What are the training or certification requirements for HAZWOPER trainers?

OSHA does not require trainers to be “certified” under the Hazardous Waste Operations and Emergency Response (HAZWOPER) standards at 29 CFR 1910.120 and 1926.65. Rather, the standards go over trainer “qualifications” in subparagraphs (e)(5), (p)(7)(iii), and (q)(7). While the three subparagraphs are not worded identically, all three call for trainers to either have:

• Satisfactorily completed a training course for teaching the subjects they are expected to teach, OR
• The academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter they are to teach.

Under (e)(5), the trainer must also “demonstrate competent instructional skills and knowledge of the subject matter” if the first trainer qualification method (about a training course for teaching) is selected. Under (q)(7), "training" may qualify in lieu of academic credentials. Subparagraph (q)(7) also offers an example of where to find a training course for teaching — the U.S. National Fire Academy — but OSHA directive CPL 02-02-073 indicates, “An in-house training program, among other options, may be developed.”

The subjects that trainers must be able to convey to trainees are summarized in paragraphs (e), (p), and (q), depending on the operation. In addition, non-mandatory Appendix E to the standards suggests training curriculum guidelines. While not specifically stated in the standards, CPL 02-02-073 adds, “Trainers should maintain professional competency by participating in professional development programs or successfully completing an annual refresher course.”