Chemical waste training in laboratories

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• Introduction
• Background—Is the inspector there to help you? You may be surprised!
• What are the objectives of RCRA training?
• How similar are OSHA and RCRA training requirements?
• What are the shortcomings of current training requirements? How can they be addressed?
• Is there a fundamental difference between safety and compliance training for laboratories?
• What training should individuals receive?
• Can/Should RCRA and OSHA training requirements be harmonized?
• A different approach to training
• Training a diverse audience
• Chemical waste training outline for laboratory workers
• Students and volunteers
• How can training be delivered?
• How can training be measured?
• Summary

Introduction

Hazardous waste training is too narrowly focused to be sufficient in laboratories. Many unwanted chemicals do not meet the regulatory definition of hazardous waste but, nonetheless, present significant hazards to people and/or the environment. Therefore, this paper broadens the focus to include training issues in chemical waste management including both regulated and non-regulated materials.

Given the specificity of chemical waste regulations, it is sometimes hard to remember that the wastes are still chemicals. Laboratory workers, however, find it very difficult to distinguish between regulated and unregulated chemicals. The laboratory viewpoint is that the rules control disposal of unwanted chemicals. Therefore, safety practices in the laboratory will be substantially the same whether a chemical is wanted or unwanted.

The purpose of the discussion is to compare the coverage of existing chemical training rules, identify alternatives and suggest good training practices and appropriate sets of recipients to create efficient and effective training systems. The purpose is not to propose increased or decreased regulation. Rather, the purpose is to show and explain elements that can make training more effective at producing the desired results. To help establish a neutral perspective, the discussion begins with a reminder that good regulations deliver benefits.

The paper proposes objectives for chemical waste training and reviews the overlap, and gaps, between OSHA and RCRA training requirements. There are far more gaps than overlap. RCRA training requirements focus almost exclusively on emergency response with the exception of provisions in the rules for the New England XL project, which covers only three of the approximately four thousand college and university campuses in the U.S.

Performance oriented training requirements focus training on individual needs rather than on a set of generic requirements. A flow chart helps consider a process to determine training content. Neither current OSHA nor RCRA rules are sufficient because the former has limited geographic coverage and does not deal with environmental concerns while the latter covers a limited subset of workers. Neither provides direct protection to students or volunteers.

The paper concludes with a discussion of ways to deliver and evaluate training.

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Background—Is the inspector there to help you? You may be surprised!

It is easy for those of us in the regulated community to complain about inspectors, focus on the burden of compliance and overlook the essential functions performed by regulatory agencies. Often we complain about unnecessary paperwork and say, “Leave us alone so we can get the ‘real work’ done.”

But there is an inescapable truth that people perform better when they are watched and encouraged to do things right. That’s why management exists, why sports events have referees and why it’s easier to win games in front of the hometown fans. As any sports referee will confirm, wherever there are penalties, relationships can become adversarial, but the fact remains that neither the game nor the referee can exist without the other.

Well-enforced regulations help reassure the general public and legislators that we are doing things right. Well designed regulations and positive inspection results help relieve public fears and help us respond to interest groups by providing a basis to start discussions. Although both groups often forget, regulators and regulated share a common interest in advancing public understanding, building public confidence and recognizing high-quality efforts.

A regulatory agency needs information if it is to make judgments and reassure the public. A full-time inspector on site, as practiced by the USDA in meat packing plants, is generally neither desirable nor financially feasible. That means we must keep records and share them with inspectors.

Finally, well enforced regulations create a level playing field for competitors. Compliance is rarely free, but if everybody is treated attentively and equally, regulation will not affect our competitive position.

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What are the objectives of RCRA training?

Reasonable objectives for training in chemical waste management include providing appropriate employees with knowledge and skills to protect public health and the environment by:

• Handling unwanted chemicals safely at all times (in laboratory, satellite accumulation areas, during transportation, in intermediate and central accumulation facilities, etc.)
• Responding safely and effectively to spills and other emergencies
• Performing waste treatment procedures properly and safely
• Reducing environmental risks
• Complying with regulations
• Creating a proper paper trail to demonstrate compliance

In addition, the employer has an interest in training that will assure waste management is cost effective as well as environmentally protective.

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How similar are OSHA and RCRA training requirements?

The OSHA Lab Standard (29 CFR 1910.1450) ^[1] interfaces with RCRA in the laboratory and also carries training requirements. OSHA focuses on protecting the safety and health of the employee and other nearby employees while RCRA focuses on emergency response and environmental protection.

Table 1 compares the training requirements of the OSHA Hazard Communication and Lab Standards, the EPA New England Universities Project XL rule and EPA RCRA facility training. The order of the rules is rearranged to put generally similar training requirements in the same row.

Clearly, the OSHA Lab Standard focuses on employee health and safety while the EPA rules focus on emergency response and environmental protection. Nonetheless, overlap is significant because OSHA does not distinguish between wanted and unwanted chemicals. Therefore, the OSHA Lab Standard protects the health and safety of lab workers as they handle RCRA-regulated waste.

Among the EPA provisions, only the New England XL rule contains significant provisions for the health and safety of laboratory employees; the rule is temporary and applies only to three medium-sized universities in New England. The other training requirement that applies to generators (40 CFR 262.34(d)(5)(iii)) only applies to those who generate 100-1,000 kg per month and wish to extend storage time from 90 to 180 days. Training requirements for other generators are imposed by reference and have little applicability outside of a central hazardous waste facility. EPA has stated that many of these facility-related requirements apply to waste treatment in laboratories ^[2], but the applicability and relevance in the laboratory setting are unclear.

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What are the shortcomings of current training requirements?
How can they be addressed?

The training requirements of the OSHA lab standard are restricted to laboratories, as the standard (29 CFR 1910.1450(b)) defines a laboratory:

Laboratory means a facility where the “laboratory use of hazardous chemicals” occurs. It is a workplace where relatively small quantities of hazardous chemicals are used on a non-production basis.

Laboratory scale means work with substances in which the containers used for reactions, transfers, and other handling of substances are designed to be easily and safety manipulated by one person. “Laboratory scale” excludes those workplaces whose function is to produce commercial quantities of materials.

Laboratory use of hazardous chemicals means handling or use of such chemicals in which all of the following conditions are met:

(i) Chemical manipulations are carried out on a “laboratory scale;”

(ii) Multiple chemical procedures or chemicals are used;

(iii) The procedures involved are not part of a production process, nor in any way simulate a production process; and

(iv) “Protective laboratory practices and equipment” are available and in common use to minimize the potential for employee exposure to hazardous chemicals.

 The OSHA definition of “laboratory” does not include “photo labs,” art studios or other areas of interest to colleges and universities. ^[3] In non-laboratory areas, the OSHA Hazard Communication Standard (29 CFR 1910.1200) applies. Therefore, the OSHA definition of laboratory needs modification to meet the needs of higher education.

OSHA standards only apply to public employees in 21 states that have signed enforcement agreements with the agency, Puerto Rico and the U.S. Virgin Islands. In contrast, EPA rules apply to all employees in all states.

As discussed in more detail below, neither OSHA nor EPA rules contain protections for students or volunteers.

As illustrated in the previous section and in Table 1, EPA training rules that apply to the health and safety of laboratory workers are very limited. Serious problems have arisen, however, when enforcement officers have attempted to insist that laboratory workers know, for example, all the rules needed to make a hazardous waste determination.

Despite the limited explicit requirements for training about EPA rules, successful operations clearly require that some employees be extremely knowledgeable about these complex rules. Successful RCRA programs have regular training and review programs for central facility workers. These workers are few in number, generally have low turnover, use the knowledge frequently and the information is central to their work—all conditions that help increase training success. Unfortunately, some past EPA interpretations of its training rules have required training of nearly all personnel who relate to regulated waste in any way, without regard to their roles or needs. ^[4] The interpretation has varied, however. ^{[5], [6], [7]}

There is a precedent for EPA to adopt the rules of other agencies into the RCRA rules. It has done so with DOT rules at 40 CFR 263.10 to extend coverage of DOT rules to the public sector. The New England XL Project rule borrows concepts and language from the OSHA Lab Standard. Although EPA has given limited attention to employee safety in previous rulemakings, the New England XL project creates a precedent for EPA to adopt OSHA language.

Among the four sets of training requirements, only the rules for the New England XL project explicitly allow the employer significant latitude to focus training to fit the duties of the trainee. And yet we know that students and trainees typically retain only a small portion of the information they receive—estimates run as low as ten percent retention after one month.

Most adults want information that is relevant to their work. They fail to connect with and do not retain material they perceive as irrelevant. Therefore, regulations that prescribe training content without regard to the needs of the individual will fail. The trainee will become inattentive and may retain the wrong information. Both efficiency and effectiveness require training that is focused on the needs of the individual. Of course, optional background or detail should be easily available for those who want more information.

In summary, although the New England XL rule comes closest to allowing the employer to fit the training to the actual needs of the worker, none of these training rules require the employer to analyze the health and safety training needs of the individual worker. Only the New England XL rule begins to encourage training that is customized to the needs of the individual.

This discussion resumes after the table with suggested logic for determining content and discussion of training-related issues including rule coverage, training delivery and evaluation.

Table 1 is a parallel layout of the three rules discussed above and, for comparison, the OSHA Hazard Communication Standard.

If Table 1 doesn’t display properly (known problem with Internet Explorer 6 browser), here is a version that will work.

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Is there a fundamental difference between safety and compliance training for laboratories?

Yes, for at least two reasons.

First, laboratory safety tends to be situational and risk based, while regulations generally establish an absolute minimum for compliance. In other words, laboratory safety has many shades of gray while compliance is black or white. Someone who uses a pipetter most of the day every day needs to be aware of possible ergonomic problems while someone who uses a pipetter for a few minutes a week rarely needs to be concerned. In contrast, anyone who pours hazardous waste out the back door is in violation, regardless of the quantity. Training needs to clearly identify the regulatory absolutes.

Second, despite generally strong efforts by regulation writers, regulations don’t necessarily make sense from the scientist’s point of view. Rule-making usually lags well behind scientific knowledge because of the time required to pass enabling legislation and to move through the rule-making process. Special interests sometimes work to delay rules that threaten established lines of business or ideology. After a regulation is finalized, office staff and enforcement officers must be trained to give consistent interpretations.

Of course, some rules don’t make scientific sense from the beginning because of honest error or haste required by public outcry or legislative mandate. Laboratory scientists tend to be sensitive to scientific inconsistencies, outdated definitions and extra work introduced by regulations. For example, the RCRA P and U lists are always good for a spirited discussion. Trainers need to be prepared to address their questions honestly.

In many, if not most, cases there is reasonable harmony between regulatory compliance and good laboratory safety practices. But even regulations that contribute little or nothing to safety in the laboratory and require extra effort are not necessarily bad. For example, many hazardous waste regulations protect the external environment, clearly a valuable objective even if it requires extra effort in the laboratory. Most EH&S programs design their services to minimize the burden on laboratories but the burden cannot be eliminated.

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What training should individuals receive?

The flow charts in Figure 1 are based on the principle that workers only need training that is relevant to their work.

Figure 1: Flow chart showing a process for identifying training needs. [text version]

* This situation creates a dilemma. The stated mission of EPA is “...to protect human health and the environment.” Nonetheless, current RCRA training rules do not explicitly address the health and safety of RCRA workers or laboratory workers. There is implicit health protection in emergency response training requirements. OSHA rules address workplace health and safety in a much broader way and do not differentiate between wanted and waste chemicals; however, public sector workers are only covered in states with OSHA enforcement agreements (Twenty-one states, Puerto Rico and US Virgin Islands). Some states have adopted rules similar to OSHA rules to cover public sector employees although enforcement practices vary. Colorado, Georgia and perhaps other states have no workplace protection rules for public employees. This discussion continues in the next section.

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Can/Should RCRA and OSHA training requirements be harmonized?

The OSHA Laboratory standard (29 CFR 1910.1450) is a good example of a performance-oriented standard that already applies to laboratories, albeit with coverage limitations noted above. Laboratory workers and supervisors change employers and geographic locations, as do other people. Consistent rules reduce confusion and improve safety and compliance. Overlapping rule coverage between agencies creates serious problems for the regulated community because interpretations and enforcement policies will inevitably differ, as illustrated by the history of EPA/NRC regulation of low-level mixed waste.

One regulatory approach is for EPA to adopt and apply the OSHA lab standard to those workplaces that meet the OSHA definition of laboratory but are not covered by OSHA regulations, at least with respect to chemical waste management. Of course, students and volunteers would not be covered and the selection of work areas that the hazardous waste rules should cover is broader than that covered by the lab standard. There is a partial precedent because EPA used this approach in the New England XL rule. The XL rule extends OSHA-like protections to laboratories in the two Massachusetts universities covered by the XL rule. Vermont, where the third university is located is an OSHA plan state and is already subject to OSHA rules, making the EPA safety training rules redundant.

For EPA purposes, a new rule may need to explicitly require that waste management and emergency response be addressed as well as extending the definition of “laboratory” to additional workplaces. From the viewpoint of the regulated community, it is very important that EPA avoid overlap with OSHA. The difficulties with low level mixed waste (radioactive RCRA waste) illustrate the pitfalls of overlapping regulations. Therefore, a training rule would need conditional provisions according to the state in which a facility is located.

The OSHA lab standard requires the appointment of a Chemical Hygiene Officer who “...is designated by the employer, and who is qualified by training or experience, to provide technical guidance in the development and implementation of the provisions of the Chemical Hygiene Plan.” While the definition leaves a great deal of latitude, technical competence in chemistry is clearly required if the Chemical Hygiene Officer is to give “technical guidance.” The National Registry of Certified Chemists has developed a certification process including an examination based on this premise. ^[8]

There also remain to be addressed many facilities that EPA or the regulated community may wish to consider laboratories, but are not included under the OSHA definition. Examples include quality assurance labs, photo labs, small pilot plants, certain art facilities, document restoration facilities and perhaps other administrative units based on their support for laboratories or for institution-wide uniformity. Some of these facilities have the chemical expertise typical of research and teaching laboratories while others do not. Nonetheless, in colleges and universities, it is hard to imagine a place where the requisite technical expertise would not exist within the institution and nearby. Therefore, the methodology used by the OSHA lab standard could be extended to chemical waste management in laboratories, art studios and photographic darkrooms by requiring the Chemical Hygiene Officer or perhaps a “Chemical Waste Officer” to have the requisite authority and expertise to assure proper management of the chemical wastes.

Finally, at a time when non-English-speaking workers are increasingly common in our workforce, neither OSHA nor EPA rules address multi-lingual training needs.

The shortcomings of present regulations do not imply that laboratories are full of untrained people with many safety problems. We can reasonably assume that laboratory workers understand safe handling procedures for the chemicals in their labs. Most incoming lab workers will have extensive laboratory experience as students or in previous employment. The safety performance of research laboratories is quite good. If that were not so, there would be accidents that would cause administrative intervention and/or unacceptable research failures.

In summary, we can postulate ways to bring EPA rules and the OSHA lab standard together in a way that leads to uniform regulation of training. Nonetheless, the complex differences, limitations and frequent opposition to OSHA make this difficult and insufficient. This is an opportunity to develop a performance-oriented rule based on sound principles of delivering and analyzing training.

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A different approach to training

As stated several times previously, the laboratory worker viewpoint is that the physical and chemical properties of a substance or a mixture are the same, whether it is wanted or unwanted, therefore, the safety precautions are the same. RCRA workers understand that the regulatory properties of an unwanted material may differ substantially from those of a chemical in inventory or active use. Efficient training related to chemical waste management will build a training program from these starting points. To the extent possible, the need for RCRA training of laboratory workers should be minimized. Extensive RCRA training should focus on the much smaller group of workers who will collect, transport and process the waste. Fewer people, lower turnover and constant use of the information all support successful training in this group.

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Training a diverse audience

Laboratory workers cover a continuum from students to researchers with many years of experience, a much broader range of knowledge and skill than found in typical industrial settings. “One size fits all” training will fail in this setting. Nonetheless, there is certain information that everyone must know to handle chemical waste properly. The essential information can be simplified but it cannot be eliminated.

Examples of typical university laboratory workers taken from the continuum include:

• Principal investigator (administrator)—Usually a Ph.D. with many years of experience. Spends little time in the lab but provides the leadership that is producing success. Leads by motivating staff and has ultimate authority over personnel. Needs to exhibit commitment and support for good waste management practices but rarely, if ever, handles waste.
• Principal investigator (hands-on)—A Ph.D. with few to many years of post-doctoral experience, but with at least undergraduate, graduate and probably post-doctoral laboratory experience. More likely to take an active role in laboratory work, leading by example as well as by motivation and authority.
• Lab manager—Many years of laboratory experience and usually an advanced degree. A continuous presence in the lab and usually a hands-on person.
• Lab worker—Several years of lab experience when hired. May or may not have advanced degree.
• Lab support person—May have little or no lab experience when hired. Typically performs support functions such as monitoring automated machinery, glassware washing, etc.
• Post-doctoral student—Recent Ph.D gaining experience in a specific area of research. Has at least undergraduate and graduate lab experience. The average turnover is about four years.
• Graduate student—Will start with undergraduate lab experience and usually remains in the lab for one to six years. The average turnover is about four years.
• Student employee—Part-time employee that usually has some undergraduate laboratory experience but may start with no lab experience. Average turnover is usually 2–3 years
• Student or volunteer—Usually in the lab part-time to do a specific piece of research or to gain résumé-building experience. May have some undergraduate lab experience to start. Usual turnover is one to two semesters.

These examples demonstrate the wide range of candidates for chemical waste training and also indicate that turnover is greatest for the least experienced. To meet these two challenges, chemical waste training must be both concise and easy to understand. In addition, conflicting schedules make classroom training difficult to accomplish.

Successful Environmental Health and Safety programs use a variety of methods including informal meetings, reference manuals and posted signs as well as formal training sessions and web based materials to build knowledge.

The diverse audience and diverse training methods make training documentation very difficult. Therefore, most EH&S programs believe that the success of training should be judged by the actual performance of the laboratory. Training session attendance can be documented but only work practices will determine that.

Relatively few EH&S programs make heavy use of posted signs or checklists to encourage proper chemical waste management, perhaps because they fear that a concise summary will omit some of the complex requirements of the current rules. However, by simplifying the role of the lab worker, reminder signs can become a potent tool to encourage compliance. Aviation safety has long recognized and benefited from extensive use of placards and checklists.

Universities have many students and staff for whom American English is not their native language. While most can read English well, their ability to speak or understand spoken English is sometimes poor, especially for new arrivals. Another advantage of reminder signs is that translation into other languages is relatively easy, compared to translation of classroom sessions.

The next section assumes an active, customer oriented EH&S program and proposes a training outline and reminder sign to build and maintain a compliant program.

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Chemical waste training outline for laboratory workers

Here is an outline of a chemical waste training program to be presented to laboratory workers. Information details will vary between labs, so some of these points may be unnecessary or additional details may be needed:

1. We need to protect the environment: We must handle chemical waste and unwanted chemicals in ways that protect the environment and meet the requirements of government regulations. There are civil and criminal penalties if we fail to do this. [Our institution] provides services to make this as easy as we possibly can.
2. Definition: When we say “chemical waste” we mean wastes from experimental work, material cleaned up from chemical spills, outdated reagents and any other unwanted chemicals, products or byproducts.
3. No drain disposal: Never put chemical waste down the drain unless you have written permission from Environmental Health and Safety to sewer that specific material.
4. Where? There is a place in your lab to put unwanted chemicals. You need to know where it is.
5. Our service: [Environmental Health and Safety] collects chemical waste for disposal by environmentally safe methods. We need your help to do this safely
   1. Safe containers: Put the waste in containers that are sound and won’t be attacked by the waste if stored for a few months
   2. Tight caps: Cap the containers tightly. (If the waste might off-gas and build up dangerous pressure in the container, pre-treat it for safety or attach a highly visible warning tag and leave the cap loose. Place the container in a ventilated storage cabinet or fume hood if the emissions are hazardous)
   3. Secondary containment: Preferably place in secondary containment pans to prevent a big mess if a container cracks.
6. Solvents: You may pour compatible solvents into the carboys that we supply (May be a separate carboy for chlorinated solvents)
7. Separate incompatibles: If two materials will react dangerously if mixed, separate the containers and preferably place them in separate secondary containment pans especially if the amounts are greater than 1 liter or 1 kilogram.
8. Label: Each container must be labeled with
   1. Name: The chemical name of the contents (your best estimate if it is a mixture)
   2. Metals: We need to know if the waste contains any of these metals—Ag, As, Ba, Cd, Cr, Hg, Pb, Se
   3. Hazards: Hazard information if you know it
9. Call for pickup or more information: To have your waste collected, call XXX-XXXX or go to [web address] if your lab is not on a regular pickup schedule. For more information, call XXX?XXXX or email [chemsafety@foobar.edu].

An example of a reminder sign is in Figure 2.

Figure 2: Sample reminder sign for in-lab chemical waste location. text version

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Students and volunteers

Students who are employed and working in their role as employees are considered employees. Neither OSHA nor EPA rules contain any provisions that suggest student status affects regulatory coverage of paid employees.

However, OSHA rules only cover people working as paid employees. OSHA regulatory interpretations consistently state that students, volunteers and other unpaid persons are not covered by OSHA rules.

Students are generally not covered by EPA rules, because the rules consistently refer to “workers.” The New England XL rule is a limited exception. 42 CFR 262.105 defines “laboratory worker” as “a person who is assigned to handle hazardous chemicals in the laboratory and may include researchers, students or technicians.” Unfortunately, the rule only covers students in laboratories at the University of Massachusetts—Boston, Boston College and the University of Vermont.

Nonetheless, colleges and universities make every effort to provide levels of protection for students that are equal to or greater than those provided to employees. Clearly, good practice demands this level of protection. In addition, students are not limited in their ability to sue for damages in case of injury. Employees’ rights of recovery are limited by workers’ compensation laws.

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How can training be delivered?
What are the relative advantages and disadvantages?

Table 2: Advantages and disadvantages of various training delivery methods.[Linearized table 2]

	Flexibility to individualize information coverage	Flexibility to individualize pace	Ease of testing retained knowledge	Relative cost per trainee
Individual	++++	++++	++++	Very high
On-the-job	++++	+++	++++	High
Classroom	+++	+	+++	Medium
Video	-	-	+	Low
Computerized	+	++	++	Low
Computerized interactive	++	+++	+++	Low

Where individual or on-the-job training is infeasible or unsafe, computerized, interactive training delivered via the internet is gaining favor because it allows users to view training at their own pace and at a time and place of their choosing. Computerized and internet based training can also be designed to test knowledge, record results and record attendance.

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How can training be measured?

1. By stakeholders?
   1. Quiz at the time of training—Objective data and a well-designed quiz assists information retention. But a quiz at the time of training does not test retention and it does not assure that knowledge will be integrated into behavior. Nonetheless, it is the direction many rulemakings have gone because it produces records that are easy to audit. Written quizzes are a poor test method for people who have reading or language difficulties.
   2. Periodic quiz—These have the same benefits and problems as the previous item except that they test information retention. As in the previous case, periodic quizzes test knowledge, not work practices.
   3. Direct observation—Viewing actual work practices is probably the best way to judge daily performance. The workers will know they are being observed so they may be especially careful to avoid careless errors, but system errors will still be visible. This is the best for people with reading or language difficulties. Direct observation is time consuming. If communication between viewer and worker is feasible, it allows immediate correction of most errors, thus incorporating teaching with evaluation.
   4. Performance review—This is similar to direct observation, but occurs after the fact. Performance review is a paper or office exercise. Therefore, it is less effective than direct observation because it does not include hands-on demonstration and immediate correction.
   5. Error identification, analysis and remediation—This makes the worker an active participant in the effort to produce quality results. It requires design of a system that provides feedback so that workers can identify problems and correct them immediately. This approach is the basis of Kaizen, the continuous improvement method developed by Deming and widely used in Japan before it penetrated the U.S. It is responsible for much of the quality production success of Toyota and Honda. Systems can be designed to keep results records that are true performance measurements.
2. By outside observers and enforcers?
   1. Records review—The traditional review of training records tests training processes but ignores operational results.
   2. Knowledge checks—Ask employees questions about things they should know. This tests management based on worker knowledge but not worker performance.
   3. Direct observation—This is a true performance measurement because it checks workers’ ability by observing their actions. It is independent of the workers’ ability to answer questions.

Training—Good Practices for Regulation, Delivery and Evaluation

1. Stakeholder
   1. Determine training content based on facility needs, pre-existing knowledge and experience and desired results
   2. Individualize content and delivery method to fit the needs of each worker as much as possible
   3. Deliver training content by multiple methods
   4. Deliver training content in multiple languages, if needed
   5. Use multiple methods to test results of training, but emphasize on-the-job performance
   6. Make training content available to all workers at all times
   7. Keep records of training content and attendance
   8. Track errors and near misses and use results to improve training
2. Regulator
   1. Emphasize performance evaluation as the basis for judging training success
   2. Recognize the existence of persons who are qualified by previous education or experience and allow their training requirements to be reduced appropriately
   3. Allow required training to be determined by needs of individual workers or groups
   4. Allow multiple methods of training delivery
3. Enforcer
   1. Review records, question workers and observe behavior
   2. Prioritize problems according to actual and/or probable damage to human health and environment
   3. Increase frequency of enforcement visits to programs that show excessive error rates or other evidence of poor training
   4. Focus enforcement actions on repeated errors that cause or have immediate potential to cause actual environmental damage
   5. Look for evidence of informational feedback loops and other good management practices

An example of an enforcement policy that incorporates these principles quite well is the Nuclear Regulatory Commission Enforcement Policy. ^[9]

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Summary

Colleges and universities have laboratory populations that are very diverse in education, experience and language skills. Successful chemical waste training for laboratory workers requires relatively simple information presented concisely and by a variety of methods to achieve excellent environmental performance. Regulations should allow broad flexibility in training methods, minimize record keeping requirements and judge the success of training by evaluating the work performance of the laboratory and the knowledge of laboratory workers. If this approach is to succeed, good support from a central environmental health and safety organization must be available and relatively simple roles must be assigned to laboratory workers.

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Note: RCRA Online Documents are available via http://www.epa.gov/rcraonline/ Use the document number in “full text search.”

^[1] The proper name of 29 CFR 1910.1450 is “Occupational exposure to hazardous chemicals in laboratories.” However, it is usually referred to as the “Lab Standard” and that name will be used throughout this paper.

^[2] Hazardous Waste Generated in Laboratories. RCRA Online Document Number 14618, 16 August 2002.

^[3] OSHA interpretive letter dated April 24, 1991 to W.M. Bernhart from Patricia K. Clark, Director of Compliance Programs.

^[4] Generator Personnel Training Requirements. RCRA Online Document Number 11429, 9 May 1989.

^[5] Training Employees. RCRA Online Document Number 12341, 1 December 1984.

^[6] Hazardous Waste Training Under 40 CFR 262.34. RCRA Online Document Number 11373, 27 October 1988.

^[7] Clarification on the Amount, Type, and Frequency of Training Required for Personnel Handling Hazardous Waste at Facilities. RCRA Online Document Number: 11779, 7 October 1993.

^[8] More about chemical hygiene officer certification.

^[9] Nuclear Regulatory Commission Enforcement Policy. NUREG 1600 Rev. 1.

Rev. 27 Mar 07, 1400
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