This is in response to your request for a written interpretation of the training certification requirements under the Occupational Safety and Health Administration's (OSHA) Hazardous Waste Operations and Emergency Response (HAZWOPER) standard (29 CFR 1910.120). Specifically, you requested clarification as to (1) whether former employees can request copies of training certificates from former employers; and (2) whether current employers can request documentation of an employee's training from the employee's former employer. The response that follows confirms your telephone conversation with Ms. MaryAnn Garrahan of my office on October 21, 1996.

Former employees can request copies of training certificates from former employers and current employers can request documentation of an employee's training from the employee's former employer. OSHA regulations, however, do not require former employers to respond to such requests. Paragraph 1910.120(e)(6) of the HAZWOPER standard requires that head instructors or trained supervisors provide a written certificate to each employee that has successfully completed the training and field experience that is specified in paragraphs (e)(1) through (e)(4) of the standard. It is the employee's responsibility to keep copies of the training certificate for themselves and for future employers.

We hope that this letter clarifies your concerns regarding requirements for training certification under OSHA's HAZWOPER standard. If you have additional questions, please contact this office at (202) 693-2190.

Sincerely,

Ruth McCully, Director
Office of Health Compliance Assistance