Step 4: Provide Safety Training to Cleanup Site Personnel

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Hazwoper & Emergency Response |

All workers at the site of cleanup operations must receive appropriate safety training (Sec. 1910.120(e)). Here’s what you’re required to do.

 

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Who Needs Safety Training

The required training must be provided to the following persons before allowing work in hazardous waste operations:

  • All workers working on the site, including equipment operators, general laborers and others, who are exposed to hazardous substances, health hazards or safety hazards; and
  • All supervisors and management responsible for the site.

 

What Training Must Cover

You must ensure that employees don’t participate in or supervise field activities until they have been trained to a level required by their job function and responsibility. Required training must “thoroughly cover”:

  • Names of personnel responsible for safety and health at the site;
  • The safety, health and other hazards at the site;
  • Use of PPE;
  • Work practices employees can use to minimize hazards;
  • Safe use of engineering controls and equipment at the site;
  • Medical surveillance, including how to recognize signs and symptoms of overexposure to hazards;
  • Decontamination procedures;
  • Emergency response;
  • Confined space entry procedures; and
  • The spill containment program for the site.

 

Initial training of employees and supervisors provided for above not necessary if there’s documentation or written certification that trainee has received equivalent training; however, employees and managers still need training on site-specific aspects and have appropriate field experience.

 

Training of Workers

 

General site workers, including equipment operators, general laborers and supervisors, engaged in removal of hazardous substance or other activities involving exposure to hazardous substances and health hazards must receive at least:

  • 40 hours of off-site instruction; and
  • 3 days of actual field experience under the direct supervision of a trained, experienced supervisor.

 

Workers on site occasionally to perform specific limited tasks like surveying and who are unlikely to be exposed over PELs and published exposure limits must get at least:

  • 24 hours of off-site instruction; and
  • 1 day of actual field experience under the direct supervision of a trained, experienced supervisor.

 

Workers on site regularly who work in areas that have been monitored and characterized to have exposures under PELs and published exposure limits, where respirators are not necessary and where there are no health hazards or potential of an emergency must get at least:

  • 24 hours of off-site instruction; and
  • 1 day of actual field experience under the direct supervision of a trained, experienced supervisor.

 

Workers who get 24 hours of training in accordance with the above must get 16 more hours and 2 more days of field experience if they become general site workers or are required to wear respirators.

Employees must also get at least 8 hours of refresher training a year, including critiques of incidents that occurred in the previous year that serve as training examples.

Training of Management and Supervisors

On-site management and supervisors directly responsible for, or who supervise employees in hazardous waste operations must get at least:

  • 40 hours of initial training; and
  • 3 days of actual field experience under the direct supervision of a trained, experienced supervisor.

Compliance Pointer: Training for on-site management and supervisors can be reduced to 24 hours of initial training + 1 day of field experience + 8 additional hours of specialized training at the time of job assignment on your health and safety program, PPE program, etc., if they’re responsible only for employees who require 24 hours of training in accordance with above.

 

Compliance Pointer: Initial training of employees and supervisors provided for above isn’t necessary if there’s documentation or written certification that the trainee has received equivalent training; however, employees and managers still need training on site-specific aspects and must have appropriate field experience.

Supervisors must also get at least 8 hours of refresher training a year, including critiques of incidents that occurred in the previous year that serve as training examples.

Other Training Requirements

 

Trainers must be qualified and either complete a training program for teaching the subjects or have the necessary academic credentials and instructional experience to teach the subjects. Instructors must demonstrate their skills and knowledge of the subject matter.

Employees and supervisors who successfully complete training must be certified by the instructor in writing. Anybody without a written certificate of training must be banned from engaging in hazardous waste operations.

 

 
 
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