HAZWOPER Training FAQs
When Was HAZWOPER Created?
The U.S. Occupational Safety and Health Administration (OSHA) implemented the Hazardous Waste Operations and Emergency Response (HAZWOPER) regulations in consultation with the U.S. Environmental Protection Agency (EPA), the U.S. Coast Guard (USCG) and the National Institute for Occupational Safety and Health (NIOSH). The four Federal agencies worked together as directed by Congress to develop and implement a HAZWOPER regulation.
The culmination of this collaboration was of course the HAZWOPER regulation but also a guide to HAZWOPER training. Their Guidance Manual for Hazardous Waste Site Activities is a considered a model for developing HAZWOPER training. The manual is a treasure trove of elements to be included in training and implementing a successful HAZWOPER program. The manual is considered by many in the industry to be the "regulatory backbone" of HAZWOPER. This is the genesis of the HAZWOPER regulation and program. Mr. William (Bill) Bunner, an OSHA official, was very instrumental in drafting the first HAZWOPER regulation. He has also conducted a peer review of our HAZWOPER training courses
The HAZWOPER regulation first appeared as an interim final rule in the Federal Register on December 19, 1986 (51 FR 45654). On August 10, 1987, OSHA issued a proposed rule in the Federal Register (52 FR 29620) that included provisions for hazwoper training. OSHA issued a permanent final rule on HAZWOPER in the Federal Register on March 6, 1989 (54 FR 9294) and went into effect on March 6, 1990. These regulations were then codified in Title 29 Code of Federal Regulations Part 1910 and in the Construction regulations Part 1926. The 3 areas where HAZWOPER impacts both private and public sectors are Emergency Response, Contaminated Sites, and RCRA Hazardous Waste Facilities.
The successful implementation of a HAZWOPER Program involves answering 4 key questions.
1. When is HAZWOPER Required?
2. What is HAZWOPER Training?
3. How To Get HAZWOPER Training?
4. When Does HAZWOPER Certification Expire?
When Is HAZWOPER Required?
What is HAZWOPER Training?
There are 3 levels of HAZWOPER training or certification. They are General Site Remediation, Emergency Response Operations, and RCRA TSD Operations.
General Site Remediation - 29 CFR 1910.120 (e)
Training for a contaminated site falls into 40 Hour, 24 Hour, 8 hour Supervisor and 8 hour annual refresher for each of these.
40 Hour HAZWOPER General Site Worker Initial
Individuals must be able to select, use, and maintain personal protective equipment to minimize exposure to hazards. You must become familiar with the operation and use of monitoring and sampling equipment used to conduct a thorough site characterization. You should also prepare Health and Safety Plans and conduct a mock site investigation. The course is designed for environmental engineers, safety and health personnel, plant/site workers, emergency response personnel, and all others involved in hazardous waste operations who must comply with the training requirements of 29 CFR 1910.120 (e).
24 Hour HAZWOPER General Site Worker Initial
This training is similar to the training described above but is intended for employees with a lower exposure, or likelihood of exposure, to hazardous materials. The course concentrates more on hazard recognition and measurement and covers personal protective equipment and work practices in keeping with the risk level.
8 Hour HAZWOPER Supervisor Initial
Training is required for onsite management and supervisory personnel who are engaged in hazardous waste operations under 29 CFR 1910.120 (e). Topics should include employer’s safety and health programs, drill planning and execution, and employee training programs. Other topics included are personal protective equipment programs, spill containment methods and procedures, and techniques for health hazard monitoring. Completion of the 40-Hour General Site Worker course is a prerequisite.
8 Hour HAZWOPER Site Worker Refresher
This annual OSHA regulatory training is required under 29 CFR 1910.120 (e). These specific refreshers for the 40-hour initial training are designed to reinforce and update current health and safety practices for personnel engaged in hazardous waste/substance operations. Students must provide proof of initial or, current refresher training.
Emergency Response Operations - 29 CFR 1910.120 (q)
One of the first questions you need to ask is whether or not you will be performing emergency response. If your facility does perform emergency response, you must determine who is responsible for emergency response and to what level. The existence of a “spill team” does not necessarily mean the team performs emergency response.
The HAZWOPER standard establishes five basic training requirements related to chemical emergency response: the First Responder Awareness Level, First Responder Operations Level, Hazardous Materials Technician, Hazardous Materials Specialist, and On-Scene Incident Commander training. These training levels are based on an emergency response.
HAZWOPER First Responder Awareness (FRA)
This training is required for individuals who are likely to witness or discover a hazardous substance release and who would take no action beyond notification of the proper authorities. Even if you do not have a spill team and do not plan to respond to spill emergencies, your employees might need First Responder Awareness Level training. This training potentially could include everyone from the chemical operator to the security guard, mail clerk and salesperson. The standard specifies six areas of competency that must be achieved either through training or experience, including understanding the risks associated with a hazardous substance incident.
HAZWOPER First Responder Operations (FRO)
Training is required for individuals who respond to releases or potential releases as part of the initial response. They are trained to respond in a defensive manner to protect people, property and the environment. Defensive actions are those taken from a safe distance to keep the spill from spreading and to prevent exposures. Examples include covering drains, placing spill booms or barriers and barricading access points,” all from safe distances. Eight hours of training or sufficient experience to demonstrate competency is required. The areas of required competency include hazard and risk assessment techniques, selection and use of personal protective equipment, spill control and containment, decontamination and standard operating procedures.
Hazardous Materials Technician - HAZMAT Technician
This training is required for individuals who will respond to the release or potential release for the purpose of stopping the release. They usually will be close to the source of the release and, therefore, have a high potential for harmful exposures. Examples include over packing a leaking drum or collecting contaminated absorbents. The Hazardous Materials Technician level calls for 24 hours of training. Personnel also must demonstrate competency in several areas, including the emergency response plan, instrumentation, the incident command system, selection and use of personal protective equipment, hazard and risk assessment, containment and control, decontamination, termination procedures and basic chemistry and toxicology.
Hazardous Materials Specialist - HAZMAT Specialist
This training is similar to the Hazardous Materials Technician training. However, the specialist is required to have greater knowledge of the chemicals to which he or she might respond, as well as to act as a liaison with governmental authorities. He or she also provides support to the hazardous materials technician and 24 hours of training is required. Areas of required competency include those required of the hazardous materials technician, plus an understanding of the state emergency plan and in- depth hazard and risk assessment techniques. He or she also must be able to determine decontamination procedures, develop a site safety and control plan and demonstrate a greater knowledge of chemistry and toxicology.
On-Scene Incident Commander
Training is required for response beyond the First Responder Awareness Level. The role of the incident commander is to assume control of the incident scene. The incident commander must be someone on-site who is designated and trained to be in charge of the incident.
The required training will vary with the level and complexity of the response. The minimum required training is 24 hours, including at least First Responder Operations Level training. Competency must be demonstrated in implementation of the incident command system, the employer’s emergency plan and the local emergency plan. He or she must understand the hazards and risks of working in personal protective equipment and the importance of decontamination.
RCRA TSD Operations - 29 CFR 1910.120 (p)
24 Hour HAZWOPER RCRA TSDF Initial
Individuals must be able to select, use, and maintain personal protective equipment to minimize exposure to hazards. You must become familiar with the operation and use of monitoring and sampling equipment used to conduct a thorough site characterization. The training is designed for environmental engineers, safety and health personnel, plant/site workers, emergency response personnel, and all others involved in hazardous waste operations relating to the treatment, storage or disposal of hazardous wastes at RCRA permitted facilities.
8 Hour HAZWOPER RCRA TSDF Refresher
This annual OSHA regulatory training is required under 29 CFR 1910.120 (p). These specific refreshers for the 24-hour or the RCRA/TSD initial training are designed to reinforce and update current health and safety practices for personnel engaged in hazardous waste/substance operations. Attendees must provide proof of initial or, current refresher training.
If your facility is a RCRA Part B permitted facility, you will fall under the purview of the RCRA Corrective Action regulations. This can have a profound impact on any remediation efforts at your facility. U.S. EPA enforces the RCRA Corrective Action regulations and any waste generated during remediation will be subject to the solid waste/hazardous waste definition. Hazardous wastes fall into 2 categories – Characteristic and Listed. If any of your generated wastes are considered “listed” the impact to your operation will be substantial. Anything that comes in contact with a listed hazardous waste must itself be managed as a hazardous waste.
OSHA HAZWOPER Personal Protective Equipment (PPE) Requirements
As required by the OSHA PPE Standard 29 CFR 1910.134, PPE must be selected which will protect employees from the specific hazards which they are likely to encounter during their work on-site.
Selection of the appropriate PPE is a complex process which should take into consideration a variety of factors. Key factors involved in this process are identification of the hazards, or suspected hazards; their routes of potential hazard to employees (inhalation, skin absorption, ingestion, and eye or skin contact); and the performance of the PPE materials (and seams) in providing a barrier to these hazards. The amount of protection provided by PPE is material-hazard specific. That is, protective equipment materials will protect well against some hazardous substances and poorly, or not at all, against others. In many instances, protective equipment materials cannot be found which will provide continuous protection from the particular hazardous substance.
Other factors in this selection process to be considered are matching the PPE to the employee’s work requirements and task-specific conditions. The durability of PPE materials, such as tear strength and seam strength, should be considered in relation to the employee’s tasks. The effects of PPE in relation to heat stress and task duration are a factor in selecting and using PPE. In some cases layers of PPE may be necessary to provide sufficient protection, or to protect expensive PPE inner garments, suits or equipment.
The more that is known about the hazards at the site, the easier the job of PPE selection becomes. As more information about the hazards and conditions at the site becomes available, the site supervisor can make decisions to up-grade or down-grade the level of PPE protection to match the tasks at hand.
The following discusses chemical protective and respiratory equipment for HAZWOPER work.
Level A
Should be worn when the highest level of respiratory, skin, and eye protection is needed (i.e., for use with highly toxic releases, such as chlorine or ammonia). Level A protection includes:
• Fully encapsulated chemical-resistant suits
• Positive-pressure SCBA or positive-pressure supplied air respirator with escape SCBA
• Double layer of chemical-resistant gloves
• Airtight seals between suit and gloves and boots
Level B
Should be worn when the highest level of respiratory protection is needed, but a lesser degree of skin protection is needed (i.e., protects against splash hazards posed by acids or caustics). Level B protection includes:
• Positive-pressure SCBA or positive-pressure supplied air respirator with escape SCBA (NIOSH approved)
• Chemical-resistant clothing
• Double layer of chemical-resistant gloves
• Chemical-resistant boots, with steel toe and shank
Level C
Should be worn when the next highest level of respiratory protection is needed after Level B. Skin protection criteria are similar to Level B (i.e., protects against contaminants, such as asbestos and lead). Level C protection includes:
• Full-face or half-mask air purification respirator (NIOSH approved)
• Chemical-resistant clothing
• Double layer of chemical-resistant gloves
• Chemical-resistant boots, with steel toe and shank
• Eye protection if half-face respirator is worn
Level D
Should be worn only as a work uniform and not at any site with respiratory hazards. Provides no protection against chemical hazards. Level D protection includes essentially common work clothes, such as safety goggles, safety gloves, and protective shoes.
Protection for General Site Workers, Emergency Response & RCRA TSD Operations Personnel – Considerations
The level of PPE, including the type of material that the components are made from, will depend on the types of hazardous substances present, their concentrations, the physical requirements of the task, the duration of the task, environmental conditions (e.g., heat stress), and the needs of the user (e.g., dexterity). These factors may be different for each site task or operation, which is why HAZWOPER requires that PPE be evaluated for each task and not for the site as a whole. In addition, hazardous conditions can quickly change, requiring a modification (e.g., upgrading or downgrading) to the level and type of PPE to provide the protection needed for the new conditions. For example, a backhoe hitting a pocket of contaminated soil can result in elevated chemical concentrations requiring a possible upgrade to the level of PPE. When conditions exist that create the possibility of immediate death, immediate serious injury or illness, or impairment of escape, employees must be provided with the highest level of PPE. If the hazard is due to a chemical that poses an inhalation hazard, then a positive pressure SCBA or positive pressure air-line respirator must be used. If a chemical poses a severe skin hazard or is highly toxic and can be readily absorbed through the skin, then appropriate protective clothing (e.g., totally-encapsulating suit) must be worn.
In contrast, it is just as important to know when to downgrade the level and type of PPE through exposure monitoring. Wearing too much PPE increases certain hazards such as heat stress, physical and psychological stress, and can impair vision, mobility and communication.