1910.120(q)(6)(ii): First Responder Operations Level Training
First responders at the operations level respond defensively to releases to protect nearby people, property or the environment without trying to stop the release. They must have at least eight hours of training or proven experience in hazard and risk assessment, PPE, hazmat terms, basic control and containment, decontamination and procedures, and the employer must certify it.
Key takeaways
- 1910.120(q)(6)(ii) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 14 times in the last 3 years, in 14 inspections, with $61,171 in current penalties.
- Most citations: OH (2), NY (2), NJ (2).
- 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)(ii) ("First responder operations 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
(ii) First responder operations level. First responders at the operations level are individuals who respond to releases or potential releases of hazardous substances as part of the initial response to the site for the purpose of protecting nearby persons, property, or the environment from the effects of the release. They are trained to respond in a defensive fashion without actually trying to stop the release. Their function is to contain the release from a safe distance, keep it from spreading, and prevent exposures. First responders at the operational level shall have received at least eight hours of training or have had sufficient experience to objectively demonstrate competency in the following areas in addition to those listed for the awareness level and the employer shall so certify: 14 citations
(A) Knowledge of the basic hazard and risk assessment techniques. 1 citations
(B) Know how to select and use proper personal protective equipment provided to the first responder operational level.
(C) An understanding of basic hazardous materials terms.
(D) Know how to perform basic control, containment and/or confinement operations within the capabilities of the resources and personal protective equipment available with their unit.
(E) Know how to implement basic decontamination procedures.
(F) An understanding of the relevant standard operating procedures and termination procedures.
Source: eCFR, text current as of 2026-10-15. Read all of 1910.120.
Where and how often it was cited
| Year | Citations |
|---|---|
| 2023 | 2 |
| 2024 | 2 |
| 2025 | 8 |
| 2026 | 2 |
Top states: OH (2), NY (2), NJ (2), IL (2), WI (1)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| CONSTELLATION ENERGY GENERATION, LLC | BYRON, IL | $16,550 |
| 3M COMPANY | PRAIRIE DU CHIEN, WI | $12,278 |
| PHILLIPS 66 PIPELINE LLC | GOLDSMITH, TX | $11,585 |
| WEST DEPTFORD FIRE DEPARTMENT/ | THOROFARE, NJ | $7,000 |
| TOWN OF KILLINGTON | KILLINGTON, VT | $5,958 |
Free toolbox talk
A 5-minute crew talk on 1910.120(q)(6)(ii), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters. (2008-11-07)
- Clarification of HAZWOPER training requirements as they apply to an employee of the town of Windsor, VT. (2007-12-04)
- Requirements for annual refresher training under OSHA's HAZWOPER standard. (2007-07-25)
- Criteria for and training of the hospital Safety Officer per the requirements of the HAZWOPER standard and as discussed in the "Best Practices for Hospital-based First Receivers" guidance document. (2005-06-23)
- Process operators' training requirements to take limited action in stopping an emergency release; role in an incident command system. (2004-02-14)
- Firefighter training requirements to respond to emergency releases, or potential emergency releases, of hazardous substance. (2003-08-01)
- Requirements for emergency response and planning under the Process Safety Management Standard. (2003-06-24)
- Training and PPE requirements for hospital staff that decontaminate victims/patients. (2002-12-02)
- Respiratory protection, medical surveillance, and training requirements under HAZWOPER (2002-09-24)
- Training and HAZWOPER. (1991-12-30)
- Application of 1910.120 to home heating oil. (1991-10-11)
- Training requirements for firefighters. (1991-10-02)
- First responders, training, hazardous materials technician, etc. (1990-11-09)
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)(6)(i) First responder awareness level 75 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)(3)(iii) 7 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
Trainers and suppliers: feature your business on this rule for $25/month.
Frequently asked questions
How much training do operations level responders need?
At least eight hours, or sufficient experience to objectively demonstrate competency, in addition to awareness level topics.
Do they try to stop the release?
No. They respond defensively, containing it from a safe distance.
Who certifies their competency?
The employer.
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.