1910.120(q)(6)(i): First Responder Awareness Level
First responders at the awareness level are people likely to witness or discover a hazardous substance release, trained only to start the emergency response by notifying the proper authorities. They must have enough training or experience to show competency in understanding hazardous substances and risks, recognizing and identifying them, knowing their role in the emergency response plan, using the DOT Emergency Response Guidebook, and making notifications.
Key takeaways
- 1910.120(q)(6)(i) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 75 times in the last 3 years, in 75 inspections, with $28,450 in current penalties.
- Most citations: IL (36), NY (32), NJ (5).
- Related part: 1910.120(q) Emergency response to hazardous substance releases (405 citations).
- Free 5-minute toolbox talk for your crew below.
In this article
What this rule covers
29 CFR 1910.120(q)(6)(i) ("First responder awareness level") is one requirement inside 1910.120 Hazardous waste operations and emergency response, an OSHA general industry standard (Part 1910, Subpart H). It includes 6 sub-paragraphs. The official text below is copied word for word from the Electronic Code of Federal Regulations (eCFR). The numbers, injury cases and training on this page show how OSHA enforces it on real job sites.
Official text
(i) First responder awareness level. First responders at the awareness level are individuals who are likely to witness or discover a hazardous substance release and who have been trained to initiate an emergency response sequence by notifying the proper authorities of the release. They would take no further action beyond notifying the authorities of the release. First responders at the awareness level shall have sufficient training or have had sufficient experience to objectively demonstrate competency in the following areas: 75 citations
(A) An understanding of what hazardous substances are, and the risks associated with them in an incident. Open (q)(6)(i)(a) 21 citations
(B) An understanding of the potential outcomes associated with an emergency created when hazardous substances are present.
(C) The ability to recognize the presence of hazardous substances in an emergency.
(D) The ability to identify the hazardous substances, if possible.
(E) An understanding of the role of the first responder awareness individual in the employer's emergency response plan including site security and control and the U.S. Department of Transportation's Emergency Response Guidebook.
(F) The ability to realize the need for additional resources, and to make appropriate notifications to the communication center.
Source: eCFR, text current as of 2026-10-15. Read all of 1910.120.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 3 |
| 2024 | 29 |
| 2025 | 26 |
| 2026 | 17 |
Top states: IL (36), NY (32), NJ (5), TX (1), ME (1)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| TOWNSHIP OF HAMILTON - WATER POLLUTION CONTROL PLANT | HAMILTON, NJ | $7,000 |
| BURLINGTON CITY WATER TREATMENT PLANT | BURLINGTON CITY, NJ | $7,000 |
| PEMBERTON TOWNSHIP MUA | PEMBERTON, NJ | $6,300 |
| TOWNSHIP OF TOMS RIVER DEPARTMENT OF PUBLIC WORKS | TOMS RIVER, NJ | $5,000 |
| WOODCLIFF LAKE DEPARTMENT OF PUBLIC WORKS | WOODCLIFF LAKE, NJ | $2,800 |
Free toolbox talk
A 5-minute crew talk on 1910.120(q)(6)(i), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Training requirements for emergency response medical service (2017-03-31)
- Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters. (2008-11-07)
- Respiratory protection, medical surveillance, and training requirements under HAZWOPER (2002-09-24)
Related parts of this rule
- 1910.120(q) Emergency response to hazardous substance releases 405 citations
- 1910.120(q)(6) Training 143 citations
- 1910.120(q)(8) Refresher training 115 citations
- 1910.120(q)(8)(i) 112 citations
- 1910.120(q)(1) Emergency response plan 67 citations
- 1910.120(q)(2) Elements of an emergency response plan 34 citations
- 1910.120(q)(3) Procedures for handling emergency response 33 citations
- 1910.120(q)(6)(iii) Hazardous materials technician 26 citations
- 1910.120(q)(6)(i)(A) 21 citations
- 1910.120(q)(3)(iv) 14 citations
- 1910.120(q)(6)(ii) First responder operations level 14 citations
- 1910.120(q)(3)(iii) 7 citations
Get your crew competent
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Frequently asked questions
What does an awareness level first responder do?
Initiates an emergency response sequence by notifying the proper authorities and takes no further action.
What must they be able to do?
Understand hazardous substances and risks, recognize their presence, identify them if possible, know their role in the plan, and make proper notifications.
What guidebook must they understand?
The U.S. Department of Transportation's Emergency Response Guidebook.
About this page
Sources
- 29 CFR 1910.120 (eCFR), text current as of 2026-10-15
- U.S. Department of Labor enforcement data: OSHA inspections, citations and accident records, copied nightly; data as of 2026-10-20
3-year window. Federal OSHA only; state-plan rules are not counted. Plain-language text is a summary, not legal advice; the official text controls. Black Belt Safety is not part of OSHA or the Department of Labor.