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Have You Leaped Over Your HazWOPER Annual Refresher Training?

Posted by Shivi Kakar

Feb 29, 2012 7:35:00 AM

By Paula Kaufmann, CIH

It’s leap day!! If you are born on a February 29th, then you will really only celebrate your birthday once every four years.  What if you took a 40-hr HazWOPER course that ended on February 29th or an 8-hour HazWOPER refresher training on leap day?  Does this mean that you only have to ‘celebrate’ your refresher training once every leap year?

Have You Leaped Over Your HazWOPER Annual Refresher Training?

OSHA would say “no” as the requirement is for ANNUAL training.  But what if you haven’t taken your HazWOPER refresher training since the last leap day?  What would OSHA think (or cite!) during a records inspection?

The OSHA enforcement office would most likely not be impressed with the one course every leap day concept.  When asked about lapsed 8-hour refresher training, here’s what OSHA wrote in a letter of interpretation

“OSHA's intent is that employees should complete their refresher training within twelve months of their initial training, although we do understand that courses may be missed due to unavoidable circumstances. The employee who misses a refresher training should attend the next available refresher course.”

What about those of us who have not been working on a HazWOPER site and haven’t taken any refresher classes since the last leap day?  What training do we need before we can leap onto a HazWOPER covered site?  Here’s what OSHA wrote about a three or four year and seven year leap …

“…an individual who has been away for three or four years, the employer may determine that, while repeating all of the training materials in the initial course is not warranted, more than eight hours of training would be required to refresh the employee's knowledge and skills. …  However, a seven year absence would clearly indicate a need for extensive retraining, with particular attention given to new technology. In such cases the employer may wish to consider repeating the initial training course.”

When was the last time that YOU attended an 8-hr HazWOPER refresher training course?  Was it within the last 12 months?

Topics: OSHA Compliance, H&S Training, Hazardous Waste Management

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