Training curriculum guidelines

The Training Director should have at least two years of employee education experience. This minimum is stated in the Training Curriculum Guidelines in 1910.120AppE and supports the employer's responsibility under 1910.120(e).

• The document calls for a Training Director who can manage program quality, direct instructors, approve course materials, and conduct annual audits.
• Employers should document the Training Director’s qualifications and experience as part of their site-specific training program records.

Instructors should be deemed competent based on documented experience, successful completion of a topic-specific "train-the-trainer" program, and evaluation by the Training Director. This recommendation appears in 1910.120AppE and helps meet the training requirements in 1910.120(e).

• Instructors should also maintain professional competency through continuing education or an annual refresher and performance review by the Training Director.
• The Training Director’s annual review should include classroom observation and review of student evaluations to document instructional competence.

The guideline recommends maximum ratios of 30 students per instructor for general classroom instruction; hands-on PPE activities should be smaller: 10:1 for Level C or D PPE and 5:1 for Level A or B PPE. These recommendations are in 1910.120AppE and support achieving the objectives of 1910.120(e).

• Use these ratios for practical exercises where students don or operate in PPE; adjust site-specific plans if hazards or complexity require smaller ratios.
• Employers must still ensure site-specific training meets the hazard assessment and task proficiency needs required by 1910.120(e).

Proficiency assessments must evaluate both knowledge and hands-on skills and be selected and approved by the Training Director. 1910.120AppE states the assessment should include a written test, skill demonstration, or both and must be documented and justified to meet 1910.120(e).

• If a written test is used alone it should have at least 50 questions; if combined with a skills demonstration, at least 25 written questions are recommended.
• Skill demonstrations must have documented tasks and scoring criteria established by the Training Director.
• The minimum achievement level for proficiency should be written and maintained in training records.

A course completion certificate should state the student’s name, course title, course date, that the student successfully completed the course, and the training provider’s name and address; it should also include an individual identification number and the levels of PPE used during training. These items are recommended in 1910.120AppE and support documentation expectations in 1910.120(e).

• The guideline suggests an optional wallet-sized card with photograph and the training certificate number for on-site verification.
• Keep copies of certificates in the training provider’s records and make them available to the student on request.

Training providers should retain course presentation dates, attendance lists, names of those who completed courses, and issued certificate counts for at least five years. This recordkeeping recommendation is in 1910.120AppE and supports compliance with 1910.120(e).

• Records should be available to students upon request or as mandated by law.
• Retain documentation of proficiency assessments and instructor reviews as part of quality control.

The Training Director should perform an annual written audit of the training program and document any corrective actions. 1910.120AppE lists this as a program quality control criterion and aligns with the employer’s duty to maintain an effective training program under 1910.120(e).

• The audit should evaluate curriculum development, instructor performance, facilities, hands-on training adequacy, student progress monitoring, and recordkeeping.
• Documented program modifications to address deficiencies should be approved and implemented and retained with the audit records.

Course materials should be peer reviewed by technically competent outside reviewers or an advisory committee and reviewed and updated at least annually. This guidance is in 1910.120AppE and helps employers meet the training content expectations in 1910.120(e).

• The Training Director must approve all course materials and ensure equipment is maintained in good working order.
• Peer reviewers should include subject-matter experts and, when applicable, an employee experienced in the work the training targets.

Site-specific training means instruction tailored to the actual operations, hazards, procedures, and controls at a particular job site and it is required whenever employees will work at a specific hazardous waste site, RCRA/TSDF, or emergency response operation. The Training Curriculum Guidelines describe this requirement in 1910.120AppE and it implements the site-specific training mandate in 1910.120(e).

• Employers must conduct a needs assessment of the site to develop the curriculum.
• Site-specific training covers tasks, PPE selection and use, emergency procedures, and exposure controls unique to that site.

Programs should ensure students are or will be involved in work with potential chemical exposures and possess necessary skills to perform the work; the program should also have a policy on medical clearance. These acceptance criteria are described in 1910.120AppE and support site-specific training obligations in 1910.120(e).

• The program should document evidence of the student’s ability to complete training (e.g., prior training, skills, certifications).
• Medical clearance policies should comply with applicable medical and respirator standards as needed for the assigned tasks.

Yes. The guideline suggests a minimum of 50 questions for a written test used alone, and a minimum of 25 written questions if used together with a skills demonstration. This recommendation appears in 1910.120AppE and is meant to support meaningful assessments for compliance with 1910.120(e).

• Test content must be relevant to course objectives and updated as the curriculum changes.
• The Training Director must document and justify the chosen assessment methods.

If a wallet-sized card is used, it should include the student’s name, course title, course date, a statement of successful completion, the training provider’s name and address, an individual identification number, and the levels of PPE used during training; a photograph is also recommended. This card content is recommended in 1910.120AppE and supports the record documentation expectations in 1910.120(e).

• Including the training certificate number on the card allows quick verification against training provider records.
• Maintain copies of the wallet cards and associated records for the retention period recommended in the guideline.

An annual instructor review should include observation of the instructor’s delivery, feedback discussion, analysis of student evaluations, and confirmation of continuing professional competency; the instructor should also complete an annual refresher course. These elements are described in 1910.120AppE and help ensure training quality under 1910.120(e).

• The Training Director should document each review and any follow-up actions.
• Instructor continuing education or development should be documented as evidence of maintained competency.

Hands-on training is training in a simulated work environment that gives each student experience performing tasks, making decisions, or using equipment appropriate to the job, and it is important because it builds practical skills and competence for real-site operations. This definition and rationale are in 1910.120AppE and supports meeting the practical training expectations of 1910.120(e).

• Hands-on sessions should be representative of site tasks and include appropriate PPE and supervision.
• Student performance during hands-on training must be evaluated via documented skill demonstrations.

Peer reviewers should include experts in occupational health, industrial hygiene, safety, chemical/environmental engineering, employee education, or emergency response as applicable; at least one reviewer should be an employee experienced in the targeted work activities. This guidance is in 1910.120AppE and supports course accuracy for compliance with 1910.120(e).

• Peer review helps ensure technical accuracy, relevance, and practical applicability of training materials.
• Maintain records of peer review input and how comments were addressed.

Training programs must update the written test and skills demonstration as the curriculum changes and have updates approved by the Training Director; the proficiency assessment methods must be justified, documented, and approved. This requirement appears in 1910.120AppE and helps satisfy the employer’s obligation under 1910.120(e).

• Keep version-controlled copies of tests, scoring rubrics, and demonstration checklists.
• Document the Training Director’s approval and the rationale for any changes.

Training facilities should have adequate space, equipment, and site locations to deliver didactic and hands-on training, with materials and equipment kept in good working order and updated at least annually. This guidance is in 1910.120AppE and supports effective implementation of 1910.120(e).

• Facilities should include areas suitable for representative PPE practice and emergency response drills.
• In multi-site training programs, satellite centers must have appropriate equipment and qualified staff comparable to the main program.

A student acceptance policy should include procedures for verifying any required medical clearance and documentation that students possess the physical and medical ability to perform training tasks safely; this recommendation is in 1910.120AppE and links to medical fitness considerations in 1910.120(e).

• If respirator use or strenuous PPE is part of training, ensure compliance with medical evaluation and respirator fit-testing requirements under applicable standards.
• Document medical-clearance policies and retain records consistent with privacy and legal requirements.

Supervisory personnel should receive additional courses and have proficiency evaluated by methods reflecting their extra responsibilities, and those methods must be acceptable to the Training Director. This guidance is in 1910.120AppE and supports the supervisory training expectations of 1910.120(e).

• Proficiency assessments for supervisors should include decision-making, incident command, and oversight skills in addition to technical proficiencies.
• The Training Director should document the supervisor-specific assessment criteria and results.

A training plan review should evaluate training duration, course content and agendas, target population requirements, curriculum development process, inclusion of hands-on methods, and student progress monitoring. These suggested evaluation factors are listed in 1910.120AppE and are intended to ensure programs meet 1910.120(e).

• Review whether objectives are clearly stated and being met, and whether facilities and staff are appropriate.
• Document findings and recommended improvements as part of the annual audit process.

Under 1910.120(e) off‑site hazardous waste operations training must cover regulatory requirements, site safety planning, medical surveillance, emergency procedures, hazard communication, and other core elements listed in the guideline. Specifically, training should include regulatory knowledge such as an overview of 29 CFR 1910.120, the content of the medical surveillance program per 29 CFR 1910.120(f), and elements of an effective site safety and health plan consistent with 29 CFR 1910.120(b)(4)(ii).

• Training should also address applicable emergency response plans and procedures (see 29 CFR 1910.38 and 29 CFR 1910.120(l)).
• The Training Curriculum Guidelines in Appendix E list additional technical and practical topics (e.g., toxicology basics, physical hazards, and decontamination).

Under 1910.120 App E the guideline recommends that a substantial portion of initial training be hands‑on—typically at least one‑third of the program. For many curricula this is implemented in a 40‑hour initial course that includes practical exercises to build competence.

• Appendix E suggests that at least one‑third of the program be devoted to hands‑on exercises and demonstrations (1910.120AppE).
• For RCRA/TSD operations the appendix also specifies a minimum of eight hours of hands‑on training as part of the required course (see 1910.120(p)).

Under 1910.120(e)(8) employers must provide an annual 8‑hour refresher training that focuses on areas needing improvement and updates on new developments. The refresher should review relevant topics from the initial training, cover developments in materials and procedures, and explain changes to OSHA or EPA rules.

• Appendix E recommends a curriculum for the 8‑hour refresher that targets topics needing reemphasis and updates (1910.120AppE).
• See the refresher requirement at 29 CFR 1910.120(e)(8).

Under 1910.120(p) RCRA treatment, storage, and disposal (TSD) facility training must include a review of applicable 1910.120 requirements, recognition of relevant hazards, confined‑space procedures, work practices to reduce risk, emergency response including first aid, decontamination, and hazard communication.

• Appendix E lists specific elements employers should include, such as review of 29 CFR 1910.120, hazard recognition, confined‑space hazards and procedures, and a review of the employer's hazardous waste handling and spill containment programs (1910.120AppE).
• The RCRA training topics explicitly reference 29 CFR 1910.120(p).

Under 1910.120(p)(3) RCRA training must review the employer's medical surveillance program and train employees to recognize signs and symptoms of overexposure to hazardous substances. Training should cover the medical program’s scope, frequency of exams, record availability, and what to do when exposure symptoms appear.

• Appendix E specifies that training include recognition of signs and symptoms of exposure, frequency and extent of periodic medical examinations, and maintenance and availability of records (1910.120AppE).
• Refer to the medical surveillance requirement at 29 CFR 1910.120(p)(3).

Under 1910.120(p)(4) decontamination training must review the employer's decontamination program and procedures, including personnel, clothing, and equipment decontamination, and how those procedures are implemented on site.

• Appendix E lists decontamination program elements such as employee decontamination, clothing decontamination, and equipment decontamination that should be taught and exercised (1910.120AppE).
• See the decontamination requirement at 29 CFR 1910.120(p)(4).

Under 1910.134 hazardous waste training must include respirator selection, use, limitations, maintenance, and documentation consistent with the employer's respirator program. Employees must be trained in donning and doffing, communication while wearing respirators, and the program's medical and fit‑testing requirements.

• Appendix E calls for instruction in respirator program components and procedures to comply with 29 CFR 1910.134, including respirator limitations and documentation procedures (1910.120AppE).
• For the full respirator program requirements see 29 CFR 1910.134.

Under 1910.146 hazardous waste site training should include confined‑space entry procedures, special PPE, permit requirements, atmospheric monitoring, communication procedures, emergency response, and applicable lock‑out procedures.

• Appendix E specifically recommends review and knowledge of confined‑space entry procedures in 29 CFR 1910.146 and describes elements of a confined‑space program to teach on site (1910.120AppE).
• See 29 CFR 1910.146 for the confined‑space standard itself.

Under 1910.120 App E employers must give employees information and training before their initial on‑site assignment that covers the hazard communication program, locations of hazardous substances, methods to detect releases, physical and health hazards present, and protective measures employees can take.

• Appendix E lists the required pre‑assignment topics, including SDS/labeling systems, monitoring and alarm recognition, site activities where hazards may be present, and specific procedures the employer has implemented to protect workers (1910.120AppE).
• Employers should ensure this training meets 29 CFR 1910.120(e).

Under 1910.120 App E site training must cover selection, proper use, maintenance, limitations, inspection, donning/doffing, decontamination, storage, and task‑duration limits for personal protective equipment.

• Appendix E explicitly lists selection, use, maintenance, limitations, donning and doffing, inspection procedures, decontamination and disposal, and task duration related to PPE (1910.120AppE).
• Respirator‑specific elements should comply with 29 CFR 1910.134.

Under 1910.120 App E the guideline recommends issuing a laminated, dated card or certificate with a photo that states the level and limitations of protection for which the employee is trained.

• Appendix E suggests issuing such identification to students who successfully complete the course, to document training level and limitations (1910.120AppE).

Under 1910.120 App E the guideline recommends mandatory attendance at all modules, successful completion of exercises, and a final written or oral exam with at least 50 questions for course completion.

• Appendix E recommends that attendance be required at all modules and that successful completion include exercises and a final exam containing at least 50 questions (1910.120AppE).

Under 1910.120(p) and Appendix E the guideline expects RCRA/TSD employees to receive hands‑on training appropriate to their job duties, including at least eight hours of hands‑on training and job‑specific skill training before participating in field activities.

• Appendix E specifies that RCRA training should include at least eight hours of hands‑on training and that employees must be trained in job skills required for their specific responsibilities before they work in the field (1910.120AppE; 1910.120(p)).

Under 1910.120(b)(4)(ii) trainees should learn the content and purpose of the site safety and health plan, including roles and responsibilities, hazard assessments, control measures, emergency procedures, and how the plan is implemented and accessed on site.

• Appendix E specifically calls for training on the elements of an effective site safety and health plan consistent with 29 CFR 1910.120(b)(4)(ii) and describes the need to teach names of responsible personnel, hazards present, and selection and use of controls (1910.120AppE).

Under 1910.120(p)(8) employers must include emergency response and first‑aid procedures in RCRA/TSD training that meet the requirements of paragraph (p)(8), covering pre‑emergency planning, roles and authority, emergency recognition, safe distances and refuge, evacuation procedures, and emergency medical treatment.

• Appendix E lists elements of the site emergency response plan that should be covered in training and references the need to meet 29 CFR 1910.120(p)(8) and related emergency planning (1910.120AppE).
• Also consider 29 CFR 1910.38 for general emergency action plan requirements.

Under 1910.120 App E training should include review and hands‑on demonstration of competency with air sampling and monitoring equipment used in the site monitoring program.

• Appendix E recommends that trainees be shown how to use and demonstrate competency with air sampling and monitoring equipment that may be employed on site (1910.120AppE).
• Respirator and monitoring program elements should align with 29 CFR 1910.134 when respiratory protection decisions follow monitoring results.

Under 1910.120 App E training should teach container sampling procedures and safeguards, general drum and container handling, special requirements for laboratory waste packs, shock‑sensitive wastes, radioactive wastes, and safe preparation of containers for shipping and transport.

• Appendix E explicitly lists container sampling procedures, safeguarding, drum handling, and shipping preparation as training topics (1910.120AppE).
• Employers should also ensure hazardous communication requirements for shipping and manifests are covered per 29 CFR 1910.1200.

Under 1910.120 App E employers should inform employees where the site safety plan and written programs are located, explain how to access and review them, and train employees on the mechanisms for review and any references used.

• Appendix E stresses discussing the location of the site safety plan and all written programs as part of training, including mechanisms for access and review (1910.120AppE).
• The site safety plan content should be consistent with 29 CFR 1910.120(b)(4)(ii).

Under 1910.120 App E supervisors should receive a specific 8‑hour supervisor training curriculum, and demonstrated competency in the knowledge and skills of a 40‑hour course should be a prerequisite for supervisor training.

• Appendix E recommends developing a curriculum for the required 8‑hour supervisor training and states that demonstrated competency from a 40‑hour course should be a prerequisite (1910.120AppE).
• These supervisory training expectations are part of the broader 29 CFR 1910.120(p) training framework for RCRA/TSD operations.

Under 1910.120 App E refresher training should include hands‑on review and re‑training on any new or modified PPE, decontamination equipment and procedures, and new air or contaminant monitoring equipment.

• Appendix E recommends that refresher courses include hands‑on review of new or altered PPE or decontamination procedures and review of newly developed air and contaminant monitoring equipment (1910.120AppE).
• This complements the annual 29 CFR 1910.120(e)(8) refresher requirement.

Yes — emergency response organizations must include the mandatory topics listed in 1910.120(q)(6).

• The standard 1910.120(q)(6) spells out the required topics for emergency responder training (for example, recognition, hazard assessment, and PPE). Appendix E to 1910.120 recommends supplementing those mandatory topics with additional subjects appropriate to the community and response level, such as hazard recognition, toxicology basics, decontamination, emergency procedures and first aid, safe sampling techniques, and medical monitoring requirements.
• Use Appendix E (1910.120AppE) to identify helpful supplemental topics when you develop local training programs that meet or exceed the 1910.120(q)(6) requirements.

First Responder Awareness, Operations, and Hazardous Materials Technician are distinct levels with different expected skills and hands-on experience.

• First Responder Awareness level focuses on recognizing a release, calling for help, and initiating protective actions; Appendix E recommends competency demonstrations in the applicable skills of 1910.120(q) and familiarization with the DOT Emergency Response Guidebook and 1910.1201.
• First Responder Operations level adds defensive response skills (containment, control without entry), more hands-on use of the DOT ERG, safety data sheets, CHEMTREC/CANUTEC, and selection and limited use of PPE as described in 1910.120AppE.
• Hazardous Materials Technician training prepares responders to take offensive actions to stop a release: advanced incident analysis, use of technical information systems, full PPE selection and use, decontamination and exposure-zone establishment — all detailed in 1910.120AppE and tied back to the skills in 1910.120(q).

(See 1910.120AppE for recommended course content and 1910.120(q) for required competencies.)

Public-sector emergency responders in states without OSHA-approved state plans are generally covered by the U.S. EPA under 40 CFR 311 rather than by Federal OSHA, and Appendix E notes this equivalence.

• Appendix E states that Federal OSHA standards in 1910.120(q) are directed toward private-sector emergency responders and that "public employees in states without approved state OSHA programs covering hazardous waste operations and emergency response are covered by the U.S. EPA under 40 CFR 311," a regulation virtually identical to 1910.120.
• For employers and trainers, Appendix E recommends using the same training criteria to create unified, community-level training between entities covered by Federal OSHA and those covered by the EPA to ensure consistent response capabilities (1910.120AppE).
• See also OSHA’s letter addressing how state-plan coverage and EPA jurisdiction can affect which standard applies in particular situations, for additional context: "Asbestos remediation protocols" (OSHA interpretation) at https://www.osha.gov/laws-regs/standardinterpretations/2024-11-14.

An Incident Commander must be trained to analyze incidents, plan and implement response actions within available capabilities, and evaluate response progress to ensure objectives are being met safely and effectively.

• Appendix E explains an incident commander "should be occupied by the most senior, appropriately trained individual present" and lists specific capabilities: ability to analyze a hazardous-substance incident to determine magnitude, ability to plan and implement an appropriate response within available personnel and equipment, ability to implement actions to improve incident outcome consistent with local plans and SOPs, and ability to evaluate response progress (1910.120AppE).
• Appendix E also notes an Awareness-level responder may temporarily serve as Incident Commander until a more senior, appropriately trained individual arrives; therefore any person expected to act as Incident Commander must be trained to the level of response they will be directing (1910.120AppE).
• These incident-commander competencies are intended to align with the minimum skills required in 1910.120(q).

Responders must be trained in decontamination procedures and practices appropriate to their response level, including how to set up decontamination zones and perform personnel and equipment decontamination.

• Appendix E specifically lists "Decontamination procedures and practices" as a training topic and recommends that higher-level courses (Technician and Specialist) include principles and practices of personnel and equipment decontamination and establishing decontamination stations and medical surveillance points (1910.120AppE).
• For Operations and Technician levels Appendix E advises hands-on practice in decon procedures, selection and limitations of PPE during decon, and procedures for maintaining contaminated waste handling consistent with local plans and SOPs (1910.120AppE; see also required competencies in 1910.120(q).

Yes — Appendix E recommends hands-on experience with the DOT ERG and other information sources at several responder levels.

• For the First Responder Awareness and Operations levels Appendix E recommends hands-on use of the U.S. Department of Transportation's Emergency Response Guidebook and, at the Operations and Technician levels, hands-on practice with safety data sheets, CHEMTREC/CANUTEC, shipper/manufacturer contacts and electronic databases to support decision-making (1910.120AppE).
• Appendix E also encourages familiarity with 1910.1201 (the OSHA standard addressing specific hazardous substances) where relevant, and with the hazard communication elements in 1910.1200 for interpreting SDS and chemical data.
• Use these practical exercises to ensure responders can rapidly retrieve, interpret, and apply ERG/CHEMTREC and SDS information during an incident.

Yes — training must cover PPE selection, proper use, care, and limitations appropriate to the responder’s role and hazards encountered.

• Appendix E explicitly lists "Use, care, and limitations of personal protective equipment" as a recommended training topic, and multiple course-level descriptions (Operations, Technician, Specialist) require review and practice in selecting and using the appropriate PPE for the response level (1910.120AppE).
• The competencies referenced in 1910.120(q) also require that responders be trained and demonstrate competency in PPE use and limitations for the hazards they may face on-scene.
• Make sure PPE training is hands-on and includes donning/doffing, limitations (e.g., heat stress, chemical permeation), decontamination of gear, and inspection and maintenance procedures as recommended in 1910.120AppE.

Yes — Appendix E recommends awareness of and alignment with consensus standards such as NFPA 472 to ensure responder competencies meet professional benchmarks.

• Appendix E specifically recommends that First Responder Awareness, Operations, Technician, and Specialist training include awareness of the competencies described in the National Fire Protection Association's Standard No. 472, Professional Competence of Responders to Hazardous Materials Incidents (1910.120AppE).
• Employers should use NFPA 472 and similar consensus guidance as supplemental benchmarks when designing training programs that already meet the mandatory elements in 1910.120(q); Appendix E describes this approach as a way to ensure responders possess recognized professional competencies (1910.120AppE).