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OSHA has stated in many interpretation letters that 40 hour HAZWOPER and 24 hour HAZWOPER require site specific hands-on training on the actual PPE an employee will be using in their job. Site specific means just that – the training cannot be done with generic PPE but most be done with the actual equipment in order to fully meet the OSHA regulations.
Listed below are key definitions related to 24 hour HAZWOPER training.
Emergency Response. An “emergency response” is an organized response to an incident that is, or may pose, an emergency. Since every industry will experience different kinds of emergencies, OSHA will not attempt to create a formula into which all emergencies will fit. Appendix A of this instruction provides further guidance.
Hazardous Substance. Hazardous substance means any substance designated or listed under the paragraphs below, and exposure to which results or may result in adverse affects on the health or safety of employees:
(1) Any substance defined under section 101(14) of CERCLA;
(2) Any biological agent and other disease-causing agent which after release into the environment and upon exposure, ingestion, inhalation, or assimilation into any person, either directly from the environment or indirectly by ingestion through food chains, will or may reasonably be anticipated to cause death, disease, behavioral abnormalities, cancer, genetic mutation, physiological malfunctions (including malfunctions in reproduction) or physical deformations in such persons or their offspring;
(3) Any substance listed by the U.S. DOT as a hazardous material under 49 CFR 172.101 and appendices; and
(4) Hazardous waste which means a waste or combination of wastes defined in 40 CFR 261.3, or those substances defined as hazardous wastes in 49 CFR 171.8.
Appendix B of OSHA’s HAZWOPER standard (29 CFR 1910.120) sets forth information about 24 hour HAZWOPER personal protective equipment (PPE) protection levels that may be used to assist employers in complying with the PPE requirements of the HAZWOPER standard. As required by the HAZWOPER standard, PPE must be selected which will protect employees from the specific hazards which they are likely to encounter during their work.
Selection of the appropriate 24 Hour HAZWOPER PPE is a complex process which should take into consideration a variety of factors. Key factors involved in this process are identification of the hazards, or suspected hazards; the routes by which employees could be exposed to the potential hazard (inhalation, skin absorption, ingestion, and eye or skin contact); and the performance of the PPE materials (and seams) in providing a barrier to these hazards. The amount of protection provided by 24 Hour HAZWOPER PPE is material and hazard specific. That is, protective equipment materials will protect well against some hazardous substances and poorly, or not at all, against others. In many instances, protective equipment materials cannot be found which will provide continuous protection from the particular hazardous substance. In these cases, the 24 Hour HAZWOPER PPE must be changed or work must stop before breakthrough time is reached.
Relevance of Other HAZWOPER Training Levels to First Responders and 24 Hour HAZWOPER
An OSHA letter of interpretation discusses the roles of 24 Hour HAZWOPER responders and other emergency responders at the scene of a hazardous substance release. “Standard emergency medical practice dictates that HAZWOPER personnel are to survey the accident scene and remain away from the hazard area until it is safe to approach. In the case of a HAZWOPER roadway emergency, the incident needs to be brought under control by more highly skilled HAZWOPER emergency responders before it would be permissible for personnel, including those certified at the first responder operations level, to enter to perform rescue or provide medical treatment.” (OSHA, 1995-Nechis).
First responder training beyond the operations level is not necessary for worker activities that are restricted to medical treatment and decontamination.
However, many HAZWOPER first responders have qualifications at higher levels of HAZWOPER training. These are personnel who elect to be cross-trained to serve an expanded role (e.g., firefighter, HAZMAT team member), and might receive other levels of hazwoper training as needed in support of those additional roles. For example, firefighters commonly obtain additional education to qualify as emergency responders (in addition to continuing to qualify as firefighters) and some HAZWOPER personnel are trained at the 24 hour HAZWOPER Hazardous Materials Technician or Hazardous Materials Specialist level to serve on special HAZMAT teams. Any HAZWOPER training that a responder receives beyond the first responder operations level would be to support the role of firefighter or HAZMAT team member. The responder might, in the capacity of firefighter, enter dangerous areas to perform non-medical activities such as controlling a hazardous substance release or performing rescue, for which the higher level of HAZWOPER training is required.