OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

June 29, 1987

Ms. Jo Hoffman-Ferenchak
Industrial Hygienist
TSD Environmental Services, Inc.
Technical Services & Design
Post Office Box 801
Collegeville, Pennsylvania 19426

Dear Ms. Hoffman-Ferenchak:

This is in response to your request for an interpretation of training requirements in the hazardous waste interim final rule (29 CFR 1910.120(e)(2) and (3)) as it applies to your operations.

If the work you are performing is at a site covered by the scope of the standard, i.e. CERCLA site, RCRA removal site, or a site designated for clean-up by a State or local authority, and your employees may be exposed to hazardous wastes, hazardous substances, or any combination of hazardous wastes and hazardous substances, then the training requirements must be met.


Leo Carey, Director
Directorate of Field Operations