After passage, four government agencies including OSHAH, USCG, NIOSH and the EPA collaborated on writing the rules and regulations to deal with safety and training issues for companies and workers dealing with hazardous substances or who might potentially be exposed to them. The results of their work came to be known as Hazardous Waste Operations and Emergency Response, or HAZWOPER.
The standards are extensive and complex, and its extremely important to know if your company or any of its employees need HAZWOPER training.
OSHA’s website provides the following guidelines for determining if your company or its employees fall within one of the five distinct groups that might encounter hazardous substances or toxic waste:
- Clean-up operations — required by a governmental body, whether federal, state, local, or other involving hazardous substances — that are conducted at uncontrolled hazardous waste sites;
- Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);
- Voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;
- Operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and
- Emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.
From that list, you should be able to figure out if your company or any employees need to take a HAZWOPER training course. But the next step is just as important, which is to figure out how much training is needed. This can get complicated, but in general, the OSHA website outlines the following groups that need either 40 hours of training and three days of field experience or 24 hours of training and 1 day of field experience:
- General site workers (such as equipment operators, general laborers and supervisory personnel) engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.
- Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor.
- Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor.
- Workers with 24 hours of training who become general site workers or who are required to wear respirators, shall have the additional 16 hours and two days of training necessary to total the training specified in paragraph 1.
- On-site management and supervisors directly responsible for, or who supervise employees engaged in, hazardous waste operations shall receive 40 hours initial training, and three days of supervised field experience (the training may be reduced to 24 hours and one day if the only area of their responsibility includes employees covered by paragraphs 2 and 3 and at least eight additional hours of specialized training at the time of job assignment on such topics as, but not limited to, the employer’s safety and health program and the associated employee training program, personal protective equipment program, spill containment program, and health hazard monitoring procedure and techniques.
Is your head spinning yet? Some of the above workers are also required to receive 8 hours of refresher training each year. If all of this looks like one big headache to you, do yourself a favor and find an experienced company that delivers a full suite of HAZWOPER training courses. That way you’ll know you’re getting the training you need.