Timing and content of HAZWOPER refresher training

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

October 16, 1991

Ms. Sandra Trower
Layne Environmental Health Sciences
[Recipient address omitted]

Dear Ms. Trower:

This is in response to your inquiry of September 5, 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 the 8 hour refresher training for employees specified in 1910.120(e)(1), (e)(4), and (q)(6).

First, the 8 hour training course does not need to be on the exact anniversary of the initial training. Employees should have the refresher course reasonably close to the anniversary date, taking into consideration the company's and the employees' convenience in scheduling the course. However, if the training does not take place by the anniversary date there should be a record in the employee's file indicating why the training has been delayed and when the training will be completed

You mention that your company currently holds "on-site health and safety briefings associated with environmental projects that are four (4) to eight (8) hours long." OSHA agrees that the accumulated hours in your "on-site health and safety" briefings may be used as 8 hour refresher courses required by 1910.120 if they cover items specified in paragraph (e)(2) and (e)(4).

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

Sincerely,
Patricia K. Clark, Director
Directorate of Compliance Programs

[The requester’s September 5 letter reproduced on the OSHA page is omitted here.]