Employees who work with uncontrolled chemical hazards require annual training in OSHA's HAZWOPER standard—short for Hazardous Waste Operations and Emergency Response. This article provides an overview of the HAZWOPER standard, who needs training in it, and how to do HAZWOPER training efficiently and avoid wasting resources.
What Is HAZWOPER?
OSHA enacted HAZPOWER in 1990, with the memory of the industrial disasters at Love Canal; the Valley of the Drums; and the deadly chemical leak from Bhopal, India's Union Carbide plant still fresh in everyone's mind (see When Safety Leadership Fails: Lessons from Major Disasters for a discussion of safety leadership in the prevention of catastrophes). To ensure the protection of workers in similar disasters, the organization sought guidance from the Department of Defense, as well as the Environmental Protection Agency, the National Institute for Occupational Safety and Health, and the U.S. Coast Guard. The result of this organizational collaboration is a standard designed to protect the workers involved in chemical release emergencies, those tasked with the subsequent clean-up of the site once the emergency has stabilized, and those tasked with cleaning up chemical contamination resulting from the country's industrial legacy.
The HAZWOPER standard, in other words, is meant to ensure the safety of those who respond to uncontrolled chemical hazards, not to train them on any specific technical response methods, such as plugging chemical leaks or managing spills.
It's important to emphasize that HAZWOPER is concerned specifically with sites that have uncontrolled chemical hazards (see Hazards vs Dangers: Do You Know the Difference? to learn more). These are, specifically, sites in which the "accumulation of hazardous substances creates a threat to the health and safety of individuals or the environment or both."
Who Needs HAZWOPER Training?
HAZWOPER training is required for workers who will be:
- Exposed to high concentrations of poisonous substances
- Exposed to chemical conditions that pose a fire or explosion hazard
- Entering sites with atmospheres at or above IDLH levels
- Exposed to oxygen-deficient atmospheres (less than 19.5% oxygen)
- Leading evacuations due to chemical atmospheres or oxygen-deficient conditions
- Performing confined space entry (see this safety moment on Confined Spaces to learn more)
- Supervising workers exposed to any of the above dangers
In practice, this is primarily relevant to people employed in one of three very specific activities:
- Uncontrolled hazardous waste site operators
- Treatment, storage, and disposal facility (TSDF) personnel
- Emergency responders
Uncontrolled waste site operators are the workers who enter chemical contamination sites to perform clean-up and remediation. They must deal with a great degree of uncertainty since they often enter a contaminated area without knowing which chemical has contaminated it or how concentrated it is. Given these conditions, strictly adhering to the standard is crucial to ensuring their safety.
TSDF personnel work at controlled waste facilities but nevertheless require the training and protection of the HAZWOPER standard since part of their job involves receiving waste from uncontrolled sites for treatment.
Emergency responders also deal with uncontrolled chemical hazards but their training is geared toward quickly stabilizing conditions during an emergency situation. Once their work is complete and the emergency has abated, the site of the emergency is then considered an uncontrolled waste site.
Who Doesn’t Need HAZWOPER Training?
This may seem like an odd question. After all, the HAZWOPER standard was designed for a very specific purpose so it should be easy to figure out who it's made for. But we constantly encounter companies that assign HAZWOPER training to any employee whose roles might bring them into contact with hazardous chemicals and waste. Many of those employees, however, don't need the training.
Remember that HAZWOPER deals specifically with uncontrolled hazards. This means that those who work on controlled hazardous waste sites, like landfills and waste collection facilities with non-permitted accumulator status (under the Resource Conservation and Recovery Act [RCRA]), are unlikely to need the training. Similarly with lab workers, water treatment plant workers, and those who work in chemical manufacturing plants—while they do work with chemical hazards on a daily basis, these are, in non-emergency situations, controlled hazards and don't require HAZWOPER training.
In these and other cases of inappropriate use of HAZWOPER training, what the workers typically need is training under the Hazard Communication standard (HAZCOM). In fact, we have often seen companies resort to HAZWOPER to fill in the gaps after HAZCOM is ineffectively applied, when what is really needed is better and more comprehensive HAZCOM training.
And needless HAZWOPER training isn't just inappropriate; it's wasteful. Most safety departments don't have overflowing budgets, so any resources used up on inappropriate training is money that could have been spent on safety initiatives and training that would actually yield significant results and improve worker safety (see Safety Training Eating Up Your Budget? for advice on cost-effective training).
How to Deliver Effective HAZWOPER Training
HAZWOPER has traditionally been taught through conventional, instructor-led programs, and this is still a common delivery method. The increasing popularity and technical improvements of online training, however, allows us to deliver the training more effectively and flexibly.
The HAZWOPER refresher training is especially well-suited to online delivery. Organizations no longer have to set aside a day for training, provide a classroom and instructor, and keep a large number of their workforce off the job for eight hours to receive instruction. Rather, a training manager can sign up for an e-learning program, like SafetySkills' 8-hour online refresher course, assign and track the course remotely throughout the organization, and allow personnel to complete the training in the time frame that works best for them.
Online tools also facilitate rolling training that takes place incrementally throughout the year. Since refresher training is only required annually, there is no reason why it cannot be completed over many months. Although it can be tempting to get it over and done with in a single day, spreading it out has its advantages. For example, being exposed to elements of HAZWOPER throughout the year, instead of once every twelve months, improves retention of the standard, resulting in increased competence and effectiveness.
Limitations to Online Delivery
Initial HAZWOPER training can certainly be delivered online, but there are important limitations that should be kept mind.
There is an essential dress-out component to HAZWOPER training that cannot be completed online. And while there are numerous online training courses that show donning and doffing procedures and respirator use through careful video instruction, OSHA does not approve of this as a training method. And, frankly, neither should EHS training managers. Training and compliance should never be about just ticking boxes (see Common Safety Cliches & Why They Aren't Helping for a related discussion). No one should send employees who have never actually donned a respirator into potentially dangerous environments—it's simply not worth the risk.
Some aspects of EHS and emergency response training will always have to be hands-on, but that doesn't mean e-learning can't play a significant role. An approach that blends in-person, instructor-led training with online instruction can give us the best of both worlds (see 7 Superb Psychological Tactics for EHS Training for advice on making the most of your in-person training). A 32-hour online course followed by 8 hours of in-class instruction, for example, could meet OSHA's training requirements if done properly. It is up to training managers to determine the best balance for their personnel but online tools give them more options and flexibility than ever before.