Reference materials for hazardous waste

Appendix D is a non‑mandatory list of references employers and responders may consult for more information about hazardous waste site activities. See 1910.120 App D for the list of suggested publications.

• These references (EPA FSOPs, NIOSH/OSHA guidance, DOT guides, etc.) are intended to help employers meet the requirements in the hazardous waste operations and emergency response standard at 1910.120, but they are not themselves mandatory OSHA requirements.
• Use the listed documents as technical support, templates, or best‑practice guidance while ensuring your written programs actually comply with the regulatory text in 1910.120.

No — the documents listed in Appendix D are recommended references and are not independently enforceable OSHA requirements. See 1910.120 App D and the primary regulatory text at 1910.120.

• Employers must meet the mandatory duties in 1910.120; Appendix D materials can help satisfy those duties but do not replace or change the standard.
• If you adopt a procedure from an Appendix D source, verify it covers every element required by 1910.120.

Yes — EPA Field Standard Operating Procedures like FSOP 7 are recommended technical resources you can use to develop a decontamination procedure, but you must ensure the procedure meets the requirements of 1910.120 and your written plan. See 1910.120 App D.

• Use FSOP 7 as a practical template for decon steps, equipment, and sequencing, but document how your method meets the hazard assessment, PPE, training, and medical surveillance elements required by 1910.120.
• Keep records showing which guidance you used and any site‑specific adaptations to demonstrate regulatory compliance.

FSOP 9 is an acceptable reference to use when preparing a site safety plan, but relying on it alone does not relieve you of meeting all written plan elements in 1910.120. See 1910.120 App D.

• Use FSOP 9 to structure site hazard analyses, decontamination, communications, and emergency procedures, then crosswalk each FSOP section to the specific requirements in 1910.120 to show compliance.
• Document site‑specific hazards, protective equipment, training levels, and medical surveillance to ensure the plan meets OSHA's mandatory elements.

Yes — the joint NIOSH/OSHA guidance manual listed in Appendix D is an appropriate resource to develop hazardous waste operations training, but training content must still meet [1910.120] requirements. See 1910.120 App D and 1910.120.

• Use the manual to identify core learning objectives (hazard recognition, PPE use, decontamination, and emergency procedures) and then map those objectives to the training frequency, competency verification, and content elements required by 1910.120.
• Keep training records and competency checks as part of your employer program documentation.

Employers should use the EPA "Standard Operating Safety Guidelines" listed in Appendix D as practical procedures to plan safe operations, but they must adapt them to meet the site hazards and the mandatory elements of 1910.120. See 1910.120 App D.

• Treat these EPA guidelines as technical supplements (work sequencing, monitoring, decontamination, PPE selection) and document how each adopted practice satisfies OSHA's required hazard assessment, training, medical surveillance, and written program elements.
• If a guideline suggests a practice that conflicts with OSHA standards, follow the OSHA standard and document the rationale for any deviation.

Yes — the Department of Transportation's Emergency Response Guidebook (listed in Appendix D) is a recommended resource for initial response actions for transportation incidents, but you must integrate it with your employer's 1910.120 emergency procedures. See 1910.120 App D.

• Use the guidebook to identify initial protective actions and evacuation distances for specific classes of materials, then include those actions in your site emergency plan and training.
• Maintain coordination procedures with local emergency responders and the Incident Command System materials listed in Appendix D to ensure consistent response actions.

Yes — the NRT‑1 guide in Appendix D is an appropriate reference for community hazard assessment and emergency planning, but employers must ensure plans meet OSHA duties under 1910.120. See 1910.120 App D.

• Use NRT‑1 to help develop coordination mechanisms with local authorities, public notification, and evacuation procedures, and then document employer responsibilities for employee protection, training, and site‑specific hazards under 1910.120.

No — the "Hazardous Waste Inspections Reference Manual" listed in Appendix D is a guidance tool and does not replace formal OSHA inspection policies or standards. See 1910.120 App D and the enforceable text in 1910.120.

• Use the manual to prepare for and to understand typical inspection focuses and technical issues at hazardous waste sites, but follow OSHA inspection directives and the regulatory requirements when responding to or managing an OSHA inspection.

No — the interagency Memorandum of Understanding provides coordinated guidance for worker protection during hazardous waste site activities, but it does not alter the legal obligations set by OSHA standards. See 1910.120 App D and consult 1910.120 for employer duties.

• The MOU is useful for harmonizing practices across agencies and for technical guidance; employers must still comply with OSHA's mandatory rules and document how interagency guidance was used to meet those rules.

Employers should use the PPE Selection Guide listed in Appendix D as a technical resource to choose appropriate ensembles for hazardous materials incidents, while ensuring selection and use comply with OSHA PPE requirements in [1910.132] and the elements of 1910.120. See 1910.120 App D.

• The Guide helps match chemical hazards to suit types, glove materials, and respiratory protection options; document why the selected PPE meets the hazard assessment and training requirements in 1910.120.
• Maintain PPE inspection, cleaning, and maintenance records as required by OSHA PPE standards.

Yes — the Incident Command System materials in Appendix D are appropriate resources to implement a standardized on‑scene management structure, provided you integrate ICS roles and procedures into your site safety plan required by 1910.120. See 1910.120 App D.

• Adopt ICS to clarify command, communications, and coordination with external responders; document how ICS procedures protect employees and meet OSHA hazard communication, training, and emergency response elements.

Yes — employers should document which Appendix D references they relied upon and how those references were adapted to meet the mandatory elements of 1910.120. See 1910.120 App D.

• Documentation provides an audit trail showing that you used recognized technical guidance and allows inspectors or stakeholders to see how site procedures were developed and validated against OSHA requirements.

Yes — FSOP 7 is a practical resource for designing decontamination sequence and equipment, but employers must ensure their decon plan satisfies all applicable requirements of 1910.120. See 1910.120 App D.

• Tailor FSOP 7 steps to site‑specific contaminants, anticipated exposures, and the PPE ensembles selected; document personnel roles, decon responsibilities, and waste handling to comply with OSHA training, medical surveillance, and exposure control elements.

Yes — many of the references listed in Appendix D are revised periodically, and employers should use the most current editions or subsequently issued guidance while ensuring continued compliance with 1910.120. See 1910.120 App D.

• Using current guidance helps incorporate state‑of‑the‑art practices for PPE, decontamination, and emergency response; document which version you used and any changes you made to fit site conditions.

No — following a reference from Appendix D does not replace a site‑specific hazard assessment required by [1910.120]; you must still evaluate actual site conditions and adjust procedures accordingly. See 1910.120 App D and 1910.120.

• Use Appendix D materials as technical inputs, but perform and document a hazard assessment that identifies contaminants, concentrations, exposure routes, and appropriate controls for the specific site.

Yes — state or local adaptations of referenced guidance may be used, but employers must ensure those versions meet or exceed the protections required by federal OSHA standards such as 1910.120. See 1910.120 App D.

• If your workplace is in a State Plan state with more stringent rules, follow the State's requirements; document compliance with whichever standards apply to your jurisdiction.

An emergency responder should use the DOT Emergency Response Guidebook for initial protective actions and then consult EPA incident response guides and the site's Incident Command System procedures for extended operations, integrating both into the [1910.120] emergency response framework. See 1910.120 App D and 1910.120.

• Use the DOT guidebook to set safe distances and initial isolation, then transition to EPA or ICS checklists for decontamination, notifications, and longer‑term incident management while maintaining worker protection requirements under 1910.120.

Employers can use the "Hazardous Waste Inspections Reference Manual" listed in Appendix D for practical checklists and inspection guidance, but they must still meet the written program and training requirements in 1910.120. See 1910.120 App D.

• The manual provides common inspection focal points (PPE, monitoring, decon, site control); adapt the checklists to site‑specific hazards and maintain documentation showing corrective actions and follow‑up.

If an Appendix D recommendation conflicts with an OSHA standard or interpretation, the employer must follow the OSHA standard or interpretation and document the rationale for any deviation. See 1910.120 App D and the mandatory text at 1910.120.

• When in doubt, apply the more protective requirement and keep records explaining how the chosen approach satisfies OSHA obligations; where helpful, cite an OSHA letter of interpretation for clarification.

If remediation activities involve asbestos‑containing building materials during demolition, renovation, or cleanup, the construction asbestos standard [29 CFR 1926.1101] usually applies rather than the general industry standard. See the OSHA asbestos interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 and consider 1910.120 App D for hazardous waste site guidance.

• The asbestos letter explains that many remediation tasks are construction‑type activities and fall under [29 CFR 1926.1101], so employers performing such cleanup must follow the construction asbestos requirements (worker protection, monitoring, work practices, and training).

Yes — storing pre‑charged equipment that contains a Category 1 flammable gas in quantities at or above the threshold at a single location can create a PSM‑covered process under [29 CFR 1910.119], according to OSHA's interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-06-06.

• The PSM interpretation explains that storage and on‑site movement of such charged equipment meet the definition of a "process" and therefore can trigger [1910.119] obligations when aggregated refrigerant quantities exceed the threshold; employers should evaluate their inventory against PSM thresholds and comply if covered.