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Eight-hour training for hazardous-waste first responders

Summary An employer asked whether the eight-hour minimum training requirement for first responders at the operational level means eight instructional hours or a normal workday. OSHA said the requirement assumes an eight-hour workday that includes lunch and other breaks, and suggested a course lasting one day or longer as needed for worker competence. The guidance concerns employers training hazardous-waste emergency responders.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1989-11-22
Date issued
November 22, 1989
Status
Active
Status last verified October 10, 2026

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About this page: The full text below is the official document from Occupational Safety and Health Administration (OSHA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.

November 22, 1989

Mr. Stephen S. Odojewski
President
Waste Resource Associates, Inc.
[Recipient address omitted]
Dear Mr. Odojewski:

This is in response to your inquiry concerning the training requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final standard (29 CFR 1910.120).

Your specific question is whether the eight hour minimal training requirement for first responders at the operational level is for eight contact hours or a "normal" work day. The eight hours assumes an eight hour work day with sufficient time for lunch and other breaks. Our suggestion is to develop a one-day or longer course depending on the needs of the workers so they are competent to perform their emergency response job duties.

I hope this information is helpful.

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

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