HAZWOPER TRAINING

The abbreviation HAZWOPER is short for “Hazardous Waste Operations and Emergency Response.” HAZWOPER is pronounced “haz-wop-er.”

The Hazardous Waste Operations and Emergency Response (or HAZWOPER) Standards are intended to protect workers from exposures to hazardous substances when they work in any one or more of three types of operations:

• Hazardous waste cleanup sites;
• Hazardous waste treatment, storage, and/or disposal facilities (TSDs); and/or
• Emergency response operations.

The HAZWOPER Standards were not OSHA’s idea. The standards were mandated by a law signed by President Reagan. The Superfund Amendments and Reauthorization Act (SARA) of 1986 was prompted after it was discovered that efforts to clean up abandoned hazardous waste sites created significant risk to the safety and health of workers in these operations.

The Hazardous Waste Operations and Emergency Response (or HAZWOPER) Standards relate to:

• Federal OSHA regulations found at 29 CFR 1910.120 for general industry and 29 CFR 1926.65 for construction.
• Federal EPA regulation 40 CFR 311, which adopts 29 CFR 1910.120 for state and local government workers engaged in hazardous waste operations.
• Various state-level regulations that call for HAZWOPER protections.

The OSHA-issued Hazardous Waste Operations and Emergency Response (or HAZWOPER) Standards cover three types of operations:

• Hazardous waste cleanup sites;
• Hazardous waste treatment, storage, and/or disposal facilities (TSDs); and
• Emergency response operations.

The standards require a covered employer to offer the following worker protections, depending on which operation(s) is at the site:

• Written safety and health program;
• Site characterization and analysis to identify site hazards;
• Site control procedures to control employee exposure to hazardous substances;
• Employee training;
• Medical surveillance;
• Engineering controls, work practices, and personal protective equipment;
• Monitoring for hazardous substances, including air monitoring;
• Informational programs to inform employees of the nature, level, and degree of exposure likely;
• Procedures for handling drums and containers;
• Decontamination;
• Emergency response plan and procedures and post-emergency response operations;
• Minimum illumination;
• Sanitation for temporary workplaces, including potable water, toilet and washing facilities, showers and change rooms, and more; and

Procedures for introduction of effective new technologies and equipment.

In most cases, the phrase Hazardous Waste Operations and Emergency Response (or HAZWOPER) training or certification is referring to OSHA 40-hour HAZWOPER training. This initial training requirement is mandated at 29 CFR 1910.120(e)(3)(i) for general site workers (such as equipment operators, general laborers, and supervisory personnel) at hazardous waste cleanup sites. These employees are engaged in hazardous substance removal or other activities which expose or potentially expose them to hazardous substances and health hazards. Upon successful 40-hour training and 3 days of field experience, the instructor and supervisor must certify the training of the employee.

However, not all employees require OSHA 40-hour HAZWOPER training. The HAZWOPER Standards have other required training levels, depending on site operations and the employee’s duties or roles. See 29 CFR 1910.120(e), (p), and (q) for all HAZWOPER training levels in general industry. See 1926.65(e), (p), and (q) for construction HAZWOPER training levels.

Depending on the site operation and employee duties or roles at the site, OSHA’s HAZWOPER training levels include the following:
 

Note: For construction, see 29 CFR 1926.65(e), (p), and (q) for the same HAZWOPER training levels as listed above.

An “incidental spill or release” has occurred when the release of a hazardous substance can be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. This type of release does not pose a significant threat to the health and safety of employees in the immediate vicinity or to the employees cleaning it up, and it does not have the potential to become an emergency within a short period. Before handling an incidental release, the employee must be trained on hazard communication, personal protective equipment (PPE), and other applicable OSHA regulations.

Factors to keep in mind when determining if a release is incidental include:

• Quantity of substance released,
• Safety or health hazards of the substance,
• Properties of the substance,
• Area ventilation,
• If the release is in a confined space or not,
• The availability of PPE,
• Existing standard operating procedures (SOPs),
• Any engineering controls that can be activated to mitigate the release, and
• Whether employees in the area are familiar with the hazards and can safely clean up the release.

An “emergency release,” on the other hand, has occurred when the release of a hazardous substance cannot be absorbed, neutralized, or controlled at the time by trained employees in the immediate area or by maintenance personnel. This type of release is uncontrolled or likely to result in an uncontrolled release, and properly trained employees from outside the immediate area or designated responders are needed to handle the release. An emergency release poses a significant threat to the health and safety of employees. Before handling an emergency release, employees or designated responders must have emergency response training or sufficient experience, in accordance with OSHA’s HAZWOPER Standards.

Some situations that would normally be considered an emergency release include:

• The response comes from outside the immediate release area,
• Evacuation of employees in the area is required,
• Conditions are or could be immediately dangerous to life or health (IDLH),
• A threat of fire or explosion exists,
• The release requires immediate attention due to imminent danger,
• The release may cause high levels of exposure to toxic substances,
• There is uncertainty about whether employees can handle the severity of the hazards with the available PPE and equipment provided and if the permissible exposure limit (PEL) could easily be exceeded, or
• The situation is unclear.

The distinction between incidental and emergency releases is facility-specific and is a function of the emergency response plan.