Hazardous Waster Operations and Emergency Response training is covered under 29CFR1910.120 which applies to five specific
operations, unless the employer can demonstrate that the operation does not involve employee exposure or the reasonable
possibility for employee exposure to safety or health hazards:
- 1910.120(a)(1)(i) Clean-up operations required by a governmental body involving hazardous substances that are conducted at uncontrolled hazardous waste sites
- 1910.120(a)(1)(ii) Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976
- 1910.120(a)(1)(iii) Voluntary clean-up operations at sites recognized as uncontrolled hazardous waste sites;
- 1910.120(a)(1)(iv) Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by RCRA
- 1910.120(a)(1)(v) Emergency response operations for releases of hazardous substances without regard to the location of the hazard.
If your company is engaged in any of the above activities, you are required to provide the appropriate level of training for all workers at that site as detailed below.
40 Hour Training (1910.120(e)3(i))
40 hour HAZWOPER training is for employees who are required to have general access to a hazardous waste site where they may
be exposed to hazardous wastes above the regulatory limits. Examples include:
- Heavy equipment operators
- Decontamination operators
- General laborers
The training consists of 40 hours of training outside of the hazardous waste area, plus 3 days field experinece under supervision. OSHA recommends that this training include significant amounts of hands on, practical training, including dressing out in Leval A or B protective ensembles. For this reason, computer based or on-line trainings alone do not meet the OSHA requirement.(See 'Why Not Online?')
24 Hour Training
This training is for:
- (1910.120(e)3(ii)Employees who will be working on a site that is fully characterized
- (1910.120(3)3(iii)Employees who will be working in a limited capacity on the site
- 1910.120(p)7(i)Empoyees working at treatment, storage, and disposal facilities handling RCRA wastes.
There are differences between a RCRA TS & D operation and general operations; for example, employees operating under 1
and 2 must also complete one day of field experience under instruction, while employees operating under number 3 do not.
Not all 24 hour courses will work for all three types of work!
TSI will make sure that you get the level of training appropriate for the work you are doing. Again, on-line or computer based courses alone do not meet the intent of the OSHA regulation (See Why Not Online?)
8 Hour Supervisor Training
Supervisors of employees who work in a Hazardous Waste site must be trained to the same level as their employees, plus an
additional 8 hours of training. This training should focus on site specific hazards, requirements, policies, and procedures.
Given the site specific nature of this training requirement, TSI does not offer a canned HAZWOPER
Supervisor training. However, we would be happy to help you develop your own training, or to develop it for you.
40 Hour training and all three versions of the 24 hour training have an annual 8 hour refresher training requirement.
However, even if you've gone more than a year since your initial training, you may not have to redo the full thing.
According to OSHA, if you've passed the anniversary of your intial training, you can no longer work in a hazardous waste
site, but you can renew your qualification if you take the refresher in a reasonable amount of time. The industry standard
definition of reasonable is 2 years. If your HAZWOPER has expired, and you're less than 2 years from your anniversary, you
can still take the 8 hour refresher and get your qualification back.