When designing a training program to satisfy the requirements listed in 29 CFR 1910.120 and 29 CFR 1926.65( commonly referred to as HAZWOPER) it is best to keep the focus on the big picture, such as what is the goal of the training. This should be based on the assigned or potential future tasks for the affected employees. Also, if the task or assignments are well thought out, several other training requirements can be incorporated into one or two programs. This will ensure consistent concepts and policies for the employees and substantially reduce the cost of redundant training.
The HAZWOPER training requirements can be broken down into three basic focus areas based upon anticipated job assignments or duties. The first area is referred to as the Hazardous Waste Site Worker training. This is found in paragraph (e) of the standard. Although it is referred to as Hazardous Waste Site Worker, hazardous substances also apply, so activities such as underground storage tanks with petroleum products can require training under this paragraph. For those removing the USTs excavation training may be needed, while those entering the tanks to clean them will need confined space training. Both of these topics can be addressed in a well designed HAZWOPER course.
The initial training should be 40 hours in length. Although there is a provision for a 24 hour course in the regulation for those people with less risk of contaminant exposure, the term “40 hour “ has become a standard in most contract requirements. And if the person has previously taken a 24 hour course, there is no practical way to make up the time to meet the 40 hour requirement. Some training providers may offer this option, but it is poor training practice. The 24 hour course has the same subject areas as the 40 hour, just less detail, so it is impractical to try and add 16 hours later.
In addition to the 40 hour initial training, the employer must document 3 days of on the job experience before the employee meets the requirements completely. The 3 days of experience should be under the supervision of some one who has completed the 8 hour hazardous waste site supervisor training.
The supervisor training is taken once by those whom supervise or manage the on site activities of others. This is in addition to the 40 hour training.
The second part of the HAZWOPER training relates to workers at hazardous waste treatment, storage and disposal facilities. 24 hours of training are required initially and 8 hours annually.
The third focus area is for emergency response. This area is explained in great detail in a separate information sheet.
Other related training requirements that could be integrated into a comprehensive training session include; hazard communication, DOT hazardous materials safety, confined space entry, bloodborne pathogens, and trenching and excavation.
Please feel free to contact us at 414-427-9844 to discuss customized training programs that are fit to your needs.
Training Requirements for Emergency Response under 29 CFR 1910.120(q)
A. Initial Training: Training shall be based on the duties and functions to be performed by each responder of an emergency response organization.
B. Employees who participate or are expected to participate in emergency response shall be given training as follows:
- First responder awareness level:(2-4 hours) 29 CFR 1910.120(q)(6)(i)- First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:
- an understanding of what hazardous substances are, and the risks associated with them in an incident;
- an understanding of the potential outcomes associated with an emergency created when hazardous substances are present;
- the ability to recognize the presence of hazardous substances in an emergency;
- the ability to identify the hazardous substances, if possible;
- an understanding of the role of the first responder awareness individual in the employer’s emergency response plan, including site security and control and DOT’s Emergency Response Guidebook; and
- the ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
- First responder operations level:(8-24 hours) 29 CFR 1910.120(q)(6)(ii) First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level:
- knowledge of basic hazard and risk assessment techniques;
- knowledge of how to select and use proper PPE provided to the first responder operational level;
- an understanding of basic hazardous materials terms;
- knowledge of how to perform basic control, containment, and/or confinement operations within the capabilities of the resources and PPE available with their unit;
- knowledge of how to implement basic decontamination procedures; and
- an understanding of the relevant standard operating procedures and termination procedures.
- Hazardous materials technician:( 8-24 hours) 29 CFR 1910.120(q)(6)(iii) Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and in addition:
- know how to implement the employer’s emergency response plan;
- know the classification, identification, and verification of known and unknown materials by using field survey instruments and equipment;
- be able to function within an assigned role in the Incident Command System;
- know how to select and use proper specialized chemical PPE provided to the hazardous materials technician;
- understand hazard and risk assessment techniques;
- be able to perform advanced control, containment, and/or confinement operations within the capabilities of the resources and PPE available with the unit;
- understand and implement decontamination procedures;
- understand termination procedures; and
- understand basic chemical and toxicological terminology and behavior.
- Hazardous materials specialist:(8-24 hours) 29 CFR 1910.120(6)(q)(iv) Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition:
- know how to implement the local emergency response plan;
- understand classification, identification, and verification of known and unknown materials by using advanced survey instrument and equipment;
- know of the state emergency response plan;
- be able to select and use proper specialized chemical PPE provided to the hazardous materials specialist;
- understand in-depth hazard and risk techniques;
- be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and PPE available;
- be able to determine and implement decontamination procedures;
- have the ability to develop a site safety and control plan; and
- understand chemical, radiological, and toxicological terminology and behavior.
- On-scene incident commander:(8-16 hours) 29CFR1910.120(q)(6)(v) On-scene incident commanders shall receive at least 24 hours of training equal to the first responder operations level and in addition:
- know and be able to implement the employer’s incident command system;
- know how to implement the employer’s emergency response plan;
- know and understand the hazards and risks associated with employees working in chemical protective clothing;
- know how to implement the local emergency response plan;
- know of the state emergency response plan and of the Federal Regional Response Team; and
- know and understand the important of decontamination procedures.
NOTE: Persons trained to the awareness level are able to recognize an emergency and activate the emergency response plan.
NOTE: Persons trained to the operations level may respond to emergencies in a defensive manner only, when there is little or no potential for exposure to hazards.