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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.
September 5, 1995
TSgt. William B. Vines
United States Air Force
447 4th Street, Suite 1
PO Box 2114
Laughlin Air Force Base
Laughlin, TX 78843
Dear TSgt. Vines:
This is in response to your letter dated April 17, 1995 requesting clarification on who must receive first responder awareness level training consistent with the paragraph (q)(6) of OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120).
Employees who work in an area (or areas) where there is a potential to witness or discover an uncontrolled release of a hazardous substance and whose response actions will be limited to initiating emergency response procedures by notifying the proper authorities, must receive first responder awareness level training consistent with the requirements of 29 CFR 1910.120(q)(6)(i). Such employees are not limited to police, hospital, or fire department personnel as suggested in your letter, but would include any employee meeting the above description.
Specific training requirements for your personnel must be derived from the roles you assign them in your emergency response plan. Accordingly, the required training level for police, hospital, and fire department personnel may exceed awareness level training, depending on the assigned emergency response roles of each of these individuals. For instance, emergency medical service personnel would require first responder awareness level training as a minimum if they were not expected to handle contaminated victims. If, however, emergency medical personnel were expected to handle victims who were only superficially decontaminated or not been decontaminated at all, these medical personnel would require first responder operations level training as described in 1910.120(q)(6)(ii). In addition, general firefighters are usually trained at the first responder operations level since they tend to participate in the initial emergency response activities for the purpose of protecting nearby persons, property, and the environment from the effects of the release.
In any case, all personnel who must receive emergency responder training under 1910.120(q)(6) must also receive annual refresher training in accordance with paragraph (q)(8).
When there is the potential for employee exposure to hazardous substances under non-emergency releases of hazardous substances, training under 29 CFR 1910.1200 (Hazard Communication) is applicable.
We hope this provides the clarification you sought. If you have additional questions, please contact Mary Ann Garrahan at (202) 219-8036.
Ruth McCully, Director
Office of Health Compliance Assistance
April 17, 1995
MEMORANDUM FOR: Mr. John B. Miles, Director, Directorate of Compliance, OSHA FROM: William B. Vines, TSgt, USAF SUBJECT: Request for written Interpretation
Mr. Miles, I have been corresponding with Mr. Moore concerning who is required Haz-mat Awareness level training. In the December 1994 time frame this base had an E-CAMP inspection where we took several write-ups for personnel not being trained. I discussed this with Mr. Moore and his verbal interpretation was that only first responders, such as police, hospital and fire department are required this training. We understand this, however our Commander would like to see something in writing from OSHA stating this.
My request is for OSHA'S interpretation of who is required Awareness training and who would be covered by the HAZCOM program. If we can get this narrowed down to what we believe it is suppose to be it will help reduce the instructional load and the amount of recurring training that would have to follow.
Any help you can provide will be appreciated. If you need any further information please feel free to contact me at 210-298-5633, or autovon 732-5633, or by fax 732-4179.
William B. Vines