June 12, 1991
Mr. Marc B. Evans
Blasland & Bouck Engineers, P.C.
Engineers and Geoscientists
6723 Towpath Road
Syracuse, New York 13214
Dear Mr. Evans:
This is in response to your inquiry of May
8, concerning the Occupational Safety and
Health Administration's (OSHA) Hazardous
Waste Operations and Emergency Response final
rule (29 CFR 1910.120). Please accept my
apology for the delay in the reply to your
letter of January 30.
Your specific question relates to the
certification of current employees with previous
experience and training in hazardous waste
operations and training certificates for
employees trained in house.
Paragraph (e)(9) delineates the requirements
for certifying an employee as equivalently
trained, who, will then not be required to
complete the initial 40 hour training. This
paragraph is written with performance language
to allow organizations to develop internal
criteria specific to their needs for certifying
current employees as equivalently trained.
Your criteria for certifying a current
employee as equivalently trained appears
adequate. All employees certified as equivalently
trained, and new to a site, must also receive
appropriate site specific training before
site entry and have appropriate supervised
field experience at the new site. These employees
would be required to have 8 hours of refresher
training per year. OSHA concurs with your
intention to issue training certificates
to those employees that have attended a 40
hour in house training course but whom did
not receive a certificate from their instructor,
assuming that these employees have also completed
the required supervised field experience.
We hope this information is helpful.
If you have any further questions please
feel free to contact us at (202) 523-8036.
Patricia K. Clark, Director
Directorate of Compliance Programs