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 http://www.osha.gov.

June 17, 1991

Mr. Eugene D. McCoy
Police Department
City of Ft. Lauderdale
1300 West Broward Blvd.
Ft. Lauderdale, Florida 33312

Dear Mr. McCoy:

This is in response to your inquiry of April 10, 1991 concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.

Your specific question relates to the application of this regulation to police officers and the minimum number of hours of training required for the awareness level. OSHA concurs with your assessment that police officers should be trained to the awareness level as a minimum.

There is no specific number of hours of training required for the First Responder Awareness Level. The training requirements are performance oriented, which means the training must develop certain competencies in an individual regardless of how long it takes. The regulation defines these competencies in paragraph (q)(6)(i) which reads;

. . . First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas:

(A) An understanding of what hazardous materials are, and the risks associated with them in an incident.

(B) An understanding of the potential outcomes associated with an emergency created when hazardous materials are present.

(C) The ability to recognize the presence of hazardous materials in an emergency.

(D) The ability to identify the hazardous material if possible.

(E) An understanding of the role of the first responder awareness individual in an employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.

(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communications center.

I hope this information is helpful. If you have any further questions please feel free to contact MaryAnn Garrahan at (202) 523-8036.


Patricia K. Clark, Director
Directorate of Compliance Programs