Standard Interpretations - Table of Contents|
| Standard Number:||1910.120; 1910.120(q); 1910.120(q)(6)(v) ; 1910.120(q)(7) ; 1910.120(q)(8)|
|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.|
"(7) Trainers. Trainers who teach any of the above training subjects [section (q)(6)(i)-(v)] shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy or they shall have training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach."Pertaining to BP's desire to certify the training subjects as "trained," Section 1910.120(q) does not delineate specific procedures, however, OSHA interprets the language of section 1910.120(q); "the employer shall so certify", to imply that the employer shall provide written certification to all personnel that have successfully completed the training for each and all of the various responder levels identified in Section 1910.120(q)(6). Certification of the yearly refresher training is also required in Section 1910.120(q). The pertinent section of the final rule states:
"(8) Refresher Training. (i) Those employees who are trained in accordance with paragraph (q)(6) of this section shall receive annual refresher training of sufficient content and duration to maintain their competencies or shall demonstrate competency in those areas at least yearly. (ii) A statement shall be made of the training or the competency and if a statement of competency is made, the employer shall keep a record of the methodology used to demonstrate competency."This guidance pertains to a current interpretation of the HAZWOPER final rule (1910.120).
|Standard Interpretations - Table of Contents|