Is a land surveyor working on a capped landfill required to have completed a 40-Hour Hazardous Waste Operations training course? And what if the surveyor is on an uncapped landfill?
The employer must demonstrate that the operation being performed, in this case surveying, does not involve employee exposure or the potential for exposure to the safety and health hazards of the site. As OSHA stipulates in a letter of interpretation for 29 CFR 1910.120 dated 2/12/92, 29 CFR 1910.120 does not apply to workers where there is no potential for exposure to hazardous substances found at the clean-up site or, in this case, the landfill. With this noted, if the surveyor is performing non-invasive work and is in controlled areas of the site where potential hazards have been abated, Hazardous Waste Operations training may not be necessary. Hazard Communication or the “Right to Know” training would be required as outlined in 29 CFR 1910.1200. On an uncapped landfill, more-than-likely hazards exist and have the potential to expose the surveyor. In this case, the surveyor would need 40-hour training. Each site and employee needs to be evaluated properly since there is no blanket so
Related Questions
- Is a land surveyor working on a capped landfill required to have completed a 40-Hour Hazardous Waste Operations training course? And what if the surveyor is on an uncapped landfill?
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