HAZMAT or HAZWOPER Training: Which One Fits Your Job?

Written by Staff Writer | Edited by Michael Purser

When you work around hazardous materials, you probably hear the terms HAZMAT and HAZWOPER pretty often. They can sound alike to the uninitiated, but they are not the same thing. Mixing them up can leave your team out of regulatory compliance and may wind up costing you money if you pay for training they don't need.

This guide shows you how to tell the two programs apart.

What Separates the Two?

The activities being performed and the agencies that oversee those activities are the main factors that separate these two programs. HAZWOPER comes from the Occupational Safety and Health Administration (OSHA) and protects workers who clean up or respond to hazardous releases. HAZMAT transportation standards come from the U.S. Department of Transportation (DOT). These rules apply to people who prepare or move hazardous materials.

The two rules also differ in safety training needs. OSHA's rule, found in 29 CFR 1910.120, sets a minimum number of hours based on an employee’s role and requires a refresher course each year. The DOT rule, located in 49 CFR 172.704, lists topics that must be covered but does not specify hours. It requires retraining at least once every three years.

Both tackle hazardous materials safety. But when people talk about HAZWOPER vs. HAZMAT, they are really talking about two separate sets of rules with two different goals.

OSHA's HAZWOPER Standard: What Does It Cover?

HAZWOPER stands for Hazardous Waste Operations and Emergency Response. This OSHA standard applies to five types of work:

• Cleanup at uncontrolled hazardous waste sites designated by a government body
• Corrective actions at sites covered by the Resource Conservation and Recovery Act (RCRA)
• Voluntary cleanups at recognized hazardous waste sites
• Treatment, storage and disposal facilities under RCRA
• Emergency response to releases of hazardous substances, no matter where they happen

It doesn't matter if the site’s a factory, a warehouse or a farm supply store or who owns the property. No matter the organization involved, work can fall under this rule. It doesn't need to be near a cleanup zone, either. Any qualifying activity must observe these rules. You can learn more on our HAZWOPER training page.

How Much Safety Instruction Is Required?

If your work falls into one of those five categories, your next step toward compliance is figuring out how much instruction each worker requires. The standard sets these minimums for cleanup crews:

• General site workers, such as laborers and equipment operators, need 40 hours of off-site instruction plus three days of supervised field experience.
• Occasional site visitors and workers in areas monitored below exposure limits only need 24 hours of instruction plus one day of field experience.
• Anyone who has completed either initial course must complete eight hours of refresher training every year.

Emergency responders follow separate levels:

• Awareness level requires no specific training. This is limited to workers who may witness or identify a hazardous release, but have no direct exposure to regulated materials.
• Operations level, or workers whose primary responsibility is to protect persons, property and the environment from a HAZMAT release, must receive at least eight hours of appropriate training.
• HAZMAT technicians, specialists and incident commanders must all complete at least 24 hours of initial training.

Qualifying emergency personnel must also complete the mandatory yearly refresher.

What Does DOT HAZMAT Cover?

HAZMAT transportation rules cover anyone whose job affects the safe shipping of hazardous materials. Workers like shipping clerks, warehouse loaders, forklift operators, drivers and people who fill out shipping papers can all fall under this umbrella.

Under 49 CFR 172.704, each of these employees must receive the following training:

• General awareness of the HAZMAT rules
• Function-specific instruction for their exact tasks, such as marking packages
• Safety lessons on emergency response information and how to avoid accidents
• Security awareness of transportation risks
• In-depth security instruction if the company is required to have a security plan

Workers who work in support roles only require a basic awareness course. Professionals directly involved in the transportation process need a more comprehensive education.

New hires may work under direct supervision for up to 90 days before they finish training. After initial instruction, retraining is required at least once every three years.

Notably, drivers seeking an H or X endorsement for a CDL must complete DOT HAZMAT training to qualify for either hazardous materials endorsement (HME). These extra letters allow drivers of commercial vehicles to transport regulated materials.

Does One Certification Count for the Other?

No. One type of training won't substitute for the other. For example, your HAZWOPER class won't teach you how to label a drum for shipping. And your DOT class isn't going to teach you how to safely enter an area where a chemical spill occurred.

That doesn't mean there isn't any overlap, though. Instruction given to meet OSHA standards, including 1910.120, may count toward DOT requirements. But this is only true when lessons cover the same required topics. Function-specific and security topics almost always need their own specific training.

Where Does the Line Get Blurry?

A cleanup technician needs HAZWOPER, and a driver needs DOT HAZMAT training. That’s pretty straightforward. But what about situations that are less clear cut?

Incidental Spills vs. Emergency Releases

While spills always require proper cleanup procedures, not every spill calls for implementing emergency response rules. If workers in the immediate area or maintenance staff can absorb, neutralize or control a spill on the spot, it's not an emergency. In a 2017 interpretation letter, OSHA explained that there is no threshold of spill size or concentration that makes a release a HAZWOPER emergency.

Instead, regulators expect employers to decide on a case-by-case basis. Once a decision is reached, employers must write their criteria into an emergency action plan. If a release goes beyond what nearby workers can safely handle, responders require formal response education.

Same Substance, Different Requirements

Different workers interact with substances, even hazardous ones, in specific ways. For instance, one role might require workers to load drums of solvent onto trucks and fill out shipping papers. The other might be on a team that responds when a drum of that solvent ruptures in the yard.

Both workers are handling the same substance, but in unique ways. Since the loader is part of the transportation process, they need DOT instruction. On the other hand, the responder needs HAZWOPER training. It’s a different approach to a different set of hazards.

When Job Duties Change

Changing jobs means changing job requirements. If a warehouse worker joins the spill team, they now need emergency response training. On the other hand, a site worker who starts signing waste manifests becomes a HAZMAT employee under DOT jurisdiction and must complete training on the corresponding standards. Supervisors must review each person's compliance requirements with every change in job functions.

The exact moment that oversight swaps from HAZWOPER to DOT is when the dangerous goods are packaged and handed off for shipping. Not when the engines roar and the wheels roll, either. Packaging, labeling and loading are part of the transportation process, which is DOT territory.

Jobs That Need Both

While most jobs fall into one category or the other, some roles come with overlapping duties. These include hazardous waste haulers, environmental cleanup crew staff shipping waste off site and industrial response contractors who have to answer to both agencies. If your team cleans up waste and also prepares it for transport, you should expect to train in both areas.

What Are Common Misunderstandings About These Rules?

A few points often cause confusion even for seasoned professionals.

Approval and certification. OSHA does not approve or certify courses. It sets the standard, and employers are responsible for choosing courses that meet it.

Renewal dates. The two programs run on different schedules, so a worker with both credentials has two dates to track. A missed HAZWOPER refresher puts that worker out of compliance even if their DOT credentials are still current.

Who takes the 40-hour course? Not everyone who works near chemicals needs 40 hours of training. Workers who face occasional exposure may only require 24 hours, and many plant or warehouse employees don't fall under the standard at all.

Understanding Your Online HAZWOPER Course Options

Online courses can cover the classroom portion of HAZWOPER instruction. But online instruction can’t replace the mandatory on-site supervised experience. All courses should cover the topics found in 29 CFR 1910.120. But the best courses will let students learn at their own pace, which is where OSHA Education Center really shines.

Our 40-hour HAZWOPER course is designed for general site workers with regular exposure, while the 24-hour course is better for lower-exposure roles. Both are fully online, so you can work on them whenever and wherever is best for you.

Our 8-hour annual refresher helps previously certified workers keep their credentials current. Check out our guide to emergency response options for explanations about the responder levels.

Keep Your Whole Team Compliant

If you manage larger teams, our business compliance solutions can help you get the most out of your safety education. We offer volume discounts and tools to track each employee's progress from one convenient dashboard.