1910.120(q)(6): Training for Emergency Responders
Employers must base emergency response training on each responder's duties and function. New responders must be trained before they take part in actual emergency operations, and employees who are or may be expected to respond must be trained at their level, starting with first responder awareness level, which covers recognizing hazardous substances and notifying authorities.
Key takeaways
- 1910.120(q)(6) is part of OSHA's general industry standards (29 CFR Part 1910, Subpart H).
- OSHA cited it 143 times in the last 3 years, in 140 inspections, with $278,213 in current penalties.
- Most citations: IL (44), NY (34), NJ (10).
- 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) ("Training") is one requirement inside 1910.120 Hazardous waste operations and emergency response, an OSHA general industry standard (Part 1910, Subpart H). It includes 41 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
(6) Training. Training shall be based on the duties and function to be performed by each responder of an emergency response organization. The skill and knowledge levels required for all new responders, those hired after the effective date of this standard, shall be conveyed to them through training before they are permitted to take part in actual emergency operations on an incident. Employees who participate, or are expected to participate, in emergency response, shall be given training in accordance with the following paragraphs: 143 citations
(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: Open (q)(6)(i) 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.
(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: Open (q)(6)(ii) 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.
(iii) Hazardous materials technician. Hazardous materials technicians are individuals who respond to releases or potential releases for the purpose of stopping the release. They assume a more aggressive role than a first responder at the operations level in that they will approach the point of release in order to plug, patch or otherwise stop the release of a hazardous substance. Hazardous materials technicians shall have received at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: Open (q)(6)(iii) 26 citations
(A) Know how to implement the employer's emergency response plan.
(B) Know the classification, identification and verification of known and unknown materials by using field survey instruments and equipment.
(C) Be able to function within an assigned role in the Incident Command System.
(D) Know how to select and use proper specialized chemical personal protective equipment provided to the hazardous materials technician. Open (q)(6)(iii)(d) 1 citations
(E) Understand hazard and risk assessment techniques.
(F) Be able to perform advance control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available with the unit.
(G) Understand and implement decontamination procedures.
(H) Understand termination procedures.
(I) Understand basic chemical and toxicological terminology and behavior.
(iv) Hazardous materials specialist. Hazardous materials specialists are individuals who respond with and provide support to hazardous materials technicians. Their duties parallel those of the hazardous materials technician, however, those duties require a more directed or specific knowledge of the various substances they may be called upon to contain. The hazardous materials specialist would also act as the site liaison with Federal, state, local and other government authorities in regards to site activities. Hazardous materials specialists shall have received at least 24 hours of training equal to the technician level and in addition have competency in the following areas and the employer shall so certify:
(A) Know how to implement the local emergency response plan.
(B) Understand classification, identification and verification of known and unknown materials by using advanced survey instruments and equipment.
(C) Know of the state emergency response plan.
(D) Be able to select and use proper specialized chemical personal protective equipment provided to the hazardous materials specialist.
(E) Understand in-depth hazard and risk techniques.
(F) Be able to perform specialized control, containment, and/or confinement operations within the capabilities of the resources and personal protective equipment available.
(G) Be able to determine and implement decontamination procedures.
(H) Have the ability to develop a site safety and control plan.
(I) Understand chemical, radiological and toxicological terminology and behavior.
(v) On scene incident commander. Incident commanders, who will assume control of the incident scene beyond the first responder awareness level, shall receive at least 24 hours of training equal to the first responder operations level and in addition have competency in the following areas and the employer shall so certify: Open (q)(6)(v) 5 citations
(A) Know and be able to implement the employer's incident command system. 1 citations
(B) Know how to implement the employer's emergency response plan.
(C) Know and understand the hazards and risks associated with employees working in chemical protective clothing.
(D) Know how to implement the local emergency response plan.
(E) Know of the state emergency response plan and of the Federal Regional Response Team.
(F) Know and understand the importance of decontamination 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 | 7 |
| 2024 | 50 |
| 2025 | 51 |
| 2026 | 35 |
Top states: IL (44), NY (34), NJ (10), OH (9), VA (7)
Largest penalties
| Employer | Location | Penalty for this rule |
|---|---|---|
| BWC TERMINALS, LLC | HOUSTON, TX | $33,100 |
| LEWISTOWN VALLEY ENTERPRISES, INC. | TAMAQUA, PA | $16,550 |
| WOODLAND PULP, LLC | BAILEYVILLE, ME | $16,550 |
| CONSTELLATION ENERGY GENERATION, LLC | BYRON, IL | $16,550 |
| PURPOSE BUILT BRANDS | GURNEE, IL | $15,000 |
Free toolbox talk
A 5-minute crew talk on 1910.120(q)(6), plus alerts when this rule changes. Free.
OSHA interpretation letters
- Training requirements for on scene incident commanders in OSHA's HAZWOPER standard (2024-02-29)
- Clarification of the HAZWOPER standard to employees engaged in the cleanup of blood from crimes or trauma incidents (2020-12-15)
- Cleanup of blood from crime or accident scenes and HAZWOPER training requirements (2019-09-06)
- Training requirements for emergency response medical service (2017-03-31)
- Applicability of HAZWOPER to the clearing and rerailing of train cars after derailment situations. (2012-03-14)
- Training requirements for fire investigators. (2009-01-06)
- Clarification of CPL 02-02-073 as it pertains to emergency response training for firefighters. (2008-11-07)
- Use of a "hybrid" course to meet training requirements for both a general site worker and a hazardous materials technician under HAZWOPER. (2008-04-28)
- 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)
- Whether firefighters trained to the HAZWOPER awareness level can respond to emergency releases of hazardous substances. (2007-03-14)
- 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)
- Application of absorbent pads for spill control;hazardous waste site cleanup training does not qualify worker as hazardous materials technician. (2003-02-26)
- 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)
- Hazwoper training for security guards; documentation necessary when training varies. (2001-05-18)
- Emergency response training necessary for hospital physicians/nurses that may treat contaminated patients. (1999-03-10)
- Training requirements for emergency and post-emergency response to marine-based oil spills. (1993-04-16)
- Training and HAZWOPER. (1991-12-30)
- Application of 1910.120 to home heating oil. (1991-10-11)
- Training requirements for firefighters. (1991-10-02)
- Employee evacuation in the event of imminent Natural Phenomenon. (1991-06-26)
Related parts of this rule
- 1910.120(q) Emergency response to hazardous substance releases 405 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)(6)(ii) First responder operations level 14 citations
- 1910.120(q)(3)(iii) 7 citations
Get your crew competent
Trainers on Black Belt Safety: Marc Harvey, Dana Reyes
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Frequently asked questions
When must a new emergency responder be trained?
Before they are permitted to take part in actual emergency operations on an incident.
What does an awareness level first responder do?
They are likely to witness or discover a release and are trained to start the emergency response by notifying the proper authorities, taking no further action.
What is the training based on?
The duties and function to be performed by each responder of the emergency response organization.
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.
