Help me out here guys. Question, Does a SQG facility have to receive 8 hours of HazCom training on an annual basis? Is it required and if so what is the requirment? :confused:
Tim

I believe i answered my own question. See if this is correct.
The RCRA compliance for Storage/Disposal for SQGs is 40 CFR 262.34(d)(5)(iii). "Familiar" being the key word. Our facility is considered to be a CESQG. So, the compliance does not apply to our facility.
Tim

Here's some advice.....

Go to www.epa.gov and look under Title 40CFR Part 262 and find out.

I know you'll get lost so I'll give another pice of advice....

Try www.osha.gov 29CFR 1910.120 to piece the puzzle together

You can finish with www.dot.gov 49CFR Part 172.


BTW what you asked isn't required by 14001 at all (not specifically anyway)

Also if you're the EHS Manager and don't know the answer to this simple question get a good lawyer because you're obviously lost and probably either violating or fixing to violate a whole bunch of law.

Help me out here guys. Question, Does a SQG facility have to receive 8 hours of HazCom training on an annual basis? Is it required and if so what is the requirment? :confused:
Tim
All employees must be familiar with proper waste handling and emergency procedures relevant to their responsibilities. 40 CFR 262.34(d)(5)(3)

Doesn't say anything about 8 hour for SQG. Usually, in my experiences, companies do an hour of two training annually. The 8 hour refresher training is praimarily for those who work on hazardous waste sites.

Are you really an EHS Specialist?
http://www.epa.gov/region09/waste/rcra/ca/trainchk.htm

Don't know about him but I have a BS Occupational Health & Safety and have managed EHS programs for Lockheed, ITT Industries and the US Army in California along with being the Director of Corporate EHS for QualServ. When it comes to HazWaste I've managed everything from waste oil (CA HW) to stuff ending with -ium (Steve Prevette knows about stuff like this).

When it comes to HazWaste I've managed everything from waste oil (CA HW) to stuff ending with -ium (Steve Prevette knows about stuff like this).
:topic:
Randy, CA seems silly to consider used oil to be hazardous even if it does not have characterisitcs of a hazardous waste. Do you know of any other states that consider used oil to be hazardous?

I was with the former OHM Corporation (now Shaw Group) from 1985-1992. That is where I recieved hazardous waste site experience.

Thanks Guys! I will do some more research. I want to be sure that we meet the requirments.
Tim

So far I've only come across CA listing oil as a HW (it has it's own number)