What is a HAZWOPER Event?
A HAZWOPER event occurs whenever any of the following scenarios below take place. An event is triggered by any of 3 scenarios listed in U.S. OSHA HAZWOPER regulations 29 CFR 1910.120 or EPA Protection of Environmental regulations located in 40 CFR.
A release of hazardous susbstance(s) occurs and emergency response operations are required for the release or substantial threats of releases of hazardous substances. This includes any releases or threats of releases from Resource Conservation and Recovery Act (RCRA) Treatment, Storage and Disposal Facilities (TSDFs).
A site is contaminated and corrective action clean up and restoration is deemed necessary by the U.S. EPA RCRA regulations. Facilities that have an EPA Identification Number and a RCRA Part B permit will also have corrective action implications.
Clean-up operations from contaminated sites as ordered by Federal, State or local governments. These typically occur at uncontrolled hazardous waste sites which include but not limited to sites placed on the National Priorities List (NPL) or state priority lists. This could also include initial and subsequent investigations to ascertain the scope, magnitude and extent of contamination at a site. Some of these clean-up operations can also be voluntary.
HAZWOPER Scenarios Summary
Hazardous substances and products are stored in various containers, tanks and places at different facilities. It is not uncommon that products are stored in underground storage tanks, above ground storage tanks and drums. Hazardous substance releases can also occur on public highways, water, railways and from the air. Depending upon the nature of the response or clean up effort, different training is required for workers. So there are 3 main HAZWOPER events that can occur - emergency response, corrective action for a RCRA facility and clean up operations from contaminated sites.
In the event of an emergency response involving people who offensively engage in handling clean up operations they must be able to identify, react and control the situation to prevent a more serious problem. The initial training required for First Responders is HAZMAT Technician training. These offensive response personnel must have adequate OSHA training and be OSHA HAZWOPER Certified. If you are a person whose role is to receognize a release or threat of a release and call for First Responders, you will need either the HAZWOPER First Responder Operations or HAZWOPER First Responder Awareness training.
Corrective action cleanup as mandated by U.S. EPA RCRA regulations require that a full assessment and characterization of a particular site be performed. This usually involves researching historical records, conducting interviews of employees and installing groundwater monitoring wells to fully delineate the contaminant plume. Personnel conducting work at these sites will initally need the 40 hour HAZWOPER or 24 hour HAZWOPER training.
Clean up operations from abandoned sites or sites not under the regulatory purview of U.S. EPA RCRA regulations can also invoke a HAZWOPER event. These typically involve a lengthy clean up and restoration process as many of these sites are heavily contaminated. Depending upon the job function of an individual, different OSHA training is required. The same HAZWOPER training is required for personnel for this scenario as listed above for scenario 2. View list of HAZWOPER training requirements.
OSHA has stated in many interpretation letters that 40 hour and 24 hour HAZWOPER sessions require site-specific hands-on learning on the actual Personal Protective Equipment (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 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.
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