OSHA HAZWOPER Training Requirements
Anfeald professionals provide hazardous waste and emergency response (HAZWOPER) training for employers in many different industries. Clients often ask us “What are the different types of training required under OSHA’s HAZWOPER standard?” or “What sessions should my employees attend?” This article will help you understand basic OSHA HAZWOPER requirements and select the appropriate training for your organization.
Although the regulation is confusing to read, the training requirements are actually very straightforward. The standard describes five operations that fall within the regulation’s scope with three training-categories that have unique but overlapping learning objectives and varying training-hours requirements. The different operations or site types included in the standard are:
- “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,
- 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.),
- Voluntary clean-up operations at sites recognized by Federal, state, local or other governmental bodies as uncontrolled hazardous waste sites,
- 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
- Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.” From 29 CFR 1910.120(a)(1)
In the first three operations OSHA describes planned environmental-remediation at different sites that one or more government agencies have acknowledged. Examples include unpermitted landfills, superfund sites, abandoned industrial sites, brownfield sites, former weapons manufacturing facilities and similar locations. Often, the work at these sites, and especially brownfield sites, voluntary clean-up sites and similar locations involve not just remediation, but preparation for the demolition and/or construction of buildings or the remodel of existing buildings. This work often involves construction general contractors, environmental engineers, excavation firms, surveyors, locators, occupational health and safety firms and other similar specialists and tradespeople. The work is complex and full remediation often takes many years to complete.
The fourth operation involves hazardous waste handling at facilities that are purpose-built to receive, treat, store or dispose of hazardous waste. These first four operations encompass a large number of workplaces but the common feature for all of them is that they describe fixed sites where the chemicals and the hazards are somewhat understood and remediation operations are planned in advance.
The fifth operation or site-type however, is different – it describes work that involves the mitigation of chemical releases on an emergency basis. Sites can include public and private facilities, manufacturing facilities, food and beverage plants, chemical plants, crude-oil tank farms and any other location where hazardous materials are used and the unintentional releases of those materials could occur during normal operations.
Once you understand the operations included in the HAZWOPER standard, it is critical to understand how OSHA defines the training categories and the requirements of each category. There are three training categories:
- Site Worker
- Emergency Response
These three training categories correspond to the five different training levels previously mentioned in this article. Site worker training applies to employees that work at planned remediation sites (site types one through three from the list above), TSD training applies to employees that work at TSD facilities (site type four) and emergency responder training is required for employees that work at uncontrolled emergency sites (site type five).
29 CFR 1910.120(e)(1) through (e)(9) describes site worker training. This training is typically referred to as 40-hour HAZWOPER training or simply site-worker training and requires an initial 40-hour session of off-site instruction and three days of field experience under a competent person for full certification. Annual refresher training for site workers is also required (29 CFR 1910.120(e)(8) addresses refresher training for previously trained 40-hour site workers) and is eight hours in length. It’s worth noting that under 29 CFR 1910.120(e)(3)(ii), OSHA allows an employer to reduce the amount of training required for occasional site workers, saving time and money:
“Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor.”
OSHA HAZWOPER site worker training provisions also call for an additional eight hours of training, over and above the 40-hour site-worker training, for onsite supervisors and managers. This training must include, but is not limited to additional related topics such as the employer’s safety and health program and the associated employee training program, personal protective equipment program, spill containment program, and health hazard monitoring procedure and techniques.
A site-worker is someone who works at a remediation site on a day-to-day basis and completes a variety of tasks associated with hazardous materials remediation within their area of specialty. Site-workers spend the bulk of their work time at the actual remediation site.
40-hours of initial training and eight hours of annual retraining are required. In addition, three days of field experience under the direct supervision of a trained, experienced supervisor is also required. 29 CFR 1910.120 (e)(3)(i)
Occasional site-workers perform specialty services on a periodic basis but are not necessarily at the site on a day-to-day basis. Surveyors are one example as they are on-site periodically for specialized tasks but do not work on the site every day. This training category is infrequently used; most owners and general contractor’s prefer that occasional site workers complete the full 40-hour course to ensure adequate knowledge.
24-hours of initial training and eight hours of annual retraining are required. In addition, one day of field experience under the direct supervision of a trained, experienced supervisor is also required. 29 CFR 1910.120 (e)(3)(i)
Manager or Supervisor (Site-Worker)
Onsite managers and supervisors are responsible for directing others must complete the same training as the general site workers (40-hours) and additional training to enhance their ability to provide guidance and make informed decisions.
Training is both time and competency based. Initial and refresher training are both required. The 40-hour class is a prerequisite. Anfeald’s HAZWOPER Site Manager course is 8-hours. 29 CFR 1910.120 (e)(3)(i)
Training for work at TSD facilities is described in 29 CFR 1910.120(p)(7)(i). This applies only to the fourth operation or site type mentioned at the start of this article. Twenty-four hours of initial training and eight hours of annual retraining are required.
Emergency responder training is covered under 29 CFR 1910.120(q)(6) and applies only to the fifth operation or site type mentioned at the start of this article. There are five training levels associated with emergency response operations; the levels are progressive.
First Responder Awareness - Level I
The only responsibilities for this level are the correct identification of a chemical release and a report to authorities on an emergency basis. There are no other responsibilities for this individual. Select this training option if you store or use chemicals in your operation but do not want your staff to have any responsibility for managing the release.
Initial and annual retraining is required. Training is competency based.
Anfeald’s typical class length is four hours.
29 CFR 1910.120 (q)(6)(i) and (q)(8)
First Responder Operations - Level II
Responders at this level perform defensive operations that do not expose them to hazards. They do not stop the release at its source but they do take other steps to manage the release. Select this option if you want to avoid excessive risk to your staff but need them to help reduce the impact of the release. If you train to this level, you should contract with a third-party firm to mitigate and clean-up releases.
Initial and annual retraining is required. Training is time and competency based.
Anfeald’s typical class length is eight hours.
29 CFR 1910.120 (q)(6)(ii) and (q)(8)
Hazardous Materials Technician - Level III
The Hazmat Technician performs all activities related to defense and mitigation. These employees stop releases at the source and complete all cleanup operations. Select this option if you intend to build and equip a fully-capable hazmat team.
Twenty-four hours of initial training is required with a competency-based annual refresher.
Anfeald’s refresher class is typically eight hours.
29 CFR 1910.120 (q)(6)(iii) and (q)(8)
Hazardous Materials Specialist - Level IV
Hazmat Specialists receive training on specific hazardous materials, specific situations and they also serve as liaisons to government agencies. Select this option for key team members that require enhanced training on specific chemicals, specific storage or transportation situations and additional training on interfacing well with authorities. This level is infrequently used.
Initial and annual retraining is required. Training is competency based
Anfeald’s typical course length is variable based on client’s needs. The hazardous materials technician (level III) course is a prerequisite.
29 CFR 1910.120 (q)(6)(iv) and (q)(8)
Incident Commander - Level V
Incident Commanders assume control of a scene and all Hazmat Teams report to an incident commander during an incident. If you intend to develop and equip a fully-capable hazmat team, at least one incident commander is required, and often several, depending on the team size and the nature and scope of the potential releases.
Initial and annual retraining is required. Training is competency based.
Anfeald’s typical course length is eight hours. The hazardous materials technician (level III) course is a prerequisite.
29 CFR 1910.120 (q)(6)(v) and (q)(8)