For over 30 years, TEST Team Inc. has been serving the Compliance & Safety needs of the Trucking Industry.  Whether it's onsite Audits, writing Policies & Manuals, SPCC Plans, training Hazwoper, Online Training or numerous other DOT, OSHA & EPA classes....we remain a reliable, and steadfast partner in helping our clients reach their corporate compliance & safety goals.


Hazwoper- Who Needs It?

Hazwoper is an OSHA requirement . Hazardous Waste Operations and Emergency Response (29CFR1910.120) states if you have over 42 gallons of any hazardous material stored you must have employees trained and certified annually.

As a person who manages training programs under OSHA Hazwoper standard I get a lot of questions about what training that the regulation requires. I continually get phone calls that usually go like this:

I am looking for a 40 Hour Hazwoper class. Do you have any in my area that I can attend?

My response usually goes something like this:

Which 40 Hour Hazwoper course are you looking for and why? The Hazwoper regulation mandates several levels of training and many of them are 40 hours long.

The caller then responds with something on the order of Huh?

I got started in 1989 with the Hazwoper training when it first became law, and I have been training in the regulations ever since. Over the years Ive found many people have misconceptions about what the regulation requires and a lot of people spend money on Hazwoper training they really dont need. What I havent actually found is a lot of people who have actually read the regulation.

The Hazwoper standard OSHA 1910.120 seeks to protect workers engaged in hazardous waste site clean-up, hazardous waste handling and emergency response  to incidents involving hazardous materials. It uses a variety of methods to accomplish this goal, the most well-known of which is training.

So which training does this regulation require? Simply put, it requires your employer to train employees to do what your employer requires you to do. It doesnt mandate a "40 hour class" for anybody. Now we got your attention lets get into the "big buts" of Hazwoper.

"But I work around hazardous waste!"

It doesnt matter.  There is nothing in the regulation that says you need Hazwoper training when you have hazardous waste in your work place.

"But we have hazardous materials where I work."

It still doesnt matter.

"But what if I have a spill?"

It still doesnt matter.

The only thing that does matter is what you are required to do about any of the above situations. The Hazwoper regulation is what federal bureaucrats call a "performance-oriented standard" (or what people might call "enough rope."). It doesnt try to specify proscriptive standards for the endless variety of workplaces nationwide. It merely says if you do a certain task then you must be trained and equipped to protect yourself from any hazards of that risk. The level of Hazwoper training you need (if any) is entirely up to you.

The main item that determines what training you need is your emergency response plan.  If your plan says if you have a HAZMAT release then all employees will evacuate the area then you require no Hazwoper training. If the plan says you have to be able to recognize that you  have a Hazmat release or spill you are what the regulations call a First Responder at the Awareness level. If you do that plus take defensive actions to contain the release than you are a First Responder at the Operations level. It goes on to specify five other levels of training, none of which require 40 hours of training.

The two situations just discussed are by far the most common in workplaces today. Most of the people who go into the 40-hour classes really fit into the mentioned above classes.

 So just who does require one of the ubiquitous 40 Hour Hazwoper classes? People who clean up hazardous waste sites and who are exposed to the hazards. Period, end of discussion. The big buts simply dont apply. Nobody else needs that level of training.

 If you dont believe me you can call the guy who wrote the regulation. His name is Mike Moore and he works at OSHA headquarters in
Washington D.C.. If you dont want to bother him read the regulation for yourself (29 CFR 1910.120). I highly recommend you take a few minutes and read the regulation for yourself. The Hazwoper regulation isnt that long and its written in plain English (for the most part)

The bottom line is: get the training you need and don't waste money and time on anything else.


                                                                     Levels of Training
(Hours may vary by state)

First Responder "Awareness"    4 Hours     Recognizes you have a spill must leave the area ( Typically office workers) 

 First Responder "Operations"   8 Hour       Dam and dikes the area ahead of the spill  (Typically Drivers)

First Responder "Technician"    24 Hours    Stops the leak and cleans up site. Works close with the ICS.
(Typically Owners, Managers, Dispatchers and  Mechanics)

 First Responder "Specialist"      24 Hour +   Outside lesion with outside agencies. (Typically Safety Manager)

 First Responder "Incident Commander"     24 Hour      In charge of operation (state agency) (Typically Owners, Managers)

CSA 2010    

CSA 2010 re-engineers the existing enforcement and compliance business process to provide a better view into how well large commercial motor vehicle (CMV) carriers and drivers are complying with safety rules, and to intervene earlier with those who are not. As the program is rolled out in 2010, FMCSA will establish a new enforcement and compliance Operational Model that will utilize its resources, and those of its State enforcement partners, more efficiently and effectively, making the roads even safer for everyone.

This new CSA 2010 Operational Model has three major components:

  • Measurement - CSA 2010 measures safety performance in new ways, using inspection and crash results to identify carriers whose behaviors could reasonably lead to crashes.
  • Evaluation - CSA 2010 helps FMCSA and its State Partners to correct high risk behavior by contacting more carriers and drivers, with interventions tailored to their specific safety problem, as well as a new safety fitness determination methodology.
  • Intervention - CSA 2010 covers the full spectrum of safety issues – from how data is collected, evaluated, and shared to how enforcement officials can intervene most effectively and efficiently to improve safety on our roads.

CSA 2010 has been carefully planned and developed over the past few years. It began with a thorough review of the agency’s current compliance review process, and proceeded through the development of a new Safety Measurement System (SMS) that will use all roadside inspection and crash data and the development of a new interventions toolbox to deal efficiently and effectively with safety problems of various natures and different levels (as identified in SMS). In addition, the new model includes a proposed change to Safety Fitness Determination (SFD), also tied to SMS results, although implementation of CSA 2010 is not dependent on the proposed change.

The expanded suite of intervention tools enable investigators to systematically evaluate why safety problems are occurring, to recommend remedies, to encourage corrective action(s), and, where corrective action is inadequate, to invoke strong penalties. 

Don't take this new regulation lightly!!!
It's your company's existence on the line.  Be sure you have all components of CSA 2010 in order.  If you have any questions about your compliance..... CALL TEST Team NOW.  (909) 261-1731

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