July 21, 1992
Mr. Stuart Buchanan
10675 Richmond Ave.
Houston, TX 77042
Dear Mr. Buchanan:
This is in response to your inquiry of June
12 concerning the Occupational Safety and
Health Administration's (OSHA) Hazardous
Waste Operations and Emergency Response final
rule (HAZWOPER), 29 CFR 1910.120.
You wrote to our office regarding Radian
Corporation's schedule for refresher training.
You conduct your eight hour refresher training
in segments presented to employees throughout
the year. Radian employees may complete their
initial training in January, but may not
complete the refresher training until December
of the next year.
OSHA agrees that companies can conduct
their refresher training in segments to meet
the requirements of the standard, as long
as all of the provisions for refresher training
in paragraphs (e), (p), or (q), are met.
However, the time frame in which you conduct
your first set of refresher training sessions
may not meet the requirements of the standard.
From the language you use in the letter,
it sounds as if the first set of refresher
training sessions begins on or about the
anniversary date of the initial training,
and is completed in two years. If you choose
to provide training in intervals, the sessions
should start soon after the initial training
and add up to eight hours by the first anniversary
We also point out that 8 hours is a
minimum requirement; many employers will find it
difficult to cover all topics listed in the
training requirements in the minimum allowable
time. The competencies to be covered during
training sessions may demand more than 8
hours. When developing training, employers
must structure their refresher training based
on the employee's expected job duties.
We hope this information is helpful.
If you have any further questions please
contact the Office of Health Compliance Assistance
at (202) 523-8036.
Patricia Clark, Director
Directorate of Compliance Programs