Training requirements in 29 CFR 1910.120 concerning hazardous waste cleanup operations.

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.

APR 24 1990

William P. Todsen, P.E. Chief, Engineering Division Department of the Army Missouri River Division, Corps of Engineers Post Office Box 103, Downtown Station Omaha, Nebraska 68101-0103

Dear Mr. Todsen:

This is in response to your letter of February 12, concerning the application of training requirements in the Hazardous Waste Operations and Emergency Response standard (29 CFR 1910.120) to hazardous waste cleanup operations.

Employees are not covered by the standard if they:

Application of the training requirements under 1910.120(e) to underwater divers.

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.

August 31, 1989

Mark E. Falerios, C.I.H.
Manager, Health and Safety
Dunn Geoscience Corporation
Lincoln Centre, Suite 106
299 Cherry Hill Road
Parsippany, New Jersey 07054

Dear Mr. Falerios:

This is in response to your inquiry of August 3 regarding the application of the training requirements under the Hazardous Waste Operations and Emergency Response final standard (29 CFR 1910.120(e)) to underwater divers.

Application of OSHA's final standard for Hazardous Waste Operations and Emergency Response.

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 28, 1989

Richard F. Boggs, Ph.D
Vice President
Organization Resources Counselors, Inc.
1910 Sunderland Place N.W.
Washington, D.C. 20036

Dear Dr. Boggs:

This is in response to your inquiry requesting interpretations of OSHA's final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120).

For the sake of clarity, I will enumerate and respond to your questions in the order you raised them:

Exemption of employees who work at the perimeter of a hazardous waste site from training requirements of 1910.120(e).

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.

December 28, 1989

Mr. James H. Kleinfelder
President
Hazardous Waste Action Coalition
1015 Fifteenth Street, N.W.
Washington, D.C. 20005

Dear Mr. Kleinfelder:

This is in response to your letter of November 27, to Secretary Dole. We believe the following explanation will resolve your concerns. Please write again if you wish a more detailed explanation or other actions by the Occupational Safety and Health Administration (OSHA)

Training requirements under 1910.120 for employees providing services which do not disturb the hazardous materials on a waste site.

Archive Notice - OSHA Archive

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

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.

June 28, 1988

Mr. Owen B Douglass, Jr.
Manager Health & Safety
SPER Division WESTON
Weston Way West
Chester, Pennsylvania 19280

Dear Mr. Douglass:

This is in response to your letter to Mr. Leo Carey concerning the training requirements under OSHA's Hazardous Waste Operations and Emergency Response interim final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.

Training requirements 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.

December 4, 1991

Mr. C. K. Shufflebarger
Nassef Engineering and Equipment Company
Post Office Box 1046
Gonzalez, Florida 32560

Dear Mr. Shufflebarger:

This is in response to your inquiry of October 9, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120).

Site observations and writing reports and findings at hazardous waste sites.

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 5, 1992

Ms. Marianne C. Bojan
14500 Avion Parkway
Suite 300
Chantilly, Virginia 22021-1101

Dear Ms. Bojan:

This is in response to your inquiry of March 11, concerning the Occupational Safety and Health Administration's (OSHA's) training requirements for workers who will be involved in "site observations and writing reports and findings" at a hazardous waste site.

Employees who work at hazardous waste sites who are not involved in cleanup.

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 27, 1992

William Holzhauer
Corporate Counsel
Niagara Mohawk Power Corp.
300 Erie Boulevard
West Syracuse, New York 13202

Dear Mr. Holzhauer:

This is in response to your inquiry of September 14, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) regulation, 29 CFR 1910.120.

HAZWOPER applications.

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 19, 1991

Michael E. Ramer, C.I.H.
Supervisor, Environmental Health Programs
Public Service Company of Colorado
Anaconda Tower
Suite 1200
555 17th Street
Denver, Colorado 80202

Dear Mr. Ramer:

HAZWOPER refresher training and training documentation.

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 7, 1998

Paul W. Jonmaire, Ph.D.
Corporate Health & Safety Director
Ecology and Environment, Inc.
368 Pleasant View Drive
Lancaster, NY 14086

Dear Dr. Jonmaire:

This is in further response to your letter of march 4, 1998, concerning refresher training in accordance with paragraph (e)(8) of 29 CFR 1910.120, Hazardous Waste Operations and Emergency Response (HAZWOPER). I apologize for the delay in responding to your letter.