The Definition of HAZWOPER

Definition of HAZWOPER

HAZWOPER stands for Hazardous Waste Operations and Emergency Response. It is the OSHA standard that protects workers who clean up hazardous waste sites, work at hazardous waste treatment, storage and disposal facilities, or respond to emergency releases of hazardous substances. The general industry version is 29 CFR 1910.120, and an identical standard for construction appears at 29 CFR 1926.65.

HAZWOPER is best known for its training hours, especially the "40-hour HAZWOPER" course, but the standard covers much more. It requires a written safety and health program, site characterization, site control, medical surveillance, PPE programs, air monitoring, decontamination, emergency response plans and specific roles for supervisors and incident commanders. It exists because work around uncontrolled hazardous substances combines unknown chemical exposures, heavy PPE, heat stress and unstable conditions in ways that ordinary workplace rules do not address.

The standard is often misunderstood in both directions. Some employers send every warehouse worker to a 40-hour class they do not need, while others assume HAZWOPER only applies to Superfund sites and miss the emergency response provisions that apply to any facility where employees are expected to respond to chemical releases.

Who HAZWOPER Covers

The standard applies to five groups of operations:

1. Cleanup operations required by a governmental body at uncontrolled hazardous waste sites, including sites on the EPA National Priorities List and state priority lists.
2. Corrective actions involving cleanup at sites covered by the Resource Conservation and Recovery Act (RCRA).
3. Voluntary cleanup operations at sites recognized by a government body as uncontrolled hazardous waste sites.
4. Operations at RCRA treatment, storage and disposal (TSD) facilities handling hazardous waste.
5. Emergency response operations for releases or substantial threats of releases of hazardous substances, regardless of where the hazard is located.

That fifth category is the one that reaches ordinary workplaces. A chemical plant, hospital, water treatment facility or distribution center that expects its own employees to stop and contain a significant release is conducting emergency response under HAZWOPER. Incidental spills that can be absorbed, neutralized or controlled by employees in the immediate area without posing a significant hazard are not emergency response.

The evacuate-only alternative

An employer that will evacuate employees during a release and rely on outside responders, such as the local fire department's hazmat team, does not need a HAZWOPER emergency response program. It must instead have an emergency action plan meeting 29 CFR 1910.38. This is a legitimate choice, but it has to be real: if supervisors routinely send people back in to shut valves or plug leaks, the employer is doing emergency response whether the plan says so or not.

HAZWOPER Training Requirements

Hazardous waste site workers

• General site workers, such as equipment operators and laborers, need at least 40 hours of initial instruction off the site plus a minimum of three days of actual field experience under a trained, experienced supervisor.
• Occasional workers who are on site only for a specific limited task, such as groundwater monitoring or surveying, and who are unlikely to be exposed above permissible exposure limits, need at least 24 hours of instruction and one day of supervised field experience. The same applies to workers regularly on site in areas monitored and found to be below exposure limits where respirators are not needed.
• Managers and supervisors directly responsible for site work need the same training as the workers they supervise plus at least eight additional hours of specialized training on topics such as the employer's safety program, PPE program and spill containment.
• Annual refresher: all of these workers need eight hours of refresher training every year.

TSD facility employees

Employees at RCRA treatment, storage and disposal facilities who are exposed to health hazards need 24 hours of initial training and eight hours of annual refresher training, or equivalent experience.

Emergency responders

Emergency response training is organized by the role a person plays, set out in 1910.120(q)(6):

• First responder awareness level: people likely to witness or discover a release, whose job is to recognize it and alert the right people. No minimum hours are specified, but competency must be demonstrated.
• First responder operations level: people who respond defensively to protect people, property and the environment without trying to stop the release, such as setting up dikes at a distance. At least eight hours of training, or demonstrated competency.
• Hazardous materials technician: people who approach the point of release to plug, patch or stop it. At least 24 hours of training at the operations level plus additional competencies.
• Hazardous materials specialist: people with more specific knowledge who support technicians and liaise with authorities. At least 24 hours of training at the technician level plus additional competencies.
• On-scene incident commander: the person who assumes control at the scene. At least 24 hours of training at the operations level plus competency in the incident command system and the employer's emergency response plan.

Responders must receive annual refresher training sufficient to maintain their competencies, or demonstrate competency annually.

Other Core Elements of the Standard

Site safety and health plan

Each cleanup site needs a written plan covering hazards, PPE, monitoring, site control, decontamination, emergency procedures and confined space entry where relevant.

Site control and decontamination

Sites are typically divided into an exclusion zone, where contamination is present, a contamination reduction zone, where decontamination happens, and a support zone. Decontamination procedures must be established before anyone enters an area where exposure is possible.

PPE levels

HAZWOPER uses the EPA's four levels of protection. Level A provides the highest protection, with a fully encapsulating vapor-tight suit and supplied air. Level B uses supplied air with splash-resistant clothing. Level C uses air-purifying respirators where contaminants are known and measured. Level D is ordinary work clothing for areas with no respiratory or skin hazards. Working in Levels A and B adds a serious heat stress burden.

Medical surveillance

Medical surveillance is required for employees exposed at or above permissible exposure limits for 30 days or more a year, those who wear respirators for 30 days or more a year, those injured or showing symptoms from an overexposure, and members of hazmat teams. Exams are required before assignment, generally every 12 months, at termination and after exposures.

Example of HAZWOPER

A municipal water treatment plant stored chlorine in one-ton cylinders. Its emergency plan said employees would evacuate and call the fire department during a leak. During a review, the safety coordinator found that night-shift operators had twice used an emergency kit to cap leaking cylinder valves themselves rather than wait for outside responders, because the nearest hazmat team was 45 minutes away. Those operators had awareness training only.

The utility decided its operators would respond to chlorine releases, so it built a HAZWOPER emergency response program. Four operators per shift completed hazardous materials technician training, the shift supervisors completed incident commander training, and everyone else completed awareness and operations training. The plant added medical surveillance and fit testing for the response team, ran quarterly drills with the fire department, and updated its written emergency response plan to match what people actually did.

Frequently Asked Questions: HAZWOPER

Does my company need 40-hour HAZWOPER training?

Only if your employees perform general site work at a covered hazardous waste cleanup site. Most industrial employers who respond to releases need the emergency response levels instead, which are based on role and competency. Workers at TSD facilities need the 24-hour TSD training. Match the training to the actual job rather than defaulting to the 40-hour course.

What happens if I miss the annual 8-hour refresher?

OSHA has indicated that a worker who misses the refresher deadline can generally take the refresher course late rather than repeating the full initial course, with the late date documented. If a long period has passed, the employer should evaluate whether the worker still has the competencies required and consider retraining.

Is a small spill cleanup covered by HAZWOPER?

Not if it is an incidental release. A small spill of a known chemical that employees in the immediate area can safely absorb or contain with available equipment, without a significant safety or health hazard, is not emergency response. Employees still need HazCom training on the chemical and the right PPE.

Does HAZWOPER certification transfer between employers?

Training certificates show that a worker completed a course, but the employer remains responsible for verifying that the training covers the hazards and procedures of its site, and for providing site-specific training. New employers commonly accept prior 40-hour certificates and add site-specific instruction.