Health and safety training for hazardous waste site activities at Oak Ridge National Laboratory: Implementation of OSHA 29 CFR 1910.120(e)

Among the requirements set forth by the interim final rule, 29 CFR Part 1910.120, promulgated by the Occupational Safety and Health Administration (OSHA) in response to the Superfund Amendments and Reauthorization Act of 1986 (SARA), are specific provisions for health and safety training of employees involved in hazardous waste operations. These training provisions require a minimum of 40 hours of initial instruction off the site for employees involved in corrective operations and cleanup activities at hazardous waste sites. A less detailed training requirement of 24 hours is specified for employees working in more routine treatment, storage, and disposal activities. Managers and supervisors who are directly responsible for or who supervise employees engaged in hazardous waste operations must complete 8 additional hours of training related to management of hazardous waste site activities. Consistent with the intent of 29 CFR 1910.120, a training program has been developed at Oak Ridge National Laboratory (ORNL) to comply with the need to protect the safety and health of hazardous waste workers. All hourly requirements specified in the interim final rule are met by a comprehensive program structure involving three stages of training. This paper will outline and discuss the content of each of these stages of the program. The involvement of various ORNL organizations in facilitating the training will be highlighted. Implementation strategies will be discussed as well as progress made to date