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SUMIDEN WIRE HAZARDOUS WASTE HANDLER TRAINING <br />Prior to the shipment of Hazardous Waste, the manifest must be signed by both the transporter and the <br />shipper. The only employees of Sumiden Wire who are authorized to sign a Hazardous Waste Manifest, are <br />those who have been trained as a Hazardous Waste Handler and has personal knowledge of the Hazardous <br />Waste that is being shipped. The manifest must be kept for 3 years. <br />Satellite Accumulation Containers: <br />Sumiden is allowed to maintain "Satellite" containers for the accumulation of items such as Aerosol Cans <br />that are used throughout the plant site. The rules for a satellite container is as follows: Sumiden can <br />accumulate up to 55 gallons, the container must have a Hazardous Waste Label, filled out using an <br />indelible pen, the initial date of accumulation is clearly marked on the label, the container has a cover and <br />is closed. The accumulation time is no more than one (1) year or 90 days from the time the quantity limit <br />of 55 gallons is reached, whichever occurs first. The 90 -day accumulation time limit begins on the day the <br />container became full and is transferred to the Hazardous Waste Accumulation Area, but cannot exceed 1 <br />year from the accumulation start date. There is no limit as to how many satellite containers Sumiden <br />maintains, however, each must comply with the regulations. <br />Hazardous Waste Training: <br />Sumiden employees who perform work that generates hazardous waste or who may come in contact by <br />handling or loading hazardous waste or who can affect compliance, must successfully complete a program <br />of classroom instruction or on-the-job training. The training should take place within the first six months of <br />employment or reassignment to a new position with different hazardous waste responsibilities at a facility, <br />and have refresher training on an annual basis. The employees written Job Description for each position, <br />must include the required skill, education, or other qualifications. The employees training records shall <br />show the training dates and the employees Job Title, and shall be kept on file until the closure of the facility <br />or for a period of three years after the employee leaves the company. <br />Regulating Agencies: <br />Sumiden Wire must operate under many different regulating agencies such as the City of Stockton <br />Environmental Control Section for our Wastewater, the San Joaquin County Air Pollution Control District <br />for the emissions from the Boiler, Acid Fume Scrubber, Dust Collectors, the Stockton Fire Department for <br />fire hazards and safety issues, San Joaquin County Office of Emergency Services requires annual review of <br />the HMMP (Hazardous Materials Management Plan), San Joaquin County Department of Environmental <br />Health. EPA (Environmental Protection Agency), DOT (Department of Transportation), Cal -OSHA <br />(California Occupation, Safety and Health Administration), DTSC (Department of Toxic Substance <br />Control) and others. All want to review Hazardous Waste records and training records etc. <br />Hazardous Waste Container and Storage Area: <br />A weekly Inspection of all containers of Hazardous Materials and Hazardous Waste is conducted and <br />documented. The inspector looks for potential hazards such as evidence of corrosion on containers, leaking <br />containers, upsets, spills, closed containers, oil drum bungs installed, Empty Labels installed on empty <br />containers, Hazardous Waste Labels installed on containers with substance in them with the generators <br />name, substance within, Start Date, Physical State checked off, the Hazardous Properties checked off, the <br />90 -day storage limit has not been exceeded etc. <br />Hazardous Waste Label: <br />Any employee who deposits a Hazardous Waste in a container is responsible for removing the Empty <br />Label, if one is installed, and is responsible for properly filling out and installing a new, Hazardous Waste <br />Label, as that person knows what was deposited. <br />R <br />