Many companies online offer HAZWOPER courses. Unfortunately, many have no idea what the regulations say, require, or the scope of those who are covered. Hopefully, this will help clear some of this up.
HAZWOPER is divided into 3 primary sections. The regulation can be found at OSHA.gov under gerneral industry standards 29 CFR 1910.120.
People who are required to have the 40-hour course are those who work at uncotrolled hazardous waste sites. One such site would be the oil cleanup in the Gulf of Mexico currently underway. These sites are uncharcterized and require site analysis, maps, plans for site excavation, sampling, and health and safety, as well as other requirements because of their "unharacterized" nature. People on-site occassionaly for limited tasks (contractors and the like) are required to have only 24-hour certification, but must be under the direct supervision of a qualified supervisor at all times. This 24-hour certifcation is not the same as the 24-hour certification required for TSD facilites that will be discussed below.
The next HAZWOPER group is those who work at Treatment Storage and Disposal Facilities (TSDF). These people work in an environment that IS controlled (or should be). All plans have been written, all materials are known, all hazards have been identified, and the facility has an EPA identification number, and a RCRA permit. These people require a 24-hour certification that has specific elements. These requirements can be found in 29 CFR 1910.120 (p).
Finally, people who are involved in emergency response operations, regardless of the location, are required to have 1910.120 (q) training.
If a company is offering 40-hour certification, it is not sufficient to work at a TSDF, and additional training is required. You may ask yourself,"why?" the answer is, like a TSDF, 40-hour certification is site specific. So even if you have 40-hour certification, additional training is needed for every uncontrolled site you work on. Many do not realize this, employees and employers alike. The same holds true for the 24-hour certification. Additional training is needed if you take your 24-hour certification to another TSDF site.
Another element offered by many HAZWOPER training companies is the "dress out". This is a complete waste of time and money. Under the personal protective equipment regulations (and they are numerous) employees must be trained on each specific piece of personal protective equipment they are to use. This includes everything from safety glasses to SCBA's. So, for a training company to train students on, lets say tyvek suits, will only do the student any good if the student uses the exact same brand and style of tyvek suit. This includes manufacturer.
GORHAM Safety and Environmental Consulting sticks to what the regulations say must be offered. I also offer training that beats all my competitors hands down because I do not waste time on "dress outs", and other unimportant information that each individual employer, or operator of a particular site, must offer anyway. This is another reason why I do not offer the 40-hour course. This saves you, the client, time and money.
There are many other regulations that accompany, yet are separate from, the HAZWOPER regulations. Some of these include:
Medical Records (29 CFR 1910.1020)
Sampling for specific hazards such as lead, cadmium, benzene, etc. (29 CFR 1910.1000 z tables).
Fire brigade training.
Emergency action plans.
There may be many others depening on your indsutrial activities.
UPDATE:
I had a conversation with the OSHA Compliance Group the other day about a medical records/program problem. If found out some interesting information you may be interested in:
Employee medical records required under OSHA (HAZWOPER, etc.) are NOT subject to the HIPPA regulations. The employer must still restrict access, keep records for the required time period (30 years), and transfer them when the business is closed, or sold, to:
- The new employer
- A medical rcord archving service
- TO OSHA
I also verified that GORHAM safety and environmntal consulting is providing training that meets OSHA standards. I also made them aware (though they were already) that there are many so called HAZWOPER training programs out there that are misleading, and making employers spend money for training that OSHA would find unsatisfactory. New regulations are in the works hopefuly, to make all traineres register with OSHA, and have thier training programs verified.
