- 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.
April 25, 1997
Mr. Thomas Whittaker
New England Hospital
Engineers' Society, Inc.
303 Buttonball Lane
Glastonbury, Connecticut 06033
Dear Mr. Whittaker:
This is in response to your letter of March 4, requesting clarification of an Occupational Safety and Health Administration (OSHA) letter to Randy Ross dated March 31, 1992, addressing emergency response training requirements for hospital staff. In the March 31, 1992 letter to Mr. Ross, OSHA indicated that hospital staff that operate decontamination facilities as part of a hazardous waste emergency response effort must be provided with at least first responder operations level training in accordance with paragraph (q) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. In your letter, you asked whether medical personnel who do not operate decontamination facilities, but are involved with the patient only to provide medical care, must be trained as skilled support personnel.
As noted in the March 31, 1992 letter to Mr. Ross, the HAZWOPER standard requires that training shall be based on the duties and function to be performed by each responder during an emergency. Hospital staff who are not expected to assist in the decontamination of patients, but may be exposed to patients needing immediate treatment prior to thorough decontamination would be considered "skilled support personnel" under paragraph (q)(4) of the HAZWOPER standard and would not require first responder operations level training. Accordingly, such medical personnel must, at a minimum, be given a briefing at the time of the incident. This briefing must include instruction in the wearing of appropriate personal protective equipment (PPE), the nature of the chemical hazards involved in the emergency, the expected duties that the medical personnel must perform, and any other safety and health precautions that the medical personnel must take including the implementation of personal decontamination procedures.
We hope that this information clarifies your concerns regarding the emergency response training requirements for medical personnel in OSHA' s HAZWOPER standard. If you have any further questions, please contact this office at [(202) 693-2190].
John B. Miles, Jr., Director
[Directorate of Enforcement Programs]
March 4, 1997
Mr. John B. Miles, Jr. Director
[Directorate of Enforcement Programs]
U.S. Department of Labor-OSHA
Room N3306, Frances Perkins Building
200 Constitution Avenue, N.W.
Washington, D.C. 20210
Ref: 29 CFR 1910.120 Standard Interpretation Letter to Randy Ross dated March 31, 1992
Dear Mr. Miles:
As a Board member of the New England Hospital Engineers Society, I am requesting a further clarification of OSHA's standard interpretation letter to Randy Ross dated March 31, 1992 (attached) concerning 29 CFR 1910.120 and it's implications for medical personnel exposed to patients contaminated with hazardous waste.
On the second page, in the section which amends the June 7, 1991 letter to Dalena Berret, you state ". . . the designated employee who will operate the decontamination facility must have at least first responder operations level training. . . ." As a further clarification of this, can this be interpreted to mean that ". . . the designated employee who will operate the decontamination facility must have at least first responder operations level training and hospital personnel (medical staff) who are involved with the patient only to provide medical care must be trained as skilled support personnel in the appropriate use of personal protective equipment and personal decontamination to facilitate treatment."
Thank you for your time in considering this addition and clarification to the letter and I look forward to your response.