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MANAGING BEST PRACTICES: Selecting a Hazwoper trainer

August 29, 2003
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Hazardous waste operations and emergency response (Hazwoper) training under OSHA 1910.120 is the most demanding of all environmental health and safety topics. But here's the rub: Most EHS pros recognize that almost anyone can conduct - and nearly every student will pass - a Hazwoper course.

Employers are burdened with selecting Hazwoper training from providers that all may claim to meet OSHA's (limited) requirements. OSHA provides Hazwoper "Training Curriculum Guidelines" at Appendix E to 1910.120, but these guidelines are not enforceable. Few trainers would honestly say they do not follow Appendix E training guidelines. And OSHA's standard for trainers simply boils down to: "Trainers shall be qualified to instruct employees about the subject matter that is being presented in training."

So how do you identify best, average, or bad training providers? Word of mouth and other recommendations are fine but may be inadequate. Different employers may have different needs and expectations.

One method is to measure a potential Hazwoper trainer using the ten elements described in this article. Score each element from zero to ten points. Under perfect conditions a trainer could score 100 percent. Scores can help you distinguish the quality between Hazwoper trainers.

1) Model programs - Anyone may provide a Hazwoper "train-the-trainer" program, but some institutions such as the Community and College Consortium for Health and Safety Training provide model programs that are a step above others. Apprentice training, where one trainer learns under another trainer, may not qualify as a "train-the-trainer" program.

The best Hazwoper train-the-trainer programs cover training techniques, including methods for adult learners, in addition to in-depth lecture and hands-on work with technical and regulatory subjects. Printed course material should have peer review and acceptance. Courses vary in length and subject matter. Ask to see the agenda for the training. Ask to see the trainer's certificate for attending the course. Provide one point (up to 10) for each day of qualified training.

2) Annually updates - Score ten points if the trainer has completed a formal refresher course on Hazwoper training within the past year. If not, provide one point (up to ten) for each specific Hazwoper subject that the trainer was refreshed in during the preceding year. Allow some points for refresher training no more than two years old.

3) Field experience - Subjectively score Hazwoper field experience. Exclude training experience. A full-time hazardous waste site employee or emergency responder, teaching Hazwoper part-time, should be granted ten points. If field experience relates to just one activity such as air monitoring, restrict points accordingly. Reduce points if field experience is more than five years old.

4) Insurance - Is the trainer covered by professional and general liability insurance with sufficient coverage? In some cases other insurance such as workers' compensation or auto coverage may be needed. Does the insurance coverage include training activities such as Hazwoper? Make sure the coverage does not exclude important aspects such as hands-on training (some policies may exclude this work). Zero points if no insurance coverage is demonstrated. Provide ten points if full insurance coverage is demonstrated.

5) Credentials - Is the trainer qualified by a reputable organization(s) as competent or qualified in an EHS discipline such as safety or health? There are more than 200 EHS credentials. Examples include EMT, RN, CSP, CIH, CET, CHMM, REHS, etc. Multiple credentials can earn up to ten points. Be careful of sham credentials, which are difficult to identify. Seek guidance from peers if you doubt the validity of any EHS credential.

6) Formal education - Does the trainer hold degrees or obtained course-work that directly relates to Hazwoper topics from reputable academic institutions? You may want to allot a Ph.D. ten points, an M.S. nine points, and a B.S. eight points. Subjectively score course-work where no degree was obtained. As with EHS credentials, be wary of junk degrees from diploma or degree mills.

7) Site-specific training - A trainer that assesses your work site and provides specific training for hazards noted should get ten points, if you think they have accurately recognized specific hazards. Provide five points or less for generic training that will cover specific hazards for your work site.

8) Resources - Do all students get a chance to don appropriate PPE, examine sampling devices, and practice using a variety of safety equipment and activities such as confined space, lockout-tagout, or job safety analyses? One self-contained breathing apparatus for more than five students requiring Level A or B training is insufficient. Score ten points if one-half or more of any Hazwoper course includes some form of hands-on training for all students.

9) Support network - Hazwoper subjects are too broad and deep for any one trainer to know everything. Who does the trainer rely upon when they need help answering a question? Does the lead trainer use other qualified trainers in the Hazwoper course? Who is the back-up trainer if the lead trainer cannot attend a scheduled Hazwoper course? Score ten points for a demonstrated network that includes a variety of direct relationships with experts in Hazwoper subjects. Regulators are an important, but limited, training support network.

10) Miscellaneous - How would the trainer handle an ethical question such as the need to fail a student from Hazwoper training? Is the trainer an active member of a local EHS association? If so, this might demonstrate a trainer's concern with improving the EHS profession. What other qualities does the trainer possess? Does his or her training style match up with the needs of your organization? This is a zero-to-ten-point score that can be widely subjective.

This scoring method is just one of several ways to measure the quality of a Hazwoper training provider. Cost of service was not a discussed element, but it could be. A Hazwoper trainer that scores below 65 percent should be excluded from training consideration.

There is sufficient voluntary guidance, such as Appendix E to OSHA 1910.120, for Hazwoper training programs. As Hazwoper training becomes more of a commodity, competition may encourage trainers to take short cuts to reduce pricing. And short cuts lead to inevitable problems.

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