Hazardous materials technician and incident commander training

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

August 9, 1990

Captain Peter J. Martinasco, Assistant State Director
Office of Emergency Management, Department of Law and Public Safety
[Recipient address omitted]
Dear Captain Martinasco:

This is an update to your request for an interpretation of the training requirements in the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120).

Specifically you have asked for our comments on New Jersey's method for preparing course materials for hazardous materials technicians and on-scene incident commanders. Your letter states that these courses meet the requirement of 24 hours of training equal to the first responder operations level by requiring the 8 hour operations course as a prerequisite and integrating into the courses 16 more hours of operations level training which covers the necessary competencies for each.

The standard requires hazardous materials technicians and on-scene incident commanders to receive 24 hours of training and in addition have competency in the areas specified in the standard. The method you describe may be acceptable if there are potentials for emergencies from only a few types of hazardous materials. In general, more than 24 hours of training would be necessary to meet both the training and competencies requirements.

We hope this information is helpful.

Sincerely,

Patricia K. Clark Director Designate Directorate of Compliance Programs

[July 12 interim OSHA reply and June 13 requester letter reproduced on OSHA page; omitted here.]