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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 https://www.osha.gov.
April 23, 2021
Mr. Brett Postelli
565 E. Hillsboro Blvd.
Deerfield Beach, Florida 33441
Dear Mr. Postelli:
Thank you for your letter to the Occupational Safety and Health Administration’s (OSHA) Directorate of Enforcement Programs, regarding training requirements of OSHA’s Hazardous Waste Operations and Emergency Response (HAZWOPER) standard, 29 CFR § 1910.120. This letter constitutes OSHA’s interpretation only of the requirements herein and may not be applicable to any situation not delineated within your original inquiry. Your question is summarized below, followed by our reply.
Background: Your concern regards employees receiving initial 24- or 40-hour HAZWOPER courses through computer-based training absent an actual hands-on training component (e.g., donning and doffing personal protective equipment (PPE)). You share that employees often receive HAZWOPER training certification without practical field experience as specified in 29 CFR § 1910.120 paragraphs (e)(1) through (e)(4), which may put themselves and others at risk when working in hazardous waste environments.
Question 1: Should the 24- or 40-hour initial HAZWOPER training course ensure that employees receive actual hands-on training in addition to in-person, classroom, or computer-based course instruction?
Response: Yes. Employers are required to ensure that employees receive HAZWOPER training from qualified trainers as specified in 29 CFR § 1910.120(e)(5). In-person, classroom, and computer-based HAZWOPER training courses must include course instruction in addition to an actual hands-on training component. It is important that the training include an opportunity for employees to become familiar with or to refresh their skills using PPE and safe practices in a non-hazardous setting. Online training that does not provide workers with an actual hands-on component would not comply with OSHA’s worker training requirements. See letter of interpretation to Mr. Anthony Chibbaro (July 11, 2019) (copy enclosed).1
Question 2: Is the initial HAZWOPER training course instruction the best stage in an employee’s certification process to provide actual hands-on instruction on donning and doffing of PPE?
Response: See above Response 1.
Question 3: Is an employee’s actual hands-on training component required during the initial 24- or 40-hour component, or only during the employer’s three-day site-specific supervision?
Response: The actual hands-on training component of an employee’s HAZWOPER training should occur during the initial HAZWOPER training course and must be completed prior to the employee’s three-day field experience component. Supervised field experience is part of an employee’s initial training, which takes place after he or she has completed course instruction. See letter of interpretation to Mr. Ron Gantt (August 16, 2004) (copy enclosed). 2
Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA’s requirements are set by statute, standards, and regulations. Our letters of interpretation do not create new or additional requirements but rather explain these requirements and how they apply to particular circumstances. This letter constitutes OSHA’s interpretation of the requirements discussed. From time to time, letters are affected when the agency updates a standard, a legal decision impacts a standard, or changes in technology affect the interpretation. To ensure that you are using the correct information and guidance, please consult OSHA’s website at https://www.osha.gov. If you have further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.
Patrick J. Kapust, Acting Director
Directorate of Enforcement Programs