Health and Safety-Related Programs

For large superfund sites, the proeess ean be similar to the DOE proeess as deseribed. Onee the site has been adequately assessed, a remedy ean be ehosen. This remedy ean vary but eould inelude a removal or stabilization phase, a treatment phase, a maintenanee phase, and, finally, dismantlement and deeontamination phases. 

For other CERCLA sites the proeess ean be very different from the typieal DOE site. The proeess may start with various phases of site assessments. The intermediate step may be a pilot study, followed by a pilot plant operation, or possibly a removal aetion or other alternative. The final steps may vary widely. However, just as in DOE sites, the appropriate rule or requirement depends on the site-speeifie faeility or operation, the assoeiated hazards, and the potential for worker exposure to the hazards. For the Army Corps of Engineers eleanup or oversight, the rules will most likely be even more stringent than for OSHA or DOE. 

It is important to differentiate between the seope and applieation of a standard of praetiee. Scope determines that an operation or loeation is eovered or governed by the standard. Application determines that portions (e.g., paragraphs) of the standard apply to the partieular operation or loeation [1]. 

These types of analysis may exelude many routine aetivities from speeifie requirements under HAZWOPER while eontinuing to provide adequate and appropriate worker proteetion. In eaeh ease the operation should review eaeh situation and make the best deeision on how to handle the entry based on the interpretation of the partieular requirements. 

Certain aetivities eondueted by DOE or the Army Corps of Engineers normally fall outside the seope of HAZWOPER. For these aetivities HAZWOPER eoneepts and prineiples should be used as a framework, and not as a rigid standard for their planning and eonduet. The following list summarizes some eonsiderations when determining the applieation of HAZWOPER as a framework for projeets not strietly regulated by the standard. 

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Deactivation and D D actions can range from stabilization of multiple hazards at a single site or facilities containing chemical or radioactive contamination, or both, to routine asbestos and lead abatement in a nonindustrial structure. Strategies include programs that meet compliance objectives, protect workers, and make certain that productivity and cost-effectiveness are maintained. The content and extent of health and safety-related programs should be proportionate to the types and degrees of hazards and risks associated with specific operations. 

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