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."