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SAFETY BULLETIN / January - March 2006
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Clearing the Fog; HAZWOPER Training - by Gary Gagliardi CFPS, Senior Safety Specialist

In conducting Hazwoper classes in Indiana and 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 which 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 NOT be 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 either 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 is 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.

If your company has a requirement for Hazardous Waste Training , either Hazardous Waste Operations or Emergency Response, feel free to contact us and we will assist you in obtaining not just training to fill a square, but training that makes a difference.
 
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