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.

November 22, 1989

Mr. Stephen S. Odojewski
Waste Resource Associates, Inc.
2576 Seneca Avenue
Niagara Falls, New York 14305

Dear Mr. Odojewski:

This is in response to your inquiry concerning the training requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final standard (29 CFR 1910.120).

Your specific question is whether the eight hour minimal training requirement for first responders at the operational level is for eight contact hours or a "normal" work day. The eight hours assumes an eight hour work day with sufficient time for lunch and other breaks. Our suggestion is to develop a one-day or longer course depending on the needs of the workers so they are competent to perform their emergency response job duties.

I hope this information is helpful.


Thomas J. Shepich, Director
Directorate of Compliance Programs