Separate HAZWOPER supervisor and annual refresher training

July 27, 1992
Mr. Timothy S. Mustard
Engineering-Science, Inc.
[Recipient address omitted]
Dear Mr. Mustard:
This is in response to your inquiry of June 18, concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response standard (HAZWOPER), 29 CFR 1910.120.
You requested clarification on whether an employee's completion on the 8-hour management and supervisory training could also satisfy the employee's 8-hour annual refresher training requirement.
OSHA would expect a general hazardous waste site worker who is becoming a supervisor or manager to receive at least 16 hours of training during the year they become a supervisor: 8 hours of management and supervisory training in addition to 8 hours of employee refresher training. HAZWOPER requires that supervisors and managers be trained and given supervised field experience to at least the level of the employees who they will oversee, and have at least eight additional hours of specialized training on the topics listed in 1910.120(e)(4).
You are also concerned about conflicting guidance that Engineering-Science has received from OSHA's regional and state offices. Some states operate under an OSHA-approved state plan, which covers all occupational safety and health concerns for that state. A state with an approved plan must provide employee protection that is "at least as effective" as Federal OSHA's and may be more stringent. Individual Engineering-Science offices that are in states with an OSHA-approved state plan are required to follow the state's HAZWOPER standard and interpretations made by the state. This letter states the interpretations which Federal OSHA has been providing to the Federal HAZWOPER standard (Please see the enclosed pamphlet "All About OSHA"). States with OSHA-approved plans are encouraged to adopt similar interpretations.
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 Clark, Director
[Directorate of Enforcement Programs]
Enclosures: "All About OSHA" Map of OSHA offices
[Corrected 1/20/2005. On August 15, 2002 the proposed 1910.121 "Accreditation of training Programs for Hazardous Waste Operations" proposed rule was withdrawn from the Unified Regulatory Agenda (see Federal Register 67:74749-74785 dated December 9, 2002).]

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