Understanding the HAZWOPER and DOT HazMat training standards

HAZWOPER

Understanding OSHA standards for Hazardous Waste Operations and Emergency Response (HAZWOPER) can be challenging for employers. There are two standards that define who is required to receive HAZWOPER training: General Industry 1910.120(a)(1)(i-v) and Construction 1926.65(a)(1)(i-v). Below is a breakdown to help employers and employees better understand these requirements.

  • clean-up operations -- required by a governmental body, whether federal, state, local, or other involving hazardous substances -- that are conducted at uncontrolled hazardous waste sites;
  • corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);
  • voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;
  • operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and
  • emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

General site workers need 40 hours of training and specific, limited-task workers need 24 hours of training.  Employees must receive 8 hours of refresher training annually.  

DOT
Another hazardous materials standard that employers might confuse with HAZWOPER is the 49 CFR § 172.700-704 transportation standard. According to these regulations, employees involved in the shipping and receiving of hazardous materials are required to undergo training and testing. This includes personnel who prepare or sign hazardous materials/waste manifests, those who prepare hazardous materials for off-site shipment, and hazardous waste generators.

Training covers several topics, including general awareness, safety training, security awareness, and recordkeeping. As stipulated by 49 CFR § 172.704, initial training must be completed within 90 days of employment or a change in job function. Furthermore, employees must receive refresher training at least once every three years.

The UT Center for Industrial Services offers this training through open enrollment or can provide on-site training at your location.

Links to upcoming training:
https://tennessee.csod.com/LMS/LoDetails/DetailsLo.aspx?loid=99216b4a-b017-40a3-a046-2f47bfb5d51b#t=3
https://tennessee.csod.com/LMS/LoDetails/DetailsLo.aspx?loid=80ef629b-51d4-43a9-8f34-b6ff0b2b5e03#t=3
https://tennessee.csod.com/LMS/LoDetails/DetailsLo.aspx?loid=0280dc3f-a046-4d62-abd1-390c658a7074#t=3

Contact us for all of your Health, Safety or Emergency Preparedness or Response training or consultative needs. 
dustin.housewright@tennessee.edu

Tags Hazardous Waste Health