HAZWOPER Training

OSHA requires HAZWOPER training for three main groups of professionals/personnel:

1. Facility emergency response personnel.  
HAZWOPER training is required for personnel who respond to emergency releases of hazardous substances, wherever the release occurs. OSHA divides the emergency responder category based on each employee's level of responsibility during an emergency release. 

This HAZWOPER infographic illustrates the levels of emergency responders and what HAZWOPER training is required for each employee.

​HAZWOPER "emergency response” actions include activities like sounding alarms, covering drains and vents, actively approaching the area of a release to plug, patch, or otherwise stop it, and overseeing the facility’s response to emergency releases. HAZWOPER training requirements for emergency response personnel are covered under HAZWOPER regulations in 29 CFR 1910.120 paragraph (q)(6).

2. Personnel who work at “uncontrolled hazardous waste sites.” 
This includes managers, supervisors, and any employees who may be exposed to hazardous substances health hazards, or safety hazards during cleanup activities—including those with non-cleanup duties, like utility workers.  


Common job responsibilities that require HAZWOPER training include assessing the site, operating equipment on site, excavating drums and other containers, monitoring hazardous substances, taking environmental samples, handling drums of hazardous waste, supervising personnel, and more.

This HAZWOPER infographic illustrates the types of site cleanup personnel who need HAZWOPER training. HAZWOPER training requirements for site cleanup activities are covered under HAZWOPER regulations in 29 CFR 1910.120 paragraph (e).

3. Personnel who work at hazardous waste Treatment, Storage, and Disposal Facilities (TSDFs).
HAZWOPER training rules for TSDFs are covered under HAZWOPER regulations at 29 CFR 1910.120, paragraph (p).
 

OSHA requires annual HAZWOPER refresher training for covered employees.

Annual HAZWOPER training is required for contaminated site clean-up site workers (see 29 CFR 1910.120(e)(8)).

Annual HAZWOPER training is required for all levels of emergency response personnel (see 29 CFR 1910.120(q)(8)(i)).
 

This is a common point of confusion for hazardous waste generators. 

Under the Resource Conservation and Recovery Act (RCRA) hazardous waste regulations US EPA requires “hazardous waste personnel” to complete annual training in proper on-site hazardous waste management practices (40 CFR 262.17).

RCRA training is required to prevent releases of hazardous waste to the environment through proper management. 

HAZWOPER is an OSHA workplace health and safety Standard (29 CFR 1910.120) to protect employees who work with hazardous substances in specific scenarios. These scenarios include response to emergency releases of hazardous substances and cleanup/remediation at contaminated sites.

RCRA training is required for all hazardous waste personnel. Some RCRA-trained personnel may also encounter or respond to emergency releases. Based on the employee's responsibilities and actions during a release, HAZWOPER training at the awareness (FRA), operations (FRO), or technician level may be appropriate.

HAZWOPER emergency response training goes far beyond what typical hazardous waste personnel need to know to safely generate and manage waste on site.

For hazardous waste personnel who's only responsibility during a release is to alert others and evacuate (taking no further action), HAZWOPER awareness training is likely most appropriate. 

Read more: RCRA vs. HAZWOPER: What’s the Difference?

OSHA allows employers to utilize online training as part of an effective health and safety training program, including to help satisfy initial or refresher HAZWOPER training requirements for employees. 

OSHA says:
 

"In OSHA's view, self-paced, interactive computer-based training can serve as a valuable tool in the context of an over-all HAZWOPER training program. " 
...
  "...OSHA believes that computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and gives trainees hands-on familiarity with protective equipment." 

OSHA Standard Interpretation (August 16, 2004)

Because HAZWOPER training must include elements that are specific to the work environment, substances, and equipment the employee will encounter on the job, online HAZWOPER training will likely need to be supplemented with site-specific instruction. 

As part of initial training for site workers at contaminated cleanup sites, OSHA requires three days of field experience in addition to 40 hours of off-site "classroom" instruction.