Hazwoper Training Certification

Many people are surprised to see blood featured as one of the main topics in HAZWOPER training. Let’s face it, if you’re working with chemicals, then why do you need training about blood-borne diseases? It’s understandable that if you’re working in a hospital, then you may be working with blood products, or perhaps even human waste produced during surgery. In fact, every worker in almost every workplace should have training related blood and blood spills.

What no one knows is what is going on internally with their workmates. They could appear to be regular everyday people, yet inside, they could be HIV+, carry one of the Hepatitis diseases, or be infected with any number of other diseases. If they are injured in the workplace, and there is a blood spill, everyone needs to protect themselves – just in case. We live in a society where we don’t need to tell everyone our problems – that’s our business, and for most people who are carrying a blood-borne disease, they just want to lead as normal life as possible. Most people are okay with that, and so is the Department of Labor.

Rather than having every single person tattooing their illness on their forehead, we put in place barrier protection that ensures no one else is as risk of contamination. This is where HAZWOPER training can be important. The training itself deals with hazardous waste that may be contaminated with blood-borne pathogens from any source. This includes people being injured, and waste that comes from hospitals and laboratories.

The 40 hour HAZWOPER training program includes the modules:

• Introduction to Bloodborne Pathogens
• Bloodborne Pathogens: Control and Compliance
• Bloodborne Pathogens: Understanding Hepatitis B
• Bloodborne Pathogens: Communication and Training
• Bloodborne Pathogens: Revision and Additions to OSHA Standards

This provides training to those who will be involved with the clean up of any accidents where the material in question could be classified as hazardous. Because we don’t know the medical history of anyone injured, every blood spill is automatically classified as hazardous. This ensures the protection of everyone.

In many workplaces, HAZWOPER training is mandatory before a worker is allowed to undertake any task, even if their work is not related to any hazardous materials. It is important for employers to carefully assess their workplaces in accordance with OSHA guidelines as HAZWOPER training, while mandatory, is often not the only training required. In most cases, OSHA guidelines insist on three days of on-the-job training related to the hazardous materials located on site.

There is a mistaken belief that HAZWOPER training is all that is required. It’s not; in fact, it’s considered to be the minimum requirement. In some instances, employees will require more in-depth training to meet OSHA guidelines. This training could include the use of breathing apparatus, HazMat suits and confined spaces training just to name a few. Failure to provide extra OSHA training can lead to heavy fines and the closure of a workplace until employees have been trained to meet the required standards.

Some training, for example, HAZWOPER and confined spaces, can be undertaken online. Other training is more specialized, for example, the use and decontamination of HazMat suits. This training needs to be completed onsite by experts in that particular field. Online training does, however, allow employees to be trained in several different areas fairly quickly, especially if they are are willing to continue their training in their own homes after working hours. This helps to reduce the costs and ensures employees are fully compliant in the shortest period possible.

While training hours are stated, for example, 24 hour HAZWOPER training, these hours are only nominal and represent the shortest possible time that a student can spend on a course. Although self-paced, a student must spend a minimum of 24 hours online before they can pass this particular course. Before signing off an employees training requirements, check to ensure there are not further training requirements. In many cases there are, and as a employee, it’s your responsibility, not your employees.

We are currently living in a society that spends a lot of time and money cleaning up the mess left behind by our forebears. Hazardous waste sites are one example, and they are proving to be a big problem as time changes their effect on our environment. At the time, having a dump site on the edge of town was a good idea, however, towns grow and eventually these dump sites are surrounded by homes and factories. Towns are generally built close to a water source, often on the banks of rivers or lakes. Dump sites, because of their age, are now starting to leach materials into ground water, and into our rivers, lakes and streams. In some areas, land fill has been covered and homes have been built over the top. It’s only now we are seeing the effect these old dump sites are having on homes, and the people within them.

There has been a drive over the last ten years to clean up these old dump sites to make them less dangerous to our environment, and to our own health. Local, state and federal governments are a part of this program, and once an old dump site is identified, it takes on the title of Uncontrolled Hazardous Waste Site. It is described as ‘uncontrolled’ because hazardous materials are confined, they are free to affect our environment depending on rain, wind and the heat of the sun.

Workers require special training before they can work on a site that has been declared an uncontrolled hazardous waste site. If their work is not related to the actual clean up of hazardous wastes, then a 24 hours HAZWOPER training program is all that is required. If they are working in the actual clean up activities, they will need to complete the 40 hour HAZWOPER training program. Each program is designed to meet the safety requirements of each worker, so special care needs to be taken when deciding which course a worker requires. Unless a worker has completed the 40 hour course, they are not permitted to take any part in the actual clean up.

HAZWOPER training courses can be undertaken online by employees. Online training is delivered in an interesting and entertaining format where students set their own learning pace. On completion, students are able to print certificates signifying their completion, and the Department of Labor will issue OSHA cards that officially signify their compliance with HAZWOPER training requirements.

There is often a misconception in the community that specialist training is reserved only for those who actually work in those specialist roles. Sure, there are some training courses that are ‘reserved’, often because you require prerequisites. When it comes to OSHA training programs, everyone is eligible. Whether or not you should is a personal decision, and since these courses do cost money, you really do need to consider whether or not you are going to gain any advantage by studying these courses.

Of course, if you’re working and dissatisfied with your work, you can look at certain OSHA courses as a valuable asset on your resume. HAZWOPER is one course that could open doors, however, there is no guarantee. You could study the complete course and never put a minute of your training into practice.

Much will depend on your intentions. If you want to work in an environment where you could be called in to clean up hazardous waste spills, then you’ll need the 40 hour HAZWOPER training course. This is less than $350 so the cost can easily be justified, more so if you find gainful employment. If you want to work, for example, on a hazardous waste site where you are working at a trade, but not involved in the clean up, then the 24 hour HAZWOPER training program is all that you require. This course, at less than $250, is even easier to justify, if you can put it to good use.

OSHA training is there for everyone. In most cases, employers pay for their workers to undertake training in order to have them compliant under OSHA guidelines. If you come to an employer with your training already complete, you will be saving them the hassles of organizing and paying for that training. It may help to sway that employer into training you – there are, however, no guarantees.

Most employers know that the Department of Labor, through the Occupational Safety and Health Administration, requires that employees receive training to meet minimum workplace safety guidelines. Where hazardous materials are involved, this training is fundamental to ensuring that any spill is managed, contained, and cleaned away with a minimum effect on people’s health and the environment.  Spills can be defined as incidental and not requiring any specific processes, and emergency, requiring a speedy effort to control and minimize any damage. So how do you classify an ‘emergency’ when it comes to hazardous materials?

There are a number if criteria that could be used and much will depend on the workplace, the hazardous materials in question, and the amount that is causing an issue. OSHA define an emergency as:

• High concentrations of toxic substances.
• Immediately Dangerous to Life and Health (IDLH) environments.
• Situations that present an oxygen deficient atmosphere.
• Conditions that pose a fire or explosion hazard.
• Situations that require an evacuation of the area.
• Situations that require immediate attention because of the danger posed to employees in the area.

HAZWOPER training is a requirement for employees who are voluntarily involved in the control and cleanup of any hazardous materials. Because they are actively involved with hazardous materials, they must complete the 40 hour HAZWOPER training program rather than the 24 hour program. Workers who continue to be involved with hazardous material emergency response duties are also required to undertake a refresher course every 12 months. Workers are not compliant until they have completed their training including the post- training assessments.

When a spill of hazardous materials is discovered, having a well trained team that can get in, control the spill, then clean up is in everyone’s interest. As an employer, you are responsible for managing the training needs of your employees, and where hazardous materials are involved, an issue you need to get right.

As an employer, wading through the pages of complex legal jargon related to OSHA can be a nightmare. When it comes to hazardous materials, in particular hazardous wastes, it can be even harder. Do your employees need training in these areas, and if so, which level of training do they require. The OSHA website can be a blessing, and nightmare, depending on which pages you read, and how much you actually read. Let’s break a small part down shall we.

According to OSHA’s website:

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).

Comment – you will need to look elsewhere for information on what constitutes a ‘HAZWOPER” emergency. To continue:

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).

Comment – that’s clear enough and the HAZMAT First Responder Training – Awareness Level training program covers those workers.

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).

Comment – again, that is a clear indication of what training is required and the HAZMAT First Responder Training – Operations Level is all that is required of those workers. However, now it becomes murkier:

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).

This is where, as an employer, you have to dig a little deeper to determine whether or not HAZWOPER 24 or 40 hour training is sufficient, or whether or not an employee requires specialist training.

The Occupational Safety and Health Administration (OHSA) is responsible for setting standards that relate to occupational health and safety in workplaces. The are so many different types of workplaces, jobs, equipment, and chemicals in use that it’s virtually impossible to have a single set of standards. It is an employer’s responsibility to ensure that their workers are following OSHA guidelines, a task that many employers find difficult. HAZWOPER training has been specifically designed for those who work with hazardous materials, however, what happens when HAZWOPER standards (or any other standards) conflict with another OSHA standard?

There is a real risk that employees will automatically assume that HAZWOPER is the ‘senior’ or more important standard that must be followed. Common sense would probably argue that the standard that was most appropriate for the situation should be followed. OSHA has other thoughts, although they too follow common sense. According to OSHA:

…if HAZWOPER conflicts or overlaps with any other OSHA standard, the provision more protective of employee safety and health must be followed…

In other words, which ever standard provides the most protection for everyone, that is the standard that must be followed. HAZWOPER training, whilst important and a requirement in many work situations, should not be seen as the only standard, or the only training required.

In many workplaces, employees are required to have additional practical training on the job to be compliant with OSHA standards. Many employees already hold certifications – for example, crane operators – and they certifications have safety requirements of their own. When the two conflict, the message is simple, which standard provides the best protection for everyone?

If you work with or around hazardous materials, then you need some form of hazardous material training. This generally takes the form of a HAZWOPER or HazMat training program. What about those workers who are working in areas that are suspected of containing hazardous materials such as suspected hazardous waste sites?

The Occupational Safety and Heath Administration is very clear on this issue:

Workers, such as utility workers, who must perform duties at a hazardous waste site that has not yet been characterized but where contamination is expected, do fall under the scope of 29 CFR 1910.120. These workers must work under the direction of an on-site supervisor and a site-specific safety and health plan, and must be fully trained and protected pursuant to the HAZWOPER standard.

The term “not yet been characterized” refers to the fact that the site is suspected of containing hazardous waste, however, it has not as yet been characterized. Because utility workers are not involved in the actual clean up, they are only required to complete the 24 hour online HAZWOPER training program. In some circumstances, that training will require site specific practical training.

It is the employers responsibility for ensuring that workers have completed HAZWOPER training, and that they complete the annual refresher training program required for all individuals who continue to work in these areas. The only exception is where a site’s ‘suspected’ status is changed to ‘minimal risk’ – HAZWOPER training is then no longer a requirement.

HAZWOPER training can be completed online through a self paced training format. It is important to note that workers must have completed their training to be compliant in a workplace – if they are still working through the training material then they are not compliant, and should not be working around hazardous materials.

HAZWOPER training differs from many of the OSHA-compliant training programs in that a refresher course has to be completed each year. Failing to complete the refresher course means an individual is no longer compliant with OSHA standards and should not be working in any area where compliance is a requirement. There is often confusion surrounding when a refresher course needs to be undertaken, particularly when it comes to the 12 month requirement.

Does the 12 month requirement mean that refresher training has commenced within the 12 months, is completed within the 12 months, or must it start at the 12 month point. Many states have their own laws when it comes to OSHA, however, in most states, the refresher training component is standard – the employee must have completed their refresher course by the 12 month anniversary of the completion of their previous training.

There is also confusion relating to an employee who has completed a HAZWOPER training program, but then been away from the industry for a period of time, and so missed the refresher course. Do they need to complete the whole course, or can they just complete the refresher course. OSHA doesn’t stipulate how an employer should handle this situation.

The deciding issue is not related to time, it is related to knowledge. When returning to the workplace, the employer needs to satisfy themselves that the employee has retained much of the knowledge gained through their initial training. If they have not, then they will need to complete the full training package. If they have retained sufficient knowledge, then they need only complete the refresher training program.

Employers need to understand both their local state requirements and those set up by OSHA. Employees who have completed training will need to complete their 8 hour HAZWOPER refresher course by their anniversary date, and it’s the employers role to keep a track of these records.

An incidental spill of hazardous materials are not considered a danger. In fact, in many workplaces, the workers clean up any mess and get on with the job. Best practice procedures would suggest otherwise and to be compliant with OSHA guidelines, many workplaces are required to document even the smallest of spills.

When it comes to hazardous materials that have a high danger level, workplaces are supposed to follow a procedure that is designed to prevent any future incidental spills. This process is one of evaluating how the incidental spill occurred, and what procedures need to be put in place to ensure there are no further spills. This should all be documented with training or instructions issued to workers related to the way they handle the hazardous materials in the future.

Why does a workplace need to go through these processes? An incidental spill doesn’t create problems. However, if an incidental spill can occur, then it’s most likely only good fortune that it wasn’t a major spill. By ensuring that a workplace is protected against minor incidents, it is also protecting the workplace from major incidents.

The 40 hour HAZWOPER training program includes subjects that relate directly to identifying hazards, and potential hazards. This is the minimum training level for those who are involved in hazardous waste cleanup teams and is a good starting point for those interested in the more involved area of hazardous material control. This includes the design of procedures related to the safe use, storage and disposal of hazardous materials.

While an incidental spill is a minor event, it has the potential to become a major event. Learning from these incidental spills can help to prevent those major events, a process that is actually required in many workplaces.