Hazwoper Training Required?
We have employees perform routine cleaning on ducts and slide gates which contains hazardous material.
Would that constitute the need for Hazwoper certification training?
Comments (6)
How much hazardous materials are they being exposed to on average? If it's just incidental spills, then in most cases, HazCom training will cover that. If it's an emergency response or large spill/release/leak, then HAZWOPER training would be required. I'll wait on further details from you, but I'm going to assume that HazCom training would cover this type of incidental exposure.
Below is a letter of interpretation that goes into some considerations when determining if it's incidental spill cleanup versus emergency response. An "emergency response" doesn't have to be calling 911, either, but I still don't think you're meeting that requirement and triggering HAZWOPER training.
https://www.osha.gov/laws-regs/standardinterpretations/1990-07-31
I agree with Drew. I've had this conversation dozens of times in my career.
My personal opinion is that it really does not matter. At the end of the day you have to train your employees and put in controls to mitigate the hazards at hand. That's really all HAZWOPER is when you get down to it...it's a little more structured, but it's really just training on hazards encountered by hazardous waste workers.
If you happen to take 40 hours to accomplish that training (doesn't have to be all at once) and you cover everything in 1910.120(e) and you want to print a certificate and call it HAZWOPER...why not?