HAZWOPER training isn't for amateurs. OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120) puts a lot of emphasis on training, both for employees and for trainers. And not just anyone can be a trainer. The standard specifies that HAZWOPER trainers themselves need to be trained, or have equivalent academic credentials and instructional experience. This means, for example, that supervisors and managers can't provide training unless they have already been trained to do so. In fact, supervisors and managers on hazardous waste sites must receive the same kind of training as other employees, plus an additional 8 hours of specialized training in subjects that will allow them to supervise others.
HAZWOPER training is highly job-specific. The OSHA standard requires that employees may not participate in field activities "until they have been trained to a level required by their job function and responsibility." The number of hours of required training varies according to the type of worker:
- Regular site workers who may be exposed to hazardous substances need at least 40 hours of off-site training, plus at least 3 days of supervised field experience.
- Regular site workers (or workers who come to the site occasionally for specific limited tasks) whose duties have a very low risk of exposure need at least 24 hours of off-site training plus 1 day of supervised field experience.
- Limited-duty or occasional site workers whose job duties change such that they are regularly exposed to hazardous substances must receive the additional 16 hours of off-site training and 2 days of supervised field experience.
- Employees who can demonstrate that they already have equivalent training and experience need not undergo initial training (of course, it is the employer's responsibility to make sure that the "equivalent" training is adequate).
- All employees (including supervisors) must receive at least 8 hours of refresher training at least annually.
Why It Matters...
- By definition, sites covered by HAZWOPER contain substances that could endanger the health of employees and, potentially, the general public.
- OSHA cares a lot about HAZWOPER training—its standard covers training requirements extensively, with an appendix on training guidelines.
- In FY 2004, there were more than 200 OSHA citations for violations of the HAZWOPER standard.
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HAZWOPER training should include plenty of "hands-on." Of course, adequate training is about more than just counting hours. That's why, for example, computer-based training (CBT) for HAZWOPER isn't enough all by itself. According to OSHA, CBT training should be accompanied by opportunities for Q&A, discussions of actual incidents and situations, and hands-on assessments of employees' knowledge. Depending on their specific job duties, types of hands-on training might include:
- Putting on and removing protective clothing
- Putting on and removing a respirator
- Cleaning and inspecting a respirator
- Conducting sampling of potentially contaminated air, soil, or water
- Demonstrating safe and proper ways to handle containers of hazardous materials