EPA Hazardous Waste Training
EPA’s primary threshold for completing employee training is that your facility be a large quantity generator (LQG) of hazardous waste (1,000 kilograms / 2,200 pounds / ~ 300 gallons) in a single calendar month. Once your facility is a LQG, the training program must be created and directed by a person who has been trained in hazardous waste management procedures. (Same qualifications for the person doing the training.) You are then required to identify each employee who is involved with hazardous waste and record their name, job title, job description, their skills or qualifications, and duties. Next, record the type and amount of both introductory and continuing training to be given to each of the employees. Of course, EPA requires you to record when all training has been completed. Typical employees needing hazardous waste training are environmental coordinators, process operators, drum handlers, emergency coordinators, waste storage inspectors, response team members, and manifest preparers.
Hazardous waste initial training must be completed within six months of the date of hire or an assignment to a position involved with hazardous waste. After initial training, the employer must provide refresher training on an annual basis. Class contact hours are not specified, but are related to the employee’s involvement with the overall waste program and the facility contingency plan.
All training records for current personnel must be kept until your facility closes, and for former employees, the records must be kept for three years from the date of termination.
CTI recommends that if your facility is a LQG, it is best to create a Waste Management Plan, which identifies and consolidates not only your employee training program, but also all of your other hazardous waste requirements within a single, easy-to-follow book format.
OSHA HAZWOPER Emergency Response Training
Although originally created to regulate worker safety at cleanups of
hazardous waste sites, OSHA’s Hazardous Waste Operations and Emergency
Response (HAZWOPER) standard was expanded to cover employees at waste
treatment facilities and those working in the private and public sector
as well. The focus of this article regards emergency responders within
private industry (29 CFR 1910.120 (q)).
HAZWOPER is embraced by many industrial facilities that wish to have
their own employees respond to spills of hazardous materials (i.e.,
hazardous raw materials and wastes or hazmat). Beyond minor spill
responses defined and allowed within OSHA’s Hazard Communication
Standard, however, most facilities do not have a clear understanding of
the various levels of training OSHA requires for response to hazmat
spills. Add-in the obligations of EPA’s LQG regulations for hazardous
waste emergencies, and one can realize the confusion that exists about
who and how to train under HAZWOPER.
The lowest level of emergency training is Evacuation. No spill response
is allowed. OSHA does not specify a specific number of training hours
for evacuation, only that the facility have a written emergency plan
(see 29 CFR 1910.38) and that employees are trained upon the development
of the plan, whenever changes are made to the plan, or when an
employee’s responsibilities change.
The next level of emergency training is Awareness Level. Again, no spill
response is allowed by employees at this level, as they have been
trained only to recognize hazmat, understand the threats of a hazmat
spill, who to notify within the chain of command for appropriate
emergency response, and other requirements under the facility emergency
plan. OSHA does not specify a specific number of training hours for this
level, only that competency is reached in the required syllabus to which
the employer certifies. Annual refreshers are required by the standard
to maintain competency.
The third level of emergency training is Operations Level. This employee
is allowed to undertake defensive maneuvers to a spill and has had at
least eight (8) hours of OSHA-specified training. Their function is to
contain, prevent spreading, and prevent exposure. Training topics
include the Awareness Level syllabus and are expanded into PPE and
decontamination, among others, to which the employer certifies
competency. An annual refresher is required to maintain or demonstrate
competency for Operations Level responders, but OSHA has not designated
a specific number of contact hours.
The fourth level of emergency training is Technician Level. This
employee is trained to stop a release at its source and has had at least
twenty-four (24) hours of OSHA-specified training. The course topics
include the Operations Level syllabus and are expanded into emergency
plan implementation, specialized PPE, and the Incident Command System,
among others. Again, the employer certifies employee competency for this
level of training. An annual refresher is required to maintain or
demonstrate competency for Technician Level responders, but OSHA has not
designated a specific number of contact hours.
One requirement frequently overlooked in the engagement of the HAZWOPER
standard above the Awareness Level is the need to also have a staff
person trained within the Incident Command System (ICS). The on scene
Incident Commander assumes control for emergencies at the Operations and
Technician levels, and typically has eight (8) additional hours of
training in the ICS and other topics, in addition to the minimum 24
hours of Operations Level training. So, if your facility is using
Operations or Technician level within your emergency plan, be sure that
you also have someone trained in Incident Command and certify to their
competency at this level. An annual refresher is required to maintain or
demonstrate competency in the ICS, but OSHA has not designated a
specific number of contact hours
Finally, remember to recognize the overlap in EPA’s hazardous waste
training and OSHA’s HAZWOPER standards. If your hazardous waste
Contingency Plan requires your employees to respond to a spill of
hazardous waste, be sure that those individuals have the appropriate
level of training to meet the requirements of HAZWOPER!
DOT Hazardous Material Safety
The Department of Transportation (DOT) has specific employee training
requirements to ensure the safety of any employee associated with the
shipment or receipt of hazardous materials or wastes. This separate and
wide-ranging standard includes all employees that work with hazmat in
shipping/receiving, manifest and bill-of-lading preparation, purchasing,
forklift operation, emergency response, drivers, and supervision.
Training must include hazard awareness, transportation-related
terminology, documents, labels, placards, and markings, container
selection and use, emergency response (HAZWOPER again!), and security
planning, among others. Wherever applicable, however, previous and
relevant portions of EPA and/or OSHA hazmat training already performed
and documented do not need to be duplicated within DOT hazmat safety
training.
DOT initial hazmat training must take place within ninety (90) days of
employment or job assignment, and it must be refreshed every three (3)
years. DOT also requires that trainees be tested by appropriate means to
determine competency with the material.
DOT training records requirements are much like EPA’s for employees
regarding details, yet also include a certification regarding the
training and testing. Recordkeeping is inclusive of the three (3)
previous years and must be retained for as long as the employee is
employed, or retained for ninety (90) days after employment ends.
If applicable for your facility, CTI recommends that EPA hazardous waste
training and DOT hazmat safety training be conducted fairly close to one
another, as your specific facility subject matter is used in both
classes and will provide for a better understanding over the long run.
|
|
