HAZWOPER Training Requirements

Frequently Asked Questions

  1. Who is covered by OSHA’s HAZWOPER standard?
  2. The HAZWOPER standard covers 5 specific areas of operations, including:

    1. Clean-up operations required by a governmental body, whether Federal, state local or other involving hazardous substances that are conducted at uncontrolled hazardous waste sites (including, but not limited to, the EPA’s National Priority Site List (NPL), state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are conducted before the presence or absence of hazardous substances has been ascertained);
    2. Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq);
    3. Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;
    4. Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and
    5. Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
  3. What is the definition of exposure?
  4. The term exposure as used in the scope of this standard has the same definition as in the OSHA Hazard Communication Standard, which defines it as follows:

    ["Exposure or exposed" means that an employee is subjected in the course of employment to a chemical that is a physical or health hazard, that includes potential (e.g., accidental or possible) exposure. "Subjected" in terms of health hazards includes any route of entry (e.g., inhalation, ingestion, skin contact or absorption).]

  5. If no exposure exists, does this mean exemption from the entire standard or just parts of the standard?
  6. This depends on the status of the site characterization effort. If the site has not yet been characterized then all of the appropriate 1910.120 requirements would apply, including training requirements. If the site has been characterized and no exposure or potential exposure exists, any further activity on site would fall outside the scope of the standard and the employer would not be required to meet any of the provisions of the standard and training may not be required.

    It is the responsibility of the employer to insure adequate site characterization. The information to be gathered is set forth in 1910.120(c). As a result of this process, employers are able to designate contaminated (hot zones) and uncontaminated areas (low hazard areas where no special personal protective equipment is necessary). Employers must have ongoing site characterization programs in case site activities or conditions change.

    Thus, anyone who enters a hazardous waste site must recognize and understand any potential hazards to health and safety associated with the cleanup activity. The level of training provided must be consistent with the worker’s job functions and responsibilities, the toxicity of the materials, the levels of exposure and the potential for an emergency to develop. 1910.120, along with other OSHA standards, insure this training.

  7. What is the definition of “working on site”?
  8. All employees who work on a hazardous waste site, which is covered by 29 CFR 1910.120, require training. Paragraph (e) recognizes that the risk of exposure to safety and health hazards exists in varying degrees. Your inquiry does not give sufficient details for a more specific response, however, it appears that the jobs you listed would typically fall under paragraph (e)(3)(ii). This subsection is for workers on site only occasionally, for a specific and limited task (as opposed to on site daily). In which case, the standard requires a minimum of 24 hours of off site training, and 8 hours of on-the-job training. The standard anticipates that this category of workers would not be exposed to chemicals above the permissible exposure limits (PELs), and would not be wearing respiratory protection.

  9. Do the operations and maintenance activities of Public Service Company Equipment on an uncontrolled hazardous waste site fall into the Scope and Application of the 1910.120 standard?
  10. If the site had not been characterized you would be responsible for conducting an initial characterization of the site in order to anticipate hazards before commencing with the maintenance activity. The characterization would have to be of sufficient detail to adequately characterize the safety and health hazards that would result from the specific operations in which your employees would be involved.

  11. Would training be required for employees performing intrusive soil activity on a defined site if the goal was to operate or maintain company owned equipment, in other words, non-cleanup activities?
  12. Yes, employees working on uncontrolled hazardous waste sites are covered whether the work they do is cleanup or non cleanup activity. However, employees are not covered if they work exclusively within uncontaminated areas of the hazardous waste site and are not exposed to health or safety hazards related to hazardous waste operations.

  13. Is online training acceptable for refresher training?
  14. online training may meet some HAZWOPER refresher training requirements, provided that it covers topics relevant to workers’ assigned duties. It must be supplemented by the opportunity to ask questions of a qualified trainer and by an assessment of hands-on performance of work tasks.

  15. What is OSHA’s position on online HAZWOPER training programs for cognitive training?
  16. In OSHA’s view, self-paced, interactive online HAZWOPER training can serve as a valuable training tool in the context of an overall training program. However, use of online HAZWOPER training by itself would not be sufficient to meet the intent of most of OSHA’s training requirements, in particular those of HAZWOPER. Our position on this matter is essentially the same as our policy on the use of training videos, since the two approaches have similar shortcomings. OSHA urges employers to be wary of relying solely on generic, “packaged” training programs in meeting their training requirements. For example, training under HAZWOPER includes site-specific elements and should also, to some degree, be tailored to workers’ assigned duties.

    Safety and health training involves the presentation of technical material to audiences that typically have not had formal education in technical or scientific disciplines, such as in areas of chemistry or physiology. In an effective training program, it is critical that trainees have the opportunity to ask questions where material is unfamiliar to them. In an online HAZWOPER program, this requirements may be providing a telephone hotline so that trainees will have direct access to a qualified trainer.

    Equally important is the use of hands-on training and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting. Many industrial operations, and in particular hazardous waste operations, can involve many complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely. Traditional, hands-on training is the preferred method to ensure that workers are prepared to safely perform these tasks. The purpose of hands-on training, for example in the donning and doffing of personal protective equipment, is two-fold: first, to ensure that workers have an opportunity to learn by experience, and second, to assess whether workers have mastered the necessary skills. It is unlikely that sole reliance on an online HAZWOPER training program is likely to achieve these objectives.

    Thus, OSHA believes that online HAZWOPER training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and provides trainees with sufficient hands-on experience.

  17. How will online HAZWOPER training be compared to required hour training as set forth in 1910.120?
  18. Where OSHA has specified a required duration represents, in OSHA’s view, the minimum amount of training that will be needed for most trainees to acquire the necessary basic skills. For the reasons stated above, OSHA does not believe that the use of online HAZWOPER training will, in the majority of cases, enable trainees to achieve competency in substantially less time than the required minimum duration for training. Therefore, the use of online HAZWOPER training will not relieve employers of their obligation to ensure that employees receive the minimum require amount of training specified under HAZWOPER and other OSHAstandards.

  19. Will an online HAZWOPER program’s outline and development material suffice for conventional training material documentation?
  20. OSHA standards, and HAZWOPER in particular, do not specify the kinds of materials that must be developed and maintained to document that a course meets the minimum requirements for course content. Employers may use whatever documentation is necessary to document the content of a training course.

  21. Will computer-based tracking of training competence levels be documentation enough for the training or will a hard copy, signed document be required?
  22. OSHA standards that require training generally contain a requirement for the employer to maintain records of employee training; these records may be kept in any form deemed appropriate by the employer, so long as the records are readily accessible to the employer, employees and their representatives, and to OSHA. However, note that the HAZWOPER standard contains a unique requirement in that employees must be provided a certificate upon the successful completion of initial training; this is best accomplished by the use of hard copy.

  23. For emergency response in an unknown or potentially IDLH atmosphere, what is the minimum number of people required?
  24. At a minimum, four (4) people are required: two working as a team inside the unknown or potentially IDLH atmosphere, and two working outside this atmosphere for assistance or rescue.

  25. Can refresher training be given in segments?
  26. Refresher training may be given in segments so long as the required 8 hours have been completed by the employee’s anniversary date.

  27. What if refresher training isn’t received in 12 months?
  28. If the date for refresher training has lapsed, the need to repeat initial training must be determined based on the employee’s familiarity with safety and health procedures used on site. The employee should take the next available refresher training course. “There should be a record in the employee’s file indicating why the training has been delayed and when the training will be completed.

  29. What are the training or certification requirements for HAZWOPER trainers?
  30. The “Hazardous Waste Operations and Emergency Response” standard (HAZWOPER), 29 CFR 1910.120, states in paragraph (e)(5) that “Trainers shall be qualified to instruct employees about the subject matter that is being presented in training”. In addition, 29 CFR 1910.120(e)(5) explains that the qualifications of the instructors may be shown by academic degrees, completed training courses and/or work experience.

    At this time, OSHA does not have any specific requirements to certify an instructor. The subjects that trainers should be able to convey to employees at hazardous waste operations who need training are summarized in paragraphs (e), (p) and (q) of the HAZWOPER standard.

  31. What are the HAZWOPER training requirements for hospital staff?
  32. OSHA’s Hazardous Waste and Emergency Response standard (HAZWOPER) requires that workers be trained to perform their anticipated job duties without endangering themselves or others. To determine the level and type of training your workers need, you must consider the hazards in your community and what capabilities your personnel need to respond to those hazards. You should make your determination based on worst-case scenarios. If your personnel are expected to provide limited decontamination services in order to attend to medical problems, they must be trained to the first responder operations level with emphasis on the use of PPE and decontamination procedures.

    This level of emergency response training is described in 29 CFR 1910.120(q)(6)(ii); additional guidance about the content of this training is available in HAZWOPER’s Appendix E. Hospitals may develop in-house training or they may send personnel to a standard first responder operations level course, then provide additional training in decontamination and PPE as needed. HAZWOPER requires the employer to certify that workers have the training and competencies listed in (q)(6)(ii). The standard also requires annual refresher training or demonstration of competency, as described in (q)(8).

  33. Do hospital physicians and nurses working in the Emergency Department need any level of emergency response training if they are treating patients who have been contaminated with chemicals?
  34. OSHA’s Hazardous Waste and Emergency Response standard (HAZWOPER) requires that workers be trained to perform their anticipated job duties without endangering themselves or others. To determine the level and type of training your workers need, you must consider the hazards in your community and what capabilities your personnel need to respond to those hazards. You should make your determination based on worst-case scenarios. If your personnel are expected to provide limited decontamination services in order to attend to medical problems, they must be trained to the first responder operations level with emphasis on the use of PPE and decontamination procedures.

    A hospital that expects its employees to handle emergencies involving hazardous substances also needs to prepare a written emergency response plan. Employees and affiliated personnel expected to be involved in an emergency response including physicians, nurses, maintenance workers, and other ancillary staff should be:

    1. Familiar with how the hospital intends to respond to hazardous substance incidents.
    2. Trained in the appropriate use of PPE, and (3) required to participate in scheduled drills.
  35. What is the difference between an incidental and an emergency spill?
  36. An incidental release is a release of a hazardous substance which does not pose a significant safety or health hazard to employees in the immediate vicinity or to the employee cleaning it up, nor does it have the potential to become an emergency within a short time frame. Incidental releases are limited in quantity, exposure potential, or toxicity and present minor safety or health hazards to employees in the immediate work area or those assigned to clean them up. An incidental spill may be safely cleaned up by employees who are familiar with the hazards of the chemicals with which they are working.

    The properties of hazardous substances, such as toxicity, volatility, flammability, explosiveness, corrosiveness, etc., as well as the particular circumstances of the release itself, such as quantity, confined space considerations, ventilation, etc., will have an impact on what employees can handle safely and what procedures should be followed. Additionally, there are other factors that may mitigate the hazards associated with a release and its remediation, such as the knowledge of the employee in the immediate work area, the response and personal protective equipment (PPE) at hand, and the pre-established standard operating procedures for responding to releases of hazardous substances. There are some engineering control measures that will mitigate the release that employees can activate to assist them in controlling and stopping the release.

    These considerations (properties of the hazardous substance, the circumstances of the release, and the mitigating factors in the work area) combine to define the distinction between incidental releases and releases that require an emergency response. The distinction is facility-specific and is a function of the emergency response plan.

    When, as a consequence of a release of a hazardous substance the following conditions, or similar conditions, may develop, such situations would normally be considered emergency situations requiring an emergency response effort:

    1. High concentrations of toxic substances.
    2. Situation that is life or injury threatening.
    3. Imminent Danger to Life and Health (IDLH) environments.
    4. Situation that presents an oxygen deficient atmosphere.
    5. Condition that poses a fire or explosion hazard.
    6. Situation that required an evacuation of the area.
    7. A situation that requires immediate attention because of the danger posed to employees in the area.
  37. What are the Emergency situations that fall under Hazwoper?
  38. Incidental releases that can be handled safely by employees in the immediate area, without the aid of a coordinated response effort from employees outside the area, would not be considered an emergency incident under 29 CFR 1910.120.

    The intent of the standard is to protect employees from exposure to the health and physical hazards of hazardous substances associated with hazardous waste operations and emergency response activities.

  39. What are the HAZWOPER training requirements for on-site workers who are not directly involved in cleanup activities?
  40. Workers, such as utility workers, who must perform duties at a hazardous waste site that has not yet been characterized but where contamination is expected, do fall under the scope of 29 CFR 1910.120. These workers must work under the direction of an on-site supervisor and a site-specific safety and health plan, and must be fully trained and protected pursuant to the HAZWOPER standard. When additional information becomes available through site characterization which verifies that there is minimal or no risk of employee exposure to hazardous substances, a lesser degree of PPE and worker training may be acceptable.

    When site characterization shows that the area to be serviced by workers is free of potential exposure, or the proposed work assignments would not expose any of the work crew to hazardous substances, the activity can be carried out as a normal maintenance or construction operation.

    The utility contractor is bound to provide at least the minimum number of training hours specified. On a hazardous waste site that has many site specific peculiarities the employer may need to train employees beyond the 40 or 24 hour minimum set by the standard. Employees must be provided training that prepares them for their job functions and responsibilities, as stated in the general requirements in 29 CFR 1910.120(e).

  41. How does 29 CFR 1910.120 covers an employee who will perform work that is not necessarily related to clean-up or control efforts at a hazardous waste site?
  42. Workers, such as utility workers, who must perform duties at a hazardous waste site that has not yet been characterized but where contamination is expected, do fall under the scope of 29 CFR 1910.120. These workers must work under the direction of an on-site supervisor and a site-specific safety and health plan, and must be fully trained and protected pursuant to the HAZWOPER standard.

  43. What is the applicability of HAZWOPER to small quantity generators?
  44. Employers who are not required to have a permit or interim status because they are conditionally exempt small quantity generators under 40 CFR 261.5 or are generators who qualify under 40 CFR 262.34 for exemptions from regulation under 40 CFR 262.34 for exemptions from regulation under 40 CFR parts 264, 265, and 270 (“excepted employers”) are not covered by paragraphs (p)(1) through (p)(7) of this section [1910.120 or 1926.65]. Excepted employers who are required by the EPA or state agency to have their employees engage in emergency response or who direct their employees to engage in emergency response are covered by paragraph (p)(8) of this section [1910.120 or 1926.65], and cannot be exempted by (p)(8)(i) of this section [1910.120 or 1926.65].

  45. What is the application of HAZWOPER to TSD facilities that store hazardous materials for 90 days or less?
  46. Conditionally-exempt small quantity generators and generators who store hazardous wastes for less than 90 days are exempt from compliance with sections (p)(1) through (p)(7), and are thus covered only by section (p)(8), the emergency response program.

    Employers who have hazardous waste storage areas in their facilities have the option of meeting the emergency response requirements of HAZWOPER by complying with either paragraph (p)(8) or paragraph (q) for those areas. The employer must meet the requirements of paragraph (q) for other areas of their facility which have potential for emergency releases of hazardous substances or hazardous raw materials.

    [Regarding the] exemption from employee training requirements under paragraph (p)(8) if the employer intends to evacuate employees in the event of an emergency. Paragraph (p)(8)(i), like paragraph (q)(1), provides an exemption from the emergency response requirements if the employer intends to evacuate all employees and provides an emergency action plan (i.e., an evacuation plan) in accordance with 29 CFR 1910.38(a).

    However, the HAZWOPER standard states in paragraph (a)(2)(iii)(B) that “employers who are required by the EPA or state agency to have their employees engage in emergency response… are covered by paragraph (p)(8) of this section, and cannot be exempted by (p)(8)(i) of this section.”

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