Training hazardous-materials responders for their assigned duties

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

November 29, 1990
Roy Waters, Captain
Administrative Services
Columbus Fire Department
[Recipient address omitted]
Dear Captain Waters:
This is in response to your inquiry concerning the Occupational Safety and Health Administration (OSHA) Hazardous Waste Operations and Emergency Response Standard (29 CFR 1910.120) and the proposed Accreditation of Training Programs for Hazardous Waste Operations standard (29 CFR 1910.121). Please accept my apology for the delay in this reply.
You have requested OSHA to review your program for accreditation. In addition, you have asked whether Hazardous Material Response Teams need an asbestos training course and if so, which one(s).
As you know, 29 CFR 1910.121 is a proposed regulation which at this time does not include accreditation for emergency response training under 29 CFR 1910.120(q). Consequently, OSHA is not reviewing programs for accreditation at the present time. In order to ensure fairness to all applicants for accreditation, we have adopted a policy not to review or hold any training programs until after the final rule is published. In the interim, you may be interested in participating in informal hearings on the proposal. I am enclosing information on the hearing dates and locations.
Under the training requirements for emergency responders (29 CFR 1910.120(q)), we do not mention specific courses that must be taken since the training needs to be based on the duties and functions to be performed for each responder of an emergency response organization. If responders may be exposed to asbestos, then this hazardous substance must be included in the training program. In addition, if the responders may be involved in removal of the asbestos, then the training requirements under 29 CFR 1926.58 (Occupational Exposure to Asbestos, Tremolite, Anthophyllite, and Actinolite) may also apply.
Employees of your fire department are exempt from Federal OSHA standards because they are public employees. However, with respect to 29 CFR 1910.120, state and local government employees are covered by regulations identical to our final rule that have been issued by the US Environmental Protection Agency (EPA).
You can contact them directly at the following address and telephone number:

Vickie Santoro
U.S. EPA Environmental Response Team
Woodbridge Avenue
Edison, New Jersey 08837
Telephone: (201) 321-6740

I hope this information is helpful.
Sincerely,
Patricia K. Clark Director
Directorate of Compliance Programs
Enclosure

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