The California Department of Toxic Substances Control (DTSC) has proposed revisions to the state’s unique Title 22 hazardous waste facility requirements. In addition to permitted treatment, storage & disposal facilities (TSDF) portions also apply to large quantity generators (LQG) of hazardous waste in the State.

The proposed hazardous waste revisions include a new reporting requirement; by March 1 each year, hazardous waste generators will be required to submit a report to DTSC that certifies that every employee has been trained on all requirements applicable to his or her job. The proposed revisions will also require employers to keep employee-signed or -certified hazardous waste training records on site.

DTSC proposed the following changes to the hazardous waste training rules for generators:

  • Allows for online hazardous waste training to be used to satisfy annual training mandate;
  • Requires that hazardous waste shipping personnel be trained to meet the US DOT’s hazmat employee training requirements found at 49 CFR 172.704;
  • Adds “identification and segregation of incompatible hazardous wastes or products” to the list of required hazardous waste training topics;
  • Introduces the concepts of “general awareness” and “function-specific” training to the 22 CCR hazardous waste training rules;
  • Requires that employees at TSD facilities be trained on relevant elements of California’s 8 CCR HAZWOPER Standard (8 CCR 5192(p));
  • Adds three new line items to §66265.16(a)(3),which lists required hazardous waste training elements: (F) shutdown of operations, (G) self-protection measures, (H) accident prevention methods;
  • Revises the training requirement for new employees from “six months” after employment or assignment to “180 days” after; and
  • Requires that employers keep a copy of a “syllabus and/or outline” of hazardous waste training employees complete

Click here to review examples of Caltha’s EHS Training projects, including California hazardous waste training.

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