What Employers Need to Know

The Occupational Safety and Health Administration (OSHA) has announced on May 7, 2026 in the Federal Register a proposal to extend the Office of Management and Budget’s (OMB) approval of the information collection and recordkeeping requirements contained in the Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard, 29 CFR 1910.120. The proposal affects employers involved in hazardous waste cleanup operations, Resource Conservation and Recovery Act (RCRA) corrective actions, treatment, storage and disposal facilities (TSDFs), and hazardous substance emergency response operations.

The announcement highlights OSHA’s continued emphasis on maintaining documentation and training records that demonstrate compliance with HAZWOPER safety requirements. These information collection requirements are considered essential for protecting workers who may be exposed to hazardous substances during cleanup operations and emergency response activities.

What Is the OSHA HAZWOPER Standard?

The HAZWOPER Standard, found in 29 CFR 1910.120, establishes safety and health requirements for workers engaged in hazardous waste operations and emergency response activities. The standard applies to several types of operations, including:

Uncontrolled hazardous waste site cleanup operations
Corrective actions conducted under RCRA
Hazardous waste treatment, storage, and disposal facilities (TSDFs)
Emergency response operations involving hazardous substance releases

HAZWOPER training requirements are designed to ensure workers understand hazardous materials, personal protective equipment (PPE), decontamination procedures, air monitoring, emergency response, and site-specific hazards.

OSHA Requests Public Comments on HAZWOPER Paperwork Requirements

According to OSHA, the agency is requesting public comments concerning the extension of the paperwork and information collection requirements associated with the HAZWOPER Standard. These requirements include records related to employee training, medical surveillance, emergency response planning, site safety and health plans, and other compliance documentation required under OSHA regulations.

OSHA explained that employers use these records to verify workers are properly trained and informed about hazards associated with hazardous waste operations and emergency response activities. The agency also relies on these records during inspections and enforcement activities to evaluate compliance with worker protection requirements.

The agency stated that failure to maintain the required records could significantly affect OSHA’s ability to reduce injuries, illnesses, and fatalities at hazardous waste sites and emergency response incidents.

OSHA Proposes Reduced HAZWOPER Burden Hours

As part of the proposed extension, OSHA announced a reduction in estimated burden hours associated with HAZWOPER information collection requirements. The agency estimates the burden will decrease from 251,002 hours to 232,668 hours, a reduction of 18,334 hours.

OSHA attributed much of the decrease to a decline in the number of RCRA treatment, storage, and disposal cleanup sites nationwide. The agency also estimates a reduction in annual operation and maintenance costs from approximately $3.77 million to $3.41 million.

Despite the reduction, OSHA estimates the HAZWOPER Standard still affects more than 17,000 respondents and generates over 1.38 million responses related to compliance activities and documentation.

Why HAZWOPER Documentation Matters

HAZWOPER documentation requirements play a critical role in workplace safety and regulatory compliance. Employers are responsible for maintaining records demonstrating that workers have received proper training and site-specific instruction before entering hazardous waste sites or participating in emergency response operations.

Typical HAZWOPER records may include:

40-Hour HAZWOPER training certificates
24-Hour HAZWOPER training records
8-Hour HAZWOPER refresher documentation
Medical surveillance records
Air monitoring documentation
Health and Safety Plans (HASPs)
PPE training and fit testing records
Emergency response plans
Decontamination procedures

These records help employers demonstrate compliance during OSHA inspections and provide evidence that workers were trained to recognize and control hazardous exposures.

OSHA Seeks Input From Employers and Industry Stakeholders

OSHA is encouraging employers, safety professionals, training providers, and other stakeholders to submit comments regarding the proposed extension. The agency specifically requested feedback on:

Whether the information collection requirements remain necessary
The accuracy of OSHA’s burden estimates
The quality and usefulness of the information collected
Methods to reduce employer burden through technology or automation

Comments may be submitted electronically through Regulations.gov under OSHA Docket No. OSHA-2011-0862.

Final Thoughts

The proposed extension of OSHA’s HAZWOPER information collection requirements reinforces the agency’s continued focus on worker safety, training documentation, and hazardous waste site compliance. While OSHA is seeking ways to reduce administrative burden, the agency continues to view recordkeeping and training documentation as essential components of protecting workers involved in hazardous waste operations and emergency response activities.

For employers operating under 29 CFR 1910.120, maintaining accurate HAZWOPER training and compliance records remains an important part of meeting OSHA requirements and ensuring worker safety in hazardous environments.

Become HAZWOPER Certified Today!

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