The training necessary for employees involved in worksite response and cleanup efforts is dependent upon the hazards at the sites and the activities and tasks the employees will perform. OSHA's HAZWOPER standard and its training requirements apply to efforts that are "HAZWOPER emergency responses" and hazardous waste site cleanups. It is important to understand that the training required for emergency response workers is quite different than that required for hazardous waste site workers. Training for both types of workers is described in the following sections.
For worksite response and recovery efforts that are not covered by HAZWOPER, workers must be trained as required by any other applicable General Industry (1910) and Construction Industry (1926) OSHA standards. For example, if there is a need to enter a permit-required confined space such as a sewer manhole, the employer would need to assure that the entrant(s) and attendant(s) are properly trained according to the Permit-Required Confined Spaces standard, 29 CFR 1910.146, prior to entry into the manhole.
If it is determined that response activities are considered a "HAZWOPER emergency response," then training for workers must minimally meet the requirements of 1910.120(q). The training levels and content required for these workers is dependent on the workers' expected duties during the emergency response. For example, workers who are likely to witness or discover a release and are expected only to initiate an emergency response by notifying the proper authorities must be trained to the first responder awareness level, 1910.120(q)(6)(i). Workers who respond in a defensive fashion without actually trying to stop the release (e.g., containing the release from a safe distance) must be trained to the first responder operations level, 1910.120(q)(6)(ii). Workers who are expected to approach the point of a hazardous substance release for the purpose of stopping the release must be trained to either the hazardous materials technician, 1910.120(q)(6)(iii), or the hazardous materials specialist level, 1910.120(q)(6)(iv). Alternatively, workers who are needed to temporarily perform immediate emergency support work (e.g., excavator operators) may be considered skilled support personnel (SSP). SSP must be provided an initial site briefing covering personal protective equipment use, the chemical hazards involved, and the tasks to be performed. Consequently, employers must evaluate the role and tasks workers will perform and train them appropriately.