 |
 |
||
 |
 |
 |
|
      
|
||||
|
Job Environmental Assessments BY BRIAN KARNOFSKY Don’t change that light bulb until you know what to do with it. This is a policy that can and should be applied to every part of every facility. Does your staff know that most light bulbs become universal waste (a type of hazardous waste) when they burn out, and anyone who changes a light bulb at work must be informed of how to manage the bulb properly?Hazardous waste not only includes wastes that are toxic, reactive, corrosive or ignitable, they also include four lengthy lists of wastes that virtually every facility generates. Moreover, most personnel who manage these wastes must receive annual training. Of the 500 employees at your site, only a few of them manage the waste and need hazardous waste training: the EHS manager and the personnel who run the hazardous waste accumulation point, right? Wrong. Do they all need training? What training is required and how often? The answer depends on the environmental aspects of each job function. You are probably familiar with job safety assessments used to determine what personal protective equipment is required for job functions where employees are exposed to occupational hazards. A ‘job environmental assessment’ is needed to determine what environmental training is required. For this assessment, evaluate each job to determine what wastes are generated, how the wastes are accumulated, how and where they are moved on-site, and how they are prepared for off-site shipment. Armed with this data, you can determine who must be trained and who should be trained as a best management practice. The scope of hazardous waste training required for an employee depends not only on whether or not they work with hazardous waste, but where they work. The ‘where’ could be either a satellite accumulation area or an accumulation area. What’s the difference? The ‘satellite’ is located at or near where the waste was generated and can have a maximum of 55 gallons (or 1 quart of acute waste). The accumulation area has no volume or location limit, but does have a time limit of 90 days for large generators and 180 days for small quantity generators. Training is not required for employees who work only in the satellite accumulation area. However, if an employee were to move waste from the satellite to the accumulation area, they must be trained. Even though training isn’t mandatory for personnel that solely work at satellites, it’s still a good idea. Otherwise, how would these personnel know, for example, what wastes are hazardous, how to ensure the containers are always closed, and ensure that they are managed properly? Annual hazardous waste training is required for personnel that work in 90-day accumulation areas at sites classified as large quantity generators (facilities that generate > 1000 kg/month). According to 40 CFR 265.16, this training must teach these employees how to perform their duties in a way that ensures the facility’s compliance with the applicable regulations. It must cover the site’s waste management procedures, emergency response procedures, and contingency plan. For sites classified as small quantity generators (facilities that generate 100 to 1000 kg/month), the federal regulations don’t use the word training, but they come very close. Personnel at these facilities must be thoroughly familiar with waste handling and emergency procedures that apply to their job functions. Training is the best way to ensure an employee is familiar with these procedures. If you generate hazardous waste, you will need to eventually ship it off-site. When you prepare the shipment, you must ensure that your hazardous waste containers meet Dept. of Transportation requirements, and you must list the waste on a hazardous waste manifest. Because all hazardous wastes that must be listed on a manifest are also DOT hazardous materials, anyone who prepares or signs the manifest, selects the shipping containers, fills the containers, or seals them for transportation must receive DOT hazardous materials training at least every three years. DOT hazardous material training is required not only for personnel that prepare hazardous waste shipments, it is also required for shippers and carriers of other hazardous materials, including those that are explosive, compressed gas, flammable, toxic, radioactive, corrosives, and many miscellaneous materials and consumer commodities. Both EPA and DOT require you to document your training. Records of hazardous waste training must include the trainee’s name, job description, training description, and evidence of training. EPA requires that your job descriptions include the skills, education, or other qualifications, and duties of facility personnel assigned to each position involving the management of hazardous waste. These records must be kept on file until your facility closes, or for at least three years for former employees. FSM Brian Karnofsky is president of Environmental
Resource Center, |
|
|
|
© 2010 Facility Safety
Management - All Rights Reserved - |
