- Standard Number:
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.
January 30, 1997
Mr. Ron Roy
Director of Health, Safety and Quality
Valley Systems, Inc.
Post Office Box 603
Canal Fulton, Ohio 44614
Dear Mr. Roy:
This is in response to your request for a written interpretation of the training certification requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120). Specifically, you requested clarification as to (1) whether former employees can request copies of training certificates from former employers; and (2) whether current employers can request documentation of an employee's training from the employee's former employer. The response that follows confirms your telephone conversation with Ms. MaryAnn Garrahan of my office on October 21, 1996.
Former employees can request copies of training certificates from former employers and current employers can request documentation of an employee's training from the employee's former employer. OSHA regulations, however, do not require former employers to respond to such requests. Paragraph 1910.120(e)(6) of the HAZWOPER standard requires that head instructors or trained supervisors provide a written certificate to each employee that has successfully completed the training and field experience that is specified in paragraphs (e)(1) through (e)(4) of the standard. It is the employee's responsibility to keep copies of the training certificate for themselves and for future employers.
We hope that this letter clarifies your concerns regarding requirements for training certification under OSHA's HAZWOPER standard. If you have additional questions, please contact this office at (202) 693-2190.
Ruth McCully, Director
Office of Health Compliance Assistance