2014 CUPA conference: What you need to know
Key takeaways for hazardous waste generators
by Lion Technology Inc.
Earlier this year, Cal/EPA hosted the 16th annual California Unified Program Conference at the San Francisco Hyatt in Burlingame, CA. Local, State, and Federal environmental agencies attended the conference to offer training for regulatory inspectors and industry professionals on topics including hazardous materials risk management, hazardous waste, regulatory enforcement, emergency response, and environmental administration and management. Below are some important highlights of this year’s Conference for hazardous waste managers and personnel in California.
Counting universal waste in CA
In California, “universal waste” includes common items like batteries, fluorescent lamps, and aerosol cans. Counting these common materials as hazardous waste can significantly increase a facility’s regulatory burden; facilities that generate 1,000 kg or more of waste each month are subject to more restrictive regulatory requirements than those that generate less than 1,000 kg.
The DTSC and local CUPA inspectors have an open dialog regarding this issue and are working to develop consistent enforcement standards and best industry practices to help generators effectively manage universal waste.
New requirements for hazardous materials business plans
Cal/EPA also provided guidance on new requirements for Hazardous Materials Business Plans, required under California’s Health and Safety Code, Section 25505(a)(2). Starting in 2015, inspectors will be reviewing facilities’ Business Plans for a site map that includes the following ten mandatory elements: North orientation, loading areas, internal roads, adjacent streets, storm and sewer drains, access and exit points, emergency shutoffs, evacuation staging areas, hazardous material handling and storage areas, and location of emergency response equipment.
Business Plans must be updated to include these elements by January 1, 2015. The Business Plan is one of many elements of hazardous waste management in California for which the rules are found in the state’s Health and Safety Code, as opposed to Title 22 of the California Code of Regulations. Because the State hazardous waste rules are complex and spread among these different sets of regulations, manufacturers and industry professionals must have a thorough understanding of what rules apply to their operations.
Land disposal restrictions
As a sponsor of this year’s conference, Lion Technology Inc. presented a training session covering Federal and State-specific Land Disposal Restrictions (LDRs).
The LDR rules set thresholds for hazardous constituents found in wastes. Generators must ensure their waste is treated to meet specific standards before disposal. Complying with LDRs in California is a complex process. Prior to disposal, Federal RCRA wastes must meet US EPA’s standards, while non-RCRA (California-only) wastes must meet State-specific standards.
Documentation of outside training
Both Federal and California regulations require annual training for hazardous waste personnel, and new or transferred employees must complete training within six months of their hire date or a change in job responsibilities. [40 CFR 265.16 and 22 CCR 66234(a)(4) and 66265.16(b) and (c)]
Many hazardous waste generators trust their training to an expert training provider. Some other facilities opt to have their own EHS managers provide training to new hires and other site personnel.
When asked what is required to train staff on-site, an inspector advised that he and his colleagues often look for proof that the manager who provides on-site training has completed training from an outside source. This criteria is used to ensure the hazardous waste manager has been properly “trained in hazardous waste management procedures” as required by Federal and State regulations. A Certificate of Achievement and other training documentation from a professional training provider is often used to satisfy this requirement.
California-specific hazardous waste training coming soon
For hazardous waste generators who need training on the unique, complex, and state-specific California hazardous waste laws and regulations, Lion Technology will present the Hazardous Waste in California Workshop statewidein April and May. The complete 2014 schedule is now available at www.Lion.com/Hazardous-Waste-in-California-Workshop
The workshop covers the Title 22 and Health and Safety Code rules that apply to large, small, and conditionally exempt generators in the state. Enrollment includes a free online prep-course, two days of expert training, a copy of the Title 22 hazardous waste regulations and select sections of the HSC, a newly designed California Hazardous Waste Road Map, compliance reference materials including a searchable reference CD, and 365 days of Lion Membership for complete regulatory support.