These guidelines have been developed by a working group consisting of both field and
headquarters personnel to provide new direction to the EM-40 program in the preparation of site-
specific Health and Safety Plans (HASPs). While based on the minimum requirements of 29 CFR
1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER), and DOE
orders, these guidelines have been developed with the express purpose of implementing a high
quality safety and health program. These EM-40 HASP Guidelines are a "living document" to be
modified and updated as new regulations and other requirements are issued. Guiding the
development of this document has been the principle that an effective and high-quality HASP
A clear chain of command for safety and health activities,
Accountability for safety and health performance,
Well defined headquarters expectations regarding safety and health,
Well defined task and operational hazards/risks,
Comprehensive hazard prevention and control methods, and
Recordkeeping requirements to track program progress.
As this document was developed the working group applied the following assumptions:
It is a generic document to be adapted on a site-by-site basis,
An adequate site characterization and comprehensive workplan exists at each field site,
Operations analysis and risk identification methods are adequate,
A written site safety and health program exists as required in 29 CFR 1910.120 (b),
Written site Standard Operating Procedures exist, and
Site specific information is available.
Each chapter of these guidelines represents an element listed in 29 CFR 1910.120(b)(4)(ii) for a
HASP. The first chapter, Regulatory Framework, provides direction on what should be included
in a site-specific HASP. 29 CFR 1910.120(b)(4) has been issued as the minimum criteria, and
starting point. In several instances this guidance goes beyond this requirement. In addition to the
requirements of 29 CFR 1910.120(b)(4) the guidance is based on good industry practice,
Environmental Protection Agency recommendations, specific DOE need (radiation protection),
and DOE orders and directives. Chapters 2 through 14 provide guidance on how to meet the
requirements specified in Chapter 1.
Each chapter provides detailed information on a particular component of a site-specific HASP.
When utilizing this guidance to prepare site-specific HASPs, the preparer of the HASP should be
able to provide appropriate documentation on how decisions were made relative to the relevant
sections of the guidance. In some cases, the requirements of different sections overlap. The
preparer of a site-specific HASP need not repeat overlapping information but should indicate by
reference where the information is located.