Who Needs HAZWOPER Training?

If you work with hazardous materials or hazardous waste,  you've no doubt heard about OSHA's HAZWOPER Standard. Found at 29 CFR 1910.120, the HAZWOPER Standard is one of the most complicated health and safety Standards found in OSHA regulation.

This HAZWOPER FAQ will help you identify which employees need HAZWOPER training and how much training they need (40 hours, 24 hours, 8 hours, etc.).

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What is HAZWOPER?
HAZWOPER is an OSHA worker safety and health standard. The acronym HAZWOPER stands for Hazardous Waste Operations and Emergency Response.

The HAZWOPER Standard, found in 29 CFR 1910.120, is intended to protect employee who work respond to emergency releases of hazardous substances, work at hazardous waste clean-up sites or "uncontrolled hazardous waste sites," or work at hazardous waste treatment, storage, and disposal facilities (TSDFs). .
 
Who needs HAZWOPER training under 29 CFR 1910.120?
OSHA HAZWOPER training is required for three main groups of personnel:

1. 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).

2. Facility emergency response personnel.  OSHA splits this up category based on each employee’s 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” covers 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).

3. Personnel who work at hazardous waste Treatment, Storage, and Disposal Facilities (TSDFs).

HAZWOPER training requirements for TSDF personnel are covered under HAZWOPER regulations at 29 CFR 1910.120, paragraph (p).
How often is HAZWOPER training required?
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)).

Initial and refresher HAZWOPER training
Who needs 40 Hour HAZWOPER training?
40 Hour HAZWOPER training is required for employees at contaminated site cleanups, specifically:
  • General site workers who perform hazardous substance cleanup activities—general labor, operating equipment, handling drums, and containers, and other jobs; and
  • Supervisors at hazardous substance cleanup sites
Each year after their initial training, employees trained to the 40-hour HAZWOPER Standard must complete 8 hours of HAZWOPER refresher training. 

In addition to 40-hour HAZWOPER training, the employee must complete three days of supervised field experience to complete the OSHA training requirement. [See 29 CFR 1910.120(e)(3)(i)]

40 Hour OSHA HAZWOPER Initial—Contaminated Site Cleanup
8 Hour OSHA HAZWPER Refresher—Contaminated Site Cleanup 
What qualifies as three days of HAZWOPER field experience?
According to OSHA:

“Supervised field experience is part of an employee's initial training, taking place after he or she has completed the off site classroom instruction. Employees must be able to familiarize themselves with the equipment and field conditions they will be expected to work under. The initial three days in the field under the supervision of another experienced employee ensures the safety and health of the new employee.”

[see OSHA Standard Interpretation 11/07/91]
 
Who needs 24 Hour HAZWOPER training?
There are two 24-hour HAZWOPER training Standards in the OSHA HAZWOPER regulations. To ensure the HAZWOPER training provided is relevant to the employee’s responsibilities, you must know which standard applies to your workers.

24 Hour HAZWOPER training is required for two groups of employees:
  • “Occasional site workers” at hazardous substance cleanup sites; and
  • Hazardous Materials Technicians (a.k.a. Level 3 Emergency Responders or “Techs”) who take aggressive response actions during an emergency to plug, patch, or otherwise stop a hazardous substance release.
Learn more about training required for each type of employee at Lion.com/HAZWOPER
Who is an "occasional site worker"?
HAZWOPER “occasional site workers” are those who visit a hazardous substance cleanup site occasionally, to perform limited tasks like groundwater monitoring, land surveying, and others, and are unlikely to be exposed to hazardous substance at any level over permissible or published exposure limits. (See 29 CFR 1910.120(e)(3)(ii)

“Occasional site workers” at hazardous substance cleanup sites must complete the 24 hours of initial HAZWOPER training. Each year after their initial training, occasional site workers trained to the 24-hour HAZWOPER Standard must complete 8 hours of HAZWOPER refresher training 

24 Hour OSHA HAZWOPER Initial—Contaminated Site Cleanup
8 Hour OSHA HAZWOPER Refresher—Contaminated Site Cleanup
Who needs 8 Hour HAZWOPER training?
General site workers at hazardous waste cleanup sites must complete 8 hours of HAZWOPER refresher training annually [29 CFR 1910.120(e)(8)].

Hazardous materials technicians who respond to emergency releases often complete 8-hour refresher training as well. The HAZWOPER Standard requires annual refresher training for emergency response personnel like technicians, but does not specify a minimum run-time for refresher training [29 CFR 1910.120(q)(8)(i)].

Lion offers 8 Hour HAZWOPER refresher training for both emergency responders and site cleanup personnel:
8 Hour OSHA HAZWOPER Refresher – Emergency Response Technician (Level III)
8 Hour OSHA HAZWOPER Refresher – Contaminated Site Cleanup
 
Who needs HAZWOPER "awareness" training?
HAZWOPER awareness training is required for employees who may encounter or discover a hazardous substance release, but who don’t have specific responsibilities for response. These “awareness-level” employees must know enough to alert appropriate personnel that a release is imminent or in progress, then clear the area or evacuate the facility as necessary.

“Awareness” training may sound basic, but these are not responsibilities to be taken lightly. Emergency response should be left to those with the training, knowledge, and skills to perform it safely and properly.  A crowd of non-authorized employees can get in the way, delay response, or get injured or exposed to hazardous substances.

2 Hour OSHA HAZWOPER Awareness Training
Emergency Response: Who is an "operations-level" first responder?

“First Responder—Operations,” often shortened to FRO and also known as Level 2 Emergency Responders, refers to facility personnel with responsibilities for taking defensive response actions. “Defensive” response actions include shutting off equipment remotely, covering storm drains, closing or covering vents, and the like. 

FRO responders do not approach the point of the release. Their responsibility is not to stop the release, but to prevent the release from spreading or getting worse. 

Emergency Response: Who is a hazardous materials technician or hazmat tech?
As mentioned above in the Who needs 24-hour HAZWOPER training answer, a Hazmat Technician or "Tech" is an employee who takes aggressive response actions during an emergency release.

Technicians approach the point of a release to plug, patch, or otherwise stop the release.
 
Emergency Response: Who is a hazardous materials specialist?
A hazardous materials specialist (a.k.a. Level 4 Emergency Responder) shares the same responsibilities as a Technician. Specialists respond alongside technicians. What makes a specialist different is that he or she holds specialized knowledge about the materials and processes on site. The specialist supports the technicians and the incident commander by providing information and guidance when needed.
 
Emergency Response: Who is a HAZWOPER Incident Commander?
The on scene incident commander (a.k.a. Level 5 Emergency Responder) are employees who will assume control of the incident scene beyond the first responder awareness level. 

Essentially, they run the show during an emergency response incident and supervise the employees doing the response.
 
Site Cleanup: What is an "uncontrolled hazardous waste site"?
OSHA’s HAZWOPER Standard at 29 CFR 1910.120(a)(1)(i)-(a)(1)(iii) covers clean-up operations ordered by Federal, State, local, or other government body that involve hazardous substances at the following types of sites.

Called "uncontrolled hazardous waste sites," these include: 
  • Sites on EPA’s National Priority Site List (NPL) (a.k.a. “Superfund Sites”)
  • Sites recommended for the EPA’s NPL
  • Hazardous waste sites on State priority lists
  • Initial investigations of government-identified sites conducted before the presence of hazardous substances has been ascertained.
  • Corrective actions involving clean-up at sites covered by the Resource Conservation and Recovery Act (RCRA) 
  • Voluntary clean-up operations at sites otherwise recognized by Federal, State, local, or other government bodies as “uncontrolled hazardous waste sites.”
What's the difference between RCRA and HAZWOPER?
This is a common point of confusion for hazardous waste generators. 

US EPA requires all “hazardous waste personnel” to complete annual training in the RCRA requirements for managing hazardous waste on site [40 CFR 262.16 and .17]. This hazardous waste training is required to prevent releases of hazardous waste to the environment through proper management. 

HAZWOPER is an OSHA workplace health and safety standard that protect employees who work with hazardous substances in specific scenarios, like site cleanup and emergency response. While some employees at your facility may be responsible for responding to an emergency hazardous substance release, HAZWOPER training goes far beyond what typical hazardous waste personnel need to know to safely generate and manage waste on site.

That said, HAZWOPER awareness training maybe appropriate for employees who may encounter a hazardous substance release. 

To learn more about hazardous waste training for typical managers and personnel, view our RCRA Training page. To see which hazardous waste personnel may need both RCRA and HAZWOPER training, view our blog on the subject. RCRA vs. HAZWOPER: What’s the Difference?
What's the difference between "site cleanup" and "emergency response"?
Contaminated site cleanup occurs at a site where hazardous substances may be found in the groundwater, soil, air, or on the land, and must be cleaned up. Often these cleanup activities are required by a Federal, State or local government. In other cases, cleanup may be voluntary.

An emergency response occurs during a release of hazardous substances that poses an immediate danger to workers, property, and/or the public at large. Emergency releases can occur anywhere—at a facility or out on the road.

Learn more at Lion.com/HAZWOPER