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HAZWOPER training for occasional repair workers at disposal sites

Summary An equipment service company asked if mechanics visiting a disposal site for repairs needed HAZWOPER training. OSHA said workers exclusively in uncontaminated areas, outside hazardous areas, and without related exposure could be outside the rule. If those conditions were not all met at a covered site, the rule's training provisions applied.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-07-18
Date issued
July 18, 1990
Status
Active
Status last verified October 9, 2026
Topics
Workplace Safety OSHA 1910 Hazwoper Safety Training
Source
View the official document

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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.

July 18, 1990

Mr. Edward K. Wright
Safety Director
Anderson Equipment Company
[Recipient address omitted]
Dear Mr. Wright:

This is in response to your inquiry of June 11 concerning the application of training requirements in the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120) to employees doing occasional maintenance or service repair work on a disposal site.

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.

It is unclear from your letter whether the workers remain exclusively within uncontaminated areas. If employees' work activities do not meet all of the exclusion criteria described above and the disposal site falls under the scope of the standard (see 1910.120(a)(1)(iv)) then employees must be trained for the duration and in the subjects specified in 1910.120(p)(7).

I hope this information is helpful.

Sincerely,
Patricia K. Clark Director
Designate Directorate of Compliance Programs

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

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