HAZWOPER Training: 40-Hour vs. 24-Hour

OSHA’s 1910.120 HAZWOPER regulation governs two separate activities:

1. Hazardous Waste Operations & Cleanup (Paragraph e)

2. Emergency Response to Chemical Releases (Paragraph q)

Each track has its own training path, requirements, and exposure considerations.

---

Track 1: Hazardous Waste Operations & Cleanup (Paragraph e)

This track applies to workers involved in long-term exposure at sites such as uncontrolled hazardous waste sites, remediation operations, RCRA corrective actions, and TSDFs (Treatment, Storage, and Disposal Facilities).

40-Hour HAZWOPER Training (High-Risk Cleanup Workers)

The 40-hour course is required for workers with routine, high-level, or long-term exposure to hazardous substances.

Who Needs It?

• Site workers engaged in hazardous substance cleanup

• Workers regularly exposed to hazardous contaminants

• Employees at TSDFs performing hazardous waste operations

• Workers involved in RCRA corrective actions

Typical Job Tasks

• Excavation, trenching, or other intrusive operations

• Handling or containerizing hazardous waste

• Wearing respirators or higher-level chemical protective clothing

• Working around unknown or unpredictable hazards

24-Hour HAZWOPER Training (Occasional or Lower-Risk Cleanup Workers)

The 24-hour course is for workers with limited or occasional exposure who do not face the same degree of risk as 40-hour workers.

Who Needs It?

• Workers with limited or occasional involvement on hazardous waste sites

• Workers not required to wear respirators or higher-level PPE

• Employees performing observation, monitoring, or support roles

Important: Both 40-hour and 24-hour cleanup workers must complete supervised field experience before working independently.

---

Track 2: Emergency Response to Hazardous Substance Releases (Paragraph q)

This track applies to workers who respond to chemical spills or releases, such as in-plant spill teams, HazMat teams, and industrial emergency personnel. Exposures are typically short-duration, high-intensity events.

Roles Requiring “At Least 24 Hours of Training”

These roles require training specific to emergency response competencies. The 24 hours here is not the same as the 24-hour cleanup course.

1. Hazardous Materials Technician

   • Action: Takes offensive measures to stop the release (e.g., plugging or patching leaks)

   • Training: Minimum 24 hours beyond Operations Level

2. Hazardous Materials Specialist

   • Action: Supports Technicians, possesses deeper substance knowledge, and liaises with regulatory agencies

   • Training: Minimum 24 hours beyond Technician Level

3. On-Scene Incident Commander (IC)

   • Action: Manages the emergency scene, focusing on Incident Command System (ICS) and strategy

   • Training: Minimum 24 hours beyond Operations Level

Other Emergency Response Levels

• First Responder Awareness Level: Recognizes a release and calls for help (competency-based; no minimum hours)

• First Responder Operations Level: Takes defensive actions only (e.g., diking, isolating; competency-based; no minimum hours)

Key Clarification: Emergency responders do not need the 40-hour or 24-hour cleanup courses unless they also perform cleanup or remediation work. Their requirements are fully governed by Paragraph q.

---

Key Differences Between Cleanup and Emergency Response Training

HAZWOPER Cleanup Training (Paragraph e)

• Purpose: Long-term cleanup, remediation, waste handling

• Exposure: Ongoing, daily, potentially long-term

• Training: Fixed hours (40-hr or 24-hr) + required supervised field experience

• 40-Hour Course: Required for high-risk cleanup workers

• 24-Hour Course: Limited-exposure course for occasional workers

Emergency Response Training (Paragraph q)

• Purpose: Responding to chemical spills or releases

• Exposure: Short-duration, high-intensity

• Training: Competency-based with minimum hours for advanced responder roles

• 40-Hour Course: Not required (unless performing cleanup work)

• 24-Hour Minimum: Applies to Technician, Specialist, and Incident Commander roles

---

Annual HAZWOPER Refresher Requirements

All certified HAZWOPER workers must maintain their knowledge and skills through annual refresher training:

• Cleanup Workers (40-hr/24-hr): 8-hour HAZWOPER refresher course

• Emergency Responders (Paragraph q): Annual refresher appropriate to assigned response level

Regular refreshers ensure compliance and help workers stay prepared for both routine operations and emergency situations.

---

Compliant and Keep Your Workers Safe

Proper HAZWOPER training isn’t just a box to check – it’s how you keep your employees safe and your operations compliant. Make sure everyone completes the right course for their role, gets the required field experience, and stays current with annual refreshers. Accurate HAZWOPER training and certification protect your team, meet OSHA HAZWOPER training standards, and ensure your organization is ready for any hazardous situation.