HAZWOPER 40 vs 24 vs 8-Hour Refresher: Which One Do You Need?

If you are unsure, ask your employer or the site safety and health plan which category applies to your job. The standard puts that decision on the employer, and many contracts and clients simply require the 40-hour course for anyone entering the site.

Under 29 CFR 1910.120(e)(3)(i), general site workers (such as equipment operators and general laborers) who are exposed to hazardous substances, health hazards or safety hazards must receive a minimum of 40 hours of instruction off the site and a minimum of three days of actual field experience under the direct supervision of a trained, experienced supervisor.

The standard covers cleanup operations required by a governmental body, RCRA corrective actions, voluntary cleanups at sites recognized by a governmental body as uncontrolled hazardous waste sites, operations at treatment, storage and disposal facilities, and emergency response to releases of hazardous substances. Construction employers have a parallel standard at 29 CFR 1926.65.

Training must cover, at a minimum, the topics in 1910.120(e)(2): site safety personnel, the hazards on the site, personal protective equipment, work practices that minimize risk, engineering controls, medical surveillance, and decontamination and emergency response procedures from the site safety and health plan.

The 24-hour level is narrower than people expect. The standard allows 24 hours of instruction plus one day of supervised field experience for two groups only:

• Occasional site workers who are on site only for a specific, limited task, such as groundwater monitoring, land surveying or geophysical surveying, and who are unlikely to be exposed over permissible exposure limits or published exposure levels (1910.120(e)(3)(ii)).
• Regular site workers who work on site in areas that have been monitored and fully characterized, where it has been determined that exposures are under limits and a respirator is not necessary (1910.120(e)(3)(iii)).

If a 24-hour worker later becomes a general site worker or is required to wear a respirator, the standard requires the additional 16 hours and two days of field experience to reach the 40-hour level (1910.120(e)(3)(iv)). Because most cleanup jobs cannot guarantee those conditions in advance, employers often choose the 40-hour course for everyone.

Under 1910.120(e)(8), employees covered by (e)(1) and managers and supervisors covered by (e)(4) must receive eight hours of refresher training annually. It covers the (e)(2) and/or (e)(4) topics, any critique of incidents that have occurred in the past year, and other relevant topics.

The refresher is a separate course from the 40-hour or 24-hour training, and it is commonly taken online. It does not replace the initial training. Check your employer’s or client’s policy if you have missed your 12-month date, because the standard does not describe a grace period and some sites will not let you work until you have taken it.

• Managers and supervisors directly responsible for hazardous waste operations need the same initial training as the workers they supervise (40 hours plus three days of field experience, unless the 24-hour level applies to them) plus at least eight additional hours of specialized training at the time of job assignment (1910.120(e)(4)).
• TSD facility employees follow the separate training rules in paragraph (p), not (e)(3).
• Emergency responders follow paragraph (q), which sets levels from first responder awareness through first responder operations (at least eight hours of training or sufficient experience) to hazardous materials technician (at least 24 hours). They need annual refresher training of sufficient content and duration to maintain competency, or must demonstrate competency yearly.

If you are a responder, confirm the level your job description requires. That is separate from the 40-hour and 24-hour cleanup worker tiers described above.

This is the point many buyers miss. The 40-hour and 24-hour requirements each have two parts: off-site instruction and supervised field experience. An online course can deliver the instruction hours. It cannot deliver the field days, which happen on an actual site under a trained, experienced supervisor, and it cannot by itself provide hands-on practice with the PPE and respirators you will use.

In practice:

• The online course builds the knowledge base and gives you a certificate of completion for the instruction portion.
• Your employer arranges the supervised field experience, the site-specific training on the hazards and procedures at the job site, and the hands-on practice with equipment.
• The standard requires that workers be certified by their instructor and trained supervisor after finishing the training and field experience (1910.120(e)(6)). Without that, they are prohibited from engaging in hazardous waste operations.

OSHA does not approve, certify or accredit online providers. Always check that your employer or client accepts the course format before you pay.

1. Will I be exposed, or could I be exposed, to hazardous substances on site? If yes, or if nobody can tell you for certain, choose the 40-hour course.
2. Is my role limited to occasional tasks or a fully characterized, monitored area with no respirator needed? Only then does the 24-hour level apply, and only if your employer confirms it.
3. Have I already completed the initial training? If so, you need the 8-hour refresher every year, not another initial course.

Gama Safety’s HAZWOPER 40-hour course is $199, with a certificate and printable wallet card when you pass, and unlimited free exam retakes. Team accounts are available if you are training a crew.

• OSHA, 29 CFR 1910.120, Hazardous waste operations and emergency response, paragraphs (a)(1), (e)(1) to (e)(9), (p) and (q).
• eCFR, 29 CFR 1910.120.
• eCFR, 29 CFR 1926.65, the construction version of the standard.