How does DOT training relate to training required by EPA or OSHA?
The U.S. Environmental Protection Agency (EPA) requires training for persons managing hazardous wastes at waste generator or treatment, storage, and disposal facilities (TSDFs). The Occupational Safety and Health Administration (OSHA) has two general chemical hazard training rules. The Hazard Communication Standard (sometimes referred to as “employees’ right to know”) requires general workplace chemical hazard training as well as chemical labeling and material safety data sheets. The Hazardous Waste Operations Standard (HWOS or HAZWOPER) requires specific training for persons involved in site cleanup, permitted TSDF operations, or chemical emergency response outside their ordinary workplace. DOT, EPA, and OSHA requirements are distinct and separate. It is generally good management practice to combine training into a single session where agency requirements are similar. However, you must assure that you comply with each rule individually.