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OSHA’s HAZWOPER Training Requirements Explained

Anfeald professionals provide HAZWOPER training for employers in many different industries. Clients often ask:

What are the different types of training required under OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard?

Although the regulation is confusing to read, the training requirements are actually straightforward.  The standard describes five operations that fall within the regulation’s scope with three training-types that have unique but overlapping learning objectives and varying training-hours requirements; let’s first review these different operations.  From 29 CFR 1910.120(a)(1):

  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 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.”

The first three operations describe   planned environmental-remediation at different kinds of fixed sites that one or more government agencies acknowledge. Examples include unpermitted landfills, superfund sites, abandoned industrial sites, brownfield sites, former weapons manufacturing facilities and similar locations.

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, for the most part, well characterized.

The fifth operation however, is quite unique  – It describes work that involves the mitigation of chemical releases on an emergency basis when the exact nature and extent of the hazards are unknown. Sites can include public and private facilities, manufacturing facilities, food and beverage plants, chemical plants and any other location where hazardous materials are used and unintentional releases of those materials could occur during normal operations.

Now that we understand the operations included in the HAZWOPER standard, let’s take a look at how OSHA has defined the training requirements:

  • 29 CFR 1910.120(e)(1) through (e)(9) describes the training requirements for those first three operations we just reviewed.  This training requires an initial 40-hour session of off-site instruction and three days of field experience.  There are additional requirements for occasional site workers and for managers and supervisors.  29 CFR 1910.120(e)(8) addresses refresher training for 40-hour site worker certified employees; this refresher training is eight hours in length.
  • Training for work at TSD facilities is described in 29 CFR 1910.120(p)(7)(i).  This applies only to the fourth operation.  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.  There are five levels of training requirements; the levels are progressive.

OSHA’s HAZWOPER
Training Requirements at a Glance

Operation
Level
Initial Training
Annual Refresher Training
Citation

29 CFR 1910.120
Class Offered by Anfeald?
Notes:[1] Field experience is not included in Anfeald’s standard class.[2] OSHA provides additional clarification on the hourly training requirements for emergency responders in questions four and five of an interpretation letter dated 24 September 2002.
Site Clean-Up OperationsSite Worker40-hour with three days of field experience[1]8-hours

(e)(3)(i)



Yes


Occasional Site Worker24-hours with one day of field experience[1]8-hours

(e)(3)(ii)



Yes


Manager or Supervisor40-hour with three days of field experience[1]8-hours

(e)(4)



Yes


TSD Facilitiesn/a24-hours8-hours

(p)(7)(i)



Yes


Emergency Response[2]First Responder AwarenessCompetency-based; no hourly requirementCompetency-based; no hourly requirement

(q)(6)(i) &


(q)(8)



Yes


First Responder Operations8-HoursCompetency-based; no hourly requirement

(q)(6)(ii) &


(q)(8)



Yes


Hazmat Technician24-hoursCompetency-based; no hourly requirement

(q)(6)(iii) & (q)(8)



Yes


Hazmat SpecialistTechnician Level + CompetenciesCompetency-based; no hourly requirement

(q)(6)(iv) & (q)(8)



Yes


Incident CommanderTechnician Level + CompetenciesCompetency-based; no hourly requirement

(q)(6)(V) & (q)(8)



Yes


HAZWOPER Emergency-Responder Levels & Responsibilities from 29 CFR 1910.120(q)

Training Level
What is it? Who needs it?
First Responder AwarenessThe 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.
First Responder OperationsResponders at this level perform defensive operations that do not expose them to hazards. They never 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.
Hazmat TechnicianThe 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.
Hazmat SpecialistHazmat 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 when you need someone to interface well with authorities. This level is infrequently used.
Incident CommanderIncident Commanders assume control of a scene. 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.

So that’s it.  Turns out it’s simple after all!

Looking for HAZWOPER, hydrogen sulfide or other occupational safety and health training?  Contact us today and find out how we can help you take your training program to the next level.