HAZWOPER (Hazardous Waste Operations and Emergency Response) was created by OSHA to train and protect workers who work with, respond to, and/or clean up hazardous substances for both routine and emergency situations.
Industries and workplaces that require HAZWOPER training include but are not limited to chemical manufacturing, industrial sites with large amounts of chemicals or hazardous materials onsite, construction, heavy equipment operators or laborers working at hazardous waste (Superfund) sites, emergency responders, environmental remediation, and waste management.
The HAZWOPER Standard
The HAZWOPER Standard is an OSHA standard, but it does have some crossover with EPA and is referenced in the EPA regulations because the majority of it is how to protect workers at RCRA corrective action or TSDF facilities. The regulations for HAZWOPER can be found at 29 CFR 1910.120 for general industry, and it has a twin in the construction standards at 29 CFR 1926.65.
The standard has sections (a) through (q) and it’s divided into three major parts.
The first part is instructions for those doing cleanup operations (forced or voluntary) at RCRA corrective action sites or uncontrolled waste sites. That means places where there is contamination that’s being cleaned up such as at a Superfund site, or a place like a brownfield that’s getting cleaned up to be redeveloped. This part of HAZWOPER takes up all the requirements (a) through (o).
Section (p) is for those working at TSDF facilities. All workers at TSDF facilities are regulated under EPA’s RCRA hazardous waste regulations at 40 CFR parts 264 and 265.
The last part, section (q) is the part for those conducting emergency response for substantial threats of releases.
Training Requirements
Training requirements for each section may have a lot of the same types of topics that need to be covered, but how you apply them is different because the situations in which they are needed are different.
40 Hour
This training is for workers at clean up operation sites (forced or voluntary cleanup), RCRA corrective action sites or uncontrolled waste sites where the hazards are already known. This would be training for everything discussed in the standard’s sections (a) through (o). Supervisors and workers at those sites must have this training. This class is not for those who come across incidental spills where the potential chemical spilled can vary, it’s for workers in a known hazardous environment and are dealing with exposures to those known chemicals. So for example, it would be for a remediation worker, backhoe operator who could be excavating contaminated dirt, someone working in a Brownfield site, or a city maintenance worker in a town that’s been contaminated by a certain industry. 40 Hr. classes focus more on understanding the daily hazards and minimizing risk, PPE, medical surveillance, site-specific HAZWOPER planning, and spill containment and confinement.
24 Hour
24-Hour HAZWOPER is the Hazmat Technician class for workers responding to emergency spills, that is those who will identify the material spilled, stop the spill from occurring and cleaning it up. Contents include how to quickly determine the hazards of what was spilled, response actions needed, and how to protect yourself and others from the hazards created by the spill. This class covers Section (q) of the HAZWOPER Standard and may also be appropriate for some TSDF facility workers, depending on their job function. Example students would be a company hazmat team member who would actually participate in stopping the spill or cleaning it up.
8 Hour/Refresher
The 8-hour HAZWOPER training course is considered the “refresher” course to maintain HAZWOPER certification and must be taken annually after the 40-hour and/or 24-hour course. The 8-hour training focuses on regulatory updates and provides opportunities to brush up on safe handling skills. There are not a lot of rules on what is to be covered other than making sure the class, just suggestions. Suggested content includes any updates or changes to the rules or the materials covered in HAZWOPER, a review of and retraining in the relevant topics covered, sharing of students on their work experiences with HAZWOPER in the past year, review of any newly developed equipment or PPE, and review of any new procedures, if applicable.
Other HAZWOPER Training Mentioned in the Standard
The HAZWOPER Standard does reference other types of training related to the emergency response side.
First Responder Awareness and First Responder Operations – These classes are for those who come across a spill and teaches them what to do about it. These classes are less about what TO do and more about what NOT to do. The awareness class teaches about what hazardous substances are, who to contact when you see a spill, and the limits on what you can do in responding to it. The First Responder Operations class includes all of the awareness training plus more on how to select and use PPE, basic hazardous materials terms and how to respond in a defensive fashion to keep it from spreading without trying to trying to stop it or clean it up. It would allow a worker to put out materials to stop the spill from spreading or entering an area. It’s not until the 24 Hr. class where the worker can actually jump in, stop the spill, and clean it up.
Specialist – This emergency response training is more advanced training for those who would be more of an expert in the substances than a technician would. They would provide specific knowledge about the chemical, have more advanced knowledge of hazard and risk assessment techniques, chemical terminology and behavior, and would be a site liaison for government authorities to work with.
Incident Commander – This person would be the one assuming control of the emergency incident and would know how to implement an incident command system, organize assistance, and how to coordinate with local, state and federal response teams and agencies.
Operations Level vs. Technician Level
Some companies will provide a 40-Hr. Technician Level course, which isn’t the same as the 40 Hr. Operations Level course. A 40-Hr. Technician Level course would be the 24 Hr. course plus two extra days of training that may include more on hazmat specialist or incident command topics. This would be for emergency responders only, not hazardous waste site workers. When you’re signing up for HAZWOPER training, make sure you’re getting the course you need.
What happens if you miss an annual refresher?
We get this question all of the time, so we though this would be a good place to answer this. Although it’s the best policy to maintain your certification within 12 months, OSHA has been somewhat understanding, especially if you use your HAZWOPER skills on a regular basis. Once you realize you are past due, register for the next available class. If it’s been more than 2 to 3 years, it is up to your employer to decide if you are still qualified. There is an OSHA interpretation letter you can refer to which explains this further.
Need HAZWOPER Training?
Whether your role demands the full 40-hour certification, the 24-hour course, or the annual 8-hour refresher, iSi has the courses you need to get and keep your HAZWOEPR certification. Email us at training@isienvironmental.com, or call us at (316) 264-7050 and we’ll get you signed up!