Training and Training Renewal Requirements
for selected programs
T.R. Consulting, Inc.
February 2004 Safety Article
Written and compiled by:
Copyright 2004 T.R. Consulting, Inc.
T.R. Consulting, Inc. regularly publishes safety and environmentally related articles on our website at
http://www.trconsultinggroup.com/safety/archive.html. These articles are a free service provided by T.R. Consulting, Inc. to all interested parties in order to promote safety and environmental awareness. T.R.
Consulting, Inc. also provides safety training information and services. Information about our safety training programs can be accessed at http://www.trconsultinggroup.com/safety/.
Note: T.R. Consulting, Inc. presents the information contained in this article as an aid in understanding of the subject matter. Referenced standards must be read and thoroughly understood in order to assure compliance with the standard. T.R. Consulting, Inc. attempts to provide accurate information, but makes no warranty with regard to either the completeness or accuracy of the information contained herein.
This article is intended to provide clarification as to the requirements for initial and renewal of several common types of training required of construction and service companies that work in proximity to chemical hazards. Because regulations are subject to change and interpretation, the following information can be considered current only at the time of first issuance.
Confined spaces training is required for all workers potentially exposed to confined space hazards. This would include employees whose work includes work within confined spaces and others that work in areas where confined spaces can be found. Certainly, the level of training required to make a confined space safe for entry or perform work within a confined space that may still contain atmospheric hazards is greater than that required to alert employees of the existence of confined spaces in their workplace and assure that those employees do not enter confined spaces without authorization from a qualified individual. In the former situation, the level of confined space training provided under a HAZWOPER training program would be insufficient to assure employee safety. In the latter situation, HAZCOM training requirements may be capable of meeting the training needs of those employees.
OSHA’s confined space regulations are contained at 29 CFR Part 1910.146. The training requirements contained therein do not specify a frequency of training, only that adequate training be provided prior to assignment to confined space entry operations. Unlike many construction activities that require retraining only when the employee provides some indication that more training is necessary (such as a near accident, being observed not following proper procedures, etc.), the failure to follow appropriate procedures in confined space entry can readily result in bodily harm or death and the risk of waiting until some deficiency is noted will place the employee at an unacceptable risk level. Thus, the most common standard in industries where confined space work is routinely performed is to require annual recertification of employees. In effect, this means that any employer who has an accident where confined space work was being performed has a substantial risk of liability if employees have not received confined space training in the past year.
T.R. Consulting, Inc. has recognized the varying level of need in the degree of confined space training required by our clients and has developed a three-tiered approach to confined space training to properly address those needs. The training levels are:
Confined Space Entry Training - this training is intended to thoroughly cover the roles and responsibilities of entrants, attendants and confined space entry supervisors for employees performing work involving the entry into confined spaces. Included are sample procedures for declassification of confined spaces, entry permit form requirements, monitoring requirements, requirements for specialized safety equipment, and information about the most common hazards associated with confined space entry. This program utilizes exercises, a flow chart diagram, text, accident reviews and a final test to provide the information necessary for employees to understand the hazards and the steps that may be taken to control or eliminate those hazards. This training is suitable for those employees that work as part of a confined space entry team. To access the T.R. Consulting, Inc. confined space training page go to: http://www.trconsultinggroup.com/safety/confspac/confspac.html
Confined Space Awareness/Refresher Training - this training focuses on the hazards posed by confined spaces and the need to control access to confined spaces to those who are authorized, properly equipped, and properly trained to perform entry. The same concepts and controls are examined as in the confined space entry training (above), but exercises to reinforce the concepts are omitted. This training is suitable for employees that work in areas where confined spaces are present but are unauthorized to enter these confined spaces. Additionally, some employers may find this level of training suitable for refresher training for those employees who have completed an in-depth confined space course previously and merely need to update or refresh that initial training. To access the T.R. Consulting, Inc. confined space awareness/refresher training page go to: http://www.trconsultinggroup.com/safety/confspac/csaware.html
Confined Space Rescue - this training is provided at the employers facility and entails a full day of hands on and classroom activities designed to assure the ability of employees to respond appropriately to an emergency situation in a confined space workplace.
The employer is required to provide training in the hazards associated with exposure to chemicals found in the workplace. Employees potentially exposed to these chemicals must be provided with information about the hazards of exposure, steps that can be taken to control exposure and steps that need to be taken if an exposure occurs. HAZCOM also covers requirements for labeling and shipping. A complete article addressing all of the HAZCOM requirements can be found at http://www.trconsultinggroup.com/safety/mar2002.html
HAZWOPER training requirements can be found at 29 CFR Part 1910.120. This training is required for employees that are potentially overexposed to chemicals as a part of clean-up operations at a site (broadly defined as a site where chemical wastes or residues are handled with the intent of making the site safer), at TSD facilities (treatment, storage and disposal) and for members of HAZMAT teams. HAZWOPER training consists of three components: initial classroom training, initial field supervision, and annual refresher training. In order to initially qualify for work at sites requiring HAZWOPER training, the employees most recent HAZWOPER training must not have taken place more than one year prior to the work on site. When a worker fails to refresh their training, there is no standard answer for the amount of training that must be undertaken in order to requalify. In most instances, merely completing a refresher course is sufficient and acceptable. However, if the lapse of training extends more than a couple of years, additional training may be required. To view an article detailing OSHA's interpretations regarding lapsed training go to http://www.trconsultinggroup.com/safety/apr2002.html. The following paragraphs outline the HAZWOPER training requirements for clean-up operations.
Initial HAZWOPER Training - prior to assignment on sites requiring HAZWOPER training, employees must receive either 40 hours or 24 hours of classroom training, depending upon the degree of expected exposure and the tasks to be performed. When the employee will only be on sites that have been characterized by a qualified person, will be performing specific, limited tasks, and will not be overexposed or be required to use a respirator, 24 hours of classroom training is deemed adequate. For all others, 40 hours of classroom training is required. 24 hour HAZWOPER training is provided both in person and on-line at http://www.trconsultinggroup.com/safety/24hrhaz/24hrhaz.html. OSHA has distributed interpretations that question the ability of a provider to provide 40 hour HAZWOPER training on-line. To address those concerns, T.R. Consulting, Inc. provides both traditional courses and a combination course where 24 hours of training is taken on-line and 16 hours of training is provided in a traditional classroom. To access the T.R. Consulting, Inc. HAZWOPER 24 + 16 hour training page go to: http://www.trconsultinggroup.com/safety/haz24_16/haz24_16.html
Qualified Field Supervision - for those completing 40 hours of classroom training, an additional 24 hours of field supervision under a qualified person is required to round out the initial training requirements. For those completing 24 hours of classroom training, an additional 8 hours of field supervision under a qualified person is required to round out the initial training requirements.
Supplemental HAZWOPER Training - OSHA specifically states that those employees receiving 24 hours of initial HAZWOPER training can receive an additional 16 hours of training and an additional 16 hours of qualified field supervision to meet the 40 hour training requirements. T.R. Consulting, Inc. now offers the classroom portion of this training on-line for those employees who received 24 hours of traditional classroom training (not on-line) previously . To access the T.R. Consulting, Inc. HAZWOPER Supplement training page go to: http://www.trconsultinggroup.com/safety/haz16/haz16.html. We also offer this supplement in traditional classroom programs.
HAZWOPER Supervisor - on-site management and supervisors of crews performing work at sites requiring HAZWOPER training are required to complete an additional 8 hours of training beyond the standard HAZWOPER training requirements. This training is intended to assure that the supervisor/manager is aware of the contents of safety and health programs, standard operating procedures, standard safety procedures, etc. issued by the employer, including the minimum requirements for these documents so that deficiencies can be corrected. This employee is viewed by OSHA as representing the interests of the employer and, therefore, needs to be acutely aware of the employer's responsibilities. T.R. Consulting, Inc. offers both traditional classroom and on-line HAZWOPER supervisor training. To access the T.R. Consulting, Inc. HAZWOPER Supervisor training page go to: http://www.trconsultinggroup.com/safety/supervis/supervis.html. There are no annual renewal requirements to the supervisor training so long as the initial HAZWOPER training (a prerequisite for supervisor training) is refreshed annually as described below.
HAZWOPER Refresher Training - this annual 8 hour course is intended to "reawaken" the safety information within employees. The required topics are a summarized approach to the same topics as those provided during initial training plus a review of any incidents (accidents, near accidents, etc) that have occurred in the past year. T.R. Consulting, Inc. offers both traditional classroom and on-line versions of this training. To access the T.R. Consulting, Inc. HAZWOPER Refresher training page go to: http://www.trconsultinggroup.com/safety/hazwop8/hazwop8.html.
SOME OTHER TRAINING REQUIREMENTS
HEARING CONSERVATION - for employers meeting the requirements for implementation of a hearing conservation program, annual retraining of employees is required. For more information go to http://www.trconsultinggroup.com/safety/oct2002.html.
BLOODBORNE PATHOGENS - Annual retraining is required as a part of a bloodborne pathogen control program. To view a power point presentation on bloodborne pathogens go to: http://www.trconsultinggroup.com/ppt/bldborne.ppt.
GENERAL CONSTRUCTION SAFETY - this training is commonly obtained as a part of the OSHA Outreach Programs for 10 hour and 30 hour Construction Safety Course, but the employer may choose to have qualified training provided to employees only in the areas applicable to the employees work exposure (i.e. for employees that do not work on or around scaffolding, scaffolding training would not be required). OSHA 10 and 30 hour courses typically provide training in scaffold use, ladder safety, fire safety, electrical safety, material handling, working around cranes and lift equipment, fall protection, etc. Many general contractors are now requiring 30 hour training certificates with the 10 hour course used as a refresher once every two years. The construction standard (OSHA) requires retraining whenever the equipment used changes, whenever the type of work changes, and whenever an employee exhibits a need for retraining (accident, near accident, not following procedures, etc.).
LIFT EQUIPMENT OPERATION - operators of fork lifts and similar equipment must be trained by a qualified individual prior to operating the equipment and observed to assure safe operation of equipment during training by a qualified individual. If the employee exhibits the need for retraining (reckless operation, improper loading, etc) or the employee is assigned to new equipment, additional training is required.