There are so many rules concerning the use, disposal, transportation, and emergency response to chemical, biological & radiological substances much of which get confusing when trying to discern which training a person would be required to obtain to meet federal or state requirements. Hopefully the following information will make it easier for a person to select the right training.
The short of it is, HazWoper is in regards to the clean-up of hazardous waste (including treatment, storage & disposal) and/or emergency response to the release or threat of release of hazardous substances. While HazMat is in regards to the transportation of hazardous materials (includes biological, chemical and radiological substances and waste). The rules are not the same when considering training requirements.
Hazardous Waste Operations and Emergency Response under OSHA’s 29 CFR 1910.120 standard involves two separate situations.
1. Hazardous waste operations (HazWop) applies to:
- Clean-up operations required by a governmental body involving hazardous substances at uncontrolled hazardous waste sites (i.e., EPA's National Priority List, state priority lists, sites recommended for the EPA NPL, etc.);
- Corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA);
- Voluntary clean-up operations at sites recognized by federal, state, local or other governmental bodies as uncontrolled hazardous waste sites;
- Operations involving hazardous waste at treatment, storage, disposal (TSD) facilities regulated by 40 CFR Parts 264 and 265;
Under hazardous waste operations, a person would need either 24 hours of training or 40 hours of training. The decision for which training to attend will be based on the known or anticipated levels of exposure to the substances on site that could be encountered.
24 hours is for those employees who would be exposed at or below the established exposure limit, while 40 hours of training is required for those employees who would be exposed above the established exposure limits. And, the training does not end there. For 24 hour training you need an additional 8 hours of supervised training (at your location) which will need to be documented by the supervisor. For 40 hour training you will need an additional 24 hours of supervised training. Both 24 & 40 hour employees must receive 8 hours of annual refresher training.
2. Emergency Response or emergency responders (ER) applies to, providing emergency response for releases of, or substantial threats of releases of, hazardous substances (chemical, biological & radiological) without regard to the location of the hazard. For emergency response training you will need to determine which role you are fulfilling, as listed below:
- First Responder - Awareness Level
- First Responder - Operations Level
- Hazardous Material Technician
- Hazardous Material Specialist
- On Scene Incident Commander
The decision for filling a role will be based on a few factors:
The responder level selected will determine the amount of training the employee will receive:
- Substances on site which if released would create a substantial threat; this can vary in amounts based on the actual substance(s).
- The personal protection provided for the responders such as; respirators including SCBA’s, responder suits, and other personal protective equipment.
- The means to identify and quantify exposures of the released substances.
- The level of risk the employer is willing to obligate the employee’s actions to control the release.
- First Responder - Awareness Level. No specified amount of training time.
- First Responder - Operations Level. This level requires 8 hours of training.
- Hazardous Material Technician. This level requires 24 hours of training.
- Hazardous Material Specialist. This level requires 24 hours of training plus additional competency in multiple identified areas.
- On Scene Incident Commander. This level requires 24 hours of training plus training for additional competencies based on leadership needs.
Emergency responders shall receive annual refresher training of sufficient content and duration to maintain competencies, or shall demonstrate competency in those areas at least yearly.
DOT Transportation of Hazardous Materials (HazMat) training requirements are found under 49 CFR 172.702. Training is focused on content and does not state time requirements for training. However, the rules do state that a new hazmat employee may perform job functions prior to completion of training provided they are under the direct supervision of a knowledgeable hazmat employee and the training is completed within 90 days after employment or change in job function.
Elements for HazMat training that must be covered include:
- General awareness/familiarization training designed to enable the employee to recognize and identify hazardous materials
- Function-specific training specifically applicable to the functions the employee performs
Safety training concerning
-Emergency response information
-Measures to protect the employee from the hazards associated with hazardous materials to which they may be exposed in the work place, including specific measures the hazmat employer has implemented to protect employees from exposure; and
-Methods and procedures for avoiding accidents, such as the proper procedures for handling packages containing hazardous materials.
- Security awareness training, awareness of security risks associated with hazardous materials transportation and methods designed to enhance transportation security, including how to recognize and respond to possible security threats. (New hazmat employees must receive the security awareness training required by this paragraph within 90 days after employment.)
Recurrent training is required at least every three years.
We regularly provide public 24 hour (3-days) HazWoper training as well as 8 hour HazMat training; both of these can also be offered privately at your location. There is no prerequisite for these two classes; however, to be eligible for the 8 hour HazWoper refresher class you must have attended a 24 hour or a 40 hour HazWoper class.
While we are at it, employees engaged in any work involving hazardous waste must receive annual EPA Resource Conservation and Recovery Act (RCRA) training. Look for this training to be added to our 2021 Training Calendar. We’ll cover the training requirement specifics in another article.
If you have questions about HazWoper or HazMat training contact Christine Reed at 515-276-4724, ext. 226 or email her at firstname.lastname@example.org