HAZWOPER training for employees in uncontaminated support areas

November 26, 1990

Mike Amen, CIH
Riedel Environmental Technologies, Inc.
[Recipient address omitted]
Dear Mr. Amen:

This is in response to your letter concerning the Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120). Please accept our apology for the delay in this reply.

Your first question is where at the site (e.g., support zone, contamination reduction zone, exclusion zone) does the scope of 29 CFR 1910.120 begin to apply. The scope of the standard potentially applies to the entire geographic area of the site designated for clean up. Once areas are characterized, however, 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 or potentially exposed to health or safety hazards related to hazardous waste operations.

Your other question concerns the training requirements for personnel whose duties are limited strictly to the support zone. The training requirements under 29 CFR 1910.120(e) are not applicable for employees who meet the criteria set forth in the answer to the first question. Training requirements of other standards such as 29 CFR 1910.1200 would be applicable.

I hope this information is helpful.

Sincerely,
Patricia K. Clark Director
Directorate of Compliance Programs

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