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OSHA 40-hr Hazardous Waste General Site Worker

Don't be burned by incorrect claims.
Read why you cannot take the full 40-hr course online.

hands-on exercises

Would you want the first time you actually performed CPR to be when someone's life is on the line? Would you want the first time you put on Personal Protective Equipment (PPE) to be when you're at a hazardous waste site, where the dangers are real?

Most likely, your answer is no. Yet, this might be the situation if you were to take a 40-hour HAZWOPER online training course. Here's why we don't offer this program when others do.

General Site Workers vs. Occasional Site Workers

OSHA regulations for hazardous waste operations training, found in 29 CFR 1910.120(e), state that "General Site Workers" shall receive a minimum of 40 hours of instruction off the site, and a minimum of three days of actual field experience, while "Occasional Site Workers" shall receive a minimum of 24 hours of instruction off the site, and a minimum of one day actual field experience. Why the difference? Occasional Site Workers' exposures to hazardous substances are under published Permissible Exposure Limits (PEL) and they would not need to wear respiratory protection. Conversely, a General Site Workers exposure may exceed published PELs and they would need to wear respiratory protection and other PPE.

Interpreting Appendix E of OSHA HAZWOPER Regulations

In Appendix E to the HAZWOPER regulations, OSHA outlines acceptable practices that would meet training regulation requirements. In an interpretation letter to David L. Barber, dated April 6, 1995, OSHA states that "the purpose of Appendix E is to provide non-mandatory general criteria to assist training providers and employers in developing training curriculum to meet the requirements of 29 CFR 1910.120(e)."

Some say since Appendix E is "non-mandatory" they don't need to pay attention to it in developing training programs. Why would OSHA write the Appendix if we don't need to pay attention to it? OSHA gave us Appendix E in order to let us know what they intended when they were writing the HAZWOPER regulation. While our training programs don't need to look exactly like the training programs outlined in Appendix E, our training better be at least as good as the Appendix E training, or else we're not meeting OSHA's intent.

OSHA's Response to 40-Hour Online Training

In an interpretation letter solicited by Ron Gantt, one of our own Remote Instructors™, dated August 16, 2004, OSHA states that along with the 40-hour HAZWOPER training, "equally important is the use of hands-on experience and exercises to provide trainees with an opportunity to become familiar with equipment and safe practices in a non-hazardous setting." OSHA also points out that:

The purpose of hands-on training is two-fold: first, to ensure that workers have an opportunity to learn by practical experience, and second, to assess whether workers have mastered the necessary skills. It is unlikely that sole reliance on a computer-based training program will accomplish these objectives.

The actual requirements for a 40-hour course are classroom instruction plus three days of supervised field experience. Some training providers may tell you that in those three days of supervised field experience workers can receive their hands-on training. However, in the same interpretation letter, when asked if this is acceptable, OSHA replies:

No. Supervised field experience is part of an employee's initial training, taking place after he or she has completed the off-site classroom instruction.

Cyber Space Does Not Deliver Hands-On Training

Until cyber space allows us to perform hands-on training via the Internet, the 40-hour General Site Worker certification cannot be offered through online training only. There must be some traditional classroom training to enable employees to practice with the equipment they will use in the field. The same principle applies to forklift certification or CPR training.

All OSHA Certification Training Programs Are NOT Created Equal

Remember, for almost all of OSHA required trainings, including HAZWOPER; it is not the instructor nor the training institution that certifies the individual employee taking the course. It is the employer's responsibility to certify their employees. The employer is the one who would be on the hook, in the form of a hefty fine, not the training provider, if OSHA were to ever find an employee's training program to be deficient.

That means it's important for you to ensure that you are getting the best training possible from your training provider. They have nothing to lose if OSHA doesn't like their training programs, but you do. This "buyer beware" factor is even more important since OSHA does not certify nor endorse any training programs. There are a lot of courses offered by companies that might not necessarily meet the OSHA requirements. You need to select a training provider that is both qualified in terms of education and experience, and one that also knows and adheres to OSHA regulations. If a company offers online 40-hour courses they might fill your need for lowering training costs, but if that company's knowledge of the regulations is suspect, in the end it's you, the employer, who pays.

For more detailed information on our HAZWOPER Training Programs or our other on-site safety compliance services call our instructors at 800-974-1419.

40-hr Certification from HazmatSchool.com

Many of those who take HAZWOPER training may also need the 40-hour certification. This is easily accomplished by taking the online 24-hour course (Occasional Site Worker) coupled with a 16-hour supplemental classroom program. This combination will fully satisfy the requirements for certification as a General Site Worker under the OSHA regulation (29 CFR, Part 1910.120). Further, because the course exceeds the basic Federal OSHA requirements, it will satisfy the requirements of the various state OSHA programs including those in California.

The 16-hour supplemental course, which includes hands-on exercises, is taught at least quarterly in San Ramon, California by our instructors from SCM. Details about the course and registration requirements are available here. A course outline is also provided in the event you wish to evaluate whether a course located close to you will incorporate the necessary elements.

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