Controlling the Uncontrolled: HAZWOPER Training at Cleanup Sites
To protect personnel and manage compliance with OSHA’s HAZWOPER Standard at “uncontrolled hazardous waste sites” (e.g., Superfund sites), EHS professionals must have a full understanding of the Standard—especially the training requirements. Providing effective, up-to-date HAZWOPER training means knowing which employees are covered by which HAZWOPER requirements, in which situations, and what they must know before performing work that could endanger their health and well-being.
OSHA’s single HAZWOPER Standard at 29 CFR 1910.120 applies to three separate groups of employees, which can cause confusion when seeking out or delivering HAZWOPER training. Each of the three covered groups works toward a different objective, and each has different responsibilities when it comes to HAZarodus Waste OPerations and Emergency Response (HAZWOPER). As such, OSHA also maintains three sets of training requirements within the HAZWOPER rules.
Do you work at a Superfund site or other uncontrolled hazardous waste site? Keep your HAZWOPER cleanup certification up-to-date with Lion’s 8-Hour OSHA HAZWOPER Refresher online course.
To provide the right kind of HAZWOPER training for personnel who perform cleanup work, site safety officers must first know which group his or her employees fall into:
- Uncontrolled hazardous waste site cleanup operations personnel
- Treatment, storage, and disposal facility (TSDF) employees
- Hazardous substance emergency responders
What’s the difference between cleanup and emergency response?
Emergency response, as defined by OSHA, occurs when a hazardous substance is released and “employees from outside the immediate release area” or “other designated responders” respond to an occurrence that results, or is likely to result, in an uncontrolled release of a hazardous substance. [29 CFR 1910.120(p)]
In other words, when an emergency release occurs, specially trained employees must respond to neutralize the immediate threat to personnel, the environment, and the public.
Cleanup at a hazardous waste site, on the other hand, has its own very specific definition under the Standard. Cleanup may be required after an emergency response event—or as part of a separate hazardous waste site cleanup operation.
A site is considered a “hazardous waste site” if it is:
- Identified or listed by a government agency as an uncontrolled hazardous waste site.
- Listed, or proposed for listing on:
- The National Priorities List, or
- A State priority list.
- Regulated as a corrective action covered by RCRA.
Who needs training to work at a hazardous waste cleanup site?
HAZWOPER training is required for all employees working on site that could be exposed to hazardous substances, safety, or health hazards, their supervisors, and management responsible for the site, before they are permitted to engage in or supervise hazardous waste operations. The Site Safety and Health Officer oversees employee training and uses information obtained from job hazard analyses to design a training program that meets specific needs of the employees.
Within the HAZWOPER cleanup training rules, OSHA lists different categories of employees found on a typical hazardous waste cleanup site. Workers are grouped by the type of work they perform and how often they are present on site. For each category, there is a prescribed minimum number of initial OSHA training hours that must be fulfilled.
General Site Workers have a regular presence on the job and perform tasks that may expose them to hazardous substances and health and safety hazards. Hazardous substance removal personnel, equipment operators, laborers, and management all fall under the category of general site workers. General site workers must initially receive a minimum of 40 hours of off-site training plus three days of hands-on experience in the field.
Periodic Site Workers are on site less frequently, including personnel who only perform a specific task, such as taking land survey measurements or collecting groundwater samples. Due to limited site visits, these workers are less likely to encounter a health or safety hazard exposure and must initially receive a minimum of 24 hours of off-site instruction plus one day of field experience.
Other Site Workers have a regular presence on the site; however, they work in areas where hazards have been fully characterized and there is no indication of potential exposures above any regulatory limits. Employees who are regularly on site, but are less likely to be exposed to hazardous substances and health hazards in their work area, must initially receive a minimum of 24 hours of off-site instruction plus one day of field experience.
Emergency Response Employees at hazardous waste cleanup sites must be specifically trained on how to respond appropriately. This specialized training is in addition to the training they receive to perform their regular duties on site.
Managers and Supervisors must complete 8 hours of specialized training, covering topics such as hazard monitoring, employee training, and the Safety and Health Program. Management training is in addition to the 40-hour HAZWOPER training plus three days field experience necessary for general site workers. Managers who supervise periodic- and low-exposure employees only may qualify to attend reduced 24-hour HAZWOPER training and one day of field experience.
The table below summarizes the employee HAZWOPER training requirements for cleanup operations at uncontrolled hazardous waste sites.
Take Charge of Additional and Refresher Training
Conditions and hazards frequently change, and employees perform various tasks and change positions at hazardous waste sites. If hazards change or new hazards are introduced, if employee tasks change, or if there is an increased potential for exposure to hazards, additional off-site training and field experience must be performed. And all employees, regardless of their initial training level, must attend at least 8 hours of refresher training once every 12 months.
Master the Required Training Elements
When it comes to the actual content of HAZWOPER training, OSHA is rather specific about what needs to be covered, providing a list of required elements along with the expectation that each element is thoroughly covered. Training must include:
- Names of personnel responsible for site safety and health.
- Safety, health and other hazards present on the site.
- Medical surveillance requirements, including recognition of signs and symptoms of overexposure.
- Engineering controls, work practices, and personal protective equipment.
- Informational programs.
- Handling drums and containers.
As always, workers must receive any other OSHA training required by applicable industry standards. For example, all employees need some form of Hazard Communication training. And, if employees need to enter a permit-required confined space, they must be trained according to that standard prior to entry.
Manage the Training Certifications
Anyone who successfully completes all of the required elements of the training curriculum, both the off-site and field experience portions, must receive a written training certificate. Failure to successfully complete all the required training components means that an individual cannot participate in any hazardous waste operations.
HAZWOPER Training at Lion.com
Because the HAZWOPER Standard is complex, Lion Technology offers a variety of HAZWOPER courses for different personnel in different situations.
For personnel who perform cleanup work at uncontrolled hazardous waste sites, Lion offers the 8-Hour HAZWOPER Refresher online course.
Do you respond to hazardous substance emergencies regardless of the location of the release? Depending on what level of response you perform, one of our two new training courses may help you take command of an emergency situation.
The HAZWOPER – Emergency Response First Responder Awareness Level I course provides the classroom-based competency content necessary for either the initial or annual refresher training required for employees who are awareness level first responders.
HAZWOPER: Emergency Responder, Level 3 Refresher online training offers the classroom-based competency content to satisfy the annual refresher training required for employees at the emergency response hazardous materials technician level per the OSHA HAZWOPER Standard.