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.

December 11, 1987

Mr. Gregory D. Kugler
Environmental Scientist
Andrews Environmental Engineering Inc.
1320 South Fifth Street
Springfield, Illinois 62703

Dear Mr. Kugler:

This is in response to your inquiry of September 22, requesting whether the certification program you described is equivalent to the 40 hours of training required in paragraph (e)(2) of 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response).

The requirements of 29 CFR 1910.120(e) are somewhat job specific. That is , the employer will have to determine what training is necessary for his employees to knowledgeably and safely perform their job functions. Thus, it is not the intent of 29 CFR 1910.120 for the Occupational Safety and Health Administration (OSHA) to approve or disapprove generic courses or certifications.

If the certification program described in your letter is determined by an employer to meet the general training needs of any employees, those employees would also need site specific training on the items described in 29 CFR 1910.120(e)(1). This training could be done on the site.

I hope this information is helpful.


Thomas J. Shepich, Director
Directorate of Compliance Programs

September 22,1987

Leo Carey
Field Coordination
Room N 3601
U.S. Department of Labor
Washington, D.C. 20210

re: Sara Training Requirements

Dear Mr. Carey:

Prior to the passage of the Superfund Amendments and Reauthorization Act of 1986, I was certified as a Hazardous Materials Manager by the Institute for Hazardous Materials Management. To obtain this certification I was required to pass a four hour examination.

I would appreciate your reviewing the attached material and determine whether this certification is equivalent to the 40 hours of training now required by OSHA for people engaged in activities that might expose them the hazardous substances.

Thank you for your consideration in this matter.

Very truly yours,

Gregory D. Kugler, Environmental Scientist

The Institute has just published a most needed HAZARD CONTROL INFORMATION HANDBOOK. It contains selective and essential sources of information on all aspects of Accident Prevention including Occupational, Product and Environmental Safety & Health. It includes listings of Computer Data Bases, Books, Journals, Standards, Federal & State Agencies, Professional and Technical Associations, College Degree and Continuing Education courses.

Following is a more detailed description of the Handbook:



The Handbook features practical and comprehensive sources of information on all aspects of Safety and Health including environmental, product and occupational. It provides intelligence and knowledge for meeting the resource and information needs of consultants, industry government and academia on managerial, professional and technical developments in loss control and accident prevention.

Contents include listings of:

    Computerized data bases information centers, libraries, and

    Federal and state government legislative, regulatory and agency
    activities and contacts.

    Professional and technical organizations including associations,
    societies, standards development, and certification.

    Safety and Health journals classified by content.

    Educational activities including college degree programs and
    continuing educational courses, identifying the organizations

    Books, reference materials, periodicals, standards, Federal and
    State agencies, trade, technical and professional organizations
    and leading colleges and universities for the following hazard
    control specialties:

         Aviation Safety            Microwave Safety
         Biohazard Control          Motor Vehicle Design and
         Chemical Safety            Noise
         Emergency Management       Nuclear Waste, Low Level
         Environmental Health       Radiological Health
         Fire Protection            Risk Analysis
         Human Factors Engineering  Risk Management
         Laboratory Safety          System Safety
         Laser Safety               Toxicology

To Order: Send $19.00 plus $2.00 for postage and handling to: Hazard Control Management, 8009 Carita Ct., Bethesda, Md. 20817.

The CERTIFIED HAZARD CONTROL CONSULTANTS directory, listing high caliber professionals in all aspects of safety and health, is also available on special at $15.00. If purchased with the Handbook the price is $10.00. All orders must be prepaid.

1. Packaging requirements for hazardous wastes are regulated by:

   A.  RCRA               D.  FIFRA
   B.  TOSCA              E.  CERCLA
   C.  DOT

2. Use of Polychlorinated Biphenyls (PCBs) in electrical equipment is subject to regulation by which of the following:

   A.  Resource Conservation and Recovery Act.
   B.  Safe Drinking Water Act.
   C.  Toxic Substances Control Act
   D.  Federal Insecticide, Fungicide and Rodenticide Act
   E.  Occupational Safety & Health Act.

3. Which of the following are not listed and promulgated as NESHAP hazardous air pollutants in the Clean Air Act:

   A.    Asbestos                D.    Mercury
   B.    Vinyl Chloride          E.    Benzene
   C.    Beryllium






A CHEMISTRY OF HAZARDOUS MATERIALS, by Eugene Meyer, Prentice Hall, Inc., Englewood Cliffs, N.J., 1977.

HAZARDOUS WASTE & MATERIALS MANAGEMENT, Bureau of Law & Business, 64 Wall St., Madison,CT., Tel. (800) 521-0136.


CHMM. Butterworth Publishers, 10 Tower Office Park, Woburn, MA 01801, 1983. 287 pages.

ENVIRONMENTAL AUDITS MANUAL, 3rd Ed., Government Institutes Inc., 966 Hungerford Drive, # 24, Rockville, MD 20850, 1984; Tel. (301) 251-9250. A step by step guide to conducting environmental audits.

MANAGING HAZARDOUS SUBSTANCES ACCIDENTS, by Al J. Smith, Jr., McGraw-Hill Book Co., New York, NY, 1981. 187 p.

TOXIC SUBSTANCES CONTROLS PRIMER, Bureau of National Affairs, Washington, D.C., 1984; Tel. (1-800) 372-1033.



A. Laws and Regulations

     Hazardous waste management (RCRA)          -40 CFR
     Hazardous materials transportation         -49 CFR
     Toxic substances control                   -40 CFR
     Pesticides management (FIFRA)              -40 CFR
     Radioactive materials control              -10 CFR
     Occupational Safety & Health               -29 CFR
     Clean Water Act                            -40 CFR
     Air Pollution                              -40 CFR
     Spills and disposal site cleanup (CERCLA)  -40 CFR
     Hazard Communication Standard              -29 CFR

B. Compliance standards, work practices and state of the art

     Packaging and transportation of hazardous materials
     Hazardous materials handling and storage
     Hazards Assessment and Communication
     Personal protection/Workplace safety and Health practices
     Standards for radioactive materials
     Standards applicable to hazardous waste generators transporters
     and TSD facilities
     Standards applicable to hazardous substances spills
     Standards applicable to the cleanup of hazardous waste disposal

C. Management of hazardous materials programs

     Basic management principles
     Applied hazard control principles and concepts

       Authority and responsibility
       Policy and decision-making

     Liability and risk management
     Information gathering (i.e., resources and reference materials)

D. Science and technology

Chemistry and physics of hazardous materials (e.g., corrosivity, oxidation/reduction, polymerization, flammability and radioactivity.)

Biological effects of hazardous materials

August 1987

Dear CHMM Diplomate:

Attached is a copy of the CHMM program explanation and requirements for recertification. The first three-year reporting cycle will be for the period July 1986 through June 1989.

Three Annual Certification Maintenance Points Reports for the years July 1, 1986 through June 30, 1987, July 1, 1987 through June 30, 1988, and July 1, 1988 through June 30, 1989 will be due in July 1989 for those diplomates certified in July 1986 or earlier.

Your official certification date is the one listed on your certificate. If you are certified on or before July 1st, your recertification will start in July of that year. For those diplomates who are certified after July 1st, the recertification year will start in July of next year.

Certification maintenance reports will be mailed out annually with the certification maintenance data billing.

It is strongly urged that you file your documentation and records per- training to recertification in a separate folder by year. Reports will be submitted to the Review Committee on a three-year cycle. Do not forward separate yearly reports. The first reports will be due on July 1, 1989.


Harold M. Gordon
Executive Director