Training Demo. RCRA Hazardous Waste Training

Transcription

1 Training Demo RCRA Hazardous Waste Training

2 TRAINING DEMO LION TECHNOLOGY INC. RCRA Hazardous Waste Training Demo Objectives Identify training requirements for employees operating under The satellite accumulation rules The 180-day accumulation rules ( small quantity generators ) The 90-day accumulation rules ( large quantity generators ) Universal waste rules Identify training requirements for employees that sign hazardous waste manifests EPA s Hazardous Waste Rules Specific set of rules for storing, moving, treating, and disposing of materials that are defined as hazardous waste Variety of storage options for hazardous wastes: Satellite accumulation 180-day accumulation 90-day accumulation Universal waste accumulation Each storage option has own requirements for training, Lafayette, NJ Page 1

3 Satellite Accumulation Satellite accumulation occurs when employees accumulate hazardous waste: At or near the point of generation Where the waste initially accumulates Without complying with the 180-day or 90-day regulations Both small and large quantity generators can do satellite accumulation [40 CFR (c)] Training Requirements for Employees in Satellite Accumulation Areas No specific requirements in the hazardous waste regulations to train satellite employees Employers must still make certain that each employee doing accumulation under this option knows his or her responsibilities in order to avoid noncompliance with rules Training would be a good management practice Satellite Employees and DOT Training Requirements If responsible for preparing packages of hazardous waste (hazardous material) for shipment, meet the DOT definition of a hazmat employee and need DOT training. Regulated activities would include: Selecting packages Filling packages Closing packages Applying DOT labels to packages [49 CFR 172, Subpart H], Lafayette, NJ Page 2

4 Satellite Employees and OSHA Training Requirements LION May be subject to numerous OSHA standards and TECHNOLOGY INC. need training under these standards. Examples would include: Handling flammable liquids or other hazardous RCRA chemicals Hazardous subject Waste to OSHA s Training Hazard Demo Communication Standard (29 CFR ) Responding to emergencies involving releases of hazardous substances under OSHA s Hazardous Waste Operations and Emergency Response (HAZWOPER) Standard (29 CFR ) Satellite Employees and 180-Day and 90-Day Objectives Training Requirements If Identify move waste training from requirements satellite accumulation for employees areas operating into central under 180-day or 90-day storage areas The are satellite no longer accumulation just satellite rules employees, but The are also 180-day 180-day accumulation or 90-day rules employees ( small Must quantity be trained generators ) under the applicable rules The 90-day accumulation rules ( large quantity generators ) Universal waste rules Identify training requirements for employees that sign hazardous waste manifests 180-Day Accumulation Area Training EPA s Hazardous Waste Rules Requirements Employees Specific set must of rules be thoroughly for storing, moving, familiar with waste treating, handling disposing and emergency of materials procedures. that are defined as hazardous waste Variety of storage options for hazardous wastes: Satellite accumulation 180-day accumulation 90-day accumulation Universal waste accumulation Each storage option has own requirements for [40 training CFR (d)(5)(iii)], Lafayette, NJ Page 3

5 180-Day Accumulation Area Training Topics LION No specific topics TECHNOLOGY required to INC. be covered during training Train employees how to do their jobs and what they need to do during emergencies RCRA Hazardous Waste Training Demo Training Frequency for Objectives Employees in 180-Day Areas No Identify specific training requirements requirements to retrain for employees operating under If job functions change, rules change, or as The time satellite passes accumulation and employees rules begin to forget The 180-day training, accumulation they will no longer rules ( small be thoroughly quantity generators ) familiar with proper procedures The 90-day accumulation rules ( large quantity generators ) As good management practice, employees should Universal be periodically waste rules retrained at Identify whatever training interval requirements is determined for employees to be that appropriate sign hazardous waste manifests Training Documentation for EPA s Hazardous Waste Rules Employees in 180-Day Areas No Specific specific set requirements of rules for storing, document moving, training treating, and disposing of materials that are defined as hazardous waste Variety As good of storage management options practice, for hazardous training wastes: should be documented in such a manner as Satellite to be able accumulation to demonstrate that the required 180-day training accumulation was provided 90-day accumulation Universal waste accumulation Each storage option has own requirements for training, Lafayette, NJ Page 4

6 90-Day Accumulation Training Requirements 90-Day generators required to follow the same training standard that interim status Treatment, Storage, and Disposal Facilities (TSDFs) follow at 40 CFR [40 CFR (a)(4)] 90-Day Accumulation Training Requirements Must provide all personnel with training regarding job-specific waste management procedures relevant to their positions Personnel basically means anyone who could cause noncompliance with the hazardous waste regulations Training must be directed by someone who has comprehensive training in hazardous waste management procedures [40 CFR (a)(1) and (2)] Specific Training Topics for Employees in 90-Day Areas Training must cover (as applicable to each person s job responsibilities) the following: Use, inspection, repair of emergency and monitoring equipment Automatic waste feed cut-off systems Communications and alarm systems Response to fires or explosions Response to groundwater contamination incidents Shutdown of operations, Lafayette, NJ Page 5

7 Timing of Training for Employees in 90-Day Areas Employees must receive initial training within six months of becoming personnel Until trained, must be supervised Employees must receive annual retraining [40 CFR (b) and (c)] What Does Annual Training Mean? U.S. EPA states annual means annual Not explicitly required to retrain by anniversary date or every calendar year Training should generally be within 12 months or so from previous training date States operating own RCRA programs may explicitly require training to be provided once every calendar year or by the anniversary date of the previous training Training Documentation for Employees in 90-Day Areas Must create a written training plan that includes: The job title for each position at the facility related to hazardous waste management A written job description for each position listed above The name of the employee filling each job A written description of the type and amount of introductory and continuing training Documentation that the required training or job experience has been given to and completed by facility personnel26 [40 CFR (d)], Lafayette, NJ Page 6

8 Training Documentation for Employees in 90-Day Areas Training records must be kept: Until closure for all current personnel For at least three years from the date the employee last worked at the facility for former personnel [40 CFR (e)] Training Requirements for Employees Handling Universal Waste Employees that handle universal waste (e.g. waste lamps and batteries) need to be trained regarding: Proper handling procedures Emergency procedures Training should be appropriate for universal wastes at facility No specific requirements to create training records or conduct periodic retraining Good management practices26 [40 CFR and ] Training for Employees Who Sign Manifests When signing a manifest, certify that the shipment is in complete compliance with all DOT rules for classifying, naming, packaging, labeling, etc. Employees who sign hazardous waste manifests must receive DOT training IN ADDITION to hazardous waste training, Lafayette, NJ Page 7

9 Thank You Contact us with any questions about our products or services: Call: Lafayette, NJ Page 8

10 RCRA HAZARDOUS WASTE TRAINING References, Lafayette, NJ Page 9

11 Training Requirements for Hazardous Waste Employees, continued TRAINING REQUIREMENTS FOR HAZARDOUS WASTE EMPLOYEES 180-Day Training Requirements [40 CFR (d)(5)(iii)] (iii) The generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies. familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: (i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; (ii) Key parameters for automatic waste feed cut-off systems; (iii) Communications or alarm systems; 90-Day Training Requirements [40 CFR ] Personnel training. Editor s Note: (a)(4) requires thatgenerators w ho are accum ulating hazardous w aste also com ply with (a)(1) Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility s compliance with the requirements of this part. The owner or operator must ensure that this program includes all the elements described in the document required under paragraph (d)(3) of this section. (2) This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. (3) At a minimum, the training program must be designed to ensure that facility personnel are able to respond effectively to emergencies by (iv) Response to fires or explosions; (v) Response to ground-water contamination incidents; and (vi) Shutdown of operations. (4) For facility employees that receive emergency response training pursuant to Occupational Safety and Health Administration (OSHA) regulations 29 CFR (p)(8) and (q), the facility is not required to provide separate emergency response training pursuant to this section, provided that the overall facility training meets all the requirements of this section. (b) Facility personnel must successfully complete the program required in paragraph (a) of this section within six months after the effective date of these regulations or six months after the date of their employment or assignment to a facility, or to a new position at a facility, whichever is later. Employees hired after the effective date of these regulations must not work in unsupervised positions until they have completed the training requirements of paragraph (a) of this section. (c) Facility personnel must take part in an annual review of the initial training required in paragraph (a) of this section. (d) The owner or operator must maintain the following documents and records at the facility:, Lafayette, NJ Page 10

12 Training Requirements for Hazardous Waste Employees, continued (1) The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; (2) A written job description for each position listed under paragraph (d)(1) of this Section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position; (e) Training records on current personnel must be kept until closure of the facility. Training records on former employees must be kept for at least three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company. [Source Note: At 71 FR 16908, April 4, 2006, effective May 4, 2006, added (a)(4). At 71 FR 40274, July 14, 2006, amended (b).] (3) A written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under paragraph (d)(1) of this section; (4) Records that document that the training or job experience required under paragraphs (a), (b), and (c) of this section has been given to, and completed by, facility personnel., Lafayette, NJ Page 11