RECORD ID D94-04-008

STANDARD NUMBER

INFORMATION DATE 12-31-1994

SUBJECT Doe Hasp Policy On Multi-employer Sites

QUESTION

On a multi-employer hazardous waste site, what is DOE's policy regarding HASPs? Does the Agency require one HASP, or is each employer responsible for developing and implementing its own HASP? As a specific example, is the prime contractor responsible for preparing and implementing a HASP that covers the drilling subcontractor?

REGULATORY REVIEW

29 CFR 1910.120 does require a sharing of information among employers at a site and it holds each employer individually responsible for compliance with the entire standard. 1910.120(b)(1)(iv) requires employers to provide information on hazards and emergency response procedures to contractors, subcontractors, or their representatives. 1910.120(b)(1)(v) requires making the written health and safety program available to contractors, subcontractors and their representatives. OSHA has interpreted the responsibilities of employers at multi-employer sites in a letter from the Acting Director of Compliance Programs in 1989. This Interpretation was re-issued by DOE as DOE 3102. Under item # 4 of this Interpretation, each contractor/subcontractor is responsible for compliance with all safety and health protection requirements for their employees. A single (HASP) comprehensive document "may promote use efficiency; enhance completeness, clarity and coordination among all affected parties." A copy is attached. A just-released EM-40 document on Health and Safety Plan (HASP) Guidelines, EM Limited Technical Standard: SAFT-0025, February, 1994 does not address the issue of multi-employer HASPs directly. It mentions the existence of multiple site safety and health officers representing various contractor and subcontractor organizations on site in the chapter on Key Personnel, but this reference is the only one to the multi-employer situation. The document does not explicitly require one document.