Chapter 3: Training Requirements

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Training Requirements

Objectives: By the end of this section, participants will be able to determine what the minimum training requirements are for selected employee types.

Why this section is important: An employer who does not comply with HAZWOPER training requirements incurs considerable potential liability (in the forms of OSHA fines, lawsuits, worker compensation insurance rate hikes, criminal charges, etc.)

Objectives of the Training Program

The Training Program

Initial Training Requirements

Recommended Training by Job Category

Site-specific Training

Elements to be Covered in Site-specific Training

Objectives of the training program for employees engaged in hazardous waste site activities are to:

Educate workers about the potential health and safety hazards they may encounter at the site

Provide the knowledge and skills necessary to minimize risk to worker health and safety

Provide thorough training in the proper use and potential limitations of safety and personal protective equipment

Ensure that workers can safely avoid or escape from emergencies

Employees may not work in an environment with the potential to hazardous waste exposure without training.

The Training Program must include:

Classroom instruction in a wide range of health and safety topics, demonstrations

"Hands-on" practice consisting of off-site drills that simulate site activities and conditions

On-site experience under the direct supervision of trained, experienced personnel

Annual refresher training to re-emphasize the initial training and to update workers on any new policies or procedures

Initial Training Requirements at Uncontrolled Hazardous Waste Sites
	Initial Training	Annual Refresher Training	Field Training

Clean-Up Operations
General Site Worker	40 Hours	8 Hours	24 Hours
Limited Site Worker	24 Hours	8 Hours	8 Hours
Supervisors / Managers of Hazardous Waste Workers	8 Hours	8 Hours	8 Hours

RCRA Operations	40 Hours	8 Hours	24 Hours

Emergency Responders
Awareness Level	Required, but no hours specified	Required, but no hours specified	None
Operations Level	8 Hours	Required, but no hours specified	None
Hazardous Materials Technician	24 Hours	Required, but no hours specified	None
Hazardous Materials Specialist	24 Hours	Required, but no hours specified	None
On-Scene Incident Coordinator	24 Hours	Required, but no hours specified	None

Recommended Training by Job Category
Training Topic	Emphasis of Training	General Site Worker	On-site Managers & Supervisors.	Health & Safety Staff
Blood, chemistry, and physics of hazardous materials	Chemical and physical properties; chemical reactions; chemical compatibilities	X	X	X
Toxicology	Dosage, exposure routes, toxicity, IDLH values, PELs, recommended exposure limits (RELs), TLVs.	X	X	X
Industrial Hygiene	Monitoring workers’ need for and selection of personal protective equipment	o	X	X
Industrial Hygiene	Calculation of doses and exposure levels; hazard evaluation; selection of worker protective measures.	o	X	X
Monitoring Equipment	Selection, use, capabilities, limitations, and maintenance	X	X	X
Hazard Evaluation and Recognition	Techniques of sampling and assessment.	X	X	X
	Evaluation of field and lab results	o	X	X
	Chemical & physical	X	X	X
	Risk assessment	o	o	X
Site Safety Plan	Safe practices, safety briefing and meetings, standard operating procedures, site safety map.	X	X	X
Standard Operating Procedures	Hands-on practice	X	X	X
Standard Operating Procedures	Development and compliance	o	X	X
Engineering Controls	The use of barriers, isolation, and distance to minimize hazards	X	X	X
Personal Protective Equipment	Assignment, sizing, fit-testing, maintenance, use, limitations, and hand-on training.	X	X	X
Personal Protective Equipment	Selection of Personal Protective Equipment	X	X	X
Medical Program	Medical monitoring, first aid, stress recognition	X	X	X
	CPR and emergencies drills	o	X	X
	Design and planning	o	o	X
	Implementation	X	X	X
Decontamination	Hands-on training using simulated field conditions	X	X	X
Decontamination	Design and maintenance	X	X	X
Legal and Regulatory Aspects	Applicable safety and health regulations	o	X	X
Emergencies / Accident Hazards Communications	Emergency help, self-rescue, drills, alarms, reporting	X	X	X
	Emergency response, investigation, and documentation	o	X	X
	Hazard Communication	X	X	X
	Employee Rights	X	X	X
X: Required Topic, o: Recommended Topic

Site-specific Training

Must Enable Site Workers to:

Identify the hazards present on-site

Determine the medical surveillance requirements

Assess pertinent elements of the Health & Safety Plan, and

Assess operating practices and procedures including the use of personal protective equipment and proper engineering controls

Elements to be Covered in Site-specific Training

Required Training

Names of personnel and alternates responsible for site safety and health

Safety, health, and other hazards present on site

Use of personal protective equipment

Work practices by which the employee can minimize risks from hazards

Safe use of engineering controls and equipment on the site

Medical surveillance techniques and recognition of symptoms and signs that might indicate overexposure to hazards

An emergency response plan meeting the requirements for safe and effective responses to emergencies, including all necessary equipment

Confined space entry procedures

A spill containment program

Decontamination procedures

Initial Training Requirements at Uncontrolled Hazardous Waste Sites