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Changes Proposed to California’s Hazardous Waste Training Rules

Posted on 10/6/2017 by Roger Marks

The California Department of Toxic Substances Control (DTSC) has proposed significant revisions to the state’s unique Title 22 hazardous waste facility permitting requirements.

While the proposed revisions are intended for California’s eighty-six permitted transfer, treatment, storage, and disposal facilities, elements of the hazardous waste permitting rules—like the Title 22 hazardous waste training standards—also apply to large quantity generators of hazardous waste in the State. 

DTSC will accept public comments on the proposed changes—under docket number R-2016-03—until November 6 and will hold a public meeting on that date to discuss the proposal.


Doesn’t US EPA Regulate Hazardous Waste Under RCRA?

Like many states, California is authorized to operate a unique hazardous waste management regulatory program in lieu of the Federal Resource Conservation and Recovery Act (RCRA) requirements. State regulations must be at least as stringent as, and must not conflict with, the Federal hazardous waste rules found in 40 CFR Parts 260—268 et al. 

Read more about the ins and outs of RCRA State Authorization here


Revised 22 CCR Hazardous Waste Training Rules

DTSC’s proposed hazardous waste revisions include a new reporting requirement for facilities. 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.


Other Title 22 Hazardous Waste Training Updates

In addition to the new reporting requirement, DTSC proposed the following changes to the hazardous waste training rules for generators (found in 22 CCR 66265.16):
 
  • Explicitly allows for online hazardous waste training to be used to satisfy DTSC’s 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, and (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.

General Awareness and Function-specific Training

Those familiar with US DOT’s Hazardous Materials Regulations are likely already comfortable with the terms “general awareness” and “function-specific” as they relate to employee training.

In short, “general awareness” training provides a big-picture overview of hazardous waste management and the hazards posed by wastes found in the workplace. “Function-specific” training covers the employee’s specific job functions—things like handling drums, marking and labeling containers, accumulating waste in satellite areas, etc.     


Updates for Liability, Financial Assurance, and Facility Closure

On top of the new requirements for training hazardous waste personnel, DTSC’s proposed rulemaking will revise the rules that facility owners and operators must follow pursuant to financial assurance, liability, and facility closure and post-closure activities.

Also addressed are DTSC’s procedures for issuing permits and inspecting permitted hazardous waste facilities and enforcing the hazardous waste regulations. While these permitting updates are broad and wide-ranging, they will affect a relatively small number of facilities compared to the generator training rules addressed above—which apply to all large quantity generators in the state.  

The full text of the proposed revision is available here.


Online Title 22 Hazardous Waste Training for California Facilities

Meet DTSC’s annual training mandate and build a streamlined approach to managing hazardous waste in line with California’s unique, stringent management regulations. Whether you’re new to hazardous waste compliance, new to California, or you’ve been at it for years, you will  find training at Lion.com to help simplify your responsibilities, protect your employees, and defend your site from releases and costly DTSC fines.  

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Tags: California, DTSC, hazardous waste, new rules, Title 22

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