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ATTACHMENT 4: Corrective Action Response to Violation #106-Failed to train employees on waste handling and emergency procedures Worldwide Flight Services maintains, at the corporate level an extensive and robust employee training program. The company's Director of Training determines which elements of the corporate training program are assigned to an employee based on job duties and responsibilities. Training is provided in several formats including computer-based LMS training as well as On-The-Job Training (OJT). Both LMS and OJT training require competency demonstration and/or certification to successfully complete the training requirement. Additionally, at the WFS-SCK Station, on a daily basis at the start of each shift there is a Safety Briefing to inform employees of new or updated safety procedures. Each station has an assigned Training Coordinator. It is the responsibility of the Training Coordinator to ensure that all station employees receive assigned safety training and to document/maintain all employee training reports. The SJCEHD Inspector's findings concluded, based on information provided by site personnel at the time of the inspection (i.e., lack of training records) and conditions observed (i.e., oily absorbent on the ground), that employees had not received hazardous waste training in accordance with CCR 66262.34(d)(2). The Inspector's findings were mis-informed. Employee training records are readily available from the Station's Training Coordinator upon request. Attached are LMS safety training records for Frank Stanich from initial hire to 2/1/2021. According to Mr. Stanich's safety training records, he has received training in both Emergency Response and Environmental Awareness, initially in 2018 and again in 2020, demonstrating competency in both topics each time with a score of 94% or better. Of particular note is the content of the company's Environmental Awareness training which includes hazardous waste awareness training (see training content excerpt, attached). The level of hazardous waste awareness training provided through the company's Environmental Awareness training, meets, and exceeds, CCR Section 66262.34(d)(2) training requirements for a Small Quantity Generator: Small Quantity Generator Training:Small quantity generators (less than 1,000 kg) must include basic hazardous waste management and emergency response procedures, but a written employee training plan and training records are not required. Effective March 1, 2021 all WFS personnel assigned to the Stockton facility will receive the following additional hazardous waste training no later than April 15, 2021: 1. Hazardous Waste Management Training (refer to the attached Training Summary); and 2. Station-specific routinely generated regulated waste management training (refer to the attached Regulated Waste Management Matrix)