HAZWOPER and Emergency Response Training: Which Do I Need?
Written by: NES, Inc. Staff
This article will help you to decipher the differences between various HAZWOPER and Emergency Response training courses.
HAZWOPER vs. Emergency Response Training
Cal/OSHA (8 CCR 5192) contains California standard information pertaining to Hazardous Waste Operations and Emergency Response (HAZWOPER). The language can be difficult to digest, so attempting to determine which EH&S training course(s) you or your employees may require can often be confusing. The training an employee requires depends on the types of job duties that the employee will, or will potentially, be performing. What follows are descriptions of two of the most commonly required OSHA training categories, HAZWOPER and Emergency Response, and the courses that fall within each.
HAZWOPER training is required for employees who will be performing remediation work in areas previously determined to be contaminated with one or more hazardous substances. The type of training that must be done depends on the hazard levels of the environments in which the work is to take place. Additionally, employees working at a treatment, storage, and disposal facility (TSDF) must also complete HAZWOPER training. Training for these employees is either 24- or 40-hour:
The 24-hour course is for occasional site workers who carry out remediation operations involving hazardous substances at fully characterized sites where exposure above established thresholds (PELs) is not expected and where the use of respirators is not required more than 30 days per year.
The 40-hour course is for general site workers who will be performing remediation in a wide array of environments, particularly when those environments are hazardous to a point necessitating the use of personal protective equipment (PPE) and/or respirators for more than 30 days per year. The regulations also state that employees who may be exposed to materials above established permissible exposure limits (PELs) during the course of their job duties are to take the 40-hour training.
If an employee initially obtained the 24-hour HAZWOPER certification but has subsequently experienced a change in job duties that 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 certificate. 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’.
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Emergency Response Training
Emergency Response training applies to employees who will be responding to emergency events in various capacities. Emergency Response 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
This is typically 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.
This is an 8-hour course for employees who would respond defensively to a hazardous substances spill/event in such a way as to contain the substances and protect the environment from possible further contamination.
This is a 24-hour course designed for those whose responsibilities include responding to, characterizing, and cleaning up a hazardous substances spill/event. The ‘Specialist’ designation refers to those technicians who specialize in the remediation of particular hazardous substances.
This training 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 training compliance (this does not apply to First Responder Awareness).
HAZWOPER or Emergency Response?
Now it is time to figure out which type of training you or your employees might need. A question to address in determining this is, “Will I, or will my employees, be tasked with responding to an emergency event?” For example, a site may have known contamination from a leak in an aboveground storage tank or from a tanker vehicle, in which case previous knowledge of the situation exists and appropriately HAZWOPER-trained employees may enter the site and perform remedial operations. But what if there is an emergency at your facility? Employers often choose to train staff so that they are prepared to respond to such an event.
The distinction between a “normal” and an “emergency” hazardous substance scenario is not made definitive by OSHA and must ultimately be decided upon by the employer.
HAZWOPER and Emergency Response Training: Conclusion
There is significant overlap between the information covered in individual HAZWOPER and emergency response classes. 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 employees looking to secure emergency response training for their 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 916-353-2360 / 1.800.NES.ADVISE (1.800.637.2384) or write to us at firstname.lastname@example.org.