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.

November 7, 1991

Mr. R. Mark Driscoll
500 Old West Street
Post Office Box 688
Randolph, Massachusetts 02368

Dear Mr. Driscoll:

This is in response to your inquiry of September 13, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). We hope that the delay in returning your correspondence has not been an inconvenience.

Your question refers to 1910.120(e)(3)(i), which requires three days actual field experience under the direct supervision of a trained, experienced supervisor. Your letter asks OSHA to specify "actual field experience" for an employee in training.

Supervised field experience is part of an employee's initial training, taking place after he or she has completed the off site classroom instruction. Employees must be able to familiarize themselves with the equipment and field conditions they will be expected to work under. The initial three days in the field under the supervision of another experienced employee ensures the safety and health of the new employee.

We hope this information is helpful. If you have any further questions please contact us (202) 523-8036.

Sincerely,



Patricia Clark, Director
Directorate of Compliance Programs