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Emergency response team training at a plating facility

Summary A plating department asked whether its team for hazardous chemical spills needed the interim HAZWOPER emergency response training. OSHA said the described policy fell under the emergency response provision and required 24 hours of training. OSHA now archives the letter as potentially outdated.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-05-23-3
Date issued
May 23, 1989
Status
Archived by the agency
OSHA archives this letter and says it may no longer represent OSHA policy.
Status last verified October 10, 2026

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The current status of this document is unclear
OSHA archives this letter and says it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

May 23, 1989

Mr. Larry McHugh
Plating Department
E. H. Titchener & Company
[Recipient address omitted]
Dear Mr. McHugh:

This is in response to your inquiry of January 9, concerning the application of the emergency response provisions of the Occupational Safety and Health Administration's (OSHA) interim final standard for Hazardous Waste Operations and Emergency Response (29 CFR 1910.120).

Emergency response training under 29 CFR 1910.120(l)(3) is applicable for emergency responses at sites other than hazardous waste cleanup sites (e.g., employers covered by 29 CFR 1910.120(a)(1)(i), (ii), and (iv)). Thus, 29 CFR 1910.120(l)(3) is applicable for the emergency response policy described in your letter and 24 hour training would be required. A copy of the standard is enclosed for your reference.

If you have further questions, please feel free to contact OSHA's New York Regional Office at:

Regional Administrator
U.S. Department of Labor - OSHA
201 Varick Street, Room 670
New York, New York 10014

Telephone: (212) 337-2325

I hope this information is helpful.

Sincerely,

Patricia K. Clark, Acting Director
Directorate of Compliance Programs
Enclosure

[Requester letter reproduced on OSHA page; omitted here.]

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