First-responder versus technician training for hazardous releases

November 9, 1990

C.L. Wright, Jr.
Safety Manager
Pennsylvania Turnpike Commission
[Recipient address omitted]
Dear Mr. Wright:

Thank you for your letter of October 12, concerning the training requirements of the Occupational Safety and Health Administration (OSHA) standard 29 CFR 1910.120 Hazardous Waste Operations and Emergency Response.

29 CFR 1910.120(q)(6)(ii) addresses the anticipated activities and the 8 hour training requirement for first responder operations level. As you discussed with Don Harvey of this office on October 24, first responders operations level function in a defensive fashion without actually trying to stop the release of a hazardous substance. Review of the anticipated duties for your employees include some activities, such as plugging of leaking fuel tanks, which assume an aggressive role in stopping the release.

29 CFR 1910.120(q)(6)(iii) addresses the role of a hazardous material technician in an emergency response. As discussed in this paragraph, hazardous material technicians assume a more aggressive role than a first responder operations level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous materials technicians must receive at least 24 hours of training which provides the equivalent of the first responder operations level training and which will also provides other specific competencies as outlined in the standard. Therefore, your 8-hour training, as outlined in your letter, would not be sufficient for employees engaged in attempting to stop a release.

At the present time, OSHA does not certify or approve training courses for employees under 29 CFR 1910.120. It is the responsibility of the employer to assure that the course content adequately addresses the potential hazards to the employee which may be encountered in the course of an emergency response. We are not familiar with the content and structure of the documents and information upon which you have structured your training.

I suggest that you contact your local OSHA Area Office at the address and telephone number below for assistance.

U.S. Department of Labor - OSHA
Progress Plaza 49 North
Progress Street
Harrisburg, PA 17109
Telephone: (717) 782-3902

I trust this discussion has adequately addressed your specific questions.

Sincerely,
Patricia K. Clark Director
Directorate of Compliance

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