Training Requirements

DOE-EM-STD-5503-94

4.0. TRAINING REQUIREMENTS

4.1. BACKGROUND

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.

4.2. GENERAL

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

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