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Section 6 - New Employee and Annual Update Training
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Initial and Annual Training Requirements
Who is covered?
Initial Training Requirements
Annual Update Training Requirements
Training Documentation Requirements
Guide to Training Your Employees
Initial and Annual Training Requirements
Minnesota Rules 7045.0454, 7045.0558, and Governor's Executive Order 91-17 require initial and annual hazardous waste and pollution prevention training for all University faculty, staff, and student employees who manage or generate hazardous waste. Initial training must be completed prior to the employee working with chemicals. Graduate student teaching assistants, research assistants, and undergraduate employees are considered University employees.
Contractors and subcontractors hired by the University must comply with all federal, state, and local regulations and laws. If contractors or subcontractors work with hazardous materials, they should provide documentation to University officials, demonstrating that all of their employees working on University property have received hazardous waste generator training.
Students must be trained by their instructors, or departmental safety officers, on how to manage hazardous waste in their teaching laboratories or research areas. At this time, training documentation is not required for students.
Who is covered?
Any employee who:
- uses chemicals and may have the need to dispose of chemical waste
- supervises employees or students who work with chemicals
- fills out waste packing forms or labels for hazardous waste containers
- transports hazardous waste
- trains others in proper hazardous waste management at the University of Minnesota
- responds or assists in the response to chemical releases or spills
- controls a program, process, or piece of equipment that generates a hazardous waste, releases chemicals to the air, sanitary sewer, or surface waters of the state of Minnesota
Initial Training Requirements
Use of the U of M Hazardous Chemical Waste Management Guidebook
- hazardous waste definitions (Part 2)
- who to call for hazardous waste information (Part 1)
Preparing waste for collection (Part 4)
- hazardous waste evaluation - using the Waste Registry
- closure of containers
- labeling of hazardous waste storage containers
- storage of incompatible wastes - separate by tray, cabinet, room, etc.
- completion of the waste packing forms
- contacting the Chemical Waste Program for waste collection
Other compliance issues (Part 2)
- container inspections - weekly for non-satellite
- secondary containment for free liquid wastes
- no hazardous waste allowed in trash or salvage dumpsters
- who to call for approval to sewer nonhazardous chemicals
- evaporation of chemical residues is not allowed
Emergency chemical spill response procedures - 911 (Part 3)
Management of problem wastes - unknowns, batteries, etc. (Part 5)
Pollution prevention techniques (Part 7)
Self auditing procedures (Part 8)
Annual Update Training Requirements
Annual update training should include the following:\
- review of initial training
- changes to the University Chemical Waste Program procedures or requirements
- recent notices of violations (NOVs) from EPA, MPCA, or county hazardous waste officials
- new pollution prevention techniques
Training Documentation Requirements
Document initial and annual update training using the form included in this section. Please photocopy the form (see Appendix II). Copies of the signed initial and annual update hazardous waste generator training records should be kept in your department's head office.
Records must be kept for at least three years past the termination date of a University employee's employment.
Alternative methods of documenting training are acceptable, e.g. electronic files, scanned files, microfiche, etc.
Records must be made available upon request by federal, state, or local hazardous waste inspection officials, or University Auditing or Environmental Health and Safety officials.
Guide to Training Your Employees
- Attend the Lab Safety Training in-person session offered by the Department of Environmental Health and Safety on a monthly basis. Or take the online version, called New Employee Safety Training.
- Review the Hazardous Waste Management Guidebook. If you have any questions, about the materials, please contact DEHS.
- Then train your employees using DEHS's Chemical Waste Mangement online tutorial.
- Anticipate what questions you might be asked. Frequently asked questions include:
- Is there any cost to have my unwanted chemicals collected?
No, the Chemical Waste Program (CWP) only charges if a department asks CWP to label and package their chemicals for waste disposal, rather then using their own personnel to do these tasks. - What do I do with unlabeled chemicals?
Call the Chemical Waste Program at (612) 626-1604, or e-mail at hazwaste@tc.umn.edu. - What do I do about old chemicals that might be shock sensitive, such as old ethers?
Call the Chemical Waste Program at (612) 626-1604, or e-mail at hazwaste@tc.umn.edu. - Is this ________ (specific name of a chemical or piece of equipment) considered a hazardous waste when I throw it out?
Call the Chemical Waste Program at (612) 626-1604 or e-mail at hazwaste@tc.umn.edu to find out. - How do I find out the status of my waste collection order?
Call the Chemical Waste Program at (612) 626-1604 or e-mail at hazwaste@tc.umn.edu to find out. - Can I sewer (or trash) this chemical, e.g. 10% ethanol?
Call the Chemical Waste Program at (612) 626-1604 or e-mail at hazwaste@tc.umn.edu to find out. (This is a complicated issue from a regulatory standpoint, so it is best to let the Chemical Waste Program answer these questions, e.g. 10% ethanol - no, 5% - yes, but regulations do not allow people to dilute waste streams to get them to allowable sewer discharge limits, so 10% ethanol solutions should be collected and sent in as hazardous waste.)
- Is there any cost to have my unwanted chemicals collected?
- Prior to doing the training, it helps to review what research or service is being done in the areas you'll be training, to get an idea of the type of chemical waste that is generated and how those wastes should be reported on University hazardous waste labels and waste packing forms.
- If you get a question you can't answer, always tell people you'll get back in touch with them after you talk to the Chemical Waste Program for advice. Make a point of getting the information back to the people who raised the question. Also, make sure people know how to contact the Chemical Waste Program, (612) 626-1604 or e-mail at hazwaste@tc.umn.edu, in case they have questions in the future.
- Document the employee's training immediately, by having the employee and the instructor sign the training form, certifying the training was completed. The signed form should go to the employee's departmental head office for storage. Regulatory inspectors will go to an employee's head office to review these training documents during their inspections.
- If you have problem employees or people who do not want to attend training or certify their training, discuss this with your department head or the Department of Environmental Health and Safety. Under the University President's and Provost's Environment, Health and Safety Roles, Responsibilities and Requirements document, it is every employee's responsibility to comply with federal, state and University environment, health and safety regulations and policies. Fines are the responsibility of the department in which the violations occurred.
- The Chemical Waste Program can train your safety officers in how to conduct hazardous waste compliance audits and reviews of training documentation.