The OSHA/EPA Final Rules: A Guide to Worker Protection Standards for Hazardous Waste and Emergency Response Operations

April 1990
Citation:
20
ELR 10143
Issue
4
Author
E. Lynn Grayson and Joseph F. Madonia

Editors' Summary: In 1986, the Superfund Amendments and Reauthorization Act (SARA) responded to public pressure to clean up hazardous waste sites and to protect surrounding communities from exposure to hazardous chemicals. In 1989, the Occupational Safety and Health Administration (OSHA) and the United States Environmental Protection Agency complied with SARA statutory directives to write standards to protect private and government workers who perform hazardous waste remedial work. Workers subjected to even a "reasonable possibility" of chemical safety or health hazards are within the reach of the 1989 OSHA/EPA worker protection standards. The broad scope of the OSHA/EPA standards, effective March 1990, will have a substantial impact on preventing workplace accidents and deaths from hazardous chemical exposure.

In this Article, the authors outline the emergency planning, training, and response requirements of the OSHA/EPA worker protection standards and suggest that regulated entities adopt an efficient and cost-effective compliance strategy. They describe the costs and benefits, observing that compliance, though economically feasible, may require employers to change their current practices and factor new expenses into the overall cost of doing business.

Ms. Grayson is Chief Legal Counsel of the Illinois Emergency Services and Disaster Agency. Mr. Madonia is an associate with the Chicago, Illinois, law firm Wildman, Harrold, Allen & Dixon.

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The OSHA/EPA Final Rules: A Guide to Worker Protection Standards for Hazardous Waste and Emergency Response Operations

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