Proper hazardous waste management falls under the control of the EPA, but it’s also an integral part of industrial hygiene (occupational hygiene or workplace health), which is the central concern of OSHA.
According to OSHA, industrial hygiene “is the science of anticipating, recognizing, evaluating, and controlling workplace conditions that may cause workers’ injury or illness.” And your responsibility thereto is assessed by “industrial hygienists,” who use “environmental monitoring and analytical methods to detect the extent of worker exposure” and “employ engineering, work practice controls, and other methods to control potential health hazards.”
OSHA develops and enforces mandatory occupational health & safety requirements across more than six million U.S. workplaces. If you handle hazardous waste, your enterprise is certainly among them. So do you need access to an industrial hygienist in advance of a visit from OSHA?
Our advice is an absolute yes, because when you read OSHA materials related to workplace hygiene (let alone hazardous waste removing), the language and tone therein are emphatically regulatory—definitely not consultative. In sum, you want to discover violations (real or perceived) before OSHA does.