Linearized (accessible) table 1

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Caption: Table 1: A parallel comparison of the training requirements of the OSHA Hazard Communication Standard, the OSHA Lab Standard, RCRA Generator Training Requirements and RCRA Facility Training requirements. Each row contains substantially parallel provisions. General information and training provisions are in the first row. Explanatory inserts are in brackets [ ].

Summary: A parallel comparison of the training requirements of the OSHA Hazard Communication Standard, the OSHA Lab Standard, RCRA Generator Training Requirements and RCRA Facility Training requirements. Each row contains substantially parallel provisions. The general information and training provisions are collected in the first row. There are 13 rows to cover different training requirements. Cells are marked "No requirement" when a regulation has no parallel requirement.

Abbreviations used in column titles:

• Hazcom = OSHA Hazard Communication Standard (applies to labs that don't comply with the Lab Standard and to non-laboratory work areas)
• Lab standard = OSHA Lab Standard (applies to all laboratories, as labs are defined in the rule)
• RCRA generator = RCRA Generator Training (New England XL project unless noted) (applies only in labs except as noted)
• RCRA facility = RCRA Facility Training (Rules established for permitted facility. Some EPA interpretations apply them to labs) ^{3, 4, 5, 6}

• Row = 1
  • Hazcom = Employers shall provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment, and whenever a new physical or health hazard the employees have not previously been trained about is introduced into their work area. Information and training may be designed to cover categories of hazards (e.g., flammability, carcinogenicity) or specific chemicals. Chemical-specific information must always be available through labels and material safety data sheets. (29 CFR 1910.1200(h)(1))
    Employees shall be informed of: The requirements of this section;(29 CFR 1910.1200(h)(2)(i))
    The details of the hazard communication program developed by the employer, including an explanation of the labeling system and the material safety data sheet, and how employees can obtain and use the appropriate hazard information. 1910.1200(h)(3)(iv) [Employees shall be informed of:] Any operations in their work area where hazardous chemicals are present; (29 CFR 1910.1200(h)(2)(ii))
  • Lab standard = The employer shall provide employees with information and training to ensure that they are apprised of the hazards of chemicals present in their work area. (29 CFR 1910.1450(f)(1))
    Such information shall be provided at the time of an employee's initial assignment to a work area where hazardous chemicals are present and prior to assignments involving new exposure situations. The frequency of refresher information and training shall be determined by the employer. 29 CFR 1910.1450(f)(2))
    The contents of this standard and its appendices which shall be made available to employees; (29 CFR 1910.1450(f)(3)(i))
    The employee shall be trained on the applicable details of the employer's written Chemical Hygiene Plan. (29 CFR 1910.1450(f)(4)(ii))
  • RCRA generator = The generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies (40 CFR 262.34 (d)(5)(iii)) (applies to labs and central accumulation areas) [NB: Applies only to generators of 100–1,000 kg per month who wish to accumulate waste for 180 days (instead of 90 days). This is not part of the New England XL rule.]
    [Employees shall be informed of:]The contents of this Subpart and the Laboratory Environmental Management Plan(s) for the laboratory(ies) in which they will be performing work; (40 CFR 262.105(d)(4)(i))
    Each University must ensure that laboratory workers receive training and are provided with information so that they can implement and comply with these Minimum Performance Criteria. (40 CFR 262.104(j) referencing 262.104 (a)-(i))
    Each University must ensure that laboratory workers receive training and are provided with the information to understand and implement the elements of each University's Environmental Management Plan that are relevant to the laboratory workers' responsibilities. (40 CFR 262.105(d)(1))
    Details of the Environmental Management Plan sufficient to ensure they manage laboratory waste in accordance with the requirements of this Subpart. (40 CFR 262.105(d)(5)(iii))
  • RCRA facility = Provide personnel with classroom or on-the-job training on how to perform their duties in a way that ensures the remediation waste management site complies with the requirements of this part, and on how to respond effectively to emergencies; (40 CFR 264.1(j)(5))
    NB: The next four paragraphs are duplicated in 40 CFR 265.
    Facility personnel must successfully complete a program of classroom instruction or on-the-job training that teaches them to perform their duties in a way that ensures the facility's compliance with the requirements of this part. The owner or operator must ensure that this program includes all the elements described in the document required under paragraph (d)(3) of this section. (40 CFR 264.16(a)(1))
    This program must be directed by a person trained in hazardous waste management procedures, and must include instruction which teaches facility personnel hazardous waste management procedures (including contingency plan implementation) relevant to the positions in which they are employed. (40 CFR 264.16(a)(2))
    Facility personnel must successfully complete the program required in paragraph (a) of this section within six months after the effective date of these regulations or six months after the date of their employment or assignment to a facility, or to a new position at a facility, whichever is later. Employees hired after the effective date of these regulations must not work in unsupervised positions until they have completed the training requirements of paragraph (a) of this section. (40 CFR 264.16(b))
    Facility personnel must take part in an annual review of the initial training required in paragraph (a) of this section. (40 CFR 264.16(c))
• Row = 2
  • Hazcom = The location and availability of the written hazard communication program, including the required list(s) of hazardous chemicals, and material safety data sheets required by this section. (29 CFR 1910.1200(h)(2)(iii))
  • Lab standard = The location and availability of the employer's Chemical Hygiene Plan; (29 CFR 1910.1450(f)(3)(ii))
  • RCRA generator = The location and availability of the Environmental Management Plan; (40 CFR 262.105(d)(4)(ii))
  • RCRA facility = No requirement
• Row = 3
  • Hazcom = No requirement
  • Lab standard = The permissible exposure limits for OSHA regulated substances or recommended exposure limits for other hazardous chemicals where there is no applicable OSHA standard; (29 CFR 1910.1450(f)(3)(iii))
  • RCRA generator = No requirement
  • RCRA facility = No requirement
• Row = 4
  • Hazcom = The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used; (29 CFR 1910.1200(h)(3)(iii))
  • Lab standard = The measures employees can take to protect themselves from these hazards, including specific procedures the employer has implemented to protect employees from exposure to hazardous chemicals, such as appropriate work practices, emergency procedures, and personal protective equipment to be used. (29 CFR 1910.1450(f)(4)(i)(C))
  • RCRA generator = Emergency response measures applicable to laboratories; (40 CFR 262.105(d)(4)(iii))
  • RCRA facility = (i) Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment;
    (ii) Key parameters for automatic waste feed cut-off systems;
    (iii) Communications or alarm systems;
    (iv) Response to fires or explosions;
    (v) Response to ground-water contamination incidents;
    (vi) Shutdown of operations (40 CFR 264.16(a)(3), duplicated at (265.16(a)(3))
• Row = 5
  • Hazcom = No requirement
  • Lab standard = Signs and symptoms associated with exposures to hazardous chemicals used in the laboratory; (29 CFR 1910.1450(f)(3)(iv))
  • RCRA generator = No requirement
  • RCRA facility = No requirement
• Row = 6
  • Hazcom = No requirement
  • Lab standard = The location and availability of known reference material on the hazards, safe handling, storage and disposal of hazardous chemicals found in the laboratory including, but not limited to, Material Safety Data Sheets received from the chemical supplier. (29 CFR 1910.1450(f)(3)(v))
  • RCRA generator = The location and availability of known reference materials relevant to implementation of the Environmental Management Plan (40 CFR 262.105(d)(4)(v))
  • RCRA facility = No requirement
• Row = 7
  • Hazcom = No requirement
  • Lab standard = No requirement
  • RCRA generator = Environmental training requirements applicable to laboratory workers. (40 CFR 262.105(d)(4)(vi))
  • RCRA facility = No requirement
• Row = 8
  • Hazcom = No requirement
  • Lab standard = No requirement
  • RCRA generator = The relevant measures a laboratory worker can take to protect human health and the environment; (40 CFR 262.105(d)(5)(iii))
  • RCRA facility = No requirement
• Row = 9
  • Hazcom = Methods and observations that may be used to detect the presence or release of a hazardous chemical in the work area (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); (29 CFR 1910.1200(h)(3)(i))
  • Lab standard = Methods and observations that may be used to detect the presence or release of a hazardous chemical (such as monitoring conducted by the employer, continuous monitoring devices, visual appearance or odor of hazardous chemicals when being released, etc.); (29 CFR 1910.1450(f)(4)(i)(A))
  • RCRA generator = Signs and indicators of a hazardous substance release; (40 CFR 262.105(d)(4)(iv))
    Methods and observations that may be used to detect the presence or release of a hazardous substance (40 CFR 262.105(d)(5)(i))
  • RCRA facility = No requirement
• Row = 10
  • Hazcom = The physical and health hazards of the chemicals in the work area (29 CFR 1910.1200(h)(3)(ii))
  • Lab standard = The physical and health hazards of chemicals in the work area (29 CFR 1910.1450(f)(4)(i)(B))
  • RCRA generator = The chemical and physical hazards associated with laboratory wastes in their work area (40 CFR 262.105(d)(5)(ii))
  • RCRA facility = No requirement
• Row = 11
  • Hazcom = No requirement
  • Lab standard = No requirement
  • RCRA generator = Requirements pertaining to Laboratory visitors:
    Laboratory visitors, such as on-site contractors or environmental vendors that require information and training under this standard must be identified in the Environmental Management Plan. (40 CFR 262.105(d)(6)(i))
    Laboratory visitors identified in the Environmental Management Plan must be informed of the existence and location of the Environmental Management Plan. (40 CFR 262.105(d)(6)(ii))
    Laboratory visitors identified in the Environmental Management Plan must be informed of relevant policies, procedures or work practices to ensure compliance with the requirements of the Environmental Management Plan. (40 CFR 262.105(d)(6)(iii))
  • RCRA facility = No requirement
• Row = 12
  • Hazcom = "Material safety data sheets:" Chemical manufacturers and importers shall obtain or develop a material safety data sheet for each hazardous chemical they produce or import. Employers shall have a material safety data sheet in the workplace for each hazardous chemical which they use. (29 CFR 1910.1200(g)(1))
  • Lab standard = Employers shall maintain any material safety data sheets that are received with incoming shipments of hazardous chemicals, and ensure that they are readily accessible to laboratory employees. 29 CFR 1910.1450(h)(1)(ii))
  • RCRA generator = No requirement
  • RCRA facility = No requirement
• Row = 13
  • Hazcom = This section [i.e. rule] does not apply to: Any hazardous waste as such term is defined by the Solid Waste Disposal Act, as amended by the Resource Conservation and Recovery Act of 1976, as amended (42 U.S.C. 6901 et seq.), when subject to regulations issued under that Act by the Environmental Protection Agency; (29 CFR 1910.1200(b)(6)(i))
  • Lab standard = No requirement
  • RCRA generator = No requirement
  • RCRA facility = No requirement

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

[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.

Rev. 4 Apr 2007, 1000
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