Brownfield sites, or “brownfields” are defined by the Small Business Liability Relief and Brownfields Revitalization Act as “real property, the expansion, redevelopment or reuse of which may be complicated by the presence of a hazardous substance, pollutant, or contaminant.”
OSHA Standards
OSHA Standards for Brownfield hazards are addressed under the OSHA General Industry as well as Construction Industry standards. If a site is determined to be a “hazardous waste site” it must comply with the HAZWOPER standards (General Industry (29 CFR 1910.120) and Construction (1926.65)). Additionally, 29 states have OSHA-approved State Plans that may have further requirements.
Types of Hazards
The types and levels of contaminants on Brownfield sites vary greatly depending on the industry or commercial facility that previously operated on the site. Brownfield site examples include former gas stations, dry cleaners, industrial facilities, abandoned railroads, vacant lots, and residential or commercial buildings built before 1989.
Job Hazard Analysis
It is the employer’s job to conduct a site assessment with site cleanup jobs in mind. The employer should plan work tasks while anticipating the types of exposures that might occur to protect workers from the chemical and physical hazards. A job hazard analysis takes into consideration any hazards that could result in employee exposure and then protect employees accordingly per OSHA standards. Contaminants might be found in the ground water, surface soil, buildings, containers, and dust on-site. It is important to know what these contaminants are through testing to be able to protect adequately against them.
BE AWARE AND BEWARE…WHEN CLEANING BROWNFIELDS!
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