Once you complete your initial 24-hour and 40-hour HAZWOPER (Hazardous Waste Operations and Emergency Response) training you need to take at a minimum an 8-hour refresher training annually to keep your certificate current. What happens if you have not completed your annual refresher training? Has it been over a year since your last HAZWOPER course?
OSHA’s intent regarding HAZWOPER refresher training is that it should be completed within 12 months of initial training. OSHA states in an interpretation letter that they do understand unavoidable circumstances preventing refresher training and the employee should get their refresher training as soon as possible. Also noted in the letter of interpretation is that state approved OSHA programs may require training be completed by the exact anniversary date. Check with your state-approved OSHA plan to find out if you’re in compliance.
What if an employee has not worked in hazardous waste for a long time? How does an employee become eligible to return to work on a hazardous waste site? A question posed in the OSHA interpretation letter “May an individual be qualified to return to hazardous waste work with only a refresher course or must the individual take the 40-hour or 24-hour course over?” First, ask, are there time lapses in service to differentiate these different cases? For example: “Is two years between training too long? Is it okay to just complete a refresher if the individual has been without training for seven or more years?”
In short, according to OSHA, this lapse in training issue is determined on a case-by-case basis by the employer. Employee training and retention of HAZWOPER knowledge and training has to be considered. A worker with very little experience versus a seasoned employee may not have skills and knowledge to keep them safe on a hazardous waste site. Take into consideration the employee’s past work history and length of experience to be able to work safely and identify hazards associated with HAZWOPER. Employees will need to demonstrate competency when the employer decides what type of training is needed.
If an employee leaves the industry for two years or less OSHA stated this would not necessitate repeating 24-hour or 40-hour training so refresher training by itself could be sufficient. If the employee has a long absence then they would definitely need the training and become familiar with new procedures and technology and other important requirements. Most importantly, all employees new to a HAZWOPER site will need site-specific training before entry into the area and also given supervised field training to the site they will be working. OSHA also recommends that employers keep a record in the employee’s training file as to why training was delayed and when the training will be completed if they are past the one year mark for HAZWOPER training.
There are many good options to complete your HAZWOPER training. Onsite and online are both good options. HAZWOPER training online is convenient allowing you to study according to your schedule. You don’t have to wait for classes to be scheduled. Get started now if you have a refresher training deadline coming up. If you devote two hours a week to it for four weeks you’ll be done. You won’t have to drive far away to attend classes or spend money on travel and hotel expenses. Do remember that site-specific training will still need to be completed by the employer.