Training requirements for on scene incident commanders in OSHA’s HAZWOPER standard

OSHA clarifies HAZWOPER training requirements for on-scene Incident Commanders and other positions in the Incident Command System (ICS) and whether previous non-HAZWOPER training can be credited toward the training required by HAZWOPER for Incident Commanders.  Here are the four (4) questions OSHA discusses:

1. Is it OSHA’s intent that Incident Commanders be 24-hour HAZWOPER trained, irrespective of their actual working location during an incident, e.g., if they are located off-scene, outside of the contaminated area or far from the incident, and are never actually exposed to the site hazards?
2. Please provide more clarity on training for Supervisors/Managers and Incident Command System (ICS) Group Supervisors and guidance on how to distinguish which personnel supporting an off-scene National Incident Management System (NIMS) ICS command structure are required to undergo 24-hour HAZWOPER Training.
3. Can previous non-HAZWOPER-specific training be counted as credit toward the 24-hour HAZWOPER training requirement for Incident Commanders, if all required training elements and competencies specified by the OSHA HAZWOPER Standard are achieved?
4. Does OSHA agree that if all other required training topics and competencies are completed (e.g., an additional 8 hours of specific training or instruction to cover the specific HAZWOPER elements and competencies), then together, the requirement for 24-hour HAZWOPER training has been met?