Clearing the Fog of HAZWOPER Training
Sealant Waterproofing and Restoration Institute, Member Briefs
May 2006
By Gary Gagliardi, CFPS, Safety Resources, Inc.
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In conducting Hazwoper classes around the country, I have found one commonality that is consistent
regardless of the industry involved. That common factor is that there is a lot
of confusion over what Hazwoper classes are required or needed. That confusion
is understandable, as there are ten different Hazwoper courses to choose from
not counting Refresher training. Determining which Hazwoper courses are required
in your company can save you significant time and costs while ensuring your
employees are properly trained and ready to respond if needed. This
step-by-step guide should assist you in recognizing your needs and thus your
training requirements.
First let’s clarify what
Hazwoper is. Hazwoper stands for Hazardous Waste Operations and Emergency
Response. There is a distinction between “Hazardous Waste Operations” and
“Emergency Response.” As you determine if your employees require Hazwoper
training, the selection of the required training should fall into place.
HAZARDOUS WASTE OPERATIONS
Hazardous waste operations include landfills, hazardous waste sites, clean up operations covered
by the Resource Conservation and Recovery Act (RCRA), operations involving
hazardous waste conducted at treatment, storage and disposal (TSD) facilities,
and DOT Hazmat. Hazardous Waste Operation is broken into two main areas,
hazardous waste cleanup activities, and activities at Treatment Storage and
Disposal Facilities (TSDF).
Hazardous waste Cleanup Activities:
If your employees work
in an area that has exposures to hazardous waste materials and has been
classified as a hazardous waste site by a governmental body or if your employees
are working on a project where a requirement for working at the site would be to
have Hazwoper certification, then your employees would need a Waste Worker
course. There are two Waste Worker courses, a 40-hour Hazwoper
Course and a 24-hour Hazwoper Course
If at the hazardous
waste site where your employees work, they will be exposed to levels of
chemicals above the 8 hour Permissible Exposure Limit (PEL) established by OSHA,
or will be expected to wear levels of personal protective equipment (PPE) or
some type of respirator to protect them from the chemical hazards, they will
need the 40 hour Hazwoper course plus three days of actual field experience
under direct supervision of a trained experienced supervisor. This is called the
General Site Worker Course.
If at the hazardous
waste site where your employees work, they will NOT be exposed to levels of
chemicals above the 8 hour Permissible Exposure Limit (PEL) established by OSHA,
or will NOTbe expected
to wear levels of personal protective equipment (PPE) or some type of respirator
to protect them from the chemical hazards, then the 24 hour Hazwoper course is
needed plus one day of actual field experience under direct supervision of a
trained experienced supervisor. The 24-hour course is called the Occasional
Site Worker Course
On-site supervisors and
managers of employees working with Hazwoper certified workers should attend the
40-hour or the 24-hour Hazwoper course (dependent on the exposure),
plus an additional 8 hours of
specialized training. This is called the Hazardous Waste
Supervisors Course.
Activities at Storage and
Disposal facilities (TSDf):
If your employees work
at a designated TSDF as defined by a governmental body, then you are required to
have the 24-hour TSDF worker training program. This is called the
TSDF Course.
DOT Hazmat Employee:
If your employees are
involved in any way in the handling, packaging, or preparation of hazardous
materials that are transported, the U. S. Department of Transportation requires
that specific training and certification be maintained. This includes employees
who work in shipping departments, mail rooms, drive trucks, handle packages with
DOT labels, fill out shipping papers, or transport shipments which contain
hazardous materials. Training is required which includes:
- General Awareness
training
- Function-Specific
training
- Safety Training
- Security Awareness
training (if a security plan is required)
This training is
required within the first 90 days of employment and every three years
thereafter.
EMERGENCY RESPONSE
Emergency Response
applies to all Hazardous Waste Operations, but this portion also applies to
facilities that utilize hazardous chemicals, toxics and reactive materials above
the threshold quantities such that they present a potential for a catastrophic
event (appendix A to 29CFR 1910.119 specifies hazardous chemicals and the
threshold quantities). An example of a need for
Emergency Response to a
hazardous substance release would be a food processing site utilizing over
10,000 pounds of Anhydrous Ammonia as a refrigerate.
There are five levels of
emergency response training. Employees that are expected to response to an
emergency release of chemicals, toxics or reactive materials are required to
have one of the five levels of emergency response training in accordance with
section (q) of the Hazwoper regulation.
OSHA leaves it up to the
employer to determine which level is needed based on what you expect the
employee to do. The five levels are as follows:
- First Responder
Awareness level
- First Responder
Operational level
- Hazardous Materials
Technician
- Hazardous Materials
Specialist
- Hazardous Materials
Command (Incident Commander)
Based on what you expect
the employee’s role to be in the event of an emergency release, the following
information will help you to determine the training required:
First Responder Awareness
Level
If you have workers who
are likely to witness or discover a hazardous substance release and whose only
responsibility will be to initiate an emergency response sequence by notifying
the proper authorities of the release, and you do not want them to take any
further action beyond notifying the authorities of the release and evacuating
the area, then First Responder Awareness Level training is
appropriate. No set minimum hours are assigned to this training.
First Responder
operational level
If you have workers that
are expected to respond to releases or potential releases of hazardous
substances as part of the initial response for the purpose of initiating actions
to limit the release without becoming
contaminated with it, containing the release from a safe distance, keep it from
spreading, and prevent exposures in order to protect nearby persons, property,
or the environment from the effects of the release without actually trying to
stop the release, then First Responder Operations Level training is appropriate.
An example of this action would be: if an employee would be able to minimize the
release by containing the material to keep it from getting into storm drains,
and turning off valves to stop the flow of materials without exposing themselves
to any of the material at any time. This requires 8 hours of training and
demonstrate Awareness level competency.
First Responder Materials
Technician Level
>If you expect your
workers to respond when a release or potential release of hazardous substances
are discovered, for the purpose of stopping the release by approaching the point
of release in order to plug, patch or otherwise stop the release, and cleanup of
the spill, then First Responder Materials Technician level training is
appropriate. These workers must be provided with the required personal
protective equipment (respirators and clothing) to safely work with the
materials, and to approach the point of release to control it without becoming
contaminated by it. Maintenance workers typically fall into this category. This
level requires Operations Level training plus 24 hours of training.
First Responder
Specialist Level
If you have workers that
would support the hazardous materials technicians due to specific knowledge of
the various substances they may be called upon to contain and whose duties
parallel those of the hazardous materials technician then First Responder
Specialist level training is appropriate. The hazardous materials specialist may
also act as the site liaison with Federal, state, local and other government
authorities in regards to site activities. This level requires Materials
Technician Level training plus 24 hours of training.
First Responder on-Scene
Incident Commander
If you have personnel
that are expected to assume control of the incident scene by overseeing the
operation and the handling of the release through its cleanup, then First
Responder On-Scene Incident Commander level training is appropriate. This level
requires Operations Level training plus 24 hours of training.
REFRESHER
COURSES
If you have taken either
the General Site Worker, Occasional Site Worker, or TSDF worker courses
previously, you are required to have an eight-hour refresher course each year.
Your certification is good for only 365 days. Site specific training is always
encouraged by OSHA to ensure that personnel are adequately trained to the
specific issues at the site. An annual 8-hour Hazwoper Refresher course is
required prior to the expiration date of the current certification for everyone
who has taken the 24 or 40 hour OSHA Hazwoper course to maintain their
certification.
Emergency response
refresher training is required but does not have a set number of hours assigned.
Generally, personnel certified to either the Awareness or Operation levels can
satisfy their refresher training program by repeating some or all of their
original class. For those with higher levels of training, hands-on practice is
necessary.