What is HAZWOPER Training?
Each year, we produce over 400 million tons of hazardous waste in the U.S. Some of it's is toxic, some of it's corrosive, and some of it is prone to igniting or exploding. Workers all over the country keep the general public safe by properly storing, treating, and disposing of the stuff. And to keep them safe, we have HAZWOPER regulations and training.
The History and Importance of HAZWOPER TrainingIn 1976, Congress passed the Resource Conservation and Recovery Act (RCRA). It regulates the handling of hazardous waste from "cradle to grave." But we had already been mishandling waste for decades. By 1978, it was clear that we needed a system to deal with pre-existing violations. A few extreme cases were making headlines. One was widespread illness in the Love Canal neighborhood built on top of buried waste. Another involved contaminated run-off from the "Valley of the Drums," a private Kentucky dump filled with thousands of deteriorating barrels. In response, Congress passed the legislation we know as Superfund. Half a dozen years later, they asked the Occupational Safety and Health Administration (OSHA) to develop protections for the workers involved in hazardous waste cleanup and disposal. The Department of Defense (DoD) already had protocols for HAZardous Waste OPerations (HAZWOP) to deal with a plutonium production site. OSHA built on these with input from several other agencies to create the HAZardous Waste OPerations and Emergency Response (HAZWOPER) standard. It published HAZWOPER in 1990 under 29 CFR 1910.120.
Who Needs to Take HAZWOPER Training?OSHA designed HAZWOPER training to reduce the exposure risk of workers who clean up, treat, store, and dispose of hazardous waste. This includes three basic job profiles (and their supervisors) covered by the HAZWOPER standard:
- Job: containing, controlling, and stabilizing an emergency involving hazardous materials
- an accidental release of hazardous substances OR
- a site with the serious threat of such a release
- until the situation is stabilized
- Threat: nature and extent unknown
- Protected Under:120(q)
- local fire departments responding to chemical fires or overturned HazMat trucks
- facility workers responding to leaking storage or an uncontrolled spill
- railroad emergency response teams dealing with a ruptured tank car
Uncontrolled Hazardous Waste Site Operators
- Job: cleanup and remediation
- Location: uncontrolled hazardous waste sites, which:
- are identified as such by federal, state, or local governments
- have an accumulation of hazardous substances that create a threat to the health and safety of individuals, the environment, or both (1910.120(a)(3))
- include stabilized emergency sites AND older sites where potential contamination has been discovered
- Threat: identity and concentration are often unknown (site still being characterized)
- Protected Under:120(b)-(o)
- Examples: Workers at Superfund sites, Brownfield sites, or abandoned industrial sites
Treatment, Storage, and Disposal Facility (TSDF) Personnel
- Job: handling waste during treatment, storage, and disposal
- Location: TSD facilities regulated under RCRA, which are:
- controlled waste facilities processing waste from uncontrolled sites
- built and permitted to receive, treat, store, and dispose of hazardous waste
- Threat: identity and concentration are known
- Protected Under:120(p)
- Workers treating hazardous waste before disposal
- Workers handling waste at an RCRA landfill
Who Doesn't Need HAZWOPER Training?Everyone else. If you don't fit into one of those three categories (or supervise people who do), HAZWOPER training wasn't designed for you. Even if an operation falls under HAZWOPER's scope, employees who work near a characterized contaminated zone but never enter it may be exempt from training requirements (think: security guard). Employers need to demonstrate that their exposure isn't a "reasonable possibility," though. Often, employers like hospitals put employees who might encounter hazardous waste through HAZWOPER training just to be cautious. But OSHA supports competency-based training specific to their exposure risk instead.
Types of HAZWOPER CoursesThere are 3 different HAZWOPER courses: 24-Hour, 40-Hour, and 8-Hour. The 24- and 40-Hour courses are initial training, for those new to HAZWOPER work. The 24-Hour course is for workers who will have minimal contact with hazardous materials. It should be followed by one day of supervised fieldwork. The 40-Hour course is for workers who will handle hazardous material regularly. It's followed by three days of supervised fieldwork. Either type of worker can take the 8-Hour refresher course.
How Often is HAZWOPER Training Required?HAZWOPER employees need refresher training once a year. Not necessarily all at once—you can divide training up throughout the year as long as you complete all hours before your anniversary.
HAZWOPER: Online or In-Person?Online training can be an efficient and effective way to learn concepts. It comes with benefits like higher retention rates and lower costs. But OSHA is very clear that initial HAZWOPER training can't be handled entirely online. You need to include an in-person session to cover:
- PPE Practice. Students need supervised practice with the use of respirators and full protective gear. They need to put the equipment on and take it off multiple times. They need a qualified trainer checking their work. There is no viable substitution for in-person training.
- Site-Specific Training. You need to layer general safety knowledge with the protocols specific to their duties and employer.