514 EM 385-1-1 Chapters 1-8

36-3. Personnel Required Qualification/Training.

Training for Environmental Cleanup and Investigation

Workers and supervisors entering the Contamination Reduction Zone (CRZ) and Exclusion Zone (EZ) must complete training as mandated by 29 CFR 1910.120(e)/29 CFR 1926.65(e), with documentation of hazardous substances exposure included in the employee's Personal Health Assessment (PHA).
Initial training requires 40 hours off-site and three days field experience for general site workers, while other workers need 24 hours off-site and one day field experience, under supervision. Supervisors undergo similar training with additional specialized training.
Annual 8-hour refresher training is necessary for all site workers and supervisors.
Trainers must be qualified to instruct employees about the subject matter that is being presented in training.

Note: Trainers must have satisfactorily completed a training program (Train-The-Trainer) for teaching the subjects they are expected to teach, or they shall have the academic credentials and instructional experience necessary for teaching the subjects. Instructors shall demonstrate competent instructional skills and knowledge of the applicable subject matter.

Medical Surveillance Program

Employees entering the CRZ or EZ more than 30 times annually must participate in medical surveillance as per 29 CFR 1910.120(f) or 29 CFR 1926.65(f).
Medical examinations are required before assignment to cleanup operations, annually, upon showing symptoms of exposure, and at employment termination or reassignment.
Certification of medical clearance must be retained and provided upon request, with USACE personnel also adhering to ER 385-1-40 standards.

Roles and Responsibilities in Environmental Cleanup

The USACE Project Safety and Health Manager (PSHM) must have at least three years of experience in occupational health and safety on hazardous waste projects, with specific occupational series requirements based on contaminants involved.
The Contractor Safety and Health Manager (SHM) needs professional certification and three years of experience in environmental cleanup project safety, along with in-depth knowledge of their employer’s health and safety program.
The Site Safety and Health Officer (SSHO) is required to meet training standards, possess experience in SOH requirements on hazardous waste projects, and have skills in exposure monitoring and control measures.

Knowledge Check Choose the best answer for the question.

36-2. What is the requirement for HAZWOPER training for general site workers?

40 hours of on-site hands-on training

24 hours of onsite or off-site OSHA Outreach training

8 hours of initial training and 1 day of field experience

Initial 40 hours off-site and three days field experience

You forgot to answer the question!

EM 385-1-1 Paragraph 36-3.

36-3. Personnel Required Qualification/Training.

a.  Training. At a minimum, train workers entering the CRZ and the EZ at an environmental cleanup and investigation project and their supervisors according to the training requirements of 29 CFR 1910.120(e)/ 29 CFR 1926.65(e).  For USACE personnel performing environmental cleanup operations, document exposure to hazardous substances as part of duties on the employee's PHA.  Specify safety-related training requirements per this paragraph on the employee PHA.  Supervisors and employees must review the PHA annually and when duties change.  See chapter 1 for PHAs.  (36-3.a)

(1)  Initial Training. Initial training must meet the requirements described below:

(a)  General site workers must receive a minimum of 40 hours of instruction off the project site and a minimum of three days actual field experience under the direct supervision of a trained experienced supervisor prior to being assigned to perform their duties.

(b)  Other site workers must receive a minimum of 24 hours of instruction off the project site, and a minimum of one day of actual field experience under the direct supervision of a trained, experienced supervisor.

(c)  Workers with 24 hours of training as described in paragraph 36-3.a(1)(b) of this chapter, and who become general site workers, must have the additional 16 hours of instructions off the project site and two days of on the job training necessary to total the training specified in paragraph 36-3.a(1)(a).

(2)  Supervisors must receive training according to paragraph 36-3.a(1)(a). Supervisory training may be reduced to 24 hours and one day of supervised field experience if they are only responsible for supervising other site workers according to paragraph 36-3.a(1)(b).  All supervisors must have at least eight additional hours of specialized training at the time of job assignment on such topics as, but not limited to, the employer's SOH program and the associated employee training program, PPE program, spill containment program, record keeping requirements, and health hazard monitoring procedure and techniques.

(3)  Refresher Training.  All site workers and supervisors participating in the training program in paragraph 36-3.a(1) must attend an annual 8-hour refresher training that meets the requirements of 29 CFR 1910.120(e)(8) or 29 CFR 1926.65(e)(8).  The refresher training must cover some of the topics from the initial course in a manner relevant to organizational operations, it must address hazards that were encountered the previous year that can serve as training examples of related work, and other relevant safety and health topics.

(4)  Equivalent training is allowed when it can be shown in writing that employee knowledge and experience is equivalent to 40-hour or 24-hour initial and refresher training requirements and objectives.  Equivalent training must be certified in writing by the employer.
    (5)  Instructor Qualifications.  Training instructor qualifications must meet the requirements in 29 CFR 1910.120(e)(5) or 29 CFR 1926.65(e)(5).

(a)  Personnel responsible for planning and teaching the initial and refresher training course must be thoroughly knowledgeable about the subject matter that is being presented in the training.

(b)  Trainers must possess the knowledge and experience to instruct on each of the topics.

(c)  Trainers must retain qualifications for teaching subject matter by regularly attending and participating in formal industrial hygiene or safety related courses, and conferences.

(d)  Trainers must meet the requirements according to ANSI Z490.1 and have successfully completed a "train-the-trainer" program or must otherwise have the academic credentials and instructional experience necessary to teach the topics that directly apply to hazardous waste cleanup and investigation operations.

(6)  Site-Specific Training.  All site workers must receive site-specific training.  Site specific training must cover the Site Safety and Health Plan (SSHP) and how the SSHP applies to the activities that are to be performed.  Site specific training must be provided before onsite work begins and include training topics specific to other chapters of this manual as they apply to the work activities performed, other occupational health standards applicable to the planned site work and operations, and site-specific hazards relevant to onsite contamination.  When relevant, assure that workers are made aware of contaminant-related hazards by use of a site-specific map.

(7)  Computer-Based Interactive Training:  Computer-based interactive training is acceptable provided it meets the following criteria:

(a)  The course covers the requirements in 29 CFR 1910.120(e) or
        29 CFR 1926.65(e).

(b)  Students must be able to ask questions and receive answers in a timely manner from qualified instructors that meet the requirements in 36.a(5).

(c)  Students must participate in 16-hours of hands-on exercises to demonstrate equipment use and procedural proficiency.

(8)  Emergency Response.  Facilities and projects using, storing, or handling hazardous substances and whose employees will be engaged in emergency response operations must receive the appropriate level of training according to 29 CFR 1910.120(q)(6) or 29 CFR 1926.65(q)(6).  All employees who are trained according to this paragraph must receive annual refresher training according to 29 CFR
    1910.120(q)(8) or 29 CFR 1926.65(q)(8).

(9)  Resource Conservation and Recovery Act (RCRA) Treatment Storage and Disposal (TSD).  RCRA TSD facilities and projects that meet the requirements of
    29 CFR 1910.120(a)(1)(iv) or 29 CFR 1926.65(a)(1)(iv) and must provide their workers with training according to 29 CFR 1910.120(p)(7) or 29 CFR 1926.65(p)(7).

(10) Shipping Materials.  All USACE employees who prepare DOT shipping papers (including hazardous waste manifests), label, package and/or mark containers for purposes of transportation must receive DOT and DoD training.  Training must be documented, and employees issued an appointment letter by their commander. Training must meet the requirements of ER 200-2-3 and EP 415-1-266.

b.  Medical Surveillance Program for Environmental Cleanup and Investigation Activities.  Medical surveillance must be performed according to 29 CFR 1910.120(f) or
29 CFR 1926.65(f).  (36-3.b)

(1)  At a minimum, employees who are anticipated to enter the CRZ or EZ more than 30 times a year must be enrolled in medical surveillance.  For employees that enter the CRZ or EZ less than 30 times per year or where the duration is difficult to
    anticipate, enrollment in medical surveillance is the discretion of the employer based on evaluation of the employee’s activities at the project and the need to enter the CRZ or EZ.

(2)  Medical surveillance examination must be provided at the following frequencies:

(a)  Prior to being assigned to hazardous waste cleanup operations.

(b)  Annually while working in the cleanup program.

(d)  At termination of employment or reassignment to work activities outside the environmental cleanup program.

(3)  Retain certification of medical clearance for all personnel and make available only upon request.

(4)  USACE personnel must also comply with the medical surveillance requirements according to ER 385-1-40.  An evaluation must be performed by the employee’s supervisor with support from their SOHO and documented in the employee’s PHA. See chapter 1 for PHAs.

c.  USACE Project Safety and Health Manager (PSHM).  Depending on the primary contaminant of concern involved in the investigation/ cleanup activities, the PSHM must belong to the occupational series specified in ER 385-1-92.  The PSHM
must possess at least three years of experience implementing occupational health and safety protection requirements on hazardous waste investigation and cleanup projects. (36-3.c)

d.  Contractor Safety and Health Manager (SHM).  Depending on the contamination to be impacted by investigation and cleanup activities, the SHM must possess professional certification as a CIH, Certified Health Physicist or Certified Safety Professional and have at least three years of experience implementing occupational health and safety protection requirements at environmental cleanup projects.  The SHM must have in-depth knowledge of the employer’s health and safety program and have access to senior leaders within their organization structure.  (36-3.d)

e.  Site Safety and Health Officer (SSHO).  The SSHO must meet the initial, refresher, and supervisor training according to paragraph 36-3.a of this manual.  The SSHO must also possess the training and experience outlined for a SSHO according to chapter 2 of this manual.  SSHOs experience required by chapter 2 must include at least one year of experience with implementing SOH requirements on hazardous waste investigation and cleanup projects.  The SSHO must have the training and experience to conduct exposure monitoring, sampling, and selecting/adjusting controls.  (36-3.e)