HAZWOPER and Emergency Response: Which Training Do I Need?
Health and Safety Training – March 7, 2017
Attempting to determine which EH&S training course(s) you or your employees may require can often be confusing. What follows are descriptions of two of the most commonly required OSHA training categories and the courses which fall within each.
Under Cal OSHA (8 CCR 5192) there are the main categories Hazardous Waste Operations (HAZWOPER) and Emergency Response (ER). Contamination from a leak in an aboveground storage tank or from a leak in a tanker vehicle on a work site would be typical examples of non-ER qualifying hazardous material/waste events, while a hazardous material/waste spill resulting from a traffic collision on a highway would be a typical example of an ER scenario; however, the distinction between a “normal” and an “emergency” hazardous material/waste scenario is not made definitive by OSHA and must ultimately be decided upon by the employer.
HAZWOPER training comes in 24- and 40-hour varieties:
- The 24-hour course is for employees who perform remediation operations involving hazardous wastes and who are occasionally responsible for hazardous materials spills/events where the hazardous materials are known to the workers (fully characterized) and monitored, where exposure above established thresholds (PELs) is not expected, and where air monitoring or use of respirators is not required.
- The 40-hour course is for those site workers who will more regularly be responding to a wide array of potential events, particularly when involving the use of personal protective equipment (PPE) and/or respirators more than 30 days per year.
If an employee initially obtained the 24-hour HAZWOPER certification but has subsequently experienced a change in job duties which makes necessary the full 40-hour training, there is a 16-hour HAZWOPER Supplemental course available. Upon successful completion of the 16-hour course, the employee will achieve his/her 40-hour certification. Employees who supervise those workers described above are required to undergo additional training; for such employees, NES offers a course entitled ‘Supervisors of Hazardous Waste Workers’.
The Emergency Response category comprises five sub-categories with corresponding training: First Responder Awareness, Emergency Response First Responder Operations, Emergency Response Hazardous Materials Technician, Emergency Response Hazardous Materials Specialist, and Incident Commander.
- First Responder Awareness is usually a relatively brief course for employees who work around common hazardous materials, such as ammonia, and who are not responsible for the cleanup of spills or other incidents. For these employees, Hazardous Communication (HazComm, a.k.a., ‘right-to-know’) training, conveying an awareness and understanding of any hazardous chemicals/materials kept on-site, is sufficient. As this course is highly specific to the particular substances maintained on-site by the client, NES regularly provides this training at a client’s facility.
- Emergency Response First Responder Operations is an 8-hour course for employees who would respond defensively to a hazardous waste spill event in such a way as to contain the spill and protect the environment from possible further contamination.
- Emergency Response Hazardous Materials Technician is a 24-hour course designed for those whose responsibilities include responding to, characterizing, and cleaning up a hazardous waste spill/event. The ‘Specialist’ designation refers to those technicians who specialize in the remediation of particular hazardous materials.
- Incident Commander is for employees who assume a position of leadership for an event, arranging the proper remedial actions, alerting the pertinent agencies, and organizing and overseeing the hazmat technicians working the scene.
An Emergency Response Annual Refresher course is required to maintain certification (this does not apply to First Responder Awareness).
There is significant overlap between the information covered in HAZWOPER and ER classes, as well as between the courses within each category. As mentioned above, OSHA does not provide thoroughly definitive training requirements for all employee types. For some employers, an annual HAZWOPER Refresher course may be considered sufficient for ER employees. The driving philosophy behind ascertaining compliance lies in an assessment of due diligence having been undergone by employers to sufficiently protect their employees and the environment.
Still not sure which training course(s) you need? Feel free to give us a call at 1.800.NES.ADVISE (1.800.637.2384) or write to us at email@example.com.