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An Overview of the OSHA HAZWOPER Training Requirements

               When Congress drafted the Superfund Amendments and Reauthorization Act (SARA) of 1986, they wanted to address the risk of potential harm that handling and cleaning up hazardous materials presented to workers involved in hazardous waste operations and emergency response incidents (Background section: Preamble to HAZWOPER Final Rule). So Congress included a requirement in Section 126 of Title 1 of the Act that the Occupational Safety and Health Administration (OSHA) promulgate regulations addressing the protection of workers involved in hazardous waste-related activities within 60 days of the Act becoming effective. Congress specified these regulations had to be at least as protective as the regulations requiring worker protection that were contained in the U.S. Environmental Protection Agency's (EPA) "Health and Safety Requirements for Employees Engaged in Field Activities" manual dated 1981.

                OSHA published interim regulations for the protection of affected workers in the Federal Register on December 19, 1986 (51 FR 45654), and they became effective immediately. OSHA then set out to develop a final set of regulations for this work, and issued their Final Rule for Hazardous Waste Operations and Emergency Response (HAZWOPER) on March 6, 1989. This new standard, found at 29CFR 1910.120, became effective exactly one year later (Intro section: Preamble to HAZWOPER Final Rule).

                The stated purpose of OSHA’s HAZWOPER standard is to protect workers from physical and health hazards presented by the potentially dangerous materials they are exposed to when working at certain job sites and/or when responding to a hazardous material spill or release. And while it may sound simple to just say something like “only trained professionals” can work with hazardous materials, this OSHA standard addresses several distinctive employee activities and hazardous materials exposures that demand differing levels of training and protection among workers. To demonstrate what I mean, consider the following hypothetical scenario:

                “A forklift operator at a factory accidentally drove into some pipes that run between chemical tanks located behind the shop, and chemicals began running onto the ground. The forklift operator ran to his foreman to report the accident. The foreman looked at the accident site from afar and realized the quantity of chemicals being released was beyond what could be handled by normal operating personnel, so he told his workers to evacuate the area, and then he contacted the site safety manager to report the incident. The site safety manager immediately called the local fire department to report the spill and specifically requested they send their hazardous materials (HAZMAT) response team to the site. He then went to the general area of the accident, careful to remain a safe distance away, and observed some of the liquid chemicals running on the pavement towards a storm drain inlet. So he grabbed some absorbent “pigs” from a nearby spill response kit and placed them across the opening of the storm drain inlet before the chemical could reach the area. Once the fire department’s HAZMAT team arrived, their incident commander conferred with the safety manager, and then instructed two of his team members to gear up and take monitoring equipment to the point of release to confirm which chemicals were involved and to evaluate any potential atmospheric hazards. By that time, the company’s head of the engineering department arrived at the scene, and he geared up to go in with the fire department’s HAZMAT team members so he could point out which valves needed to be shut off. Once that was done, one of the HAZMAT team members turned the valves to stop the chemicals from running out of the broken pipes, and they stabilized the area to prevent further spread of the chemicals. Later, a company that specializes in hazardous materials clean-up arrived at the scene, and their crew cleaned up, packed and loaded all residual chemicals and contaminated materials for shipment to a treatment and disposal facility located several miles away. There, workers treated (neutralized) the materials or disposed of them via incineration.”

                In this scenario, there are three different phases of work addressed within the OSHA HAZWOPER standard. The first one mentioned in the OSHA standard is uncontrolled hazardous waste clean-up sites, be it a crew cleaning up after a hazardous chemical accident like in our scenario presented earlier, or at a hazardous waste clean-up site such as an abandoned dump where chemicals were buried years earlier and need to be remediated. The second type of work site covered in the OSHA standard is the chemical treatment, storage, and disposal (TSD) sites, such as the one in our scenario where the hazardous waste was shipped. And the third type of work site covered is wherever there is an initial response to a hazardous material that is spilled or otherwise released, such as the factory where the accident occurred in our scenario, or at accidents involving material releases such as a train derailment involving chemical tankers. And the OSHA HAZWOPER standard has separate training standards for workers involved in each of these three phases or areas of work. And in those three phases, there are ten different worker categories addressed in standard, their level of training depending on their involvement in an incident. Here is an overview of training requirements for workers in each phase of our scenario.

PHASE I - Emergency Responders

                There are five worker categories identified in section 1910.120(q) of the OSHA HAZWOPER standard regulating those people involved in the initial response to the hazardous material spill or release. The first worker category listed is called “First Responder Awareness Level”, and their training requirements are described in 1910.120(q)(6)(i). In our scenario, this person would have been the foreman in the area where the forklift struck the pipes. In other incidents, this may be someone such as a police officer who happens upon a major wreck involving a chemical tank-truck, or perhaps a security officer making rounds after hours at a chemical manufacturing plant who happens upon an unexpected spill or release of chemicals.

                The awareness-level responder in our scenario had to be provided with training sufficient to understand that the release of chemicals was beyond the scope of an incidental release, and would require response and clean-up by specially trained workers. He notified the site safety manager of the release, and also initiated the evacuation of workers in the area per his company’s emergency action plan. He did not take any further action to try to contain or confine the chemical release. Awareness level responders must also receive adequate training to be able recognize and identify the hazardous substance(s) involved in the release, to understand the risks presented by the hazardous material(s) involved, and be able to implement whatever part they are assigned in executing the emergency action plan at the site. There is no minimum time period that their training must cover, just a requirement that the training enable the first responder to perform his duties.

                The next person involved in the emergency response in our scenario was the site safety manager, who had been trained as a “First Responder Operations Level”, as outlined in 1910.120(q)(6)(ii). In other cases, this may be a fire-fighter who responds to a wreck and sprays water on a burning tanker from afar, or an equipment room operator who tries to electronically manipulate valves from the control room to shut off an electronic valve or pump on a broken chemical line. The site safety manager responded to the initial chemical release in a purely defensive fashion to protect the environment from the effects of the chemicals by placing the absorbent pigs in front of the storm drain inlet, never putting himself in a position to be harmed by the released chemicals. Operations level responders must be trained to the same level of knowledge required for an Awareness Level responder (previously described), as well as in what defensive steps should be taken to contain the release from a safe distance to protect nearby workers and property.

                Operations-level responders must also be trained to properly utilize any personal protective equipment (PPE) necessary to perform their job safely, have an understanding of the basic terminology used in emergency responses to chemical releases, and know the procedures needed to ensure safe decontamination of their equipment and PPE when needed. The OSHA standard states their training must take at least eight (8) hours to complete or that person must have enough experience to objectively demonstrate competency in all required areas.

                The next level of responder covered in our scenario are the members of the fire department’s HAZMAT crew who went into the hot zone (where the accident actually occurred) to evaluate the atmosphere and stop the actual leak. They are referred to as “Hazardous Materials Technicians”, and their training requirements are addressed in OSHA standard 1910.120(q)(6)(iii). These workers must receive at least 24 hours of training on topics needed to enable them to perform their duties safely, which includes but is not limited to understanding the means and methods necessary to stop the actual release of chemicals (for example, closing valves or patching / plugging a ruptured line). Their training must consist of instruction equaling that of the First Responder Operations Level, plus additional instruction to enable them to implement the emergency action plan for their organization, select and utilize personal protective equipment necessary for the particular incident in which they are involved, utilize equipment to identify and verify the hazardous materials (chemical, biological, and/or radiological) involved in the incident, function within their role in the Incident Command System (ICS), and have a basic knowledge of the terms commonly used in hazardous materials responses, as well as have an understanding of the harmful effects of the materials to which they are exposed.

                The next level of emergency responder is called the “Hazardous Materials Specialist”, covered in 1910.120(q)(6)(iv). They provide support to the Hazardous Materials Technicians by offering skills or knowledge about the specific materials or processes involved in the incident, and/or act as liaison to various agencies responding to the event.   In our scenario, this was the company’s head of the engineering department, who went into the hot zone with the Hazardous Materials Technicians to point out which valves shut off the flow of chemicals in the ruptured pipes. These “Specialists” must have a minimum of 24 hours training in the same general topics as that required for the First Responder Operations Level, plus whatever specialized knowledge is needed to perform their designated task (such as use of specialized monitoring instrumentation, ability to identify and/or operate critical valves . . .). While commonly employed, a HAZMAT Specialist may not be required for all emergency response incidents.

                The fifth and final classification of emergency responder found in this particular section of the OSHA standard is that of the “On Scene Incident Commander.” Their training requirements are outlined in 1910.120(q)(6)(v), and must consist of at least 24 hours training in topics covered for the First Responder Operations Level, plus additional training to be able to act oversee the execution of the emergency action plans for all entities involved (local, state, federal). They must have knowledge of the hazards of the hazardous materials (chemical, biological, and/or radiological) involved in the incident, and also be able to manage or evaluate the selection, use, and decontamination of the personal protective equipment used in the response incident. In our scenario, the On Site Incident Commander was the leader of the Fire Department’s HAZMAT Response Team. However, the person acting in this role may change from person to person over time as different agencies respond to the scene, per the protocols outlined in the Incident Command Systems (ICS).

PHASE II – Cleanup at the Hazardous Waste Site

                In our scenario, a privately-owned company was called in to clean up the contaminated materials at the site, and their mandatory training requirements are addressed in section 1910.120(e). This is a different section of the OSHA HAZWOPER standard than that discussed in the section for emergency responders. This section would also apply to workers at all other uncontrolled hazardous waste sites; for example, workers cleaning up after the BP Horizon Deepwater oil spill along the gulf coast or at a designated Superfund site.

                OSHA standard 1910.120(e)(3) outlines the initial training requirements for three different categories of workers employed at these hazardous waste clean-up sites. And paragraph (4) of that standard covers the training required for the supervisors and managers who oversee those workers. According to paragraph 1910.120(e)(2), topics to be addressed in the general site workers’ training include identification of persons responsible for running the site safety program, the identity of the hazardous materials (chemical, biological, and/or radiological) present at the clean-up site and how to recognize the symptoms and signs of over-exposure to those materials. Training must also address the proper use of their personal protective equipment (PPE), the safe work practices they must follow to minimize exposure to the hazardous materials at the site, and how to properly use any equipment required while performing the functions of their jobs. Their training must also address decontamination procedures for their gear and PPE, the elements of their site emergency action plan (including spill control and emergency response measures), and where necessary, training in confined space entry procedures established for the worksite.

                The job classifications and general training requirements for workers at hazardous waste clean-up sites are as follows:

•             General site workers, such as general laborers and equipment operators – Any such employee having actual or potential exposure to hazardous substances or health hazards must receive at least 40 hours of off-site classroom training, followed by at least three full days of directly-supervised experience in the field, per 1910.120(e)(3)(i).

•             Workers who are only on site occasionally to perform a specific task, such as performing a survey or monitoring wells, and who therefore have limited exposure to chemicals at levels below the OSHA permissible limits (PELs), are only required to have 24 hours of off-site classroom training, followed by at least one full day of directly-supervised experience in the field, per 1910.120(e)(3)(ii))

•             Workers who regularly work on these clean-up sites but whose activities are limited to specific areas that have been quantitatively evaluated and characterized as having low exposure to chemicals (levels below OSHA PELs) so no respirator is necessary, and that also with no potential for developing into an emergency release or exposure, are only required to have 24 hours of off-site classroom training, followed by at least one full day of directly-supervised experience in the field, per 1910.120(e)(3)(iii).

•             On site managers and the supervisors who directly oversee operations and/or workers listed above that were required to have the 40-hours of training and three days of supervised field experience must also be provided with 40 hours of off-site classroom training followed by at least three full days of directly-supervised experience in the field. However, if the employees they oversee are only required by the standard to have 24 hours of training and one day of supervised field experience, then they too are only required to have 24 hours of off-site classroom training followed by at least one full day of directly-supervised experience in the field, per 1910.120 (e)(4)(iv).

                One important requirement that should not be overlooked is that if a worker, supervisor, or manager who falls into a 24 hour classroom/one day supervised field experience category is reassigned to a different job or position that requires 40 hours of Hazwoper classroom training and three days of supervised field experience, then that person must undergo the additional training and supervised field experienced needed to get to the required level, per 1910.120(e)(3)(iv).

PHASE III - Workers at Treatment, Storage and Disposal Facilities

                Once the hazardous materials were cleaned up and packaged at the site of the incident in our scenario, they were shipped off to be treated or disposed of at a facility designed for that purpose. OSHA standard 1910.120(p)(7) outlines the initial training requirements for all new workers employed at such hazardous waste treatment, storage, and disposal (TSD) facilities. The training requirements spelled out in this section are surprisingly brief when compared to the previous sections we have covered, only requiring workers be provided with 40 hours of training to enable them to perform their assigned job tasks in a “safe and healthful manner so to not endanger themselves or other employees” at the site.

                To meet this requirement, the same general topics that were covered for workers involved in emergency response events and hazardous waste clean-up sites would need to be covered, including but not limited to: identity and hazards of, and the signs/symptoms of overexposure to, the hazardous materials at the site; recognition of hazard warnings on labels, markings, and placards; proper selection and utilization of their personal protective equipment; decontamination procedures; the site emergency action plan; and work practices necessary to minimize exposure to the hazardous materials at the site. In addition, paragraph 1910.120(p)(8)(iii) requires that any site workers who are assigned to perform tasks associated with the site’s emergency action plan be adequately trained in the topics necessary to properly execute their tasks at that site.

Refresher Training

                In addition to the initial training requirements spelled out in the OSHA standards for workers involved in these three phases of work covered under the OSHA HAZWOPER standard, there are requirements for refresher training so all of these workers can maintain the knowledge and skills needed to perform their jobs safely. According to paragraphs 1910.120(e)(8), 1910.120(p)(7)(ii), and 1910.120(q)(8), affected workers and supervisory personnel must be provided with refresher training annually to maintain their level of competency, with the training usually totaling at least eight (8) hours in duration.

HAZWOPER Training Certification

                Each section of the OSHA HAZWOPER training standard also requires certification of the completion of all initial and refresher training conducted for affected personnel to be completed for each individual worker. The specific requirements for documentation of all HAZWOPER training can be found at 1910.120(e)(6), 1910.120(p)(7), and 1910.120(q)(8)(ii).

Qualification of HAZWOPER Trainers

                One more topic addressed in the OSHA HAZWOPER standards is the qualification of the trainers. OSHA has taken a performance-based approach to the trainer qualifications, generally stating that trainers only be “qualified to instruct employees about the subject matter that is being presented in the training.” However, these standards do state the trainers should have completed a training program for the subjects they are covering, or possess a teaching credential and/or the experience necessary to teach the subjects. The specific standards addressing the trainer requirements can be found at 1910.120(e)(5), 1910.120(p)(7)(iii), and 1910.120(q)(7).

Training Curriculum Guidelines

                The OSHA HAZWOPER standard contains several non-mandatory appendices. Among those is Appendix E, titled Training Curriculum Guidelines. This helpful document contains, among other things, suggested general criteria, suggested core criteria, suggested program quality control criteria, and suggested training curriculum guidelines for all three phases of hazardous waste handling that were discussed in our scenario.


                The OSHA HAZWOPER standards contain detailed training requirements for workers involved in all phases of hazardous waste operations and emergency response, each spelled out in one of three sections of the standard; Section 1910.120(e) addresses training requirements for workers employed at hazardous waste clean-up sites, section 1910.120(p) covers training requirements for workers employed at hazardous waste treatment, storage, and disposal (TSD) facilities, and section 1910.120(q) contains the training requirements for workers involved in emergency response to hazardous materials spills and releases. In fact, there were ten different categories of HAZMAT worker involved in our hypothetical scenario, each with their own specified level of mandatory training listed in the OSHA standards. HAZWOPER training is so important because without it, incidents similar to that in our scenario as well as many others involving similar emergency situations could easily expose workers to hazardous materials in quantities presenting potentially grave consequences.