Understanding the Differences Between 24 and 40-hour HAZWOPER Site Worker and Emergency Responder Training Requirements
OSHA’s 1910.120 HAZWOPER regulation governs two separate activities:
Hazardous Waste Operations & Cleanup (Paragraph e)
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.
Hazardous Materials Technician
Action: Takes offensive measures to stop the release (e.g., plugging or patching leaks)
Training: Minimum 24 hours beyond Operations Level
Hazardous Materials Specialist
Action: Supports Technicians, possesses deeper substance knowledge, and liaises with regulatory agencies
Training: Minimum 24 hours beyond Technician Level
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 refresher training for HAZWOPER. Accurate HAZWOPER training and certification protect your team, meet OSHA HAZWOPER training standards, and ensure your organization is ready for any hazardous situation.
