Under OSHA regulations, construction companies must instruct personnel on how to stay safe on sites where they may face exposure to hazardous waste. Here’s how an organization should manage hazardous waste training.
When Is Hazardous Waste Training Necessary?
Under OSHA Hazardous Waste Operations and Emergency Response (HAZWOPER) standards for the construction industry, all employees need hazardous waste training if they are involved in one of these activities:
- Clean-up at unmanaged hazardous waste sites, like Superfund projects.
- Clean-up at sites covered under the Resource Conservation and Recovery Act (RCRA).
- Emergency response to “hazardous substance releases or substantial threats of releases.”
- Any operations involving hazardous waste at waste treatment, storage and disposal facilities.
Organizations need to provide this training in addition to other employee protections, including medical surveillance for workers, an OSHA-compliant site control program and a written health and safety program.
There are exceptions to these rules if a construction company can prove that employees won’t face exposure to hazardous materials during construction. Regulatory bodies only consider certain kinds of waste dangerous, and you won’t need to provide training if no hazardous waste or substances are on-site.
How Much Waste Training Do Workers Need?
Different operations require different levels of training. Every employee working on the sites listed above will need hazardous materials training, but the amount and type of training will vary from job to job.
Workers on uncontrolled hazardous waste operations need the most instruction. Regular workers will need 40 hours of initial training and three days of actual field experience. Workers who only visit the site occasionally will need 24 hours of training and one day of supervised field experience. Supervisors and managers who will be on-site need an additional eight hours of training. All employees will also need an annual refresher course to maintain their knowledge and stay certified.
Workers at treatment, storage and disposal facilities licensed under RCRA need less training — just 24 hours for certification. They will also need an annual refresher course.
Training for emergency response workers at sites that are not licensed under the RCRA or considered uncontrolled hazardous waste sites will vary depending on worker roles. For instance:
- First-responders at the “awareness” level must show competency in certain areas related to hazardous waste management — like recognizing the presence of harmful materials.
- First-responders at the “operations level” must demonstrate the same competency, and also need eight hours of training.
- Hazardous materials technicians, specialists and on-scene incident commanders will all need 24 hours of training that prepares them for job responsibilities required by their role. For example, hazardous materials technicians must know how to carry out their employer’s clean-up plan and decontaminate the site.
All of these workers will also need an annual refresher course.
The exact type of training each worker needs will vary depending on their role. For example, training at the “first responder operations level” must teach employees to respond aggressively without trying to stop or eradicate the release. Businesses can find the full HAZWOPER training guidelines in 29 CFR 1926.65(q)(6), which is available on OSHA’s website.
Training Construction Workers for Hazardous Waste Operations
If an employee of a construction company works on a site where they may face dangerous materials, they will probably need hazardous waste training. The amount of instruction depends on the type of hazardous waste site worked on and the employee’s role. Almost every employee, however, will need hours of formalized, hands-on training before they’re certified to work on these sites.
This article was written by Emily Folk, a freelance writer covering topics in green technology and sustainability. You can follow her on her blog, Conservation Folks, or Twitter @EmilySFolk for her latest updates.