November 22, 1989

Mr. Stephen S. Odojewski
President
Waste Resource Associates, Inc.
2576 Seneca Avenue
Niagara Falls, New York 14305

Dear Mr. Odojewski:

This is in response to your inquiry concerning the training requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final standard (29 CFR 1910.120).

Your specific question is whether the eight hour minimal training requirement for first responders at the operational level is for eight contact hours or a "normal" work day. The eight hours assumes an eight hour work day with sufficient time for lunch and other breaks. Our suggestion is to develop a one-day or longer course depending on the needs of the workers so they are competent to perform their emergency response job duties.

I hope this information is helpful.

Sincerely,



Thomas J. Shepich, Director
Directorate of Compliance Programs