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Maintenance employees at hazardous-waste treatment, storage, and disposal facilities

Summary An employer asked whether maintenance employees entering its permitted hazardous-waste treatment, storage, and disposal areas for repairs, housekeeping, and material transfers were covered by OSHA's hazardous-waste operations rule. OSHA said employees with regular or periodic duties in those permitted areas were covered by section 1910.120(p).
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1991-02-13
Date issued
February 13, 1991
Status
Active
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Hazwoper Hazardous Waste
Source
View the official document

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

February 13, 1991

Jeffrey J. Williams,
Section Manager
McDonnell Douglas Occupational
Safety and Health Services
[Recipient address omitted]
Dear Mr. Williams:

This is in response to your inquiry to Mr. James F. Foster concerning the application of the Hazardous Waste Operations and Emergency Response standard (29 CFR 1910.120). Please accept my apology for the delay in this reply.

Your specific question is the coverage of maintenance employees who "will enter the RCRA designated TSD facility to repair and perform periodic maintenance on mechanical or electrical equipment, conduct general housekeeping duties, and transfer materials between a storage tank on container and a licensed waste hauler." Maintenance employees who have regular (periodic) duties in the permitted areas would be covered by section (p) of the standard.

I hope this information is helpful.

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

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

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