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Are my HAZWOPER Refresher training requirements met through this on-line course?

OSHA developed a written interpretation in October, and again in November of 1994, which established several guidelines that need to be followed in order for HAZWOPER training to be considered in compliance with current regulations. The guidelines are listed below with the qualifications of the programs developed by Technical Safety Institute. The Interpretations can be viewed directly at the following hyperlink: http://www.osha.gov/html/faq-hazwoper.html

General Interpretation

From the interpretation dated November 22, 1994, OSHA states "computer-based training programs can be used as part of an effective safety and health training program to satisfy OSHA training requirements, provided that the program is supplemented by the opportunity for trainees to ask questions of a qualified trainer, and provides trainees with sufficient hands-on experience.

OSHA however, urges employers to be wary of relying solely on generic, "packaged" training programs in meeting their training requirements, and goes on to say the following. "Hazardous waste operations can involve many complex and hazardous tasks. It is imperative that employees be able to perform such tasks safely. Thus, auditing of worker performance is required for all types of HAZWOPER training. The employer may determine that hands-on training is unnecessary for a given refresher course. However, if an employer elects not to use hands-on training in their refresher course, the employer must first assess the employees' skill level, and ensure that workers remain competent in their current and any newly assigned duties."

Because our training programs can be customized to more fully represent the site-specific conditions at your worksite, employers may feel comfortable with providing very little further training to their employees. While our programs are very comprehensive, additional site-specific training may be required for certain hazardous operations that may be encountered at different sites. Means to provide this additional training include site orientations or regular safety meetings. The employer must be aware that the responsibility of providing site specific training remains with the employer and conditions and procedures unique to your worksite or company, including personal protective equipment, may require training which no computer-based training program can provide. The employer should always evaluate each employee's skill level and the need for further training after this or any other web-based program.

Specific Guidelines

OSHA regulations require that an instructor have the minimum education and or experience with hazardous materials to teach this course.

Our on-line courses are all developed by industry experts in their particular field of expertise. The main developer of each course or module offered by TSI is board certified by one or more of the following entities:

  • American Board of Industrial Hygiene in Comprehensive Practice
  • Board of Certified Safety Professionals in Comprehensive Practice; or
  • American Board of Health Physics.
 

This level of expertise is unsurpassed in the industry.

In order for the training to be effective, trainees must have the opportunity to ask questions.

It is very important to Technical Safety Institute that your employees complete their training with all of their questions answered. For this reason, each trainee is encouraged to ask their questions of our qualified instructors through our integrated e-mail system. Each and every question will be routed to either a Certified Industrial Hygienist or a Certified Safety Professional, depending upon the question's content. Personal communication between your employees and the highest professional level of expertise in this industry is just one of the benefits of training with TSI.

The trainees' mastery of covered knowledge and skills must be assessed.

TSI offers an on-line training program which can be customized to meet many site-specific training needs. In addition to providing a dynamic and interesting presentation, a written exam is required in order for the student to receive a Certificate of Completion. This final exam is also customized by the program to more fully represent the specific training needs of the employee's work site.

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How were the individual training modules chosen and can I change the curriculum?

OSHA requires that certain elements be covered in an 8-hour refresher course (1910.120(e)(2)(i). These elements include the following:

  • Names of personnel and alternates responsible for site safety and health
  • Safety, health and other hazards present on the site
  • Use of personal protective equipment
  • Work practices by which the employee can minimize risks from hazards
  • Safe use of engineering controls and equipment on the site
  • Medical surveillance requirements including recognition of symptoms and signs which might indicate over-exposure to hazards
  • Decontamination
  • Emergency response
  • Confined space
  • Spill Containment

These modules constitute the core of our training and must be completed as part of the core curriculum. Names of responsible individuals at the employee's worksite will of course, have to be provided by the employer.

Specifying site-specific hazards to best reflect the hazards of your site

Technical Safety Institute has developed a library of hazard topics to reflect the wide variety of hazardous waste work within the industry. Core module 2 (Safety, health and other hazards present on the site), lists a recommended core group of hazard topics in accordance with the recommendations of the Occupational Safety and Health Guidance Manual for Hazardous Waste Site Activities which is the product of a four-agency committee, the National institute of Occupational Safety and Health (NIOSH), the Occupational Safety and Health Administration (OSHA), the United States Coast Guard (USCG) and the United States Environmental Protection Agency (USEPA). These "standard hazards include:

  • Chemical exposure
  • Fire and explosion
  • Oxygen deficiency
  • Ionizing radiation
  • Biological hazards
  • Safety hazards
  • Electrical hazards
  • Heat stress
  • Cold exposure
  • Noise

In addition to the above, a number of other modules are available to choose from. The individual student will complete any number of the desired "standard hazards" above and choose additional modules from the hazard library (See Elective Module Descriptions) to complete 10 hazard topics in all. When an employer wishes to customize training for his particular site, he may require his employees to choose specific topics to better reflect his site-specific risks. This gives the employee or employer a choice of a variety of hazard-topics to choose from. The substitution is simple and the final exam will automatically reflect questions only from modules and the specific hazards chosen by the student..

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Why can't I call TSI and speak directly with one of your instructors?

Our instructors are not full time teachers but are actual consultants in the hazardous waste business. Because of this, they are often at worksites and may even be inside controlled areas at any given moment during the day. Our integrated e-mail system allows each and every question to be sorted by an operator and routed to an appropriate Certified Industrial Hygienist or Certified Safety Professional, depending upon the question's content. These individual's answer these questions when they check their daily messages and e-mail. When the question cannot be answered easily in an e-mail, one of our professionals will often place a call to the student.

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Must an individual complete a refresher course by the anniversary of his or her initial training each year,
or can this training be taken any time during the calendar year?

OSHA's intent is that employees should complete their refresher training within twelve months of their initial training, but understands that courses may be missed due to unavoidable circumstances. The employee who misses a refresher training should attend the next available course.

Source: OSHA Standard Interpretations, 03/12/1993 - Hazardous Waste Operations and Emergency Response Lapsed refresher training requirements hyperlink:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21062

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In a case where an individual has not worked in the hazardous waste environment for some time, and has let his initial training expire, will the individual be eligible to work in a HAZWOPER environment again, simply by taking a refresher course or must he take the 24 or 40 hour course again?

OSHA allows the employer to determine, on a case by case basis, the level of training necessary for each employee in this situation. In the standard interpretation cited below, a two year absence is referenced and the interpretation indicates that in many cases, this amount of time would not necessitate repetition of the course materials for the initial 24 hour or 40 hour training.

In other words, the 8-hour refresher training would be sufficient for the employee as long as employees new to a site are given appropriate site-specific training before site entry and given supervised field experience at the site to which they are assigned.

Source: OSHA Standard Interpretations, 03/12/1993 - Hazardous Waste Operations and Emergency Response Lapsed refresher training requirements hyperlink:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21062

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In the year that an employee takes a HAZWOPER Supervisor course, can this Supervisor course count as that year's 8 Hour HAZWOPER refresher as well?

In a 1992 OSHA interpretation, OSHA indicates that they would expect a worker to complete BOTH the Supervisor training AND the Refresher training in the year that they become a HAZWOPER Supervisor for a total of 16 hours of instruction. For a look at the interpretation letter go here:

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20664 Back to Top