40-Hour, 24-Hour, 8-Hour Training & Refresher Courses
OSHA has stated in many HAZWOPER interpretation letters that 40 hour and 24 hour sessions require site-specific hands-on learning on the actual PPE that an employee will be using in their job. Site-specific means just that. The training cannot be done with generic PPE, but must be done with the actual equipment in order to fully meet the OSHA regulations. The OSHA training requirements for these courses are listed below.
A minimum of 24 or 40 hours of offsite instruction.
Site-specific training on the actual PPE. A public seminar with people from different job sites cannot fulfill this requirement.
Either 1 or 3 days of training under the direction of a qualified supervisor.
Medical physical exam conducted by a fully licensed physician. The physical must also include a pulmonary function test of the lungs.
Appropriate annual refresher training must be performed in order to maintain the certification status.
How Many Levels of HAZWOPER Training does OSHA Enforce?
There are three levels for HAZWOPER training as listed in the OSHA regulations. The first HAZWOPER level pertains to emergency response. The second level is clean-up of contaminated hazardous waste sites, and the last level pertains to the treatment, storage and disposal (TSD) of hazardous waste. Within these 3 categories are various job functions and training requirements.
1. Emergency Response
2. Clean-up of Contaminated Hazardous Waste Sites
3. Treatment, Storage and Disposal (TSD) of Hazardous Waste
Who Are Considered Emergency Responders?
HAZWOPER training requirements for the first responder operations level appear under 29 CFR 1910.120 (q)(6)(ii), which indicates a minimum training duration of 8 hours and outlines topics to be covered (competencies the worker must acquire). Training that is relevant to the required competencies counts toward the 8-hour requirement, even if the training is provided as a separate course. For example, training on PPE that will be used during patient decontamination activities may be applied towards the 8-hour minimum first responder operations level learning requirement, regardless of whether the PPE training is conducted as part of a specific HAZWOPER training course or as part of another training program.
General Site Workers
General Site Workers at Contaminated Sites
Without question, this is the largest pool of people requiring HAZWOPER certification. This may change as the contaminated sites are slowly remediated. These contaminated sites are placed on the National Priority List (NPL) by the U.S. Environmental Protection Agency (EPA) and are scheduled for clean-up. The responsible party as identified in the EPA regulations – usually the site owner or past occupant – must pay for the clean-up costs.
The types of training for the general site worker are as follows: 40 Hour, 24 Hour, 8 Hour Annual Refresher, 8 Hour Site Supervisor, and Incident Command. The standard is performance-based, and the type of training will need to meet the job function. For the training titles listed, the 40 hour course is designed for workers who are exposed to hazardous materials above the OSHA Permissible Exposure Level (PEL). Once work conditions exceed the PEL, respiratory protection is required.
The 24 hour course is designed for workers who have a temporary or short work task at a HAZWOPER site. Usually, these workers are not exposed to hazardous substances or materials above the PEL, and no respiratory protection is required. An 8 hour refresher is required for both the 40 hour and 24 hour designations. Failure to receive the annual refresher can involve the lapse of certification and associated non-compliance status from OSHA.
OSHA HAZWOPER regulations also require that at least one person per work group have the 8 hour supervisor training. The incident commander session is usually reserved for emergency response, but can sometimes be invoked for a HAZWOPER site.
Which Workers at Permitted Hazardous Waste Treatment, Storage and Disposal Facilities Need Training?
There is a 24 hour training requirement for workers involved in hazardous waste operations, and an associated 8 hour refresher. This work typically consists of managing and handling Resource Conservation and Recovery Act (RCRA) hazardous wastes. EPA has regulations that declare a waste as a hazardous waste.
When and Where Did HAZWOPER Training Online Begin?
The online HAZWOPER training industry began in 1998 when our company published the first online HAZWOPER Refresher training course. Since this time, many companies have seen the great value that online training provides. Many credible reports indicate that online training provides better comprehension of material and a paper trail to ensure compliance with OSHA HAZWOPER regulations.
U.S. OSHA has also seen the great value in online training and currently adminsters the OSHA Outreach Training program from their training institute in Arlington Heights, Illinois. While HAZWOPER training is excluded from their offerings, they have initated the OSHA 10 and 30 hour program with great success. More and more employers are deciding to train their employees online rather in a conventional classroom training setting. U.S. OSHA has accepted the use of our HAZWOPER Hands-on Simulator® for online delivery and a copy of their letter is available in the download section of our website. This is yet another step closer to OSHA fully accepting online regulatory training.
Training for Marine Oil Spills
OSHA has issued special directives or guidance documents with respect to marine oil spill cleanup. According to these documents, some of the HAZWOPER training requirements maybe be lessened. For example, a worker retrieving tar balls on a beach may not need the 40 hour course. The beach workers could possibly receive a specialized 8 hour course and be in compliance with OSHA. All of this depends upon the OSHA permissible exposure levels (PELs) of the constituents in the oil.
For workers who are on a vessel or boat and the PELs are exceeded, these workers would be required to be trained to the HAZWOPER 40 standard. Cleanup of oil on the water surface tends to be more of a occupational hazard than retrieving tar balls on a beach. Download OSHA HAZWOPER Training Guidance Document for Marine Oil Spills.
Clandestine Meth Labs
How Does HAZWOPER Relate to Clandestine Meth Lab Remediation?
OSHA requires that personnel entering a suspected clandestine methamphetamine (meth) lab to be trained to the HAZWOPER standard. Meth labs are considered to be very dangerous operations for law enforcement personnel. These labs are also very dangerous for people who “cook” or produce meth. Buliding or land owners are responsible for cleaning or remediation of these clandestine labs. There are several states that have promulgated regulations governing the remediation of meth labs but anyone entering one of these labs must first be trained to the HAZWOPER level. The state regulations primarily address the cleanup action levels, training, owner responsibilities and then rely on the HAZWOPER standard for the protection of meth lab remediation workers.
The 40 hour HAZWOPER course for general workers is the one to choose if you are involved with a meth lab remediation project. This course provides the fundamentals used for protection of personnel in order to safely carry out cleanup operations. Also, because of the hazardous waste that is generated during lab decontamination, the Resource Conservation and Recovery Act (RCRA) regulations apply. Personnel must be trained to properly handle, treat and/or store hazardous wastes. RCRA training is required for anyone who handles or manages hazardous wastes.
Uniqueness of the HAZWOPER Certification Regulation
The OSHA HAZWOPER regulation is unique in that it is primarily a performance based standard, contains minimum time requirements for courses, is sometimes competency based, maybe administered at the federal or state level, and covers 3 categories of worker classifications. As many regulations impact both the private and public sectors so does the HAZWOPER standard. But what makes this regulation so unique is that it is a performance based standard. Employers are responsible for adequately training their employees but to what level? Similar jobs in different industries will have different methods of complying with the OSHA regulations.
An employer must determine exactly how health and safety regulations appliy to them. Professional emergency responders would obviously have to be trained at a far greater level than an engineer or scientist who is conducting groundwater sampling at a contaminated site.
The employer must conduct a training needs analysis to identify any gaps between regulations and the job an employee is performing. A training needs analysis is critical to ensuring compliance with health and safety regulations and protecting employees. Usually a matrix is prepared to cross-reference the regulations to the job. Once this is accomplished, any gaps for deficient training are noted and employees must receive the appropriate training.
In order to adequately protect human health and the environment from exposure to hazardous waste and contaminants, Congress enacted several regulatory programs to protect the nation’s air and water resources, as well as ensure the safety of employees. The one requirement by Congress to OSHA was that certain courses should have minimum time requirements. OSHA promulgated the HAZWOPER regulation with 8, 24 and 40 hour time requirements for different courses. This was to ensure the correct scope and breadth of various topics in the courses. Some of the initial and refresher courses are competency based as well.
For state regulatory agencies that are under the purview of U.S. OSHA, they can administer their own regulatory programs which include HAZWOPER programs. U.S. OSHA approves of the state plan to enforce worker health and safety regulations. These states are commonly know as State Plan States. There are approximately 27 State Plan States with more applying for OSHA approval. An employer must comply with the regulatory agency that has primacy for their respective state. The state regulations must be at least as stringent as the federal standards. Typically, the regulations are almost identical but there are some differences depending on your state. You should be sure to consult with your training provider before taking any training.
HAZMAT Certification Training for Ebola Virus
Ebola viruses are transmitted through direct contact with blood or body fluids/substances (e.g., urine, feces, vomit) of an infected person with symptoms or through exposure to objects (such as needles) that have been contaminated with infected blood or body fluids.
The decontamination of buildings, dwellings, homes, facilities, etc., contaminated with the Ebola virus would be under the purview of either Federal or State OSHA regulations. If you work in an OSHA Plan State, you would need to comply with your state regulations. If you do not have a state regulatory agency, you would need to comply with the Federal OSHA regulations. These regulations can be found in Title 29 Code of Federal Regulations (CFR) Part 1910.120. While the OSHA regulations pertain to employers and employees, any business or organization employee decontaminating an Ebola site must receive at a minimum 24 Hour HAZMAT Technician Level training.
Hospital personnel receiving incoming infected or suspected infected patients need to complete the HAZWOPER First Responder Operations (FRO) training or First Receiver training. While OSHA has not formally developed regulations for First Receivers at Hospitals, they have issued guidance documents. Typically, a First Receiver would complete a FRO course with an emphasis in etiologic agents. OSHA requires that FRO training be at least 8 hours in duration. What HAZWOPER or HAZMAT training should I take?
HAZWOPER / HAZMAT Training and Certification Sequence
One of the more frequent questions we receive is “what is the sequence for General Site Personnel HAZWOPER training and certification”? The HAZWOPER training sequence for certification varies according to your job function. For general site cleanup professionals, either the 40 hour or 24 hour course is completed first as there are no prerequisites for either of these courses. The primary difference between these two courses centers on the OSHA Permissible Exposure Limits (PELs). If you are exposed to a hazardous substance(s) at or above the OSHA PEL, then you must complete the 40 hour HAZWOPER course. If your work does not involve meeting or exceeding the OSHA PELs, then you can complete the 24 hour HAZWOPER course. As a general rule of thumb, if you are visiting a contaminated site, performing short work tasks such as surveys or groundwater sampling, or any other type of work activity with little or no expectation of exceeding the OSHA PELs, most people complete the 24 hour course. Individuals who are actively involved in the remediation of a contaminated site must complete the 40 hour HAZWOPER.
For HAZMAT emergency response professionals, there are 5 different job classifications that come under this level. These classification are generally referred to as someone possessing a HAZMAT Certification status. Annual refreshers are required for the 5 classifications. These are competency based re-certification requirements and differ from the General Site Personnel refresher requirements that must meet study time requirements for each course. The First Responder Awareness course is usually the entry course for most people seeking an emergency response certification. As the title of the course suggests, it is an awareness level course and people are limited in response actions taken. The next level is the First Responder Operations course which allows a person to respond defensively to a release of hazardous substances. The next level deals with HAZMAT Technicians and HAZMAT Specialists. These levels are almost identical but the Specialist training focuses more on chemical training and specialty operations such as patching chlorine gas cylinders. Finally, the Incident Commander is responsible for overseeing all HAZMAT emergency response operations. Incident commanders must complete an initial 24 course followed by a competency based annual refresher.
For RCRA TSD professionals, the training and certification sequence is much more straight forward. The entry job classification is the 24 hour HAZWOPER training for TSD facilities followed by an 8 hour annual refresher.
HAZWOPER Training Innovation
HAZWOPER Training Innovation
Everything we do is designed around providing good competent HAZWOPER training for our clients. We’re especially proud of our advances in regulatory compliant training. We do our best to work with regulatory officials to ensure we are providing not only engaging and user friendly courses but training that you know is in compliance with U.S. OSHA and various U.S. OSHA approved Plan States. (Please see U.S. OSHA HAZWOPER training interpretation letter). When we design and publish a course, we use our Safetyneering™ process that produces what we believe to be the best online training available. Our courses are packed with useful information but delivered in an aesthetically pleasing format. HAZWOPER Course Demo