Hazardous Waste Management Training

Overview After completing this training you should be able to describe the purpose and requirements of the environmental health standards for the management of hazardous waste. Learning Objective

Overview The regulation identifies those wastes which are subject to regulation as hazardous wastes and which are subject to the notification requirements of Health and Safety Code section 25153.6. The Standard

Overview A material which is not defined as a waste, or identified as a hazardous waste pursuant to the regulation, is still a waste and a hazardous waste for purposes of Health and Safety Code sections 25185 and 25187.1, if the Department has reason to believe that a material may be a waste within the meaning of Health and Safety Code section 25124 and a hazardous waste within the meaning of Health and Safety Code section 25117. The Standard

Definitions A hazardous waste is any waste, or combination of wastes, which because of it quantity, concentration, or physical or chemical characteristics may either cause of significantly contribute to an increase in mortality or an increases in a serious irreversible, of incapacitating reversible illness, or pose a substantial present or potential hazard to human health or the environment when improperly treated, stored, transported, or disposed of, or otherwise managed. What is a hazardous waste?

Definitions What is a hazardous waste? A waste is a hazardous waste if it exhibits any of these characteristics: Characteristic of Ignitability It is a liquid, other than an aqueous solution containing less than 24 % alcohol by volume, and has a flash point less than 60 C (140 F); It is not a liquid and is capable, under standard temperature and pressure, of causing fire through friction, absorption of moisture or spontaneous chemical changes and, when ignited, burns so vigorously and persistently that it creates a hazard; It is an ignitable compressed gas or an oxidizer.

Definitions What is a hazardous waste? A waste is a hazardous waste if it exhibits any of these characteristics: Characteristic of Corrosivity It is aqueous and has a pH less than or equal to 2 or greater than or equal to 12.5. It is not aqueous and, when mixed with an equivalent weight of water, produces a solution having a pH less than or equal to 2 or greater than or equal to 12.5. Characteristic of Toxicity It has been shown through experience or testing to pose a hazard to human health or environment because of its carcinogenicity, acute toxicity, chronic toxicity, bioaccumulative properties or persistence in the environment.

Definitions What is a hazardous waste? A waste is a hazardous waste if it exhibits any of these characteristics: Characteristic of Reactivity It is normally unstable and readily undergoes violent change without detonating, including water reactives, explosives, sulfide or cyanide bearing wastes. California law states that generators are responsible for determining if their wastes are hazardous.

Definitions What is a hazardous waste? Generator: Any business, institution or individual who produces or generates a waste which falls within the California Health and Safety Code’s (H&S) definition of a hazardous waste becomes a “generator” of hazardous waste and is subject to regulation. Hazardous waste: (H&S Code, Section 25117) A waste, or combination of wastes, which because of its quantity, concentration, or physical, chemical, or infectious characteristics may either: (a) cause or significantly contribute to an increase in mortality or an increase in a serious irreversible, or incapacitating reversible illness; (b) pose a substantial present or potential hazard to human health or environment when improperly treated, stored, transported, or disposed of, or otherwise managed. The term “ hazardous waste” shall be understood to also include extremely hazardous waste. (California Code of Regulations, Title 22, Div. 4.5) Material which meets any of the criteria presented in Chapter 11 (“Criteria for identification of hazardous and extremely hazardous waste”), or material listed in Appendix X (a list of hazardous wastes and hazardous materials by chemical names and common names) is considered a hazardous waste.

Definitions What is a hazardous waste? Extremely hazardous waste: Any waste which, if human exposure should occur, may likely result in death, disabling personal injury or serious illness caused by the hazardous waste or mixture of hazardous wastes because of its quantity, concentration, or chemical characteristics” (H&S Code 25115). Extremely hazardous wastes are designated with ah asterisk in Appendix X of Title 22.* Note: If you generate an extremely hazardous waste, you must obtain an Extremely Hazardous Waste Permit from the California Department of Toxic Substances Control prior to transporting, treating, storing or disposing of the waste. Call the Extremely Hazardous Waste Disposal Hotline at (510) 540-3953 to obtain more information. EPA and State Identification Numbers: EPA or State ID numbers are assigned to each site address where waste is generated. This ID number is used to track hazardous waste from cradle to grave. ID numbers have a prefix of three letters followed by nine numbers (with the exception of federal facilities). The following are some of the more common types, and what they denote: CAL - Given to generators of non-RCRA hazardous waste or to generators of RCRA hazardous waste generating a total of less than 100 kg of waste per month (approximately 220 lbs. or 27 gallons). CAD - Given to generators of RCRA hazardous waste generating a total of more than 100 kg of waste per month (approximately 220 lbs. or 27 gallons) and/or 1 KG or more of extremely hazardous waste. CAX - State permanent or provisional number issued before 1987. No longer valid. CAC - State provisional or emergency number. Valid for 90 days only unless granted an extension.

Generator Requirements Under California law, generators of hazardous waste must comply with the following general requirements: characterize waste obtain an EPA or State identification manage waste in compliance with laws and regulations maintain records select appropriate treatment and disposal options obtain any required permits provide personnel with appropriate training prepare a contingency plan eliminate, reduce and recycle wastes Generator Identification Number If you generate hazardous waste, you must obtain a Generator Identification Number. This number is required before waste can be transported from your facility. For assistance in obtaining a generator identification number call 1-800-618-6942. The only exemption to the requirement for obtaining a generator number applies to generators who meet all of the following three criteria: only used oil and/or parts cleaning solvents are generated in quantities of less than 27 gallons per month and this waste is hauled via a "milk run" system by a licensed hazardous waste hauler.

Hazardous Waste Determination

Hazardous Waste Determination The waste is a hazardous waste if the material safety data sheet for the material(s) from which the waste was derived indicates listed constituents, exhibits a hazardous waste characteristic, or is harmful to humans or the environment and is not otherwise shown to be not a hazardous waste by laboratory testing. Common hazardous wastes in California include: used oil, waste engine coolant (antifreeze), solvents and thinners, oil-based paints, parts cleaning solvents, absorbent and spill clean-up debris, paint spray booth filters, used oil filters (exempt if reclaimed), silver from photochemical wastes, waste perchloroethylene, chemical wastes from plating shops, lead/acid batteries, waste pesticides. For more detailed information, refer to California Title 22, Article 11, or contact Cal/EPA's Waste Evaluation Unit at (916) 322-7676. Any analytical work performed for classification purposes must be performed by a state certified hazardous waste testing laboratory.

Hazardous Waste Determination If you produce a hazardous waste (refer to Chapter XII of Title 22, Division 4.5, of the California Code of Regulations), you must comply with the State’s hazardous waste regulations. However, in certain unique situations, an exemption may be petitioned from the State. If you wish to petition the State to exempt your wastes from the requirements, you must send to the Department of Toxic Substances Control a written application for classification of the waste as non-hazardous. Information you must provide on the application from includes a description of the waste, a label report from a State-approved laboratory identifying the hazardous components of the waste and their concentrations, and a summary of evidence with technical references which show why the waste should not be classified as hazardous. These application forms may be obtained upon request from the California Department of Toxic Substances Control. A copy of that exemption must be provided to the County of Santa Clara, Environmental Health Department, Hazardous Materials Compliance Division, 2220 Moorpark Ave., San Jose, CA 95128. Classification of hazardous waste as non-hazardous

Hazardous Waste Accumulation Time There are limits on the amount of time that hazardous wastes can be stored on site without a special permit. Businesses that generate less than 1000 Kg per month of hazardous waste (approx. 270 gallons) are allowed to store waste for up to 180 days without a permit. If the hazardous waste is hauled to a facility which is greater than 200 miles away, the storage time becomes 270 days. Generators of more than 1000 Kg per month must still meet the 90 day storage limit. Waste must be transported by a licensed hazardous waste hauler and it must go to a state permitted treatment, storage and disposal facility (TSDF).

Hazardous Waste Accumulation Time If you generate LESS than 27 gallons or 100 Kg of waste OR 1 quart or 1 Kg of extremely hazardous waste each month, the accumulation period begins when the first 27 gallons of hazardous waste are accumulated. If you generate MORE than 27 gallons or 100 Kg of waste OR 1 quart or 1 Kg of extremely hazardous waste each month, the accumulation period begins when any amount of hazardous waste is accumulated.

Hazardous Waste Accumulation Time Satellite accumulation is a way that a generator can store hazardous waste on-site for up to 12 months. In order to qualify for this exemption the following criteria must be met: the waste must be accumulated at or near the area where the waste is being generated (i.e. in the same room); the waste must be under the control of the operator of the process generating the waste; no more than 55 gallons per waste stream may be accumulated; the waste cannot be accumulated in a tank; the container must be labeled "hazardous waste" and have the accumulation start date marked on it; once 55 gallons are generated, the waste must be transported off-site by a licensed hazardous waste hauler to a permitted TSD facility; waste storage time cannot exceed 12 months. Hazardous waste satellite accumulation requirements

Hazardous Waste Accumulation Time Satellite accumulation is the collection of hazardous waste in a container, not a tank, located at or near the point (i.e., process or piece of equipment) where the waste is generated. The container must be under the control of the operator of the waste generation process. 22 CCR §66262.34(e)(1)(A) Definition of satellite accumulation Quantity limits No more than 55 gallons of a hazardous waste, or one quart of an acutely hazardous or extremely hazardous waste, may be accumulated at each satellite accumulation point. These limits apply to each waste stream. You can accumulate more than one waste in each satellite accumulation area. 22 CCR §66262.34(e)(1)

Hazardous Waste Accumulation Time Containers must be: In good condition. 22 CCR §66265.171 as referenced by 22 CCR §66262.34(e)(1)(D) Compatible with the waste held. 22 CCR §66265.172 as referenced by 22 CCR §66262.34(e)(1)(D) Kept closed except when adding or removing waste. 22 CCR §66265.173(a) as referenced by 22 CCR § 66262.34(e)(1)(D) Container requirements Labels 22 CCR §66262.34(f)(3) as referenced by 22 CCR §66262.34(e)(1)(E)

Hazardous Waste Accumulation Time You can keep a satellite accumulation container on-site for a maximum of one year from the date you first place waste in the container, or 90 or 180 days1 from the date you reach the 55 gallon or one quart satellite accumulation quantity limit described in Section B, above, whichever occurs first. Accumulation time limits 22 CCR §66262.34(e)(1)(B) Advantages of satellite accumulation You do not have to call for waste pick-ups as often (saves money); If you operate only under satellite accumulation requirements and ship each container off-site for proper disposal within three (3) days of reaching the 55 gallon (or one quart) accumulation quantity limit you are exempt from Title 22 requirements for hazardous waste management training, weekly container inspections, emergency equipment, and posting of emergency information.

Labels Hazardous waste The following information must be clearly marked on each satellite accumulation container: The name of the waste generator; The address of the waste generator, including phone number EPA ID Number Manifest Tracking Number should be written down when the Manifest is provided by the transporter to generator EPA & California Waste Numbers which describe the waste The accumulation start date for the waste (i.e., the date waste was first placed in the container); The composition of the waste; Proper shipping name, hazard class and UN# or NA# The physical state of the waste (i.e., solid or liquid); The hazardous properties of the waste (i.e., flammable, corrosive, reactive, toxic); NOTE: The label at a Satellite Accumulation Point shall have printed “Satellite Accumulation Point”. Within 3 days of reaching the 55 gallon or one quart satellite accumulation limit, the container must be marked with the date the quantity limit was reached.

Labels Hazardous waste storage All hazardous waste storage must be labeled with the following information: Health (Blue) 4-Danger: May be fatal on short exposure. Specialized protective equipment required 3-Warning: Corrosive or toxic. Avoid skin contact or inhalation 2-Warning: May be harmful if inhaled or absorbed 1-Caution: May be irritating 0-No unusual hazard Flammability (Red) 4-Danger: Flammable gas or extremely flammable liquid 3-Warning: Flammable liquid flash point below 100° F 2-Caution: Combustible liquid flash point of 100° to 200° F 1-Combustible if heated 0-Not combustible

Labels Hazardous waste storage All hazardous waste storage must be labeled with the following information: Reactivity (Yellow) 4-Danger: Explosive material at room temperature 3-Danger: May be explosive if shocked, heated under confinement or mixed with water 2-Warning: Unstable or may react violently if mixed with water 1-Caution: May react if heated or mixed with water but not violently 0-Stable: Not reactive when mixed with water Special Notice Key (White) W: Water reactive OXY: Oxidizing agent

Labels Guidelines for labeling 1. Storage areas should be identified by markings (e.g. signs, stenciling, etc. on walls or fences) as described below. a. Unless specified otherwise, lettering should be large enough to be read from a distance of 20 feet. For recommendations regarding small containers or unusual circumstances, contact your local agency. b. Lettering should contrast highly with the background. c. Markings should not be located where they might be obstructed (e.g. by open doors, equipment, etc.). Drums with side markings or labels shall be positioned with the markings/labels facing outwards. d. To assist emergency response personnel, it is recommended that empty container storage areas and pipes or containers holding non-hazardous materials be clearly identified. 2. All safety cans should be marked with the chemical name and hazard class of the liquid contained within. If safety cans are used for the collection of hazardous waste, they shall be labeled in accordance with the requirements specified for hazardous waste labels, above. 3. Open tanks, vats, and baths should be identified with a marking on the tank or on a wall directly behind the vessel. The marking should show the chemical name, hazard class, and percentage concentration of the single highest-hazard material, including constituents of mixtures or solutions contained within the vessel.

Labels Guidelines for labeling 4. Rinse-dragouttanks should be marked "RINSE WATER" or equivalent. 5. Aboveground tanks should be identified with a marking on the tank which shows the chemical name, hazard class, and percentage concentration of the single highest-hazard material, including constituents of mixtures or solutions contained within the tank. Such markings should be easily visible from a distance of 60 feet. 6. Hazardous waste tanks or treatment units operating under Tiered Permit provisions shall be marked with: The name of the person/facility (legal entity) which owns the tank/unit; The facility’s EPA ID number; The tank/unit’s individual serial number. 7. Tanks operating under Tiered Permit not subject to continuous throughput shall additionally be marked with: The words “HAZARDOUS WASTE”; The accumulation start date for the waste in the tank. 8. Containers holding drained used oil filters to be transported off-site - either directly or via a storage or consolidation facility - to a smelter for recycling shall be marked with the following information: The words “DRAINED USED OIL FILTERS”; The accumulation start date for the filters in the container.

Labels Guidelines for labeling 9. Containers and tanks holding recyclable hazardous materials excluded from classification as hazardous waste pursuant to H&SC §25143.2(b) or (d) shall be marked as follows. a. Containers or Portable Tanks: The words “EXCLUDED RECYCLABLE MATERIAL”; The accumulation start date for the material in the container; Composition (e.g. oil; acetone 40%, toluene 60%; etc.) and physical state (i.e. solid, liquid, etc.) of the material; Hazardous properties (e.g. flammable, corrosive, reactive, toxic, etc.) of the material; Name and address of the facility generating the material. b. Non-Portable Tanks: i. Accumulation or storage tanks shall be marked with the following information: The words “EXCLUDED RECYCLABLE MATERIAL”; The accumulation start date for the material in the tank. ii. Aboveground tanks shall also be marked in accordance with CFC Standard 79-3. CFC §7902.1.3.2 & 8003.1.2 10. Cabinets used for the storage of flammable liquids shall be provided with a conspicuous label in red letters on contrasting background which reads “FLAMMABLE - KEEP FIRE AWAY”. CFC §7902.5.9.3.1

Labels Guidelines for labeling 11. Each empty container* larger than 5 gallons which previously held a hazardous material and is considered a hazardous waste shall be marked with the date it was emptied. [Exceptions: (1) Empty gas cylinders are exempt when the pressure in the container reaches atmospheric pressure; (2) Aerosol cans are exempt provided that they are not a RCRA-regulated hazardous waste or California extremely hazardous waste and that the containers are emptied of contents and propellant to the maximum extent practical under normal use; (3) Containers or container liners made of wood, paper, cardboard, fabric, or any other similarly absorptive materials must be managed as hazardous wastes if they were in direct contact with and have absorbed the hazardous waste or hazardous material they held; (4) Containers or container liners which have held RCRA acutely hazardous (P List) wastes or California extremely hazardous wastes must be managed as hazardous wastes unless they have been triple rinsed or otherwise cleaned in a manner approved by the California Department of Toxic Substances Control.] * The California Department of Toxic Substances Control’s Fact Sheet titled “Contaminated Container Regulations” (DTSC Doc. #106) defines what constitutes an “empty” container.

Labels Guidelines for labeling 12. Stations Dispensing Gasoline or Other Flammable Liquids: a. Conspicuous signs prohibiting smoking, prohibiting dispensing into unapproved containers, and requiring vehicle motors to be stopped during fueling operations shall be posted within sight of each customer being served. CFC §5201.8 b. When supervision by a qualified attendant is not provided, instructions for safe operation of dispensing equipment shall be conspicuously posted. CFC §5201.6.3 c. The emergency shut-off switch for the dispensing operation shall be marked "EMERGENCY PUMP SHUTOFF". CFC §5201.5.3 d. The following sign shall be posted in a conspicuous location: CFC §5201.6.3 (Note: If applicable, a facility’s internal fire department number may be shown on the sign in place of 911. However, the facility must still call 911 in the event of an emergency.)

Labels Guidelines for labeling Compressed Gases and Liquefied Gases: a. Stationary compressed gas containers, cylinders, and tanks shall be marked in accordance with CFC Standard 79-3. Markings shall be visible from any direction of approach. CFC §7401.5.2 b. All portable toxic gas tanks and cylinders shall be marked to indicate the valve's orifice size, in inches. The orifice size shall be printed on the certification tag for the portable tank or cylinder as well as on the vessel itself. The lettering shall be a minimum of 1/4" high. TGO c. Rooms or cabinets shall be conspicuously labeled “COMPRESSED GAS”. CFC §8001.7 14. Piping and Tubing Containing Hazardous Materials Liquids and Gases: a. All exposed piping and tubing, including gas exhaust systems prior to treatment, which contain hazardous materials shall be marked at intervals no greater than every twenty (20) feet with the name of the material contained and the direction of flow. Lines shall be marked thus at each point where changes in direction occur and where wall, ceiling, or floor penetration occurs. Where lines are shorter than 20 feet in length, such markings shall appear at least once along the length of the run. Where supplementary color identification of piping is used, it shall be in accordance with the hazardous materials and colors indicated in nationally recognized standards as referenced in the California Fire Code. CFC §7401.5.3 & 8001.4.3.2 b. Emergency control valves and shut-off valves shall be marked to indicate their function. CFC §8001.4.3.2

Hazardous Waste Manifest Hazardous wastes to be transported must be accompanied by a Uniform Hazardous Waste Manifest form. This form, once completed by the appropriate hazardous waste generator, transporter, treatment storage and/or disposal (TSD) facility, will ensure ‘cradle to grave’ management of all hazardous wastes produced. As a generator of hazardous waste, you are fully responsible and liable for the wastes you produce. By accurately completing a manifest form and by making sure you receive a signed and dated copy (back from the disposal or recycling facility responsible for final disposal), you are taking appropriate, responsible action as a hazardous generator. To obtain and complete a hazardous waste manifest, take the following steps: Obtain manifest forms from the State, Department of General Services at (916) 574-2200 or from a registered hazardous waste hauler. (Sample hazardous waste manifest is on page 8). Obtain an EPA Identification Number or State Identification Number as required. An identification number is required on the manifest form. If you do not have the required identification number, you may obtain one by calling Cal/EPA Department of Toxic Substances Control at (800) 6218-6942 or Federal EPA at (415) 495-8895.

Hazardous Waste Manifest Hazardous wastes must be transported by a registered hazardous waste hauler only. These haulers are registered by the Department of Toxic Substances Control and inspected for safety and container integrity. The wastes must be transported to a permitted treatment, storage, or disposal (TSD) facility or transfer station. These sites have either received a hazardous Waste Facility Permit or have been issued to Interim Status Document by the Department of Toxic Substances Control. Hazardous wastes may not be disposed of in the regular trash or on the ground. In addition, they may not be dumped into the sewer system, e.g., the sink or toilet, or any storm drain. Only rain water may be allowed to enter any storm drain. Use of a registered hazardous waste hauler

Hazardous Waste Manifest

Hazardous Waste Manifest If the signed original of the manifest is not received within 35 calendar days from the disposal site the plant must contact the disposal site to forward a copy of the signed manifest immediately. If the signed original, or a copy, has not been received with 45 days after the shipment, an Exception Report must be submitted to the Department of Toxic Substances Control. This Exception Report must document all efforts taken to locate the hazardous waste shipment and the results of these efforts. Document all correspondence and telephone conversations. Exception reporting

Hazardous Waste Manifest The requirements that apply just to explosive and poisonous waste classified by U.S. DOT (Department of Transportation) under Code of Federal Regulations, Title 49, as hazard division 1.1 through 1.6 and hazard division 6.1 are more stringent. a. “Priority Discrepancy” is a variation in weight greater than one percent for bulk waste, any variation in piece count for containerized waste, or any variation in the type of waste as listed in Title 22, 66264.72 & 66265.72(c). “Priority Discrepancy” has to be solved in 24 hours between the TSDF and the Generator. DTSC must be informed within 24 hours after discovery if the discrepancy is unsolved by the TSDF and Generator. The Generator shall follow-up with a letter submitted to DTSC in five (5) days after discovery of unresolved priority discrepancy. b. “Significant Discrepancy” is a variation in weight greater than ten percent for bulk waste, any variation in piece count for containerized waste, or any variation in the type of waste where the waste is not an explosive or poisonous material as listed in Title 22, 66264.72 & 66265.72(a). The TSDF has 15 days to reconcile a significant manifest discrepancy with the Generator or Transporter(s). If the discrepancy cannot be solved the owner must notify DTSC in writing in 15 days after receiving the shipment. Manifest discrepancy reporting

Hazardous Waste Manifest U.S. EPA and State regulations require that copies of the manifest signed by the disposal site must be retained for three years. Record retention Periodic reports U.S. EPA and State regulations require any large generator who ships hazardous waste off-site to submit a biennial report.

Storage and Compatibility of Hazardous Waste Hazardous waste must be stored in secured area in containers constructed of material compatible with the waste (usually steel or plastic). Containers must have tight-fitting lids and must be kept closed at all times except when wastes are being added or removed.

Storage and Compatibility of Hazardous Waste Secondary containment is a way to catch and prevent spills and leaks of wastes before they are discharged into the environment. The following are recommended secondary containment guidelines for generators: A base should underlie the containers which is free of cracks or gaps and is sufficiently impervious to leaks, spills and accumulated precipitation until the collected material is detected and removed. The base shall be sloped or the containment system shall be otherwise designed and operated to drain and remove liquids resulting from leaks, spills or precipitation, unless the containers are elevated or are otherwise protected from contact with accumulated liquids. The storage area shall have sufficient capacity to contain precipitation from at least a 24 hour, 25-year storm PLUS 10 % of the aggregate volume of all containers OR the volume of the largest container, whichever is greater. Run-on into the storage area shall be prevented unless the storage area has sufficient excess capacity in addition to that required to contain any run-on which might enter the storage area. Spilled or leaked waste and accumulated precipitation shall be removed from the collection area in as timely a manner as is necessary to prevent overflow of the storage area. Secondary containment

Storage and Compatibility of Hazardous Waste Acid + Oil or Grease = Fire Flammable Liquid + Hydrogen Peroxide = Fire/Explosion Acid + Caustic = Heat/Spattering Aluminum Powder + Ammonium Nitrate = Explosion Caustics + Epoxies = Extreme Heat Sodium Cyanide + Sulfuric Acid = Lethal Hydrogen Cyanide Chlorine Gas + Acetylene = Explosion Ammonia + Bleach (or other Chlorine source) = Toxic Chloramine (i.e., Mustard Gas) Some hazardous combinations

Storage and Compatibility of Hazardous Waste Leaks or spills of wastes are considered "unauthorized releases" and must be cleaned up immediately. When a new hazardous material is spilled or released it too becomes a hazardous waste if it cannot be reused. Absorbent used on the spill must be managed as hazardous waste. Large volume spills or long term leaks can contaminate equipment, floor surfaces, soil, surface and groundwater. Clean-ups can become very costly at this stage. Generators are required to train personnel to respond to leaks and spills when appropriate, have clean-up equipment available, and know who to call if the release cannot be handled safely by facility personnel. All clean-up workers must utilize proper personal protective equipment. Spill and leak clean-up

Storage and Compatibility of Hazardous Waste Hazardous waste containers (<60 gallons) must be inspected weekly while hazardous waste in tanks (60 gallons or more) must be inspected daily for leaks and corrosion. A written log shall be maintained to document the inspections. The inspection shall cover the following: 1. Storage area free of spills & leaks 2. Containers & storage area properly labeled 3. Containers within secondary containment 4. Fire extinguishers serviced & tagged 5. Hazardous waste labels complete & visible 6. Eye wash, safety showers, ER equipment functional 7. Containers sealed with tight-fitting lids/bungs 8. Incompatibles properly separated 9. Waste not stored over allowable time Inspections

Storage and Compatibility of Hazardous Waste Business owners, managers, supervisors and employees who handle hazardous waste, including those who sign the hazardous waste receipts or manifests for transportation, must have annual training. This training must be directed by a person trained in hazardous waste management procedures and must include at a minimum: emergency procedures, effective response to emergencies, proper use of emergency equipment and systems including contingency plan implementation. Records which document the training must be kept at the hazardous waste generator facility for at least three years. Facility personnel shall successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the requirements of this chapter. The owner or operator shall ensure that this program includes all the elements described in the document required under subsection (d)(3) of this section. Personnel training

Storage and Compatibility of Hazardous Waste (2) This program shall be directed by a person trained in hazardous waste management procedures, and shall include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. (3) At a minimum, the training program shall be designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where applicable: (A) procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; (B) key parameters for automatic waste feed cut-off systems; (C) communications or alarm systems; (D) response to fires or explosions; (E) response to ground-water contamination incidents; and Personnel training

Storage and Compatibility of Hazardous Waste (F) shutdown of operations (b) Facility personnel shall successfully complete the program required in subsection (a) of this section within six months after the date of their employment or assignment to a facility, or to a new position at a facility. Employees hired after the effective date of these regulations shall not work in unsupervised positions until they have completed the training requirements of subsection (a) of this section. (c) Facility personnel shall take part in an annual review of the initial training required in subsection (a) of this section. (d) The owner or operator shall maintain the following documents and records at the facility: (1) the job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job; Personnel training

Storage and Compatibility of Hazardous Waste (2) a written job description for each position listed under subsection (d)(1) of this section. This description may be consistent in its degree of specificity with descriptions for other similar positions in the same company location or bargaining unit, but shall include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position; (3) a written description of the type and amount of both introductory and continuing training that will be given to each person filling a position listed under subsection (d)(1) of this section; (4) records that document that the training or job experience required under subsections (a), (b), and (c) of this section has been given to, and completed by, facility personnel. (e) Training records on current personnel shall be kept until closure of the facility. Training records on former employees shall be kept for at least three years from the date the employee last worked at the facility. Personnel training records may accompany personnel transferred within the same company. Personnel training

Emergency/Contingency Plans All facilities handling hazardous waste require a Contingency Plan. This plan describes emergency procedures in response to fire, explosion, or any unplanned release of hazardous wastes to air, soil, surface water, or that could threaten human health or the environment. Businesses that have prepared other plans that are required pursuant to other laws, such as a Hazardous Materials Business Plan and/or a Spill Prevention Control and Countermeasures Plan may elect to amend that plan to incorporate the hazardous waste Contingency Plan. The Contingency Plan must include the following elements: Description of the actions facility personnel will take to implement emergency procedures. Arrangements agreed to by local police departments, fire departments, hospitals, contractors, and state and local emergency responders to coordinate emergency services. An up-to-date list of names, addresses, and phone numbers of all persons qualified to act as the emergency coordinator. An up-to-date list of emergency equipment at the facility, including the location and physical description of each item and its capabilities. An evacuation plan. Phone number for the State Office of Emergency Services.

Emergency/Contingency Plans Hazardous Waste generators are encouraged to reduce or recycle hazardous wastes. Hazardous waste volume can be reduced by good facility management and equipment maintenance procedures. In some cases, non-hazardous substitutes can be used in place of raw materials that become hazardous wastes. Other waste minimization alternatives exist for most businesses, including on-site recycling. Contact the Cal/EPA Source Reduction/Treatment Technologies unit at (916) 322-3670 for more information. This information packet covers basic waste generator requirements. For more detailed information about regulatory requirements, refer to the state hazardous waste regulations, Title 22 California Code of Regulations. Copies can be purchased from Barclay's Law Publishing at 1-800-888-3600.

Hazardous Waste Management Training