OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at https://www.osha.gov.

March 10, 1999

Mr. Daniel Burke
Safety Coordinator
St. John's Mercy Medical Center
615 S. New Ballas Rd.
St. Louis, Mo. 63141

Dear Mr. Burke:

This is a response to your January 29, 1999, letter about emergency response training in accordance with 29 CFR 1910.120(q)(6), Hazardous Waste Operations and Emergency Response. You specifically ask if hospital physicians and nurses working in the Emergency Department need any level of emergency response training if they are treating patients who have been contaminated with chemicals. Your letter indicates that you expect that chemically-contaminated patients would be largely decontaminated by field emergency personnel and that your staff will primarily treat their injuries.

OSHA's Hazardous Waste and Emergency Response standard (HAZWOPER) requires that workers be trained to perform their anticipated job duties without endangering themselves or others. To determine the level and type of training your workers need, you must consider the hazards in your community and what capabilities your personnel need to respond to those hazards. You should make your determination based on worst-case scenarios. If your personnel are expected to provide limited decontamination services in order to attend to medical problems, they must be trained to the first responder operations level with emphasis on the use of PPE and decontamination procedures. This level of emergency response training is described in 29 CFR 1910.120(q)(6)(ii); additional guidance about the content of this training is available in HAZWOPER's Appendix E. Hospitals may develop in-house training or they may send personnel to a standard first responder operations level course, then provide additional training in decontamination and PPE as needed. HAZWOPER requires the employer to certify that workers have the training and competencies listed in (q)(6)(ii). The standard also requires annual refresher training or demonstration of competency, as described in (q)(8).

A hospital that expects its employees to handle emergencies involving hazardous substances also needs to prepare a written emergency response plan. Employees and affiliated personnel expected to be involved in an emergency response including physicians, nurses, maintenance workers, and other ancillary staff should be (1) familiar with how the hospital intends to respond to hazardous substance incidents, (2) trained in the appropriate use of PPE, and (3) required to participate in scheduled drills.

OSHA Publication 3152, Hospitals and Community Emergency Response - What You Need to Know (1997), is an excellent reference on this topic. It discusses the range of emergency response planning and training a hospital needs to undertake, depending on its role in community emergency response. A copy of this publication is enclosed. I hope that this information is helpful. If you need further assistance, please contact OSHA's Office of Health Compliance Assistance at (202) 693-2190.

Sincerely,

Richard E. Fairfax
Director
Directorate of Compliance Programs

S