The toughest job in safety? It could be cleaning up toxic messes
The OSHA standards below require employers to certify training. Which requires “A written certificate shall be given to each person so certified”?
- Powered industrial trucks 1910.178(l)(6).
- Hazardous waste operations and emergency response 1910.120(e)(6).
- Confined spaces 1910.146(g)(4).
- The control of hazardous energy (lockout/tagout) 1910.147(c)(7)(iv).
- Powered platforms for building maintenance 1910.66(i)(1)(v).
OSHA 1910.178(l)(6) states, “The employer shall certify that each operator has been trained and evaluated as required by paragraph (l). The certification shall include the name of the operator, the date of the training, the date of the evaluation, and the identity of the person(s) performing training or evaluation.” Federal OSHA does not require that each employee trained and qualified to operate a PIT be required to carry a PIT license, however.
Confined spaces, LOTO and powered platforms, likewise, have similar certification requirements – employers maintain a record of certification, but employers don’t have to give individual employees a written certificate of their training.
First aid / CPR
Be aware that OSHA standards requiring first aid and CPR training -- 1910.151 and 1926.50(c) often utilize training services from instructors qualified by the American Red Cross. American Red Cross is mentioned at 1926.50(c) as an example of a training provider. Red Cross issues valid certificates with expiration date, instructor signature, etc. to individuals they train. OSHA requires first aid and CPR training be verified by “documentary evidence” but this does not necessarily mean each person trained is given their own certificate.
Each person certified for 8-, 24- or 40-hour Hazwoper offsite training, followed by supervised field experience at hazardous waste operations must be given their own written certificate of training. Emergency response (q) training under Hazwoper requires a certification record like PITs, confined spaces, LOTO, and powered platforms. A written certificate of emergency response training -- first responder operations level for each person -- is not required.
What makes hazardous waste operations training unique and requires each person trained be given their own certificate?
Hazardous waste work is a tough job. Hazardous waste employees often move among different employers seeking better pay and working conditions. Owning an 8-, 24- or particularly the 40-hour Hazwop certificate is a big advantage. If a Hazwop employer only had to maintain a “certification record,” then access to this record by an employee could be denied, delayed or otherwise disadvantage the worker that seeks new other employment.
An online Hazwop 40-hour course may cost only about $250 per student. Online Hazwop students go through self-guided study with questions about various key training topics. Online programs record Q&A success. If the online student achieves the provider’s Q&A success level (OSHA does not set a pass/fail level), a certificate can be downloaded and printed. OSHA doesn’t say which online provider is good or bad. OSHA’s main involvement with online Hazwop courses is that the provider must allow the student to ask questions to a real person, as needed. To satisfy OSHA’s interpretation for questions to be answered by a real person, online providers provide students with a phone number.
Hazwop 40 training topics
Broad categories include worksite organizational structure; comprehensive work plan; site-specific health and safety plan (HASP); safety and health training program; medical surveillance; and standard operating procedures for safety and health. Specific knowledge and eventual skills include hazard analysis for each site task; PPE to be used based on hazard analysis; site control measures; and, decontamination procedures. Depending upon task, Hazwop 40 workers may also require training in LOTO, confined space, bloodborne pathogens – just to name a few.
Supervised field experience
A 40-hour Hazwop offsite trained worker requires 24-hour supervised field experience. A 24-hour Hazwop trained worker requires 8-hour supervised field experience. The difference in training hours depends upon whether the person is a general site worker or occasional on-site worker, with the occasional on-site worker needing less training time.
OSHA Hazwoper is generally thought of as cleanup of improperly disposed or mismanaged chemicals, or emergency response to spills of hazardous chemicals. “Hazardous substance” as defined in the standard includes, “Any biological agent and other disease-causing agent…” Infectious and communicable disease from a virus such as CORVID-19 is applicable.
A qualified Hazwop 40 worker is ready to respond to cleanup of messes from a variety of sources. Ready includes medically qualified, clean shaven, PPE qualified with skills to decontaminate themselves and decontaminate or properly dispose of contaminated equipment, including PPE, as defined at decontamination procedures outlined at 29 CFR 1910.120(k).
Gaps in OSHA
Across the globe news media shows teams of workers decontaminating areas suspected to contain CORVID-19. What qualifications do these workers need to protect themselves and ensure that decontamination procedures are conducted properly? The future is uncertain but likely that CORVID-19 decontamination services will increase at U.S. worksites.
OSHA has standards for PPE, respiratory protection and the like – but they’re not comprehensive for CORVID-19 concerns. Hazwoper is the most comprehensive approach to CORVID-19 decontamination services but the standard is not specific to this task.
My advice is to cut to the chase and if worksite decontamination services are necessary, the people doing the actual work should present their Hazwop 40 training certificate. I wouldn’t accept a Hazwop 8- or 24-hour training certificate or any other “certificates” such as trained in PPE, respiratory protection or janitorial services. Businesses that sponsor the Hazwop 40 worker for decontamination services should be required to develop and enforce a site-specific CORVID-19 decontamination HASP.
If you’re familiar with Hazwop 40 trained workers, they are needed but often underappreciated. EMS, fire department and other first responders to some crisis get the praise. But Hazwop workers that safely clean up messes that remain when a crisis is over are mostly overlooked for the valuable services they provide.