Safety training ยท OSHA 1910.120
HAZWOPER refresher requirements under OSHA 1910.120
Every worker and supervisor who needed the 24- or 40-hour HAZWOPER course needs eight hours of refresher training every year after it. Emergency responders have their own annual rule.
Who needs the annual refresher
The refresher rule is paragraph (e)(8) of the HAZWOPER standard. Employees covered by (e)(1), and managers and supervisors covered by (e)(4), "shall receive eight hours of refresher training annually" on the topics of their initial training. The refresher may cover a critique of incidents from the past year (29 CFR 1910.120(e)(8)).
Two other groups have annual requirements of their own:
- Treatment, storage, and disposal (TSD) facility workers. Initial training is 24 hours, and refresher training is eight hours annually (1910.120(p)(7)).
- Emergency responders. They must receive annual refresher training "of sufficient content and duration to maintain their competencies," or demonstrate competency in those areas at least yearly. If the employer uses a statement of competency, it must keep a record of the method used (1910.120(q)(8)).
Initial training hours by role
The refresher builds on the initial course, so it helps to know which one each person took (1910.120(e)(3), (e)(4), (q)(6)):
| Role | Minimum initial training |
|---|---|
| General site workers | 40 hours off site, plus 3 days of supervised field experience |
| Workers on site occasionally for a specific limited task | 24 hours, plus 1 day of field experience |
| Workers regularly on site in monitored areas below exposure limits | 24 hours, plus 1 day of field experience |
| Managers and supervisors | 40 hours plus 3 days of field experience (24 hours plus 1 day if they only supervise 24-hour workers), plus at least 8 hours of specialized training |
| Emergency response, operations level | At least 8 hours, or demonstrated competency |
| Hazardous materials technician, specialist, or on-scene incident commander | At least 24 hours |
A worker who took the 24-hour course and later becomes a general site worker, or has to wear a respirator, needs the additional 16 hours and two days that bring them up to the 40-hour level ((e)(3)(iv)).
Certificates
Workers and supervisors who complete the training must be certified, and "a written certificate shall be given to each person so certified." Anyone not certified, and without documented equivalent training, is prohibited from hazardous waste operations ((e)(6)). Equivalent training can replace the initial course, but workers new to a site still need site-specific training before they enter ((e)(9)).
What if the refresher lapses?
The standard does not provide a grace period. OSHA has addressed lapses in interpretation letters and its HAZWOPER FAQ:
- OSHA's intent is that refresher training is completed within 12 months, and an employee who misses one "should attend the next available refresher course" (OSHA interpretation, March 1993).
- The same letter says a two-year absence from hazardous waste work would often not require repeating the course material, while a seven-year absence would clearly call for extensive retraining. Employees do not need to retrain in elements where they can demonstrate competency.
- When a refresher date has lapsed, the need to repeat initial training is decided case by case, and the employee's file should record why the training was delayed (OSHA HAZWOPER FAQ).
- Refresher training can be given in segments, as long as the full eight hours are completed (OSHA HAZWOPER FAQ).
- Some state OSHA plans require the refresher by the exact anniversary of the initial training (OSHA interpretation, March 2007).
In practice, the safest target is the anniversary date itself. That keeps you compliant in states that read the rule strictly, and it avoids a case-by-case judgment call after the fact.
How to track HAZWOPER refreshers
- Record the initial course type (24-hour, 40-hour, TSD, or emergency response level) and its completion date.
- Record each refresher completion date. Next due is the last refresher date plus 12 months.
- If refreshers are split into segments, log the hours of each segment and flag anyone below eight hours as the anniversary approaches.
- Keep every certificate. Note in the file why any refresher was late.
- Set reminders at 90 and 30 days, since eight-hour sessions take planning to fit around field work.
Rules change. This guide summarizes public sources and is not legal advice. Confirm current requirements with OSHA or your state OSHA plan before acting on them.