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Before an employee may engage in hazardous waste operations or perform emergency response, the employee must be properly trained. The trouble is OSHA’s Hazardous Waste Operations and Emergency Response Standards, 29 CFR 1910.120 for general industry and 29 CFR 1926.65 for construction, seem to be the most complex regulations to comply with, especially when it comes to determining training requirements. In this Idea of the Week, we walk you through the steps, so you won’t have to guess.
Because the paragraphs in 1910.120 and 1926.65 are almost identical, we will refer to 1910.120 from here on. However, you may use the same steps for 1926.65. To determine which HAZWOPER training requirements apply to you:
1) See 1910.120(a)(1) to determine your company operations. You may fall under more than one of them, and it may be necessary to refer to definitions in 1910.120(a)(3) to make determinations. Any operation that can demonstrate that it does NOT involve or have the reasonable possibility for employee exposure to safety/health hazards is exempt from 1910.120, according to 1910.120(a)(1).
2) See 1910.120(a)(2) to determine which sections of 1910.120 you need to meet.
| In step 1, if you determine that your facility falls under 1910.120: | Then you will follow 1910.120: | Including the training requirements of 1910.120: |
|---|---|---|
| (a)(1)(i) | (b) to (o) and Appendices | (e) |
| (a)(1)(ii) | (b) to (o) and Appendices | (e) |
| (a)(1)(iii) | (b) to (o) and Appendices | (e) |
| (a)(1)(iv) | (p) and Appendices Note: See exceptions listed under 1910.120(a)(2)(iii). | (p)(7) and (p)(8) Note: See exceptions listed under 1910.120(a)(2)(iii). |
| (a)(1)(v) | (q) and Appendices Note: See the exception listed under 1910.120(q)(1). | (q)(4) to (q)(8) and (q)(11) Note: See the exception listed under 1910.120(q)(1). |
3) Look at the training requirements within the sections you are required to meet. You will see that there are many levels of training. Select specific training based on the roles and duties you assign to each employee.
| Operation: | Employee type: | Training under 1910.120: |
|---|---|---|
| In step 1, you determined that your facility falls under 1910.120(a)(1)(i), (ii), and/or (iii) | General site employees | (e)(3)(i) and (e)(8) |
| Routine site employees (minimal exposure) | (e)(3)(iii) and (e)(8) | |
| Non-routine site employees | (e)(3)(ii) and (e)(8) | |
| Supervisors/Managers of general site employees | (e)(4) and (e)(8) | |
| Supervisors/Managers of routine site employees (minimal exposure) | (e)(4) and (e)(8) | |
| Supervisors/Managers of non-routine site employees | (e)(4) and (e)(8) | |
| Emergency response personnel | (e)(7) | |
| Trainers | (e)(5) | |
| In step 1, you determined that your facility falls under 1910.120(a)(1)(iv) | General site employees | (p)(7) and (p)(7)(ii) |
| Emergency response personnel | (p)(8)(iii) | |
| Trainers | (p)(7)(iii) | |
| In step 1, you determined that your facility falls under 1910.120(a)(1)(v) | First responder awareness level | (q)(6)(i) and (q)(8) |
| First responder operations level | (q)(6)(ii) and (q)(8) | |
| Hazardous materials technician | (q)(6)(iii) and (q)(8) | |
| Hazardous materials specialist | (q)(6)(iv) and (q)(8) | |
| On-the-scene incident commander | (q)(6)(v) and (q)(8) | |
| Trainer | (q)(7) | |
| Clean-up crew member (but not emergency responder) | (q)(11) | |
| Skilled support personnel | (q)(4) | |
| Specialist employees | (q)(5) | |
| Any operation above that does not permit any of its employees to assist in handling an emergency release | All employees | In addition to applicable training above, (l)(1)(ii), (p)(8)(i), and/or (q)(1), AND 1910.38(e) or 1926.35(e) for construction |
It’s important that you provide adequate training for your employees. Ensuring they get that training takes proper determination of training requirements. As you can see, HAZWOPER training determinations can be made in three steps: determine your operations, determine the sections that apply, and determine and select training requirements.