HAZWOPER Hands on Training

Throughout our professional careers, we have engaged in communication with the Directorate of Enforcement Programs at the U.S. Occupational Safety and Health Administration (OSHA) in Washington, D.C., specifically concerning Hazardous Waste Operations and Emergency Response (HAZWOPER) training. These discussions consistently revolved around the practical aspects of the HAZWOPER 40 or 40 hour HAZWOPER and 24 hour HAZWOPER training. OSHA has set forth precise requirements for the content and execution of this training, as outlined in OSHA regulation 29 CFR 1910.120 Appendix E (Non-Mandatory Guidelines), which indicates that hands-on training must complement HAZWOPER courses. Although Appendix E is not a mandatory regulation, OSHA maintains clear expectations regarding its implementation.

The core message conveyed to OSHA field enforcement offices is that individuals undergoing HAZWOPER training must receive instruction using the exact model and type of Personal Protective Equipment (PPE) they will use in their respective roles. It has been emphasized that generic classroom or seminar-based HAZWOPER training on respirators, for instance, does not align with OSHA's expectations. In a classroom setting that accommodates students from different employers, the likelihood of the instructor possessing the precise PPE relevant to each worker's job is slim. Therefore, it is imperative that individuals receive hands-on training with the actual equipment and PPE they will use, a requirement that cannot be fulfilled through classroom instruction, online training, simulators or videos. Instead, employers must conduct site-specific hands-on training using the authentic equipment their employees will encounter.

Notably, HAZWOPER certification is a shared responsibility between the instructor and the employer, a principle that has been consistently upheld. Given the employer's primary role in safeguarding their employees' health and safety, their direct knowledge of specific job tasks and site conditions positions them as the natural candidates to administer the hands-on and PPE aspects of the training.

In essence, this approach aligns with what competent employers have been doing all along, as the HAZWOPER training standard is performance-based. We continue to provide the academic portion of the training online, with the employer taking responsibility for training employees on the exact make and model of equipment they will use in their roles. In our numerous interactions with employers, it appears that many are already following this practice.

It is crucial to distinguish between generic hands-on training offered in public seminars and site-specific hands-on training. If your employees have attended a public 24 hour HAZWOPER or 40 hour HAZWOPER training seminar and relied solely on this training for hands-on experience (assuming it was conducted), it's important to note that this does not meet the OSHA standard. OSHA holds the employer accountable for ensuring site-specific hands-on training is provided, not the training provider.

We take pride in collaborating with some of the most diligent Health and Safety managers in the industry, recognizing that their top priority is the safety of their workforce. We are grateful for the trust many companies and individuals have placed in us for their HAZWOPER training needs, always prioritizing the safety and well-being of all parties involved. The clarification regarding hands-on training requirements is a welcome development in our ongoing commitment to maintaining high safety standards. OSHA Mentor provides 40 hour HAZWOPER, 24 hour HAZWOPER and the HAZWOPER 8 hour refresher training courses.

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