HAZWOPER Hands-on Training

Discussions with U.S. OSHA Directorate of Enforcement

The purpose of this webpage is to document conversations we had with the U.S. Occupational Safety and Health Administration (OSHA) Directorate of Enforcement. The content on this page(s) should be treated as informational as we do not speak for OSHA nor any other regulator(s). Also, we do not list the name(s) of OSHA officials we had discussions with unless we have their permission. We encourage you to call U.S. OSHA at 202.693.2100 or visit their website should you have any questions regarding Hazardous Waste Operations and Emergency Response (HAZWOPER) hands-on training. You can always call or email us as well.

Throughout our professional careers, we have been fortunate to engage in communication with the OSHA Directorate of Enforcement Programs in Washington, D.C., These discussions centered on HAZWOPER hands-on training and the practical aspects of this training. Specifically, the two training courses discussed were the 24 hour HAZWOPER and 40 hour HAZWOPER found in 29 CFR 1910.120(e). OSHA has set forth precise requirements for the content and execution of this training, as outlined in OSHA regulation 29 CFR 1910.120 Appendix E (Non-Mandatory Guidelines), which indicates that site-specific hands-on training must complement HAZWOPER courses. Although Appendix E is not a mandatory regulation, OSHA maintains clear expectations regarding its implementation.

What is OSHA’s Core Message on HAZWOPER Hands-on Training?

The core message conveyed to OSHA field enforcement offices is that individuals undergoing HAZWOPER training must receive site-specific hands on instruction using the exact model and type of Personal Protective Equipment (PPE) they will use in their respective roles. It has been emphasized that generic classroom or open enrollment hands on training on respirators, for instance, does not align with OSHA’s expectations. In a classroom setting that accommodates students from different employers, the likelihood of the instructor possessing the precise PPE relevant to each worker’s job and each site is slim. Also, site-specific training is required for a contaminated site such as reviewing the health and safety plan with employees, conducting drills for emergency procedures, evacuations, specific hazards, etc. Therefore, it is imperative that individuals receive hands-on training with the actual equipment and PPE they will use, a requirement that cannot be fulfilled through open enrollment class instruction, online training, simulators or videos. Instead, employers must conduct site-specific hands-on training using the actual equipment their employees will encounter.

Generic Hands-on Training vs Site-Specific Hands-on Training

Not all hands-on training is created equal. It is crucial to distinguish between generic hands-on training offered in public seminars and site-specific hands-on training. We have already mentioned this earlier in this article but the importance of understanding the difference between generic and site-specific hands-on training is critical. For example, if your employees attended a public 24 hour HAZWOPER or 40 hour HAZWOPER (29 CFR 1910.120(e)) training seminar and relied solely on this training for hands-on experience (assuming it was conducted), it’s important to note that this does not meet the OSHA standard. The standard requires site-specific training. Generic hands-on training can be done but often times employees have a false sense of compliance thinking this is all that is required. If the only hands-on training you took was generic and not site-specific, you would be considered out of compliance subject to violations and fines. OSHA holds the employer accountable for ensuring site-specific hands-on training is provided, not the training provider.

The goal in requiring a hands-on component is to ensure that each worker has practical exposure to the conditions, materials, and decision-making processes they will face on an actual hazardous waste site. The standard mandates that trainees complete at least three days of field experience under the direct supervision of someone who is both experienced and properly trained—typically a supervisor or site manager who has the knowledge and skills to be a HAZWOPER instructor.

During this period, trainees are expected to demonstrate competency in critical safety procedures such as proper use of PPE, site control and hazard recognition, decontamination procedures, and safe handling of tools and materials. Unlike classroom instruction, the field experience immerses workers in realistic scenarios—whether it’s practicing donning and doffing chemical-resistant suits, simulating spill containment, or setting up decontamination lines. These exercises reinforce what was learned during the initial instruction phase and bridge the gap between knowledge and action.

Examples of Hands-on Exercises

Although each program should be tailored to site conditions, there are common practical activities that OSHA expects to be included in the hands-on portion. Workers should practice donning, fitting, and maintaining respiratory protection and chemical-resistant clothing to ensure complete understanding of protective equipment use. They should engage in decontamination drills, setting up contamination reduction corridors, sequencing the removal of protective gear, and properly handling contaminated tools and waste.

Other exercises may include safe operation of site-specific machinery, spill containment simulations, and mock emergency responses such as chemical releases or system failures. These scenarios help workers understand how to communicate under pressure, coordinate with emergency personnel, and execute site evacuation routes when necessary. By working through these drills in realistic conditions, trainees build muscle memory and situational awareness that classroom learning alone cannot provide.

Employer Responsibility

What is an Acceptable HAZWOPER Training Method?

In essence, OSHA’s core message aligns with what competent employers have been doing all along, as the HAZWOPER training standard is performance-based. We continue to provide the academic portion of the training online, with the employer taking responsibility for training employees on the exact make and model of equipment they will use in their roles. In our numerous interactions with employers, it appears that many are already following this practice.

Notably, HAZWOPER certification is a shared responsibility between the instructor and the employer, a principle that has been consistently upheld. Given the employer’s primary role in safeguarding their employees’ health and safety, their direct knowledge of specific job tasks and site conditions positions them as the natural candidates to administer the site-specific hands-on training.

We take pride in collaborating with some of the most diligent Health and Safety managers in the industry, recognizing that their top priority is the safety of their workforce. We are grateful for the trust many companies and individuals have placed in us for their HAZWOPER training.needs. The clarification regarding hands-on training requirements is a welcome development in our ongoing commitment to maintaining high safety standards. OSHACode™ provides OSHA compliant 40 hour HAZWOPER, 24 hour HAZWOPER and the HAZWOPER 8 hour refresher training courses.

Why In-House Hands-On Training Works

A common question among employers and safety managers is whether this three-day field component must be conducted by an external training provider or if it can be managed internally. OSHA’s position is clear: employers may conduct the hands-on portion in-house, provided that it is led by a qualified supervisor and that the training content and documentation meet the agency’s standards. When done properly, in-house hands-on and field training can strengthen safety performance, reduce costs, and align training with site-specific hazards more effectively than generic exercises.

There are significant advantages to conducting field training within the organization itself. Perhaps the most important is site-specific relevance. Every hazardous waste operation is different—each with unique materials, exposure pathways, and emergency response protocols. Conducting training on-site allows workers to practice using the same equipment, tools, and PPE that they will rely on in actual operations. It ensures familiarity with your facility’s layout, its decontamination stations, and its response procedures, creating a direct link between training and daily work.

From a logistical standpoint, in-house training offers greater flexibility and cost efficiency. Instead of coordinating travel or waiting for external classes to align with your production schedule, employers can integrate training into regular shifts or downtime. The reduced travel expenses and time savings can be significant, particularly for companies managing large teams or multiple worksites.

In addition, employees tend to be more comfortable and engaged in familiar surroundings. Practicing with their own supervisors and peers often encourages questions, experimentation, and teamwork. This environment fosters a stronger safety culture—one built not on fear of compliance, but on confidence and competence.

Hands-on Training Student to Instructor Ratio

29 CFR 1910.120 Appendix E

The student to instructor ratio should not exceed 30 students per instructor for a 40 hour HAZWOPER training or a 24 hour HAZWOPER training class. Site-specific hands-on activity requiring the use of actual PPE should have the following student to instructor ratios. For Level C or Level D PPE the ratio should not exceed 10 students per instructor. For Level A or Level B PPE the ratio should not exceed 5 students per instructor.