What Positions Typically Require 24-Hour OSHA HAZWOPER Training?

 Training Requirements for HAZWOPER

The Occupational Safety and Health Administration (OSHA) outlines employer compliance requirements regarding Hazardous Waste Operations and Emergency Response (HAZWOPER) within 29 CFR 1910.120.

And just to refresh, the OSHA HAZWOPER standard applies to five (5) distinct groups of workers. This includes any employees who are exposed or potentially exposed to hazardous substances, including hazardous waste, and who are engaged in one of the following operations as specified by OSHA regulation CFR 1910.120(a)(1)(i-v):

• Clean-up operations required by a governmental body, whether federal, state, local, or other involving hazardous substances, that are conducted at uncontrolled hazardous waste sites;
• Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);
• Voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;
• Operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities (TSD) regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and
• Emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard

Employee training requirements are addressed in 1910.120(e) of the HAZWOPER standard. In a recent blog, we addressed the 40-hour employee training requirement. Specifically in 1910.120(e)(3)(i), it addresses 40 hours of off-site instruction required for workers engaged in hazardous substance removal or other activities which expose or potentially expose workers to hazardous substances and health hazards at or above the Permissible Exposure Limit (PEL). This 40-hour training, arguably the most popular of the HAZWOPER training courses, is targeted for general site workers, which typically includes roles such as general laborers, equipment operators, and supervisory personnel. General site workers differ from emergency response support/specialist roles, which include first responders, HAZMAT (Hazardous Materials) technicians/specialists, and incident commanders, which require different training curriculums. Do all workers require this 40-hour training? This is one of the most commonly asked questions regarding HAZWOPER training.

 24-Hour HAZWOPER Training Requirements

Some workers will only require 24-hours of training. This requirement is addressed within three paragraphs of the OSHA HAZWOPER standard, as opposed to one paragraph in the 40-hour requirement. Specifically, Sections 1910.120(e)(3)(ii) through (e)(3)(iv), states the following:

"1910.120(e)(3)(ii)- Workers on site only occasionally for a specific limited task (such as, but not limited to, ground water monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor."

So, this first qualifier addresses two key points, limited tasks and exposure below permissible/published exposure limits.

"1910.120(e)(3)(iii)- Workers regularly on site who work in areas which have been monitored and fully characterized indicating that exposures are under permissible exposure limits and published exposure limits where respirators are not necessary, and the characterization indicates that there are no health hazards or the possibility of an emergency developing, shall receive a minimum of 24 hours of instruction off the site, and the minimum of one day actual field experience under the direct supervision of a trained, experienced supervisor."

This second qualifier also addresses two key points, whether or not respiratory protection will be required and no possibility of health hazards/emergencies. This is also why a thorough site characterization performed by a qualified person is so important.

"1910.120(e)(3)(iv)- Workers with 24 hours of training who are covered by paragraphs (e)(3)(ii) and (e)(3)(iii) of this section, and who become general site workers or who are required to wear respirators, shall have the additional 16 hours and two days of training necessary to total the training specified in paragraph (e)(3)(i)"

This third paragraph states the importance that some workers who initially only need 24 hours of training might eventually require 40 hours. For that reason, OSHA allows employers to administer an additional 16 hours of training to the employee who has previously taken a 24-hour course.

 24-Hour HAZWOPER Training Topics

Like the 40-hour OSHA HAZWOPER course, the 24-hour course typically includes topics such as:

• Safety and health programs
• Roles and responsibilities
• Site control, characterization, and analysis
• Personal protective equipment (PPE)
• Medical surveillance
• Hazard control
• Monitoring and informational programs
• Handling drums and containers
• Decontamination
• Permissible exposure limits (PEL)
• Emergency response

And don’t forget, to keep the certification current, the student must complete 8-Hours of HAZWOPER refresher training every year.

 24-Hour HAZWOPER Training Industries

A wide range of industries are affected by HAZWOPER requirements, including:

• Construction
• Manufacturing
• Treatment/storage/disposal (TSD)
• Transportation
• Engineering
• Environmental services

In addition, within these industries, numerous occupational roles are directly and indirectly impacted by the HAZWOPER standard and associated training requirements. They include:

• General and specialized laborers
• Engineers
• Project managers
• Delivery drivers
• Equipment operators
• Surveyors
• Consultants

Whatever your role and industry, be certain you are in compliance with the correct type and amount of OSHA HAZWOPER training. For more information, please review the Overview section of OSHA’s HAZWOPER page.