June 30, 1989

John P. Goniglio, C.S.P.
President
Risk & Technical Management, Inc.
700 Main Street
Buffalo, New York 14202

Dear Mr. Goniglio:

This is response to your inquiry concerning the training certification requirements of the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response rule (29 CFR 1910.120). Specifically, you are interested in whether there is some agency and/or individual who could review your qualifications to determine whether they meet the requirements of the rule.

It is the employer who can show by documentation or certification that an employee's work experience and/or training meets the requirements of the rule. If you are the employer, then you can certify yourself. OSHA does not certify individuals. This summer, OSHA expects to propose in the Federal Register a program for certifying courses under the rule. There will be an opportunity for interested parties to comment on the proposal and participate in public hearings.

I hope this information is helpful.

Sincerely,

Patricia K. Clark, Acting Director
Directorate of Compliance Programs