Clarification of OSHA’s HAZWOPER Standard (1910.120) as it applies to clearing and re-railing train cars after derailments

Question 1: Do derailment response operations fall under paragraph (q) of the HAZWOPER standard?
Question 2: Are the members of a crew responsible only for clearing and/or re-railing train cars during an emergency response operation considered skilled support personnel? Is there a required level of training for personnel who direct skilled support personnel?
Question 3: Are earth moving and collecting operations to control the spread of released hazardous substances, control exposures, and protect the environment during rail car clearing or re-railing operations considered actions that can be performed by skilled support personnel?
Question 4: Must members of HAZMAT teams who take aggressive actions to stop the release of hazardous substances meet the training requirements for hazardous materials technicians?
Question 5: Does the HAZWOPER standard’s 40-hour training requirement apply on train derailments if there is a need for post-emergency clean-up operations?

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