Required programs at hazardous-waste treatment facilities
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June 23, 1989
Mr. Jeremy Millstone
Connolly & Freshman, Inc.
[Recipient address omitted]
Dear Mr. Millstone:
This is in response to your letter of June 13, concerning the relationship of several paragraphs within the 29 CFR 1910.120 Standard.
After further study of the paragraphs in question (i.e., 1910.120(p)(1), (p)(5) and (6)), I believe my telephone response was not quite accurate. Paragraph (p)(5) would take precedence over paragraph (p)(1) which uses the phrase "as appropriate" and would require that employers put in place a method to become aware of new technologies involving hazardous waste operations (including storage) and introduce them into their workplaces if appropriate for their operations.
The same would hold true for paragraph (p)(6). Employers would need to follow the referenced requirements of paragraph (j), if appropriate, to their operations.
Thus contrary to my telephone response to you, the phrase "as appropriate" applies to the specifics of paragraphs (p)(5) and (p)(6), and does not give the option to not have the programs called for in these paragraphs.
If I can be of further service to you, please do not hesitate to contact me.
Sincerely,
Chappell D. Pierce, Director
Office of Fire Protection Engineering and
Systems Safety Standards
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