HAZWOPER training for hazardous waste truck drivers

June 7, 1991
Mr. Robert M. Underation
Wills Trucking Company
Director of Safety
[Recipient address omitted]
Dear Mr. Underation:
This is in response to your inquiry of February 27, 1990 and subsequent correspondence concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my profound apology for the delay in this reply. The file containing your correspondence somehow found its way into the docket file where it has languished until most recently.
Your specific question relates to the training requirements for drivers hauling hazardous waste that do not interact with the waste other than to transport it. Employees are not covered by the standard if they are not exposed to health or safety hazards related to hazardous waste operations. It is unclear from your letter whether the driver's work activities meet this exclusion criteria. For your assistance, I have enclosed a brief summary of the 1910.120 training requirements.
There is an equivalent training clause in paragraph (e) of HAZWOPER which reads;

(9) Equivalent training. Employers who can show by documentation or certification that an employee's work experience and/or training has resulted in training equivalent to that training required in paragraphs (e)(1) through (e)(4) of this section shall not be required to provide the initial training requirements of those paragraphs to such employees.

Therefore, if covered by the standard, you may be able to certify some of your employees as "equivalently trained" because of the past training they have attended and their on-the-job training as described in your letter. However, all potentially exposed personnel entering the hazardous waste site would require 8 hours of refresher training on a yearly basis.
I hope this information is helpful. If you have any further questions please feel free to contact [the Office of Health Enforcement at (202) 693-2190].
Sincerely,
Patricia K. Clark, Director
[Directorate of Enforcement Programs]
[Corrected 10/08/08]
Enclosure

[The requester's February 27, 1990 letter reproduced on the OSHA page is omitted here.]