Awareness-level training for hazardous-release witnesses

September 5, 1995

TSgt. William B. Vines
United States Air Force
[Recipient address omitted]
Dear TSgt. Vines:

This is in response to your letter dated April 17, 1995 requesting clarification on who must receive first responder awareness level training consistent with the paragraph (q)(6) of OSHA's Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120).

Employees who work in an area (or areas) where there is a potential to witness or discover an uncontrolled release of a hazardous substance and whose response actions will be limited to initiating emergency response procedures by notifying the proper authorities, must receive first responder awareness level training consistent with the requirements of 29 CFR 1910.120(q)(6)(i). Such employees are not limited to police, hospital, or fire department personnel as suggested in your letter, but would include any employee meeting the above description.

Specific training requirements for your personnel must be derived from the roles you assign them in your emergency response plan. Accordingly, the required training level for police, hospital, and fire department personnel may exceed awareness level training, depending on the assigned emergency response roles of each of these individuals. For instance, emergency medical service personnel would require first responder awareness level training as a minimum if they were not expected to handle contaminated victims. If, however, emergency medical personnel were expected to handle victims who were only superficially decontaminated or not been decontaminated at all, these medical personnel would require first responder operations level training as described in 1910.120(q)(6)(ii). In addition, general firefighters are usually trained at the first responder operations level since they tend to participate in the initial emergency response activities for the purpose of protecting nearby persons, property, and the environment from the effects of the release.

In any case, all personnel who must receive emergency responder training under 1910.120(q)(6) must also receive annual refresher training in accordance with paragraph (q)(8).

When there is the potential for employee exposure to hazardous substances under non-emergency releases of hazardous substances, training under 29 CFR 1910.1200 (Hazard Communication) is applicable.

We hope this provides the clarification you sought. If you have additional questions, please contact [the Office of Health Enforcement at (202) 693-2190].

Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

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

[Corrected 12/6/2024]