Hazardous Training
When designing a training program to satisfy the requirements listed in 29 CFR 1910.120 and 29 CFR 1926.65( commonly referred to as HAZWOPER) it is best to keep the focus on the big picture, such as what is the goal of the training. This should be based on the assigned or potential future tasks for the affected employees. Also, if the task or assignments are well thought out, several other training requirements can be incorporated into one or two programs. This will ensure consistent concepts and policies for the employees and substantially reduce the cost of redundant training.
The HAZWOPER training requirements can be broken down into three basic focus areas based upon anticipated job assignments or duties. The first area is referred to as the Hazardous Waste Site Worker training. This is found in paragraph (e) of the standard. Although it is referred to as Hazardous Waste Site Worker, hazardous substances also apply, so activities such as underground storage tanks with petroleum products can require training under this paragraph. For those removing the USTs excavation training may be needed, while those entering the tanks to clean them will need confined space training. Both of these topics can be addressed in a well designed HAZWOPER course.
The initial training should be 40 hours in length. Although there is a provision for a 24 hour course in the regulation for those people with less risk of contaminant exposure, the term “40 hour “ has become a standard in most contract requirements. And if the person has previously taken a 24 hour course, there is no practical way to make up the time to meet the 40 hour requirement. Some training providers may offer this option, but it is poor training practice. The 24 hour course has the same subject areas as the 40 hour, just less detail, so it is impractical to try and add 16 hours later.
In addition to the 40 hour initial training, the employer must document 3 days of on the job experience before the employee meets the requirements completely. The 3 days of experience should be under the supervision of some one who has completed the 8 hour hazardous waste site supervisor training.
The supervisor training is taken once by those whom supervise or manage the on site activities of others. This is in addition to the 40 hour training.
The second part of the HAZWOPER training relates to workers at hazardous waste treatment, storage and disposal facilities. 24 hours of training are required initially and 8 hours annually.
The third focus area is for emergency response. This area is explained in great detail in a separate information sheet.
Other related training requirements that could be integrated into a comprehensive training session include; hazard communication, DOT hazardous materials safety, confined space entry, bloodborne pathogens, and trenching and excavation.
Please feel free to contact us at 414-427-9844 to discuss customized training programs that are fit to your needs.