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• Standard Number: 1910.120

November 7, 1991

Mr. R. Mark Driscoll
500 Old West Street
Post Office Box 688
Randolph, Massachusetts 02368

Dear Mr. Driscoll:

This is in response to your inquiry of September 13, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). We hope that the delay in returning your correspondence has not been an inconvenience.

Your question refers to 1910.120(e)(3)(i), which requires three days actual field experience under the direct supervision of a trained, experienced supervisor. Your letter asks OSHA to specify "actual field experience" for an employee in training.

Supervised field experience is part of an employee's initial training, taking place after he or she has completed the off site classroom instruction. Employees must be able to familiarize themselves with the equipment and field conditions they will be expected to work under. The initial three days in the field under the supervision of another experienced employee ensures the safety and health of the new employee.

We hope this information is helpful. If you have any further questions please contact us (202) 523-8036.

Sincerely,



Patricia Clark, Director
Directorate of Compliance Programs

Standard Interpretations - Table of Contents Standard Interpretations - Table of Contents