HAZWOPER guide · 2 min read · Updated 2026-11-03

HAZWOPER Compliance Checklist for Employers

Use this checklist to review your HAZWOPER program. It follows the structure of 29 CFR 1910.120 and points to the guides for each topic. It isn't legal advice; your site's hazards and contracts decide what you actually need.

1. Scope

  • Have you decided which of your operations fall under 1910.120(a)(1): cleanup, corrective action, TSDF, or emergency response?
  • If employees won't respond to releases, do you have an emergency action plan (1910.38) that tells them to evacuate?
  • For California and other state-plan states, have you checked the state rule? (Cal/OSHA)

2. Written programs

3. Training

  • Each worker's level matches their duties (40, 24 or 8 hour)
  • Supervisors have the extra 8 hours
  • Field experience is documented (3 days or 1 day)
  • Annual 8-hour refreshers are tracked and up to date (refresher rules)
  • Emergency responders are trained to their level (response levels)
  • Trainers are qualified (1910.120(e)(5)). Consider train-the-trainer for in-house instructors
  • Written certificates are on file for every worker
  • Spanish-language training for workers who need it (40 Hour Spanish)

4. Medical surveillance

  • Workers exposed above PELs 30+ days a year, respirator users 30+ days a year and HAZMAT team members are enrolled
  • Baseline, annual, termination and post-exposure exams are scheduled
  • Physician's written opinions are on file; records kept for employment plus 30 years

See medical surveillance.

5. Monitoring and PPE

  • Air monitoring plan with action levels; instruments bump tested and calibrated
  • PPE levels chosen from hazard data and written into the plan
  • Respirator fit tests done every year
  • Heat stress controls for Level A and B work

6. Common OSHA citations to avoid

  • No written safety and health program or site plan
  • Untrained or under-trained employees, or no annual refresher
  • No emergency response plan for employers whose staff respond to releases
  • No medical surveillance for respirator users or HAZMAT teams
  • Missing training certificates

Training a whole crew

Add every course your team needs to the cart and check out once, with a seat count for each course. For large groups or purchase orders, call or email our team.

Frequently asked questions

What are the most common HAZWOPER violations?

Lack of a written safety and health program, missing site-specific plans, untrained or under-trained employees, missed annual refreshers, no emergency response plan, and no medical surveillance for respirator users and HAZMAT teams.

Who can train employees in HAZWOPER?

Trainers must be qualified to instruct by having completed a training program for the subjects they teach, or by academic credentials and instructional experience, under 1910.120(e)(5).

What HAZWOPER records must employers keep?

Training certificates for every employee, documentation of field experience and refreshers, medical surveillance records (employment plus 30 years), and exposure monitoring records.

This guide summarizes federal OSHA, Cal/OSHA and EPA rules for training purposes. It is not legal advice. Always check the current regulation text and your site safety and health plan.

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