COMDTINST 6260.31A
appendices; however, ultimately, it is up to the employer to ensure that employees
are trained in recognition, evaluation, and control of workplace hazards that could
reasonably be expected during the course of their involvement with an operation.
(2) The competency requirements are performance criteria that the worker must be able
to meet. These competencies are separate from and in addition to the specific
training hours previously described. Column (1) of enclosure (1) cites the applicable
HAZWOPER standard section for these competencies. These are also more
completely described in enclosure (2).
(3) Field experience refers to experience at an actual or simulated response that is
supervised. It is only required for post-emergency training levels.
The training requirements listed in enclosure (1) are non-recurring, with the exception of
annual refresher training. That is, a member needs to receive the level of non-refresher
training outlined for their response role only once to satisfy the standard. Refresher
training is intended to ensure that the responder is able to maintain a minimum
knowledge base and competency level.
e. HAZWOPER Trainers. The regulations recommend that trainers who provide any level
of HAZWOPER training shall have satisfactorily completed a training course for trainers.
Although this may be an expectation, it is not mandatory. The regulations actually
specify a performance standard: qualified trainers need to have training or academic
credentials and instructional experience necessary to demonstrate good instructional skills
and a good command of the subject matter of the courses they are teaching. Whether or
not a train-the-trainer course has been attended, the employer still determines whether a
trainer is sufficiently qualified to provide training to other employees. OSHA, as well as
providers of train-the-trainer courses, cannot "certify" trainers; only the employer can.
5. REQUIREMENTS.
a. Personnel Affected:
(1) Coast Guard personnel assigned to units engaged in emergency response operations
which have or have the potential to have releases of hazardous materials are required
to meet the training requirements outlined in this instruction. As noted previously,
these would certainly include personnel responding to oil and chemical spills but
would also include personnel engaged in search and rescue operations, law
enforcement activities, and port security. This does not include personnel who are
engaged in the treatment, storage, or disposal of hazardous wastes regulated by 40
CFR 264-5 pursuant to the Resource Conservation and Recovery Act (RCRA), for
personnel that respond to spills at a TSDF, or for personnel that may neutralize or
control incidental releases of a hazardous substance in their immediate work area.
Although personnel engaged in post-emergency operations must meet the training
requirements of reference (a), the requirements outlined by this instruction are not
applicable to those operations. For such post-emergency activities, the cognizant
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