August 19, 1991
Mr. Al Carino
165A Old Forge Road
Jamesburg, New Jersey 08831
Dear Mr. Carino:
This is in response to your inquiry of May
20, to Mr. Thomas Hall concerning the
Safety and Health Administration's
Hazardous Waste Operations and Emergency
Response final rule (29 CFR 1910.120).
Your specific question reads "how
I apply this training [a comprehensive
apprenticeship program] toward the
certification requirements necessary
hazard[ous] waste operations?"
Paragraph (e)(9) of 1910.120 discusses
training" and states;
(9) Equivalent training. Employees
show by documentation or certification
an employee's work experience and/or
has resulted in training equivalent
training required in paragraphs (e)(1)
(e)(4) of this section shall not be
to provide the initial training requirements
of those paragraphs to such employees.
certified employees new to a site shall
appropriate, site specific training
site entry and have appropriate supervised
field experience at the new site.
Therefore, your employer may decide,
on the course content, that your apprenticeship
meets the requirements of the off site
training. Your letter covered some
topics in your apprenticeship, which
employer must compare to training program
requirements. The training must adequately
prepare an employee to perform his
in a safe and healthful manner.
If your employer intends to certify
or partially as "equivalently
he should retain a copy of your training
certificate and the comparison of training
requirements in your personnel file.
you can be certified as equivalently
you must have the required hours of
job supervised training. Additionally,
employer is required to supply the
with 8 hours of refresher training
Generally, if there has been a lapse
years without refresher training since
initial training, the initial training
be repeated. Therefore, if you have
no additional training specific to
waste operations since the end of your
in 1977, it may be necessary for you
the initial 40 hour training course.
I hope this information is helpful.
have any further questions please feel
to contact MaryAnn Garrahan at (202)
Patricia K. Clark, Director
Directorate of Compliance Programs