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0 0 <br /> The following is an itemized list of RCRA hazardous waste violations that have not <br /> been addressed for KAISER PERMANENTE as of September 12, 2017. <br /> Open violations from June 13, 2017 inspection <br /> Violation #118 -Failed to complete training on hazardous waste management and emergency response <br /> procedures. <br /> It was not clear at time of inspection what hazardous waste training was being provided to employees. Inspector <br /> was provided with different training modules for different time periods but employees were not able to identify who <br /> had received the training, and what trainings were applicable to theirjob functions. <br /> Lack of training was evident during the inspection when the same hazardous waste stream was identified differently <br /> on hazardous waste labels or not at all. <br /> At one point during the inspection when looking at an incomplete hazardous waste label, a comment was made by <br /> Darryl Gardner, "these guys don't really know what they're doing". <br /> Personnel who handle hazardous waste shall be trained within six months of assignment and take part in an annual <br /> review of the initial training received. At a minimum, the training program shall be designed to ensure that facility <br /> personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, <br /> emergency equipment, and emergency systems, including where applicable: <br /> 1. procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment; <br /> 2. key parameters for automatic waste feed cut-off systems; <br /> 3. communications or alarm systems; <br /> 4. response to fires or explosions; <br /> 5. response to ground-water contamination incidents; and <br /> 6. shutdown of operations. <br /> The owner or operator shall maintain the following documents and records at the facility: <br /> 1. the job title for each position at the facility related to hazardous waste management, and the name of each <br /> employee filling each job; <br /> 2. written job description for each position listed above; <br /> 3. written description of the type and amount of both introductory and continuing training that will be given to <br /> each person filing positions listed above; <br /> 4. records that document that the training has been given to and completed by facility personnel. <br /> Training records on current employees shall be kept until closure of the facility. Training records on former <br /> employees shall be kept for at least three years from the date the employee last worked at the facility. Immediately <br /> provide employees with initial or refresher hazardous waste training. Submit a copy of the roster and the syllabus to <br /> the EHD. <br /> Page 1 of 4 <br />