We begin our EHS and compliance training deep-dive series with an analysis of hazardous waste management training guidelines.
Worker training is necessary for virtually every process, task, or program within the field of environmental, health, and safety (EHS)—including for those employees tasked with hazardous waste management.
EHS Training: Vital Yet Complex
But it can be complex for managers to determine just how often a training is needed and in which format it is best perceived, especially considering the many variations in these and other training factors, including:
- Frequency with which it is required (annually, just once at date of hire, quarterly, etc.)
- Required or desired objective
- Which relevant state, federal, or other regulatory bodies dictate safety, health, and other compliance terms for the organization
- Worker roles, education, learning capabilities, schedule, and more
Factoring hazardous waste management into these already complex general EHS training elements adds a layer of intricacy and rigidity. Naturally, keeping up with every compliance and regulatory requirement can be a challenge indeed.
To meet this challenge and help lessen the fog surrounding EHS and compliance training requirements, we’re taking a deep dive into the most common EHS and compliance trainings—to set you on the path to regulatory success. Our first stop on this EHS compliance training dive is hazardous waste management training, a topic I have dug into frequently myself, seeing both successes and failures.
EPA, OSHA, and Others Enforce Training Requirements
When organizations generate regulatory required hazardous waste, they must comply with strict training guidelines set forth and enforced by the Environmental Protection Agency (EPA). Depending on location, industry, and types of hazardous materials generated, other enforcers or government agencies may enact their own hazardous waste management training requirements (and penalties). These organizations include:
- State-based agencies like the Department of Environmental Protection (DEP)
- The federal Department of Transportation (DOT), when waste is being shipped via major transportation
- The Occupational Safety and Health Administration (OSHA), which works to ensure no workers are harmed during hazardous waste management
Training Noncompliance Penalties
Any of these governing bodies can fine organizations for noncompliance with hazardous waste management training standards—and enforcement can be strict. I have seen myself, for example, that the DEP will specifically ask for training plans and records—and fine those who are found to be non-compliant.
Noncompliance fines can be heavy. The EPA alone can issue penalties of $156,259 a day for willful violation; OSHA fines can amount to $16,131 per violation, per day. This isn’t even considering any DEP or DOT sanctions. The reality is that maintaining EHS training compliance is simply smart business.
Many governing bodies will tend to be lenient when managers show good faith and plans to remediate the infraction. Nevertheless, it’s common sense to avoid training noncompliance in the first place—to avoid operational disruptions, loss of morale and brand, and everything else that comes with noncompliance, including worker safety and health. A study by the National Institutes of Health (NIH) found that proper training led to a 42% decrease in medical claims among certain groups. It is in any manager’s best interest to ensure training compliance.
Hazardous Waste Management Training Must-Haves
At a minimum, hazardous waste management training needs to:
1. Define "hazardous waste"
This is outlined by the EPA. Note that the mandated training does not cover:
- Regulated medical waste
- Radioactive waste
- Mixed wastes
- Biochemical wastes
2. Detail proper storage of hazardous waste
After the training, employees should be able to:
- Identify and locate all:
- Satellite accumulation areas (SAAs), specifically regulated sites for storing hazardous waste in preparation for relocation
- Central accumulation areas (CAAs), previously called main accumulation areas (MAAs), where all waste is stored before transport off-site
- Understand what makes a waste container compatible and compliant, ensuring that the container is:
- Closed
- Properly located
- With proper spill containment (if relevant)
- Follow all container rules and best practices, including knowing:
- What a container in good condition looks like
- Proper storage protocols, including how they must be placed safely away from any other incompatible wastes that could react with one another and introduce risk
- Thoroughly monitor, own, and maintain good condition of SAAs
- Identify when a waste container is full and is ready to be moved to the CAA
- Comply with CAA make-and-setup regulations, including those that stipulate that the area:
- Is secure and access-controlled
- Has a concrete floor
- Utilizes relevant spill control
- Prepare an information document listing the waste types, or be able to clearly communicate relevant data with the employee or third-party documentation specialist
3. Outline how to move hazardous waste
Not all employees will be moving hazardous waste, but all should understand that whenever waste is being moved there is an assumption of risk. Workers should also be aware of whose responsibility it is to move waste, either internally or externally. This will vary from organization to organization or even facility to facility.
Employees responsible for moving hazardous waste must also ensure they perform all related processes by the book, from packing to moving and manifesting all the way through ensuring it is accounted for and signed off on.
Note that this training does not require instruction about cleanup protocols—that is more within the purview of emergency response training.
Frequency of Hazardous Waste Management Training
Obviously, complete and successful hazardous waste management training is no small task. Training frequency will vary according to an organization’s generator status and the amount of waste shipped. Generator categories are as follows:
- Very Small Quantity Generators (VSQGs) produce 100 kg or less of hazardous waste per month. There is no frequency requirement for VSQGs.
- Small Quantity Generators (SQGs) produce more than 100 kg but less than 1,000 kg of hazardous waste per month. There is no frequency requirement for SQGs.
- Large Quantity Generators (LQGs) produce more than 1,000 kg of hazardous waste per month. Because of the large amounts of hazardous waste being generated, these organizations have increased training responsibilities—including an annual training requirement.
Even when not officially required, it is good practice to hold worker trainings on hazardous waste management at least annually. This will help an organization avoid preventable incidents and stay compliant.
Ease the Hazardous Waste Burden
For hazardous waste management training, a training format that is custom-designed to resemble your specific lab and facility areas will be beneficial. Such a training will enable workers to identify exact focus locations within their actual worksite, including:
- Lab safety and risk areas
- Common waste locations
- SAAs and the CAA
A traditional, generic training just lacks the flexibility to provide this level of granular detail and is thus less effective for the learner.
Triumvirate Environmental offers a fully custom-built, configurable curriculum with EHSLearn™: Custom. We can design a training formulated specifically to your facility layout to ensure maximum safety, retention, and compliance.
Additionally, we offer on-site support services that eliminate the hazardous waste burden from your employees. Our dedicated and knowledgeable team of experts can handle waste storage and moving as well as all related processes. This way, your team can focus on maximizing their training time and will be able to support if needed—without being in the thick of hazardous waste management on a daily basis. In doing so, they will remain safe and your organization will stay compliant, avoid fines, and foster a positive work environment.
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