4.0. TRAINING REQUIREMENTS
The Training Requirements portion of the HASP should cover OSHA training regulations and
training requirements in applicable DOE Orders for personnel working, auditing, touring, and
visiting DOE hazardous waste sites under the cognizance of EM-40. Activities addressed under
these requirements include:
Environmental Restoration (ER) activities regulated under RCRA corrective action
authority and/or CERCLA;
Treatment, Storage, and Disposal (TSD) activities regulated under RCRA; and
Hazardous substance release response activities under Section 303 of the Superfund
Amendments and Reauthorization Act (SARA) of 1986 (Emergency Planning and
Community Right-to-Know Act of 1986, 42 U.S.C. 11003).
Applicable DOE Orders and OSHA regulations should be consulted to ensure full compliance
with all training requirements. However, in some cases, training beyond the requirements of
OSHA is required for certain EM-40 employees and contractor employees (see Appendix D).
The Training chapter has two main objectives. One is to provide the minimum training
requirements (in compliance with 29 CFR 1910.120, DOE Orders, and applicable federal, state,
and local codes and standards) for personnel engaged in the activities listed above. The second is
to recommend personnel not to participate in field activities until appropriately trained.
DOE Order 5480.4 Environmental Protection, Safety, and Health Protection Standards, and
5483.1A Occupational Safety and Health Program for DOE Contractor Employees at
Government-Owned Contractor-Operated Facilities, require both DOE employees and
contractors at DOE-owned contractor-operated facilities to comply with OSHA standards
established in 29 CFR 1910.120. The 29 CFR 1910.120 standards provide regulations to ensure
the safety of employees involved in hazardous waste operations. Subsections (e) and (p) of 29
CFR 1910.120 specify training requirements for all employees who may be exposed to safety or
health hazards at ER sites and RCRA TSD sites respectively. Subsection (q) specifies training
requirements for employees who participate in emergency responses to hazardous substance
releases. This chapter provides the specific training required for EM-40 employees and
contractor employees involved in these types of operations.
EM-40 has adopted, and in some cases exceeded, OSHA training standards for its employees and
contractor employees. All general employees working at ER sites, RCRA TSD sites, and those
responding to hazardous substance releases should receive a minimum of 40 hours of initial
safety and health training and further should receive a minimum of three days (24 hours) of