Are 8 hours of HazCom training required per year for Small Quantity Generators (SQG)?

[Al Rosen]

Re: Are 8 hours of HazCom training required per year for Small Quantity Generators (S

I could swear I read in one of the CFRs that refresher training isn't necessary if there have been no changes in the work environment. But I'll be darned if I can find the reference.

It's in 29cfr1910.1200 para (h) (1)

(h) Employee information and training. (1) Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area.

 

[SteelMaiden]

Re: Are 8 hours of HazCom training required per year for Small Quantity Generators (S

Training needs are dependant upon the employees responsibilities and certification levels, no? 8 hour refresher is required to maintain a HazWOper certification (in any state that I've lived in)

 

[Al Rosen]

Re: Are 8 hours of HazCom training required per year for Small Quantity Generators (S

Training needs are dependant upon the employees responsibilities and certification levels, no? 8 hour refresher is required to maintain a HazWOper certification (in any state that I've lived in)

We were discussing the OSHA Right To Know Hazard Communications regulations in 29CFR1910.1200

 

[PotentCompoundSafety]

Re: Are 8 hours of HazCom training required per year for Small Quantity Generators (S

This is a topic I know extremely well. On a U.S. Federal regulation level, the hazard communication standard 29 CFR 1910.1200 does not require a specific number of hours of training. What you are likely thinking of is the OSHA HAZWOPER Standard (29 CFR 1910.120). The HAZWOPER standard addresses requirements for two distinct types of employees: 1) hazardous waste site cleanups such as CERCLA, RCRA Corrective Action Sites, Superfund sites, and Treatment, Storage, and Disposal facility sites; and 2) Emergency Response Personnel regardless of the location. It is very important to remember that those employees covered by those activities mentioned in item 1 are not your traditional generators (CESQG, SQG, or even LQG). In item 1 they are talking about employees who are cleaning up sites such as Love Canal, Valley of the Drums, leaking UST sites, and hazardous wastes burial or incinerator sites. The TSDF employees in item 1 are your Part B permitted facility employees. Very few SQGs are Part B permitted. You only need a Part B permit if you accumulate wastes longer than the 90/180 day accumulation periods, or accumulating waste onsite in excess of the limits for those types of generators, or are performing onsite treatment or disposal.

Employees covered by those activities in item 1 need up to 40 hours of training depending upon their involvement. In addition they need 8 hours of annual refresher training.

What makes this confusing for people, is that a few consulting firms or individuals have over stated what the requirements are in order to teach 8 hour seminars. In addition, some of OSHA's letters of interpretation on this issue are difficult to understand without a firm grasp of both OSHA and EPA regulations.

With that say, always remember that the bottom line is employee safety and the protection of the environment. Depending upon the types of wastes that you're handling training might take longer than 8 hours.

Hope this answers your question.