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Inspection procedures for hazardous-waste emergency response

Summary A training adviser asked whether OSHA would check compliance with its hazardous-waste emergency response standard at every inspection. OSHA said it was revising its enforcement guidelines and considering that question; meanwhile, its general field procedures addressed review of employers' emergency response plans. OSHA now archives the letter and warns that it may no longer represent policy.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-01-30-1
Date issued
January 30, 1991
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Hazwoper Inspections
Source
View the official document

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OSHA archives this letter and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 30, 1991

Mr. Tom Crowther Chairman
Regulatory Issues Committee
New England Consortium Advisory Board
University of Lowell
[Recipient address omitted]
Dear Mr. Crowther:

This is in response to your most recent inquiry of January 8, concerning enforcement guidelines for the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120).

You have asked whether checking for compliance with this standard would be mandated for every inspection in the same way that it is now required for the Hazard Communication Standard (29 CFR 1910.1200). As I mentioned in our October 31, 1990 letter to you, we are updating the enforcement guidelines on this standard. The issue you raised is being considered during this process. In the interim, general inspection procedures in our Field Operations Manual address the evaluation of an employer's emergency response procedures. (Copies of pertinent sections are enclosed.)

We hope you find this information helpful.

Sincerely,
Gerard F. Scannell
Assistant Secretary

Enclosures

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