Is an outside trainer obligated to provide employer-specific information during refresher training for hazardous waste site workers?

According to an OSHA Letter of Interpretation, the employer (not the outside trainer) has the ultimate responsibility to ensure that employees’ HAZWOPER refresher training meets the requirements, including the employer-specific information required by paragraph 1910.120(e)(8).

Employers have various options for meeting these responsibilities:

• The employer can contract with an outside commercial trainer to design a course specifically for employees and hazards at a particular site.
• The employer can supplement outside training with site-specific training.
• The employer can provide refresher training during on-site health and safety briefings throughout the year. With this option, the accumulated hours may count toward the 8-hour HAZWOPER refresher training requirement.

As part of refresher training, critiques of incidents can be discussed during the site-specific training or the on-site health and safety briefings mentioned above. Medical surveillance requirements must include company-specific/site-specific information. Employees must be instructed on how to recognize symptoms and signs of overexposure to hazards on the job and must be aware of specific parts of the site safety and health plan.

For guidance on refresher training topics, employers can consult paragraph A.2. under the heading “Suggested Training Curriculum Guidelines” of the standard’s non-mandatory Appendix E.

OSHA’s ultimate concern is that workers are competent to perform their assigned duties. It is beneficial for employers to assess the training needs of workers on an ongoing basis.