As a practicing Industrial Hygienist and “sometime”  manufacturing manager, I’ve had the great fortune to work across a spectrum from the dynamic world of the Environmental Professional  to the highly structured order of “just in time” precision manufacturing.  In both places, there is always a duty to recognize, evaluate and control occupational hazards.  Then there’s project scope, budget reality, timelines, multiple stakeholder input and the contaminants of concern (COC) we may face.  How many times do we ask what amount of (insert name of hazardous chemical here) requires (insert level of protection here) if we do (insert type of work here)?  Think about the number of times “Level D, Modified” might appear in project briefings.  Exactly what is that and where is it found (or not) in HAZWOPER? 

In my “off-duty,” I climb mountains. This is a pursuit that is also dynamic, fluid, and has great consequence – when the rules aren’t followed.  Just like managing a contamination investigation and remedial program, these activities require constant vigilance and adjustment to find the balance between getting the job done and following the rules.   As they say, climbing a mountain means getting to the top … and back … alive.  That means everyone.  A successful climb requires training, planning, provisioning, communication, hazard evaluation, protective gear, and at least a Plan B and C (and don’t forget the risk to rescuers for Plan D), all of it inside an expeditious, efficient team framework.  Doesn’t matter how big, distant or difficult a mountain is – ask anyone that’s ever spent a few hours wondering how to get back to the car as dark approaches.  The White Mountains can be as deadly in winter as anywhere on earth – prepared or unprepared.

When the Hazardous Waste Operations and Emergency Response (HAZWOPER – 29 CFR 1910.120) was first published in 1990, industry rushed to it.  There had been other approaches, but this was the one – OSHA and EPA together.  The HAZWOPER embraced collaboration and systemized decision making.  It gave us a performance specification to use in our daily operations.  Some of us have worked on large scale National Priorities List (NPL) projects – lots of process controls and “checks and double checks.”   Others have become expert in lower intensity petroleum hydrocarbon cleanups under state contingency plans.

And, almost all of us have to take the 40 Hour initial HAZWOPER with refreshers every year – (after year, after year) with the obligatory Emergency Response Guide and other handouts.

So, one of the great challenges is relevancy – as in a relevant HAZWOPER curriculum and development of field skills.  We’ve recently had hazardous materials episodes from  Hurricanes Irene and Sandy here in the northeast; we’ve decommissioned three nuclear power plants; demolished or renovated millions of square feet of industrial, institutional, and commercial space; and we manage the impacts of countless underground storage tank systems.  There are plenty of opportunities for relevance.

Almost all of these work-scopes fit within the framework of the HAZWOPER rule – whether it actually applies or not, it is our standard of care.  As Environmental, Safety and Health professionals (IH or not), it’s our duty to make sure we have a plan that is appropriate and executable for our jobs.  It’s also our duty to see that it is followed and improved on continuously.

So there’s a bridge here – American business, our business requires systems and continuous improvement to be sustainable. Let’s make our HAZWOPER training do the same thing – let’s use it to make better decisions and to improve our work environment.

Joe can be reached at (800) 789-3530 or