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Hazardous-waste site training coverage

Summary An environmental services company asked when hazardous-waste operations training applied to its work. OSHA said the training requirements applied if the work was at a covered cleanup or removal site and employees might be exposed to hazardous waste or substances. The answer was tied to the interim rule cited in the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1987-06-29
Date issued
June 29, 1987
Status
Active
Status last verified October 10, 2026

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June 29, 1987

Ms. Jo Hoffman-Ferenchak
Industrial Hygienist
TSD Environmental Services, Inc.
[Recipient address omitted]
Dear Ms. Hoffman-Ferenchak:

This is in response to your request for an interpretation of training requirements in the hazardous waste interim final rule (29 CFR 1910.120(e)(2) and (3)) as it applies to your operations.

If the work you are performing is at a site covered by the scope of the standard, i.e. CERCLA site, RCRA removal site, or a site designated for clean-up by a State or local authority, and your employees may be exposed to hazardous wastes, hazardous substances, or any combination of hazardous wastes and hazardous substances, then the training requirements must be met.

Sincerely,
Leo Carey, Director
Directorate of Field Operations

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