HWF NOTES ©
This month's HWF Notes is written by Bill Gabbard. Bill is President of Gabbard Environmental, Inc. GCI and Gabbard Environmental have worked together on many projects, including the recent BIF Compliance tests. This issue will focus on some of the new 1993 environmental or regulatory compliance matters:
- DOT Hazmat Training (April 1, 1992 deadline)
- DOT Proper Shipping Names (October 1, 1993 deadline)
In addition, we will pass along fresh information on the Community Right-to-Know Program (SARA Title III) report for this year known as the July 1 "Toxic Release Inventory" Report.
DOT HAZMAT TRAINING
The Department of Transportation's stated objective is:
"To ensure that each hazmat employer trains hazmat employees regarding safe loading, unloading, handling, storage and transporting of hazardous materials and emergency preparedness for responding to transport-related hazmat accidents or incidents."
A program guide sheet has been attached for additional information. Here are the cement plant situations covered by this new rule:
- Unloading of gasoline into the yard equipment fuel storage tanks.
- Receipt and unloading of blasting compounds and supplies.
- Other miscellaneous plant receipts; propane, some welding or cutting gases, maintenance shop parts washer solvent, plus any of the grinding aids that get shipped as Department of Transportation hazardous materials.
A hazardous waste fuel blending facility will have nearly all its inbound receipts and outbound loads transferring residues to other facilities covered by the rule. The only exception may be used oil.
DOT did not establish minimum standards or specifications for the amount, duration or depth of training required. It is up to each company to determine its own training needs.
Waste fuel facilities will be able to substitute their RCRA employee hazardous waste training covering hazards awareness, use of personal protective equipment, safe work practices, emergency response procedures and related subjects for the corresponding DOT training requirement as long as the work is documented. The DOT inspector should be able to see:
- An identification of the employee training session including the time and date and name of the instructor.
- The outline or written narrative of the material covered.
- Some type of short quiz or test that helps evaluate the effectiveness of the training.
Areas that may not be covered by current hazardous waste training could be for the "person who marks and labels packages" and the "person who fills out shipping papers".
April 1, 1993 is the deadline for completing the DOT hazmat training. New employees need to be trained within 90 days of their hire date, and refresher training is a two-year requirement.
For additional details, see the Federal Register, May 15, 1992, page 20944.
PROPER SHIPPING DESCRIPTIONS
October 1, 1993 is the next deadline in the Department of Transportation's five year program to convert packaging, labeling and shipping description specifications over to the international standard.
Use of the international shipping description format is now optional, and at least one national reclaimer is already switching over to the revised descriptions. Here are examples:
Waste Acetone, Flammable Liquid, UN 1090, (F003)
RQ Waste Flammable Liquid, N.O.S., UN 1993, (Xylene, Toluene), (F003, F005)
Waste Acetone, 3, UN 1090, PG II, (F003) RQ Waste Flammable Liquid, N.O.S., 3,
UN 1993, PG 1, (Xylene, Toluene), (F003, F005)
It has been common practice for the waste handler to take care of the customer's shipping documents. Companies providing this service will need to have the new descriptions in use by October 1, 1993.
JULY 1 "TOXIC RELEASE INVENTORY" REPORT
Cement plants are covered by this annual reporting requirement for certain blasting compound ingredients and for components of grinding aids as well as several hazardous waste fuel compounds.
Gossman Consulting, Inc. publishes a detailed step-by-step working document for preparing the July 1 report. Contact the Hampshire office if you would like additional information.
The U.S. EPA reports that they have no plans for any significant revisions to the report covering 1992 operations (due date July 1, 1993).
HAZMAT TRAINING RULE
The purpose of this new rule making is to ensure that each hazmat employer trains hazmat employees regarding safe loading, unloading, handling, storing and transporting of hazardous materials and emergency preparedness for responding to transport-related hazmat accidents or incidents.
HAZMAT EMPLOYER means one that uses one or more of its employees in connection with:
HAZMAT EMPLOYEE means a person who is employed by a hazmat employer and who in the course of employment directly affects hazardous materials transportation safety. The term includes an owner-operator of a motor vehicle which transports hazardous materials in commerce. This term refers to an individual, including a self-employed individual who, during the course of employment:
Some specific examples of who will be required to be trained are:
This final rule became effective July 1, 1992 and compliance with the new amendments was authorized immediately. Training for hazmat employees employed on or before November 15, 1992, must be completed prior to April 1, 1993. Training for a hazmat employee employed after November 15, 1992, must be completed within 90 days after employment.
Each hazmat employee must repeat the required training at least once every two years.
A hazmat employer shall ensure that each of its hazmat employees is tested by appropriate means on the training subjects covered in §172.704.