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HAZWOPER training certificates after employment ends

Summary An employer asked whether former workers or their new employers could request HAZWOPER training certificates from a previous employer. OSHA said they could ask, but its rule did not require the former employer to respond. The rule required a written certificate for a worker who completed specified training and field experience; OSHA now archives the letter.
Document
Federal opinion letter
Agency
Occupational Safety and Health Administration (OSHA)
Document number
1997-01-30
Date issued
January 30, 1997
Status
Archived by the agency
OSHA labels this an archive document and warns that it may no longer represent OSHA policy.
Status last verified October 9, 2026

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OSHA labels this an archive document and warns that it may no longer represent OSHA policy. It may no longer reflect the agency's current position. Treat this page as historical context, not current guidance, and verify current law before relying on anything here.
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NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

January 30, 1997
Mr. Ron Roy
Director of Health, Safety and Quality
Valley Systems, Inc.
[Recipient address omitted]
Dear Mr. Roy:
This is in response to your request for a written interpretation of the training certification requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120). Specifically, you requested clarification as to (1) whether former employees can request copies of training certificates from former employers; and (2) whether current employers can request documentation of an employee's training from the employee's former employer. The response that follows confirms your telephone conversation with Ms. MaryAnn Garrahan of my office on October 21, 1996.
Former employees can request copies of training certificates from former employers and current employers can request documentation of an employee's training from the employee's former employer. OSHA regulations, however, do not require former employers to respond to such requests. Paragraph 1910.120(e)(6) of the HAZWOPER standard requires that head instructors or trained supervisors provide a written certificate to each employee that has successfully completed the training and field experience that is specified in paragraphs (e)(1) through (e)(4) of the standard. It is the employee's responsibility to keep copies of the training certificate for themselves and for future employers.
We hope that this letter clarifies your concerns regarding requirements for training certification under OSHA's HAZWOPER standard. If you have additional questions, please contact this office at (202) 693-2190.
Sincerely,
Ruth McCully, Director
Office of Health Compliance Assistance

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