Gulf Oil Spill HAZWOPER Training Guidance
HAZWOPER Requirements that Apply to Marine Oil Spills
The National Contingency Plan (NCP) defines oil as any kind of oil in any form, including petroleum, fuel oil, sludge, oil refuse, and oil mixed with wastes but not dredged spoil (dirt or rock). Response actions conducted under the NCP must comply with the provisions of HAZWOPER. You’ll find this requirement in 40 CFR 300.150. Therefore, if your workers are participating in a response action under the NCP, you must have an occupational safety and health program consistent with HAZWOPER and you must train your workers according to HAZWOPER’s training requirements. This applies whether the responsible party or a government agency is directing the cleanup.
For marine oil spill emergency response, the HAZWOPER provisions that most directly apply include:
• Emergency response operations in HAZWOPER paragraph 29 CFR 1910.120 (q), and
• Post-emergency response cleanup operations in paragraph 29 CFR 1910.120 (q)(11).
See also emergency response training provisions in paragraph (q)(6), and post-emergency
response training requirements in paragraph (q)(11).
The OSHA booklet below will provide in depth information in order for you to plan which training course you will need. In essence, either the 24 or 40 hour HAZWOPER course will be your choice in the vast majority of situations. Your best move at this time is to have the maximum amount of training (40 hour HAZWOPER course) due to the rapidly changing work tasks associated with the gulf oil spill cleanup. You will want to have the best training possible to be of the most help.
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OSHA Accepts our HAZWOPER Hands-on Simulator®
In an interpretation letter dated February 4, 2009 OSHA stated that our exclusive HAZWOPER Hands-on Simulator® is acceptable when used in conjunction with site specific training. Site specific hands-on training on the actual equipment an employee will be using is required for both online training and public seminar (open enrollment) classroom training. (If you thought you met the OSHA requirements by sending your employees offsite to a public seminar training class, please read the detailed explanation below). Employers can now train their employees online for the 40 or 24 hour HAZWOPER courses and then conduct site specific hands-on training on the actual equipment an employee will be using in their job.