HAZWOPER Training Requirements for TSDFs

Under the requirements, employees who have received emergency response training under OSHA’s HAZWOPER rules do not need to receive separate emergency response training under Resource Conservation and Recovery Act (RCRA) rules as long as the overall training program includes all of the elements of the RCRA training requirements.

HAZWOPER training for hazardous waste treatment, storage, and disposal facilities (TSDF) personnel is required if work at the TSDF involves employee exposure or the reasonable possibility for employee exposure to worksite safety or health hazards. If there is no reasonable possibility for employee exposure, the HAZWOPER standard and its training requirements do not apply.

Workers at TSDFs with no corrective actions involving cleanup. 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. The rule doesn’t specify whether any of the initial training is required to be on-site.

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Workers at TSDFs with corrective actions involving cleanup. Workers at these sites 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 who occasionally enter a corrective action or cleanup site work area. Examples of these employees are groundwater monitors or surveyors. These employees need 24 hours of off-site training and 1 day of supervised field experience.

Employee members of facility emergency response organizations. 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 personal protective equipment (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

Emergency response awareness training. Employers need not provide complete training to all workers if there is a sufficient number of workers with specialized training to control emergencies. 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.

Employers may also decide to use outside emergency response personnel and to provide only awareness training to staff. Arrangements must be made in advance with the outside group that requires a response in a reasonable amount of time. In-house workers must receive sufficient awareness training to recognize that an emergency response situation exists that requires outside help.

Administrative staff. 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.

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