OSHA’s HAZWOPER training requirements are complex, requiring varying amounts and types of training for different levels of emergency responders, site cleanup workers, and TSDF personnel.
To provide HAZWOPER training that effectively prepares employees to carry out their responsibilities, employers must understand how OSHA organizes the regulations in 29 CFR 1910.120.
OSHA requires 24 hours of training in three places
in the HAZWOPER Standard. 24 hour HAZWOPER training is required for some individuals who respond to hazardous substance releases, some who work at hazardous waste cleanup sites, and some who work at hazardous waste treatment, storage, and disposal facilities or TSDFs.
While all three groups of employees need 24 hour HAZWOPER training, the information covered during the 24 hours will vary based on an employee’s specific responsibilities under the HAZWOPER Standard.
24-Hour HAZWOPER for Emergency Response
OSHA requires 24 hour HAZWOPER training for hazardous materials technicians
, described in the HAZWOPER Standard at 29 CFR 1910.1200(q)(6)(iii). A hazardous materials technician is an employee who approaches the point of a hazardous substance release (or a potential release) to plug, patch, or otherwise stop the release.
Recommended 24 hour HAZWOPER course:
24 Hour HAZWOPER—Emergency Response Technician
Sometimes called “hazmat techs” or “industry techs,” technicians are key players on every hazmat response team. Technicians must develop emergency response competencies like hazard recognition, PPE selection and maintenance, functioning within the Incident Command System (ICS) and others detailed in the Standard.
Annual refresher training
is also requried.
OSHA requires 24 hour HAZWOPER training for emergency responders above the technician level as well, i.e., specialists and incident commanders in the HAZWOPER Standard.
More: HAZWOPER for Emergency Response: Illustrated Guide
24 Hour HAZWOPER for Site Cleanup
Under its HAZWOPER requirements for uncontrolled hazardous waste sites (like Superfund sites) in paragraph "e" of the Standard, OSHA requires 24 hour HAZWOPER training for two types of site workers:
Recommended 24 hour HAZWOPER course:
24 Hour HAZWOPER—Contaminated Site Cleanup
- Occasional site workers who are on site only occasionally to do a specific limited task and are unlikely to be exposed over relevant exposure limits; and
- Workers regularly on site who work in areas that have been monitored and fully characterized to show that exposures are under relevant exposure limits, where respirators are not necessary, and where there are no health hazards or possibility of an emergency developing.
In addition to 24 hour HAZWOPER training, these site workers must complete one day of supervised field experience (29 CFR 1910.120(e)(3)(ii) and (iii)). Annual refresher training
is also required.
For general site workers
engaged in hazardous substance removal like equipment operators, laborers, and supervisors, OSHA requires a minimum of 40 hours of training
days of supervised field experience.
More: HAZWOPER For Site Cleanup: Illustrated Guide
24 Hour HAZWOPER for Treatment, Storage, and Disposal Facilities (TSDFs)
Thirdly, OSHA requires 24 hour HAZWOPER training for “new employees” at treatment, storage, and disposal facilities, defined in 29 CFR 1910.120(p).
24 hour HAZWOPER training provided for new employees at TSD facilities must enable them to safely perform their assigned job duties without endangering themselves or other employees (29 CFR 1910.120(p)(7)).
Employees at TSD facilities who will respond to releases of hazardous substances should receive training pursuant to their specific role in the emergency response—awareness, operations, technician, etc.—according to the requirements outlined in paragraph q of the HAZWOPER Standard.
To learn more about who needs 24 hour HAZWOPER training, 40 hour, 8 hour, or other types of training, read: Who Really Needs HAZWOPER Training?