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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:
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.