Are there guidelines for issuing HAZWOPER citations when I am conducting a Process Safety Management (PSM) investigation?
Inspections of facilities that fall under both the Process Safety Management (PSM) standard (29 CFR 1910.119 and 1926.64) and HAZWOPER can lead to citations that may either be grouped or cited separately, depending on the specific violation. Paragraph (n) of the PSM standard specifically states that, “The employer shall establish and implement an Emergency Action Plan for the entire plant in accordance with 29 CFR1910.38″ for general industry or 29 CDR 1926.35 for construction. It further states that, Employers covered under this standard may also be subject to the hazardous waste and emergency response provisions contained in 29 CFR 1910.120(a), (p), and (q) and/or 29 CFR 1926.65(a), (p), and (q).” (1) You should make the determination to cite HAZWOPER as if the site were not covered by the PSM standard. Once you have determined that HAZWOPER will be cited, the citation may either be grouped with a citation for paragraph (n) of the PSM standard, or paragraph (n) of the PSM standard ca
