From the archives of the Enforcement and Compliance Listserv for Hazardous Waste Generators

April 2010 - Personal Protective Equipment

Personal protective equipment, also referred to as PPE, is not only required by hazardous waste law for small and large quantity generators, it is also vital for worker health and safety. That said, personal protective equipment should be considered the last line of defense. Your business should already have precautionary measures in place such as: engineering controls to physically limit your employees' contact with hazardous waste; implemented safe work practices including training employees; and put in place administrative controls such as limiting employees time and exposure to hazardous waste. In situations where Personal Protective Equipment is necessary, remember:  

  • Select appropriate personal protective equipment that fits your employees. A large protective suit will not fit a small person and vice versa.
  • Communicate your personal protective equipment selection to employees. Explaining the "why personal protective equipment is necessary" usually will motivate workers to use it. Reminder signs, a 15 minute weekly safety meeting, and a written policy that employees sign are all good tools to communicate your personal protective equipment requirements.
  • Require employees to use personal protective equipment as a condition of employment.  Safety glasses do not provide eye protection when they are sitting on a desk or in someone's truck.
  • Personal protective equipment selected should be suitable for the hazardous waste that you or your employees are managing. For instance, latex gloves can lose their structural integrity when exposed to most organic solvents. Nitrile gloves are usually suitable for use with most organic solvents however they are less comfortable to wear and can hinder dexterity. Each situation is unique and should be evaluated individually to determine the best personal protective equipment. Personal protective equipment manufacturers are a great source of information regarding their products compatibility with certain hazardous wastes, limitations, and uses.   When training employees to use personal protective equipment, make sure that they know:  
  • How to use personal protective equipment properly. 
  • How to put on, adjust, and remove personal protective equipment without increasing the potential for exposure to the hazard present.  Practice these procedures regularly so that employees are prepared for emergency situations.
  • When to use personal protective equipment.
  • Training employees using real world scenarios from your business and the type of hazardous waste that you have. 
  • The limitations of the personal protective equipment that they are using and what the personal protective equipment will NOT protect them from.
  • How to maintain personal protective equipment. Most personal protective equipment (including hard hats) has an expiration date. Non-disposable personal protective equipment should be decontaminated and inspected for cracks, tears, and deterioration after EACH use. Safety goggles, glasses, and face shields should never have scratches or smudges that impair visibility.

Dec. 28, 2009  - Adequate and Proper Spill Control

What constitutes adequate and proper spill control for hazardous waste? In Missouri, large and small quantity generators must have on site spill control, decontamination, and safety equipment available for employees to use. This equipment may include but is not limited to: fire blankets, self-contained breathing apparatuses (often referred to as SCBAs), absorbents, and the like. Please note that some of these items may not be required due to the nature of the wastes and activities conducted or reasonably anticipated. For example, SCBAs are not likely needed to clean up a small spill of spent caustic soda. It is important that you know the properties of your hazardous waste and the best way to manage these wastes in the event of a spill or release. The equipment that you have must be consistent with what is expected of your employees in the event of an emergency.

Spill control equipment, such as absorbents, must be compatible with the wastes you have on site and must not react or cause a fire. For example, you should never use sawdust to absorb or impede a strong oxidizer because it may cause a fire. Your business should provide enough spill equipment for the release of the largest size hazardous waste container that you store. For example, if you only store your hazardous waste in 5-gallon buckets, a relatively small amount of absorbent is needed and the overpack for that container could be small. If, however, you store some hazardous wastes in 55-gallon drums and 250-gallon totes, you should have absorbent sufficient enough to absorb a spill from the larger 250-gallon tote. Don't forget to have expendable equipment, such as drums, containers, mops, brooms, etc, on site to clean up absorbent and spilled materials!

Decontamination equipment, such as eye wash stations or safety showers [see Occupational Safety and Health Administration, or OSHA, regulations and guidance] should be in good condition and routinely checked to see that they are in working order. We recommend that decontamination equipment be within a ten second radius of the potential hazard. No door should separate the decontamination equipment and the hazard. As a general rule, eye wash stations and safety showers should provide enough water for fifteen minutes of rinsing. All decontamination equipment should be well lit and have adequate signs that are easy to read in an emergency situation.

If employees wear respirators for emergency response situations, inspectors may check your records for proper fit testing and respirator inspections. Please see OSHA requirements for more information. Again, any spill control or safety equipment listed in your contingency plan will likely be inspected during an inspection. It is vital that the equipment provided to employees satisfactorily address problems so that a somewhat minor spill or emergency is prevented from becoming a larger, more dangerous situation.

Adequate Water Control and Fire Equipment

What constitutes adequate water supply and fire control equipment? Large and small quantity generators must have an on site water supply and fire control equipment. Inspectors will look at contingency plans or facility maps to identify the location of fire control equipment and make sure that the equipment is actually where it is designated to be and in working condition. Fire control equipment may consist of fire alarms, smoke detectors, sprinkler systems, dry chemical fire suppression systems, foam fire suppression systems, fire blankets, fire extinguishers, and the like. Be certain that your fire control equipment is appropriate for the type of hazardous waste that you have. For instance, you would never use a water sprinkler system on a hazardous waste that is reactive to water.

The most commonly used fire control equipment is a fire extinguisher. Fire extinguishers have an A, B, or C classification system. A is for ordinary combustibles, B is for flammable liquids, and C is for electrical fires. Many fire extinguishers are a combination and can be used for all three types of fires. Tailor the fire extinguisher that you choose for the specific type of hazardous waste you have. Fire extinguishers must be charged and inspected as required (please see OSHA requirements and consult your local fire department). We recommend that fire extinguishers be stored near each area where you store or accumulate hazardous waste rather than directly inside the hazardous waste area. This prevents employees from entering the hazardous waste area to retrieve the fire extinguisher to fight the fire. If employees are going to use a fire extinguisher or hose system, it is better to have that equipment stored near the hazardous waste area rather than wading through the hazardous waste area to get the fire control equipment. Again, the department does not require businesses to stay and fight any fire on their property and we strongly encourage businesses to first contact emergency services when a fire occurs

Oct. 30, 2008

Large Quantity Generators, or LQGs

There are two basic subjects in which employees must be trained: hazardous waste management and emergency response as outlined in 40 CFR 265.16.

  • Hazardous waste management training can include: accumulation, container or tank management, hazardous waste regulations, inspections, waste determinations, pre-transportation, report and record keeping, waste minimization, and packaging.
  • Emergency response training can include: communications, evacuation routes, contingency plans (this is a BIGGIE!), emergency equipment upkeep, and response to fires, explosions, and spills.

Be certain that you tailor individual training plans according to individual responsibilities. This means that if an employee is responsible for labeling and marking containers in storage, then they must have received training regarding labeling and marking. A different employee responsible for satellite accumulation areas must be trained in the requirements for satellite accumulation areas.

Some training required for the U.S. Department of Transportation, or US DOT, such as general awareness and safety, or for Occupational Safety and Health Administration, or OSHA, can also fulfill requirements for hazardous waste management training.  Remember, Large Quantity Generator's are required to have an annual review of the initial training. See our Jan. 8, 2007 listserv archive for required training documentation for LQG's.

Small quantity generators (SQG)

Small quantity generators have more simple training requirements. The requirements are outlined in 40 CFR 262.34(d)(5)(iii)

  • SQG employees must be familiar with proper waste handling and emergency procedures relevant to their responsibilities during normal facility operations and emergencies.
  • Employees must be trained in emergency procedures, such as emergency communications, how to extinguish a fire, and how to clean up hazardous waste spills.  See EPA guidance on this topic. .
  • EPA stated this in the preamble to the SQG rule: that "...employees who work in or adjacent to areas where hazardous waste is generated, handled, or stored, but do not handle hazardous wastes must still be trained to be thoroughly familiar with basic emergency procedures." This includes office or clerical staff.
  • Although not required, your business may want to have a written training plan and records of employee names, training dates, and employee signatures.


Unfortunately, the regulations do not include every detail as to what should be included in the required training. Every site is unique and so are the training needs. Most RCRA training violations received by businesses are based on the lack of records or inadequate records - not the actual training received so make sure you focus on keeping good records of training.

An advantageous way to organize your training records is to create a binder or file folder, segregated by year, to keep training certificates. Each training certificate should state the course name, the date of the training, and the name of the employee that completed the training.

Remember that U.S. DOT requires specific training for any employee involved in hazardous waste transportation, see 49 CFR 172.700 and 173.1. Also, OSHA regulations require training for employees who could be exposed to a physical or health hazard see 29 CFR 1910.1200(h)

Feb. 20, 2007

Information on spills and equipment in the archive.

As the last few years have pointed out, it is reasonable for businesses to plan for disasters that can damage facilities and shut down operations for days or longer. Severe weather such as Missouri's recent winter storms, fire, or other disasters can strike at any time. In addition to dealing with the immediate evacuation or response to hazardous waste spills, facilities may find it is worthwhile to develop a plan for assessment and recovery in the event of a disaster. Having a plan can help a facility recover faster and better, and pre-planning can help avoid wasted or redundant efforts, protect your business's assets, and help you qualify for insurance or government disaster payments. The Department of Homeland Security's Ready Business website can provide some advice on this kind of recovery planning.

Jan. 8, 2007

The next few issues of this listserv are going to focus on safety and emergency situations. While reviewing this listserv, try to picture how your employees would react to an emergency. Are they prepared?

1. Communication

Small Quantity Generator and Large Quantity Generator facilities must have a device in the hazardous waste operations area capable of summoning emergency assistance. The device can be a telephone, intercom, cell phone, two-way radio, air horn, whistle, cow bell, whatever, as long as it is capable of summoning assistance and employees are trained to recognize the signal and act appropriately. Test it! If someone is in trouble in the operations area, can they summon assistance with the device? If your business has more than one hazardous waste operations area (i.e. containerization or storage area) then there must be a device capable of summoning emergency assistance located in EACH area.

Conditionally Exempt Small Quantity Generators (those that generate or accumulate 220 lbs of non-acute hazardous waste or less a month or less than 2.2 lbs of acutely hazardous waste) are NOT required to have such a device in their hazardous waste area but it is still a good, low cost way to protect you and your employees.

2. Training

What, if any, training must a Conditionally Exempt Small Quantity Generator provide to its employees? Although training requirements are not spelled out for Conditionally Exempt Small Quantity Generators, if you fall in this category you must be capable of making a hazardous waste determination and properly managing your wastes so they do not threaten human health or the environment or create a public nuisance. There are several training options, including attending formal training, taking a course online, or reviewing information available to you at the library or on the Internet. Review making a hazardous waste determination.

Small Quantity Generators are not required to have formal training records for their employees, however, it is important that each employee involved with hazardous waste be familiar with waste handling and emergency procedures. This protects your workers from injury and your facility from damage. Inspectors can evaluate if employees are familiar with waste handling and emergency procedures by speaking with employees. Inspectors will ask employees that are responsible for a specific waste stream direct questions about hazardous waste management. Establishing and periodically reviewing proper training and procedures at your business helps make sure your employees can not only answer an inspector's questions but that they know what to do in an emergency situation.

For Large Quantity Generators training and documentation requirements are more formal. Large Quantity Generators must provide training to their employees on how to respond to an emergency, have their training reviewed annually, and be sure employees don't work in unsupervised positions until their training is completed. The documentation required includes:

  • maintaining personnel training plans onsite that include the information below;
  • listing the name, job title and description of each employee filling a hazardous waste position (this must include requisite skill, education or other qualifications, and duties of facility personnel assigned to each position);
  • a written description of introductory and continuing training for each position (including type and amount of training);
  • documentation of training completed by personnel, this may include the title of the training offered and a dated sign in sheet or the duration and description of on the job training each employee receives;
  • maintaining the records of current employee's training until the business' closure and retaining former employee records for at least three years.

Large Quantity Generator's program director must be trained in hazardous waste management procedures. Employees that manage, move, label, inspect, consolidate, prepare for transport, etc. hazardous waste must have training relevant to their position. Inspectors will often quiz employees about the training they received, emergency contingency plans, and other safety matters.

Oct. 23, 2006

Is your company prepared for an emergency?  It's a good idea to review the Preparedness Prevention and Emergency Procedures in Section D of the department's Small Quantity Generator Inspection Record and Checklist . The checklist reviews the important emergency preparedness information that is required by 40 CFR 262.34(d)(5)(ii) and 10 CSR 25-5.262(1) for small quantity generators. Although this information is not required for large quantity generators and conditionally exempt small quantity generators, it is always a good idea to put safety first and prepare in advance for emergencies. Small Quantity Generators must post the required emergency information at the main office telephone and at each hazardous waste operational area. It is also recommended that you post the emergency information by the telephone in the office of the supervisor in charge of hazardous waste operations.

For Small Quantity Generators the information must include:

  1. Name and phone number of the company's Emergency Coordinator(s). The emergency coordinator(s) must be on-site or on-call 24 hours a day, seven days a week.
  2. Location of fire extinguishers and spill equipment and if applicable, fire alarm.
  3. Fire department phone number, even if it is 911.

Although not required by regulation, you may also want to post:  

  • employee evacuation routes.
  • a designated safe meeting area away from the building in case of an emergency.

All of this information can be shown on a simple map of the building. To ensure its durability you may want to laminate the emergency information or even place it in a frame. Make sure it is easy to see in the areas of hazardous waste operation.  For example, the information should be displayed at eye level and you should use a large font and clear print.

Large quantity generators are required to maintain a contingency plan to deal with emergency situations on-site. We suggest that large quantity generators print multiple copies of the contingency plan and make it easily accessible to employees that work in the hazardous waste areas. Large quantity generators may review their list of preparedness, prevention and emergency procedures and the contingency plan requirements in Sections D and H of the Large Quantity Generator Inspection Record and Checklist .

Dec. 16, 2005

1. At the end of the work day, we all want to go home to our family and friends. Preventing injury or harm is the basis for many Hazardous Waste Laws and regulations. Storing reactive chemicals separately, closing hazardous waste containers, having proper spill equipment on-hand, and providing training for your employees on what to do in an emergency are all requirements based on protecting the health and safety of you and your workers. Take some time to review your workplace, procedures, and training. Use the department's Small Quantity Generator Inspection Record and Checklist or the Large Quantity Generator Inspection Record and Checklist .  Both checklists go over basic safety preparedness, prevention, and emergency response for hazardous waste generators. For additional information on reactive chemicals and preventing accidental reactions, please visit the Occupational Health and Safety Administration (OSHA) web site on Chemical Reactivity Hazards.  From there, check out "How can I recognize chemical reactivity hazards in my workplace?" for a free online version of Essential Practices for Managing Chemical Reactivity Hazards manual.

2. Ever heard of the Hazard Communication Standard (HCS), Code of Federal Regulations 1920.1200? Under the authority of OSHA, the HCS requires that employers alert employees to the potential hazards and management of individual chemicals. Specific assistance on which chemicals to include and how to transmit this information to employees is available from OSHA's Frequently Asked Questions web site.

For information on which employees, if any, should have the 40 hour Hazardous Waste Operations and Emergency Response Training, please review the information available at OSHA's Frequently Asked Questions on Hazwoper web site.

And for basic information on OSHA requirements for training, jobsite safety, record keeping and more, visit OSHA's Quick Start Guide

If you would like updates and information on hazardous waste or know of anyone else who would like to be added to this listserv, visit DNR Enforcement and Compliance Assistance Newsletter Generators Subscription to sign up.

If you need further assistance, please Email or contact the Department of Natural Resources' Hazardous Waste Program at 573-751-7560 or 800-361-4827.

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