A biohazard remediation company asked OSHA whether employees who clean up blood from crime or accident scenes must be trained under the HAZWOPER standard. OSHA's answer splits the work into two scenarios.
For emergency and post-emergency response operations involving hazardous substance releases, HAZWOPER training applies. Workers in offensive or aggressive roles need hazardous materials technician level training (24 hours), while defensive, non-aggressive roles need first responder operations level training (8 hours) under 29 CFR 1910.120(q)(6) and (q)(11). Post-emergency cleanup workers who remove contaminated materials must meet the requirements in 1910.120(b)-(o): 24 or 40 hours of off-site training plus 1 to 3 days of supervised field experience for general site cleanup, with managers and supervisors needing eight additional hours of specialized training.
When a biohazard company performs cleanup without a declared emergency, HAZWOPER does not apply. Instead, the employer must comply with other applicable standards, including bloodborne pathogens (29 CFR 1910.1030), PPE, respiratory protection, and hazard communication. OSHA emphasized that HAZWOPER is performance-oriented, so employers must assess the hazard exposure scenarios their workers can reasonably anticipate and train accordingly.