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HAZWOPER training when hazardous waste exposure is unlikely

Summary An attorney asked whether people entering a hazardous waste site without expected hazard exposure needed HAZWOPER training. OSHA said its training requirements did not apply to employees with no probable likelihood of exposure who would not participate in emergency response. The answer was limited to those stated conditions.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1990-09-05
Date issued
September 5, 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.

September 5, 1990

Mr. Gerard P. Cavaluzzi
Attorney and Counselor at Law
[Recipient address omitted]
Dear Mr. Cavaluzzi:

This is a follow-up response to your letter of July 24, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response Standard 29 CFR 1910.120.

Specifically you have asked for the number of hours of training required under this standard for people who may enter areas where hazardous waste may exist but will not be exposed to health or safety hazards. The training requirements under this standard do not apply to employees who have no probable likelihood of being exposed to safety or health hazards and would not participate in emergency response activities.

If you have further questions please feel free to call MaryAnn Garrahan at OSHA's Office of Health Compliance Assistance at (202) 523-8036

We hope this response sufficiently addresses the concerns you raised.

Sincerely,
Gerard F. Scannell
Assistant Secretary

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

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