Significance and Use
This guide is written for all persons involved with HHWCs, but especially for those primarily responsible for establishing and providing training to workers at HHWCs. This guide is intended to provide recommended training topics which should be covered during the initial baseline and annual refresher training. The actual topics and depth of training for each worker must be assessed by the HHWC operator on a case-by-case basis with emphasis on the particular job assignment for each worker. The major factors the operator should consider are what are the anticipated hazards to which each worker may be exposed and what are the controls/work practices which the worker must know in order to do his or her job assignments safely.
Another factor which the operator must consider is the areas in which each worker is expected to work or the areas to which each worker has access to as part of job assignments. For example, if an administrative assistant only has access to the office area, and never enters the active HHWC area, then training may be limited to required actions as part of the contingency plan. If, however, the administrative assistant is periodically required to enter into the active HHWC area, more detailed training is required based on anticipated hazards which the administrative assistant may be exposed to while in the HHWC area.
When deciding on the training topics for the annual refresher training, the HHWC operator must decide on topics in Section 7 which are relevant to the HHWC workers attending the refresher training class. Factors which should be considered are:
4.3.1 Hazards to which the workers may be exposed to,
4.3.2 Changes in the standard operating procedures, contingency plan since the previous training,
4.3.3 Length of time from which a worker has received training in the topics listed in Section 7, and
4.3.4 Identification of incidents, hazards, unsafe conditions, or any other situations which indicate a need to retrain workers in a particular topic to ensure a safe and healthful workplace.
Scope
1.1 This guide covers recommended health and safety training topics for workers at operations for the collection of household hazardous waste or conditionally exempt small quantity generator waste, or both, regardless of the type of collection. Although this guide is intended to protect the worker, public health, and the environment, it is not intended to satisfy all the health and safety training requirements under the Occupational Safety and Health Act of 1970 or the Resource Conservation and Recovery Act of 1976. Additionally, local and state requirements may also vary. Therefore, it is recommended that the operator of a household hazardous waste collection operation also check federal, state, and local regulations for additional requirements.
This standard does not purport to address all of the safety concerns, if any, associated with its use. It is the responsibility of the user of this guide to establish appropriate safety and health practices and determine the applicability of regulatory limitations prior to use.