Compliance with HAZWOPER training requirements and certification

Does OSHA certify HAZWOPER (CFR 1910.120) training? What are the training requirements for employees and site managers?

Answered by Scott Wallace, production manager and authorized OSHA trainer, Summit Training Source, Grand Rapids, MI.

A falsehood has developed in the marketplace that OSHA certifies or approves hazardous waste operations and emergency response training. First and foremost, it is important to clarify that OSHA does not certify or endorse HAZWOPER (or any) training. Students who complete HAZWOPER training will not receive an official completion card from OSHA or the Department of Labor.

Training can be considered certified by the instructor once all training criteria have been met. HAZWOPER training consists of both classroom and hands-on instruction. The classroom portion of training can be taken online or in a computer-based training format. Online courses should include multiple types of media and interactivity to ensure an engaging learning process. Also, students should receive a quiz at the end of each online topic or an overall quiz to ensure learning has taken place. Online or computer-based training must be supplemented by the opportunity to ask a qualified trainer any questions. Once the student completes the classroom portion of training, they must complete hands-on training and an assessment of performance of the hands-on work tasks. Hands-on or field experience must be conducted under the direct supervision of a trained experienced supervisor.

OSHA does not certify or currently have specific requirements to certify HAZWOPER instructors. Qualifications of the instructors may be shown by academic degrees, completed training courses and/or work experience.

HAZWOPER training is commonly broken down into segments established by the amount of training an employee or supervisor requires based on work functions. Before workers of any level enter a hazardous work area, site-specific information and training should be administered by a manager or supervisor.

General site workers engaged in hazardous substance removal or other activities that expose or potentially expose workers to hazardous substances and health hazards, and onsite management and supervisors directly responsible for these employees, must receive a minimum of 40 hours of instruction off-site and a minimum of three days of actual field experience.

Workers regularly on-site who work in areas that have been monitored and fully characterized with exposures under permissible exposure limits and published exposure limits must receive a minimum of 24 hours of instruction off-site and a minimum of one day of actual field experience.

All affected employees and managers must receive at least eight hours of refresher training annually. Whether refresher training must be completed with off-site instruction, hands-on instruction or a combination of both is not specified in the OSHA regulation.

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