I led the investigation into a hydrogen selenide release caused by a cylinder rupture with over 160 lbs. Caused 38 people to go to hospital with 5 acutely injured in Jan 2001. We had to decon many and rescue 1. OSHA was interested in whether the responders were certified as HazWoper Technicians. They did not look at training records but what program and training we had in place to certify them.

Eugene Ngai
Chemically Speaking LLC
www.chemicallyspeakingllc.com

-----Original Message-----
From: ACS Division of Chemical Health and Safety On Behalf Of Lawrence M Gibbs
Sent: Friday, October 23, 2020 7:33 PM
To: DCHAS-L**At_Symbol_Here**Princeton.EDU
Subject: Re: [DCHAS-L] OSHA COVID-19 Tip of the Day for October 23, 2020

The same issue is present for hazardous waste training where the training is required by RWG but documentation of same was not required by the reg. We had much debate with inspectors and required them to show the regulation specifics which they couldn‰??t do. We did extensive training and did document but looked at inspections from a risk management approach. We informed all who took the training that they were responsible for knowing the 4 basic elements of the training and responding appropriately whenever questioned by inspectors. We informed inspectors that we provide training on the requirements and they could inquire of the individuals only on these 4 issues of required training. With the need to train over a thousand new people every year the probability of not having documentation was probably higher than the individuals in the lab not knowing the four elements of the requirement. Worked well and individual lab personnel had more ownership of the matter.

Larry

> On Oct 23, 2020, at 2:39 PM, Daniel Kuespert <0000057d3b6cd9b7-dmarc-request**At_Symbol_Here**lists.princeton.edu> wrote:
>
> •ČŔThis is not to say that having proper documentation isn‰??t useful or good. It‰??s great as an admin control to make sure people get their training, and documents settle a lot of compliance arguments. Besides, DOT and EPA require training docs for specific trainings too, like AHERA qualifications. I don‰??t recall any general requirement to document everything in EPA, though‰??is there a specific example you had in mind?
>
> Regards, Dan
>
> Sent from my iPad
>
>> On Oct 23, 2020, at 17:06, Stuart, Ralph wrote:
>>
>> •ČŔ
>>>
>>> there was a court decision (OSHA v. Westvaco?) that held that OSHA cannot require any documentation not specifically asked for by a reg.
>>
>> So, while DOT and EPA regulations require safety training documentation (for specific hazmat related jobs), OSHA can't for general safety training? I've been working in compliance for 35 years and never picked up on that subtle point. I suppose OSHA's proposed regulations have a high paperwork reduction standard to cross...
>>
>> Thanks for the explanation.
>>
>> - Ralph
>>
>>
>> Ralph Stuart, CIH, CCHO
>> Environmental Safety Manager
>> Keene State College
>> 603 358-2859
>>
>> ralph.stuart**At_Symbol_Here**keene.edu
>>
>> ---
>> For more information about the DCHAS-L e-mail list, contact the
>> Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on
>> Twitter **At_Symbol_Here**acsdchas
>
> ---
> For more information about the DCHAS-L e-mail list, contact the
> Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on
> Twitter **At_Symbol_Here**acsdchas

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org Follow us on Twitter **At_Symbol_Here**acsdchas

---
For more information about the DCHAS-L e-mail list, contact the Divisional membership chair at membership**At_Symbol_Here**dchas.org
Follow us on Twitter **At_Symbol_Here**acsdchas

Previous post   |  Top of Page   |   Next post