December 24, 1991
Mr. Joe H. Boothe
Environmental & Safety Services,
Post Office Box 7305
Kansas City, Missouri 64116
Dear Mr. Boothe:
This is in response to your inquiry of November
18, concerning the Occupational Safety and
Health Administration's (OSHA) Hazardous
Waste Operations and Emergency Response final
rule (HAZWOPER), 29 CFR 1910.120.
Your question concerns the number of
minimum training hours an On Scene Incident
Commander must obtain before getting certified.
You have perceptively pointed out that OSHA
requires "...at least 24 hours of training
equal to the first responder operations level
and in addition have competency in the following areas...,"
but the minimum training hours that First
Responder Operations Level must acquire is
The intent of the standard is to provide
an incident command system that is headed
up by a single person who does not necessarily
have extensive knowledge about the classification
and verification of hazardous materials,
but rather who is able to manage emergencies
of differing severity, as well as oversee
the rest of the HAZMAT team. Appendix C explains:
"This enable[s] one individual to be
in charge of managing the incident, rather
than having several officers from different
companies making separate, and sometimes
conflicting, decisions. The individual in
charge of the [incident command system] would
delegate responsibility for performing various
tasks..." Consequently, the Incident
Commander requires more extensive training
in general matters, plus extensive training
in command and management.
Hence, the Incident Commander will
require more than 24 hours of total training.
The training hours suggested in the standard
are minimums; we often find that people developing
training programs must go over the minimum
8, 24, or 40 hours to properly instruct employees
on all of the required subjects.
We hope this information is helpful.
If you have any further questions please
feel free to contact us at (202) 523-8036.
Patricia Clark, Director
Directorate of Compliance Programs