Review Employee Training Records

All employees working onsite (such as but not limited to equipment operators, general laborers, and others) exposed to hazardous substances, health hazards, or safety hazards, and their supervisors and managers responsible for the site operations, shall receive training before they are permitted to engage in hazardous waste operations or waste handling duties that could expose them to hazardous substances, safety, or health hazards. They are also required to receive annual refresher training.

Employees shall not be permitted to participate in or supervise field activities until they have been trained to a level required by their job function and responsibility.

The training shall thoroughly cover the following information:
  • Names of personnel and alternates responsible for site safety and health;
  • Safety, health, and other hazards present on the site;
  • Use of personal protective equipment;
  • Work practices by which the employee can minimize risks from hazards;
  • Safe use of engineering controls and equipment on the site;
  • Medical surveillance requirements, including recognition of symptoms and signs which might indicate overexposure to hazards;
  • Emergency procedures; and
  • The contents of the site safety and health plan.
Training records are a good means of determining how well site personnel have been trained to perform their jobs and to respond to site emergencies. These records should be reviewed during your site visit to ensure first training is being conducted, and finally, that each worker’s refresher training is current. The lack of real training is the root cause for accidents and spills during daily operations. This training is mandatory. All training records must be maintained onsite, and should be made available for review during your site visit.