HAZWOPER: A Primer
Employees who don't regularly respond to hazardous substance emergencies will require HAZWOPER refresher training annually.
HAZWOPER is an acronym that stands for Hazardous Waste Operations and Emergency Response, and training for it is covered under the OSHA standard of the same name.
In this article, we'll go over what this important standard is, when it applies, and what your responsibilities are when it does.
What Is HAZWOPER?
The HAZWOPER standard mandates specific work policies, practices, and procedures that employers must follow to protect workers from exposure to hazardous substances, as well as information and training criteria necessary to ensure the health and safety of workers during hazardous waste, emergency response, and cleanup operations that involve hazardous substances.
The purpose of HAZWOPER is to mitigate or prevent worker exposure to hazardous substances that can have a serious health impact. Workers who come into contact with these substances – whether by touching them, breathing fumes, or other pathways to exposure – may experience a variety of acute and chronic effects. These include:
- Nausea and dizziness
- Skin or eye irritation
- Chemical burns
- Life threatening effects
The release of hazardous substances can also lead to other dangerous situations, including fires, explosions, high-energy events, and toxic atmospheres.
Who Does HAZWOPER Apply To – And When?
OSHA names five distinct groups of employers and employees that the Hazardous Waste Operations and Emergency Response standard applies to:
- Cleanup operations required by a governmental body involving hazardous substances conducted at uncontrolled hazardous waste sites
- Corrective actions involving cleanup operations at RCRA-covered sites
- Operations involving hazardous wastes at TSD facilities
- Operations that generate hazardous waste but are not TSD facilities
- Emergency response operations involving releases of hazardous substances
In general, workers require HAZWOPER training if any of the following applies in an uncontrolled setting:
- Exposure to high concentrations of poisonous substances
- Exposure to chemical conditions that pose a fire or explosion hazard
- Entering sites with atmospheres at or above IDLH (immediately dangerous to life or health) levels
- Exposure to oxygen deficient atmospheres (less than 19.5% oxygen)
- Leading evacuations due to chemical atmospheres or oxygen deficient conditions (learn about Muster Points: How to Keep Your Team Safe During an Emergency)
- Performing confined space entry (see 7 Things to Consider Before Entering a Confined Space for related reading)
- Supervising workers exposed to any of the above dangers
There are, of course, situations involving hazardous substances where HAZWOPER does not apply. These are referred to as "incidental releases" and include the accidental or foreseeable release of a hazardous substance that is a) limited in quantity and b) does not pose an emergency or significant threat to the health and safety of workers in the immediate vicinity.
Employees working with hazardous waste in controlled environments like landfills usually don’t need HAZWOPER training, either.
Employers with workers covered by HAZWOPER must ensure that those workers are trained to a standard that allows them to complete their work tasks safely (we'll discuss training in the next section).
To be in compliance with HAZWOPER, employers must develop a written health and safety plan or program that identifies, evaluates, and controls hazards to health and safety for each hazardous waste site. It should include such items as:
- Initial site characterization and analysis
- Air, soil, and water monitoring activities during work
- Employee training
- Employee medical monitoring
- Emergency response procedures
Employers are also required to provide personal protective equipment (PPE) for employees if:
- Their work environment or work processes present or are likely to present a hazard to any part of their bodies
- They may come into contact with hazardous chemicals, radiation, or mechanical irritants during their work
- It’s not possible to eliminate exposure or potential exposure to the hazard using engineering controls, work practice, or administrative controls
HAZWOPER Training Requirements
Employers must ensure that any worker covered by HAZWOPER is fully trained. Initial training consists of a 24- or 40-hour course, depending on the job type and experience.
OSHA does not recommend or endorse any specific training programs or courses. However, they do offer two essential guidelines for anyone who is considering taking a HAZWOPER course:
- Training should have a practical component. It’s critical for trainees to have hands-on experience and exercises that allow them to become familiar with equipment and safe practices in a setting that is free of hazardous substances. A hands-on component ensures that workers can learn by practical experience and allows instructors to assess whether workers have mastered the skills they require (e.g. donning protecting equipment, using air monitoring equipment). If the course is online, employers must find out how the practical component will be applied.
- Trainees should have an opportunity to ask questions. Trainees should be able to seek clarification about material that is unfamiliar or new to them. In-person courses easily meet this requirement. Online courses may provide a telephone hotline or email contact that gives trainees access to a qualified trainer if questions come up.
(Learn more about Delivering Effective HAZWOPER Training.)
Refresher training should be undertaken annually. If the date for refresher training has lapsed, OSHA recommends that employees take the next available refresher training course.
Barry R. Weissman, a corporate safety manager and member of the editorial advisory board of Occupational Health & Safety magazine notes that there is no specific duration for refresher training. Rather, the OSHA standard requires “sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.”
He further explains that if you have an active team that drills regularly of has real incidents, they’re continually demonstrating their competency each time they respond. Teams that don’t drill or have incidents will need refresher training to demonstrate that they are still competent.
Ultimately, workers must be sufficiently trained to allow them to perform their job duties in a safe manner. This means that employees who have gone a substantial length of time without any training or drills may need to repeat initial training, rather than just a refresher course. The necessity of this should be determined by the employer on a case-by-case basis.
Though it might seem complex at first, HAZWOPER doesn’t have to be complicated. Employers should educate themselves about whether the standard is applicable to them and ensure they understand what’s required in terms of employee training and health and safety planning. At the end of the day it’s about practicing safe hazardous waste procedures to protect the health of employees – and it’s the law.