at (502) 607-1638 or (800) 255-2587.
Kentucky does not currently require that a copy of the manifest be sent to the state.
What are Kentucky specific waste codes?
N001 – GB (isopropyl methyl phosphonofluoridate) (H)
N002 – VX (o-ethyl-S-(2-diisopropyl-aminoethyl)-methyl phosphonothiolate) (H)
N003 – H (bis(2-chloroethyl) sulfide) and related compounds (H)
Contact Bill Schneider at William.Schneider@ky.gov for further information.

Storage Tanks
KDEP Division of Waste Management — Underground Storage Tank Branch
200 Fair Oaks Lane
Frankfort, KY 40601
Phone: (502) 564-5981
Website: www.epa.gov/oust/states/ky.htm
For information on Kentucky’s regulations regarding aboveground storage tanks, see this
PDF: www.gov.ky/pls/portal/docs/PAGE/CIGHOME/PRESSROOM/ARCHIVE/200509/
TANKS.PDF
Kentucky Division of Emergency Management
Attn: Barbara J. Yates
Capital Complex East
1025 Capital Center Drive
Frankfort, KY 40601
Phone: (502) 607-5759
E-mail: barbara.yates1@us.army.mil
Website: www.kyem.ky.gov/
Kentucky Division of Emergency Management
Attn: Frank Longley
1025 Capital Center Drive, Suite 101
Frankfort, KY 40602
Phone: (502) 607-5731
E-mail: frank.longley@us.army.mil
Website: www.kyem.ky.gov/
Kentucky requires the use of a state Tier II form. There is a fee for filing.
HazCom
Kentucky incorporates by reference the federal regulations for hazard communication
(HAZCOM); therefore, the state requirements are identical to the federal requirements.
Transportation
Kentucky Transportation Cabinet
200 Mero Street
Frankfort, KY 40622
Phone: (502) 564-4890
Website: www.transportation.ky.gov
Louisiana
Louisiana Department of Environmental Quality
Louisiana Department of Environmental Quality
602 N. Fifth Street
Baton Rouge, LA 70802
E-mail: envhelp@ky.gov www.deq.louisiana.gov

Air
LDEQ — Air Permits Division
P.O. Box 4313
Baton Rouge, LA 70821-4313
Phone: (225) 219-3417
Website: www.deq.louisiana.gov/portal/tabid/64/Default.aspx
Water
LDEQ — Water Permits Division
P.O. Box 4313
Phone: (225) 219-9371
Stormwater/NPDES permitting information: Information on Louisiana’s nonpoint source
pollution program can be viewed at http://nonpoint.deq.state.la.us/.
Information on LPDES permits can be obtained at www.deq.louisiana.gov/portal/Default.
aspx?tabid=243
LDEQ
602 N. Fifth St.
Phone: (225) 219-5337 or Toll free: (866) 896-5337
Website: www.deq.louisiana.gov/
Spill information:
To report an environmental incident (emergency), call (225) 219-3640.Non-emergency,
call (225) 342-1234.
Use the federal Uniform Hazardous Waste Manifest form.
Contact the Department of Environmental Quality at (225) 219-5337 for further
information.
Storage Tanks
Louisiana Department of Environmental Quality Underground Starage Tanks Division
602 N. Fifth St. P.O. Box 4312
Phone: (225) 219-3181
E-mail: _DEQ-wwwUST@LA.gov
Aboveground storage tanks are regulated by the Louisiana State Fire Marshall’s Office
Phone: (800) 256-5452
Website: www.dps.state.la.us/sfm/
Aboveground storage tanks are regulated by LDEQ Water Quality Regulations under
LAC 33:IX.Chapter 9. Spill Prevention Control if over 660 gallon capacity.


LDEQ
Morton Wakeland, TRI Coordinator (6P)
EPCRA Section 313 Enforcement Coordinator
Toxics Section, Multimedia Planning and Permitting Division
1445 Ross Avenue, Suite 1200
Dallas, TX 75202-2733
Phone: (214) 665-8116
E-mail: wakeland.morton@epa.gov
Website: www.deq.louisiana.gov/portal/Default.aspx?tabid=105
Louisiana Emergency Response Commission
Louisiana State Police, Right-to-Know
PO Box 66168
Phone: (225) 925-6113 Ext. 3
Website: Right to Know Unit www.lsp.org/rtk.html
Louisiana requires the use of a state Tier II form. There is a fee for filing.
HazCom
Louisiana follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
Louisiana Department of Transportation and Development
1201 Capitol Access Road
Phone: (225) 379-1232
Website: www.dotd.la.gov
Maine
Maine Department of Environmental Protection
Maine Department of Environmental Protection
17 State House Station
28 Tyson Drive
Augusta, Maine 04333-0017
Phone: 207-287-7688
TTY: 800-492-0859
Air
LDEQ — Air Permits Division
P.O. Box 4313
Phone: (225) 219-3417

Water
MDEP — Bureau of Land and Water Quality
Augusta ME 04333-0017
Phone: (207) 287-7688
Toll-free (in-state only): (800) 452-1942
Website: www.state.me.us/dep/blwq/index.htm
Stormwater/NPDES permitting information: The Bureau of Land and Water Quality
regulates storm water in Maine. To view details of the program, visit www.state.me.us/
dep/blwq/docstand/stormwater/index.htm
Solid waste:
MDEP — Bureau of Remediation and Waste Management
Division of Solid Waste Facilities Regulation
28 Tyson Drive
Augusta, Maine 04333-0017
Phone: (207) 287-2651
Toll-free: (800) 452-1942
Website: www.maine.gov/dep/rwm/solidwaste/index.htm 602 N. Fifth St.
Hazardous waste: MDEP — Bureau of Remediation and Waste Management
Division of Oil and Hazardous Waste Facilities Regulation
Augusta, ME 04333-0017
Phone: (207) 287-7688
Spill information:
To report oil spills call (800) 482-0777 (24-hour number).
To report hazardous material spills call (800) 452-4664 (24-hour number).
The State of Maine requires copies of the manifest be submitted from both generators
and facilities, regardless of whether the waste is sent out of state or coming into the
state.
Since the manifest has six copies, it is the generator’s responsibility to make a photocopy
of the manifest upon initiating a shipment and submit it to MDEP within seven (7) days
of the shipment. This requirement is found in the Hazardous Waste Management Rules,
Chapter 857.7(A)(5).
The transporter may send copies of the manifest to MDEP as a service to the generator.
The Department may require the transporters to submit copies for the generator as a
condition of its transporter license. The Maine Rules require that the Designated Facility
mail the appropriate copies of the manifest to the Department, regardless of whether the
State of Maine is considered the “Generator State” (i.e. shipment is from a Maine-based
generator) or “Destination State” (i.e. shipment is to a Maine-based designated facility).
This requirement is in the Maine Rules, Chapter 857.9(A)(3)(b) and (c).
Copies should be mailed to this address:
MDEP — Hazardous Waste Manifest Bureau of Remediation and Waste Management
Augusta, ME 04333

Storage Tanks
Underground storage tanks (USTs) and leaking underground storage tanks:
MDEP — Bureau of Remediation and Waste Management Division of Remediation
Augusta ME 04333-0017
Phone: (207) 287-7688
Website: www.maine.gov/dep/rwm/index.htm
To see Maine’s regulations regarding aboveground storage tanks, go to the following link:
www.maine.gov/dep/waste/abovegroundtanks/dtree.html
Maine State Emergency Response Commission
ATTN: Robert Gardner
Phone: (800) 452-8735 (in-state); or
Phone: (207) 624-4400
Website: www.state.me.us/mema/
Maine Emergency Management Agency
State Emergency Response Commission (SERC)
Augusta, ME 04333
Phone: (207) 624-4400
Toll-free: (800) 452-8735 (in-state)
Website: www.maine.gov/mema/serc/
Maine requires the use of a state Chemical Inventory Reporting form and there is a fee
for filing.
HazCom
Maine follows the federal OSHA safety and health program requirements for HazCom.
Transportation
Maine Department of Transportation
Child Street
Phone: (207) 624-3000
TTY: 1-888-516-9364
Website: www.main.gov/mdot

Maryland
Maryland Department of the Environment
Maryland Department of the Environment
201 Baptist St # 15
Salisbury, MD 21801
Phone: (410) 713-3680
Website: www.mde.state.md.us
AIR
MDOE — Air and Radiation Management Administration
1800 Washington Blvd.
Baltimore, MD 21230
Phone: (410) 537-3000
Toll-free: (800) 633-6101
Website: www.mde.maryland.gov/Programs/Air/Pages/Index.aspx
Water
MDOE — Water Management Administration
Baltimore, MD 21230
Phone: (410) 537-3000
Toll-free: (800) 633-6101
Website: www.mde.maryland.gov/programs/water/pages/programs/waterprograms/index.
aspx
Storm water information can be obtained from: Stormwater Management Program
Baltimore, MD 21230
Phone: (410) 537-3000
Toll-free: (800) 633-6101
Website: www.mde.state.md.us/Pages/Home.aspx
For information on NPDES permits in Maryland, contact: Environmental Permit Service
Center (410) 537-3543 or (800) 633-6101 ext. 3772
Solid waste:
MDOE — Waste Management Administration Solid Waste Program
Baltimore, MD 21230
Phone: (410) 537-3000
Website: www.mde.state.md.us/Pages/Home.aspx
Hazardous waste:
MDOE — Waste Management Administration Hazardous Waste Program
Baltimore, MD 21230
Phone: (410) 537-3400
Spill information:
To report hazardous material or oil spills, call (866) 633-4686 or (866) MDE-GOTO.

Maryland requires that, in addition to the distribution of manifest copies required by
federal regulations, the following distributions of copies of the manifest be made:
The destination facility (treatment, storage, disposal or recycling facility to which
hazardous waste is sent) is required to provide the Maryland Department of the
Environment, Hazardous Waste Program, with a copy of the manifest.
A copy of the manifest is required to be submitted by the destination facility irrespective
of whether the facility is located in Maryland or another state.
A destination facility located in Maryland that receives a shipment of waste from an out-
of-state generator is only required to send a copy of the manifest to the generator’s state
regulatory agency only if the generator’s state requires submission of the copy.
The generator is not required to submit a copy of the manifest to the Maryland
Department of the Environment. A Maryland generator sending waste to a destination
facility in another state should check that state’s requirements to see if the generator
must submit a copy of the manifest to that state.
Numerous wastes are regulated as hazardous under Maryland’s regulations but not
federal regulations.
Storage Tanks
Underground storage tanks (USTs) :
MDOE — Oil Control Program
Baltimore, MD 21230
Phone: (410) 537-3000
Toll-free: (800) 633-6101
The Oil Control Program has highly trained staff to help owners ensure that their
Aboveground Storage Tanks (ASTs) are in compliance with state and federal regulations.
ASTs with capacities of 1,000 gallons of used oil or 10,000 gallons or more of virgin oil
are required to have oil operations permits issued by the Oil Control Program.
All regulated ASTs are required to have secondary containment, such as dikes. Other
requirements for regulated ASTs can be found in COMAR 26.10.01. The Oil Control
Program is available to assist in reviewing plans.
Should an AST leak, notify the Oil Control Program. Reporting leaks and cleaning them
up assures the protection of Maryland’s citizens and environment. For technical and
compliance information for ASTs, call: (410) 537-3442. The toll-free number is also
available for Maryland residents: 1-800-633-6101, then ask for the last four digits of the
above numbers.
To report oil spills call: 1-866-633-4686 (Available 24 hrs a day.)
MDOE
Public Information Act
Baltimore, MD 21230
Phone: (410) 537-3000


MDOE
Public Information Act
Baltimore, MD 21230
Phone: (410) 537-3000
Website: www.mde.maryland.gov/assets/document/crtk.pdf
Maryland requires the use of a federal Tier II form.
HazCom
Maryland incorporates by reference the federal regulations for hazard communication
(HAZCOM); however, the state adds further requirements regarding access to
information about hazardous and toxic substances. Contact the Maryland Division of
Labor and Industry at (410) 527-2091. Website: www.dllr.state.md.us/labor/mosh/.
Transportation
Maryland Department of Transportation
7201 Corporate Center Drive
Hanover MD 21076
Phone: (410) 865-1228
Website: www.mdot.maryland.gov
Massachusetts
Massachusetts Department of Environmental Protection
Massachusetts Department of Environmental Protection
One Winter Street
Boston, MA 02108
Phone: 617-292-5500
Website: www.mass.gov/dep
AIR
MDEP — Bureau of Waste Prevention
Air Program Planning Unit
One Winter Street
Boston, MA 02108
Phone: (617) 292-5520
Website: www.mass.gov/dep/about/organization/bwpprogs.htm
Water
MDEP
One Winter Street
Boston, MA 02108
NPDES Surface Water Permitting Contacts:
Individual NPDES permits:
Bryant.Firmin@state.ma.us
Phone: (508) 849-4003
Individual and general NPDES permits:
Kathleen.Keohane@state.ma.us
Phone: (508) 767-2856
Website: www.mass.gov/dep/water/


NPDES stormwater permits: (617) 292-5821
E-mail: Frederick.Civian@state.ma.us
Massachusetts EPA contact: David J. Gray (617) 918-1577
E-mail: dep.infoline@state.ma.us or gray.davidj@epa.gov
Or contact the DEPRegional Service Center near you: www.mass.gov/dep/water/
wastewater/stormwat.htm
Solid waste:
MDEP
One Winter Street
Boston, MA 02108
Phone: (617) 292-5500
Website: www.mass.gov/dep/
Hazardous waste:
MDEP
One Winter Street
Boston, MA 02108
Phone: (617) 292-5898
Website: www.mass.gov/dep/recycle/hazardous/hwgens.htm
Spill information:
To report a spill, call your local fire department and the Mass DEP toll-free 24-hour
statewide number at (888) 304-1133.
Complete and distribute forms according to the instructions on the manifest and use the
appropriate waste codes, including those for wastes that are regulated only by
Massachusetts (e.g. MA01 for waste oil).
If the hazardous waste shipment goes directly to a Massachusetts hazardous waste
facility, the generator does not have to submit a copy to MassDEP.
If the shipment goes directly to an out-of-state hazardous waste facility, the generator
must submit a fully executed photocopy of Copy 3 to MassDEP within 30 days of
receiving it from the designated facility.
Send MassDEP copies to:
MassDEP Bureau of Waste Prevention
Attention: MANIFEST
One Winter Street, 7th Floor
Boston, MA 02108
Phone: (617) 292-5500.
Storage Tanks
Massachusetts Department of Revenue UST Program
P.O. Box 9563
100 Cambridge Street, 7th floor
Boston, MA 02114-9563
Phone: (617) 626-2600
Website: www.mass.gov/?pageID=dorsubtopic&L=4&L0=Home&L1=Businesses&L2=
Programs+%26+Services&L3=Underground+Storage+Tank+Program+(UST)&sid=Ador


The AST regulations are currently enforced by the State Fire Marshal, and require
anyone constructing or installing new aboveground storage tanks to obtain a permit from
the Office of the State Marshal. The regulations also require that all such tanks have an
annual Use Permit issued by the marshal and be inspected no less than annually. Due to
the number of tanks across the state, the regulations require that the tank owner or
operator retain a qualified inspector for the required annual inspection.
MDEP — Bureau of Waste Prevention
Attn: John Fischer
One Winter Street
Boston, MA 02108
Phone: (617) 292-5632
E-mail: john.fischer@state.ma.us
Massachusetts Emergency Management Agency
400 Worcester Road (Route 9 Eastbound)
Framingham, MA 01702-5399
Phone: (508) 820-2000
Massachusetts requires the use of a federal Tier II form.
HazCom
Massachusetts follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
Massachusetts Department of Transportation
10 Park Plaza, Suite 4160
Boston, MA 02116
Phone: ( 617) 973-7000
Michigan
Michigan Department of Environmental Quality
Michigan Department of Environmental Quality
525 West Allegan Street
P.O. Box 30473
Lansing, MI 48909-7973
Toll-free: (800) 662-9278
Website: www.michigan.gov/deq
AIR
MDEQ — Air Quality Division
525 W. Allegan
Constitution Hall
3rd Floor N.
Lansing, MI 48933
Phone: (517) 373-7023
Website: www.michigan.gov/deq/0,1607,7-135-3310---,00.html

Water
MDEQ — Surface Water Quality Division
P.O. Box 30273
Lansing, MI 48909
Phone contact numbers:
Program Support Section (517) 335-1180
Enforcement Unit (517) 373-6437
Field Operations Section (517) 241-1313
Great Lakes and Environmental Assessment Section (800) 662-9278
Permits Section (517) 241-1346
Michigan has been delegated the regulatory authority to implement a storm water
discharge permit program for the state. For information on Michigan’s Storm Water
Program, write to:
MDEQ Surface Water Quality Division — Storm Water Program
P.O. Box 30438
Lansing, MI 48909
NPDES permits can be obtained through the Surface Water Quality Division Permits
Section:
525 W. Allegan
Constitution Hall
2nd Floor N.
Lansing, MI 48933
Phone: (517) 241-1346
Website: www.michigan.gov/deq/0,1607,7-135-3313_3682_3716---,00.html
Solid waste:
MDEQ — Waste Management Division
3rd Floor North Tower
Lansing, MI 48933
Phone: (517) 335-4035
Hazardous waste:
MDEQ — Waste Management Division
Lansing, Michigan 48933
Phone: (517) 373-9875
Spill information:
To report an environmental emergency situation, dial the 24 hour Pollution Emergency
Alert System (PEAS) - Environmental Response Division at: (800) 292-4706 (within
Michigan); or
(517) 373-7660 (outside Michigan).

Upon placing the waste into transportation, after the generator and first transporter
signs and dates manifest, make a legible copy and submit the copy to the Michigan
Department of Environmental Quality, Waste and Hazardous Materials Division no later
than the 10th day of the month following the shipment.
Beyond the hazardous waste listed by the EPA, the Michigan Department of
Environmental Quality has additional state-specific waste codes. These can be found in
the Hazardous Waste Management Program Administrative Rules promulgated pursuant
to Part 111, Hazardous Waste Management, of Michigan’s Natural Resources and
Environmental Protection Act, 1994 PA 451, as amended.
Phone: (517) 373-9875 to order this form.
Website: www.michigan.gov/documents/deq/deq-whm-hwp-uniform-manifest-
requirements_213003_7.pdf
Storage Tanks
MDEQ — Storage Tank Division
P.O. Box 30241
Phone: (517) 335-4035
Website: www.michigan.gov/deq/0,1607,7-135-3311_4115---,00.html
To view Michigan’s regulations regarding aboveground storage tanks, see this PDF:
http://www.deq.state.mi.us/documents/deq-ead-tas-astbroch.pdf
MDEQ — Environmental Assistance Division
State Emergency Planning and Community Right-to-Know
P.O. Box 30457
Lansing, MI 48909
Phone: (517) 373-8481
SARA Title III Program Office
MDEQ — Environmental Assistance Division
P.O. Box 30457
Phone: (517) 373-8481
Michigan requires the use of a federal Tier II form.
HazCom
Michigan incorporates by reference the federal regulations for Hazard communication;
however, the state adds further requirements. Find out more at www.michigan.gov/cis/
0,1607,7-154-11407---,00.html.

Transportation
Michigan Department of Transportation
State Transportation Building
425 W. Ottawa St.
P.O. Box 30050
Lansing, MI 48909
Phone: (517) 373-2090
Minnesota
Minnesota Environmental Quality Board
Minnesota Environmental Quality Board
658 Cedar St # 3
Saint Paul, MN 55155
Phone: (651) 296-9027
Website: www.epb.state.mn.us
AIR
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-4194
Phone: (651) 296-6300
Toll-free: (800) 657-3864
Website: www.pca.state.mn.us/index.php/air/index.html
Water
520 Lafayette Road
St. Paul, MN 55155-4194
Phone: (651) 296-6300
Toll-free: (800) 657-3864
Website: www.pca.state.mn.us/index.php/water/types-and-programs/index.html
Minnesota Pollution Control Agency (MPCA) has obtained permitting authority to
administer the federal National Pollutant Discharge Elimination System (NPDES)
program. For details on the Minnesota requirements for industrial and construction
activities, visit www.pca.state.mn.us/water/stormwater/index.html
520 Lafayette Road
St. Paul, MN 55155-4194
Phone: (651) 296-6300
Toll-free: (800) 657-3864
Website: www.pca.state.mn.us/index.php/waste/waste-and-cleanup/waste-management/
hazardous-waste/hazardous-waste.html
Spill information:
24-hour emergency number: (651) 649-5451 or (800) 422-0798
TTY 24-hour emergency number: (651) 297-5353 or (800) 627-3529

If you are a small or large quantity generator (SQG or LQG) of hazardous waste located
anywhere in Minnesota, send a copy of the initial manifest page to:
MPCA ATTN: HWIMS
520 Lafayette Road North
Saint Paul, MN 55155-4194
If you are a very small quantity generator (VSQG) located outside the seven-county
metropolitan area, the MPCA currently does not require you to submit copies; however,
make sure you retain the manifests for your records.
If you are a VSQG located in one of the following metropolitan area counties — Anoka,
Carver Dakota, Hennepin, Ramsey, or Washington — send a copy of the initial manifest
page to:
Hazardous Waste Manifest Program
Mail Code 609 300 South 6th Street
Minneapolis, MN 55487
If you are a VSQG located in Scott County, send a copy of the initial manifest page to:
Scott County Environmental Health
200 Fourth Ave. West
Shakopee, MN 55379-1220
Minnesota’s state specific waste codes are:
MN01- The waste exhibits the characteristics of lethality
MN02- The waste is a lab pack (a collection of small amounts of unrelated but
compatible chemicals shipped in one container)
MN03- Polychlorinated biphenyls (PCBs) at a concentration of 50 parts per million or
greater
MN04-Used oil that is not recycled or burned for energy recovery
Phone: Minnesota Bookstore (651) 297-3000 or (800) 657-3864
Beyond the hazardous waste listed by the EPA, the Michigan Department of
Environmental Quality has additional state-specific waste codes. These can be found in
the Hazardous Waste Management Program Administrative Rules promulgated pursuant
to Part 111, Hazardous Waste Management, of Michigan’s Natural Resources and
Environmental Protection Act, 1994 PA 451, as amended.
Storage Tanks
520 Lafayette Road
St. Paul, MN 55155-4194
Phone: (651) 296-6300
Toll-free: (800) 657-3864
Website: www.pca.state.mn.us/cleanup/ust.html
To view Minnesota’s regulations regarding aboveground storage tanks, see this website:
www.pca.state.mn.us/index.php/waste/waste-and-cleanup/waste-management/tank-
compliance-and-assistance/aboveground-storage-tanks-ast/aboveground-storage-tank-ast-
systems.html?menuid=&redirect=1


Minnesota Division of Security & Emergency Management
Emergency Planning and Community Right-to-Know (EPCRA) Program
444 Cedar Street, Suite 223
DEM phone: (651) 201-7416
Website: www.epcra.state.mn.us/
Minnesota Division of Security & Emergency Management
Emergency Planning and Community Right-to-Know (EPCRA) Program
444 Cedar Street, Suite 223
DEM phone: (651) 201-7416
Website: www.epcra.state.mn.us/
Minnesota requires the use of a state Tier II form. There is a fee for filing.
HazCom
Minnesota’s state requirements regarding hazard communication (HAZCOM) include a
substantial amount of regulatory information beyond the federal requirements. Find out
more at www.dli.mn.gov/MnOsha.asp.
Transportation
Minnesota Department of Transportation
395 John Ireland Boulevard
Saint Paul, MN 55155
Phone: (651) 296-3000
Website: www.dot.state.mn.us
Mississippi
Mississippi Department of Environmental Quality
Mississippi Department of Environmental Quality
515 East Amite Street
Jackson, MS 39201
Phone: (601) 961-5171
Website: www.deq.state.ms.us
AIR
MS Office of Pollution Control Air Division
Jackson, MS 39201
Phone: (601) 961-5165
Website: www.deq.state.ms.us/Mdeq.nsf/page/Air_Homepage?OpenDocument
Water
MS Central Regional Office
1542 Old Whitfield Rd.
Pearl, MS 39208
Phone: (601) 961-5159
Website: www.deq.state.ms.us/MDEQ.nsf/page/SurfaceWater_home?OpenDocument


Under the MDEQ Office of Pollution Control, the Surface Water Division is approved to
administer the NPDES permit program. For more information, visit the MDEQ website
at www.deq.state.ms.us/MDEQ.nsf/page/epd_epdgeneral?OpenDocument.
Solid waste:
515 Amite St
Jackson, MS 39201
Ethan Mayeu – Chief of the Solid Waste & Mining Branch
Phone: (601) 961-5613
Website: www.deq.state.ms.us/MDEQ.nsf/page/ECED_SolidWaste_Mining?OpenDocument
Hazardous waste:
Jackson, MS 39201
Website: www.deq.state.ms.us/MDEQ.nsf/page/Cleanup_HazardousWaste?OpenDocument
Spill information:
To report a hazardous materials incident, call the Mississippi Emergency Management
Agency, 24 hours, at (601) 352-9100 or (800) 222-MEMA (6362).
Use the federal Uniform Hazardous Waste manifest form.
Storage Tanks
Mississippi Underground Storage Tank Branch
Jackson, MS 39201
Phone: (601) 961-5142
Website: www.deq.state.ms.us/MDEQ.nsf/page/UST_PageHome?OpenDocument
In Mississippi, all aboveground storage tanks (ASTs) are regulated by EPA Region 4’s
Emergency Response Program. Mississippi has no specific AST regulations. However,
Mississippi incorporates the Southern Building Code Congress International (SBCCI)
standard fire prevention code and references the National Fire Prevention Association
(NFPA) Code 30 and NFPA Code 30A for oil storage on state facilities. SBCCI generally
only applies to ASTs located in state buildings or in places of public assembly.
Most local authorities regulate ASTs on public property. Local rules must be at least as
stringent as the state code. Most local authorities in Mississippi have adopted the SBCCI
code as part of their local building code.
Mississippi Emergency Response Commission
1410 Riverside Dr.
Jackson, MS 39202-1297
OR
Mississippi Emergency Management Agency
P.O. Box 5644
Pearl, MS 39288
Phone: (601) 352-9100
Website: www.msema.org/


Mississippi Emergency Response Commission
#1 MEMA Drive
Pearl, MS 39208
OR
Mississippi Emergency Management Agency
P.O. Box 5644
Pearl, MS 39288
Phone: (601) 933-6362
24-hours: (800) 222-MEMA (6362)
Mississippi requires the use of a federal Tier II form.
Website: www.msema.org
HazCom
Mississippi follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
MS Department of Transportation
401 North West Street
Jackson, MS 39201
Phone: (601) 359-7001
Website: www.gomdot.com
Missouri
Missouri Division of Environmental Quality
P.O. Box 176
Jefferson City, MO 65102
Phone: (800) 361-4827 or (573) 751-0763
E-mail: environmental@dnr.mo.gov
Website: www.dnr.mo.gov.env
AIR
MO Department of Natural Resources
Air Pollution Control Program
P. O. Box 176
Phone: (800) 361-4827 or (573) 751-4817
Website: www.dnr.mo.gov/env/apcp/index.html
Water
Missouri Department of Natural Resources, Water Protection and Soil
Conservation Division
Water Pollution Control Branch, P. O. Box 176
Phone: (800) 361-4827 or (573) 751-1300
E-mail: cleanwater@dnr.mo.gov
Website: http://www.dnr.mo.gov/env/wpp/index.html


Water pollution control stormwater permits for construction and industrial activities can
be obtained from the Water Pollution Control Program, Permit Section, at (573) 751-1300
or (800) 361-4827. For more information on storm water permits in Missouri, visit http://
www.dnr.mo.gov/env/wpp/permits/index.html. E-mail: cleanwater@dnr.mo.gov
Solid waste:
Missouri Department of Natural Resources Air and Land Protection Division — Solid
Waste Management Program
P. O. Box 176
Phone: (800) 361-4827 or (573) 751-4932
Email: soils@dnr.mo.gov Website: http://www.dnr.mo.gov/env/swcp/index.html
Hazardous waste:
Missouri Department of Natural Resources Air and Land Protection Division Hazardous
Waste Program
P.O. Box 176
Phone: (800) 361-4827 or (573) 751-3176
E-mail: hazwaste@dnr.mo.gov
Website: http://www.dnr.mo.gov/env/hwp/index.html
Spill information:
Report an environmental emergency by calling (573) 634-2436.
Generators and Treatment, Storage, and Disposal Facilities must follow the manifest
distribution outlined in the federal register. Send the appropriate page of the manifest
to: Missouri Department of Natural Resources. Contact Missouri At Your Service directly
at (800) 361-4827, OR Contact Jennifer Johnson at (573) 751-7560.
Storage Tanks
Department of Natural Resources Air and Land Protection Division Hazardous Waste
Program
P. O. Box 176
Tanks Section: (573) 751-6822; Field Services Division: (800) 361-4827
E-mail: hazwaste@dnr.mo.gov
Website: http://www.dnr.mo.gov/env/hwp/tanks/tanks.htm
The operation of above ground storage tanks is not regulated by the Missouri
Department of Natural Resources. For information about regulation and inspection of
above ground storage tanks, contact the Missouri Department of Agriculture, 573-751-
5636. Petroleum releases from above ground storage tanks must be managed using the
Missouri Risk-Based Corrective Action Process for Petroleum .


State designated Section 313 contact (Form R submissions) Missouri Department of
Natural Resources Outreach and Assistance Center Environmental Assistance Office
P.O. Box 176 Jefferson City, MO 65102
Phone: (573) 751-3443 or (800) 361-4827
E-mail: energy@dnr.mo.gov
Website: http://www.dnr.mo.gov/energy/renewables/re-conference.htm
Missouri Emergency Response Commission
2302 Militia Dr. P.O. Box 3133 Jefferson City, MO 65102
Phone: (800) 780-1014
Website: http://hazmat.dps.mo.gov
Missouri requires the use of a state Tier II Form and there is a fee for filing. Missouri
facilities submit forms to the Missouri Emergency Response Commission, their local
emergency planning committee, and the fire department/district with jurisdiction for
their facility.
HazCom
Missouri follows the federal OSHA safety and health program requirements for HazCom.
Transportation
MO Department of Transportation
1711 Highway 61 S
Hannibal, MO 63401
Phone: (573) 248-2490
Website: www.modot.mo.gov
Montana
Montana Department of Environmental Quality
Montana Department of Environmental Quality
1100 N Last Chance Gulch
Helena, MT 59620
Phone: (406) 841-5000
Website: www.deq.mt.gov
AIR
MDEQ — Permitting and Compliance Division
Air and Waste Management
Lee Metcalf Building
Main Office: 1520 E. Sixth Avenue P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-3490
Website: www.deq.mt.gov/AirQuality/AQinfo.mcpx

Water
MDEQ — Permitting and Compliance Division
Water Protection
Main Office 1520 E. Sixth Avenue P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-6763
Website: www.deq.mt.gov/wqinfo/default.mcpx
Under the Permitting and Compliance Division of the Montana DEQ, the Water
Protection Bureau was formed to prevent surface and ground water pollution by review
of the potential sources of pollution and issuance of Montana Pollutant Discharge
Elimination System Permits.
Further detail on the MPDES Program can be found at www.deq.mt.gov/wqinfo/mpdes/
default.mcpx.
The Water Quality Standards and Classifications DEQ staff contact is Tom Reid:
Water Quality Discharge Permit Section- MDEQ — Permitting and Compliance Division
1520 E. Sixth Avenue P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-5329
E-mail: Toreid@mt.gov
Solid waste: MDEQ — Permitting and Compliance Division
Community Services Bureau
Main Office 1520 E. Sixth Avenue P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-2544
Website: deq.mt.gov/SolidWaste/default.mcpx
Hazardous waste: MDEQ — Permitting and Compliance Division
Air and Waste Management
Main Office: 1520 E. Sixth Avenue
P.O. Box 200901
Helena, MT 59620-0901
Phone: (406) 444-2876
Website: http://deq.mt.gov/HazWaste/index.asp
Spill information:
Spills must be reported immediately to Montana’s Disaster and Emergency Services
Division (DES) 24-hour phone number (406) 841-3911. If no one can be reached at that
number, the spill may be reported to the Montana Department of Environmental Quality
(DEQ) duty officer at (406) 431-0014.
Generators and Treatment, Storage, and Disposal Facilities must follow the manifest
distribution outlined in the Montana does not require manifest copies submitted to the
state.
No Montana Specific waste codes are required for Montana.
Phone: Contact Robert D. Reinke at (406) 444-1435 or Breinke@mt.gov for information
regarding hazardous waste manifests.

Storage Tanks
Underground storage tanks (USTs) and Leaking USTs :
Montana Department of Environmental Quality Remediation Division
Technical Services Bureau, Environmental Services Section
Underground Storage Tank (UST) Leak Prevention Program
Physical address: 1100 N. Last Chance Gulch
Helena, MT 59601
Mailing address: P.O. Box 200901
Helena, MT 59602-0901
Phone: (406) 841-5000
Report a spill by calling the Leak Line at (800) 457-0568 or (406) 841-3941 (after hours
and holidays). Website: www.deq.mt.gov/rem/default.mcpx
To view Montana’s regulations regarding aboveground storage tanks, see this website:
www.deq.mt.gov/dir/legal/Chapters/Ch57-01.pdf
MT Emergency Response Commission DEQ
Attn: Tom Ellerhoff
Helena, MT 59620-0901
Phone: (406) 444-6780
E-mail: tellerhoff@mt.gov
MT Emergency Response Commission DEQ
Attn: Tom Ellerhoff
Helena, MT 59620-0901
Phone: (406) 444-6780
E-mail: tellerhoff@mt.gov
Minnesota requires the use of a state Tier II form. There is a fee for filing.
HazCom
Montana follows the federal OSHA safety and health program requirements for HazCom.
Transportation
Montana Department of Transportation
2701 Prospect Avenue
Helena, MT 59620-1001
Phone: (406) 444-6201
Website: www.mdt.mt.gov

Nebraska
Nebraska Department of Environmental Quality
Nebraska Department of Environmental Quality
1200 “N” Street
Suite 400 P.O. Box 98922
Lincoln, NE 68509
Phone: (402) 471-2186
Website: www.deq.state.ne.us
AIR
NDEQ — Air and Waste Management Division
1200 “N” Street
Suite 400 PO Pox 98922
Lincoln, NE 68509
Phone: (402) 471-2186
Website: www.deq.state.ne.us/NDEQSite.nsf/Section
Water
NDEQ — Water Quality Division
1200 “N” Street
Lincoln, NE 68509
Phone: (402) 471-2186
NPDES permits are handled by the Permits and Compliance Section of the Water
Quality Division. Website: http://www.deq.state.ne.us/NDEQSite.nsf/Section
Solid waste: NDEQ — Air and Waste Management Division
1200 “N” Street
Lincoln, NE 68509
Phone: (402) 471-2186
Hazardous waste: NDEQ — Air and Waste Management Division
1200 “N” Street
Lincoln, NE 68509
Phone: (402) 471-2186
Spill information:
To report emergencies during business hours, call (402) 471-7430 or (402) 471-7251.
To report emergencies during non-business hours, call (402) 471-4545 (State Patrol
Dispatch).
Phone: (402) 471-2186 for information regarding hazardous waste manifests.

Storage Tanks
NDEQ — Leaking Underground Storage Tank/Emergency Response Section
1200 “N” Street
Lincoln, NE 68509
Phone: (402) 471-2186
An owner or operator of permanently located aboveground storage tanks dispensing
hazardous substances must register such tank with the NE State Fire Marshal. Storage
tanks of 1000 gallons or less are exempt from this requirement.
A registration form must be completed for each tank and sent to this office with a check
or money order for the registration fee - $10 per tank. Any changes in the registration
require a new registration form to be submitted with a check or money order for $10 per
tank that is to be changed.
Petroleum Products Owners/operators of aboveground storage tanks storing petroleum
products must obtain an installation permit to install new and replacement tanks and
piping installations. An application must be submitted to the State Fire Marshal and be
accompanied by a detailed site plan and $50 inspection fees at least 10 working days
prior to the proposed installation date. The fee is per installation regardless of the
number of tanks to be installed. Once the permit is issued, at least 72-hour notification
of the date and time of installation must be given to the Fuels Division – FLST Section.
Website: www.sfm.ne.gov/programs-services/fuels/flst/ast.html
NDEQ
1200 “N” Street
Suite 400 PO Box 98922
Lincoln, NE 68509
Phone: (402) 471-2186
For more information E-mail: Pubinfo@mail.deq.state.ne.us
NDEQ
1200 ″N″ Street
Suite 400 PO Box 98922
Lincoln, NE 68509
Phone: (402) 471-2186
For more information E-mail: Pubinfo@mail.deq.state.ne.us
Nebraska requires the use of a state Tier II form.
HazCom
Nebraska follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
Nebraska Department of Roads
Director and Deputy Directors Office
Phone: (402) 479.4615
Website: www.nebraskatransportation.org

Nevada
Nevada Division of Environmental Protection
Nevada Division of Environmental Protection
901 South Stewart Street,
Suite 4001
Carson City, NV 89701–5249
Phone: (775) 687–4670
Website: www.ndep.nv.gov
AIR
NDEP — Bureau of Air Quality
901 South Stewart St.,
Suite 4001
Carson City, NV 89701-5249
Phone: (775) 687-9349
Website: http://ndep.nv.gov/bapc/index.htm
Water
NDEP — Bureau of Water Pollution Control
901 South Stewart St.,
Suite 4001
Phone: (775) 687-9418
Website: www.ndep.nv.gov/bwpc/bwpc01.htm
In compliance with EPA stormwater regulations, the NDEP has issued three baseline
general permits. Procedures to obtain stormwater discharge permits can be viewed at
http://ndep.nv.gov/bwpc/storm01.htm
For further information, contact NDEP’s Carson City office at (775) 687-9429 or a
stormwater attendant at (775) 687-9430.
Stormwater Coordinator Bureau of Water Pollution Control Nevada Division of
Environmental Protection
901 S. Stewart St.,
Suite 4001
Solid waste: NDEP — Bureau of Waste Management Solid Waste Branch
901 S. Stewart St.,
Suite 4001
Phone: (775) 687-4670
Website: ndep.nv.gov/bwm/solid.htm
Hazardous waste: NDEP — Bureau of Waste Management Hazardous Waste
Management Program
901 S. Stewart St.,
Suite 4001
Phone: (775) 687-4670
Website: http://ndep.nv.gov/bwm/hazard.htm

Spill information:
Hazardous materials emergency: (888) 331-NDEP (6337)
Outside of Nevada: (775) 687-9485
For information on state reporting requirements, when to call, who to call, or
information on data, call the Bureau of Corrective Actions at (775) 687-9368 (8:00 – 5:00
PST).
Website: http://ndep.nv.gov/bca/spil_rpt.htm
Use the federal Uniform Hazardous Waste Manifest form. (Nevada accepts any properly
filled out state manifest form.)
Contact: Mike Verchick
Phone: (702) 486- 2850 Ext. 239
Storage Tanks
NDEP — Bureau of Corrective Actions Underground Storage Tank Program
901 S. Stewart St.,
Suite 4001
Phone: (775) 687-9368
Website: http://ndep.nv.gov/bca/ust_home.htm
A number of different state and federal regulations regulate aboveground storage tanks
(ASTs), depending on size, location, use of tank, and product stored. Nevada does not
have any specific AST requirements. The exception is with regard to AST systems located
at or near water located at a marina. Owners and operators of marina ASTs must
register the tanks with DEP and pay a registration fee.
The state has adopted National Fire Code and the NFPA Codes 30 and 30A and other
standards related to the design, construction, and safe operation of ASTs. See the
national section ABOVEGROUND STORAGE TANKS for an overview of NFPA codes and
other industry standards applicable to ASTs.
Nevada State Emergency Response Commission
2621 Northgate Ln., Suite 10
Carson City, NV 89706
Phone: (775) 687-6973
Website: http://ndep.nv.gov/bwm/hazard05.htm or http://serc.nv.gov/
Nevada State Emergency Response Commission
2621 Northgate Lane, Suite 10
Carson City, NV 89706
Phone: (775) 687-6973
Website: http://ndep.nv.gov/bwm/hazard10.htm
Nevada requires use of a state Tier II form and there is a fee for filing.
HazCom
Nevada incorporates by reference the federal regulations for hazard communication

Transportation
Nevada Department of Transportation
1263 South Stewart Street
Carson City, Nevada 89712
Phone: 775-888-7000
E-mail: info@dot.state.nv.us
Website: www.nevadadot.com
New Hampshire
New Hampshire Department of Environmental Services
New Hampshire Department of Environmental Services
29 Hazen Dr
Concord, NH 03301
Phone: (603) 271-3503
Website: www.des.nh.gov
AIR
NHDES — Air Resources Division
29 Hazen Drive
P.O. Box 95
Concord, NH 03302-0095
Phone: (603) 271-1370
Website: des.nh.gov/organization/divisions/air/index.htm
Water
NHDES — Watershed Management Bureau
29 Hazen Drive
P.O. Box 95
Phone: (603) 271-3289
Website: des.nh.gov/organization/divisions/water/wmb/index.htm
For state storm water general information, call (603) 271-8475.
For state storm water regulations/permits, call (603) 271-2984.
Stormwater information is online at http://des.nh.gov/organization/divisions/water/
stormwater/index.htm
Solid waste: NHDES — Solid Waste Technical Assistance Section
29 Hazen Drive
P.O. Box 95
Phone: (603) 271-2900
Website: des.nh.gov/organization/divisions/waste/index.htm
Hazardous waste: NHDES — Site Remediation Programs
29 Hazen Drive
PO Box 95
Phone: (603) 271-3744
Website: des.nh.gov/organization/divisions/waste/hwrb/index.htm

Spill information:
Hazardous materials emergency: Between 8 a.m. and 4 p.m., Monday - Friday, call (603)
271-3899.
Evenings and weekends, call the New Hampshire State Police Hazardous Materials
Number at (800) 346-4009.
Petroleum Spills: Between 8 a.m. and 4 p.m., Monday – Friday, call (603) 271-3899.
Evenings and weekends, call the New Hampshire State Police Hazardous Materials
Number at (800) 346-4009.
New Hampshire will require the NH generator to make a photocopy of page 6 of the
manifest and submit it to:
NH Dept. of Environmental Services
Waste Management Division-RIMS
PO Box 3900 Concord NH 03302-3900
If the destination state where your waste is being disposed of requires a copy of the
manifest, you, as the New Hampshire generator, will be required to make a photocopy of
page 6 of the manifest and submit that to the destination state.
New Hampshire has specific waste codes to be used on the new manifests to classify
exemptions.
NHX1 - Instead of Recycling Exempt
NHX2 - Instead of Household Hazardous Waste Exempt
NHX3 - Instead of Remediation
NHX4 - Instead of Sludge Exempt
NHX5 - Instead of MSW Ash Exempt
NHX6 - Instead of Shooting Range Exempt
Call (603) 271-2942 for manifesting and reporting requirements.
For more information on manifests in New Hampshire, visit des.nh.gov/organization/
divisions/waste/swmb/rims/faq_manifest.htm
Storage Tanks
Underground storage tanks (USTs) and leaking USTs:
NHDES — Oil Remediation and Compliance Bureau
29 Hazen Drive
Concord, NH 03301
Phone: (603) 271-3899
Website: des.nh.gov/organization/divisions/waste/orcb/ocs/ustp/index.htm
The Aboveground Storage Tank Program is designed to prevent releases of oil from
Aboveground Petroleum Storage Tanks (ASTs) in New Hampshire. Petroleum ASTs are
regulated by both the Department of Environmental Services (DES) and the New
Hampshire Fire Marshal’s Office. DES established rules for petroleum ASTs in April
1997. The rules entitled Control of Aboveground Petroleum Storage Facilities (Env-Wm
1402) with revision effective May 28, 2005 can be downloaded below. These rules apply
to:
Facilities with a single AST system having a capacity greater than 660 gallons, or
Facilities with two or more ASTs that have a total storage capacity greater than 1,320
gallons

(Note: ASTs with a combined capacity of 1,320 gallons or less storing fuel oil (not used oil
or waste oil) used only to heat an on-premise structure are exempt. This includes home
heating oil tanks.) For further information regarding New Hampshire’s aboveground
storage tank regulations, visit the following link: des.nh.gov/organization/divisions/waste/
orcb/ocs/astp/index.htm
New Hampshire State Emergency Management Agency
Title III Program Incident Planning and Operations Center
110 Smokey Bear Blvd
Concord, NH 03301
Phone: (603) 271-2231
Toll-free: (800) 852-3792
Website: www.nh.gov/safety/divisions/bem/index.html
New Hampshire Department of Safety
Homeland Security and Emergency Management Headquarters
Location: Incident Planning and Operations Center
110 Smokey Bear Blvd
Concord, NH 03301
Mailing address: New Hampshire Department of Safety Division of Fire Safety &
Emergency Management
Bureau of Emergency Management
33 Hazen Drive
Concord, NH 03305
Phone: (603) 271-2231
Toll-free: (800) 852-3792 (in New Hampshire)
Website: www.nh.gov/safety/divisions/bem/index.html
New Hampshire requires the use of a state Tier II form.
HazCom
New Hampshire follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
New Hampshire Department of Transportation
19 Base Hill Road
Keene, NH 03431
Phone: (603) 352-2302
Website: www.nh.gov/dot/
New Jersey
New Jersey Department of Environmental Protection
New Jersey Department of Environmental Protection
401 E. State St. 7th Floor,
East Wing P.O. Box 402
Trenton, NJ 08625-0402
Website: www.state.nj.us/dep/

AIR
NJ DEP — Bureau of Air Quality Planning
401 East State Street,
2nd Floor P.O. Box 027
Phone: (609) 292-6710
Website: www.nj.gov/dep/daq/
Water
NJ DEP — Division of Water Quality
Mail Code 401-02B
P.O. Box 420
401 E. State Street
Phone: (609) 292-4543
Website: www.nj.gov/dep/dwq/
NJDEP-DWQ Bureau of Nonpoint Pollution Control — Division of Water Quality
Mail Code 401-02B
401 E. State Street, 3rd Floor P.O. Box 420
Phone: (609) 292-0407
The Bureau of Nonpoint Pollution Control regulates the discharge of stormwater and
ground water to waters of the state. Website: http://www.nj.gov/dep/dwq/bnpc_home.htm
Solid waste: NJ DEP Protection Division of Solid and Hazardous Waste —
Bureau of Solid Waste Regulation
P.O. Box 414
401 East State Street, 2nd Floor
Phone: (609) 633-1418
Website:www.nj.gov/dep/dshw/
Hazardous waste: NJ DEP Division of Solid and Hazardous Waste — Bureau of
Hazardous Waste Regulation
P.O. Box 423
401 East State Street, 3rd Floor
Phone: (609) 292-2795
Website: www.nj.gov/dep/enforcement/shwr.html
Spill information:
For Emergency Response or to Report an Environmental Abuse, call the 24-Hour Hotline
at 1-877-WARNDEP (1-877-927-6337). This number can be used in the New Jersey, New
York, Pennsylvania, and Delaware calling areas.
For other hotlines, go to www.nj.gov/dep/warndep.htm.

New Jersey does not require submittal of generator copies.
Submit the Designated Facility to Destination State and Designated Facility to
Generator State copies (copy 1 and 2, respectively) of the manifest to: New Jersey
Department of Environmental Protection Division of Solid & Hazardous Waste,
Compliance & Enforcement
Trenton, NJ, 08625-0422
PO Box 0422
Phone: (609) 292-7081
Storage Tanks
NJ DEP Bureau of Underground Storage Tanks
P.O. Box 402
General questions: (609) 984-3081
UST Operational issues: Jonathan Berg (609) 633-0737
Website: www.nj.gov/dep/srp/bust/bust.htm
For information regarding New Jersey’s aboveground storage tank regulations, view the
following PDF: http://www.nj.gov/dep/rpp/brp/dp/downloads/
DPHS_Tank_Testing_Guide_2010.pdf
State designated Section 313 contact (Form R submissions)
EPCRA Section 313 NJDEP
Bureau of Release Prevention
22 S. Clinton Ave., 3rd Floor
P.O. Box 424
Phone: (609) 633-0610
Website: www.nj.gov/dep/rpp/brp/
NJDEP Pollution Prevention & Right to Know
22 S. Clinton Ave., 3rd Floor
Mail Code 22-036
P.O. Box 420
Phone: (609) 777-0518
(Main Number) (609) 292-6714 (Community Right-to-Know)
Website: www.nj.gov/dep/opppc/index.html
New Jersey requires a Community Right to Know Survey Release and Prevention
Report.
HazCom
New Jersey follows the federal OSHA safety and health program requirements for this
topic for private sector employees. Public sector employees are covered under the New
Jersey PEOSH (state plan) program.

Transportation
New Jersey Department of Transportation
P.O. Box 600
Website: www.state.nj.us
New Mexico
New Mexico Environment Department
New Mexico Environment Department
1190 S Saint Francis Dr
Santa Fe, NM 87505
Phone: (505) 476-8600
Website: www.nmenv.state.nm.us
AIR
NMED — Air Quality Bureau
1301 Siler Road, Building B
Santa Fe, NM 87507
Phone: (505) 476-4300
Website: www.nmenv.state.nm.us/aqb/
Water
NMED — Surface Water Quality Bureau
Harold Runnels Building
Room N2050 1190 St. Francis Drive
Santa Fe, NM 87505
Phone: (505) 827-0187
Regional Offices…
Albuquerque Office: 5500 San Antonio
Phone: (505) 222-9500
Las Cruces Office: 1170 N. Solano Dr., Suite M
Phone: (575) 647-7926
Las Vegas Office: 2538 Ridge Runner Rd.
Phone: (505) 454-2810
Silver City Office: 3082 32nd St. Bypass - Suite D
Phone: (575) 388-1934
Website: www.nmenv.state.nm.us/SWQB/


Solid waste: NMED — Solid Waste Bureau
Harold Runnels Building, Room S2050
1190 Saint Francis Drive P.O. Box 5469
Santa Fe, NM 87502-5469
Phone: (505) 827-0197
Website: www.nmenv.state.nm.us/SWB/
Hazardous waste: NMED — Hazardous and Radioactive Materials Bureau
2905 Rodeo Park Drive East Building 1
Santa Fe, NM 87505
Phone: (505) 476-6000
Website: www.nmenv.state.nm.us/hwb
Spill information:
Hazardous materials emergency: (505) 827-9329.
New Mexico does not require copies of hazardous waste manifests be submitted to the
State unless specifically requested to do so by the New Mexico Environment Department
Hazardous Waste Bureau (for example, as follow-up to a hazardous waste inspection).
If hazardous waste manifests are requested by Hazardous Waste Bureau personnel, the
copies should be submitted by mail to:
NMED Hazardous Waste Bureau
2905 Rodeo Park Drive East, Bldg. 1
Santa Fe, NM 87505
New Mexico has not designated any State-specific waste codes. Only the federal waste
codes are required on hazardous waste shipping manifests. For more information,
contact: Art Vollmer Phone: 505-476-6000
E-mail: art.vollmer@state.nm.us
Storage Tanks
New Mexico Environment Department Petroleum Storage Tank Bureau
1301 Siler Road Bldg. B
Santa Fe, NM 87507
Phone: (505) 476-4397
Website: www.nmenv.state.nm.us/ust/ustbtop.html
For information regarding New Mexico’s aboveground storage tank regulations, visit the
following link: www.nmenv.state.nm.us/ust/asts.htm
New Mexico Emergency Response Commission
Department of Public Safety Office of Emergency Management
13 Bataan Blvd.
Santa Fe, NM 87504
Phone: (505) 476-9600
Website: www.dps.nm.org/divisions/emergency/index.php


New Mexico Emergency Response Commission
Department of Public Safety Office of Emergency Management
13 Bataan Blvd.,
Santa Fe, NM 87504
Phone: (505) 476-9600
Website: www.dps.nm.org/divisions/emergency/index.php
There is a fee for filing the Tier II form in New Mexico.
HazCom
New Mexico incorporates by reference the federal regulations for hazard communication
(HAZCOM); however, the state adds further requirements. Find out more at www.nmenv.
state.nm.us/Ohsb_Website/index.htm
Transportation
New Mexico Department of Transportation
1120 Cerrillos Road
Santa Fe, NM 87504-1149
Phone: (505) 827-5100
Website: www.dot.state.mn.us
New York
New York Department of Environmental Conservation
New York Department of Environmental Conservation
5917 Junction Blvd # 19
Flushing, NY 11373
Phone: (718) 595-7000
Website: www.nyc.gov/dep/
AIR
NYDEC — Division of Air Resources
625 Broadway
Albany, NY 12233-3250
Phone: (518) 402-8452
Website: www.dec.ny.gov/chemical/281.html
Water
NYDEC — Division of Water Resources
625 Broadway
Albany, NY 12233-3500
Phone: (518) 402-8233
New York has a state program, approved by EPA, known as the State Pollutant
Discharge Elimination System (SPDES). New York’s program is broader in scope than
the federal program in that it controls point source discharges to groundwaters as well
as surface waters. For more information, contact the Bureau of Water Permits at: (518)
402-8111.


Solid waste: NYDEC — Division of Solid and Hazardous Materials
Solid Waste Management Program
625 Broadway 9th Floor
Albany, New York 12233-7250
Phone: (518) 402-8706
Hazardous waste: NYDEC -- Hazardous Waste Management
625 Broadway
Albany, NY 12233-7012
Phone: (518) 402-9764
Spill information:
24-hour emergency release reporting number: (800) 457-7362
In New York, the waste Generator will need to make additional copies of the manifest
form. They will need to make copies for “Generator State — Mailed by Generator” and
“Disposer State - Mailed by Generator” as necessary and submit them to the Generator
or Disposer State.
Additionally, if a TSDF rejects a waste shipment back to the original Generator or
rejects-on to a secondary TSDF, the Generator or secondary TSDF will sign Block 18c to
certify receipt of the rejected waste. Once signed in Block 18c, a copy of this form also
needs to be submitted to NYS DEC.
Hazardous Waste Manifest forms submitted to NYS DEC must be postmarked within 10
days of waste shipment for the generator within 10 days of waste receipt for TSDFs.
Generators must complete Block 13 Waste Codes. They may designate up to, but not
more than, six Waste Codes. If applicable, NYS DEC’s “B” type Waste Codes for PCB
wastes must be used.
Phone: (518) 402-8730
Storage Tanks
NYDEC Division of Environmental Remediation
Bureau of Spill Prevention and Response
625 Broadway
Albany, NY 12233-7020
Phone: (518) 402-9543
For information on tanks and bulk storage, call the bulk storage help-line: (518) 402-
9543
In 1983, the State Legislature enacted Article 17, Title 10 of the Environmental
Conservation Law, entitled “Control of the Bulk Storage of Petroleum.” The Law applies
both to Underground Storage Tanks (USTs) and Aboveground Storage Tanks (ASTs), or
groupings of such tanks with a combined storage capacity of more than 1,100 gallons.
Exempted from this law because they are regulated under other programs are: oil
production facilities; facilities licensed under the Navigation Law; and, facilities
regulated under the Natural Gas Act.

Under the regulations (6NYCRR 612-614) promulgated in 1985, owners are required to
register storage facilities with DEC. Facilities must be re-registered every five years.
Registration fees vary from $100 to $500 per facility, depending on capacity.
NYDEC Pollution Prevention Unit
625 Broadway
Albany, NY 12233-7020
Phone: (518) 402-9553
New York Emergency Response Commission
1220 Washington Ave., Bldg. 22, Suite 101
Albany, NY 12226-2251
Phone: (518) 292-2301
Emergency Coordination Center (staffed 24 hours): (518) 292-2200
Website: www.semo.state.ny.us/programs/SERC/serc.cfm
New York has its own form and a fee is required.
HazCom
New York follows the federal OSHA safety and health program requirements for this
topic for private sector employees. Public sector employees are covered under the New
York PESH (state plan) program. Click the link(s) below to view the federal
requirements.
Transportation
New York Department of Transportation
Borough Commissioner Margaret Forgione
Phone: (212) 839-6210
Website: www.nyc.gov/dot/
North Carolina
North Carolina Department of Environment and Natural Resources
North Carolina Department of Environment and Natural Resources
217 W. Jones St.
Raleigh, NC 27699-1601
Toll-free: (877) 623-6748
Website: www.ncdenr.org
AIR
NCDOENR — Division of Air Quality
1641 Mail Service Center
Phone: (919) 733-3340
Website: daq.state.nc.us/

Water
NCDOENR — Division of Water Management
Mailing address: 1617 Mail Service Center
Street address: 512 N. Salisbury St.
Raleigh, NC 27604
Phone: (919) 807-6457
Website: portal.ncdenr.org/web/wq
In North Carolina, NPDES permits are issued by the Water Quality Section of the
Division of Water Quality. Details of the program can be viewed at http://portal.ncdenr.
org/web/wq/ws/su
Solid waste: NCDOENR Division of Waste Management Solid Waste Section
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: (505) 827-0197
Phone: (919) 508-8400
Website: http://portal.ncdenr.org/web/wm/
Hazardous waste: NCDOENR Division of Waste Management Hazardous Waste
Section
401 Oberlin Road, Suite 150
Raleigh, NC 27605
Phone: (919) 508-8400
Website: http://portal.ncdenr.org/web/wm/
Spill information:
Hazardous materials emergency: 24-hour number: (800) 858-0368 or (919) 733-3300
The State of North Carolina does not require the submission of manifest copies.
North Carolina does not have state specific waste codes.
Phone: Helen Cotton at (919) 508-8537 for information regarding hazardous waste
manifests.
E-mail: helen.cotton@ncdenr.gov
Storage Tanks
NCDOENR Division of Waste Management UST Section
1646 Mail Service
Center Raleigh, NC 27699-1637
Phone: (919) 733-1321
Website: http://portal.ncdenr.org/web/wm/ust
Aboveground storage tank construction standards are addressed in the North Carolina
Building Code, Chapter 22 of the North Carolina Fire Code and the National Fire
Protection Association Standard 30 and 30A (NFPA 30 and NFPA 30A). Currently, no
DENR environmental regulations exist for installation, construction, permitting or
monitoring of ASTs.
Questions regarding AST construction standards should be directed to the local and/or
county fire prevention departments where the AST is being installed.

The North Carolina Department of Insurance, Office of State Fire Marshal may also be
contacted for questions at (919) 661-5880.
For more information regarding North Carolina’s regulations on aboveground storage
tanks, visit this website: portal.ncdenr.org/web/wm/ust/astmain
North Carolina Emergency Response Commission
Division of Emergency Management Regional Response Team
Phone: (919) 733-3867 or (919) 715-0465
Website: www.nccrimecontrol.org/Index2.cfm?a=000003,000010
North Carolina Emergency Response Commission
EPCRA Division of Emergency Management
Attn: Tier II Reports
Phone: (800) 451-1403 or (919)733-1361
Websites: www.nccrimecontrol.org/Index2.cfm
North Carolina requires the use of a federal Tier II form. There is a fee for filing.
HazCom
North Carolina incorporates by reference the federal regulations for hazard
communication except for the following: 1910.1200(b)(6)(ii) is amended to read: “Any
hazardous substance as such term is defined by the Comprehensive Environmental
Response, Compensation, and Liability Act (CERCLA) (42 U.S.C. 9601 et seq), when
regulated as a hazardous waste under that Act by the Environmental Protection Agency.”
Transportation
North Carolina Department of Transportation
Phone: (919) 715-7000
Website: www.ncdot.gov
North Dakota
North Dakota Department of Health -- Environmental Health Division
North Dakota Department of Health
600 East Boulevard Avenue
Bismarck, N.D. 58505-0200
Phone: (701) 328.2372
Website: www.ndhealth.gov/ehs
AIR
NDDOH Division of Air Quality
918 E. Divide Ave., 2nd Floor
Bismarck, ND 58501-1947
Phone: (701) 328-5188
Website: www.health.state.nd.us/aq/default.htm

Water
NDDOH Division of Water Quality
918 E. Divide Ave., 4th Floor
Phone: (701) 328-5210
Website: www.health.state.nd.us/wq
Solid waste: NDDOH Division of Waste Management Solid Waste Program
918 E. Divide Ave., 3rd Floor
Phone: (701) 328-5166
Website: www.health.state.nd.us/wm
Hazardous waste: NDDOH Division of Waste Management Hazardous Waste
Program
Phone: (701) 328-5166
Spill information:
Hazardous Materials Emergency: Call (800) 472-2121 (in-state) answered 24 hours or
(800) 773-3259 during business hours.
Call (701) 328-8100 (out-of-state) during normal business hours or (701) 328-9921 during
weekends and non-business hours.
Large quantity generators must submit a copy of the signed manifest within 21 days of
the date:
1. When first signed by the generator and transporter; and
2. As signed by and received from the designated facility or alternate facility.
Small quantity generators and conditionally exempt small quantity generators are not
required to submit manifest copies. The manifest copies should be sent to:
NDDOH Division of Waste Management
918 East Divide Avenue, Floor 3
North Dakota does not have any state-specific waste codes.
For more information, see: http://www.health.state.nd.us/WM/
Storage Tanks
NDDOH Division of Waste Management Underground Storage Tank Program
Phone: (701) 328-5166


In North Dakota, a number of different state and federal rules regulate aboveground
storage tanks (ASTs), depending on size, location, use of tank, and product stored. The
North Dakota Fire Marshal’s Office requires preinstallation application for public fuel-
dispensing sites, and has established general requirements for tanks installed at
government and commercial sites. North Dakota has a Petroleum Tank Release
Compensation Fund that may reimburse the tank owner for certain cleanup activities if
a leak or release is discovered.
North Dakota Emergency Response Commission Department of Emergency Services
P.O. Box 5511
Phone: (701) 328-8100
Website: www.nd.gov/des/
North Dakota Emergency Response Commission Department of Emergency Services
P.O. Box 5511
Phone: (701) 328-8100
Website: www.nd.gov/des/
HazCom
North Dakota follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
North Dakota Department of Transportation
608 East Boulevard Avenue
Phone: (701) 328-2500
Website: www.dot.nd.gov/
Ohio
Ohio Environmental Protection Agency
Ohio Environmental Protection Agency
50 West Town Street, Suite 700
Columbus, OH 43215
Phone: (614) 644-3020
Website: www.epa.state.oh.us
AIR
Ohio EPA Division of Air Pollution Control
50 West Town Street Suite 700
Columbus, Ohio 43215
Phone: (614) 644-2270
Website: www.epa.state.oh.us/dapc/

Water
Ohio EPA Division of Surface Water
Street address: 50 W. Town St., Suite 700
Columbus, OH 43215
Columbus, OH 43216-1049
Phone: (614) 644-2001
Website: www.epa.state.oh.us/dsw/
National Pollutant Discharge Elimination System (NPDES) permits are issued to
municipal and industrial wastewater and stormwater dischargers. Contact Mark Mann
in the Stormwater Section at (614) 644-2023
For stormwater program forms and permits, visit www.epa.ohio.gov/dsw/storm/index.aspx
Solid waste: Division of Solid and Infectious Waste Management
50 West Town Street Suite 700
Columbus, Ohio 43215
Phone: (614) 644-2621
E-mail: georgia.frakes@epa.state.oh.us
Website: www.epa.state.oh.us/Default.aspx?alias=www.epa.state.oh.us/dsiwm
Hazardous waste: Ohio EPA Division of Hazardous Waste Management
50 West Town Street, Suite 700
Columbus, OH 43215
Mailing address: Ohio EPA Division of Hazardous Waste Management
Lazarus Government Center
P.O. Box 1049
Columbus, Ohio 43216-1049
Phone: (614) 644-2917
Website: www.epa.state.oh.us/dhwm/
Spill information:
To Report Spills, Releases and Abandoned Waste: (800) 282-9378 (in Ohio) and (614) 224-
0946 (out of state).
Ohio EPA does not require generators or TSDs to send a copy of the manifest.
Phone: (614) 644-2917
Storage Tanks
Ohio Department of Commerce
Division of State Fire Marshal
Bureau of Underground Storage Tank Regulations
8895 East Main St.
Reynoldsburg, Ohio 43068
Phone: (614) 752-8200
E-mail: websfm@com.state.oh.us
Website: www.com.ohio.gov/fire/BUSTMain.aspx
Ohio’s State Fire Marshal regulates aboveground storage tanks. For more information,
visit this website: www.com.ohio.gov/fire/onestoptankshop.aspx


Ohio EPA Division of Air Pollution Control
Columbus, OH 43215
Mailing address: (SERC) c/o Ohio EPA
Attn: RTK P.O. Box 1049
Phone: (614) 644-2270
CDX Help Desk: (888) 890-1995
Website: epa.ohio.gov/dapc/tri/tri.aspx
State Emergency Response Commission
Columbus, OH 43215
Mailing address: (SERC) c/o Ohio EPA
Attn: RTK P.O. Box 1049
Phone: (614) 644-2260 or (888) 644-2260
E-mail: SERC@epa.state.oh.us
Website: www.epa.state.oh.us/dapc/serc/index.aspx
Ohio requires Facility Identification and Inventory Forms, a site map, and Tier II
supplement. There is a fee for filing.
HazCom
Ohio follows the federal OSHA safety and health program requirements for HazCom.
Transportation
Ohio Department of Transportation
1980 West Broad Street
Columbus, OH 43223
Phone: (614) 466-7170
Website: www.dot.state.oh.us
Oklahoma
Oklahoma Department of Environmental Quality
Oklahoma Department of Environmental Quality
707 N Robinson
Oklahoma City, OK 73102
Phone: (405) 702-0100
Website: www.deq.state.ok.us
AIR
OK DEQ Air Quality Division
P.O. Box 1677
Oklahoma City, OK 73101-1677
707 N. Robinson
Phone: (405) 702-4100
Website: www.deq.state.ok.us/AQDnew/index.htm

Water
OK DEQ Water Quality Division
P.O. Box 1677
Phone: (405) 702-8100
Website: www.deq.state.ok.us/WQDnew/index.htm
Questions about stormwater permitting should be directed to the Water Quality Division,
Storm Water Unit.
Phone: (405) 702-8100
Website: www.deq.state.ok.us/WQDnew/stormwater/index.html
Solid waste: OK DEQ Land Protection Division
P.O. Box 1677
Phone: (405) 702-5100
Website: www.deq.state.ok.us/lpdnew/index.htm
Hazardous waste: OK DEQ Land Protection Division
P.O. Box 1677
Phone: (405) 702-5100
Website: www.deq.state.ok.us/LPDnew/hwindex.html
Spill information:
Hazardous materials emergency: (800) 522-0206
Oklahoma does not require copies of manifests be submitted to it regardless of whether
the waste originates or is disposed of in the state. The only exceptions are when the
shipment is an international shipment or the DEQ is the generator of the waste.
Oklahoma does not have any state specific waste codes.
For more information: (405) 702-5100
Storage Tanks
Physical address: Oklahoma Corporation Commission
Petroleum Storage Tank Division
Jim Thorpe Building
2101 N. Lincoln Boulevard
Mailing address: Oklahoma Corporation Commission
Petroleum Storage Tank Division
P.O. Box 52000
Phone: (405) 521-4683
Website: www.occeweb.com/ps/aboutpst1.html
Oklahoma’s aboveground storage tanks are regulated by Oklahoma Corporation
Commission. To find out more information, visit their website: www.occeweb.com


OK DEQ Customer Services Division
P.O. Box 1677
Phone: (405) 702-1000 or (800) 869-1400
Website: www.deq.state.ok.us/CSDnew/index.htm
OK DEQ Customer Services Division
P.O. Box 1677
Phone: (405) 702-1000 or (800) 869-1400
Website: www.deq.state.ok.us/CSDnew/index.htm
Oklahoma requires the use of a federal Tier II form.
There is a fee for filing.
HazCom
Oklahoma follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
Oklahoma Department of Transportation
Website: www.okladot.state.ok.us
Oregon
Oregon Department of Environmental Quality
DEQ Headquarters Office
811 SW 6th Avenue
Portland 97204-1390
Phone: (503) 229-5696
Website: www.cms.oregon.gov/deq
AIR
OR DEQ Air Quality Division
811 SW Sixth Ave.
Portland, OR 97204-1390
Phone: (503) 229-5969 or (800) 452-4011
Air Quality Index: (503) 229-5359
E-mail: DEQinfo@deq.state.or.us
Website: www.deq.state.or.us/aq/index.htm
Water
OR DEQ Water Quality Division
DEQ Headquarters Water Quality Division
811 SW 6th Ave.
Phone: (503) 229-5696 or (800) 452-4011
Website: www.oregon.gov/DEQ/WQ/


In Oregon, the DEQ is responsible for administering the storm water permit program.
DEQ has four permits that address industrial activities specified by EPA.
As of May 1, 1999, the application fee for the storm water general permits is $560. There
is also an annual compliance fee of $275 for subsequent years to maintain the permit.
Contact the local DEQ office to obtain an application, www.deq.state.or.us/programs.htm.
Visit the following website for fee information and links to permit application forms:
www.deq.state.or.us/permitslicenses.htm
Solid waste: OR DEQ Waste Prevention and Management Division
811 Sixth Ave.
Phone: (503) 229-5696 or (800) 452-4011 (toll-free in Oregon)
Website: www.deq.state.or.us/lq/sw/index.htm
Hazardous waste: OR DEQ Waste Prevention and Management Division
811 Sixth Ave.
Phone: (503) 229-5696 or (800) 452-4011 (toll free in Oregon)
Website: www.deq.state.or.us/lq/hw/index.htm
Spill information:
Oregon Emergency Response system (OERS) (any spill to the environment):
In state: (800) 452-0311
National Response Center (NRC) (any spill to the environment above the federal
reportable quantity): (800) 424-8802
If you have questions about DEQ’s Spill Management Program, please call (503) 229-
5695.
In Oregon call toll-free: (800) 452-4011
The Oregon Department of Environmental Quality (DEQ) does not require copies of the
Uniform Hazardous Waste Manifests.
Oregon has state-specific hazardous waste codes. If your waste is neither a federally
listed or characteristic hazardous waste, it may be a “State Only” hazardous waste.
Waste codes that are considered hazardous waste only in Oregon are in OAR 340-101-
033 (or see www.deq.state.or.us/lq/pubs/factsheets/hw/
OregonSpecificRequirementsHWManifest.pdf).
Contact Nancy Dollar at (503) 229-6968 for further information.
Storage Tanks
811 SW Sixth Ave.
Phone: (503) 229-6652
Hazmat Spill Helpline: (800) 452-0311
Underground Storage Tanks Leak: (800) 742-7878
Website: www.deq.state.or.us/lq/tanks/index.htm
Oregon’s Land Quality Division regulates aboveground storage tanks. To find out more
information, visit this website: www.deq.state.or.us/lq/tanks/index.htm


Oregon Emergency Planning and Response Section
c/o State Fire Marshal
4760 Portland Rd NE
Salem, OR 97305-1760
Phone: (503) 373-1540
E-mail: oregon.sfm@state.or.us
Website: www.oregon.gov/OSP/SFM/EPRS_Home.shtml
Oregon Emergency Response Commission
Office of the State Fire Marshal Incident Reporting Program
4760 Portland Rd NE
Salem, OR 97305-1760
Phone: (503) 373-1540
E-mail: oregon.sfm@state.or.us
Phone: (800) 454-6125 (Hazardous Substance Information Hotline)
(800) 452-0311 (Hazardous Materials Emergency)
Website: www.oregon.gov/OSP/SFM/EPRS_Home.shtml
Hazardous Substance Employer Survey required (not a Tier II form, but similar
information). There is a fee for filing.
HazCom
Oregon incorporates by reference the federal regulations for hazard communication;
however, the state adds further requirements. Find out more at www.cbs.state.or.us/
external/osha/
Transportation
Oregon Department of Transportation
1158 Chemeketa Street Northeast
Salem, OR 97302
Phone: (888) 275-6368
Pennsylvania
Pennsylvania Department of Environmental Protection
Pennsylvania Department of Environmental Protection
Rachel Carson State Office Building
400 Market Street
Harrisburg, PA 17101
Phone: (717) 783-2300
Website: www.portal.state.pa.us
AIR
PA DEP Bureau of Air Quality
Rachel Carson State Office Bldg.
12th Floor P.O. Box 8468
Harrisburg, PA 17105-8468
Phone: (717) 787-9702
Website: www.dep.state.pa.us/dep/deputate/airwaste/aq/default.htm

Water
PA DEP Bureau of Watershed Management
P.O. Box 2063
Phone: (717) 783-5267
Website: www.depweb.state.pa.us/watershedmgmt/site/default.asp
In Pennsylvania, the NPDES permit program is delegated to and administered by the PA
DEP. DEP has delegated the management of the NPDES program to most of the county
conservation districts (districts). DEP and districts jointly regulate construction activities
utilizing existing state regulations concerning erosion control and NPDES permits to
implement the federal requirements.
NPDES: (717) 787-8184
Website: www.depweb.state.pa.us/watershedmgmt/site/default.asp
Solid Waste: PA DEP Bureau of Waste Management
Division of Waste Minimization and Planning
14th Floor Rachel Carson State Office Bldg.
400 Market St. PO Box 8471
Phone: (717) 787-6239
Website: www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a=1216&Q=
442095&landrecwasteNav=|
Hazardous waste: PA DEP Bureau of Waste Management Division of Hazardous
Waste
14th Floor Rachel Carson State Office Building
PO Box 8471
Phone: (717) 787-6239
Website: www.depweb.state.pa.us/landrecwaste/cwp/view.asp?a=1242&Q=455143
Spill information:
The PA DEP prefers that notifications be made to the appropriate regional office. DEP
also maintains a statewide toll free number, (800) 541-2050, which is a backup to the
regional numbers and a reporting mechanism for people who do not know which regional
office is responsible for a particular area.
Website: www.portal.state.pa.us/portal/server.pt/community/
rcra_corrective_action_program/14075
In Pennsylvania, only the Treatment, Storage or Disposal Facility must submit a signed
manifest copy to the Department. The Department also wishes to receive a signed
manifest copy (copy 2) from facilities located outside of Pennsylvania which receive
hazardous waste from Pennsylvania generators. These copies should be mailed to:
PA DEP Manifest Section
P O Box 8550 Harrisburg, PA 17105-8550
The generator of the hazardous waste does not have to submit a generator copy to the
Commonwealth.
Pennsylvania does not require any additional wastes other than RCRA hazardous waste
to be shipped using a Uniform Hazardous Waste Manifest.
Contact: Robert Finkel: (717) 783-9183

Storage Tanks
PA DEP Bureau of Watershed Conservation
Division of Storage Tanks
P.O. Box 8762
Phone: (800) 428-2657 (within PA) or (717) 772-5599
E-mail: tanks@state.pa.us
Website: www.depweb.state.pa.us/portal/server.pt/community/waste_management/14069
PA DEP regulates aboveground storage tanks. To find out more information, visit this
website: www.dep.state.pa.us/dep/deputate/pollprev/BPManual/DStorage.htm
Pennsylvania Department of Labor and Industry
1623 Labor and Industry Building
7th and Forster Streets
Phone: (717) 783-2071
Toll-free: (888) SAFE-422
E-mail: li-pennsafe@pa.gov
Reports are to be sent to the following agencies:
For Regular Mail: Department of Labor and Industry Bureau of PENNSAFE
155-E Labor and Industry Bldg.
P.O. Box 68571
EPCRA Reporting Center Toxic Chemical Release Inventory
PO Box 3348
Merrifield, VA 22116-3348
For each chemical reported on the Toxic Chemical Release Inventory or alternate
Threshold Certification Form, a fee of $250 is to be paid to the Pennsylvania Hazardous
Material Response Fund. Fees are due with the reports by July 1st of each year. The
maximum fee for any facility is $5,000, regardless of how many chemicals are reported.
Under Act 165, there are no county fees associated with this form.
Pennsylvania Department of Labor and Industry
General Mailing Address: Commonwealth of Pennsylvania Department of Labor &
Industry Bureau of PENNSAFE
P.O. Box 68571
Phone: (717) 783-2071
Toll-free: (888) SAFE-422
E-mail: li-pennsafe@pa.gov

The Bureau of PENNSAFE, Pennsylvania Safety First administers and enforces the PA
Worker and Community Right to Know Law and selected provisions of the state’s
Hazardous Materials Emergency Planning and Response Act (Act 165) and SARA Title
III. The Federal Emergency Planning and Community Right-to-Know Act (PL 99-499,
Section 312) requires the owner or operator of any facility which must have a Material
Safety Data Sheet under the Occupational Safety and Health Administration Act (OSHA)
of 1970 to submit an emergency and hazardous chemical inventory form to the Local
Emergency Planning Committee (LEPC), the state, and to the fire department with
jurisdiction over the facility.
In Pennsylvania, the form required for this report is the Tier II Form.
HazCom
Pennsylvania follows the federal OSHA safety and health program requirements for this
topic.
Transportation
PA Department of Transportation
Riverfront Office Center
1101 South Front Street
Phone: (800) 932-4600
Website: www.dot.state.pa.us
Rhode Island
Rhode Island Department of Environmental Management
Rhode Island Department of Environmental Management
235 Promenade St # 350
Providence, RI 02908
Phone: (401) 222-2797
Website: www.dem.ri.gov
AIR
RI DEM Office of Air Resources
235 Promenade Street
Providence, RI 02908-5767
Phone: (401) 222-2808
Website: www.dem.ri.gov/programs/benviron/air/index.htm
Water
RI DEM Office of Water Resources
Phone: (401) 222-3961
After Hours Emergencies: (401) 222-3070
Website: www.dem.ri.gov/programs/benviron/water/index.htm


The Rhode Island Pollutant Discharge Elimination System (RIPDES), Pretreatment
Program, Priority Pollutant Monitoring program currently oversees permit compliance
for 29 major discharges and approximately 130 minor discharges. The Pretreatment
Program is necessary to prevent industrial discharges from interfering with the
operation of municipal wastewater treatment facilities and/or causing the facility to
violate its discharge limits. DEM provides oversight of 14 approved local pretreatment
programs administered by publicly owned wastewater treatment facilities In addition,
this program conducts the priority pollutant monitoring on an annual basis at all
municipal wastewater treatment facilities.
Solid Waste: RI DEM Office of Waste Management
Phone: (401) 222-2797
E-mail: tracee.lewis@dem.ri.gov
Website: www.dem.ri.gov/programs/benviron/waste/index.htm.
Hazardous waste: RI DEM Office of Waste Management
Phone: (401) 222-2797
E-mail: tracee.lewis@dem.ri.gov
Website: www.dem.ri.gov/programs/benviron/waste/index.htm.
Spill information:
If waste is generated by or deposited at a facility within the state of Rhode Island, the
generator will be required to photocopy the manifest and send it to the Rhode Island
DEM at the following address:
RI DEM Office of Waste Management
235 Promenade Street, Suite 220
Providence, Rhode Island 02908
There is room for six waste codes. Federal waste codes should be used first and the
remaining space for state codes. State codes R001-R010 are to be used if Federal codes
do not apply. The state codes will work on the new Uniform Hazardous Waste Manifest
in exactly the same way as they functioned on the previous manifest. State codes R011-
R016 are to be used for Fee Exempt waste and should be used in addition to federal
waste codes. In the event that the waste carries more than six waste codes, the
generator should select the most appropriate codes for use.
Phone: Alyson Silva at (401) 222-2797 ext. 7134 to obtain this form.
Storage Tanks
RI DEM Office of Waste Management Underground Storage Tank Management
Phone: (401) 222-2797
Website: www.dem.ri.gov/programs/benviron/waste/


All new construction/installation of a new facility or replacement tank system should not
commence until an application of registration has been filed. The registration
information should be signed by a local Fire Department official.
Please mail completed forms to: RI DEM Office of Emergency Response Aboveground
Storage Tank Program
If you have any questions, please call the Aboveground Storage Tank program at (401)
222-1360 x 4426 for assistance.
RI DEM Office of Air Resources
Attn: Toxic Release Inventory
Phone: (401) 222-2808
Website: www.dem.ri.gov/programs/benviron/air/index.htm
Rhode Island Department of Labor and Training
Attn: SARA Title III Division Center
General Complex 1511 Pontiac Avenue
Cranston, RI 02920
Phone: (401) 462-8559
(401) 222-3070 (Hazardous materials emergency)
Rhode Island accepts the electronic Tier II from the EPA website.
HazCom
Rhode Island follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
RI Department of Transportation
2 Capitol Hill
Phone: (401) 222-2481
Website: www.dot.ri.gov
South Carolina
South Carolina Department of Health and Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: (803) 898-DHEC (3432)
Website: www.scdhec.gov

AIR
SC Department of Health and Environmental Control — Bureau of Air Quality
2600 Bull Street
Columbia, SC 29201
Phone: (803) 898-4123
Website: www.scdhec.gov/environment/baq/
Water
SC Department of Health and Environmental Control — Bureau of Water
2600 Bull Street
Columbia, SC 29201
Phone:(803) 898-4300
Website:www.scdhec.net/water/
Municipal Storm water NPDES: Arturo Ovalles (803) 898-4178
Industrial and construction activity: Rick Nuzum (803) 898-4034
Solid Waste: Bureau of Land and Waste Management Division of the Office of
Solid Waste Reduction and Recycling
2600 Bull Street
Columbia, SC 29201
Phone: (803) 898-3432
Website:www.scdhec.net/lwm/
Hazardous waste: Bureau of Land and Waste Management Division of
Hazardous and Infections Waste Management
2600 Bull Street
Columbia, SC 29201
Phone: (803) 896-4000
Website: www.scdhec.gov/lwm/
Spill information:
Emergency Response: Toll-Free 24-Hour Number for Reporting Chemical Spills, Oil
Spills, or Fish Kills is 1-888-481-0125.
In Columbia, SC, call (803) 253-6488.
South Carolina does not require copies of the completed manifest to be sent to the South
Carolina Department of Health and Environmental Control. (South Carolina has not
required completed copies of the manifest be sent since June 27, 1997.) The state gathers
manifest information by way of its Computerized Quarterly Report System.
State-specific waste codes can be found in the South Carolina Hazardous Waste
Management Regulations:
Phone: C. Carroll Burley, Jr. at (803) 896-4141 with questions.

Storage Tanks
SC Department of Health and Environmental Control Bureau of Underground Storage
Tanks
2600 Bull Street
Columbia, SC 29201-1708
Phone: (803) 896-4000
Website: www.scdhec.net/lwm/html/ust.htm
For information regarding South Carolina’s aboveground storage tank regulations, visit
this website: www.envcap.org/statetools/st/strl.cfm?st=SC
Mary Peyton Wall
Community Right-to-Know
2600 Bull Street
Columbia, SC 29201
Phone: (803) 898-4064
Angel Thompson, EPCRA Reporting South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia, SC 29201
Phone: (803) 898-3432 or (803) 898-4058
Website: www.scdhec.gov/environment/baq/EPCRA-Tier2Reporting/
The SC State Emergency Response Commission requires an annual submission of a Tier
II report due March 1 from qualifying facilities. There are other provisions of the law,
and the law itself should be consulted for proper compliance. The agency requires the
use of E-Plan to satisfy the State’s Tier II reporting requirements. Facilities have to sign
up for an account in E-Plan and authorize a user to have access to the system. The
agency no longer accepts other reporting methods.
HazCom
South Carolina incorporates by reference the federal regulations for hazard
communication; therefore, the state requirements are identical to the federal
requirements.
Transportation
SC Department of Transportation
955 Park Street
P.O. Box 191
Phone: 855-GO-SCDOT (855-467-2368)
Website: www.dot.state.sc.us

South Dakota
South Dakota Department of Environment and Natural Resources
South Dakota Department of Environment and Natural Resources
PMB 2020 Joe Foss Building
523 E Capitol
Pierre, SD 57501
Phone: 605-773-3151
Website: www.denr.sd.gov
AIR
SD DENR Air Quality Program
PMB 2020, Joe Foss Building
523 E. Capitol
Pierre, SD 57501
Phone (605) 773-3151
Website: http://denr.sd.gov/des/aq/airprogr.aspx
Water
SD DENR Ground Water Quality
PMB 2020
Joe Foss Building
523 E. Capitol
Pierre, SD 57501
Phone: (605) 773-3296
Website: http://denr.sd.gov/des/gw/groundprg.aspx
Surface Water Discharge permits are required for any point source that is discharging
pollutants to waters of the state, with some exemptions.
An application for a Surface Water Discharge or Pretreatment Industrial User permit
should be sent to the department at least 180 days prior to any discharge. The
regulations can be found in the Administrative Rules of South Dakota 74:52.
For information contact the Surface Water Quality Program in Pierre at (605) 773-3351.
Solid Waste: SD DENR Waste Management Program
PMB 2020
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501
Phone: (605) 773-3153
Website: http://denr.sd.gov/des/wm/wmp/wmpmainpage.aspx
For assistance in the form of grants and loans for solid waste site closure, site
development, recycling, waste tire pile cleanups, and other projects, contact the Water
and Waste Funding Program at (605) 773-4216.
Hazardous waste: SD DENR Waste Management Program
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501
Phone: (605) 773-3153
Website: http://denr.sd.gov/des/wm/hw/hwmainpage.aspx

Spill information:
National Response Center: (800) 424-8802
South Dakota notification: (605) 773-3296
After hours: (605) 773-3231
The spill or release can be reported at the phone number listed above during business
hours or by contacting (605) 773-3231 during non-business hours. The after hour phone
number is State Radio and they will contact the appropriate individuals in the event of a
release or spill.
If you have any questions concerning the reporting of releases or spills, call (605) 773-
3296 in Pierre.
Use the federal Uniform Hazardous Waste Manifest form. For more information, contact:
Carrie Jacobson Phone: 605-773-3153
Storage Tanks
SD DENR Ground Water Quality
PMB 2020
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501
Phone: (605) 773-3296
Website: http://denr.sd.gov/des/wm/hw/hwmainpage.aspx
For information regarding South Dakota’s aboveground storage tank regulations, visit
this website: http://denr.sd.gov/des/gw/tanks/ust_ast_definition.aspx
Trish Kindt, TRI Coordinator
SD DENR PMB 2020
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501-3181
Phone: (605) 773-3296 or (800) 433-2288
Trish Kindt South Dakota Response Commission
SD DENR PMB 2020
Joe Foss Bldg.
523 E. Capitol
Pierre, SD 57501-3181
Phone: (605) 773-3296 or (800) 433-2288
A state Tier II form is required and there is a fee for filing. The federal regulations
governing SARA Title III are found in 40 CFR 300-355. Related state statutes are found
in South Dakota Codified Law 1-50.
For more information contact Trish Kindt at (800) 433-2288.
HazCom
South Dakota follows the federal OSHA safety and health program requirements for
HazCom.

Transportation
SD Department of Transportation
Becker-Hansen Building
700 E. Broadway Ave.
Pierre, SD 57501
Phone: 605-773-3265
Website: www.sddot.com
Tennessee
Tennessee Department of Environment and Conservation
Tennessee Department of Environment and Conservation
401 Church Street
L&C Tower
Nashville, TN 37243
Phone: (888) 891-8332
Website: www.tn.gov/environment
AIR
TN DEC Division of Air Pollution Control
401 Church Street
L&C Annex, 9th Floor
Nashville, TN 37243-1531
Phone: (615) 532-0554
Website: http://tn.gov/environment/apc/
Water
TN DEC Division of Water Pollution Control
401 Church Street
Phone: (615) 532-0625
Website: http://tn.gov/environment/wpc/
The Division of Water Pollution Control is responsible for the administration of the
Tennessee Water Quality Control Act of 1977 (T.C.A. 69-3-101). In addition, the Division
is responsible for the non-coal surface mining program and illegal coal mining under the
Tennessee Coal Surface Mining Law of 1980, as amended.
Under the Water Quality Control Act, municipal, industrial and other discharges of
wastewater must obtain a permit from the Division.
Applications and assistance can be obtained from the appropriate Division of Water
Pollution Control Field Office.
Website: http://tn.gov/environment/ea/sbeap/stormwater/
Division of Solid/Hazardous Waste Management
401 Church Street
Phone: (615) 532-0780
Website: http://www.tn.gov/environment/swm/

Spill information:
Tennessee State Law requires anyone who becomes aware of a hazardous materials spill
involving chemical or radiological materials to report that to the State Emergency
Operations Center as soon as possible at (615) 741-0001 (Nashville local, primary), (800)
262-3400 (in-state), or (800) 258-3300 (out-of-state). This includes citizens, drivers of
commercial vehicles, other state government agencies, etc. The State EOC is staffed 24-
hours per day, 365 days a year.
Use the federal Uniform Hazardous Waste Manifest form. Contact Dennis Woodson at
(615) 532-0487 for further information.
Storage Tanks
TN DEC Division of Underground Storage Tanks
401 Church Street
Nashville, Tennessee 37243-1541
Phone: (888) 891-8332 or (615) 532-0945
Website: http://tn.gov/environment/ust
The State Fire Marshall’s Office enforces the 2000 NFPA Codes. In particular, NFPA 30
and NFPA 30A address above ground storage tanks. You will want to ensure that above
ground storage tanks meet the current codes. This office can be contacted at (615) 741-
7190. http://tn.gov/commerce/sfm/index.shtml
Tennessee Emergency Management Agency
3041 Sidco Drive
Phone: (615) 741-0001
E-mail: ops@tnema.org
Website: www.tnema.org/
Tennessee Emergency Management Agency
3041 Sidco Drive
Phone: (615) 741-0001
E-mail: ops@tnema.org
Website: www.tnema.org/
HazCom
Tennessee’s state requirements regarding hazard communication (HAZCOM) include a
substantial amount of regulatory information beyond the federal requirements. Read the
sate rules at www.tn.gov/sos/rules/0800/0800-01/0800-01-09.pdf

Transportation
TN Department of Transportation
James K. Polk Bldg.
505 Deaderick Street
Suite 700
Nashville, TN 37243
Phone: (615) 741-2848
Website: www.tdot.state.tn.us
Texas
Texas Commission on Environmental Quality
12100 Park 35 Circle
Austin, TX 78753
Phone: (512) 239-1000
Website: www.tceq.texas.gov
AIR
TCEQ
Austin, TX 78753
Use for express carrier deliveries ( U.S. Post Office Express Mail, FedEx, UPS, etc.).
Please call your TCEQ contact to determine the exact building location before sending to
the physical address. Main switchboard: (512) 239-1000 Website: http://www.tceq.state.tx.
us/
Water
TCEQ
Austin, TX 78753
the physical address. Main switchboard: (512) 239-1000 Website: http://www.tceq.state.tx.
us/
For enforcement questions, contact the Wastewater Enforcement Section at 512/239-
2545.
For information or assistance with stormwater permits, contact the Wastewater Permits
Section at 512/239-4671.
Information is also available at www.tceq.state.tx.us/nav/permits/sw_permits.html
Federal authority TPDES stormwater permits are required by the federal Clean Water
Act (CWA) and are issued by the TCEQ. All activities relating to the regulation of storm
water have been administered by the agency’s Wastewater Division since September 14,
1998, when the U.S. Environmental Protection Agency (EPA) authorized Texas to
implement the program.


TCEQ
Austin, TX 78753
Use for express carrier deliveries (U.S. Post Office Express Mail, FedEx, UPS, etc.).
the physical address.
Main switchboard: (512) 239-1000
Website:www.tceq.state.tx.us/
Waste Permits Division Main line: (512) 239-2335
Spill information:
To report an environmental emergency, discharge, spill, or air release, call:
State: Environmental Release Hotline or the Texas Commission on Environmental
Quality (TCEQ) (800)-832-8224
Regional Office, Monday through Friday 8:00 to 5:00 TCEQ (24-Hours) at (512) 239-1000.
Federal: National Response Center (NRC) (800) 424-8802 (Notification of the National
Response Center does not constitute notice to the state).
For more information visit: www.tceq.state.tx.us/response/spills.html
The TCEQ does not currently require that a copy of the manifest be sent to the state. If
a generator originates the manifest, he should keep a copy for his records.
The manifest remains with the waste throughout transit to the final destination. The
manifest is signed and the copy is returned to the generator.
Texas has its own 8-digit waste code that identifies each waste stream. The Texas waste
code will still go on the manifest — regardless of if the waste is hazardous or not.
Use two of the 6 waste code blocks in Item 13 for the Texas Waste Code.
For hazardous waste, up to 4 applicable EPA codes (e.g., D001, F001, etc) will go in the
remaining waste code boxes.
The formula for the Texas waste code is: The 4-digit sequence number + the 3-digit form
code + the 1-digit classification code.
The rules corresponding to this formula can be found in 30 TAC Section 335.501 - .521
(Subchapter R). The regulatory guidance RG-022, Guidelines for the Classification and
Coding of Industrial and Hazardous Wastes is the best resource for Texas Waste Code
information. If you are shipping only non-hazardous waste, enter the 5-digit Texas
Registration numbers instead of the EPA ID numbers for generator, transporter and
receiver.
Phone: (512) 239-6413 to obtain the Texas manifest. For more information, refer to http://
www.tceq.state.tx.us/permitting/registration/ihw/epa_waste_manifest_system.html.
Storage Tanks
TCEQ
Austin, TX 78753
the physical address.
Main switchboard: (512) 239-1000
Website:www.tceq.state.tx.us/
Contact Registration staff at (512) 239-2160


For more information regarding Texas’s aboveground storage tank regulations, visit the
following website: http://www.tceq.texas.gov/permitting/registration/pst/Am_I_Regulated.
html.
Small Business and Environmental Assistance Division Section 313/TRI Program
TCEQ
12100 Park 35 Circle, Building E (MC-112)
Austin, TX 78753
Phone: (512) 239-5366
Website: www.tceq.state.tx.us/
TRI coordinators are available at the TCEQ to help Texas industries determine which
facilities must report and complete TRI forms. TRI reporting packages, technical
guidelines for specific industries, and TRI data reports are available upon request. TRI
coordinators also provide assistance to citizens to help them understand what is reported
to TRI in Texas and how they can access the TRI data. TRI coordinators can be reached
at (512) 239-4TRI or by writing:
Toxic Release Inventory Program, MC164
P.O. Box 13087
Austin, TX 78711-3087
Phone: (512) 239-4TRI
E-mail: toxic@tceq.state.tx.us
Tier II Chemical Reporting Program MC 2835
Texas Department of State Health Services
1100 West 49th Street
Austin, TX 78756-3199
Toll-free in TX: (800) 452-2791
Oustide TX: (512) 834-6603
Website: www.dshs.state.tx.us/tiertwo/default.shtm
HazCom
Texas follows the federal OSHA safety and health program requirements for HazCom.
Transportation
TX Department of Transportation
125 E. 11th Street
Austin, TX 78701-2483
Phone: 512-463-8630
Website: www.txdot.gov
Utah
Utah Department of Environmental Quality
Utah Department of Environmental Quality
195 North 1950 West
Salt Lake City, UT
Phone: (801) 536-4400
Website: www.deq.utah.gov

AIR
Ut DEQ Division of Air Quality
195 North 1950 West Fourth Floor Box 144820
Salt Lake City, UT 84116-4820
Phone: (801) 536-4000
Website: www.airquality.utah.gov/
Water
Ut DEQ Division of Water Quality
P.O. Box 144870
Phone: (801) 536-4300
Website: www.waterquality.utah.gov
Storm water general permit for construction and industrial activities:
UPDES application forms can be found at http://www.deq.utah.gov/
Solid waste: UT DEQ Division of Solid and Hazardous Waste
195 North 1950 West 2nd Floor P.O. Box 144880
Phone: (801) 536-0220
TDD: (801) 536-4414
Hazardous waste: UT DEQ Division of Solid and Hazardous Waste
195 North 1950 West 2nd Floor P.O. Box 144880
Phone: (801) 536-0220
TDD: (801) 536-4414
Website: http://www.hazardouswaste.utah.gov/
Spill information:
24-hour emergency phone number for incident spills: (801) 536-4123
Utah does not have any manifest requirements in addition to the federal requirements
found in the Appendix to 40 CFR Part 262. However, Utah does have two additional
listed hazardous wastes that are not listed by EPA. These two additional wastes relate to
chemical nerve agents:
F999 Residues from demilitarization, treatment, and testing of nerve, military, and
chemical agents CX, GA, GB, GD, H, HD, HL, HN-1, HN-2, HN-3, HT, L, T, and VX.
(R,T,C,H)
P999 Nerve, Military, and Chemical Agents (i.e., CX, GA, GB, GD, H, HD, HL, HN-1,
HN-2, HN-3, HT, L, T, and VX),(R,T,C,H) Phone:
Contact Jon Parry at (801) 538-6170 for information regarding hazardous waste manifest
forms.
Storage Tanks
Utah Division of Environmental Response and Remediation
195 North 1950 West First Floor Box 144840
Phone: (801) 536-4141
Website: www.undergroundtanks.utah.gov/


For more information regarding Utah’s aboveground storage tank regulations, visit the
following website: www.undergroundtanks.utah.gov
Mike Zucker
Utah Division of Environmental Response and Remediation
Phone: (801) 536-4100
E-mail: mzucker@utah.gov
Website: www.environmentalresponse.utah.gov/
UT DEQ Division of Environmental Response and Remediation
Website: www.environmentalresponse.utah.gov/
Phone: (801) 536-4100
Hazardous Materials emergency: (801) 536-4123
The preferred report format for Utah is the Tier II form. Tier II reports are due March 1,
of each calendar year. Tier II reports should reflect chemical inventories for the previous
calendar year. This modification of federal and state regulations does not apply in Salt
Lake City or Salt Lake County.
Each of the following agencies need to receive a copy of your Tier II report:
The Division of Environmental Response and Remediation, 195 North 1950 West, First
Floor, Box 144840, Salt Lake City, UT 84114-4840
The Local Emergency Planning Committee (LEPC)
The local fire department Tier II reports submitted to the above should include one Tier
II form with an original signature in the “Certification” section of the form.
There is no fee for submission of Tier II reports to the State of Utah.
HazCom
Utah incorporates by reference the federal regulations for hazard communications ;
Transportation
UT Department of Transportation
4501 South 2700 West
Salt Lake City, UT 84114
Phone: (801) 985-4000
Website: www.udot.utah.gov
Vermont
Vermont Agency of Natural Resources
Vermont Agency of Natural Resources
1 National Life Drive, Davis 2
Montpelier, VT 05620-3901
Phone: (802) 828-1294
Website: www.anr.state.vt.us

Vermont Department of Environmental Conservation

DEC Commissioner’s Office
1 National Life Drive, Main 2
Phone: (802) 828-1556
AIR
VT DEC Air Quality and Climate Division
Davis Building — 2nd Floor
1 National Life Drive
Phone: (802) 828-1288
Website: www.anr.state.vt.us/air/
Water
VT DEC Watershed Division
1 National Life Drive, Main 2
Phone: (802) 828-1535-3777
Website: www.anr.state.vt.us/dec/waterq/wqdhome.htm
Vermont Stormwater Program
Phone: (802) 241-3777
Website: www.anr.state.vt.us/dec/waterq/stormwater.htm
VT DEC Agency of Natural Resources Waste Management & Prevention Division
1 National Life Drive — Davis 1
Phone: (802) 828-1138
Website: www.anr.state.vt.us/dec/wmd.htm
Spill information:
All discharges and/or releases that meet DEC’s criteria shall be immediately reported by
calling the DEC Spill Response Team at (802) 828-1138, during regular office hours, or
the Department of Public Safety, Emergency Management Division at (800) 641-5005,
in-state 24 hours/day.
The copies shall be distributed as required in the instructions. At this time, VT is not
requiring photocopies to be mailed from the generator to either the destination state or
generator state. However, it is the generator’s responsibility to ensure that Vermont
receives the “designated facility to generator state” and/or “designated facility to
destination state” copies.
Vermont has numerous state-specific waste codes, with a list available at www.anr.state.
vt.us/dec/wastediv/rcra/hazregs/VTlistedwastes.pdf
Phone: (802) 522-0261

Storage Tanks
VT DEC WMPD/UST
1 National Life Drive — David 1
Phone: (802) 828-1138
Website: www.anr.state.vt.us/dec/wastediv/ust/home.htm
For more information regarding Vermont’s aboveground storage tank regulations, see
www.anr.state.vt.us/dec/wastediv/ust/pubs/GRchart.pdf and/or www.anr.state.vt.us/dec/
wastediv/ust/regs/ASTRules.pdf.
VT DEC Environmental Assistance Division
Pollution Prevention Planning
Phone: (802) 522-0219
Website: www.anr.state.vt.us/dec/ead/ppap/index.htm
Vermont Emergency Management
Tier II Compliance Program
Division of Fire Safety
1311 U.S. Route 302 – Berlin, Suite 600
Barre, VT 05641
Phone: (802) 479-7586 or (800) 640-2106
Website: http://vem.vermont.gov/programs/epcra
Note: Facilities that use or possess cooling and freezing equipment may be required to
report these chemicals if they exceed 100 lbs. of chemical in all onsite freezer/cooling
units. See the above website for more information.
Electronic Reporting: The VT State Emergency Response Commission asks facilities to
submit Tier II reports by using EPA’s Tier2Submit software program. Find the
Tier2Submit software at www.epa.gov/emergencies/content.epcra/statetier2.htm#vermont.
A SEPARATE TIER TWO FORM MUST BE SUBMITTED FOR EACH DIFFERENT
GEOGRAPHIC FACILITY SITE.
Tier II data, a Safety Data Sheet (SDS) for each reported hazardous material, and the
appropriate fee must be submitted by March 1 of each year to the SERC (Original and
fees); LEPC; and local fire department.
HazCom
Vermont incorporates by reference the federal regulations for hazard communications;
Transportation
VT Department of Transportation
One National Life Drive
Phone: (802) 828-2657
Website: www.aot.state.vt.us

Virginia
Virginia Department of Environmental Quality
Virginia Department of Environmental Quality
629 East Main Street
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4000
Website: www.deq.state.va.us
AIR
VA DEQ
Richmond, VA 23218
or
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4000
Toll-free in VA: (800) 592-5482
Website: http://deq.virginia.gov/air/
Water
VA DEQ
Richmond, VA 23218
or
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4000
Toll-free in Virginia: (800) 592-5482
Website: http://deq.virginia.gov/water/
DEQ, the Department of Conservation and Recreation, and the Chesapeake Bay Local
Assistance Department are coordinating three separate state programs that regulate the
management of pollution carried by stormwater runoff. The programs were developed
from separate state and federal laws passed to address surface water contamination from
land use activities: The federal Clean Water Act; VA Stormwater Management Act; and
Chesapeake Bay Preservation Act.
Website: http://deq.virginia.gov/vpdes
VA DEQ Waste Management
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4000
Toll-free in VA: (800) 592-5482
Website: http://deq.virginia.gov/waste/hazardous.html
Spill information:
During business hours, call the nearest DEQ regional office. Or call the Department of
Emergency Services, 24 hours a day, at 1-800-468-8892 (toll-free in Virginia only) or
(804) 674-2400.

Contact Melanie D. Davenport (804) 698-4038 for more information.
Storage Tanks
VA DEQ
Richmond, VA 23218
Phone: (804) 698-4010
Website: http://deq.virginia.gov/tanks/
For more information regarding Virginia’s aboveground storage tank regulations, visit
the following website: www.deq.state.va.us/Programs/LandProtectionRevitalization/
PetroleumProgram/StorageTanks/AbovegroundStorageTanks.aspx
Virginia Emergency Response Council c/o VA DEQ
SARA Title III Program
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4159
Website: http://deq.virginia.gov/sara3/
Virginia Emergency Response Council (VERC) c/o VA DEQ
SARA Title III Program
P.O. Box 1105
Richmond, VA 23218
Phone: (804) 698-4000
Website: http://deq.virginia.gov/sara3/
Virginia facilities have the option of submitting either Tier I or Tier II information to
satisfy this reporting requirement. EPA and the Virginia Emergency Response Council
encourage the use of the Tier II form. All reporting facilities are required to submit a
Tier II form to the VERC and a copy to the LEPC and the local fire department with
jurisdiction for the facility.
HazCom
Virginia adopts (although not by reference) the federal regulations for hazard
communication; therefore, the state requirements are identical to the federal
requirements.
Transportation
VA Department of Transportation
1401 East Broad Street
Richmond, VA 23219
Phone: (804) 786-8032
Website: www.virginiadot.org

Washington
Washington State Department of Ecology
Washington State Department of Ecology
300 Desmond Drive SE
Lacey, WA 98503
Phone: (360) 407-6000
Website: www.ecy.wa.gov
AIR
WA Department of Ecology Air Quality Program
PO Box 47600
Olympia, WA 98504-7600
300 Desmond Drive
Lacey, WA 98503
Phone: (360) 407-6000
Website: www.ecy.wa.gov/programs/air/airhome.html
Water
WA Department of Ecology Water Quality Program
PO Box 47600
300 Desmond Drive
Lacey, WA 98503
Phone: (360) 407-6000
Website: www.ecy.wa.gov/programs/wq/wqhome.html
Website: www.ecy.wa.gov/programs/wq/stormwater/
If you have questions, call (360) 407-6438. Call Ecology’s stormwater request line at
(360) 407-7156 to request a copy of the permits, a sample public notice, industrial and
construction booklets, guidance for auto recyclers, log yard operations, vehicle washing,
and the guidance manual for developing a stormwater pollution prevention plan
(SWPPP) for industrial facilities.
Solid Waste: WA Department of Ecology
Physical address: Solid Waste and Financial Assistance Program
300 Desmond Dr.
Lacey, WA 98503
Main Reception: (360) 407-6000
Website: www.ecy.wa.gov/programs/swfa/index.html
Hazardous Waste: WA Department of Ecology
Hazardous Waste and Toxics Reduction
PO Box 47600
300 Desmond Drive
Lacey, WA 98503
Phone: (360) 407-6700
Website:www.ecy.wa.gov/programs/hwtr/

Spill information:
Report spills to the following emergency telephone numbers:
Report all OIL or hazardous materials spills to: National Response Center: 1-800-424-
8802 AND Washington State: 1-800-258-5990 or 1-800-OILS-911 AND the nearest
appropriate regional Department of Ecology office:
Northwest Region, Bellevue: 425-649-7000
Southwest Region, Olympia: 360-407-6300
Central Region, Yakima: 509-575-2490
Eastern Region, Spokane: 509-329-3400
Website: www.ecy.wa.gov/programs/spills/other/reportaspill.htm .
Page 2 of the manifest, “Designated Facility to Generator State″, is not required in
Washington State. State-specific waste codes for Washington are available at www.ecy.
wa.gov/programs/hwtr/waste-report/wa_waste_codes.htm.
Contact: Iris Aguilera Phone: (360) 407-6734
Storage Tanks
WA Department of Ecology Site Cleanup/Underground Storage Tanks
PO Box 47600
300 Desmond Drive
Lacey, WA 98503
Phone: (360) 407-7170
Website:www.ecy.wa.gov/programs/tcp/ust-lust/tanks.html
For more information regarding Washington’s aboveground storage tank regulations,
visit the following website: https://fortress.wa.gov/ecy/publications/summarypages/
0308014.html
WA Department of Ecology CRTK Unit
PO Box 47659
Phone: (800) 633-7585, press 2 at the greeting
Website: www.ecy.wa.gov/epcra/index.html
The state of Washington accepts electronic reports.
WA Department of Ecology CRTK Unit
PO Box 47659
Phone: (800) 633-7585, press 2 at the greeting
Websitewww.ecy.wa.gov/epcra/index.html
Washington requires completion of the Tier Two Emergency and Hazardous Chemical
Inventory report by all facilities which have reportable quantities. Three separate
reports with an original signature are due March 1 of each year.

Send your reports with an original signature to each of the following:

1) your Local Emergency Planning Committee (see http://www.ecy.wa.gov/epcra),
2) the local fire district, and
3) the state at this address (note: the Department of Ecology accepts reports on behalf of
the SERC): Community Right-To-Know Unit Department of Ecology PO Box 47659
If you have any questions, call 1-800-633-7585, press 2 at the greeting. The toll-free line
is staffed M-F 9am to 4pm.
E-mail: epcra@ecy.wa.gov
The state of Washington accepts electronic reports.
HazCom
Most of Washington’s requirements for hazard communication are identical to the federal
requirements; however, the state adds further requirements. Go to www.lni.wa.gov/
wisha/rules/corerules/default.htm.
Transportation
WA Department of Transportation
310 Maple Park Avenue SE
Phone: 360.705.7000
Website: www.wsdot.wa.gov
West Virginia
West Virginia Department of Environmental Protection
West Virginia Department of Environmental Protection
601 - 57th Street
Charleston, WV 25304
Phone: (304) 926-0480
Website: www.dep.wv.gov
AIR
WV DEP Office of Air Quality
601-57th Street
Voice: (304) 926-0475
Website: www.dep.wv.gov/air/Pages/default.aspx
Water
WV DEP Office of Water Resources
Acting Chief Bill Brannon
601-57th Street
Phone: (304) 926-0495
Website: www.dep.wv.gov/water/Pages/default.aspx
The Nonpoint Source Program coordinates a multi-agency effort to control pollution
originating from improper land uses, manages pollution prevention efforts and provides
water quality certification to state and federal projects.

The Permit Section manages the National Pollutant Discharge Elimination System
(NPDES) permitting program for facilities other than coal activities. This section also
manages the pretreatment program and has the authority to issue general permits and
regulate federal facilities under the state delegated NPDES program.
WV DEP Division of Water and Waste Management
601-57th Street SE
Phone: (304) 926-0495
Website: www.dep.wv.gov/WWE/Pages/default.aspx
Spill information:
The Compliance Assurance and Emergency Response section of DEP responds directly to
hazardous waste emergencies.
Pollution Spills & Dam Emergency, DEP Elkview Emergency Response Unit (800) 558-
5938
Pollution Spills & Dam Emergency, State (800) 642-3074
Pollution Spills & Dam Emergency, National (800) 424-8802
West Virginia Department of Environmental Protection does not require copies of
manifests be submitted to it regardless of whether the waste originates or is disposed of
in the state. The only exceptions are when the shipment is an international shipment or
a shipment utilizing a state-issued one-time provisional US EPA ID Number. The
provisional number is used for a one-time cleanup of regulated waste, and is usually
issued for a period of 30 days.
West Virginia does not have any state specific waste codes.
Contact Marjorie A. Skeens at (304) 926-0499 x1297 for further information.
Storage Tanks
West Virginia Division of Environmental Protection Division of Water and Waste
Management
601-57th Street
Phone: (304) 926-0470
Website: www.dep.wv.gov/WWE/ee/ust/Pages/default.aspx
For more information regarding West Virginia’s aboveground storage tank regulations,
visit the following website: http://www.dep.wv.gov/WWE/Programs/gw/Documents/
AST%20Guidance%20Document.pdf.
West Virginia Emergency Response Commission Office of Emergency Services
Main Capitol Building 1 - Room EB-80
1900 Kanawha Blvd East
Charleston, WV 25305-0360
Phone: (304) 558-5380


West Virginia Emergency Response Commission Office of Emergency Services
Main Capitol Building 1 - Room EB-80 1900 Kanawha Blvd East
Charleston, WV 25305-0360
Phone: (304) 558-5380
Website: www.wvdhsem.gov/
You must use the revised Nov. 1990 Tier Two form. The Tier One form is not acceptable
in West Virginia. Tier Two forms must be submitted annually by March 1 to:
1. WV State Emergency Response Commission (SERC)
2. Local Emergency Planning Committee (LEPC)
3. Fire department having jurisdiction over your facility.
Call WVSERC if you need the address/telephone of any LEPC or fire department.
HazCom
West Virginia follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
WV Department of Transportation
Building 5
1900 Kanawha Blvd E
Phone (304) 558-0444
Website: www.transportation.wv.gov
Wisconsin
Wisconsin Department of Natural Resources
Wisconsin Department of Natural Resources
101 S. Webster Street
Madison, WI 53707
Phone: (608) 266-2621
Website: www.dnr.wi.gov
AIR
WI DNR Bureau of Air Management
101 S. Webster St.,
PO Box 7921
Madison, WI 53707-7921
Telephone: (608) 266-7718
Website: http://dnr.wi.gov/air/index.asp
Water
WDNR Bureau of Watershed Management
101 S. Webster St.
P.O. Box 7921
Madison, WI 53707
Phone: (608) 267-7694
Website: www.dnr.wi.gov/org/water/wm/


The Wisconsin DNR regulates municipal, industrial, and significant animal waste
operations discharging wastewater to surface waters or groundwater through the
WPDES Permit Program.
To have a storm water WPDES application mailed to you, call 1-888-936-7463. In
addition, there is an Industrial Storm Water Pollution Prevention Planning Manual,
Storm Water Sampling Manual and a Wisconsin Construction Site Handbook available
from Department of Administration (DOA)Document Sales, P.O. Box 7840, Madison, WI
53707. Call 608-266-3358 for more information.
WI DNR Bureau of Waste Management
101 S. Webster St.
P.O. Box 7921
Telephone: (608) 266-2621
Website: www.dnr.wi.gov/org/aw/wm/
The Wisconsin Department of Natural Resources operates a federally authorized
hazardous waste regulatory program.
Spill information:
The 24-hour hotline number for reporting spills is 1-800-943-0003.
All discharges of hazardous substances that adversely impact, or threaten to adversely
impact public health, welfare or the environment must be immediately reported to the
DNR.
Phone: Patricia Chabot at (608) 264-6015 to obtain this form.
Storage Tanks
The Storage Tank Regulation Section of the WI Department of Safety and Professional
Services is the primary unit responsible for the administration and regulation of the WI
Administrative Code SPS 310 — Flammable and Combustible Liquids. The agency
oversees both aboveground and underground storage tanks.
Storage Tank Regulation Section
P.O. Box 7837
201 W. Washington
Madison, WI 53707
Phone:(608) 266-7874
Website: dsps.wi.gov/er/er-bst-homepage.html
WDNR
101 South Webster Street
PO Box 7921
Phone: (608) 266-8931


Wisconsin Emergency Management
2400 Wright Street
P.O. Box 7865
(608) 242-3223
(800) 943-0003 Hazardous Materials Emergency
WI prefers Tier II reporters use the new Wisconsin Haz-Mat Online Planning and
Reporting System (WHOPRS) for Tier II reporting. Find the blank forms at
emergencymanagement.wi.gov/. To enter data into the Tier II WHOPERS, go to: whoprs.
wisconsin.gov.
Website: http://emergencymanagement.wi.gov/
HazCom
Wisconsin follows the federal OSHA safety and health program requirements for
HazCom.
Transportation
WI Department of Transportation
Hill Farms State Transportation Building
4802 Sheboygan Avenue
Phone: (608) 266-8676
Website: www.dot.state.wi.us
Wyoming
Wyoming Department of Environmental Quality
Wyoming Department of Environmental Quality
122 West 25th St,
Herschler Building
Cheyenne 82002
Phone: ( 307) 777-7937
Website: www.deq.state.wy.us
AIR
WY DEQ Air Quality Division
Herschler Building – 4W
Cheyenne, WY 82002
Website: http://deq.state.wy.us/aqd/index.asp?pageid=8
Water
WY DEQ Water Quality Division
Herschler Building – 4th Floor- West
Cheyenne, WY 82001
To reach Division offices, call: Cheyenne (307) 777-7781
Lander (307) 332-3144
Sheridan (307) 673-9337
Casper (307) 473-3465
Website: http://deq.state.wy.us/wqd/index.asp


Point Source Program (NPDES) (supervisor is Barb Sahl, 307-777-7570)
If you are interested in receiving a copy of all NPDES public notices, you may submit a
written request to Leah Krafft, Wyoming Department of Environmental Quality, Water
Quality Division, 122 West 25th Street, Herschler Building, 4th Floor - West, Cheyenne,
WY82002.
WY DEQ Solid and Hazardous Waste Division
Herschler Building - 4W
Cheyenne, WY 82002
Lander (307) 332-6924
Casper (307) 473-3450
Website: http://deq.state.wy.us/shwd/index.asp
Spill information:
24 Hour Hotline Number for reporting spills is (307) 777-7781
If you are unsure about whether the substance that has been released is reportable or
would be considered a hazardous substance, you should contact the Wyoming DEQ
Emergency Response Coordinator at (307) 777-5885.
For more information, contact: Tim Link Phone: (307) 777-7164
Storage Tanks
WY DEQ Water Quality Division
Herschler Building – 4th Floor - West
Cheyenne, WY 82001
Lander (307) 332-3144
Sheridan (307) 673-9337
Casper (307) 473-3465
Website: http://deq.state.wy.us/wqd/index.asp
For more information regarding Wyoming’s aboveground storage tank regulations, visit
the following website: http://deq.state.wy.us/shwd/STP/Compliance/Downloads/
ASTRequirements.pdf.
CERC and LEPC Program Manager Wyoming Office of Homeland Security
122 W. 25th St.
Herschler Bldg, 1st Floor East
Cheyenne, WY 82002
Phone: (307) 777-4663


Correspondence to: SERC and LEPC Program Manager
Wyoming Office of Homeland Security
122 W. 25th St. Herschler Bldg, 1st Floor East
Cheyenne, WY 82002
Phone: (307) 777-4663
After-hours hazardous materials emergency: (307) 777-4321
Website: http://wyohomelandsecurity.state.wy.us/main.aspx
Wyoming requires the federal Tier II form for annual reporting.
HazCom
Wyoming incorporates by reference the requirements for hazard communication
Transportation
WY Department of Transportation
WYDOT Headquarters
5300 Bishop Blvd.
Cheyenne, WY 82009-3340
Phone: (307)777-4375
Website: www.dot.state.wy.us

Reserved

FEDERAL INFORMATION
CONTENTS
OSHA regional offices.......................................................................................... 1

OSHA district offices........................................................................................... 2
OSHA local area offices ....................................................................................... 3
States with OSHA-Approved Programs.................................................................. 12
OSHA regional hazard communication coordinators .................................................. 15
Association addresses ........................................................................................ 16
Other relevant addresses.................................................................................... 19
FMCSA Service Centers ..................................................................................... 21
FMCSA field offices ........................................................................................... 22
EPA regional offices........................................................................................... 27
EPA hotline phone numbers and information .......................................................... 28
3/14 Federal information TOC–1

Reserved
2–Federal information TOC 3/14

OSHA regional offices

If you are unable to contact your local OSHA Area Office, you may contact the appropriate
OSHA Regional Office for information and/or assistance. These addresses are current as of
August 7, 2014.
Region I Region VI
(CT* MA, ME, NH, RI, VT*) (AR, LA, NM,* OK, TX)
JFK Federal Building, Room E340 525 Griffin Street, Suite 602
Boston, MA 02203 Dallas, TX 75202
(617) 565-9860 (972) 850-4145
Fax: (617) 565-9827 Fax: (972) 850-4149
Region II Region VII
(NJ, NY, Puerto Rico, Virgin (IA,* KS, MO, NE)
Islands)* Two Pershing Square Building
201 Varick Street, Room 670 2300 Main Street, Suite 1010
New York, NY 10014 Kansas City, MO 64108-2416
(816) 283-8745
(212) 337-2378
Fax: (816) 283-0547
Fax: (212) 337-2371
Region VIII
Region III
(CO, MT, ND, SD, UT,* WY*)
(DC, DE, MD,* PA, VA,* WV)
Cesar Chavez Memorial Building
U.S. Department of Labor/OSHA 1244 Speer Blvd., Suite 551
The Curtis Center—Suite 740 West Denver, CO 80204
170 S. Independence Mall West (720) 264-6550
Philadelphia, PA 19106-3309 Fax: (720) 264-6585
(215) 861-4900
Fax: (215) 861-4904 Region IX
(American Samoa, AZ,* CA,* Guam,
Region IV HI,* NV,* Trust Territories of the
(AL, FL, GA, KY,* MS, NC,* SC,* TN*) Pacific)
61 Forsyth Street SW 90 7th Street, Suite 18100
Room 6T50 San Francisco, CA 94103
Atlanta, GA 30303 (415) 625-2547 (Main Public — 8:00 AM -
(678) 237-0400 4:30 PM Pacific)
Fax: (678) 237-0447 Fax: (415) 625-2534
Region V Region X
(IL,* IN,* MI,* MN,* OH, WI) (AK,* ID, OR,* WA*)
230 South Dearborn Street, Room 3244 300 Fifth Avenue, Suite 1280
Chicago, IL 60604 Seattle, WA 98104-2397
(312) 353-2220 (206) 757-6700
Fax: (312) 353-7774 Fax: (206) 757-6705
*These states and territories operate their own OSHA-approved job safety and health pro-
grams (Connecticut, Illinois, New Jersey, New York, and Virgin Islands plans cover public
employees only). States with approved programs must have a standard that is identical to,
or at least as effective as, the federal standard.
9/14 Federal information–1

OSHA district offices

Note: Not all OSHA Regions have a district office. This information is current as of August
4, 2014.
Region I Region VI
(CT,* MA, ME, NH, RI, VT*) (AR, LA, NM,* OK, TX)
JFK Federal Bldg., Rm. E340 525 Griffin St., Ste. 602
(617) 565-9860 (972) 850-4145
Fax: (617) 565-9827 Fax: (972) 850-4149
(NJ, NY,* PR,* VI*) (IA,* KS, MO, NE)
201 Varick St., Rm. 670 Two Pershing Square Building
New York, NY 10014 2300 Main St., Ste. 1010
(212) 337-2378 Kansas City, MO 64108-2416
(816) 283-8745
Fax: (212) 337-2371
Fax: (816) 283-0547
Region III
Region VIII
(DC, DE, MD,* PA, VA,* WV)
(CO, MT, ND, SD, UT,* WY*)
U.S. Department of Labor/OSHA
Cesar Chavez Memorial Building
The Curtis Center, Ste. 740 W 1244 Speer Blvd., Suite 551
170 S. Independence Mall W Denver, CO 80204
Philadelphia, PA 19106-3309 (720) 264-6550
(215) 861-4900 Fax: (720) 264-6585
Fax: (215) 861-4904
Region IX
Region IV
(American Samoa, AZ,* CA,* Guam,
(AL, FL, GA, KY,* MS, NC,* SC,* TN*) HI,* NV,* Trust Territories of the
61 Forsyth St., SW Pacific)
Room 6T50 90 7th St., Ste. 18100
Atlanta, GA 30303 San Francisco, CA 94103
(678) 237-0400 (415) 625-2547
Fax: (678) 237-0447 Fax: (415) 625-2534
Region V Region X
(IL, IN,* MI,* MN,* OH, WI) (AK,* ID, OR,* WA*)
230 S Dearborn St., Rm. 3244 300 Fifth Ave., Ste. 1280
(312) 353-2220 (206) 757-6700
Fax: (312) 353-7774 Fax: (206) 757-6705
* These states and territories operate their own OSHA-approved job safety and health pro-
grams (Connecticut, Illinois, New Jersey, New York, and Virgin Islands plans cover public
employees only). States with approved programs must have a standard that is identical to,
or at least as effective as, the Federal standards.
2–Federal information 9/14

OSHA local area offices

The following is a list of addresses and telephone numbers of OSHA Local Area Offices.
These offices are sources of information, publications, and assistance in understanding the
requirements of the standards. These addresses are current as of August 4, 2014.
Alabama Arkansas
http://labor.alabama.gov/ www.labor.ar.gov/Pages/default.aspx
Birmingham Area Office Little Rock Area Office
Medical Forum Building 10810 Executive Center Dr.
950 22nd Street North, Room 1050 Danville Building #2, Suite 206
Birmingham, AL 35203 Little Rock, AR 72211
(205) 731-1534 (501) 224-1841
Fax: (205) 731-0504 Fax: (501) 224-4431
Mobile Area Office California
1141 Montlimar Drive, Suite 1006 www.dir.ca.gov/occupational_safety.html
Mobile, AL 36609 California Department of Industrial
(334) 441-6131 Relations
Fax: (334) 441-6396 Office of the Director
Alaska 1515 Clay St., 17th Floor
www.labor.state.ak.us/ Oakland, CA 94612
Anchorage Area Office (510) 622-3965
Scott Ketcham, Area Director Oakland Area Office
U.S. Department of Labor - OSHA U.S. Department of Labor - OSHA
222 W. 7th Avenue, Box 22 Ronald Dellums Federal Building
Anchorage, AK 99513 1301 Clay St., Suite 1080 N
(907) 271-5152 Oakland, CA 94612-5217
Fax: (907) 271-4238 (510) 637-3800
Fax: (510) 637-3846
Arizona
www.ica.state.az.us/ADOSH/ San Diego Area Office
ADOSH_main.aspx U.S. Department of Labor - OSHA
Industrial Commission of Arizona 550 West C St., Suite 970
800 West Washington Street, 2nd Floor San Diego, CA 92101-3540
Phoenix, AZ 85007 (619) 557-5030
(602) 542-5795 Fax: (619) 557-6001
Fax: (602) 542-1614 Colorado
Tucson office www.colorado.gov/cs/Satellite/CDLE-
2675 E. Broadway Blvd. #239 LaborLaws/CDLE/1240336908932
Tucson, AZ 85716 Denver Area Office
(520) 628-5478 1391 Speer Boulevard, Suite 210
Fax: (520) 322-8008 Denver, CO 80204-2552
Phoenix Area Office (303) 844-5285
Arizona Division of Occupational Safety Fax: (303) 844-6676
and Health (ADOSH) Englewood Area Office
800 W. Washington St., 2nd floor 7935 East Prentice Avenue, Suite 209
Phoenix, AZ 85007 Englewood, CO 80111-2714
(602) 542-5795 (303) 843-4500
Fax: (602) 542-1614 Fax: (303) 843-4515

Connecticut Tampa Area Office

www.ctdol.state.ct.us/ 5807 Breckenridge Parkway, Suite A
Bridgeport Area Office Tampa, FL 33610-4249
Clark Building (813) 626-1177
1057 Broad Street, 4th Floor Fax: (813) 626-7015
Bridgeport, CT 06604 Georgia
(203) 579-5581
http://www.dol.state.ga.us/
Fax: (203) 579-5516
Atlanta East Area Office
Hartford Area Office LaVista Perimeter Office Park
William R. Cotter Federal Building 2183 North Lake Parkway, Building 7
135 High St., Room 361 Suite 110
Hartford, CT 06103 Tucker, GA 30084-4154
(860) 240-3152 (770) 493-6644
Fax: (860) 240-3155 Fax: (770) 493-7725
Delaware Atlanta West Area Office
www.delawareworks.com/ 1995 North Park Place S.E., Suite 525
Wilmington Area Office Atlanta, GA 30339
Mellon Bank Building, Suite 900 (678) 903-7301
919 Market Street Fax: (770) 984-8855
Wilmington, DE 19801-3319 Savannah Area Office
(302) 573-6518 450 Mall Boulevard, Suite J
Fax: (302) 573-6532 Savannah, GA 31406
District of Columbia (912) 652-4393
Fax: (912) 652-4329
Baltimore/Washington, D.C. Area Office
OSHA Area Office Hawaii
U.S. Department of Labor-OSHA http://labor.hawaii.gov/
1099 Winterson Road, Suite 140 Honolulu Area Office
Linthicum, MD 21090 U.S. Dept. of Labor – OSHA
(410) 865-2055/2056 Prince Jonah Kuhio Kalanianaole
Fax: (410) 865-2068 Federal Building
Florida 300 Ala Mona Blvd., Room 5-146
Honolulu, HI 96850
www.myflorida.com (808) 541-2680
Fort Lauderdale Area Office Fax: (808) 541-3456
1000 South Pine Island Road, Suite 100
Fort Lauderdale, FL 33324 Idaho
(954) 424-0242 http://labor.idaho.gov/
Fax: (954) 424-3073 Boise Area Office
Jacksonville Area Office 1150 North Curtis Road, Suite 201
Ribault Building, Suite 227 Boise, ID 83706
1851 Executive Center Drive (208) 321-2960
Jacksonville, FL 32207 Fax: (208) 321-2966
(904) 232-2895
Fax: (904) 232-1294

Illinois Kansas
www.illinois.gov/idol/Pages/default.aspx www.kdhe.state.ks.us/
Calumet City Area Office Wichita Area Office
1600 167th Street, Suite 9 100 N. Broadway, Suite 470
Calumet City, IL 60409 Wichita, KS 67202
(708) 891-3800 (316) 269-6644
Fax: (708) 862-9659 (800) 362-2896 (Kansas residents only)
Chicago North Area Office Fax: (316) 269-6185
701 Lee Street, Suite 950 Kentucky
Des Plaines, IL 60016 www.labor.ky.gov/Pages/LaborHome.aspx
(847) 803-4800 Nashville Area Office
Fax: (847) 390-8220 51 Century Boulevard Suite 340
Fairview Heights District Office Nashville, TN 37214
11 Executive Drive, Suite 11 (615) 232-3803
Fairview Heights, IL 62208 Fax: (615) 232-3827
(618) 632-8612
Louisiana
Fax: (618) 632-5712
www.ldol.state.la.us/
North Aurora Area Office
Baton Rouge Area Office
365 Smoke Tree Plaza
9100 Bluebonnet Center Boulevard, Suite
North Aurora, IL 60542
201
(630) 896-8700
Fax: (630) 892-2160
(225) 298-5458
Peoria Area Office Fax: (225) 298-5457
1320 West Commerce Drive
Peoria, IL 61615-1462 Maine
(309) 589-7033 www.state.me.us/labor/
Fax: (309) 589-7326 Augusta Area Office
E.S. Muskie Federal Building
Indiana 40 Western Avenue, Room G-26
www.state.in.us/dol/ Augusta, ME 04330
Indianapolis Area Office (207) 626-9160
46 East Ohio Street, Room 453 Fax: (207) 622-8213
Bangor District Office
(317) 226-7290
382 Harlow Street
Fax: (317) 226-7292
Bangor, ME 04401
Iowa (207) 941-8177
www.iowaworkforce.org/ Fax: (207) 941-8179
U.S. Department of Labor - OSHA Maryland
210 Walnut Street, Room 815
www.dllr.state.md.us
Baltimore/Washington, DC Area Office
(515) 284-4794
OSHA Area Office
Fax: (515) 284-4058 U.S. Department of Labor-OSHA
1099 Winterson Road, Suite 140
Linthicum, MD 21090
(410) 865-2055/2056
Fax: (410) 865-2068

Massachusetts Missouri
http://www.mass.gov/lwd/ http://labor.mo.gov/
North Boston Area Office Kansas City Area Office
Shattuck Office Center 2300 Main Street, Suite 168
138 River Road, Suite 102 Kansas City, MO 64108
Andover, MA 01810 (816) 483-9531
(978) 837-4460 (800) 892-2674 (Missouri residents only)
Fax: (978) 837-4455 Fax: (816) 483-9724
South Boston Area Office St. Louis Area Office
639 Granite Street, 4th Floor 1222 Spruce Street, Room 9.104
Braintree, MA 02184 St. Louis, MO 63103
(617) 565-6924 (314) 425-4249
Fax: (617) 565-6923 Voice Mail: (314) 425-4255
Springfield Area Office (800) 392-7743 (Missouri residents only)
1441 Main Street, Room 550 Fax: (314) 425-4289
Springfield, MA 01103-1493 Montana
(413) 785-0123 http://dli.mt.gov/
Fax: (413) 785-0136 Billings Area Office
Michigan Jeff Funke, Area Director
www.michigan.gov/lara/0,4601,7-154- 2900 4th Avenue North, Suite 303
61256_11407---,00.html Billings, MT 59101
Lansing Area Office (406) 247-7494
U.S. Department of Labor Fax: (406) 247-7499
Occupational Safety and Health Nebraska
Administration www.dol.nebraska.gov
315 West Allegan St., Room 207
Omaha Area Office
Lansing, MI 48933
444 Regency Parkway Drive, Suite 303
(517) 487-4996
Omaha, NE 68114
Fax: (517) 487-4997
(402) 553-0171
Minnesota (800) 642-8963 (Nebraska residents only)
www.dli.mn.gov/Main.asp Fax: (402) 551-1288
There are no area offices in Minnesota.
Nevada
Contact the area office in Eau Claire, WI
at: http://dirweb.state.nv.us/
1310 W. Clairemont Avenue Nevada OSHA
Eau Claire, WI 54701 1301 North Green Valley Parkway, Suite
(715) 832-9019 200
Fax: (715) 832-1147 Henderson, NV 89074
Mississippi (702) 486-9020
www.ms.gov/home/ Fax: (702) 990-0365
Jackson Area Office Reno Office
Dr. A.H. McCoy Federal Bldg. 4600 Kietzke Lane, Suite F-153
100 West Capitol St., Suite 749 Reno, NV 89502
Jackson, MS 39269-1620 (775) 824-4600
(601) 965-4606 Fax: (775) 688-1378
Fax: (601) 965-4610

Las Vegas Area Office New Mexico

U. S. Department of Labor - OSHA www.dws.state.nm.us/
Alan Bible Federal Building There are no area offices in New Mexico.
600 Las Vegas Blvd. South, Suite 750 Contact the area office in Lubbock, TX at:
Las Vegas, NV 89101 Lubbock Area Office
(702) 388-6150 1205 Texas Avenue, Room 806
Fax: (702) 388-6160 Lubbock, TX 79401
New Hampshire (806) 472-7681
Fax: (806) 472-7686
www.nh.gov/labor/
Concord Area Office New York
J.C. Cleveland Federal Building www.labor.ny.gov/home/
53 Pleasant Street, Suite 3901 Albany Area Office
Concord, NH 03301 401 New Karner Road, Suite 300
(603) 225-1629 Albany, NY 12205-3809
Fax: (603) 225-1580 (518) 464-4338
New Jersey Fax: (518) 464-4337
http://lwd.dol.state.nj.us/labor/lsse/ Buffalo Area Office
safetyhealth_index.html U.S. Dept. of Labor/OSHA
Avenel Area Office 130 South Elmwood Avenue, Suite 500
1030 St. Georges Avenue Buffalo, NY 14202-2465
Plaza 35, Suite 205 (716) 551-3053
Avenel, NJ 07001 Fax: (716) 551-3126
(732) 750-3270 Long Island Area Office
Fax: (732) 750-4737 1400 Old Country Road
Hasbrouck Heights Area Office Suite 208
500 Route 17 South, 2nd Floor Westbury, NY 11590
Hasbrouck Heights, NJ 07604 (516) 334-3344
(201) 288-1700 Fax: (516) 334-3326
Fax: (201) 288-7315 Manhattan Area Office
Marlton Area Office 201 Varick Street, Room 908
Marlton Executive Park, Building 2 New York, NY 10014
701 Route 73 South, Suite 120 (212) 620-3200
Marlton, NJ 08053 Fax: (212) 620-4121
(856) 596-5200 Queens District Office of the Manhattan
Fax: (856) 596-5201 Area Office
Parsippany Area Office 45-17 Marathon Parkway
299 Cherry Hill Road, Suite 103 Little Neck, NY 11362
Parsippany, NJ 07054 (718) 279-9060
(973) 263-1003 Fax: (718) 279-9057
Fax: (973) 299-7161 Syracuse Area Office
3300 Vickery Road
North Syracuse, NY 13212
(315) 451-0808
Fax: (315) 451-1351

Tarrytown Area Office Toledo Area Office

660 White Plains Road, 4th Floor 420 Madison Avenue, Suite 600
Tarrytown, NY 10591-5107 Toledo, OH 43604
(914) 524-7510 (419) 259-7542
Fax: (914) 524-7515 Fax: (419) 259-6355
North Carolina Oklahoma
www.nclabor.com/osha/osh.htm www.ok.gov/odol/
Raleigh Area Office OSHA_Safety_Pays_Consultation_/index.
4407 Bland Road html
Somerset Park, Suite 210 Oklahoma City Area Office
Raleigh, NC 27609 55 North Robinson, Suite 315
(919) 790-8096 Oklahoma City, OK 73102-9237
Fax: (919) 790-8224 (405) 278-9560
Fax: (405) 278-9572
North Dakota
www.nd.gov/labor/index.html Oregon
Bismarck Area Office www.cbs.state.or.us/external/osha/
Eric Brooks, Area Director Portland Area Office
U.S. Department of Labor 911 NE 11th Ave., Suite 649
Occupational Safety and Health Portland, OR 97232
Administration (503) 231-2017
521 East Main Avenue, Suite 200 Fax: (503) 231-2329
Bismarck, ND 58501
Pennsylvania
(701) 250-4521
Fax: (701) 250-4520 www.dli.state.pa.us/landi/site/default.asp
Allentown Area Office
Ohio Stabler Corporate Center
www.ohiobwc.com/employer/programs/ 3477 Corporate Parkway
safety/SandHOSHAOnsiteDetails.asp Suite 120
Cincinnati Area Office Center Valley, PA 18034
36 Triangle Park Drive (267) 429-7542
Cincinnati, OH 45246 Fax: (267) 429-7567
(513) 841-4132 Erie Area Office
Fax: (513) 841-4114 1128 State Street, Suite 200
Erie, PA 16501
Cleveland Area Office
(814) 874-5150
Essex Place
Fax: (814) 874-5151
6393 Oak Tree Blvd., Suite 203
Cleveland, OH 44131-6964 Harrisburg Area Office
(216) 447-4194 43 Kline Plaza
Fax: (216) 520-1624 Harrisburg, PA 17104-1529
(717) 782-3902
Columbus Area Office Fax: (717) 782-3746
200 North High Street, Room 620
Philadelphia Area Office
Columbus, OH 43215
U.S. Custom House, Room 242
(614) 469-5582
Second & Chestnut Street
Fax: (614) 469-6791
Philadelphia, PA 19106-2902
(215) 597-4955
Fax: (215) 597-1956

Pittsburgh Area Office South Dakota

U.S. Department of Labor-OSHA http://dlr.sd.gov/
William Moorhead Federal Building, There are no area offices in South
Room 905 Dakota. Contact the regional office in
1000 Liberty Avenue Bismarck, ND at:
Pittsburgh, PA 15222 Bismarck Area Office
(412) 395-4903 Eric Brooks, Area Director
Fax: (412) 395-6380 U.S. Department of Labor
Wilkes-Barre Area Office Occupational Safety and Health
The Stegmaier Building, Suite 410 Administration
7 North Wilkes-Barre Boulevard 521 East Main Avenue, Suite 200
Wilkes-Barre, PA 18702-5241 Bismarck, ND 58501
(570) 826-6538 (701) 250-4521
Fax: (570) 821-4170 Fax: (701) 250-4520
Puerto Rico Tennessee
Puerto Rico Area Office www.tn.gov/labor-wfd/tosha.shtml
Triple S Building Nashville Area Office
1510 FD Roosevelt Avenue, Suite 5B 51 Century Boulevard Suite 340
Guaynabo, Puerto Rico 00968 Nashville, TN 37214
(787) 277-1560 (615) 232-3803
Fax: (787) 277-1567 Fax: (615) 232-3827
Rhode Island Texas
www.dlt.ri.gov/occusafe/ www.twc.state.tx.us/
Providence Area Office Austin Area Office
Federal Office Building La Costa Green Bldg.
380 Westminster Mall, Room 543 1033 La Posada Drive, Suite 375
Providence, RI 02903 Austin, TX 78752-3832
(401) 528-4669 (512) 374-0271
Fax: (401) 528-4663 Fax: (512) 374-0086
South Carolina Corpus Christi Area Office
Wilson Plaza
www.llr.state.sc.us/
606 North Carancahua, Suite 700
Columbia Area Office
Corpus Christi, TX 78476
Strom Thurmond Federal Building
(361) 888-3420
1835 Assembly Street, Room 1472
Fax: (361) 888-3424
(803) 765-5904 Dallas Area Office
Fax: (803) 765-5591 1100 East Campbell Road, Suite 250
Richardson, TX 75081
(972) 952-1330
El Paso Area Office
U.S. Dept. of Labor - OSHA
4849 North Mesa Street, Suite 200
El Paso, TX 79912-5936
(915) 534-6251
Fax: (915) 534-6259

Fort Worth Area Office Vermont

North Starr II, Suite 302 http://labor.vermont.gov/
8713 Airport Freeway There are no area offices in Vermont.
Fort Worth, TX 76180-7610 Contact the regional office in Boston, MA
(817) 428-2470 at:
Fax: (817) 581-7723 JFK Federal Building, Room E340
Houston North Area Office Boston, MA 02203
690 S. Loop 336 W., Suite 400 (617) 565-9860
Conroe, TX 77304 Fax: (617) 565-9827
(936) 760-3800 Virginia
Houston South Area Office www.doli.virginia.gov/
17625 El Camino Real, Suite 400 Norfolk Area Office
Houston, TX 77058 Federal Office Building, Room 614
(281) 286-0583 200 Granby St.
(800) 692-4202 Norfolk, VA 23510-1811
Fax: (281) 286-6352 (757) 441-3820
Fax: (757) 441-3594
Lubbock District Office
1205 Texas Avenue, Room 806 Virgin Islands
Lubbock, TX 79401 There are no area offices in the Virgin
(806) 472-7681/7685 Islands. Contact the regional office in
Fax: (806) 472-7686 New York, NY at:
San Antonio District Office 201 Varick Street, Room 670
Fountainhead Tower, Suite 605 New York, NY 10014
8200 W. Interstate 10 (212) 337-2378
Fax: (212) 337-2371
San Antonio, TX 78230
(210) 472-5040 Washington
Fax: (210) 472-5045 www.lni.wa.gov/wisha
Utah Bellevue Area Office
520 112th Avenue, NE, Suite 200
http://laborcommission.utah.gov/ UOSH/ Bellevue, WA 98004
Index.html (425) 450-5480
There are no area offices in Utah. Fax: (425) 450-5483
Contact the regional office in Denver, CO
at: West Virginia
Herb Gibson, Area Director www.wvminesafety.org/
U.S. Department of Labor Charleston Area Office
Occupational Safety and Health 405 Capitol Street, Suite 407
Administration Charleston, WV 25301-1727
1391 Speer Boulevard, Suite 210 (304) 347-5937
Denver, CO 80204-2552 Fax: (304) 347-5275
(303) 844-5285, Ext. 106 Wisconsin
Fax: (303) 844-6676 http://dwd.wisconsin.gov/
Appleton Area Office
1648 Tri Park Way
Appleton, WI 54914
(920) 734-4521
Fax: (920) 734-2661

Eau Claire Area Office

1310 West Clairemont Avenue
Eau Claire, WI 54701
(715) 832-9019
Fax: (715) 832-1147
Madison Area Office
4802 East Broadway
Madison, WI 53716
(608) 441-5388
Fax: (608) 441-5400
Milwaukee Area Office
310 West Wisconsin Avenue, Room 1180
Milwaukee, WI 53203
(414) 297-3315
Fax: (414) 297-4299
Wyoming
http://wyomingworkforce.org/Pages/
default.aspx
There are no area offices in Wyoming.
Contact the regional office in Denver, CO
at:
Herb Gibson, Area Director
U.S. Department of Labor
Occupational Safety and Health
Administration
1391 Speer Blvd., Suite 210
Denver, CO 80204-2552
(303) 844-5285, Ext.106

States with OSHA-Approved Programs

The OSH Act encourages states to develop and operate their own job safety and health
programs. Federal OSHA approves and monitors state plans and provides up to 50 percent
of an approved plan’s operating costs. There are currently 22 states and jurisdictions operat-
ing complete state plans (covering both the private sector and state and local government
employees) and five states which cover public employees only. The following information is
current as of August 7, 2014.
Alaska Hawaii
http://labor.state.ak.us/lss/home.htm http://labor.hawaii.gov/hiosh/
Alaska Department of Labor & Workforce Hawaii Department of Labor and
Development Industrial Relations
1111 W 8th Street, Room 304 Hawaii Occupational Safety and Health
P.O. Box 111149 Division (HIOSH)
Juneau, AK 99811-1149 830 Punchbowl Street, Suite 423
(907) 465-4855 Honolulu, HI 96813
(808) 586-9100
Arizona
www.ica.state.az.us/ADOSH/ Illinois
ADOSH_main.aspx www.illinois.gov/idol/Pages/default.aspx
Arizona Division of Occupational Safety Illinois Department of Labor
and Health (ADOSH) 900 S. Spring Street
800 W Washington Street, 2nd floor Springfield, IL 62704
Phoenix, AZ 85007-2922 (217) 782-6206
(602) 542-5795 Indiana
California www.in.gov/dol/iosha.htm
Indiana Department of Labor
www.dir.ca.gov/occupational_safety.html
402 West Washington Street, Room W195
California Department of Industrial
Relations (DIR) (317) 232-2693
Division of Occupational Safety and
Health Iowa
1515 Clay Street Suite 1901 www.iowaworkforce.org/labor/iosh/index.
Oakland, CA 94612 html
(510) 286-7000 Iowa Division of Labor Services and
Workforce Development
Connecticut 1000 East Grand Avenue
www.ctdol.state.ct.us/osha/osha.htm Des Moines, IA 50319-0209
Connecticut Department of Labor (515) 242-5870
200 Folly Brook Boulevard
Kentucky
Wethersfield, CT 06109
(860) 263-6000 www.labor.ky.gov/dows/oshp/Pages/
Occupational-Safety-and-Health-
Conn-OSHA Program.aspx
38 Wolcott Hill Road Kentucky Occupational Safety and
Wethersfield, CT 06109 Health Program
(860) 263-6900 1047 U.S. Highway 127 South, Suite 4
Frankfort, KY 40601
(502) 564-3070

Maryland New Jersey

www.dllr.state.md.us/labor/mosh.html http://lwd.dol.state.nj.us/labor/lsse/
Department of Labor, Licensing and employer/Public_Employees_OSH.html
Regulation New Jersey Department of Labor and
Division of Labor and Industry Workforce Development
Maryland Occupational Safety and Public Employees Occupational Safety
Health (MOSH) and Health (PEOSH) Office
10946 Golden West Drive, Suite 160 1 John Fitch Plaza
Hunt Valley, MD 21031 P.O. Box 110
(410) 527-4499 Trenton, NJ 08625-0110
(609) 633-3896
Michigan
www.michigan.gov/lara/0,4601,7-154- New Mexico
61256_11407---,00.html www.nmenv.state.nm.us/Ohsb_Website/
Michigan Department of Licensing and index.htm
Regulatory Affairs (LARA) New Mexico Environment Department
Michigan Occupational Safety & Health Occupational Safety and Health Bureau
Administration (MIOSHA) 525 Camino de los Marquez, Suite 3
P.O. Box 30643 Santa Fe, NM 87502
7150 Harris Drive (505) 476-8700
New York
(517) 322-1814
www.labor.state.ny.us/workerprotection/
Minnesota safetyhealth/DOSH_PESH.shtm
www.dli.mn.gov/MnOsha.asp NYS Department of Labor
Minnesota Department of Labor and Public Employees Safety and Health
Industry (PESH) Bureau
Minnesota OSHA Compliance W.A. Harriman Campus
443 Lafayette Road North Building 12, Room 158
St. Paul, MN 55155 Albany, NY 12240
(651) 284-5050 (518) 457-1263
Nevada North Carolina

http://dirweb.state.nv.us/OSHA/osha.htm www.nclabor.com/osha/osh.htm
Nevada Division of Industrial Relations North Carolina Department of Labor
Occupational Safety and Health Occupational Safety and Health Division
Administration
1301 North Green Valley Parkway, Suite
(919) 807-2900
200
Henderson, Nevada 89074 Oregon
(702) 486-9020 www.orosha.org/
Oregon Occupational Safety and Health
Division (Oregon OSHA)
Department of Consumer and Business
Services
350 Winter Street NE, Room 430
P.O. Box 14480
Salem, OR 97309-0405
(503) 378-3272

Puerto Rico Virgin Islands

www.trabajo.pr.gov/prosha/index.asp www.vidol.gov/Units/OSHA/OSHA.htm
Puerto Rico Occupational Safety and Virgin Islands Department of Labor
Health Administration (PR OSHA) (VIDOSH)
P.O. Box 195540 St. Croix Main Office
San Juan, PR 00919-5540 3012 Golden Rock, VITRACO Mall
(787) 754-2172 St. Croix, VI 00890
South Carolina (340) 772-1315
www.scosha.llronline.com/ St. Thomas Main Office
South Carolina Department of Labor, 53A & 54B Kronprindense Gade
Licensing and Regulation St. Thomas, VI 00803-2608
South Carolina OSHA (340) 776-3700
P.O. Box 11329
Virginia
Columbia, S.C. 29211
(803) 896-7665 www.doli.virginia.gov/
Virginia Department of Labor and
Tennessee
Industry
www.tn.gov/labor-wfd/tosha.shtml Main Street Centre Bldg.
Department of Labor and Workforce 600 East Main Street
Development Richmond, VA 23219-4101
TOSHA (804) 371-2327
220 French Landing Drive
Nashville, TN 37243-0655 Washington
(615) 741-2793 www.lni.wa.gov/Safety/default.asp
Utah Washington Department of Labor and
Industries
www.laborcommission.utah.gov/divisions/
Division of Occupational Safety & Health
UOSH/index.html
Utah Labor Commission (DOSH)
Utah OSHA P.O. Box 44600
160 East 300 South, 3rd Floor Olympia, WA 98504-4600
P.O. Box 146600 (360) 902-5494
Salt Lake City, UT 84114-6600 Wyoming
(801) 530-6901
http://wyomingworkforce.org/employers-
Vermont and-businesses/osha/Pages/default.aspx
http://labor.vermont.gov/vosha/ Wyoming Workers Safety and
Vermont Department of Labor and Compensation Division
Industry 1510 East Pershing Boulevard, West
5 Green Mountain Drive Wing
P.O. Box 488 Cheyenne, WY 82002
Montpelier, VT 05601-0488 (307) 777-7786
(802) 828-4000
Note: Connecticut, Illinois, New Jersey, New York, and the Virgin Islands plans cover public
employees only.

OSHA regional hazard communication coordinators

Current as of August 4, 2014.
Region I Region VI
Boston Regional Hazard Communication Dallas Regional Hazard Communication
Coordinator Coordinator
U.S. Department of Labor-OSHA U.S. Department of Labor-OSHA
JFK Federal Building, Room E340 525 South Griffin Street, Room 602
(617) 565-9860 (214) 767-4145

New York Regional Hazard Kansas City Regional Hazard
Communication Coordinator Communication Coordinator
Two Pershing Square Building
201 Varick Street, Room 670
2300 Main Street, Suite 1010
New York, NY 10014
Kansas City, MO 64105
(212) 337-2378
(816) 283-8745
Region III
Region VIII
Philadelphia Regional Hazard Denver Regional Hazard Communication
Communication Coordinator Coordinator
The Curtis Center, Suite 740 West Cesar Chavez Memorial Building
170 South Independence Mall West 1244 Speer Blvd., Suite 551
Philadelphia, PA 19106-3309 Denver, CO 80804
(215) 861-4900 (720) 264-6550
Region IV Region IX
Atlanta Regional Technical Support- San Francisco Assistant Regional
Hazard Communication Administrator
61 Forsyth Street, SW, Room 6T50 90 7th Street, Suite 18100
Atlanta, GA 30303 San Francisco, CA 94103
(678) 237-0400 (415) 625-2547
Region V Region X
Chicago Regional Hazard Communication Seattle Regional Hazard Communication
Coordinator Coordinator
230 South Dearborn Street, Room 3244 300 Fifth Ave., Ste. 1280
(312) 353-2220 (206) 757-6700

Association addresses
Alliance of Hazardous Materials American Institute of Chemical Engineers
Professionals (AHMP) (AICE)
www.ahmpnet.org www.aiche.org
9650 Rockville Pike 120 Wall St. Fl. 23
Bethesda, MD 20814 New York, NY 10005-4020
(800) 437-0137 (toll-free) (800) 242-4363
(301) 634-7430 (203) 702-7660 (outside the U.S.)
Fax: (301) 634-7431 Fax: (203) 775-5177
American Chemistry Council (ACC) American National Standards Institute
www.americanchemistry.com (ANSI)
700 2nd St., Northeast www.ansi.org
Washington, DC 20002 1899 L St., NW, 11th Fl.
(202) 249-7000 Washington, DC 20036
Fax: (202) 249-6100 (202) 293-8020
Fax: (202) 293-9287
American Chemical Society (ACS)
or
www.acs.org 25 W 43rd St., 4th Fl.
1155 16th St., Northwest New York, NY 10036
Washington, DC 20036 (212) 642-4900
(800) 227-5558 (US only) Fax: (212) 398-0023
(202) 872-4600 (Worldwide)
American Petroleum Institute (API)
American Conference of Governmental
www.api.org
Industrial Hygienists (ACGIH)
1220 L St., Northwest
www.acgih.org Washington, DC 20005-4070
1330 Kemper Meadow Dr. (202) 682-8000
Cincinnati, OH 45240
(513) 742-2020 (customers/members) American Society of Heating, Refrigerating
(513) 742-6163 (administrative phone) and Air-Conditioning Engineers
Fax: (513) 742-3355 www.ashrae.org
1791 Tullie Circle, Northeast
American Industrial Hygiene Association
Atlanta, GA 30329
(AIHA)
(800) 527-4723 (U.S. and Canada only)
www.aiha.org (404) 636-8400
3141 Fairview Park Dr., Ste. 777 Fax: (404) 321-5478
Falls Church, VA 22042
(703) 849-8888 American Society for Testing and Materials
Fax: (703) 207-3561 (ASTM)
www.astm.org
100 Barr Harbor Dr.
P.O. Box C700
West Conshohocken, PA 19428-2959
(877) 909-2786 (U.S. and Canada only)
(610) 832-9585 (International)

American Society of Agricultural and Compressed Gas Association (CGA)

Biological Engineers (ASABE) www.cganet.com
www.asabe.org 14501 George Carter Way, Ste. 103
2950 Niles Rd. Chantilly, VA 20151-2923
St. Joseph, MI 49085 (703) 788-2700
(269) 429-0300 Fax: (703) 961-1831
Fax: (269) 429-3852
International Agency for Research on
American Society of Mechanical Engineers Cancer (IARC)
(ASME) www.iarc.fr
www.asme.org 150 Cours Albert Thomas
2 Park Ave. 69372 Lyon CEDEX 08
New York, NY 10016-5990 France
(800) 843-2763 (U.S. and Canada) +33 (0)4 72 73 84 85
001-800-843-2763 (Mexico) Fax: +33 (0)4 72 73 85 75
(973) 882-1170 (outside North America)
International Safety Equipment Association
American Society of Safety Engineers www.safetyequipment.org
(ASSE) 1901 N Moore St.
www.asse.org Arlington, VA 22209-1762
1800 E Oakton St. (703) 525-1695
Des Plaines, IL 60018 Fax: (703) 528-2148
(847) 699-2929
National Association of Manufacturers
Fax: (847) 768-3434
(NAM)
American Welding Society (AWS) www.nam.org
www.aws.org 733 10th St. Northwest, Ste. 700
8669 NW 36 St., Ste. 130 Washington, DC 20001
Miami, FL 33166-6672 (800) 814-8468
(800) 443-9353 (202) 637-3000 (in Washington, DC)
(305) 443-9353 Fax: (202) 637-3182
Chemical Abstract Service (CAS) National Fire Protection Association (NFPA)
www.cas.org www.nfpa.org
P.O. Box 3012 1 Batterymarch Park
Columbus, OH 43210 Quincy, MA 02169-7471
(800) 848-6538 (North America only) (617) 770-3000
(614) 447-3600 (worldwide) Fax: (617) 770-0700
Fax: (614) 447-3713
National Safety Council
Council of Producers & Distributors of www.nsc.org
Agrotechnology 1121 Spring Lake Dr.
Formerly known as Chemical Producers Itasca, IL 60143-3201
and Distributors Association (800) 621-7615
http://cpda.com/ (630) 285-1121
1730 Rhode Island Ave., Ste. 812 Fax: (630) 285-1315
(202) 386-7407
Fax: (202) 386-7409

National Waste & Recycling Association

https://wasterecycling.org/
4301 Connecticut Ave., Northwest, Ste.
300
(800) 424-2869
(202) 244-4700
Fax: (202) 966-4824
Society of Automotive Engineers (SAE)
www.sae.org
SAE International
400 Commonwealth Dr.
Warrendale, PA 15096-0001
(877) 606-7323 (U.S. and Canada)
(724) 776-4970 (Outside U.S. and
Canada)
Fax: (724) 776-0790
Society for Chemical Hazard
Communication (SCHC)
www.schc.org
P.O. Box 1392
Annandale, VA 22003-9392
(703) 658-9246
Fax: (703) 658-9247
Society of Chemical Manufacturers &
Affiliates (SOCMA)
Formerly known as Synthetic Organic
Chemical Manufacturers Association
www.socma.com
1850 M St. NW, Ste. 700
Washington, DC 20036-5810
(202) 721-4100
Fax: (202) 296-8120

Other relevant addresses

Occupational Safety and Health Administration (OSHA)
United States Department of Labor
200 Constitution Avenue, NW
(800) 321-6742
OSHA Enforcement Programs
Directorate of Enforcement Programs (DEP)
U.S. Dept. of Labor, OSHA
200 Constitution Avenue, NW, RM N-3119
(202) 693-2100
OSHA Training Institute
OSHA Directorate of Training and Education
2020 South Arlington Heights Road
Arlington Heights, IL 60005-4102
(847) 759-7700
National Institute for Occupational Safety and Health (NIOSH)
Education and Information Division (EID)
Mailstop C14
4676 Columbia Parkway
Cincinnati, OH 45226
(513) 533-8302
National Toxicology Program
Office of Liasion, Policy and Review
PO Box 12233, MD K2-03
Research Triangle Park, NC 27709
(919) 541-0530
(919) 541-3419 (Central Data Management)
Cincinnati Technical Center
Formerly Cincinnati Laboratory
(Technical equipment calibration and repair)
435 Elm Street, Suite 500
Cincinnati, OH 45202-2673
(513) 684-3721
Salt Lake City Laboratory
(Chemical analyses of monitoring samples)
Salt Lake Technical Center
8660 South Sandy Parkway
Sandy, UT 84070-6424
(801) 233-4900

World Health Organization (WHO)

Regional Office of the Americas
525 23rd Street, NW
(202) 974-3000

FMCSA Service Centers

The Federal Motor Carrier Safety Administration (FMCSA) maintains Service Centers, to
which official correspondence may be directed, and Field Offices, where the safety investiga-
tors for each state are located. The field offices are also referred to as “divisions.” Each state
has one Field Office, which is where the Division Administrator for that Field Office is
located. The staffs at these offices are ready and willing to answer questions and help any-
one who is interested in improving commercial vehicle safety.
Eastern Service Center
802 Cromwell Park Dr.
Ste. N
Glen Burnie, MD 21061
(443) 703-2240
Fax: (443) 703-2253
Connecticut, Delaware, District of Columbia, Maine, Maryland, Massachusetts, New
Hampshire, New Jersey, New York, Pennsylvania, Puerto Rico, Rhode Island, Vermont,
Virginia, Virgin Islands, West Virginia
Southern Service Center
1800 Century Blvd., Ste. 1700
Atlanta, GA 30345
(404) 327-7400
Fax: (404) 327-7349
Alabama, Arkansas, Florida, Georgia, Kentucky, Louisiana, Mississippi, North Carolina,
Oklahoma, South Carolina, Tennessee
Midwestern Service Center
4749 Lincoln Mall Dr., Ste. 300A
Matteson, IL 60443
(708) 283-3577
Fax: (708) 283-3579
Illinois, Indiana, Iowa, Kansas, Michigan, Minnesota, Missouri, Nebraska, Ohio,
Wisconsin
Western Service Center
Golden Hills Office Centre
12600 W. Colfax Ave., Ste. B-300
Lakewood, CO 80215
(303) 407-2350
Fax: (303) 407-2339
Alaska, American Samoa, Arizona, California, Colorado, Guam, Hawaii, Idaho, Montana,
Nevada, New Mexico, North Dakota, Northern Mariana Islands, Oregon, South Dakota,
Texas, Utah, Washington, Wyoming
Note for Canadian and Mexican Carriers:
Canadian carriers should contact an FMCSA division (state) office in AK, ME, MI, MT, NY,
ND, VT, or WA.
Mexican carriers should contact an FMCSA division (state) office in AZ, CA, NM, or TX.

FMCSA field offices

Alabama Connecticut
Federal Motor Carrier Safety Federal Motor Carrier Safety
Administration Administration
520 Cotton Gin Rd. Glastonbury Corporate Center
Montgomery, AL 36117-2018 628-2 Hebron Ave., Ste. 302
(334) 290-4954 Glastonbury, CT 06033-5007
Fax: (334) 290-4944 (860) 659-6700
Fax: (860) 659-6725
Alaska
Federal Motor Carrier Safety Delaware
Administration Federal Motor Carrier Safety
Frontier Bldg., Ste. 260 Administration
3601 “C” St. College Business Park
Anchorage, AK 99503 1203 College Park Dr., Ste. 102
(907) 271-4068 Dover, DE 19904-8703
Fax: (907) 271-4069 (302) 734-8173
Arizona Fax: (302) 346-5101
Federal Motor Carrier Safety District of Columbia
400 E. Van Buren St., Ste. 401 Administration
Phoenix, AZ 85004 1990 K St., NW, Ste. 510
(602) 379-6851 Washington, DC 20006
Fax: (602) 379-3627 (202) 219-3576
Arkansas Fax: (202) 219-3546
Federal Motor Carrier Safety Florida
Administration
Federal Motor Carrier Safety
2527 Federal Bldg.
700 W. Capitol Ave. Administration
Little Rock, AR 72201 545 John Knox Rd., Rm. 102
(501) 324-5050 Tallahassee, FL 32303
Fax: (501) 324-6562 (850) 942-9338
Fax: (850) 942-9680
California
Georgia
1325 J St., Ste. 1540 Administration
Sacramento, CA 95814-2941 Two Crown Center
(916) 930-2760 1745 Phoenix Blvd., Ste. 380
Fax: (916) 930-2778 Atlanta, GA 30349
(678) 284-5130
Colorado
Fax: (678) 284-5146
Administration
12300 W. Dakota Ave., Ste. 130
Lakewood, CO 80228
(720) 963-3130
Fax: (720) 963-3131

Hawaii Kentucky
Prince Jonah Kuhio Kalanianaole Bldg. Federal Building and U.S. Courthouse
300 Ala Moana Blvd., Rm. 3-239 330 W. Broadway, Rm. 124
P.O. Box 50226 Frankfort, KY 40601
Honolulu, HI 96850 (502) 223-6779
(808) 541-2790 Fax: (502) 223-6767
Fax: (808) 541-2702
Louisiana
Idaho Federal Motor Carrier Safety
Federal Motor Carrier Safety Administration
Administration 5304 Flanders Dr., Ste. A
3200 N. Lakeharbor Ln., Ste. 161 Baton Rouge, LA 70808
Boise, ID 83703 (225) 757-7640
(208) 334-1842 Fax: (225) 757-7636
Fax: (208) 334-1046
Maine
Illinois Federal Motor Carrier Safety
Administration Edmund S. Muskie Federal Bldg.
3250 Executive Park Dr. 40 Western Ave., Rm. 411
Springfield, IL 62703-4514 Augusta, ME 04330
(217) 492-4608 (207) 622-8358
Fax: (217) 492-4986 Fax: (207) 622-8477
Indiana Maryland
Minton-Capehart Federal Bldg. City Crescent Bldg.
575 N. Pennsylvania St., Rm. 261 10 S. Howard St., Ste. 2710
Indianapolis, IN 46204-1520 Baltimore, MD 21201
(317) 226-7474
(410) 962-2889
Fax: (317) 226-5657
Fax: (410) 962-3916
Iowa
Massachusetts
Administration
105 6th St. Administration
Ames, IA 50010-6337 50 Mall Rd., Ste. 212
(515) 233-7400 Burlington, MA 01803
Fax: (515) 233-7494 (781) 425-3210
Fax: (781) 425-3225
Kansas
Administration
1303 SW First American Pl., Ste. 200
Topeka, KS 66604-4040
(785) 271-1260
Fax: (877) 547-0378

Michigan Nevada
Federal Bldg. 705 N. Plaza St., Ste. 204
315 W. Allegan St., Rm. 219 Carson City, NV 89701
Lansing, MI 48933-1514 (775) 687-5335
(517) 853-5990 Fax: (775) 687-8353
Fax: (517) 377-1868
New Hampshire
Minnesota Federal Motor Carrier Safety
Administration 70 Commercial St., Ste. 102
380 Jackson St. Concord, NH 03301
Galtier Plaza, Ste. 500 (603) 228-3112
St. Paul, MN 55101 Fax: (603) 223-0390
(651) 291-6150
New Jersey
Fax: (651) 291-6001
Mississippi Administration
Federal Motor Carrier Safety One Independence Way, Ste. 120
Administration Princeton, NJ 08540
100 West Capitol St., Ste. 1049 (609) 275-2604
Jackson, MS 39269 Fax: (609) 275-5108
(601) 965-4219
New Mexico
Fax: (601) 965-4674
Missouri Administration
Federal Motor Carrier Safety 2440 Louisiana Blvd., NE
Administration Ste. 520
3219 Emerald Ln., Ste. 500 Albuquerque, NM 87110
Jefferson City, MO 65109 (505) 346-7858
(573) 636-3246 Fax: (505) 346-7859
Fax: (573) 636-8901
New York
Montana Federal Motor Carrier Safety
Administration Leo W. O’Brien Federal Bldg., Rm. 815
2880 Skyway Dr. Clinton Ave. and N. Pearl St.
Helena, MT 59602 Albany, NY 12207
(406) 449-5304 (518) 431-4145
Fax: (406) 449-5318 Fax: (518) 431-4140
Nebraska North Carolina
100 Centennial Mall North, Rm. 406 310 New Bern Ave., Ste. 468
Lincoln, NE 68508-5146 Raleigh, NC 27601
(402) 437-5986 (919) 856-4378
Fax: (402) 437-5837 Fax: (919) 856-4369

North Dakota Rhode Island

1471 Interstate Loop 20 Risho Ave., Ste. E
Bismarck, ND 58503 East Providence, RI 02914
(701) 250-4346 (401) 431-6010
Fax: (701) 250-4389 Fax: (401) 431-6019
Ohio South Carolina
200 N. High St., Rm. 609 1835 Assembly St., Ste. 1253
Columbus, OH 43215-2482 Columbia, SC 29201-2430
(614) 280-5657 (803) 765-5414
Fax: (614) 280-6875 Fax: (803) 765-5413
Oklahoma South Dakota
300 N. Meridian, Ste. 106 North 1410 E. Highway 14, Ste. B
Oklahoma City, OK 73107-6560 Pierre, SD 57501
(405) 605-6047 (605) 224-8202
Fax: (405) 605-6176 Fax: (605) 224-1766
Oregon Tennessee
The Equitable Center 640 Grassmere Park, Ste. 111
530 Center St., NE, Ste. 440 Nashville, TN 37211
Salem, OR 97301-3740 (615) 781-5781
(503) 399-5775 Fax: (615) 781-5780
Fax: (503) 316-2580
Texas
Pennsylvania Federal Motor Carrier Safety
Administration 903 San Jacinto Blvd., Ste. 101
215 Limekiln Rd., Ste. 200 Austin, TX 78701
New Cumberland, PA 17070 (512) 916-5440
(717) 614-4060 Fax: (512) 916-5482
Fax: (717) 614-4066
Utah
Puerto Rico Federal Motor Carrier Safety
Administration 310 E. 4500 S., Ste. 102
Torre Chardón Ste. 207 Salt Lake City, UT 84107-3993
350 Chardón St. (801) 288-0360
Hato Rey, PR 00918 Fax: (801) 288-8867
(787) 766-5985
Fax: (787) 766-5015

Vermont West Virginia

Federal Bldg. 700 Washington St. East
87 State St., Rm. 305 Geary Plaza, Ste. 205
P.O. Box 338 Charleston, WV 25301
Montpelier, VT 05601 (304) 347-5935
(802) 828-4480 Fax: (304) 347-5617
Fax: (802) 828-4581
Wisconsin
Virginia
Administration One Point Pl., Ste. 101
400 N. 8th St., Ste. 780
Richmond, VA 23219-4827
(608) 662-2010
(804) 771-8585
Fax: (608) 829-7540
Fax: (804) 771-8670
Washington Wyoming
2424 Heritage Ct., SW, Suite 302 2617 East Lincolnway, Ste. F
Olympia, WA 98502-6031 Cheyenne, WY 82001
(360) 753-9875 (307) 772-2305
Fax: (360) 753-9024 Fax: (307) 772-2905
Note for Canadian and Mexican Carriers: Canadian carriers should contact an FMCSA
Field Office in AK, ME, MI, MT, NY, ND, VT, or WA. Mexican carriers should contact an
FMCSA Field Office in AZ, CA, NM, or TX.

EPA regional offices

This information is current as of March 5, 2008.
Region I Region VI
(CT, MA, ME, NH, RI, VT) (AR, LA, NM, OK, TX)
1 Congress Street, Suite 1100 Fountain Place 12th Floor, Suite 1200
Boston, MA 02114-2023 1445 Ross Avenue
www.epa.gov/region01/ Dallas, TX 75202-2733
(888) 372-7341 (within Region) www.epa.gov/region06/
(617) 918-1111 (outside Region) (214) 665-2200
(800) 887-6063 (in Region 6)
Region II
Region VII
(NJ, NY, Puerto Rico, Virgin Islands)
290 Broadway (IA, KS, MO, NE)
New York, NY 10007-1866 11201 Renner Blvd.
Lenexa, KS 66219
www.epa.gov/region02/
www.epa.gov/region07/
(212) 637-3000
(913) 551-7003
Region III (800) 223-0425
(DC, DE, MD, PA, VA, WV) Region VIII
1650 Arch Street (3PM52) (CO, MT, ND, SD, UT, WY)
Philadelphia, PA 19103-2029 1595 Wynkoop St.
www.epa.gov/region03/ Denver, CO 80202-1129
(215) 814-5000 www.epa.gov/region08/
(800) 438-2474 (within Region) (303) 312-6312
Region IV (800) 227-8917 (within Region)
(AL, FL, GA, KY, MS, NC, SC, TN) Region IX
Atlanta Federal Center (American Samoa, AZ, CA, Guam, HI,
61 Forsyth Street, SW NV, Trust territories of the Pacific)
Atlanta, GA 30303-3104 75 Hawthorne Street
www.epa.gov/region04/ San Francisco, CA 94105
(800) 241-1754 (415) 947-8000
(866) EPA-WEST (within Region)
Region V
(IL, IN, MI, MN, OH, WI) Region X
77 West Jackson Boulevard (AK, ID, OR, WA)
Chicago, IL 60604-3507 1200 Sixth Avenue
www.epa.gov/region5/ Seattle, WA 98101
(800) 621-8431 (within Region) (206) 553-1200
(800) 424-4372

EPA hotline phone numbers and information

This information is current as of June 3, 2008.
Acid Rain Hotline Clearinghouse for Inventories and Emission

1-202-343-9620 Factors’ Info CHIEF Help Desk
919-541-1000
Aerometric Information Retrieval System
email: info.chief@epa.gov
(AIRS) - Air Quality Subsystem (AQS) -
Hotline Emissions Measurement Center (EMC)
1-866-411-4EPA email: emc@epa.gov
Aerometric Information Retrieval System Endangered Species Protection Program
(AIRS) - AIRS Facility Subsystem (AFS) - (Pesticides) Information Line
Helpline 1-800-447-3813
1-800-367-1044
Energy Star
Ambient Monitoring Technology Information 1-888-STAR-YES (1-888-782-7937)
Center 202-775-6650 (Washington, DC Area
email: amtic@epamail.epa.gov Local)
Antimicrobial Information Hotline Environmental Financing Information
1-703-308-6411 Network (EFIN)
Fax: 1-703-308-6467 202-564-4994
email: Info___Antimicrobial@epa.gov Fax: 202-565-2587
email: efin@epa.gov
Asbestos Ombudsman Hotline
1-800-368-5888 Environmental Justice Hotline
202-566-1970 (Washington, DC Area 1-800-962-6215
Local) email: environmental-justice-epa@epa.gov
Fax: 202-566-1505
EPA Enforcement Economic Models
Best Workplaces For Commuters Helpline
Fax: 813-974-5168, Attention: Phil 1-888-ECONSPT (1-888-326-6778)
Winters
EPA Grants and Fellowships Hotline (NCER
Center for Exposure Assessment Modeling Hotline)
(CEAM) Help Desk 1-800-490-9194
706-355-8403
EPA Imported Vehicles and Engines Public
Fax: 706-355-8302
Help Line
email: ceam@epa.gov
734-214-4100
Clean Air Technology Center (CATC) Fax: 734-214-IMPO (4676)
Infoline e-mail: Imports@epa.gov
formerly Control Technology Center
EPA Test Methods
919-541-0800 (English)
919-541-1800 (Spanish) 617-918-1991
Fax: 919-541-3207 Fax: 617-918-1992
email: catcmail@epa.gov email: nelson.peg@epa.gov

Indoor Air Quality Information National Radon Hotline

Clearinghouse (IAQINFO) 1-800-SOS-RADON (1-800-767-7236)
1-800-438-4318 1-800-55-RADON (helpline)
email: iaqinfo@aol.com 1-866-528-3187 (Spanish/English)
202-293-2270 (EHC)
Inspector General Hotline
Fax: 202-293-0032
1-888-546-8740
202-566-2476 (Washington, DC Area National Response Center Hotline
Local) 1-800-424-8802
Fax: 202-566-2549 202-267-2675 (Washington, DC Area
Local)
Integrated Risk Information System (IRIS)
Hotline National Small Flows Clearinghouse Hotline
202-566-1676 1-800-624-8301
Fax: 202-566-1749 304-293-4191 (West Virginia Local)
email: Hotline.IRIS@epa.gov
Office of Water Resource Center (OWRC
Local Government Reimbursement Program 202-566-1729
Helpline Fax: 202-566-1736
1-800-431-9209 1-800-832-7828 (Wetlands Helpline)
email: border.team@epa.gov email: center.water-resource@epa.gov
National Compliance Assistance Ozone Protection Hotline
Clearinghouse 1-800-296-1996
202-564-0697 202-343-9210 (Washington, DC Area
Local)
National Service Center for Environmental
Publications (NSCEP, formerly NCEPI) Pay-As-You-Throw (PAYT) Helpline
1-800-490-9198 1-888-EPA-PAYT, (1-888-372-7298)
Fax: 301-604-3408
Pollution Prevention Information
email: nscep@bps-lmit.com
Clearinghouse (PPIC)
National Hispanic Indoor Air Quality Hotline 202-566-0799
1-866-528-3187 (Spanish/English) Fax: 202-564-8899
email: ppic@epa.gov
National Lead Information Center Hotline
1-800-424-LEAD (1-800-424-5323) Reasonably Available Control Technology/
email: epa-hotline@abvi-goodwill.com Best AvailableControl Technology/ Lowest
Achievable Emission Rate Clearinghouse
National Pesticide Information Center (RBLC)
1-800-858-7378 919-541-0800
Fax: 541-737-0761 Fax: 919-541-0242
email: npic@ace.orst.edu
Safe Drinking Water Hotline
National Poison Control Hotline
1-800-426-4791
1-800-222-1222 (emergency only) Fax: 703-412-3333
202-362-3867 (for administrative and
materials requests)
202-362-8563 (TDD)

Small Business Ombudsman Hotline Toxic Substances Control Act (TSCA)

1-800-368-5888 Hotline
202-566-2075 (Washington, DC Area 202-554-1404
Local) Fax: 202-554-5603
Fax: 202-566-1505
email: suber.angela@epa.gov WasteWise Helpline
1-800-EPA-WISE (1-800-372-9473)
Storet Water Quality System Hotline
Fax: 703-308-8686
1-800-424-9067 email: OSWWasteWise@epa.gov
email: STORET@epa.gov
Wetlands Information Hotline
Superfund and EPCRA Call Center
1-800-832-7828
800-424-9346 202-566-1730 (Washington, DC Area
1-800-553-7672 (TDD) Local)
703-412-3323 (Washington, DC Area local
Fax: 202-566-1736
TCC)
email: wetlands.helpline@epa.gov
Fax: 703-412-9810
email: tri.us@epa.gov
Toxic Release Inventory - User Support
Service
202-566-0250
email: tsca-hotline@epa.gov
Toxic Release Inventory - Community Right
To Know - EPCRA Hotline
1-800-424-9346
703-412-9810 (Washington, DC Area
Local)
1-800-553-7672 (TDD)
703-412-3323 (Washington, DC Area
Local TDD)

SUBJECT INDEX
This subject index is designed to help you quickly locate information in Environmental
Compliance Manual. Because each chapter is numbered separately, subject categories are
referenced by chapter and page number within that chapter.
A
Aboveground Storage Tanks (ASTs)
Federal regulatory overview - Storage tanks-24
Acid rain
Federal regulatory overview - Clean air-34
Aerosol cans
Federal regulatory overview - Waste-60
Air Monitoring
Federal regulatory overview - HAZWOPER-14
Air permit exemptions
Air permits
Air pollution prevention
Air toxics
Attainment/nonattainment
B
Batteries
Federal regulatory overview - Waste-68N, 75
Federal regulatory overview - Hazardous materials-23
Boilers and incinerators - NESHAPS
C
CAA enforcement provisions
CAA New source performance standards (NSPS)
CAA Regional Haze
CAA State implementation plans (SIPS)
9/14 Index–1

CAA Titles
CAA Transport rules
California’s clean vehicle program
CERCLA
Chemical inventory
Federal regulatory overview - HazCom-30
Chemical security
Clean Air Act (CAA)
Federal regulatory overview - Community right to know-31
Federal regulatory overview - Process safety and risk management-7, 13, 15
Federal regulatory overview - TSCA-16
Clean Air Act reporting deadlines
Clean Air Interstate Rule (CAIR)
Clean Water
Federal regulatory overview - Clean water-22
Clean Water Act (CWA)
Federal regulatory overview - Community right to know-31, 44
Clean-Fuel fleet program
Community Right to Know
Comprehensive Environmental Response, Compensation and Liability Act (CERCLA)
Construction General Permit (CGP)
Federal regulatory overview - Clean water-4B
Container labels
Continuous Release Reporting
Cross-state air pollution rule (CSAPR)
Index–2 9/14

D
Department of Transportation (DOT)
Federal regulatory overview - Waste-62, 63, 74, 75
Dipping and coating operations
Drums and Containers
E
Electronic hazardous waste manifesting
Federal regulatory overview - Waste-68L
Emergency Action Plan (EAP)
Federal regulatory overview - HAZWOPER-7, 161
Emergency Planning
Federal regulatory overview - Community right to know-2, 3, 21
Emergency Planning and Community Right To Know Act (EPCRA)
Emergency Response
Federal regulatory overview - HAZWOPER-17, 21, 32, 48, 70, 78, 80, 97, 111
Emergency Response Guidebook (ERG)
Emergency Response Plan
Federal regulatory overview - HAZWOPER-17, 32, 71, 101, 111
Emergency Response Release
Emissions standards for mobile sources
Engineering Controls
Environmental Protection Agency (EPA)
Compliance assistance - Federal information-28
EPA
Compliance assistance - Federal information-27
Exports
Extremely Hazardous Substance (EHS)
9/14 Index–3

F
Facility Response Plan (FRP)
Federal regulatory overview - Clean water-14B
First Aid
Form R
G
Geologic Sequestration of CO2
Globally Harmonized System for classifying and labeling chemicals (GHS)
Federal regulatory overview - HazCom-1, 2
Greenhouse gases (GHGs) - emission standards
Greenhouse gases (GHGs) - mandatory reporting
Greenhouse gases (GHGs) - permitting
H
Hazard Communication checklist
Hazard Communication definitions
Hazard Communication (HazCom)
Hazard Communication program
Hazard communication references
Hazard statements
Hazardous Materials
Federal regulatory overview - Hazardous materials-3, 25
Hazardous Materials Incident Reports
Federal regulatory overview - Hazardous materials-20H
Hazardous Waste
Federal regulatory overview - HAZWOPER-17, 21, 57, 73, 113
Index–4 9/14

Hazardous waste — Annual reporting

Hazardous waste — Biennial reporting
Hazardous waste — Waste minimization plans
Hazardous waste containers
Hazardous waste labeling
Hazardous Waste Manifest
Federal regulatory overview - Waste-64, 82
Hazardous waste manifesting
Federal regulatory overview - Waste-68L
Hazardous waste marking
Hazardous Waste Operations and Emergency Response (HAZWOPER)
Federal regulatory overview - HAZWOPER-3, 172, 173
Hazardous waste release notifications
Hazardous waste shipping
I
Incidental Release
Indoor air pollution sources
Indoor air quality
Indoor air quality program
Industry focus — Painting contractors
Industry focus — Photo processors
ISO 14000
ISO 14001
9/14 Index–5

L
Labels
Lamps
Large Quantity Handlers of Universal Waste (LQHUW)
Local Emergency Planning Committee (LEPC)
M
Major source/area source air permitting
Markings
Maximum theoretical emissions
Federal regulatory overview - HAZWOPER-10, 13, 19, 42
Mercury
Mercury and air toxics standards for power plants
Montreal Protocol
N
NAAQS Criteria pollutants
National ambient air quality standards (NAAQS)
National emissions standards for hazardous air pollutants (NESHAPS)
National secondary drinking water regulations
O
Oil Pollution
Index–6 9/14

Ozone depletion
P
Permits
Personal Protective Equipment (PPE)
Pesticides
Pictograms
Placards
Pollution Prevention Plan (PPP)
Federal regulatory overview - Clean water-4A
Polychlorinated biphenyls (PCBs)
Potential to emit
Precautionary statements
Pretreatment Program
Prevention of Significant Deterioration of air quality
Primary and secondary NAAQS
Process Safety Management (PSM)
Federal regulatory overview - Process safety and risk management-3
R
RCRA
RCRA personnel training
RCRA personnel training guidance
RCRA personnel training tips
REACH
9/14 Index–7

Recordkeeping
Federal regulatory overview - Hazardous materials-20G
Regulated chemicals
Renewable fuels standard (RFS)
Resource Conservation and Recovery Act (RCRA)
Federal regulatory overview - Waste-1, 20, 39, 59, 68N
Respirators
Responders
Risk Management Plan (RMP)
Risk Management Plan (RMP) (Checklist)
S
Safe Drinking Water Act
Safety Data Sheet (SDS)
Safety Data Sheets (SDS)
SARA Title III
Sick building syndrome
Signal words
Site Security
Index–8 9/14

Site Security Plan

Small Quantity Handlers of Universal Waste (SQHUW)
Solvent-contaminated wipes (Shop rags)
SPCC Plan
Federal regulatory overview - Clean water-14, 25
Spill Kit
Spill Prevention, Control, and Countermeasures (SPCC)
Spills
State Emergency Response Commission (SERC)
Stormwater
Superfund Amendments and Reauthorization Act (SARA)
Superfund (SARA)
T
TCLP
Tier I Reports
Tier II Reports
Total maximum daily loads (TMDLs)
Toxic Chemical Release Reporting
Toxic Release Inventory (TRI)
Toxic Substances Control Act (TSCA)
Training
Federal regulatory overview - Hazardous materials-20L
9/14 Index–9

Federal regulatory overview - HAZWOPER-11, 30, 34, 45, 112, 125, 46

Federal regulatory overview - HAZWOPER-19, 59, 69, 76, 97, 111
TSCA
U
Underground injection control
Underground storage tanks (USTs)
Underground Storage Tanks (USTs)
Universal Waste Transporters
Used Oil
Federal regulatory overview - Waste-26, 27, 28, 29, 31, 32, 33, 34, 35
W
Waste Reduction
Water Pollution
Wetlands
Written Hazard Communication program
Index–10 9/14

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How to use this manual

This publication is designed to provide reasonably accurate and authoritative information in

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Introduction to the Environmental Protection Agency

How EPA is organized

Office of the Administrator (AO)

EPA also operates 10 regional offices around the nation.

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Plans and priorities

EPA’s top 7 themes

1. Making a visible difference in communities across the country.

2. Addressing climate change and improving air quality.

3. Taking action on toxics and chemical safety.

4. Launching a new era of state, tribal, and local partnerships.

5. Embracing EPA as a high performing organization.

6. Working toward a sustainable future.

Multi-year strategic planning

• Goal 1: Taking Action on Climate Change and Improving Air Quality

• Goal 2: Protecting America’s Waters

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A focus on enforcement activities

2011 EPA enforcement estimates:

• $19 billion invested to improve environmental performance (a record year);

• $3 billion (included in the $19 billion) to clean up hazardous waste in communities

• $25 million in additional investments for supplemental environmental projects that

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• 1.8 billion pounds of pollution reduced, treated or eliminated; and

• 89.5 years of incarceration for environmental criminals.

What is environmental justice?

• Protect health in communities over-burdened by pollution.

• Empower communities to take action to improve their health and environment.

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A quick look at the regulatory process

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1. Proposed rules. The Agency proposes a regulation, known as a Notice of Proposed

EPA and businesses

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Clean air — Meeting EPA’s requirements ................................................................ 1

9/14 Clean air TOC–1

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Title VI: Stratospheric ozone and global climate protection......................................... 42

2–Clean air TOC 9/14

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Clean air — Meeting EPA’s requirements

The Clean Air Act of 1970

3/12 Clean air–1

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2–Clean air 3/12

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CAA Titles 1-7