What sorts of training are expected for staff at MRW fixed facilities? *
Training requirements are largely contained in regulations of other agencies, such as L&I and the Department of Transportation, and in locally adopted fire codes. The part of the rule cited above is not a complete list of required training for the operation of an MRW fixed facility. Ecology has worked with L&I to establish baseline health and safety training for persons responsible for fixed facility operations. In many cases, it is expected that fixed facility operators will have 24 hours or training similar in extent to that required under L&I requirements for hazardous waste workers (see 296-800 WAC). All workers also need to have on-the-job training and understand the operations plan, safety procedures, correct authorized use of safety and production equipment, etc. For limited MRW collection facilities, the training requirements will be much less extensive than for a full-service fixed facility.
In addition, there may be other initial and ongoing training. Some topics that will be needed by some operators include:
Discuss your training needs with your safety officer and health and safety professionals. Labor and Industries also has a list of consulting health and safety professionals that can provide facility-specific advice on how to comply with their rules. These consultations are free and do not involve enforcement citations or penalties, so there is no financial risk.
In addition, anyone who transports (ships) hazardous materials or arranges for such transportation over the roads needs to comply with the hazardous materials transportation training requirements of the Department of Transportation.
Many other trainings may be useful or required depending on the specifics of your operation. Some product vendors offer training in the safe and efficient use of their products. There are private firms that specialize in providing health and safety evaluation and training services. Some counties and cities have developed MRW facility training programs for themselves. They may be able to assist nearby jurisdictions in meeting their training obligations or coordinating the use of a paid trainer for multiple programs.
* Note: The answers provided to Frequently Asked Questions are guidance for implementing WAC 173-350-360. Following this guidance is not a requirement of operation or design for MRW facilities, as facilities may meet regulatory requirements through other means. Local Health Departments should be consulted to determine what will be sufficient to meet the regulatory standards.
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