Subpart D
The Training Director must have a minimum of two years of employee education experience. See the Training Curriculum Guidelines in 1926.65AppE which state the Training Director should have at least two years of employee education experience.
Instructors must be judged competent based on documented experience, completion of a relevant "train-the-trainer" program, and an evaluation by the Training Director, and they must maintain competency through continuing education or annual refresher training. The guideline in 1926.65AppE specifies documented experience, successful completion of specific train-the-trainer programs, annual review by the Training Director, and continuing education or an annual refresher course.
Site-specific training means training tailored to the actual operations, hazards, and procedures of a particular job site and must be developed based on a needs assessment before workers begin site activities. The non‑mandatory guidance in 1926.65AppE explains that site-specific programs must be developed from a needs assessment to meet the training requirements in 1926.65(e).
For hands-on activities requiring Level A or Level B personal protective equipment, the suggested maximum student-to-instructor ratio is 5 students per instructor. The guideline in 1926.65AppE recommends a 5:1 ratio for Level A or Level B PPE hands-on training.
The suggested maximum student-to-instructor ratio for hands-on training with Level C or Level D PPE is 10 students per instructor. This recommendation is included in the Training Curriculum Guidelines at 1926.65AppE.
The guideline recommends that general classroom student-to-instructor ratios should not exceed 30 students per instructor. See the Suggested Core Criteria in 1926.65AppE.
A course completion certificate must include the student's name, course title, course date, a statement that the student successfully completed the course, the name and address of the training provider, an individual identification number, and a list of the PPE levels used during the course. These required elements are listed in the Training Curriculum Guidelines at 1926.65AppE.
Training providers should retain records of course dates, attendee names, successful completions, and certificates for a minimum of five years after the date an individual participated. The recordkeeping recommendation appears in 1926.65AppE, which advises keeping these records for at least five years.
If a written test is used alone, there should be a minimum of 50 questions; if used together with a skills demonstration, there should be at least 25 questions. The Training Curriculum Guidelines at 1926.65AppE specify these minimum written-test question counts and require that the test content be relevant to course objectives.
Skills demonstrations must have the tasks chosen and the rating criteria fully documented and approved by the Training Director, and the methods for judging successful completion must be written. The guideline in 1926.65AppE requires the Training Director to document chosen tasks, rating methods, and minimum achievement levels for skills demonstrations.
Course materials should be peer reviewed by technically competent outside reviewers or a standing advisory committee with expertise as applicable in occupational health, industrial hygiene, safety, chemical/environmental engineering, employee education, or emergency response; at least one reviewer should be an employee experienced in the work. The guidance in 1926.65AppE outlines these peer-review criteria.
Course materials should be reviewed and updated at least annually. The Training Curriculum Guidelines in 1926.65AppE recommend an annual review and update of all course materials.
A training program should verify that each student will perform work where chemical exposures are likely and that the student possesses the necessary skills and any required medical clearance before accepting them. The Suggested Core Criteria in 1926.65AppE advise programs to include assurances of job relevance, necessary skills, and a medical clearance policy.
If a wallet-sized laminated card is issued, it should show the student's name, course title, course date, successful completion statement, training provider name and address, the individual certificate identification number, and the PPE levels used in training. The guideline in 1926.65AppE lists these items for certificate cards.
The Training Director should conduct or direct an annual written audit of the training program, document any program modifications to correct deficiencies, and store those documents at the training facility. The Program Quality Control Criteria in 1926.65AppE require an annual audit and documented corrective actions.
A balanced mix of classroom lecture, demonstration, and hands-on training is recommended, with adequate inclusion of hands-on demonstrations and practice to reflect real job tasks. The quality criteria in 1926.65AppE emphasize appropriate inclusion of hands-on, demonstration, and instructional methods.
Peer reviewers should be technically competent with expertise in relevant disciplines such as occupational health, industrial hygiene, safety, chemical/environmental engineering, employee education, or emergency response, and at least one reviewer should be an employee experienced in the target work. These peer-review qualifications are suggested in 1926.65AppE.
The student-acceptance program should confirm that recruits will be involved in work with likely chemical exposures, that they possess required skills with documentation, and that medical clearance policies are followed. The Suggested Core Criteria in 1926.65AppE list these elements for accepting students.
Supervisors’ additional training should be evaluated and documented by proficiency assessment methods that reflect their extra responsibilities, and the Training Director must approve those assessment methods. The guideline in 1926.65AppE requires supervisor assessments to reflect supervisory duties and be acceptable to the Training Director.
The non‑mandatory guidelines in Appendix E can be used to help develop site-specific training programs that meet the requirements of 1926.65(p)(7) and 1926.65(q)(6)-(8), which require specific training for certain hazardous waste and emergency-response operations. Appendix E itself explains it is non-mandatory guidance to assist in meeting the training requirements in 1926.65AppE and the cited regulatory paragraphs.
Under 1926.65(e) the 40‑hour hazardous waste operations course must cover regulatory knowledge, technical knowledge, and technical skills needed to work safely on hazardous waste sites.
These subjects are described in the Suggested Training Curriculum Guidelines in 1926.65 App E, which supplements the requirements in 1926.65(e).
Under 1926.65(e)(8) the annual 8‑hour refresher must review and update employees on relevant topics from the initial training and on new developments affecting site hazards and controls.
Under 1926.65(p) training for employees at treatment, storage, and disposal facilities (TSDFs) must include a detailed review of site safety and health procedures, hazard recognition, and safe work practices specific to the waste streams handled.
Under 1926.65(p)(8) and the emergency action plan requirements in 1910.38, employers must train employees on the site emergency response plan, recognition of emergencies, evacuation routes, duties and lines of authority, and first‑aid procedures.
Under 1926.65 employers should document that employees received required training and are competent for their duties; 1926.65 App E recommends issuing dated cards or certificates and keeping training records.
Under 1926.65(e) on‑site pre‑assignment training must give employees information specific to their work area before initial assignment, including hazard communication, locations of hazards, detection methods, and protective measures.
Under 1910.134 and the guidance in 1926.65 App E, respirator training must include selection, fit testing, use limitations, maintenance, and communication methods while wearing respirators.
Under 1926.65 App E, supervisor training should cover the same core topics as worker training but with additional supervisory responsibilities, and the App E recommends that supervisors first demonstrate competency with the 40‑hour course content.
According to 1926.65 App E and 1926.65(e), a substantial portion of training must be hands‑on: App E recommends at least one‑third of the program be practical exercises and section 20(r) recommends at least 8 hours of hands‑on training.
Under 1910.147 lockout/tagout procedures must be taught whenever employees will service, maintain, or otherwise interact with equipment where unexpected energization could cause injury; 1926.65 App E also recommends including LOTO in hazardous waste training.
Under 1910.1200 hazard communication training must teach employees how to read and use labels and safety data sheets (SDSs), the employer’s written program, and methods to detect releases of hazardous chemicals; 1926.65 App E highlights this as essential on‑site training.
Under 1910.146 and 1926.65 App E, confined space training must teach employees hazard recognition, permit procedures, monitoring requirements, rescue and communication procedures, and special PPE needed for entry.
Under 1926.65(f) and 1926.65 App E, medical surveillance training must explain the components of the site medical program, signs and symptoms of exposure, and procedures for reporting health concerns.
Under 1926.65(p)(3) TSDF training must include a review of the employer’s medical surveillance program elements and recognition of signs and symptoms of overexposure.
Per 1926.65(e)(8) and 1926.65 App E, refresher training must be provided annually (every 12 months) and should be conducted by qualified training providers.
Under 1926.65 App E, employees must demonstrate competency in both knowledge and hands‑on skills relevant to their job duties before participating in or supervising field activities.
Under 1926.65(p)(4) and 1926.65 App E, decontamination training must cover personnel, clothing, and equipment decontamination procedures, including hands‑on practice with level‑appropriate ensembles.
Under 1910.38 and 1926.65 App E, training must teach the site emergency action plan elements, including evacuation procedures, alarm systems, personnel roles, escape routes, and methods for accounting for employees.
According to 1926.65 App E, a training evaluation tool should test both knowledge and hands‑on skills relevant to the course content and be reviewed and updated regularly to stay current with site changes and new regulations.
Per 1926.65 App E and respirator requirements in 1910.134, training must teach methods of communication that are effective when employees wear respiratory protection.
Yes — employers must provide training before an employee’s first assignment and it must cover the listed topics in the appendix. The training topics include the emergency response plan and first aid; the employer’s hazardous waste handling and spill containment procedures (including the location of spill kits and who is trained to respond); the hazardous communication program; the medical surveillance program and signs or symptoms of exposure; decontamination procedures; the employer’s training program and responsible parties; the PPE program and selection based on site hazards; and all relevant site‑specific safety and health procedures. See 1926.65 App E for the full list of required topics.
Yes — hazardous communication training must meet OSHA’s Hazard Communication Standard requirements. The appendix explicitly requires training on the employer’s hazardous communication program that meets 29 CFR 1910.1200. See 1926.65 App E which directs employers to include HazCom training as part of the site curriculum.
Include other relevant exposures and physical hazards when appropriate — the appendix recommends covering biological and radiological exposures, fire and explosion hazards, thermal hazards, and physical hazards such as electrical hazards, powered equipment, lockout/tagout, motor vehicle hazards, and walking‑working surface hazards. Employers should tailor training to the site‑specific risks present. See 1926.65 App E and the related discussion about applying these topics in emergency response settings.
The Awareness level focuses on recognition and safe initial actions, while the Operations level adds hands‑on competency to respond defensively. Specifically, First Responder Awareness training includes recognizing hazardous substances, performing the applicable skills of 29 CFR 1926.65(q), and familiarization with tools such as the DOT Emergency Response Guidebook and 1926.60. First Responder Operations training requires demonstration of competency in those skills, hands‑on use of information sources (SDSs, CHEMTREC/CANUTEC, ERG), selection and use of PPE, and practice of decontamination and defensive containment techniques. See 1926.65 App E and the topics referenced in 1926.65(q)(6).
Train employees on the employer’s decontamination program and the specific procedures they will use — decontamination training should teach the written decontamination procedures, practical decontamination techniques for personnel and equipment, setup of decon stations, sequencing to avoid cross‑contamination, and proper disposal of contaminated materials. The appendix lists decontamination as a required topic and as a suggested practical skill for responders at operations and technician levels. See 1926.65 App E and the responder course recommendations in 1926.65(q)(6).
The appendix is non‑mandatory but OSHA recommends that public sector responders outside Federal OSHA jurisdiction consider these criteria — the guidance is not an enforceable standard, yet it is intended to help public and private responders develop compatible, community‑level training programs. States with OSHA‑approved plans must have regulations at least as effective as Federal OSHA; where Federal OSHA does not apply to certain public employees, similar EPA or State rules may cover them. See 1926.65 App E for the recommendation and the discussion of State plan coverage in the appendix.
Technician and specialist training should include hands‑on use of response tools and information sources such as the DOT Emergency Response Guidebook, manufacturer SDSs, CHEMTREC/CANUTEC, shipper/manufacturer contacts, databases and response models, and response equipment for plugging or patching containers. Training should also practice incident analysis, selecting defensive or offensive strategies, PPE selection, establishing exposure zones, and organizing multi‑team responses. These recommendations appear repeatedly for Hazardous Materials Technician and Specialist curricula in 1926.65 App E and reference familiarity with 1926.60.
Train employees on the exact site‑specific procedures and the names of personnel and alternates who are responsible for safety and response — include the employer’s hazardous waste handling procedures, location of spill kits and equipment, who is trained to respond, decontamination steps, where to find the emergency plan, and which individuals or alternates have response duties. The appendix explicitly requires covering these site‑specific procedures and naming responsible personnel as part of initial training. See 1926.65 App E.
Employees must be trained to recognize signs and symptoms of exposure to the hazardous substances relevant to their site and be instructed on the employer’s medical surveillance program. Training should explain which exposures trigger medical monitoring, the signs and symptoms to watch for (including known synergistic effects), how and when to report symptoms, and what medical surveillance procedures are in place. This is a required training topic in the appendix; see 1926.65 App E and the responder training topics in 1926.65(q)(6).
The incident commander must be trained and able to lead the response safely and effectively, including analyzing the incident, planning and implementing a suitable response, evaluating progress, and adjusting the response as needed. See 1926.65AppE.
The guidance also says the incident commander position should be filled by the most senior, appropriately trained individual present, but a first responder at the awareness level may temporarily assume the role until a more senior, properly trained person arrives. For the broader training framework that applies to emergency response duties, see 1926.65(q).