There are not very many OSHA standards that call out the “trainer qualification(s)” for those who teach on the subject matter, but the HAZWOPER standard does. When a trainer uses the phrase HAZWOPER over and over but does not recognize this is an acronymn that stands for Hazardous Waste Operations and Emergency Response, has no emergency response background, and/or has never received training themseleves on the subject matters that make up a 24-hour/40-hour course content… WE HAVE A SERIOUS PROBLEM!
This week the DOJ announced an OSHA 10-hr Trainer was selling fake 10-hr cards for $200/each and he had sold well over 100 cards. This is a FRAUD on both ends (the seller and buyer) and everyone needs to be held accountable. But some of these “fly-by-night” training outfits commit a fraud on many businesses when they claim to be qualified to conduct emergency response training for the business and they “can do it for much less”. OSHA’s HAZWOPER standard, 1910.120(q)(7), clear states (emphasis by me):
1910.120(q)(7) Trainers. Trainers who teach any of the above training subjects shall have satisfactorily completed a training course for teaching the subjects they are expected to teach, such as the courses offered by the U.S. National Fire Academy, or they shall have the training and/or academic credentials AND instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter of the courses they are to teach.
Now it is up to the business to quantify these requirements and/or qualify your emergency response trainers, but this is one area where the “low bidder” may not be the person(s) you want to hire to train your team to respond to IDLH atmopsheres! It is down right scary how many times a responder wants to “correct me” on something that is as fundamental as Lower Explosive Limits or IDLH to only learn they had been taught INCORRECTLY – and I mean out of this world wrong!
We are not all experienced emergency responders, but just a simple request for the instructor(s) credentials and some quick verifications can save a lot of time and money and more importanly ensure your team is receiving proper training. Lastly, if you’re a PSM/RMP facility, the company that does this training for your site may very well need to be qualified under your contractor safety program.