OSHA specific on 8-hour HAZWOPER refresher training  

Mar. 28, 2008

By Mark J. Fisher
Environmental and Munitions
Center of Expertise

The Occupational Safety and Health Administration's (OSHA's) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard was written to protect workers in three uniquely different industries:  cleanup operations, operation of treatment, storage and disposal facilities, and emergency response operations.  Not surprisingly, OSHA expects annual refresher training to reflect the safety and health hazards unique to each industry. 
 
The work the U.S. Army Corps of Engineers (USACE) performs for the Installation Restoration Program (IRP), Formerly Used Defense Sites (FUDS), Environmental Protection Agency (EPA) Superfund and Formerly Utilized Sites Remedial Action Program (FUSRAP) is considered cleanup work and as such, eight-hour annual refresher training for USACE personnel working in these programs should follow the refresher training requirements specified in paragraph (e) of the HAZWOPER standard.  USACE organizations should also be careful not to confuse paragraph (e) requirements with emergency response refresher training requirements specified in paragraph (q) of the standard.
 
A well designed eight-hour refresher course for cleanup operations, whether presented by an instructor in a traditional classroom setting or offered through an online service, will cover the technical requirements from paragraph (e) (8) of the HAZWOPER standard (29 CFR 1910.120/29 CFR 1926.65) and allow sufficient student interaction with knowledgeable safety and occupational health professionals.  Technical requirements for cleanup operations refresher training include the following:  

1.  Evaluation of safety and occupational health incidents at cleanup projects from the past.  Primarily from the previous year but incidents from the more distant past are acceptable.
2.  Identification of USACE staff with direct responsibility for developing and implementing safety and occupational procedures for working on cleanup projects.
3.  Safety and occupational health hazards typical of USACE cleanup operation.
4.  Use of personal protective equipment on cleanup projects.
5.  USACE work practices and procedures that minimize risk from safety and health hazards on cleanup projects.
6.  Use of engineering controls and equipment to minimize exposure to safety and health hazards at cleanup projects.
7.  Medical surveillance requirements for cleanup operations including signs and symptoms of exposure to typical contamination.
8.  Decontamination procedures typical of USACE cleanup operations.
9.  Emergency response planning procedures and technical requirements typical of USACE cleanup operations.
10.  Confined space recognition and entry procedures.
11.  Spill containment procedures for handling liquids and solids from drums and containers.
 
Refresher training requirements covered by OSHA's HAZWOPER standard are industry specific and as a result, refresher training courses are not created equally.  Refresher training courses for USACE organizations with environmental cleanup missions should comply with refresher training requirements for cleanup operations, should provide information relevant to the safety and health of staff performing the cleanup mission and should not be interchanged with refresher training courses intended for treatment storage and disposal operators or emergency responders.
 
Point of contact at the EM-CX for hazardous waste site cleanup safety and health requirements is Mark Fisher at 402-697-2587.