HAZWOPER, OSHA's Hazardous Waste Operations and Emergency Response standard, is one of the most misunderstood training requirements in general industry and construction. Some employers send people to a 40-hour course they don't need. Others assume a chemical spill kit and a data sheet binder are enough, and find out otherwise during an inspection.
The standard is 29 CFR 1910.120 for general industry, mirrored for construction at 29 CFR 1926.65. How many hours a worker needs depends on two things: what kind of operation they work in, and what they do there.
Does HAZWOPER apply to you at all?
HAZWOPER covers five kinds of work:
- Cleanup operations required by a government body at uncontrolled hazardous waste sites
- Corrective actions at sites covered by RCRA (the Resource Conservation and Recovery Act)
- Voluntary cleanup operations at sites a government body has recognized as uncontrolled hazardous waste sites
- Operations at RCRA hazardous waste treatment, storage and disposal (TSD) facilities
- Emergency response to releases, or substantial threats of releases, of hazardous substances, wherever they happen
Most manufacturers and warehouses aren't cleanup sites or TSD facilities, so for them the question is really about the fifth item, emergency response. A small spill that the people in the immediate area can safely clean up is generally an incidental release, not an emergency response, and HAZWOPER training isn't triggered. If your plan is for employees to respond to releases beyond that, HAZWOPER applies.
If your chemical exposure is day-to-day handling and labeling rather than cleanup or emergency response, the standard you need is usually hazard communication, not HAZWOPER.
Cleanup sites: 40-hour, 24-hour and supervisor training
For workers at hazardous waste cleanup sites, 1910.120(e) sets the hours by job and exposure:
40 hours + 3 days of field experience General site workers, such as equipment operators, general laborers and supervisory staff, who remove hazardous substances or do other work that exposes them to hazardous substances. They need at least 40 hours of off-site instruction and at least three days of actual field experience under the direct supervision of a trained, experienced supervisor.
24 hours + 1 day of field experience Workers who are on site only occasionally for a specific, limited task, such as groundwater monitoring or land surveying, and who are unlikely to be exposed above permissible exposure limits. The same applies to workers who are regularly on site but only in areas that have been monitored and fully characterized, where exposures are under the limits, respirators aren't needed and no emergency is expected.
Moving from 24 to 40 A worker with the 24-hour course who becomes a general site worker, or who has to wear a respirator, needs an additional 16 hours of training and two more days of supervised field experience.
Supervisors: + 8 hours On-site managers and supervisors directly responsible for cleanup operations need the same initial training as the workers they supervise, plus at least 8 hours of specialized training in the site safety and health program, PPE, spill containment and health hazard monitoring.
Annual refresher: 8 hours Everyone in these categories needs at least 8 hours of refresher training every year.
Classroom hours don't replace the supervised field days. The field experience is a separate requirement, and it is where workers learn to use PPE and respirators under real conditions.
TSD facilities: 24 hours initial, 8 hours annually
Employees at RCRA treatment, storage and disposal facilities who are exposed to health hazards or safety hazards need 24 hours of initial training and 8 hours of refresher training every year, under 1910.120(p).
Emergency response: five levels of responder
For emergency response, 1910.120(q) trains people by their role in a response, not by a fixed number of hours:
- First responder awareness level. People likely to witness or discover a release, whose job is to recognize it and call it in. Training has to be sufficient for them to demonstrate competency. The standard sets no minimum hours.
- First responder operations level. People who respond defensively to protect nearby people, property and the environment, without trying to stop the release. At least 8 hours of training, or enough experience to demonstrate competency.
- Hazardous materials technician. People who approach the point of release to plug, patch or stop it. At least 24 hours of training equal to the operations level, plus technician competencies.
- Hazardous materials specialist. People who support technicians with specialized knowledge. At least 24 hours of training equal to the technician level, plus specialist competencies.
- On-scene incident commander. People who take control of the response beyond the awareness level. At least 24 hours of training equal to the operations level, plus incident command competencies.
Responders need annual refresher training to keep their competencies, or have to show those competencies at least once a year.
Getting it right
Start with an honest look at what your people actually do. Most facilities need a clear emergency response plan, awareness-level training for everyone, and operations or technician training only for the people who will actually respond. Cleanup contractors need a clear record of which workers are 40-hour, which are 24-hour, and when each person's refresher is due.
How BHG Safety Partners helps
We deliver HAZWOPER training matched to the roles and hazards at your site, and we help you work out who needs which level before anyone sits through training they don't need. If you aren't sure whether HAZWOPER applies to your operation at all, contact us and we'll work through it with you.