Hazardous-waste-site training for perimeter and support workers

December 28, 1989

Mr. James H. Kleinfelder
President
Hazardous Waste Action Coalition
[Recipient address omitted]
Dear Mr. Kleinfelder:

This is in response to your letter of November 27, to Secretary Dole. We believe the following explanation will resolve your concerns. Please write again if you wish a more detailed explanation or other actions by the Occupational Safety and Health Administration (OSHA)

Employees who work at the perimeter of a hazardous waste site, do not enter areas where hazardous waste may exist, are stored or are processed and are not exposed to health or safety hazards related to hazardous waste operations are not covered by the standard. Consequently clerical personnel or support personnel meeting the above requirements are not covered by the standard including its training requirements. Delivery persons who leave off the delivered items in perimeter areas and meet the above requirements also are not covered. A truck driver delivering clean fill may not be covered if the area where the fill is delivered is not where hazardous wastes are located and if the driver is not exposed to health or safety hazards resulting from hazardous waste operations.

However, if clerical employees, support personnel or drivers are in areas where there may be exposure to health or safety hazards resulting from hazardous waste operations, they are covered by the standard. Training would have to be 40 hours or 24 hours depending upon which provision of paragraph 1910.120(e) covers them.

I hope this information is helpful.

Sincerely,
Gerard F. Scannell
Assistant Secretary

[Requester letter reproduced on OSHA page; omitted here.]