Keeping workers safe at brownfield cleanup sites

Many former factories and waste disposal facilities have fallen into disrepair and may be abandoned, leaving behind pollutants or contaminants. Fortunately, the Environmental Protection Agency (EPA) sponsors cleanups of these areas, making them attractive sites for companies to engage in urban renewal and rehabilitation. In fact, the EPA estimates that every dollar the organization spends on such efforts yields $18.29 in corporate and private profits. Additionally, it is projected that over 72,000 jobs have been generated so far thanks to brownfield cleanups.

Brownfields pose unique hazards to workers and may make it necessary for employers to take additional steps to ensure their workers are safe and protected when engaging in brownfield cleanups and during land reclamation projects.

Common dangers
Waste and pollutants found in soil, buildings, containers, and groundwater aquifers can create some of the biggest hazards that can be found at brownfield sites. Before environmental regulations were commonplace, many organizations disposed of chemicals on-site without adequate protective measures.

Workers should be trained to handle materials that might be found during excavations. Chemical hazards from contaminants could be present in the soil or containers on the worksite, so employees need to wear coveralls and disposable respirators when necessary.

Many brownfield sites are often in various states of disrepair because they have been deemed too dangerous or polluted for everyday work. When working on a facility for re-use or redevelopment, there may be crumbling walls and collapsed foundations that require personnel to build scaffolding or use aerial lifts to reach high places. Outfit these workers with fall protection such as web lanyards and fall harnesses to ensure their safety.

Collapses and falling debris, as well as cave-ins and crumbling trenches, put employees at risk. Use hard hats, work gloves, and steel-toed boots to prevent injury.

Getting started
Review the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. This standard applies to brownfield sites that include work such as:
1. Cleanup operations required by a governmental body involving hazardous substances conducted at an uncontrolled hazardous waste site.
2. Corrective actions involving cleanup operations at sites covered by the Resource Conservation and Recovery Act of 1976.
3. Voluntary cleanup operations at sites recognized by a governmental body as an uncontrolled hazardous waste site.

If the HAZWOPER standard applies, OSHA regulations require employers who are engaged in repairs or cleanup efforts at formerly polluted sites to create a written Health and Safety Plan (HASP) before beginning work. This sort of plan must be specific to each new worksite, though it may be possible to draw upon parts of former strategies as long as the necessary details of each site have been addressed.

The components of a HASP may include a site hazard analysis, control measures for leaking materials, an evaluation of necessary personal protective equipment, employee training for chemical handling, medical surveillance measures, decontamination procedures, monitoring and sampling, spill containment, confined space requirements, and emergency response strategies.

A HASP can be developed with help from a number of agencies. The Department of Labor (DOL) offers cleanup training for various hazardous materials and helps coordinate Workforce Investment Act (WIA) programs in brownfield communities. The DOL maintains regional offices around the country and can help employers prepare the necessary training measures.

Additionally, OSHA-approved local environmental agencies operating at the state level can help with on-site consultations to determine which materials pose a risk to workers and how to properly dispose of the materials.

With the added emphasis on ecologically friendly work practices and green initiatives, companies around the country are discovering that it is both profitable and helpful for communities to rehabilitate urban areas and former worksites. With the right training from government agencies and the proper use of safety supplies and safety equipment, employers can effectively help to clean up ecologically damaged sites while keeping their workers safe.

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