The U.S. Department of Labor, Occupational Safety and Health Administration (OSHA) under 29 CFR 1910.120 Hazardous waste operations and emergency response requires workers who work at hazardous waste sites who may be exposed to safety and health hazards1 to receive initial and refresher training from qualified instructors. Initial training must be completed prior to work on hazardous waste sites. The following training discussion follows OSHA guidance in interpreting the standard. OSHA-approved state programs, however, may have differing interpretations or regulations.
Table I outlines the time requirements for the initial offsite training and field experience. Training times include lunch and breaks. 2, 3 The training shall cover the following topics:
- Names of personnel and alternates responsible for site safety and health
- Safety, health and other hazards present on the site
- Use of personal protective equipment
- Work practices by which the employee can minimize risks from hazards
- Safe use of engineering controls and equipment on the site
- Medical surveillance requirements including recognition of symptoms and signs which might indicate over exposure to hazards
- The contents of the site safety and health plan
- Emergency response training, if the worker will respond to emergency situations that may expose them to hazardous substances
The 8-hours of specialized training for managers and supervisors may include the employers safety and health program, the employee training program, personal protective equipment program, spill containment program, and health hazard monitoring procedure and techniques. Equivalent training is permitted for the initial 40-hour offsite training if the workers experience and training can be clearly documented and certified to address the required topics.
Table I: Initial Training Required
|Worker Type||Offsite Training||Field Experience|
|General Site Workers|
|Workers on site occasionally and hazardous exposures unlikely workers do not wear respirators|
|Workers onsite regularly in established safe areas workers do not wear respirators|
|Managers and supervisors of General Site Workers|
40-hours minimum plus
8-hours specialized training
|Managers and supervisors of workers who work on site occasionally or regularly in safe areas and who do not wear respirators|
24-hours minimum plus
8-hours specialized training
All training must be certified by the training instructor, head instructor and trained supervisor as having completed the necessary training. The instructor must assess whether the worker has achieved the training objectives and certify the individual accordingly.4 A written certificate shall be given to each person so certified for offsite and field experience. A certificate of attendance is not sufficient.
Online or computer-based training alone are not sufficient to satisfy the 40-hour training requirements, but may be used to satisfy part of the training requirements.5 Training should have the opportunity for trainees to ask questions and participate in hands-on experiences and exercises, especially the use of personal protective equipment.
Equivalent training provided to employees in order to comply with other OSHA standards may be counted towards the 40-hours as long as all of the applicable training topics of the HAZWOPER standard are address and total training time is at least 40 hours.6 In general, training for employees working at hazardous waste sites differs from the training required for employees who respond to emergency releases of hazardous substances and normally should not be considered equivalent.7
Table II lists the required time for the refresher training. Training times include lunch and breaks. 2, 3 Refresher training shall address the same topics as listed for the initial training and include any critique of incidents that have occurred in the past year. Other relevant topics may be included in refresher training. Refresher training is to be completed annually. Training maybe segmented over time as long as the training is completed within one year.8
Table II: Refresher Training Required Annually
|All workers, managers and supervisors|
Computer-based training is not recommended by OSHA, but is acceptable if the following criteria are met: 1) the training covers topics relevant to workers assigned duties; 2) there an opportunity to ask questions of a qualified instructor; and 3) an assessment of worker skill is conducted to measure hands-on performance of work tasks.9
The question becomes, what happens if you let your refresher training lapse? Do you have to take the initial 40-hour training over? There is no specific requirement that you must repeat the 40-hour training. OSHA states that if an employee misses a refresher training, he or she should attend the next available refresher course. As the length of time increases between the completion of the 40-hour course and the refresher course, the more likely the person would need to take the 40-hour course again. The decision about what training is needed after a lapse in refresher training must be determined on a case-by-case basis and depends on the experience, knowledge and skills of the individual involved. 10
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