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Which HAZWOPER Program is Right for My Organization? |
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Finding the Right Hazardous Waste Operations/Emergency Response (HAZWOPER) Training Program for Your Workers With the large number of Hazardous Waste Operations and Emergency Response (HAZWOPER) training programs available today, it’s important to understand which program is right for your staff. Advertised classes can vary significantly in their content; choosing between them can be difficult. Since they all involve time and money, it’s important to understand which program is right for your workers. The key issue is to understand what the worker’s responsibilities include. OSHA’s HAZWOPER standard (Title 29, Code of Federal Regulations, section 1910.120) targets three general types of workers:
Hazardous waste site cleanup workers are involved in cleaning up sites like Superfund sites, state hazardous waste sites and voluntary cleanups coordinated through a government agency. Cleanup workers may also be employees at an operating facility, where the hazardous substance release occurred. Hazardous waste treatment/disposal workers handle or manage hazardous wastes at treatment, storage or disposal facilities regulated by EPA. Emergency responders would include firefighters/hazmat team members for municipalities or regional teams and for industrial facilities, like refineries or any other facility that stores or handles hazardous substances in bulk quantities. Determining which type of training course for certain workers should be straightforward, such as hazardous waste removal company workers or a hazardous materials response team. However, if your employees are construction equipment operators that may encounter hazardous substances while excavating soil or while drilling below the surface (drill rig operators), it might be less clear. Since they would likely encounter buried drums or tanks, they could stop their work until samples were collected and the results received. They would not require emergency responder training, but would need the same training as a cleanup worker. On the other hand, facility maintenance staff may be seen as a cleanup worker, but, if they are responsible for dealing with potential releases that could involve high concentrations of toxic gases, or could require immediate action due to the danger presented to other workers or the public, they should be trained as emergency responders. Another common activity involving hazardous substance releases is testing spilled materials and contaminated media. Employees of laboratories, consulting firms, research organizations, universities and regulatory agencies are often directed to collect samples of hazardous substances or of air, soil and water contaminated with hazardous substances. Those workers should take the same training as cleanup workers. Cleanup workers that are employees at the facility where they are conducting cleanup of hazardous substances are not subject to the HAZWOPER requirements, as long as they are not performing emergency response tasks. They are, however, required to meet all other applicable training requirements for General Industry and Construction regulations. This would include programs like Hazard Communication (29 CFR 1910.1200), Respiratory Protection (29 CFR 1910.134) or Permit-required Confined Spaces (29 CFR 1910.146). General Training Requirements for Hazardous Waste Site Workers The basic training requirements for workers in the hazardous waste site category are covered in 29 CFR 1910.120(b)-(o) and including the following. Initial Training
Manager/Supervisor Training Managers or supervisors must have the same training for any workers they supervise that work on hazardous waste site, whether it involves a 40-hour class or a 24-hour class. Managers and supervisors must also receive training on the company’s safety and health program and any employee training programs. Refresher Training All hazardous waste site workers must complete eight (8) hours of annual refresher training. Refresher training must cover topics consistent with their initial training program. General Training Requirements for EPA-regulated Hazardous Waste Treatment/Disposal Facilities Training programs designed for RCRA TSDF workers are required to consist of 24 hours of instruction and followed up with eight (8) hours of refresher training annually. Their requirements are found at 29 CFR 1910.120(p). The content should be based on their safety and health program and would include addressing hazards specific to their facility, which might consist of the waste analysis plan, site analysis, engineering controls, maximum exposure limits, hazardous waste handling procedures and uses of new technologies. General Training Requirements for Emergency Responders Depending on their job assignments, emergency responders are placed into one of the following categories. For details, see 29 CFR 1910.120(q).
The most common categories are the awareness level, operations level responder and hazardous materials technician. Awareness level Worker type: law enforcement staff, security guards, truck drivers, highway workers, dispatchers, and EMS workers. Training objectives: to recognize that an incident has occurred and understand who is to be notified and what type of resources would be needed. Besides notification, their duties might include restricting access to the scene. General training requirements: generally presented over eight (8) hours, but no limit is specifically listed by OSHA. Operations level Worker type: firefighter/hazmat team member, hospital emergency department staff, EMS workers. Training objectives: to respond to the scene of an incident for the purposes of protecting nearby persons, property, or the environment. They are to respond in a defensive mode, containing the release from a safe distance, keep it from spreading, and prevent exposures without actually trying to stop the release. They are typically limited to working in the decontamination zone or the support zone. General training requirements: at least eight (8) hours of training (typically equivalent to Awareness level programs) in addition to topics specifically listed in the HAZWOPER standard. Technician level Worker description: firefighters/hazmat team members, private sector emergency Training objective: to control or contain releases. Technician assume a more aggressive role than an operations level responder by approaching the source of the release and may come into direct contact with the substance as they work to stop the release. General training requirements: at least 24 hours of training equal to the first responder operations level plus additional requirements listed in the HAZWOPER standard. In addition to meeting the requirements of OSHA regulations, public sector emergency responders are trained to meet additional standards established by the National Fire Prevention Association. It’s important to note that some requirements are best handled by the responder’s organization. This would include the organization’s emergency response plan and their standard operating procedures. Training providers should instruct the students that their organization must have operating procedures or policies that establish how responders are to perform their duties. This is inherent to emergency response and takes the place of site-specific health and safety plans required for organizations that conduct cleanup operations at hazardous waste sites. It is just as important that employers also understand that they are responsible for certifying employees as awareness level, operations level or technician level responders, not the training provider. The training provider is responsible for delivering the appropriate materials in a professional manner and providing certificates to document successful completion of training, but it is up to the employer to ensure that the employee can demonstrate competency and meet the requirements for a particular level of emergency responder. Further information regarding training for those who work with hazardous substances can be found at: Title 29, Code of Federal Regulations, section 1910.120; Hazardous Waste Operations and Emergency Response. NFPA 472, Standard for Professional Competence of Responders to Hazardous Materials Incidents, National Fire Protection Association, 1 Batterymarch Park, PO Box 9101, Quincy, MA 02269-9101, 2007 Edition |