HAZWOPER training for emergency medical personnel

June 14, 1991
Mr. Edward McNamara
Executive Director
Central Massachusetts Emergency
Medical Systems Corporation
[Recipient address omitted]
Dear Mr. McNamara:
This is in response to your letter of March 21, to Region I office concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120). Please accept my apology for the delay in this reply.
Your specific question relates to the training requirements for emergency medical service personnel.
Section (q)(6) of 1910.120 discusses the training requirements for five levels of emergency responders. The specific training requirements for emergency medical service personnel depend on the duties they are expected to perform during an emergency response to a release of hazardous substance.
If the contaminated victims have been totally and thoroughly decontaminated and removed from the danger area, the emergency medical service personnel treating these victims would not have specific training requirements under 1910.120. However, these personnel should be given an initial briefing at the site prior to their participation in the emergency response.
Emergency Medical Service personnel are often the first on the scene and therefore should be given first responder awareness level training as a minimum even if they are not expected to handle contaminated victims.
If the emergency response personnel must handle victims whom have been only superficially decontaminated or have not been decontaminated at all, training to the first responder operations level as described in 1910.120 section (q)(6)(ii) would be required. The minimum amount of training required by this paragraph is 8 hours.
The emergency response plan for the jurisdiction should clearly define who will be responsible for decontaminating victims during an emergency response. The emergency medical service personnel should be trained in accordance with the responsibilities they will be expected to assume during an emergency response as described in the community emergency response plan.
We 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 1/6/03]

[The regional routing memorandum, requester letter, and earlier regional letters reproduced on the OSHA page are omitted here.]