Standard Interpretations - Table of Contents|
| Standard Number:||1910.120|
February 12, 1992
Mr. Jon Williams
Diamond Shamrock, Inc.
Health and Safety Department
Post Office Box 696,000
San Antonio, TX 78269-6000
Dear Mr. Williams:
This is in response to your letter of December 13, concerning the Occupational Safety and Health Administration's (OSHA) training provisions for hazardous waste operations.
The "Hazardous Waste Operations and Emergency Response" standard (HAZWOPER), 29 CFR 1910.120, states in paragraph (e)(5) that "Trainers shall be qualified to instruct employees about the subject matter that is being presented in training". In addition, 29 CFR 1910.120(e)(5) explains that the qualifications of the instructors may be shown by academic degrees, completed training courses and/or work experience.
At this time, OSHA does not have any specific requirements to certify an instructor. The subjects that trainers should be able to convey to employees at hazardous waste operations who need training are summarized in paragraphs (e), (p) and (q) of the HAZWOPER standard.
The training programs
The response above is OSHA's general explanation to your questions, however the following responses are answers to your specific questions:
Question 1. Are Train the Trainer courses to be specific for each type of hazardous waste operations and/or emergency response operations? Does this mean there are Train the Trainer courses for HAZMAT trainers?
Answer: Train the Trainer course must instruct the trainer on the subjects to be covered in the employee training course. It is unlikely that one course would be able to incorporate all of the topics required to be covered for all hazardous waste operations and emergency response operations. A more practical approach would be to create separate courses. The trainer must be able to demonstrate an understanding of the material to be transmitted to employees. Training courses for employees outlined in the HAZWOPER standard
Question 2. What is meant by academic credentials? Does this mean a person with a degree in safety, industrial hygiene, toxicology, environmental science, and/or some other related degree?
Answer: Yes. Trainers may also show transcripts from courses in safety and industrial hygiene that are not necessarily part of a degree.
Question 3. Would an engineer, not having a degree in safety or industrial hygiene, and not having attended an adequate number of safety and hygiene courses, related to aspects concerning hazardous wastes or materials, be considered to have the proper academic credentials? If so, what would an adequate number of safety and hygiene courses be?
Answer: An adequate number of courses would vary depending on the course and the engineer's experience and training in safety and industrial hygiene practices. As mentioned above, the trainer must be able to demonstrate an understanding of the material to be transmitted to trainees and have some credentials or experience in training others.
Question 4. What are the minimum requirements for a trainer in terms a layman would understand?
Answer: Please see the answer to Question 1.
Question 5. Does experience mean that a person that has spill experience and a 40-hr. hazardous waste and emergency response course can teach the training course? If so, does this mean that a person can teach all aspects of the hazardous waste or emergency response course?
Answer: It seems unlikely that the person described above would able to instruct employees on all aspects of the hazardous waste or emergency response course, and would feel confident in answering any questions that employees may have during their training. However, such a person could probably teach some aspects of the course.
Question 6. Paragraph 1910.120(q)(7) states that trainers "shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as courses offered by the U.S. Fire Academy, or they shall have the training and/or academic credentials and instructional experience necessary to demonstrate competent instruction skills and a good command of the subject matter in the specific subject they are to teach." I will assume the standard is speaking of the Maryland Fire Academy when it states the U.S. Fire Academy. Here again we are speaking of training and/or academic credentials. What exactly does this mean?
Answer: The Incident Command System and the training levels within a HAZMAT team originated from the National Fire Protection Association's (NFPA) Standard for Professional Competence of Responders to Hazardous Materials Incidents, codified as NFPA 472. Emergency response training given by the U.S. Fire Academy in Emmittsburg, Maryland, would be identical or similar to HAZWOPER training requirements outlined in paragraph (q).
Question 7. Where do you draw the line on who is and who is not qualified to instruct these courses:
We hope this information has helped you. If you have any further questions regarding current HAZWOPER training please feel free to contact [the Office of Health Enforcement at (202) 693-2190]
Patricia Clark, Director
[Directorate of Enforcement Programs]
[Corrected 1/20/2005. On August 15, 2002 the proposed 1910.121 "Accreditation of Training Programs for Hazardous Waste Operations" proposed rule was withdrawn from the Unified Regulatory Agenda (see Federal Register 67:74749-74785 dated December 9, 2002).]
Standard Interpretations - Table of Contents|