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Item#118. CCR 66265.16(a-c)Failed to complete training on hazardous waste management and emergency response procedures. There were no records available to demonstrate how all personnel who handle hazardous waste are trained. There was only training available for acid sludge but the facility also generates other types of hazardous waste. See supporting PDF file Item 118. Sumiden uses multiple media to train and acclimate employees into our safety culture. New hires are trained using the new hire employee check list and slug discharge within their first 30 days. Due at the end of the calendar year employees are trained using our safety partner Health and Safety Institute. This electronic base media is used to train and quiz employees for understanding. Both checklist and year to date progress is attached. The course work assigned to all Sumiden employees are: Emergency Preparedness Hazardous Waste Lockout/ragout: Affected Employees Lockout/Tagout: Authorized Employees Bloodborne Pathogens GHS Globalize Your Communication Safety Orientation Fire Extinguisher Forklift Safety: Basics and Best Practices Overhead Crane Safety Personal Protective Equipment: Your Final Defense Sexual Harassment: Understanding and Preventing Workplace Violence, Prevent the Threat Sumiden employee are also further trained on business specific subjects at our monthly employee meetings. Key team members to include maintenance and waste water handling personnel, employees are trained using SOP and outside vendor (Cooper Control) on how to operate, adjust and calibrate Sumiden's waste water balance tanks. See attached SOP, Cleaning & Calibration of pH Probes. Sumiden Wire uses the following document to provide training for its hazardous material handler document titled, "Hazardous Material Handler Training RCRA & NON-RCRA as required by Title 22 of the California Code of Regulations 66265.16." This training document was originally drafted on 10/16/2006 by WFM (Wayne Mannor). Attached is the document revised 5/15/2019 and training records of those trained in the subject. The course content remains the same however updated are waste disposal tonnage, shipment history and labeling examples. Training for Hazardous Material Handler will take place within 6months of hire for those who interacts directly with hazardous material and an annual basis. Training will be provided for those in maintenance, specific shipping and handling roles and salaried employees.