Who Needs HAZWOPER Training?Found at 29 CFR 1910.120, the HAZWOPER Standard is one of the most complicated health and safety Standards 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.).
The HAZWOPER Standard, found in 29 CFR 1910.120, is intended to protect employees who 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).
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).
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
- 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
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
“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]
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.
“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
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
“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
“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.
Technicians approach the point of a release to plug, patch, or otherwise stop the release.
Essentially, they run the show during an emergency response incident and supervise the employees doing the response.
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.”
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?
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