Which Type of HAZWOPER Training Do Your Workers Need?

All American workers who may be exposed to sudden and unexpected release of hazardous substances, encounter hazardous waste, or take part in emergency response or cleanup operations after toxic spills must receive adequate and appropriate HAZWOPER training.

HAZWOPER is an acronym that stands for Hazardous Waste Operations and Emergency Response. It is a set of standards developed and overseen by the Occupational Safety and Health Administration (OSHA) for both the construction industry and general industry. These standards guide the implementation of appropriate procedures for the safe handling, storage, transport, cleanup, and disposal of hazardous materials and hazardous wastes on worksites.

Many employers have two major questions related to HAZWOPER training: which employees need it and which training do those employees need?

The 3 Categories of HAZWOPER Training

OSHA has developed three levels of HAZWOPER training, each corresponding to the worker's level of exposure as well as the type of work carried out. 29 CFR Part 1910.120 outlines these levels:

Providing employees with the right training is an essential step in keeping them safe. Maintaining a valid (not expired) HAZWOPER course completion certificate for every worker who needs one is also required for compliance with OSHA regulations.

The initial 40 hour or 24 hour HAZWOPER course is not sufficient for meeting this requirement. OSHA also requires employees to regularly complete the HAZWOPER refresher training course to maintain their certification.

Note that this article will focus on the HAZWOPER Section (e) training for general site workers.

(For related reading, see Hazardous Materials Storage Buildings – When Are They Required?)

The Initial 40 Hour HAZWOPER Training

OSHA HAZWOPER standards 29 CFR 1910.120(e)(3)(i) and 29 CFR 1926.65(e)(3)(i) state that:

“General site workers (such as equipment operators, general laborers, and supervisory personnel) engaged in hazardous materials removal or other activities which expose or potentially expose workers to hazardous substances and health hazards shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor.”

This 40 hours of training is highly comprehensive, covering a range of topics relevant to operations at a hazardous waste site:

The Initial 24 Hour HAZWOPER Training

According to OSHA HAZWOPER Regulations, 29 CFR 1910.120(e)(3)(ii) and 29 CFR 1926.65(e)(3)(ii):

“Workers on site only occasionally for a specific limited task (such as, but not limited to, groundwater monitoring, land surveying, or geophysical surveying) and who are unlikely to be exposed over permissible exposure limits and published exposure limits shall receive a minimum of 24 hours of instruction off the site, and the minimum of one-day actual field experience under the direct supervision of a trained, experienced supervisor.”

This means that any employee who occasionally carries out their work on hazardous waste sites and who are exposed to hazardous substances below the Permissible Exposure Limits (PELs) must hold a valid HAZWOPER training certificate.

(Learn more about 5 Essential Exposure Limit Terms Worth Knowing)

Given the lower level of risk faced by these workers, the 24 hour HAZWOPER training course does not go in-depth. Instead, it focuses on key areas of the HAZWOPER program:

Which HAZWOPER Training Course Do Your Workers Need?

Permissible Exposure Limits (PELs) are the main factor that will guide you in selecting the right training course for your employees:

• 40 hours of HAZWOPER training is required for workers who are exposed to hazardous substances that exceed the PELs
• 24 hours of HAZWOPER training is sufficient for employees whose work does not expose them to hazardous substances at or above the PELs

The type of operation also determines the amount of training a worker requires:

• Site Cleanup Operations
  • General Site Workers: 40 hours + 3 days supervised field experience
  • Occasional Site Workers: 24 hours + 1 day of field experience
  • Management/Supervisors: 40 hours or 24 hours + 3 days of supervised field experience and 8 hours of supervisor training
• Treatment, Storage, and Disposal (TSD) Facilities
  • TSD Site Workers: 24 hours
• Emergency Responders
  • First Responder Awareness: No hourly requirement (competency based)
  • First Responder Operations: 8 hours
  • Hazardous Materials Technician: 24 hours
  • Hazardous Materials Specialist: Technician-level competencies
  • Incident Commander: 24 hours

The 8-Hour HAZWOPER Refresher Training

According to OSHA HAZWOPER Standards, 29 CFR 1910.120(e)(8) and 29 CFR 1926.65(e)(8):

“Employees specified in paragraph (e)(1) of this section, and managers and supervisors specified in paragraph (e)(4) of this section, shall receive eight hours of refresher training annually on the items specified in paragraph (e)(2) and/or (e)(4) of this section, any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics.”

This means that employees who have completed either the 40 hour or 24 hour HAZWOPER training in the previous year must enroll and successfully complete 8 hours of refresher training to maintain valid HAZWOPER certification and be allowed to continue working on sites with hazadous materials.

This refresher training provides summarized, topic-relevant information covered in the initial HAZWOPER training courses:

How Can Workers Obtain HAZWOPER Training?

HAZWOPER training is easily available. The off-site instruction can be completed in one of three ways:

1. Enrolling individual workers in a relevant online training course
2. Organizing a classroom-style in-person training program
3. Arranging virtual instructor-led training for a group of workers