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Is HAZWOPER Refresher Training Always 8 Hours?

Posted on 9/22/2020 by Joel Gregier, CDGP

If you've been through your initial HAZWOPER training, you probably already know that OSHA requires annual re-training. There is some confusion in industry, though, about how long that yearly refresher training must be. Is it really true that HAZWOPER refresher training must be 8 hours long?

The answer, as it almost always goes with regulations, is that it depends. In this case, it depends on what type of HAZWOPER employee you are.

8-Hour HAZWOPER Training Required for Some (But Not for All)

There are three types of employees subject to HAZWOPER training. The hours of HAZWOPER training and re-training OSHA requires for you depends on which of these three groups you are in:
  1. Cleanup site employees,
  2. TSDF employees, and
  3. Emergency responders.

Only two of these three types of employees must have 8-hour refresher training: the cleanup site employees and TSDF employees.

HAZWOPER Training for Cleanup Sites and TSDFs 

Refresher training required: Annually 
Hours of re-training required: 8 hours 

Cleanup site workers include those workers directly involved in a hazardous substance or hazardous waste cleanup activity. For instance, people who work at “Superfund” sites. If you have “real or potential exposure” or “minimal exposure” to these hazardous substances, you must have 8-hours of refresher training.  This also goes for supervisors and managers at these sites. [29 CFR 1910.120(e)(8)]

To help employers satisfy OSHA HAZWOPER training mandates for site cleanup employees, Lion offers 100% online 8 Hour OSHA HAZWOPER Refresher - Contaminated Site Cleanup. 

A 40 Hour Initial HAZWOPER training is also available online. 

TSDF workers include people who work at permitted hazardous waste facilities that treat, store, and dispose of hazardous waste.  Employees covered here would only include those workers actually involved with the TSDF operation.  These types of employees would require 8-hour refresher training. [29 CFR 1910.120(p)(7)]

Those not involved directly with TSDF operations but do emergency response at TSDF sites would be subject to “emergency responder” training requirements (see below). [29 CFR 1910.120(p)(8)(iii)]

HAZWOPER Training for Emergency Responders

Refresher training required: Annually 
Hours of re-training required: Not necessarily 8 hours 

HAZWOPER emergency responders include employees who must respond to emergencies involving hazardous substances. This includes people like firefighters but also employees who do emergency response on site for their employer. To be clear, if you do emergency response at cleanup sites or directly related to TSDF operations, you would fall into the first two categories and must be trained as such.

There are five levels of emergency responders, but they all have the same requirement for refresher training; annual refresher training should be of “sufficient content and duration to maintain their competencies.” [29 CFR 1910.120(q)(8)]

What that means is there is no requirement to do 8-hour training.  You simply need to train long enough to cover everything the responder needs to know. The lower your responder level, the more likelihood your training would be shorter. For instance, a Level 2 “operations level” employee would not need to be retrained on as many topics as a Level 3 “HAZMAT technician.”

Some employers still like to do 8-hour HAZWOPER training for emergency responders as a best management practice, but again, that time frame is not mandated by the regulations.

HAZWOPER Refreshers for Emergency Responders

Lion offers courses for different levels of emergency responders, from general awareness to training for those who aggressively respond to hazardous substance releases as technicians. Check out two popular refresher courses below. 

8 Hour HAZWOPER Refresher - Emergency Response Technician (Level III
4 Hour OSHA HAZWOPER Refresher - First Responder Operations (Level II) 

Browse all online HAZWOPER training courses and find resources to help you choose the right course at Lion.com/HAZWOPER

Tags: 29 CFR, 8 hour HAZWOPER, emergency response, HAZWOPER training, OSHA Hazwoper

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