(Hazardous Waste Operations and Emergency Response)
The HAZWOPER standard covers 5 specific areas of operations, including:
- -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 (including, but not limited to, the EPA’s National Priority Site List (NPL), state priority site lists, sites recommended for the EPA NPL, and initial investigations of government identified sites which are conducted before the presence or absence of hazardous substances has been ascertained);
- -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 bodies as uncontrolled hazardous waste sites;
- -Operations involving hazardous waste that are conducted at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265 pursuant to RCRA; or by agencies under agreement with U.S.E.P.A. to implement RCRA regulations; and
- -Emergency response operations for releases of, or substantial threats of releases of, hazardous substances without regard to the location of the hazard.
OSHA recognizes several levels of training, based on the work the employee will be performing and the level of hazard they will be facing. Each level requires a different training program, and OSHA specifies topics and minimum training times. Training requirements outlined include the standard 40 hour off site and 3 day on site, the 24 hour occasional worker, 8 hour supervisor, and the 8 hour refresher training. The various training requirements are outlined below:
- -Standard 40 hour (off site) and 3 day (on site)All Workers
- -HAZWOPER requires that all workers on a UXO site (not just UXO TechniciansPersonnel who are qualified for and filling Department of Labor, Service Contract Act, Directory of Occupations, and contractor positions of UXO Technician I, UXO Technician II, and UXO Technician III.)have a minimum 40-hour instruction (off site)and 3 days supervised field experience and 8 hours of refresher training annually.
- -Occasional Workers
- -Workers on site only occasionally for a specific limited task 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 one day of supervised hands on training.
- -Supervisor Training
- -Managers and supervisors require the same level of training as the people they supervise 40 hours and the three days of supervised field experience and at least eight additional hours of specialized training on such topics as the employer’s safety and health program, personal protective equipment program, spill containment program, and health hazard monitoring procedure and techniques.
- -Refresher Training
- -Employees and managers/supervisors need to receive eight hours of refresher training annually.
- -Equivalent training
Employers who can show by documentation or certification that an employee’s work experience and/or training has resulted in training equivalent to that training required shall not be required to provide the initial training requirements. However, certified employees or employees with equivalent training new to a site shall receive appropriate, site specific training before site entry and have appropriate supervised field experience at the new site. Equivalent training includes any academic training or the training that existing employees might have already received from actual hazardous waste site experience. Currently, in accordance with the guidance from the Department of the Army Office for Environment, Safety and Occupational Health,completion of EOD school meets the training requirements of HAZWOPER.
There are many sources for OSHA compliant HAZWOPER training. Community colleges, labor unions, employers, and training companies are all good sources for training. The employer must ensure the training provider covers the areas of knowledge required by the standard and provide certification to the student that they have passed the training. A rising trend in HAZWOPER training is computer and web based training. These courses may be adequate to satisfy part of the OSHA requirements; however, the 40 hour general worker training and the 8 hour refresher both require some hands on training and evaluation.This makes computer based training, particularly the online variety, an incomplete solution.