In many of our 40-hour HAZWOPER or HAZMAT classes the question is asked, “Who can teach my 8-hour refresher class?” One case a student asked this question because nearly the entire workforce of the company was in the training class EXCEPT for anyone from the safety department who would later be responsible for teaching the refresher material. So, what is this refresher? In OSHA’s Hazardous Materials standard (1910.120) it specifies that if you are an employee that is required to receive HAZWOPER training you are also required to have eight hours of refresher training annually. OSHA, however, does not certify instructors. The helpful (or tricky) language in the standard states:

1910.120(e)(6) Qualifications for trainers. Trainers shall be qualified to instruct employees about the subject matter that is being presented in training. Such trainers shall have satisfactorily completed a training program for teaching the subjects they are expected to teach, or they shall have the academic credentials and instructional experience necessary for teaching the subjects. Instructors shall demonstrate competent instructional skills and knowledge of the applicable subject matter.

So, this hopefully clears up the question, right? However, this statement doesn’t prevent a subject matter expert who may have not completed the 40-hour HAZWOPER class from teaching a portion of the class. To answer the question at the start of this post, the safety person who didn’t attend the course could certainly teach something within the realm of HAZWOPER if they completed a training program for the subjects, have academic credentials and instructional experience. They must be competent in what they are teaching the students.

Further in the standard it speaks specifically to refresher training 1910.120(e)(8) which, very basically, restates the requirements of the initial class and that they should be met in the refresher training. 1910.120(q)(8)(i) also states employees shall receive annual refresher training of sufficient content and duration to maintain their competencies, or shall demonstrate competency in those areas at least yearly.

According to 1910.120(e)(8) you should be covering 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 (PPE)
• 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
• Site safety and health plan
• Any critique of incidents that have occurred in the past year that can serve as training examples of related work, and other relevant topics

If your HAZWOPER refresher instructor is capable of providing this instruction and meets the other requirements for a “qualified trainer,” they certainly can teach. What the concern might be is that someone who has no training in a fully encapsulating protective suit is now teaching a group of people who must be competently trained and refreshed annually to do so – following the standard this person would not be authorized to teach this section, though could be qualified in other areas.

Throughout the OSHA standard there are various exceptions and alternate conditions for training [1910.120(e)(9)], new employees [1910.120(p)(7)], and employees who have received HAZWOPER training previously but are new to the site [1910.120(e)(9)].

This may have helped you determine who can teach your training. Certainly, if you have any questions regarding any aspect of HAZWOPER training please reach out to us, we’d be happy to walk through our process or your process and needs with you.

The greatest safety plans are the ones that are constantly evaluated and updated based on their effectiveness. There may be no greater illustration of this than the handling of hazardous chemicals. Day-to-day tasks may be easy to plan and train for--all of your employees have HAZWOPER training and they're kept safe using engineering controls and PPE.

What about spills? What is your plan when the drums start leaking or the forklift driver pierces a tote? A bulk delivery driver is delivering a tanker full of hazardous materials to your site storage tanks, now the trailer is leaking, what can you do?

Employees trained in the HAZWOPER training standard can respond to a spill and dramatically reduce the impact of the hazard. By comparison, your on-site team can respond faster to hazmat problems within your facility than a fire department of off-site hazmat response team. The quicker the response to the chemical spill, the more likely you'll protect employees and limit damage or contamination to the workplace.

Do you have a spill kit?

You have a plan, you have training, you have PPE, and you have the tools to confine or contain the spill. When was the last time you inspected your hazmat response equipment? Spill kits stored outdoors are subjected to extreme cold, heat, and UV damage when stored in the sun. What was once a functional response kit can very quickly become dry-rotting absorbent pads, frozen emergency response guidebooks, and chemical gloves that can be penetrated by the chemicals they were designed to protect you from.

There is no governing regulation regarding inspection frequency but some regular inspection process should be developed for your site and equipment. There is no universal expiration date for hazmat response equipment and each piece of equipment is different. At all times manufacturer guidelines should be followed.

While breakdown from exposure to the environment can be problematic, your spill kit may be opened and used by employees to clean up ordinary leaks and drips. An empty kit or missing and damaged equipment is useless when there is a spill. Inspections are a great opportunity for response team familiarization and to ensure your facility is ready to respond to a chemical emergency.