March 6, 1992
Ralph L. Freed
Gove Associates, Inc.
1601 Portage Street
Kalamazoo, Michigan 49001-3899
Dear Mr. Freed:
This is in response to your inquiry of February
10, concerning the Occupational Safety
Health Administration's (OSHA) Hazardous
Waste Operations and Emergency Response
rule (HAZWOPER), 29 CFR 1910.120.
Your question concerns clarification
of the annual 8 hour refresher training
employees who work on hazardous waste
required in paragraph (e). Your letter
that you could not find where accreditation
for the 8 hour refresher course is
in the Notice of Proposed Rulemaking
Accreditation of Training Programs
OSHA did not propose to require accreditation
of refresher training, although the
regulation, printed in the January
issue of the Federal Register (enclosed),
is not a final rule. Changes and additions
may be made before the standard becomes
The question of whether or not refresher
training should be accredited was an
which received comment, as noted in
of the proposed rulemaking. You may
to monitor the progress of the standard
contacting OSHA's Office of Safety
at (202) 523-8063.
Regardless of the final rule's scope
of coverage, your company may create
own 8 hour refresher training course
the guidance given in the HAZWOPER
If in the future the final rule for
of training programs includes 8 hour
training, then your company may submit
training course that it developed prior
the final rule for accreditation.
I hope this information is helpful.
If you have any further questions please
contact MaryAnn Garrahan at (202) 523-8036.
Patricia Clark, Director
Directorate of Compliance Programs