Are you confused by HAZWOPER and RCRA training requirements? So you heard about providing 40-hour HAZWOPER/RCRA training for your hourly personnel and frontline supervisors, but how much training is required for other staff, such as administrative personnel? Avoid over-training your employees by knowing exactly who needs training, and when, at your hazardous waste treatment, storage, and disposal facility (TSDF).

OSHA HAZWOPER Training Requirements

TSDFs with NO Corrective Actions Involving Cleanup - Workers at these sites need 24 hours' initial training and 8 hours' annual refresher training. The TSDF rule doesn't specify whether any of the initial training is required to be on-site.

TSDFs with Corrective Actions Involving Cleanup - Workers at these sites must do the full 40-hour training. The trainer must have completed a training course for teaching the subjects presented in the worker training course (29 CFR 1910.120(p)(7)(iii)).

Emergency Responders - These workers must be provided with training that meets HAZWOPER requirements at 29 CFR 1910.120(q). If your staff is required to respond to hazardous substance releases, the employees with that responsibility must be trained. If you have hired a contractor for emergency response, you don't need to train your workers; however, if this is the case, you may want to train one or more workers to be a first responder (awareness level).

Administrative Staff - If these employees do not enter work areas where hazardous materials are present they do not need HAZWOPER training. However, they may need some training under EPA's TSDF training rules.

Employees Who Enter a Corrective Action or Cleanup Site Work Area Occasionally - Examples of these employees are groundwater monitors or surveyors. These employees need 24 hours of off-site training and 1 day of supervised filed experience.

EPA's TSDF Training Requirements

TSD Site Workers - These employees must complete classroom or on-the-job training, and receive annual refresher training, designed to ensure compliance with EPA rules (40 CFR 264.16 and 265.16). There is no minimum number of training hours; you are just required to provide enough training to ensure compliance with TSDF rules in general. This type of training is not the HAZWOPER training, but focuses on the use and maintenance of emergency and monitoring equipment, alarm systems, response to fires/explosions, response to groundwater contamination incidences, and shutdown of operations.

Administrative Staff - These workers may need the EPA training if they could be involved in supporting workers conducting the emergency or groundwater contamination responses.

Don't forget about recordkeeping. HAZWOPER and EPA rules also have requirements regarding training recordkeeping.