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The following is an itemized list of hazardous waste violations that have not been
<br /> addressed for Aztlan Ornamental Iron as of January 21, 2021.
<br /> Open violations from January 27, 2020 inspection
<br /> Violation#714-UWH failed to train employees and maintain records on UW handling and emergency
<br /> procedures.
<br /> OBSERVATION: The facility could not provide an annual training record or description of training for all of the facility
<br /> personnel who manage and process universal waste aerosol cans.
<br /> REGULATION GUIDANCE:
<br /> (a)A universal waste handler shall ensure that all personnel who manage universal wastes at the universal waste
<br /> handler's facility are thoroughly familiar with proper universal waste management and emergency response
<br /> procedures relative to those persons' responsibilities, as specified in subsections(b)and (c)of this section.
<br /> (1)For purposes of this section, "personnel who manage universal waste" means any persons who consolidate,
<br /> sort,treat, recycle, package for transport, offer for transport, or physically relocate containers of universal waste.
<br /> (2)Persons who, in the course of their normal duties, only generate universal wastes from onsite sources and place
<br /> them into accumulation containers, areas or locations are not"personnel who manage universal waste" (e.g., an
<br /> office worker who removes spent batteries from an electronic device).
<br /> (b)A universal waste handler shall initially train and provide annually,thereafter,training to all personnel who
<br /> manage or who supervise those who manage universal wastes.Training materials shall be in the form of any written
<br /> media (e.g., brochures, electronic mail, company letters, pamphlets, posters, etc.)and shall include the date of that
<br /> material. This training shall include, at a minimum:
<br /> (1)The types and hazards associated with the universal waste that personnel may manage at the facility(e.g.,
<br /> hazards due to leaded glass in CRT devices or CRTs);
<br /> (2)The proper disposition of universal wastes managed at the facility(e.g., the locations of universal waste
<br /> containers, or the location of a centralized universal waste accumulation area);
<br /> (3)The proper procedures for responding to releases of universal wastes(e.g., spilled CRT glass)including the
<br /> position titles and the means of contacting those personnel at the facility who are designated to respond to reports
<br /> of releases(e.g., spilled CRT glass)and/or to respond to questions received from other personnel at the facility; and
<br /> (4)The applicable requirements contained in this chapter regarding labeling, collecting, handling, consolidating, and
<br /> shipping universal wastes at the facility, including, but not limited to, the prohibition on the disposal of universal
<br /> wastes, and for personnel involved in shipping universal wastes who are"hazmat employees", as defined in 49
<br /> Code of Federal Regulations section 171.8, the applicable requirements prescribed in 49 Code of Federal
<br /> Regulations section 172.704.
<br /> (c)The universal waste handler shall maintain a written record by date(e.g., a list of personnel who have received
<br /> either initial or annual training information)indicating the names of personnel who received the information specified
<br /> in subsection (b)of this section.
<br /> (d)The universal waste handler shall maintain the record specified in subsection (c)of this section for at least three
<br /> years from the date the person last managed any universal waste at the facility. The record of training for a"hazmat
<br /> employee", as defined in 49 Code of Federal Regulations section 171.8, shall meet the applicable requirements of
<br /> 49 Code of Federal Regulations section 172.704(d). The training record may accompany a person who is
<br /> transferred within the same company.
<br /> California Code, Health and Safety Code-HSC§25201.16
<br /> (h)A universal waste handler may process a universal waste aerosol can to remove and collect the contents of the
<br /> universal waste aerosol can, if the universal waste handler meets all of the following requirements:
<br /> (8)The handler ensures,through a training program utilizing the written operating procedures developed pursuant to
<br /> paragraph (4),that each employee is thoroughly familiar with the procedure for sorting and processing universal
<br /> waste aerosol cans, and proper waste handling and emergency procedures relevant to his or her responsibilities
<br /> during normal facility operations and emergencies.
<br /> CORRECTIVE ACTION: Immediately provide employees with UW training in the detail required by this section.
<br /> Generate a training record with a list of trained employees and the date of training. Provide a corrective action
<br /> statement, the training record, a detailed description of the training, and supporting documentation to the San
<br /> Joaquin County Environmental Health Department(EHD)within 30 days.
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