HAZWOPER Training Requirements

COMDTINST 6260.31A

body and evidence recovery following aircraft crashes; floating drums; skimming,

pumping, salvage or lightering operations; and waterborne oil cleanup operations.

Nearly all Coast Guard operations that involve or could potentially involve

hazardous substances can be classified under the emergency response sections in

terms of the HAZWOPER standard.

(2) Post-emergency response is that portion of an emergency response performed "after

the immediate threat of a release has been stabilized or eliminated and cleanup of the

site has begun." For spill response missions, this phase would occur when the

products are in a secure container with no compromised structural integrity--floating

bladders, barges, drums, and roll-off containers on shore--or when "stranded" on

shore with no reasonable expectation to be re-released into the environment by wave

or storm effects, essentially above the high tide mark or storm surge boundary.

Floating oil is not considered stabilized, even if contained within a boom. Thus

booming and skimming operations are not considered post-emergency. Examples of

non-marine safety operations in the post-emergency phase would be post-SAR

salvage and repair operations conducted at the pier or battery recovery operations

conducted by Aids to Navigation personnel.

(3) For incidents that may transition from an emergency response to a post-emergency

response, the personnel who start out in the emergency phase and continue working

into the post-emergency phase need only to have the training required for emergency

response. For example, a ship goes aground and spills 500 gallons of fuel into the

water. A crew deploys a boom around the vessel to corral the oil, and employs a

skimmer to remove it. Despite these efforts, approximately 150 gallons end up on

the beach. The crew then picks up shovels and manually picks up about 100 gallons

of oil. That evening, there's a high high tide and strong winds which blow the

remaining 50 gallons well above the surf-line. At that point the response goes from

emergency to post emergency. The crew who initially picked up oil with shovels had

emergency phase training. As long as the same crew is used, they do not require post

emergency training prior to picking up the remaining oil. Since very few U. S. Coast

Guard personnel, with the exception of specially trained and equipped personnel, e.g.

Strike Teams, initially go into an event during the post emergency phase, meeting the

training requirements for a preceding emergency phase renders personnel "trained"

for any subsequent post-emergency operations as well.

d. HAZWOPER Training Requirements. Enclosure (1) summarizes training required by the

reference (a). Although this instruction specifically addresses training requirements for

Coast Guard emergency response operations, post-emergency requirements are also

included for informational purposes. The training levels are defined by three elements:

hours, competencies and field experience.

(1) The hours requirements are defined in terms of the minimum number of hours of

training needed to satisfy a particular training level. The content provided during

this mandatory period of training is at the discretion of the employer. The

HAZWOPER regulations provide some non-mandatory suggestions in their