Medical clearance for respirator wearers in emergency response situations.

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.

November 16, 1994

Mr. J. R. Toren
General Counsel
Delta Environmental Consultants
3900 Northwoods Drive Suite 2000
Saint Paul, Minnesota 55112

Dear Mr. Toren:

Thank you for your letter of March 10, concerning a request for clarification on medical clearance for respirator wearers in emergency response situations. Please accept my apology for the delay in this response.

Clarification on HAZWOPER emergency response training requirements.

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.

November 8, 1994

Robin Morecroft, P.E. Manager, Operations Engineering Mission Operation and Maintenance, Inc. Suite 300 12500 Fair Lakes Circle Fairfax, Virginia 22033

Dear Mr. Morecroft:

Thank you for your letter of May 10, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120.

1910.120 Application to Petroleum Product Spills or Releases Subject to State Codes

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.

July 17, 1991

Mr. Lawrence M. Sontoski
Radian Corporation
5103 W. Beloit Road
Milwaukee, Wisconsin 53214

Dear Mr. Sontoski:

This is an updated response to your request to Mr. Gerald Cunningham for interpretations of OSHA's Hazardous Waste Operations and Emergency Response Standard, 29 CFR 1910.120. You raised several issues and questions which will be answered in the same order as your presentation.

Eight hours refresher training per year required specific to job responsibilities at a TSDF.

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.

May 15, 1991

Mr. Jack Powers
Section Manager, Occupational Safety and Health
McDonald Douglas Inc.
Building 4, Dept. #064, Mail Code 0012491
Post Office Box 516
St. Louis, Missouri 63166

Dear Mr. Powers:

This is in response to your telephone inquiry of Thursday, April 11, 1991 concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.

Training and certification procedures of Hazwoper.

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.

May 13, 1991

Ms. Karen L. Artz
Training Coordinator
BP Oil Company
4850 East 49th Street
Cleveland, Ohio 44125-1079

Dear Ms. Artz:

This is in response to your inquiry of February 22, concerning the training and certification procedures in the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120) HAZWOPER. Please accept my apology for the delay in this reply.

Training requirements for employees in food storage facility where ammonia is used solely as a refrigerant.

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.

May 10, 1991

Mr. William Murray
Safety Coordinator
Christian Salvesen Inc.
One Enterprise Avenue
Secaucus, New Jersey 07094

Dear Mr. Murray:

Thank you for your inquiry of March 12, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.

The acceptability of a computer based, self-paced training program for use in meeting the refresher training requirements of the standard.

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.

October 11, 1994

Mr. Gerald J. Joy
Health and Safety Director
ICF Kaiser Engineers, Inc.
Environment and Energy Group
Four Gateway Center
Pittsburgh, Pennsylvania 15222-1207

Dear Mr. Joy:

Voluntary safety and health audits under the Occupational Safety and Health Act

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.

September 11, 1996

Mr. Frank White
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place, NW
Washington, D.C. 20036

Dear Mr. White:

Thank you for your letter to Secretary Reich concerning voluntary safety and health audits under the Occupational Safety and Health Act (the Act). Secretary Reich has asked me to respond. I appreciate Organization Resource Counselors' (ORC) interest in this issue. ORC's expertise in occupational safety and health issues is well established, and its views merit careful consideration.

Worker protection for employees incinerating hazardous waste on cement plant property.

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.

May 15, 1996

Mr. Thomas Blank
Communications Director
Association for Responsible
Thermal Treatment
1090 Vermont Avenue, N.W.
Washington, D.C. 20005

Dear Mr. Blank:

Clarification of the requirements of the Hazardous Waste Operations and Emergency Response Standard

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.

October 31, 1997

Mr. Daniel H. Sherman IV
Long, Aldridge & Norman
One Peachtree Center
303 Peachtree Street, Suite 5300
Atlanta, Georgia 30308

Dear Mr. Sherman: