Equivalent HAZWOPER training for tank-removal subcontractors

August 15, 1991

Ms. Cynthia Sundquist
Manager, Health and Safety
ABB Environmental Services, Inc.
ASEA Brown Boveri
[Recipient address omitted]

Dear Ms. Sundquist:

Thank you for your letter of July 18, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response final rule (29 CFR 1910.120).

Your specific question relates to training certification of current employees with previous experience and training in the removal of underground storage tanks (USTs).

If your subcontractors meet the requirements of paragraph (e)(9) for certifying an employee as equivalently trained they will not be required to complete the initial 40 hour training. This paragraph is written to allow organizations to certify current employees as equivalently trained if the employee's work experience and/or training has resulted in training equivalent to that training required in paragraph (e)(1) through (e)(4). The employee must have had sufficient training and/or experience to perform their expected duties safely.

Your subcontractors currently have specific skills for the removal of USTs. If you certify them under (e)(9) they may be able to perform removals of underground storage tanks. However, they will need further training if you require them to perform any other hazardous waste operation.

All employees certified as equivalently trained and new to a site must also receive appropriate site specific training before site entry and have appropriate supervised field experience at the new site. These employees would be required to have 8 hours of refresher training per year.

We hope this information is helpful. If you have any further questions please feel free to contact MaryAnn Garrahan at (202) 523-8036.

Sincerely,
Gerard F. Scannell
Assistant Secretary

[The requester’s July 18 letter reproduced on the OSHA page is omitted here.]