A fill in the blank model plan designed for facilities with relatively small, simple hazardous materials and hazardous waste operations is included in the HMBP form (Appendix K). If you have questions about the applicability of the fill in the blank form to your operation, please call the Fire Department at 925.454.2338.
The following instructions are organized to follow the format in the blank form. You may also use these instructions as a guideline for developing your plan format or for ensuring your existing plan meets all the regulatory requirements.
The fill in the blank form and these instructions only to address the requirements of the Hazardous Materials Business Plan and Hazardous Waste Generator Program requirements. Your business may be subject to other training requirements (Illness and Injury Prevention, Hazard Communication, etc.). If you wish, you can use this form and its instructions to combine the Hazardous Materials Business Plan and Hazardous Waste Generator Program requirements with those of other programs to produce one training plan that satisfies several requirements.
The plan should identify who is responsible for ensuring the provisions of the plan are carried out. This can be one person or responsibilities can be divided up with one person responsible for the overall plan with individual tasks delegated to other individuals. The plan should at a minimum identify the individual with overall responsibility.
3. New Employees
The plan must contain provisions for ensuring that appropriate personnel receive initial training. This includes ensuring workers are trained in handling hazardous waste within six months of starting a job and are supervised by a trained individual until their training is complete.
4. New Assignments and Changes in Operations for Existing Employees
In the event of new assignments or changes in operation for existing employees, training must be provided before the new assignment or change in operation takes place.
5. Refresher Training
The plan must contain provisions for ensuring that personnel receive refresher training (at least annually for hazardous waste operations). Refresher training can be accomplished in a variety of ways including safety meetings and/ or classes.
6. Training Topics - General
The regulations require the topics listed in this section be covered at all facilities:
- Methods of safe handling of hazardous materials
- Emergency response including:
- The Emergency Response Plan
- Procedures for coordination with local emergency response organizations
- Use of emergency response equipment and supplies this employee may use
- Procedures for using, inspection, repairing, and replacing facility emergency and monitoring equipment for which this employee is responsible
- Communication and alarm systems
- Response to a release or threatened release of hazardous materials (what is expected of this employee and what can the employee expect others to do)
- Response to fires or explosions
The following topics must be covered at all facilities which generate hazardous waste (including waste oil):
- Hazardous Waste Management
- Response to fires or explosions
- On-site management and storage requirements
- Proper use of safety equipment
- Proper use of hazardous waste management supplies
- Off-site transportation requirements
- Interaction with waste haulers and disposal sites
- Conducting periodic inspections
- Response to ground water contamination incidents (if applicable)
- Shutdown of operations (if applicable)
7. Training Topics - By Job Title
While all the topics listed in Section 6 must be covered at this facility, not every individual must be trained in each topic. Training given to each individual will be commensurate with the tasks assigned to that employee. For example an employee who physically handles hazardous wastes, but does not fill out or manage manifest, needs training in safe handling but not manifesting, while the clerical person who is responsible for the manifest needs training in manifesting but not in handling waste.
For jobs involving hazardous waste management or handling, hazardous waste generators must maintain:
- The job title and the name of the employee(s) filling that position
- A written job description that includes the requisite skill, education or other qualifications and duties of employees assigned to each position
- A written description of the type and amount of training - both introductory and ongoing that each position is to receive.
The Fire Department has a form that can be used to document this information.
8. Training Documentation
Training must be documented. The Fire Department has model forms - one for initial training and one for refresher training - that can be used to document training.
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.
The plan should specify where these records will be kept.