February 5, 1992
Dr. Donald Alberts
Spill Response Inc.
2550 Eisenhower Blvd
Fort Lauderdale, Florida 33316
Dear Dr. Alberts:
This is in response to your letter of January
17, concerning oil spill response training
required by the Occupational Safety and Health
Administration's (OSHA) Hazardous Waste Operations
and Emergency Response standard (HAZWOPER),
29 CFR 1910.120.
Currently, OSHA does not certify individuals
or approve training programs. It is the
employer who must show by documentation or
certification that an employee's work experience
and/or training meets the requirements in
HAZWOPER. There must be a written document
which clearly identifies the employee, the
person certifying the employee, and the training
and/or past experience which meets the requirements.
One possibility would be to include this
information in the employee's personnel file.
The preferred method is to include this information
on a separate certificate for each employee.
The Accreditation of Training Programs
for Hazardous Waste Operations standard (29
CFR 1910.121) is currently in rule making.
You may want to monitor the progress of this
new standard and anticipate needed changes
in your training and certification programs
to ensure continued compliance. Please find
a copy of the Notice of Proposed Rulemaking
The training programs required to be
accredited under this proposed regulation
are found in the Hazardous Waste Operations
and Emergency Response standard, 29 CFR 1910.120,
paragraphs (e) and (p). These training programs
are required for employees involved in clean-up
operations required by a governmental body
involving hazardous substances; corrective
actions involving cleanup operations at sites
covered by the Resource Conservation and
Recovery Act (RCRA); voluntary clean up operations
at sites recognized by a governmental body;
and operations involving hazardous waste
that are conducted at RCRA permitted treatment
storage and disposal (TSD) facilities. 29
CFR 1910.121 does not propose to accredit
training programs for employees engaged in
emergency response activities, although the
final decision on this has not been made.
Enclosed, please find a the compliance
directive for post emergency response operations,
CPL 2-2.51, intended specifically for oil
spill response organizations. Also enclosed
are the OSHA instruction STP 2-1.154C; the
Hazard Communication Standard; and the HAZWOPER
For suggestions and assistance in developing
training programs you may want to contact:
the OSHA Training Institute at (708) 297-4810;
your OSHA Regional Office at (404) 347-2281;
or the OSHA Consultation Services for the
Einployer at (904) 488-3044.
We hope this information has helped
you. If you have any further questions regarding
current HAZWOPER training please feel free
to contact MaryAnn Garrahan at (202) 523-8036.
Patricia Clark, Director
Directorate of Compliance Programs