Hazardous-material patient care and hospital responder training

April 25, 1997
Mr. Thomas Whittaker
New England Hospital
Engineers' Society, Inc.
[Recipient address omitted]
Dear Mr. Whittaker:
This is in response to your letter of March 4, requesting clarification of an Occupational Safety and Health Administration (OSHA) letter to Randy Ross dated March 31, 1992, addressing emergency response training requirements for hospital staff. In the March 31, 1992 letter to Mr. Ross, OSHA indicated that hospital staff that operate decontamination facilities as part of a hazardous waste emergency response effort must be provided with at least first responder operations level training in accordance with paragraph (q) of the Hazardous Waste Operations and Emergency Response (HAZWOPER) standard. In your letter, you asked whether medical personnel who do not operate decontamination facilities, but are involved with the patient only to provide medical care, must be trained as skilled support personnel.
As noted in the March 31, 1992 letter to Mr. Ross, the HAZWOPER standard requires that training shall be based on the duties and function to be performed by each responder during an emergency. Hospital staff who are not expected to assist in the decontamination of patients, but may be exposed to patients needing immediate treatment prior to thorough decontamination would be considered "skilled support personnel" under paragraph (q)(4) of the HAZWOPER standard and would not require first responder operations level training. Accordingly, such medical personnel must, at a minimum, be given a briefing at the time of the incident. This briefing must include instruction in the wearing of appropriate personal protective equipment (PPE), the nature of the chemical hazards involved in the emergency, the expected duties that the medical personnel must perform, and any other safety and health precautions that the medical personnel must take including the implementation of personal decontamination procedures.
We hope that this information clarifies your concerns regarding the emergency response training requirements for medical personnel in OSHA' s HAZWOPER standard. If you have any further questions, please contact this office at [(202) 693-2190].
Sincerely,
John B. Miles, Jr., Director
[Directorate of Enforcement Programs]
[Corrected 1/6/03]

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