Site Characterization: How HAZWOPER Questions Test Early Hazard Recognition

29 CFR 1910.120(c) · Site Characterization and Analysis

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Site Characterization Steps

1. Off-site survey: review records, aerial photos, previous assessments, manifest records before approaching site.
2. Initial entry: minimum Level B or Level A if hazard unknown; buddy system required; no solo entry.
3. Approach strategy: approach from upwind, uphill, upstream — this gives maximum time to respond if a release occurs.
4. Visual survey: identify containers, labels, placards, physical hazards, signs of reaction, stressed vegetation.
5. Air monitoring survey: perimeter first, then progressively closer to suspected source.
6. Sample collection: only after hazards are assessed sufficiently to allow approach.
7. Site safety plan (SSP): must be developed and communicated before any work begins.

Site Control — Three Zones

Site Characterization Exam Traps

• The site safety plan must be site-specific — a generic safety plan does not meet HAZWOPER requirements.
• The buddy system is mandatory for initial site entry — no one works alone in the exclusion zone.
• "Upwind/uphill/upstream" applies to approach direction AND to where the command post and support zone are placed.
• An IDLH or unknown atmosphere requires Level A or Level B; you cannot assume Level C is acceptable without air monitoring data.
• Stressed vegetation (dead trees/grass in a pattern) is a key site characterization observation indicating possible underground contamination or chemical release.
• Site characterization is an ongoing process — conditions can change as work proceeds and monitoring must continue.