Suggested General Criteria
Definitions:
Competent means possessing the skills, knowledge, experience, and judgment to perform assigned tasks or activities satisfactorily as determined by the employer.
Demonstration means the showing by actual use of equipment or procedures.
Hands-on training means training in a simulated work environment that permits each student to have experience performing tasks, making decisions, or using equipment appropriate to the job assignment for which the training is being conducted.
Initial training means training required prior to beginning work.
Lecture means an interactive discourse with a class lead by an instructor.
Proficient means meeting a stated level of achievement.
Site-specific means individual training directed to the operations of a specific job site.
Training hours means the number of hours devoted to lecture, learning activities, small group work sessions, demonstration, evaluations, or hands-on experience.
Suggested Program Quality Control Criteria
Factors listed here are suggested criteria for determining the quality and appropriateness of employee health and safety training for hazardous waste operations and emergency response.
A. Training Plan.
Adequacy and appropriateness of the training program’s curriculum development, instructor training, distribution of course materials, and direct student training should be considered, including:
- The duration of training, course content, and course schedules/agendas;
- The different training requirements of the various target populations, as specified in the appropriate generic training curriculum;
- The process for the development of curriculum, which includes appropriate technical input, outside review, evaluation, program pretesting.
- The adequate and appropriate inclusion of hands-on, demonstration, and instruction methods;
- Adequate monitoring of student safety, progress, and performance during the training.
B. Program management, Training Director, staff, and consultants.
Adequacy and appropriateness of staff performance and delivering an effective training program should be considered, including:
- Demonstration of the training director’s leadership in assuring quality of health and safety training.
- Demonstration of the competency of the staff to meet the demands of delivering high quality hazardous waste employee health and safety training.
- Organization charts establishing clear lines of authority.
- Clearly defined staff duties including the relationship of the training staff to the overall program.
- Evidence that the training organizational structure suits the needs of the training program.
- Appropriateness and adequacy of the training methods used by the instructors.
- Sufficiency of the time committed by the training director and staff to the training program.
- Adequacy of the ratio of training staff to students.
- Availability and commitment of the training program of adequate human and equipment resources in the areas of:
- Health effects,
- Safety,
- Personal protective equipment (PPE),
- Operational procedures,
- Employee protection practices/procedures.
- Appropriateness of management controls.
- Adequacy of the organization and appropriate resources assigned to assure appropriate training.
- In the case of multiple-site training programs, adequacy of satellite centers management.
C. Training facilities and resources.
Adequacy and appropriateness of the facilities and resources for supporting the training program should be considered, including:
- Space and equipment to conduct the training.
- Facilities for representative hands-on training.
- In the case of multiple-site programs, equipment and facilities at the satellite centers.
- Adequacy and appropriateness of the quality control and evaluations program to account for instructor performance.
- Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course evaluation, feedback, updating, and corrective action.
- Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation program.
- Adequacy and appropriateness of the role of student evaluations to provide feedback for training program improvement.
D. Quality control and evaluation.
Adequacy and appropriateness of quality control and evaluation plans for training programs should be considered, including:
- A balanced advisory committee and/or competent outside reviewers to give overall policy guidance;
- Clear and adequate definition of the composition and active programmatic role of the advisory committee or outside reviewers.
- Adequacy of the minutes or reports of the advisory committee or outside reviewers’ meetings or written communication.
- Adequacy and appropriateness of the quality control and evaluations program to account for instructor performance.
- Adequacy and appropriateness of the quality control and evaluation program to ensure appropriate course evaluation, feedback, updating, and corrective action.
- Adequacy and appropriateness of disciplines and expertise being used within the quality control and evaluation program.
- Adequacy and appropriateness of the role of student evaluations to provide feedback for training program improvement.
E. Students.
Adequacy and appropriateness of the program for accepting students should be considered, including:
- Assurance that the student already possess the necessary skills for their job, including necessary documentation.
- Appropriateness of methods the program uses to ensure that recruits are capable of satisfactorily completing training.
- Review and compliance with any medical clearance policy.
F. Institutional Environment and Administrative Support.
The adequacy and appropriateness of the institutional environment and administrative support system for the training program should be considered, including:
- Adequacy of the institutional commitment to the employee training program.
- Adequacy and appropriateness of the administrative structure and administrative support.
G. Summary of Evaluation Questions
Key questions for evaluating the quality and appropriateness of an overall training program should include the following:
- Are the program objectives clearly stated?
- Is the program accomplishing its objectives?
- Are appropriate facilities and staff available?
- Is there an appropriate mix of classroom, demonstration, and hands-on training?
- Is the program providing quality employee health and safety training that fully meets the intent of regulatory requirements?
- What are the program’s main strengths?
- What are the program’s main weaknesses?
- What is recommended to improve the program?
- Are instructors instructing according to their training outlines?
- Is the evaluation tool current and appropriate for the program content?
- Is the course material current and relevant to the target group?
Suggested Training Curriculum Guidelines
The following training curriculum guidelines are for those operations specifically identified in 29 CFR 1926.65 as requiring training. Issues such as qualifications of instructors, training certification, and similar criteria appropriate to all categories of operations addressed in 1926.65 have been covered in the preceding section and are not re-addressed in each of the generic guidelines. Basic core requirements for training programs that are addressed include:
- General Hazardous Waste Operations
- RCRA operations—Treatment, storage, and disposal facilities.
- Emergency Response.
A. General Hazardous Waste Operations and Site-specific Training
- Off-site training.
Minimum training course content for hazardous waste operations, required by 29 CFR 1926.65(e), should include the following topics or procedures: - Regulatory knowledge.
- A review of 29 CFR 1926.65 and the core elements of an occupational safety and health program.
- The content of a medical surveillance program as outlined in 29 CFR 1926.65(f).
- The content of an effective site safety and health plan consistent with the requirements of 29 CFR 1926.65(b)(4)(ii).
- Emergency response plan and procedures as outlined in 29 CFR 1910.38 and 29 CFR 1926.65(l).
- Adequate illumination.
- Sanitation recommendation and equipment.
- Review and explanation of OSHA’s hazard-communication standard (29 CFR 1910.1200) and lock-out-tag-out standard (29 CFR 1910.147).
- Review of other applicable standards including but not limited to those in the construction standards (29 CFR Part 1926).
- Rights and responsibilities of employers and employees under applicable OSHA and EPA laws.
- Technical knowledge.
- Type of potential exposures to chemical, biological, and radiological hazards; types of human responses to these hazards and recognition of those responses; principles of toxicology and information about acute and chronic hazards; health and safety considerations of new technology.
- Fundamentals of chemical hazards including but not limited to vapor pressure, boiling points, flash points, ph, other physical and chemical properties.
- Fire and explosion hazards of chemicals.
- General safety hazards such as but not limited to electrical hazards, powered equipment hazards, motor vehicle hazards, walking-working surface hazards, excavation hazards, and hazards associated with working in hot and cold temperature extremes.
- Review and knowledge of confined space entry procedures in 29 CFR 1910.146.
- Work practices to minimize employee risk from site hazards.
- Safe use of engineering controls, equipment, and any new relevant safety technology or safety procedures.
- Review and demonstration of competency with air sampling and monitoring equipment that may be used in a site monitoring program.
- Container sampling procedures and safeguarding; general drum and container handling procedures including special requirement for laboratory waste packs, shock-sensitive wastes, and radioactive wastes.
- The elements of a spill control program.
- Proper use and limitations of material handling equipment.
- Procedures for safe and healthful preparation of containers for shipping and transport.
- Methods of communication including those used while wearing respiratory protection.
- Technical skills.
- Selection, use maintenance, and limitations of personal protective equipment including the components and procedures for carrying out a respirator program to comply with 29 CFR 1910.134.
- Instruction in decontamination programs including personnel, equipment, and hardware; hands-on training including level A, B, and C ensembles and appropriate decontamination lines; field activities including the donning and doffing of protective equipment to a level commensurate with the employee’s anticipated job function and responsibility and to the degree required by potential hazards.
- Sources for additional hazard information; exercises using relevant manuals and hazard coding systems.
- Additional suggested items.
- A laminated, dated card or certificate with photo, denoting limitations and level of protection for which the employee is trained should be issued to those students successfully completing a course.
- Attendance should be required at all training modules, with successful completion of exercises and a final written or oral examination with at least 50 questions.
- A minimum of one-third of the program should be devoted to hands-on exercises.
- A curriculum should be established for the 8-hour refresher training required by 29 CFR 1926.65(e)(8), with delivery of such courses directed toward those areas of previous training that need improvement or reemphasis.
- A curriculum should be established for the required 8-hour training for supervisors. Demonstrated competency in the skills and knowledge provided in a 40-hour course should be a prerequisite for supervisor training.
- Refresher training.
The 8-hour annual refresher training required in 29 CFR 1926.65(e)(8) should be conducted by qualified training providers. Refresher training should include at a minimum the following topics and procedures: - Review of and retraining on relevant topics covered in the 40-hour program, as appropriate, using reports by the students on their work experiences
- Update on developments with respect to material covered in the 40-hour course.
- Review of changes to pertinent provisions of EPA or OSHA standards or laws.
- Introduction of additional subject areas as appropriate.
- Hands-on review of new or altered PPE or decontamination equipment or procedures. Review of new developments in personal protective equipment.
- Review of newly developed air and contaminant monitoring equipment.
- On-site training.
- The employer should provide employees engaged in hazardous waste site activities with information and training prior to initial assignment into their work area, as follows:
- The requirements of the hazard communication program including the location and availability of the written program, required lists of hazardous chemicals, and safety data sheets.
- Activities and locations in their work area where hazardous substance may be present.
- Methods and observations that may be used to detect the present or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearances, or other evidence (sight, sound or smell) of hazardous chemicals being released, and applicable alarms from monitoring devices that record chemical releases
- The physical and health hazards of substances known or potentially present in the work area.
- The measures employees can take to help protect themselves from work-site hazards, including specific procedures the employer has implemented.
- An explanation of the labeling system and safety data sheets and how employees can obtain and use appropriate hazard information.
- The elements of the confined space program including special PPE, permits, monitoring requirements, communication procedures, emergency response, and applicable lock-out procedures.
- The employer should provide hazardous waste employees information and training and should provide a review and access to the site safety and plan as follows:
- Names of personnel and alternate responsible for site safety and health.
- Safety and health hazards present on the site.
- Selection, use, maintenance, and limitations of personal protective equipment specific to the site.
- Work practices by which the employee can minimize risks from hazards.
- Safe use of engineering controls and equipment available on site.
- Safe decontamination procedures established to minimize employee contact with hazardous substances, including:
- Employee decontamination,
- Clothing decontamination, and
- Equipment decontamination.
- Elements of the site emergency response plan, including:
- Pre-emergency planning.
- Personnel roles and lines of authority and communication.
- Emergency recognition and prevention.
- Safe distances and places of refuge.
- Site security and control.
- Evacuation routes and procedures.
- Decontamination procedures not covered by the site safety and health plan.
- Emergency medical treatment and first aid.
- Emergency equipment and procedures for handling emergency incidents.
- The employer should provide hazardous waste employees information and training on personal protective equipment used at the site, such as the following:
- PPE to be used based upon known or anticipated site hazards.
- PPE limitations of materials and construction; limitations during temperature extremes, heat stress, and other appropriate medical considerations; use and limitations of respirator equipment as well as documentation procedures as outlined in 29 CFR 1910.134.
- PPE inspection procedures prior to, during, and after use.
- PPE donning and doffing procedures.
- PPE decontamination and disposal procedures.
- PPE maintenance and storage.
- Task duration as related to PPE limitations.
- The employer should instruct the employee about the site medical surveillance program relative to the particular site, including:
- Specific medical surveillance programs that have been adapted for the site.
- Specific signs and symptoms related to exposure to hazardous materials on the site.
- The frequency and extent of periodic medical examinations that will be used on the site.
- Maintenance and availability of records.
- Personnel to be contacted and procedures to be followed when signs and symptoms of exposures are recognized.
- The employees will review and discuss the site safety plan as part of the training program. The location of the site safety plan and all written programs should be discussed with employees including a discussion of the mechanisms for access, review, and references described.
B. RCRA Operations Training for Treatment, Storage and Disposal Facilities.
- As a minimum, the training course required in 29 CFR 1926.65 (p) should include the following topics:
- Review of the applicable paragraphs of 29 CFR 1926.65 and the elements of the employer’s occupational safety and health plan.
- Review of relevant hazards such as, but not limited to, chemical, biological, and radiological exposures; fire and explosion hazards; thermal extremes; and physical hazards.
- General safety hazards including those associated with electrical hazards, powered equipment hazards, lock-out-tag-out procedures, motor vehicle hazards and walking-working surface hazards.
- Confined-space hazards and procedures.
- Work practices to minimize employee risk from workplace hazards.
- Emergency response plan and procedures including first aid meeting the requirements of paragraph (p)(8).
- A review of procedures to minimize exposure to hazardous waste and various type of waste streams, including the materials handling program and spill containment program.
- A review of hazard communication programs meeting the requirements of 29 CFR 1910.1200.
- A review of medical surveillance programs meeting the requirements of 29 CFR 1926.65(p)(3) including the recognition of signs and symptoms of overexposure to hazardous substance including known synergistic interactions.
- A review of decontamination programs and procedures meeting the requirements of 29 CFR 1926.65(p)(4).
- A review of an employer’s requirements to implement a training program and its elements.
- A review of the criteria and programs for proper selection and use of personal protective equipment, including respirators.
- A review of the applicable appendices to 29 CFR 1926.65.
- Principles of toxicology and biological monitoring as they pertain to occupational health.
- Rights and responsibilities of employees and employers under applicable OSHA and EPA laws.
- Hands-on exercises and demonstrations of competency with equipment to illustrate the basic equipment principles that may be used during the performance of work duties, including the donning and doffing of PPE.
- Sources of reference, efficient use of relevant manuals, and knowledge of hazard coding systems to include information contained in hazardous waste manifests.
- At least 8 hours of hands-on training.
- Training in the job skills required for an employee’s job function and responsibility before they are permitted to participate in or supervise field activities.
- The individual employer should provide hazardous waste employees with information and training prior to an employee’s initial assignment into a work area. The training and information should cover the following topics:
- The Emergency response plan and procedures including first aid.
- A review of the employer’s hazardous waste handling procedures including the materials handling program and elements of the spill containment program, location of spill response kits or equipment, and the names of those trained to respond to releases.
- The hazardous communication program meeting the requirements of 29 CFR 1910.1200.
- A review of the employer’s medical surveillance program including the recognition of signs and symptoms of exposure to relevant hazardous substance including known synergistic interactions.
- A review of the employer’s decontamination program and procedures.
- A review of the employer’s training program and the parties responsible for that program.
- A review of the employer’s personal protective equipment program including the proper selection and use of PPE based upon specific site hazards
- All relevant site-specific procedures addressing potential safety and health hazards. This may include, as appropriate, biological and radiological exposures, fire and explosion hazards, thermal hazards, and physical hazards such as electrical hazards, powered equipment hazards, lock-out-tag-out hazards, motor vehicle hazards, and walking-working surface hazards.
- Safe use engineering controls and equipment on site.
- Names of personnel and alternates responsible for safety and health.
C. Emergency response training.
Federal OSHA standards in 29 CFR 1926.65(q) are directed toward private sector emergency responders. Therefore, the guidelines provided in this portion of the appendix are directed toward that employee population. However, they also impact indirectly through State OSHA or USEPA regulations some public sector emergency responders. Therefore, the guidelines provided in this portion of the appendix may be applied to both employee populations.
States with OSHA state plans must cover their employees with regulations at least as effective as the Federal OSHA standards. Public employees in states without approved state OSHA programs covering hazardous waste operations and emergency response are covered by the U.S. EPA under 40 CFR 311, a regulation virtually identical to §1926.65.
Since this is a non-mandatory appendix and therefore not an enforceable standard, OSHA recommends that those employers, employees or volunteers in public sector emergency response organizations outside Federal OSHA jurisdiction consider the following criteria in developing their own training programs. A unified approach to training at the community level between emergency response organizations covered by Federal OSHA and those not covered directly by Federal OSHA can help ensure an effective community response to the release or potential release of hazardous substances in the community.
- General considerations.
Emergency response organizations are required to consider the topics listed in §1926.65(q)(6). Emergency response organizations may use some or all of the following topics to supplement those mandatory topics when developing their response training programs. Many of the topics would require an interaction between the response provider and the individuals responsible for the site where the response would be expected. - Hazard recognition, including:
- Nature of hazardous substances present,
- Practical applications of hazard recognition, including presentations on biology, chemistry, and physics.
- Principles of toxicology, biological monitoring, and risk assessment.
- Safe work practices and general site safety.
- Engineering controls and hazardous waste operations.
- Site safety plans and standard operating procedures.
- Decontamination procedures and practices.
- Emergency procedures, first aid, and self-rescue.
- Safe use of field equipment.
- Storage, handling, use and transportation of hazardous substances.
- Use, care, and limitations of personal protective equipment.
- Safe sampling techniques.
- Rights and responsibilities of employees under OSHA and other related laws concerning right-to-know, safety and health, compensations and liability.
- Medical monitoring requirements.
- Community relations.
- Suggested criteria for specific courses.
- First responder awareness level.
- Review of and demonstration of competency in performing the applicable skills of 29 CFR 1926.65(q).
- Hands-on experience with the U.S. Department of Transportation’s Emergency Response Guidebook (ERG) and familiarization with OSHA standard 29 CFR 1926.60.
- Review of the principles and practices for analyzing an incident to determine both the hazardous substances present and the basic hazard and response information for each hazardous substance present.
- Review of procedures for implementing actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’s ERG including emergency notification procedures and follow-up communications.
- Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
- Awareness and knowledge of the competencies for the First Responder at the Awareness Level covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.
- First responder operations level.
- Review of and demonstration of competency in performing the applicable skills of 29 CFR 1926.65(q).
- Hands-on experience with the U.S. Department of Transportation’s Emergency Response Guidebook (ERG), manufacturer safety data sheets, CHEM-TREC/CANUTEC, shipper or manufacturer contacts and other relevant sources of information addressing hazardous substance releases. Familiarization with OSHA standard 29 CFR 1926.60.
- Review of the principles and practices for analyzing an incident to determine the hazardous substances present, the likely behavior of the hazardous substance and its container, the types of hazardous substance transportation containers and vehicles, the types and selection of the appropriate defensive strategy for containing the release.
- Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’s ERG including extended emergency notification procedures and follow-up communications.
- Review of the principles and practice for proper selection and use of personal protective equipment.
- Review of the principles and practice of personnel and equipment decontamination.
- Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
- Awareness and knowledge of the competencies for the First Responder at the Operations Level covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.
- Hazardous materials technician.
- Review of and demonstration of competency in performing the applicable skills of 29 CFR 1926.65(q).
- Hands-on experience with written and electronic information relative to response decision making including but not limited to the U.S. Department of Transportation’s Emergency Response Guidebook (ERG), manufacturer safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, computer data bases and response models, and other relevant sources of information addressing hazardous substance releases. Familiarization with 29 CFR 1926.60.
- Review of the principles and practices for analyzing an incident to determine the hazardous substances present, their physical and chemical properties, the likely behavior of the hazardous substance and its container, the types of hazardous substance transportation containers and vehicles involved in the release, the appropriate strategy for approaching release sites and containing the release.
- Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization’s standard operating procedures, and the current edition of DOT’s ERG including extended emergency notification procedures and follow-up communications.
- Review of the principles and practice for proper selection and use of personal protective equipment.
- Review of the principles and practices of establishing exposure zones, proper decontamination and medical surveillance stations and procedures.
- Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
- Awareness and knowledge of the competencies for the Hazardous Materials Technician covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.
- Hazardous materials specialist.
- Review of and demonstration of competency in performing the applicable skills of 29 CFR 1926.65(q).
- Hands-on experience with retrieval and use of written and electronic information relative to response decision making including but not limited to the U.S. Department of Transportation’s Emergency Response Guidebook (ERG), manufacturer safety data sheets, CHEMTREC/CANUTEC, shipper or manufacturer contacts, computer data bases and response models, and other relevant sources of information addressing hazardous substance releases. Familiarization with 29 CFR 1926.60.
- Review of the principles and practices for analyzing an incident to determine the hazardous substances present, their physical and chemical properties, and the likely behavior of the hazardous substance and its container, vessel, or vehicle.
- Review of the principles and practices for identification of the types of hazardous substance transportation containers, vessels and vehicles involved in the release; selecting and using the various types of equipment available for plugging or patching transportation containers, vessels or vehicles; organizing and directing the use of multiple teams of hazardous material technicians and selecting the appropriate strategy for approaching release sites and containing or stopping the release.
- Review of procedures for implementing continuing response actions consistent with the local emergency response plan, the organization’s standard operating procedures, including knowledge of the available public and private response resources, establishment of an incident command post, direction of hazardous material technician teams, and extended emergency notification procedures and follow-up communications.
- Review of the principles and practice for proper selection and use of personal protective equipment.
- Review of the principles and practices of establishing exposure zones and proper decontamination, monitoring and medical surveillance stations and procedures.
- Review of the expected hazards including fire and explosions hazards, confined space hazards, electrical hazards, powered equipment hazards, motor vehicle hazards, and walking-working surface hazards.
- Awareness and knowledge of the competencies for the Off-site Specialist Employee covered in the National Fire Protection Association’s Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents.
- Incident commander.
The incident commander is the individual who, at any one time, is responsible for and in control of the response effort. This individual is the person responsible for the direction and coordination of the response effort. An incident commander’s position should be occupied by the most senior, appropriately trained individual present at the response site. Yet, as necessary and appropriate by the level of response provided, the position may be occupied by many individuals during a particular response as the need for greater authority, responsibility, or training increases. It is possible for the first responder at the awareness level to assume the duties of incident commander until a more senior and appropriately trained individual arrives at the response site.
Therefore, any emergency responder expected to perform as an incident commander should be trained to fulfill the obligations of the position at the level of response they will be providing including the following: - Ability to analyze a hazardous substance incident to determine the magnitude of the response problem.
- Ability to plan and implement an appropriate response plan within the capabilities of available personnel and equipment.
- Ability to implement a response to favorably change the outcome of the incident in a manner consistent with the local emergency response plan and the organization’s standard operating procedures.
- Ability to evaluate the progress of the emergency response to ensure that the response objectives are being met safely, effectively, and efficiently.
- Ability to adjust the response plan to the conditions of the response and to notify higher levels of response when required by the changes to the response plan.
[78 FR 9315, Feb. 8, 2013]