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Laboratory Pollution Prevention (P2) - page 11 / 12





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Ask the Inspector continued from page 9

2. How soon must I train my staff after employment or assignment to a position involving hazardous waste management?

Employees must receive training within six months after the date of their employment or assignment to an applicable position at the facility. Employees must not work in unsupervised positions until they have completed the training requirements of paragraph (A) of OAC rule 3745-65-16. Personnel also must complete an annual training review.

3. Do I have to train contractors hired for the management of some or all of the facility’s hazardous waste?

Contractors hired to do work which involves management of the facility’s hazardous waste must receive the same training as facility employees.

4. How do I know whether I am qualified to provide the required training?

The person who is instructing the hazardous waste training program must be trained in hazardous waste management procedures to ensure that the facility is in compliance with the applicable requirements found in OAC Chapters 3745-65 to 69 and Chapter 256 (as required by OAC rule 3745-65-16(C)). To gain the needed knowledge and experience the training pro- gram instructor may have coursework and /or on-the-job experience with the hazardous waste rules that qualifies him or her to train facility personnel as appropriate. Each facility training program must be individually developed to address the site specific hazards based on the work performed at that site, the type of waste generated and managed at the site, and the toxicity of that waste. The training program must teach facility personnel hazardous waste management procedures relevant to the positions in which they are employed. The training program must be designed to ensure that facility personnel are able to respond effectively to emergencies, provide instruction in waste management procedures and implement the company’s contingency plan.

The person providing the training must receive annual refresher training and be able to document that the refresher training has been completed. Documented completion of annual refresher training will ensure compliance with OAC Chapters 3745-65 to 69 and Chapter 3745- 256.

5. Are training records required?

Yes. The following training records must be maintained at the facility.

  • For each position related to hazardous waste management, the job title and name of each employee, along with written job descriptions, including the required skills, education or other qualifications.

  • A written description of the type and amount of introductory and continuing training that will be provided to each person filling a hazardous waste management position.

  • For current employees, records documenting that training has been must be maintained until the facility closes. Training records for previous employees must be maintained for a minimum of three years for previous employees.

Are small quantity generators (SQGs) required to train facility personnel?

According to OAC rule 3745-52-34(D)(5)(c), SQGs must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operation and emergencies.

The Spring 2006 Notifier will feature a supplemental article on SQG training requirements.

Notifier-Winter 2006



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