ISO 14001 and HAZWOPER - My registrar has stated that HAZWOPER is necessary

[GeneK]

Good afternoon, being new to the forum, I would like to say hello to everyone here and if I do anything stupid or ask stupid questions, I am sorry.

My question deals with element 4.4.7 of ISO-14001. Is there any documented requirement that HAZWOPER is a required form of training in meeting 4.4.7 requirements? I have implemented 14001 at 12 of our plants and have made the management attend HAZWOPER training. My registrar has stated that HAZWOPER is necessary, yet searching the internet, I can't find definative evidence of this. If anyone can help me, or lead me in the right direction I would appreciate it.

Thanks..

 

[D.Scott]

Welcome to the Cove Gene. Let's start by saying there are no stupid questions here and you will be hard done by to beat some of the stupid things a lot of us have already done. We are here as quality professionals with the objective of helping each other whenever we can and having a place to just hang out with people who "understand" what we are going through in our jobs. You just go ahead and ask away and feel free to impart some of the experience you have gained too.

Now, to the question. I don't know anywhere that HAZWOPER is required. The training is a requirement but I don't know anywhere it is specified that this is the only way to meet the requirement. Could your registrar mean that HAZWOPER training is a demonstration of the requirement being met? I would think other demonstrations would be acceptable.
This is not an area of specialty for me so others may have a different opinion which I will surely welcome but maybe this will start the ball rolling in the right direction.
Again, welcome to the Cove.
Dave

 

[BadgerMan]

My interpretation (right or wrong) is that Hazwoper is one means to an end.

Our internal Emergency Preparedness and Response process/documents satisifed our registrar.

However, if Hazwoper is a regulatory requirement of your facility, your registrar my be correct. I believe that you will have to check the scope section of the subject OSHA standard and determine if it applies to your facility, or not.

 

[GeneK]

For clarification, 5 of our plants paint interior and exterior parts for the automotive. We have pretty much transitioned to water based paint and away for from solvent. Yet, we still do some with solvent. And all the plants have injection and blow molding on site. We handle MEK, laquer thinner, oxidizers, corrosives (used to keep the ph of the water within a certain range for our non-contact cooling water used in the presses. Most items are either in 55 gallon drums or 320 gallon totes.

The only exception is one plant (#13) that is only assembly. They were not required to have any HAZWOPER training.

 

[SteelMaiden]

I think that Badgerman is on the right path. If you need to have Hazardous Waste Operations in place you need to have refresher training (or a note in the training files why the annual refresher was not done). I don't think that every business in the world necessarily needs to have HazWOpER personnel on staff. I know that we do have both HazWOpER and HazMat teams and we have to do refresher training for both, annually. (per OSHA requirements, not ISO 14000)

 

[Randy]

Gene ask your registrar or whoever it is giving you that bogus tripe to get tested for suspected substance abuse. (Hopefully I haven't violated protocol here).

I'm a EHS professional by trade and education Gene (BS Occupational Health & Safety w/4.0 final GPA), I've personally managed ESH programs and have stood toe-to-toe with regulators and not one of my employers ever recieved a citation as a result of compliance inspections during my tenure, so I know something about this. I'm also presently qualified to Level A Operations for HAZWOPER and teach the subject as well as being an authorized OSHA Safety Trainer and and carry professional credentials from the National Safety Council. Above that let me say that I have probably spent close to 600+ hours this year alone presenting various ISO 14001 related training courses in the US and Canada, and I carry personal credentals in the field of EMS auditing. To say that I have a little practical knowledge in this area would be an understatement.

Upon my review of ISO 14001:1996 and in studying the new DIS ISO 14001 I feel safe in saying that HAZWOPER is not mentioned or required anywhere.

The requirements for HAZWOPER are soley based upon individual organizations status as a Hazardous Waste Generator, in being a TSDF or possessing the potential for emergency levels of uncontrolled releases of hazardous materials/hazardous wastes into the environment. The requirements for HAZWOPER training are specifically spelled out in 29CFR 1910.120 which has specific subparts concerning organizations, training requirements and other various topics. If your organization does not have the potential for what are considered to be emergency level spills you only need to meet the requirements for incidental spill release which basically consists of Hazard Communication Training, training on your organizations Emergency Action Plan and possibly specific training on the use of types of Personal Protective Equipment.

Title 40CFR (Environmental Protection) spells out in parts 262, 264, & 265 requirements for training of personnel involved in the various stages of Hazardous Waste management but does not state what the training "must" consist of, this information can only be determined by reviewing the applicable supporting regulations like 29CFR 1910.120 and 49CFR 172.

Clause 4.4.7 does not specify any specific training or regulatory requirements that have to be addresses in emergency planning and response. The requirement for this starts in 4.2 commitment to comply with relevent legislation, 4.3.2 by having a system of identifying applicable regulations and keeping current with them, 4.4.2 training, awareness & competence with special emphasis on understanding personal issues related to emergency operations, 4.4.6 having control mechanisms in place that prevent deviation from policy & 4.5.1 evaluation of regulatory compliance. This just names a few and this is not complete.

I can go on but I'll stop here and say that this is an issue that should be discussed with the registrar management with specific concern towards the competence of the auditor in question.

 

[GeneK]

Randy and crew , thank you for the information on HAZWOPER. Since I posted initially, I have had a couple of conversations with the registrar late yesterday.

Here is what was said. The reason that HAZWOPER was required was due to the fact that none to very few of our plant management and supervision have had any type of hazcom, hazmat, confined space, spills, etc training either internally or through outside services and yet we deal with paints, solvents, MEK, lacquer thinner, acids and many other hazardous chemicals in large quantities. No records existed and when interviewed their knowledge of how to respond to an emergency during the Stage I audits was weak at best. The auditors (4) believe that HAZWOPER (24 hour class) was the best buy for the money ($) to get management to understand, or obtain an understanding of the type of chemicals we are handling, versus having individual training on most of the categories under OSHA and emergency preparedness and response.

You may be wondering why the plants were so weak at the Stage I audit in this area? That is because the owner of our company assigned the task of getting the plants registered to ISO-14001 and the first 3 were to be done in 3 months. I had no previous experience with ISO-14001 and needed to document a Level 1, procedures and work instructions and get these plants ready. I felt that scheduling the Stage I and informing the auditor that we truely were not fully ready at least gave me the opportunity to get some hands on experience and learn what I needed to have in place for the Stage II registration audit. I have learned a lot in the last 2 years but there are still many questions that I don't even know that I need to ask yet.

 

[Randy]

If your registrar/auditor is providing solutions to issues the border has been crossed between impartiality/objectivity/independence to consulting and thats an ethics issue which is not acceptable.

The HAZWOPER solution as far as I'm concerned is not the appropriate method for making people aware. A more correct solution would be a well planned training program covering a variety of topics starting with your management being made aware of their civil & criminal liabilities regarding workplace safety issues and basic training on the Williams-Steiger Act of 1970, Public Law 91-596 and specifically clause 5.a.

Trust me when I say that HAZWOPER does not and will not suffice when it comes to appropriate and necessary training. Quite honestly if you are aware of this situation and are in a position of responsibility and don't take immediate steps to correct what is occuring you also have potential culpability in the event of unfortunate circumstances (in other words...pray that no one gets seriously hurt and regulators don't visit).

HAZWOPER ain't it!!!!!!

 

[SteelMaiden]

Trust me when I say that HAZWOPER does not and will not suffice when it comes to appropriate and necessary training. Quite honestly if you are aware of this situation and are in a position of responsibility and don't take immediate steps to correct what is occuring you also have potential culpability in the event of unfortunate circumstances (in other words...pray that no one gets seriously hurt and regulators don't visit).

HAZWOPER ain't it!!!!!!

HazWOpER is not, nor was it ever intended to be general training for awareness. I agree with Randy. I am trained in HazWOpER. In stands for Hazardous Waste Operations and Emergency Response. You certainly are not going to have every person in your facility trained to respond to a hazardous waste, the first thing you learn as a responder is to keep the general population away. Somebody is whack, and they may take you down with them. Be very, very careful about following a directive that uses HazWOpER training to satisfy Hazard Communication training.

 

[GeneK]

Thank you very much for your insight. I will work to rectify the requirement to more of a hazmat, hazcom, spill training, handling etc. vs the 24 hazwoper position. Great forum you folks have here and excellent advice.