Hazardous-waste training and professional certification

December 11, 1987

Mr. Gregory D. Kugler
Environmental Scientist
Andrews Environmental Engineering Inc.
[Recipient address omitted]

Dear Mr. Kugler:

This is in response to your inquiry of September 22, requesting whether the certification program you described is equivalent to the 40 hours of training required in paragraph (e)(2) of 29 CFR 1910.120 (Hazardous Waste Operations and Emergency Response).

The requirements of 29 CFR 1910.120(e) are somewhat job specific. That is , the employer will have to determine what training is necessary for his employees to knowledgeably and safely perform their job functions. Thus, it is not the intent of 29 CFR 1910.120 for the Occupational Safety and Health Administration (OSHA) to approve or disapprove generic courses or certifications.

If the certification program described in your letter is determined by an employer to meet the general training needs of any employees, those employees would also need site specific training on the items described in 29 CFR 1910.120(e)(1). This training could be done on the site.

I hope this information is helpful.

Sincerely,
Thomas J. Shepich, Director
Directorate of Compliance Programs

[Requester letter and third-party certification materials reproduced on OSHA's page; omitted here.]