The regulatory framework which identifies who must be trained may be circuitous, but must be complied with nevertheless. 40 CFR 265.16 and 40 CFR 264.16 require training for personnel at interim status and permitted hazardous waste management treatment, storage and disposal (TSD) facilities. Hazardous waste generators are instructed in 40 CFR 262.34(a)(4) to comply with the requirements of 40 CFR 265.16 which is included in Appendix C of this manual. Therefore, hazardous waste management training is required for personnel who work at facilities which fit into any of the following categories:
Persons who must be trained include those who are involved with or are occupationally exposed to hazardous waste. This may include (but is not limited to) persons who perform any of the following tasks:
The required training must be successfully completed by all of the personnel described above. For new personnel, training must be successfully completed within six months after assignment to the facility or to a new position at the facility, whichever is later. Until that time, untrained personnel must not perform any tasks involving hazardous waste management unless they are supervised by trained personnel. Facility personnel may be required to take part in an annual review of the entire training program.
The Hazardous Materials Manager will direct training of all applicable facility personnel in hazardous waste management procedures. Included in this training will be instruction in job specific hazardous waste management as well as contingency plan implementation.
There are two general components to the training requirements in 40 CFR 265.16; personnel must be trained:
EPA regulations published in 40 CFR 265.16 regarding personnel training are presented in Appendix C of this manual (separate document, copies available from EH&S).
Besides the required RCRA training, other laws and regulations require training for many of the same personnel who must receive RCRA training. For example, persons working at permitted TSD facilities as well as hazardous substance emergency response personnel are required to be trained in accordance with OSHA regulations published in 29 CFR 1910.120. Personnel who work in areas in which hazardous chemicals are present may be required to be trained in accordance with OSHA regulations published in 29 CFR 1910.1200 or in accordance with substance specific standards in 29 CFR 1910 Subpart Z. All employees who handle, prepare for shipment, load, unload or drive a vehicle hauling DOT hazardous materials must be trained in accordance with the DOT training requirements in 49 CFR 172.700-.704. These regulations require initial general awareness, function-specific and safety training as well as recurrent training every three years or when changes in the regulation occur. To ensure that Clemson University personnel meet all of the training requirements specified by environmental laws, the dean, director, department head or supervisor, with guidance from the Environmental Compliance Officer, should determine the necessary training required for associated employees.
The following documents and records must be maintained at Clemson University: