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HomeMy WebLinkAboutDSHW-2024-008893UO Annual Training 2024 Used Oil Training Rachel Boyer Presentation Overview Marketers Training requirements for Used Oil Marketers 01 02 03 04 05 06Processors Training requirements for Used Oil Processors Training Sheet Example of used oil training aendance sheet Transporters Training requirements for Used Oil Transporters Transfer FacilitiesTraining requirements for Used Oil Transfer Facilities Common Issues Common mistakes we see with used oil training ●Permiees shall initially train employees that handle used oil and manage used oil records. New employees may not manage used oil without a trained employee present until training has been completed. ●Permiees shall ensure that employees can demonstrate competence to collect a representative used oil sample from tank or containers. ●Permiees shall provide, at a minimum, an annual used oil training refresher course for its employees associated with this registration. ●Employees and supervisors shall sign and date the training aendance sheet to document class aendance ●Permiees shall keep copies of training records for each employee for a minimum of three years. Language from Current UO Marketer Registration Template UO Marketers ●The Permiee shall train handlers of used oil in accordance with Utah Administrative Code R315-15-4 and the requirements of this Permit. ●New employees may not manage or process used oil without a trained employee present until used oil training is completed. ●The Permiee shall document that employees are trained in the identification of used oil, recordkeeping requirements, emergency spill plan and facility used oil procedures for handling, transporting, sample collection, halogen screening and laboratory analytical methods, rebuable presumption testing, and the appropriate use of “generator knowledge” when determining the halogen content of used oil. Language from Current UO Transporter Permit Template UO Transporters ●Employees collecting and performing field halogen testing shall be trained and demonstrate competence in collecting a representative used oil sample and testing for halogens using a CLOR-D-TECT® kit prior to fieldwork. ●The Permiee shall provide, at a minimum, an annual used oil training refresher course for employees handling used oil. ○Additional training is required if the Permiee changes used oil handling procedures or this Permit is modified. ●Employees and supervisors shall sign and date training aendance sheets to document class aendance. ●The Permiee shall keep training records for each employee for a minimum of three years. Language from Current UO Transporter Permit Template UO Transporters ●The Permiee shall train handlers of used oil in accordance with Utah Admin. Code R315-15-4 and the requirements of this Permit. ●New employees may not manage used oil without a trained employee present until used oil training is completed. ●Employee training shall include documentation that the following topics were covered: identification of used oil, recordkeeping requirements and facility used oil procedures for handling, transporting, sampling and analysis, emergency response, spill reporting and personal safety. Language from Current UO Transfer Facility Permit Template UO Transfer Facilities ●Employees collecting and performing field halogen testing shall be trained and shall demonstrate competence in collecting a representative used oil sample and testing for halogens using a CLOR-D-TECT® kit prior to fieldwork. ●The Permiee shall provide, at a minimum, an annual used oil-training refresher course for employees handling used oil. ○Additional training is required if the Permiee changes used oil handling procedures. ●Employees and supervisors shall sign and date training aendance sheets to document class aendance. ●The Permiee shall keep training records for each employee for a minimum of three years. Language from Current UO Transfer Facility Permit Template UO Transfer Facilities ●The Permiee shall train employees that handle used oil in the applicable regulatory requirements of Utah Admin. Code R315-15 and the requirements of this Permit. ●New employees may not manage or process used oil without a trained employee present until their used oil training is completed. ●The Permiee shall implement a wrien training plan. Employee training shall include identification of used oil, recordkeeping requirements and facility used oil procedures for the handling, storing, processing, sampling and analysis of used oil, emergency response, spill reporting and personal safety. ●The Permiee shall train new and existing employees in the handling of used oil and PCB-contaminated used oil. Language from Current UO Processor Permit Template UO Processors ●Employees authorized to test used oil shall demonstrate competence to lock-down the tank/container, collect a representative used oil sample, screen used oil for halogens using a Clor-D-Tect kit (EPA method 9077) or prepare required documentation to submit sample to the laboratory for analysis. ●The Permiee shall provide, at a minimum, an annual used oil-training refresher course for employees handling used oil. ○Additional training is required when the Permiee changes used oil-handling operational procedures. ●Employees and supervisors shall sign and date training aendance sheets to document class aendance. ●The Permiee shall keep training records for each employee for a minimum of three years. Language from Current UO Processor Permit Template UO Processors Common Training Issues ●Missing annual used oil refresher training ○Seing a reminder to complete used oil training ●Missing training aendance sheet ●Missing topics covered during training ○Copy and paste the topics directly from the permit to the training aendance sheet. ■Make sure that all topics listed on the training aendance sheet were covered during training. ○Maintain a syllabus that contains all of the information covered during the training ○Have used oil training slides slides readily accessible for review during inspections Questions? Ted Sonnenburg Program Manager Used Oil & Outreach Rachel Boyer Environmental Scientist PHONE(801) 503-4334 EMAILrachelboyer@utah.gov PHONE (385) 499-0980 EMAILtsonnenburg@utah.gov Watch Our First Used Oil Annual Training Here!