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Who Really Needs HAZWOPER Training?

Posted on June 01, 2020 by Joel Gregier, CDGP

Which HAZWOPER course should I take?

It sounds like a simple question but unfortunately, there's no simple answer. HAZWOPER training is not one-size-fits-all. To answer the question with any accuracy, we need to answer a few questions about if and why HAZWOPER training is required. 

Below we explore the types of employees who need HAZWOPER training, how many hours of HAZWOPER training each employee needs, and additional requirements for the personnel covered under this expansive OSHA Standard. 

What is HAZWOPER?

Let's start at the beginning. HAZWOPER is an OSHA workplace safety Standard found in 29 CFR 1910.120.

HAZWOPER stands for “Hazardous Waste Operations and Emergency Response.” The acronym originated with the US military's post-WWII program to dispose of hazardous wastes generated in the war effort.  

Don’t let the name fool you: HAZWOPER covers more than just hazardous waste. The was put in place to protect employees who perform emergency response or contaminated site cleanup involving “hazardous substances.” 

While the term “hazardous substance” includes EPA hazardous wastes, it also covers CERCLA hazardous substances, DOT hazardous materials, and biologic agents. [29 CFR 1910.120(a)(3)]

In other words, employees may need HAZWOPER training even if they never get near a hazardous waste. With that, let's discuss the three main categories of individuals who need HAZWOPER training. 

Who Needs HAZWOPER Training?

Each of these three main categories comes with its own set of training requirements.
  1. Cleanup site workers are workers directly involved in a hazardous substance or hazardous waste cleanup activity.  For instance, people who work at “Superfund” sites.

  2. TSDF workers are personnel who work at permitted hazardous waste facilities that treat, store, and dispose of hazardous waste.  Employees covered here would only include those workers actually involved with the TSDF operation.

  3. Emergency responders are employees who respond to emergencies involving hazardous substances. This includes people like firefighters but also facility employees who handle on-site emergency response for their employer. To be clear, if you do emergency response at cleanup sites or TSDFs, you would fall into the first two categories.
Training for each type of employee must cover specific topics. The topics that must be covered in HAZWOPER training for each type of employee are found at:
  • 29 CFR 1910.120(e) for cleanup site workers,
  • 29 CFR 1910.120(p) for TSDFs, and
  • 29 CFR 1910.120(q) for emergency responders.

5 Levels of HAZWOPER Emergency Responders 

To respond effectively to an emergency release, a team of employees must work together and each employees  must do his or her part safely and effectively. OSHA recognizes this, and splits its emergency responders HAZWOPER category into five “levels," each with its own training standards.   

The five levels of emergency responders are:

Level 1 - First responder “awareness level” – Employees who do not do any active response.  For instance, they see a spill or release, run away, and get someone else to help (e.g., call the fire department/tell the boss).

Level 2 - First responder “operations level” – Employees who will respond defensively to a release to protect nearby persons, property, or the environment. These people do NOT try to stop the release. For instance, they might put up protective barriers around a leaking drum, but they would not plug the leaking drum.

Level 3 - "HAZMAT technician” - Employees who will respond offensively and will aggressively try to stop the release.  These employees would try to plug the leaking drum.

Level 4 - "HAZMAT specialist” - Employees who provide support to technicians, including technical knowledge and guidance, and act as liaisons to government authorities.

Level 5 - “On-scene incident commander” - Employees who assume control of the incident scene beyond the first responder awareness level.  Essentially, they head up the response team.

How Many Hours of HAZWOPER Training Do I Need?

The duration of HAZWOPER training required –40 hours, 24 hours, 8 hours, etc.– depends on what type of HAZWOPER employee you are. Here’s the basic rundown of the HAZWOPER training hours OSHA requires for each type of covered employee:

Cleanup site employees
  • “Real or potential exposure” – 40 hour initial, 24 hours in the field, 8 hour annual refresher
  • “Minimal exposure” – 24 hour initial, 8 hours in the field, 8 hour annual refresher
  • “Supervisors/managers” – have the same criteria as the previous two but also need 8 hours of “specialized” training
TSDF employees
  • “General site” – 24 hours initial, 8 hours annual refresher
  • Emergency response personnel – trained to a level of competency, annual refresher
Emergency responders
  • Level 1 – “sufficient training,” annual refresher
  • Level 2 – Level 1 competency and 8 hours initial or proven experience in specific competencies, annual refresher
  • Level 3 – 24 hours of Level 2 and proven experience in specific competencies, annual refresher
  • Level 4 – 24 hours of Level 3 and proven experience in specific competencies, annual refresher
  • Level 5 – 24 hours of Level 2 and additional competencies, annual refresher

Initial training for emergency responders must be completed before they can take part in actual emergency operations [(29 CFR 1910.120(q)(6)].

For all levels of emergency responders, OSHA requires annual refresher training. Refresher training for emergency responders must be "of sufficient content and duration to maintain their competencies” [29 CFR 1910.120(q)(8)]. 

Who Can Train Employees on HAZWOPER?

Not just anyone can train employees on HAZWOPER topics. OSHA mandates qualifications for trainers throughout the HAZWOPER Standard. 

For all types of HAZWOPER training, OSHA requires that trainers have "satisfactorily completed a training program for teaching the subjects they are expected to teach, or have the academic credentials and instructional experience necessary for teaching the subjects." Trainers must be able to demonstrate competent instructional skills and a good command of HAZWOPER subject matter.

See 29 CFR 1910.120(e)(5), (q)(7), and (p)(7)(iii)

Additional Training Required 

In addition to covering the relevant information from OSHA's HAZWOPER Standard, HAZWOPER training must cover job- and site-specific elements including, but not limited to, training on the site's emergency response plan and training on the hazards of specific substances the employee may encounter. 

As described above, site cleanup personnel must complete some duration of field experience in addition to their training. 

More HAZWOPER Resources 
For a visual explainer of who needs HAZWOPER training and how many training hours are requried, see our HAZWOPER explainer graphics linked below:
HAZWOPER Emergency Responder Training
HAZWOPER Site Cleanup Training 


Online HAZWOPER Training 
Browse online HAZWOPER training options at Lion.com/HAZWOPER 

For cleanup site workers, Lion offers initial (40 Hour) and refresher (8 Hour) HAZWOPER training.

Also, find courses for most levels of emergency responders, like:  

Awareness Level (Level 1) - Initial or Refresher
Operations Level (Level 2) - 8 Hour Initial 
Operations Level (Level 2) - 4 Hour Refresher 
Technician Level (Level 3) - 8 Hour Refresher 
Incident Commander (Level 5) - 4 Additional Training Hours 

See Spanish-language HAZWOPER courses at Lion.com/Spanish