HAZWOPER training for hazardous waste treatment, storage, and disposal facility (TSDF) personnel is required by 29 CFR 1910.120(p) if work at the TSDF involves employee exposure or the reasonable possibility for employee exposure to worksite safety or health hazards.
- Workers at TSDFs with corrective actions involving cleanup must do the full 40-hour training. The trainer must have completed a training course for teaching the subjects presented in the worker training course.
- Workers at TSDFs that are not subject to corrective action involving cleanup operations but where employees are or may be exposed to safety and health hazards are not subject to the more comprehensive training requirements for uncontrolled waste sites. However, such workers need 24 hours of initial training and 8 hours of annual refresher training (i.e., complete their refresher training within 12 months of their initial training or previous refresher training) to enable them to perform their assigned duties and functions in a safe and healthful manner so as not to endanger themselves or other employees.
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- Workers who occasionally enter a corrective action or cleanup site work area (for example, groundwater monitors or surveyors) need 24 hours of off-site training and 1 day of supervised field experience.
- If there is no reasonable possibility for employee exposure, the HAZWOPER standard and its training requirements do not apply. For example, if administrative employees do not enter work areas where hazardous materials are present, they do not need HAZWOPER training. However, they may need some training under the federal EPA’s TSDF training rules (40 CFR 264.16).
Emergency Response Training
Employee members of TSDF emergency response organizations must be trained to a level of competence in the recognition of health and safety hazards to protect themselves and other employees. Training for such members must include the following information:
- Recognition of health and safety hazards
- Safe use of control equipment
- Selection and use of appropriate PPE
- Safe operating procedures to be used at the incident scene
- Techniques of coordination with other workers in order to minimize risks
- Appropriate response to overexposure from health hazards or injury to themselves or other workers
- Recognition of subsequent symptoms that could result from overexposure
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You need not provide complete emergency response training to all workers if there are a sufficient number of workers with specialized training to control emergencies.
However, the remaining workers must have received awareness training to be able to recognize that an emergency response situation exists and that fully trained workers need to be called to handle the situation. Such employees should be given a site-specific safety briefing and be made aware of procedures in case of an emergency incident.
You may also decide to use outside emergency response personnel and to provide only awareness training to staff.
Certification of Training
You must certify that all covered employees have completed the training required and certify each employee’s competency at least annually. You must record and maintain the method used to demonstrate competency for certification of training.
In tomorrow’s Advisor, we’ll talk more about HAZWOPER requirements and tell you about BLR’s comprehensive HAZWOPER Training Library, the program that makes training easy and affordable.