• Spill Response Part 5: Spill Reporting Requirements Guide
  • Karen

    Karen D. Hamel, CSP, WACH, is a regulatory compliance professional, trainer and technical writer for New Pig. She has more than 22 years of experience helping EHS professionals find solutions to meet EPA, OSHA and DOT regulations and has had more than 100 articles published on a variety of EHS topics. Karen is a Certified Safety Professional (CSP), Walkway Auditor Certificate Holder (WACH), Community Emergency Response Team (CERT) trainer and hazmat technician. She also serves on the Blair County, Pa., LEPC and has completed a variety of environmental, safety, emergency response, DOT and NIMS courses, including Planning Section Chief. She has conducted seminars at national conferences and webinars for ASSE and other national organizations. She can be reached at 1-800-HOT-HOGS (468-4647) or by email karenh@newpig.com.

  • Chrs Boydsays:
    10/13/2016 at 1:37 pm Reply

    Under OSHA 1910.120 shouldn’t we be telling companies in order to use a spill kit the workers needs to be trained in Hazwoper ???

    • Karensays:
      10/13/2016 at 2:11 pm Reply

      Hi there,

      There a lot of scenarios that allow employees to use spill kits without HAZWOPER training. Most spills in fixed facilities, for example, are incidental spills, and OSHA’s HAZWOPER rule does not apply to incidental spills. An incidental spill is a spill that:

      • Does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up
      • Does not have the potential to become an emergency within a short time
      • Is limited in quantity, exposure potential or toxicity

      In order for HAZWOPER to apply, the spill needs to be an emergency. There is no one-size-fits-all answer as to what kind of spill constitutes an emergency. But in order for a spill to be an emergency, there has to be an immediate threat to human health or the environment. Examples of an emergency spill include:

      • It may cause high levels of exposures to toxic substances
      • It is life or injury threatening
      • Employees must evacuate the area
      • It poses Immediately Dangerous to Life and Health (IDLH) conditions
      • It poses a fire and explosion hazard
      • It requires immediate attention because of danger
      • It represents an oxygen deficient condition

      Although employees do not need HAZWOPER training to clean up incidental spills, they still do need to be trained to recognize the hazards a spill presents, know how to protect themselves and how to use spill response tools, materials and equipment. This can be included in hazard communication or other applicable safety trainings.


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