The proper training could have avoided this garbage can of used oil.
Warning: this article might test your knowledge of environmental, health and safety training abbreviations and acronyms!
As professionals in the environmental field, we may be exposed to hazardous work conditions, possibly radiological, chemical and/or physical. For some of us it’s a routine part of our jobs. If you are working around hazardous conditions, there is most likely a required environmental, health, and safety (EH&S) training course you’ll need to complete. Unfortunately, people often get inadequate information or misinterpret the course(s) they need. Depending on your job, the required course could be from a federal regulation, state regulation, a requirement of a client, and even individual job locations may require a specific course or more.
As an instructor of environmental, health, and safety courses, one of the most common problems I encounter is people who believe that because they’ve taken a “Hazmat Class” or an “Environmental Course”, they think they’re adequately trained. Saying, “I took a Hazmat class.” is a lot like saying, “I took a math class.” It tells me you know some math, but was it algebra, geometry, calculus, or arithmetic?
What kind of “Hazmat” class did you really take? It may have been a 40-hour DOT hazardous material shipping course, but what you really needed was a HAZCOM (hazard communication) course for the hazards in your workplace. The list of environmental and hazardous material courses covers a range of regulations that can go on and on – RCRA, CERCLA, FIFRA, asbestos building inspectors, HAZCOM, HAZWOPER, EPCRA, respiratory protection, etc. There are also the safety specific, OSHA-based courses that cross into the environmental field, such as confined space entry, fall protection, Lockout/Tagout, and others.
It can get confusing because there is quite a bit of overlap in both the courses and regulations. A confined space entry course should not only cover the physical hazards and procedures, it should offer an understanding of the chemical hazards you could encounter (toxins, flammables, and low oxygen). You can’t teach a hazardous waste management course to a large quantity generator TSDF without dipping into the HAZCOM topics of labeling and MSDSs. This overlap does not exempt you from other required courses.
The most common training course that is both improperly referenced and taken is HAZWOPER, (hazardous waste operations and emergency response – from CFR 1910.120). It has become the course brought up more than any other. “I need HAZWOPER training.” when often, they don’t. I really believe HAZWOPER has gained this attention because it has a name that is easy to remember and fun to say. (I’m not kidding.) A particular problem with HAZWOPER is that people, who only need HAZCOM or hazardous waste management training, go looking for HAZWOPER. It’s understandable because “hazardous waste” is part of the title, but it’s not an EPA RCRA course. It is very specifically an OSHA clean up and emergency response course. Many people have wasted time and money sitting through 40-hours of training, to then realize they only needed a 4-hour training course.
If you’re not sure what type of training is required, start by looking at the hazards you’ll encounter on the job. For example, not everyone working in an oil and gas field needs training on hydrogen sulfide (H2S) gas. If you are one of the “lucky ones” working in an oil or gas field with the poisonous, flammable gas, you shouldn’t miss the H2S training. Hopefully the owner/operator of that field wouldn’t even let you on location without it. Another example of hazard training required in Colorado is the Asbestos Building Inspector certification. Not only will you need to complete the EPA TSCA AHERA asbestos training course, but you also need to pass the state exam required by the CDPHE Air Pollution Control Division.
One can easily get lost in the web of regulations and misinterpret or overlook a required environmental, health or safety course. But it’s important to remember that there is a reason for that course, to make sure you complete your job without injury or hazardous exposure to you and the environment. There are three types of students in E, H, & S training courses – scholars, vacationers, and prisoners. Hopefully in your next course, you’ll be the scholar.