Compliance guidelines for cleanup

An occupational safety and health program is a written, site-specific safety system led by the site coordinator or the employer's representative that protects employees during hazardous waste cleanup operations. The program must be developed before work begins, be implemented as work proceeds, and facilitate coordination and communication among all parties on the site. See the guidance in 1926.65AppC and the general duties in 1926.65.

Yes — the site safety and health program must be in writing. The appendix explicitly states that the program is to be in writing and should detail policy statements, methods for identifying and controlling hazards, communication of plans and procedures, training, emergency preparedness, and feedback mechanisms. See 1926.65AppC and the related employer responsibilities in 1926.65.

Yes — each contractor on a cleanup site must have its own safety and health program that interfaces smoothly with the site coordinator's program, and employers involved in treatment, storage, and disposal (TSD) operations must also implement programs. These TSD programs must include the hazard communication program required in 1926.65(p)(1) and the employee training required in 1926.65(p)(7) and 1926.65(p)(8). See 1926.65AppC for guidance on contractor program integration and 1926.65(p) for specific TSD requirements.

The written program must include policy statements of authority and accountability; procedures to identify and control site hazards; methods to communicate plans, work rules, and standard operating procedures; training methods for employees and supervisors; emergency preparedness and response measures; and methods for feedback and program evaluation to improve effectiveness. These elements are listed in 1926.65AppC and should be tailored to the site's hazards and operations.

Employees covered by 1926.65(e) must be trained on the safety and health hazards they can expect on hazardous waste cleanup sites, control measures and techniques, monitoring procedures, elements of an effective employer safety program and site safety plan, hands-on use of personal protective equipment (PPE), relevant portions of the OSHA standard, and employee responsibilities under OSHA. Supervisors must also receive training in their program duties (spill containment, PPE programs, medical surveillance, emergency response, etc.). See 1926.65AppC for guidance on training design.

Employers covered by 1926.65(p) must implement a hazard communication program as required in 1926.65(p)(1) and provide employee training described in 1926.65(p)(7) and 1926.65(p)(8). Training must cover hazards affecting employees' duties, elements of the employer's safety and health program, medical surveillance requirements, and how to use controls and PPE appropriate to their jobs. See 1926.65AppC for implementation guidance.

Emergency response and hazardous-substance-response training must be refreshed annually. 1926.65AppC states that all affected employees require annual refresher training and specifies content tailored to the level of response in 1926.65(q).

Decontamination procedures must be tailored to the specific site hazards and the employee's level of exposure; one procedure will not fit all situations. The appendix advises evaluating decontamination and PPE decontamination methods as needed to ensure workers are not re-exposed when PPE is reused, and suggests using Appendix D and other references for guidance. See 1926.65AppC and consult the referenced U.S. Coast Guard manual at COMDTINST M16465.30 for practical decontamination guidance.

Yes — an employer's emergency response plan must be compatible with applicable state and local district emergency response plans. 1926.65AppC directs employers to use state and district plans in developing their employer emergency response plans and states the employer's plan should be compatible with those local plans; see also the emergency response provisions in 1926.65(q).

Yes — the guidance recommends using qualified professional safety and health personnel (such as Certified Safety Professionals, Board Certified Industrial Hygienists, or Registered Professional Safety Engineers) to administer and manage the employer's safety and health program. This recommendation appears in 1926.65AppC to improve program effectiveness and protection for site workers.

Employers must investigate accidents, injuries, and illnesses to determine causes and take corrective actions to prevent recurrence, and use investigation results as feedback to improve the safety program. 1926.65AppC emphasizes turning investigation findings and employee suggestions into positive program improvements.

Yes — employers must assess the workplace to determine if hazards are present and produce a written certification of the hazard assessment when PPE is required. OSHA's interpretation in https://www.osha.gov/laws-regs/standardinterpretations/2024-03-28 clarifies that the employer must assess hazards and document the assessment per the Personal Protective Equipment requirements; 1926.65AppC also stresses that PPE programs should be part of the overall safety program and that assessments guide PPE selection.

Respirator selection for Class I asbestos cleanup work must follow the asbestos-in-construction requirements: if exposures exceed 1 f/cc (8-hour TWA), employees must be supplied-air respirators (SARs) operated in pressure-demand mode with an auxiliary positive-pressure SCBA; if exposures are at or below 1 f/cc employers must provide tight-fitting PAPRs or full facepiece SARs unless a negative exposure assessment (NEA) is documented. See OSHA's respirator interpretation at https://www.osha.gov/laws-regs/standardinterpretations/2024-01-04 and the asbestos-remediation coverage clarification at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14 for application to cleanup work under the construction asbestos standard.

PPE can create hazards such as heat stress, reduced vision, limited mobility, communication impairment, and psychological stress; employers should select PPE that gives adequate protection without causing undue hazards and periodically evaluate its effectiveness. 1926.65AppC recommends using PPE in combination with other controls and monitoring for PPE-related risks as part of the site's PPE program.

Skilled support personnel and outside helpers who may be called to an incident should receive at least a safety and health briefing before entering the area of potential or actual exposure; those who are not part of the emergency response plan and who do not meet training requirements must be made aware of hazards and provided necessary protective clothing and equipment. See 1926.65AppC and the training elements described for response in 1926.65(q).

Yes — items of an employer's emergency response plan that are already properly addressed in a facility's contingency plan may be substituted into or kept together with the employer's [1926.65] emergency response plan, so long as the combined plan meets the standard's requirements and is usable by employees. See 1926.65AppC and the emergency response requirements in 1926.65(q).

A comprehensive PPE program must include hazard identification, medical monitoring, environmental surveillance, selection, use, maintenance, decontamination of PPE, and associated training. The appendix explicitly lists these elements as core components of the PPE program and advises employers to document policies, procedures, and guidelines in a written program (1926.65AppC). For additional guidance on employer responsibility to assess hazards before selecting PPE, see OSHA's interpretation on PPE hazard assessments (OSHA letter of interpretation, Mar 28, 2024).

Yes — the PPE program must be written and copies should be made available to all employees with a reference copy at the worksite. The appendix directs employers to prepare a written PPE program containing policy statements, procedures, and guidelines and to keep technical data and manuals with it (1926.65AppC). This requirement aligns with OSHA's broader obligation that employers perform hazard assessments and document them when PPE is required (OSHA letter of interpretation on PPE hazard assessments, Mar 28, 2024).

Keep policy statements, procedures, technical data on equipment, maintenance manuals, relevant regulations, and other essential information with the written PPE program. The appendix specifically recommends collecting and maintaining these items so workers and supervisors have ready access to the information at the worksite (1926.65AppC).

The senior official responding to the incident is the individual in charge of the ICS. The appendix explains the ICS assigns one person—typically the most senior officer on scene—to manage the incident, make strategy/tactic decisions, and delegate tasks (1926.65(q)(3)(ii), 1926.65AppC).

All communications should be routed through the command post to reduce radio traffic and avoid confusion, while strategy and tactical decisions are made by the single incident commander. The appendix emphasizes centralizing communications and decisionmaking through the command post or ICS to improve coordination and safety (1926.65(q)(3)(ii), 1926.65AppC).

For a small incident the ICS can be run by one individual who may perform many roles, but at least two backup employees should be designated for rescue or assistance. The appendix notes that on small incidents the commander may also serve as safety officer and should designate at least two backup personnel because assistance needs can include rescue; OSHA recommends a minimum of two backups (1926.65(q)(3)(ii), 1926.65AppC).

When the incident is large or complex, the incident commander should delegate tasks to maintain a manageable span of control, using either geographic sectors or functional assignments. The appendix recommends dividing the scene by location or by function (for example, medical services, evacuation, water supply, resources, media relations, safety, site control) so subordinate officers can coordinate activities within an assigned sector or function (1926.65AppC).

Because large incidents involve many workers and evolving hazards, multiple safety officers and backup personnel are needed to monitor conditions, recommend precautions, and provide rescue support. The appendix states that designating several safety officers and backup personnel improves monitoring, coordination, and worker protection at complex incidents (1926.65AppC).

A Site Safety and Control Plan should include a summary hazard analysis and risk assessment, a site map, defined work zones (clean, transition/decon, hot), the buddy system, communications plan, command post, standard operating procedures and safe work practices, medical/triage area, hazard monitoring plan, decontamination procedures/areas, and other relevant items. The appendix lists these elements and recommends the plan be part of or an extension of the employer's emergency response plan (1926.65AppC).

The appendix recommends at minimum a clean zone, a transition/decontamination zone, and a work or "hot" zone: the clean zone is a contamination-free area for support functions; the transition or decontamination zone is where workers and equipment are cleaned before entering/leaving the hot zone; and the hot zone is where contamination and direct cleanup operations occur. These zones help control contamination spread and protect workers (1926.65AppC).

Yes — the appendix says the Site Safety and Control Plan should be part of the employer's emergency response plan or an extension tailored to the specific site. Embedding site-specific controls in the employer's overall emergency plan ensures consistent procedures and readiness (1926.65AppC).

Not always — for some small incidents where personnel and contamination are limited, decontamination procedures may not be necessary. The appendix gives an example (an overturned tank truck with a small flammable liquid leak) where, if the incident commander uses the fewest personnel necessary and exposure is controlled, decontamination procedures would not be required (1926.65AppC).

OSHA says a medical surveillance program is essential to assess and monitor workers' health and fitness for hazardous waste operations, provide emergency and other treatment as needed, and keep accurate records. The appendix recommends such programs and points to the joint OSHA/NIOSH/USCG/EPA guidance as an example of recommended medical testing for surveillance (1926.65AppC).

Workers must be trained in the employer's established operating procedures, the use and care of spill-control equipment, and the hazards and controls associated with spill containment work. The appendix requires that all involved workers receive this training and use appropriate protective clothing and equipment (1926.65AppC); OSHA's PPE hazard-assessment interpretation also underscores the employer's duty to evaluate hazards and train/select PPE accordingly (OSHA letter of interpretation, Mar 28, 2024).

The appendix describes modern agents and devices such as solidifiers, vapor-suppression agents, activated carbon adsorption agents, pressurized portable applicators, and hose/nozzle systems that can be applied remotely to solidify liquids, suppress vapors, or neutralize acids/caustics. These technologies can improve control and reduce worker exposure when used as recommended by manufacturers (1926.65AppC).

Yes — the appendix explains that treating spills on-site (for example, by solidifying or neutralizing liquids) can create less hazardous materials that are easier to handle, and that such treatment may sometimes be acceptable to EPA under certain permit exceptions (see 40 CFR part 261 and the permit exception referenced in the appendix). Employers should follow manufacturer instructions and applicable waste regulations when using treatment agents (1926.65AppC).

Employers should evaluate new products and application methods as part of a new-technology program to determine whether they complement traditional methods (diking, ditching, absorbents), improve effectiveness, and reduce worker hazards. The appendix recommends testing product performance, following manufacturer instructions, and incorporating training and procedures for safe use into the employer's spill-response program (1926.65AppC).

Yes — paragraph 1926.65(q)(3)(ii) requires implementation of an ICS for emergency responses involving hazardous substances, and the appendix explains how ICS organizes command, communications, and coordination for incidents of all sizes (1926.65(q)(3)(ii), 1926.65AppC).

A hazard monitoring plan should be part of the Site Safety and Control Plan and specify air contaminant monitoring and other environmental surveillance needed to protect workers. The appendix lists hazard monitoring (for example, air contaminant monitoring) among the essential elements of an effective site safety plan (1926.65AppC).

OSHA recommends the buddy system because it provides immediate backup, assists with monitoring, and supports rescue capability when workers are operating in contaminated or high-risk zones. The appendix lists the buddy system among key site practices to protect response personnel (1926.65AppC).