What to do if Your HAZWOPER 40-Hour, 24-Hour, or 8-Hour Refresher Training Certificate Expires?
All HAZWOPER workers are well-aware that it is important to keep their OSHA 40 hour and 24-hour HAZWOPER training up to date. However, while we know that we must take the 8-Hour HAZWOPER Refresher training course annually, as is human nature, we sometimes forget the time has come and gone! Hence, there are many instances when workers face the situation where their 40 hour or 24-hour HAZWOPER training completion certificate has expired as they were unable to complete the 8-hour Refresher training program within 12 months of completing their initial HAZWOPER training. It is also common for workers’ 8-hour Refresher HAZWOPER training completion certificates to have lapsed. So, what happens when one of these HAZWOPER training certificates expires? Does this mean that the worker must take the initial 40 hour or 24-hour HAZWOPER training program again? Or will sitting for the 8-hour refresher training suffice? Does OSHA give some leeway and allow workers to renew lapsed HAZWOPER training certificates?
Let’s find out what OSHA has to say by using a few scenarios.
Training Requirement for Lapsed HAZWOPER Training Certificates
OSHA, in its HAZWOPER Standard FAQs section on its website, and in a Standard Interpretation Letter dated March 12, 1993, guides the type of HAZWOPER training requirements when workers’ certificates lapse or expire due to various reasons.
Gary and Ellen have been working in the hazardous waste industry for quite some time. They are both experienced hazardous waste workers and are also capable and remain active in their jobs. Both of them had to complete their annual 8-hour HAZWOPER refresher training on or before January 15, 2021. However, things got away from Gary and Ellen fell ill, resulting in both of them missing their deadline for renewing their HAZWOPER training certificate. What can they do now?
A: As both Gary and Ellen are familiar with their workplace and the relevant safety and health processes and procedures at their workplace and job site, although their refresher training has lapsed and the certificate expired, they can repeat the 8-hour HAZWOPER refresher training course. However, the employer must make a note of the delay and when the training will be completed in their employee records (OSHA, n.d.).
NOTE: The general rule is to complete the 8-hour HAZWOPER refresher training on or before the anniversary date of the worker’s initial training.
Peter completed the 40-hour and Jane the 24-hour HAZWOPER training course in December 2019. They know they needed to complete their refresher training within 12 months of completing their initial HAZWOPER training. However, they both forgot to take the refresher course in December 2020. It is now January 2021. What should they do?
A: In this case too, Peter and Jane will both have to take the 8-hour HAZWOPER refresher training. OSHA in its Standard Interpretation Letter states, “The employee who misses a refresher training should attend the next available refresher course. Please note that in some states operating their own OSHA-approved state safety and health program, refresher training must be completed by the exact anniversary of the initial training” (OSHA 1993, paragraph 4).
Crawford has been working in hazardous waste operations for one year and completed his initial training before he began work. Drew has been working in the hazardous waste industry for the last two years. Both were due to take the 8-hour HAZWOPER refresher training course on or before the end of November 2020. Both missed their refresher training deadline, and their training certification has lapsed. Crawford and Drew have also been making mistakes in following protocols at the worksite in the few months. What training requirement must they now fulfill?
A: As Crawford’s initial HAZWOPER training certificate has lapsed and he is also making mistakes, his employer may require him to retake the initial HAZWOPER training course. Although Drew would have taken the 8-hour refresher training in the previous year, due to the errors in following protocols and procedures, his employer may realize a need for additional training, thereby requiring that Drew also retake either the 40-hour or 24-hour initial HAZWOPER training course.
Junius has not worked in hazardous waste operations for some time now (about 2 years). When he used to work in the industry in the past, he did complete both the initial HAZWOPER training and the refresher 8-hour HAZWOPER training. Now, that he has decided to return to work, which training program must he complete – the 40-hour, 24-hour, or 8-hour refresher?
A: The need for the training based on absence from working in hazardous waste operations must be decided on a case-by-case basis. If employees can demonstrate competency then retraining is not required. Consider the following to better understand an employee’s training needs after an absence.
- What is Junius’s capabilities regarding ‘information retention’?
- Whether Junius worked for a considerable period in the hazardous waste industry in the past? As more time spent working in the industry would result in greater retention of information and knowledge.
- It is important to also consider the relevance of the past training that Junius completed. Have there been any significant changes in the standard and the requirement for training by OSHA in the last two years?
- Also, consider the specific work tasks and activities that Junius will do now? Is it significantly different from what he did in the past?
- Also, consider the difference in operations and processes between his previous employer and the current employer.
OSHA’s Standard Interpretation Letter also states, “In many cases, a two-year absence from hazardous waste work would not necessitate repetition of the course materials of the initial 24-hour or 40-hour training, and refresher training by itself could be sufficient. However, a seven-year absence would clearly indicate a need for extensive retraining, with particular attention given to new technology. In such cases, the employer may wish to consider repeating the initial [HAZWOPER] training course” (1993, paragraph 7).
If Junius had been away for more than three or four years, then his employer may decide that he needs to repeat a lot of the initial training to ensure the necessary skills and knowledge to work again in the hazardous waste industry. Thus, the training requirement would exceed more than the 8-Hour refresher training. However, the determination of the length of the training requirement is left to his employer.
As Junius is a new employee, the employer is still required to provide site-specific training and supervised field experience before he starts working.
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OSHA. (n.d.). HAZWOPER Training FAQs. Website. https://www.osha.gov/emergency-preparedness/hazardous-waste-operations/faq-hazpower#faq4
OSHA. (1993). Standard Interpretation Letter (from Jim Heringer, Administrator Corporate Industrial Hygiene and Safety, Harding Lawson Associates). Website. https://www.osha.gov/laws-regs/standardinterpretations/1993-03-12