Training for workers in uncontaminated hazardous waste site areas

APR 24 1990

William P. Todsen, P.E.
Chief, Engineering Division
Department of the Army
Missouri River Division, Corps of Engineers
[Recipient address omitted]
Dear Mr. Todsen:

This is in response to your letter of February 12, concerning the application of training requirements in the Hazardous Waste Operations and Emergency Response standard (29 CFR 1910.120) to hazardous waste cleanup operations.

Employees are not covered by the standard if they:

1. Work exclusively within uncontaminated areas of the hazardous waste site.

2. Do not enter areas where hazardous waste may exist, are stored or are processed; and

3. Are not exposed to health or safety hazards related to hazardous waste operations.

Consequently, it appears that workers in your example (a), such as clerical or support personnel, or those engaged in construction activities in uncontaminated areas who meet all the conditions described above are not required to be trained under the standard. However if employees' work activities do not meet all of the exclusion criteria described above, employees must be trained for the duration and in the subjects specified in paragraph 1910.120(e).

It is unclear in your example (b) whether the workers remain exclusively within the uncontaminated areas. The requirements stated above can also be used to determine coverage for these employees.

I hope this information is helpful.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

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