HAZWOPER 40 work, involves working with hazardous substances that could cause serious injuries or health conditions. Cancer or some skin conditions can result from exposure in the past or repeated exposure over time. Not all exposure symptoms show up right away. For that reason, exercising caution and using the appropriate PPE become even more important. Employers must provide their employees with adequate HAZWOPER 40 training prior to work in these hazardous areas.
Can HAZWOPER 40 training be taken online? The HAZWOPER 40 Course is taken online. As with any training (classroom or online) the employer is required by regulations to train the employee(s) on performance based standards for any applicable equipment. This is a site-specific requirement and typically cannot be achieved in a regular public seminar or open enrollment class where training on a respirator(s) or PPE in general does not meet the site-specific regulatory requirement.
Respiratory protection requirements are well defined for specific emergency response situations. OSHA’s HAZWOPER standard and letters of interpretation dictate the levels of protection that OSHA requires for HAZWOPER 40 workers in cases of high hazard and when the hazard is very low. The respiratory hazard evaluation that employers conduct helps them define the types of respiratory protection that most HAZWOPER sites require. Employers of HAZWOPER 40 workers who could be called upon to play a role in emergency response must equip their workers to work safely in their assigned roles.
HAZWOPER 40 work can be some of the most hazardous work employees will face
HAZWOPER’s provisions require facilities to consider both overall performance and specific elements when complying with the standard. HAZWOPER is referred to as a performance-oriented standard, which allows employers the flexibility to develop a safety and health program suitable for their particular facility. The standard offers work practice guidelines to protect employees from potential risks, but also has specific requirements. In evaluating compliance with 29 CFR 1910.120, Compliance Safety and Health Officers (CSHO’s) shall consider both the specific requirements and whether the intent of the standard has been met.
The most important aspect of HAZWOPER 40 paragraph (q) is planning for emergencies through the development of an emergency response plan and/or an emergency action plan.
When reviewing an emergency response plan, the CSHO must evaluate the employer’s ability to contain, control, and cleanup hazardous substance(s) if an emergency were to occur.
If a facility does not have an emergency response plan or an emergency action plan, the employer must prove that the chemicals and the quantities used in the facility will not develop into an emergency incident if released in a (reasonably predictable) worse-case scenario. In other words, if there is a potential for an emergency, the employer must plan for it, and if there is no potential then the employer does not fall within the scope of HAZWOPER 40. (See Appendix E of this instruction for guidance on releases that require an emergency response.) Although HAZWOPER 40 may not apply, incidental chemical releases are still covered by the Hazard Communication standard, 1910.1200 and 1926.59. Check what, if any, written procedures exist in the employer’s written hazard communication program for handling incidental releases.
Paragraph (q) of HAZWOPER 40 lists seven emergency responder categories, which include five principal training levels (first responder awareness level, first responder operations level, hazardous materials technician, hazardous materials specialists, and on-scene incident commander), skilled support personnel, and specialist employees. Employees responding to emergencies at different levels in the command structure are required by the OSHA HAZWOPER standard to have specific training that is intended to ensure that emergency responders are properly trained and equipped to perform their assigned tasks.
OSHA Instruction “OSHA Responses to Significant Events of Potentially Catastrophic Consequences,” offers guidance and procedures that will apply to many inspections covered under this instruction. Prior to inspection of any emergency response, or in a routine review of the emergency response provisions of HAZWOPER, compliance staff are advised to review both this instruction and OSHA HAZWOPER 40 guidance documents to ensure the safety and health of CSHO’s and employees and to provide consistent and uniform application of OSHA HAZWOPER policy.
HAZWOPER 40 certification can be done by completing either the 40 or 24 hour HAZWOPER course. These are widely considered to be the initial courses for HAZWOPER certification. Annual refresher must then be taken to maintain the certification. The OSHA HAZWOPER 40 refresher certification course is widely known as the HAZWOPER 8 hour annual refresher. Employers and instructors have dual responsibility to make sure the student is certified.
The basic steps for determining necessary HAZWOPER 40 training and PPE include:
1) The employer determines the HAZWOPER 40 responder’s expected role in a reasonably anticipated worst-case scenario.
2) The employer conducts a hazard assessment to identify any anticipated hazards associated with the HAZWOPER responder’s role during such a response.
3) The employer develops an Emergency Response Plan that spells out how the HAZWOPER 40 responders will be prepared to safely perform their anticipated roles. The plan should indicate the level of training that the HAZWOPER responders should receive and the type of PPE that will be provided to those responders.
A summary of OSHA’s Recommendations for HAZWOPER 40 Training and PPE, both PPE and respiratory protection are prescribed for hazardous environments by the HAZWOPER standard, which requires an SCBA respirator and Level A or Level B PPE, as defined by Appendix B of the HAZWOPER standard.
HAZWOPER 40 paragraph (q) outlines requirements for advance planning, training, medical monitoring and PPE for emergency responders. Several specific categories of emergency response personnel are defined in this paragraph, including first responder awareness level and first responder operations level. OSHA’s compliance directive for paragraph (q) specifically includes “emergency medical services” responding to a hazardous substance release area.
OSHA has clarified that the HAZWOPER 40 standard only applies to emergency releases, or substantial threats of releases, of hazardous substances. HAZWOPER does not necessarily apply to every incident in which an individual requiring medical treatment is contaminated with [a] hazardous substance. OSHA cannot require HAZWOPER 40 training for incidents outside the scope of the standard, although such training may be beneficial. The scope of the HAZWOPER 40 standard does not cover “incidental releases,” releases that are limited in quantity and pose no emergency or significant threat to the safety and health of workers in the immediate vicinity.