Hazardous substance response training for hospital staff

October 27, 1992
Howard W. Levitin, MD
[Recipient address omitted]
Dear Dr. Levitin:
This is in response to your inquiry of August 4 concerning the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response regulation (HAZWOPER), 29 CFR 1910.120.
Your questions concern OSHA's training requirements for hospital personnel who are part of an emergency response involving hazardous substances. We will answer them in the order that you presented them:

1. I would appreciate a written clarification of the training requirements for hospital employees if they receive contaminated individuals. Does a hospital need to be trained to first responder operations level if they already have an in-house training program that stresses the use of personal protective equipment and decontamination procedures?
   All hospital personnel who are expected to take part in emergency responses to releases of a hazardous substances must be trained in accordance with 29 CFR 1910.120. Emergency medical personnel who would decontaminate victims who were involved in a release of a hazardous substance are to be trained to the first responder operations level, 29 CFR 1910.120(q)(6)(ii), which provides instruction on the selection and use of personal protective equipment (PPE) and on basic decontamination procedures. Training does not need to be duplicated, therefore appropriate training in PPE and decontamination procedures that a hospital currently provides can be used totally or in part to meet the requirements of HAZWOPER.
   Instruction for emergency medical personnel in topics under 29 CFR 1910.120(q)(6)(ii) that are not directly relevant to emergency medical care is not necessary, although employees must be trained to perform the duties and functions expected of them. This is considered a de minimis violation, which is reserved for employers who are not technically in compliance with a regulation but who provide a safe and healthful working environment for their employees.
2. If this training is necessary, does it only pertain to the individual who sets up and operates the decontamination facility or does it also involve those persons who actually do the decontamination procedure?
   Hospitals are required to train all personnel expected to be involved in the decontamination of victims, for example, personnel exposed to hazardous substances during decontamination procedures.
3. Does the level of training required depend on the hospital's designation under SARA Title III?
   A hospital must train personnel who are expected to respond to emergencies involving hazardous substances. This is true if the hospital has agreed to be incorporated into any emergency response plan through designation by SARA Title III organizations, an agreement with a facility or hazardous waste site, or other means.

Please bear in mind that employers in the state of Indiana are regulated by the Indiana Department of Labor whose occupational safety and health program may have requirements that are more stringent than that of Federal OSHA's. Employers in Indiana are required to follow the Indiana standards and interpretations. However, to be of assistance, we are providing you with interpretations made on Federal OSHA's HAZWOPER regulation.
For any particular requirements applying in your state, you may contact the following:

Kenneth J. Zeller,
Commissioner Indiana
Department of Labor
State Office Building
402 West Washington Street,
Room W195
Indianapolis, Indiana 46204
Telephone: [(317) 232-2655 (DOL); (317) 232-2693 (IOSHA)]

We hope this information is helpful. If you have any further questions on Federal OSHA's HAZWOPER regulation, please contact the [Office of Health Enforcement at (202) 693-2190].
Sincerely,
Roger A. Clark,
Director
[Directorate of Enforcement Programs]
[Corrected 1/6/03]