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 Permissible Exposure Limit 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” need 40 hours of training and “Occasional Site Workers” only need 24 hours of training. Why the difference? General Site Workers are either exposed to hazardous substances above the OSHA published Permissible Exposure Limit (PEL) and other published exposure limits, or they are required to wear Personal Protective Equipment (PPE), such as a respirator.

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 that Appendix E is a “non-mandatory” and don’t pay attention to it in developing training programs. So why would OSHA write the regulation 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 training regulations. 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 (TM), 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 to Ron Gantt, 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 becomes more real and allows us to perform real, 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 things like 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 is “buyer-beware” factor is even more important since OSHA does not certify or 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 information on our HAZWOPER Training Programs or our other safety compliance services, contact us.