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TITLE 8 VIOLATIONS: <br /> No hazardous waste training program was found to be provided <br /> to employees. Such a program would require a minimum of 40 <br /> hours of hazardous waste recognition and personal safety <br /> equipment training. Section 5192 (D) (2) (A) , Title 8, CCR. <br /> (29 CFR Section 1910. 120) <br /> DISCUSSIONS WITH MANAGEMENT: <br /> Upon completion of the inspection a meeting was held with Mr. <br /> Smith and Mr. Tupas and all 4 inspection team members present. <br /> Mr. Smith was asked about the training requirements and if he <br /> or any of his staff had received 40 hours of hazardous waste <br /> training, this would include anyone who handled or treated the <br /> hazardous waste at the facility. Mr. Smith stated that he had <br /> taken a course on waste water treatment. I again asked Mr. <br /> Smith if he or his employees had taken a class in hazardous <br /> waste which included respiratory protection and hazardous <br /> waste recognition. Mr. Smith stated that one of his employees <br /> had taken a class in hazardous materials handling from Office <br /> of Emergency Services but admitted that the class was only one <br /> day. Mr. Smith was asked if he had a list of the duties of <br /> each employee and which employee was assigned to work on <br /> shipping and handling of the hazardous waste. Mr. Tupas <br /> stated that the employees were on an "on call" basis and no <br /> one was assigned to do hazardous waste. Mr. Smith was asked <br /> if he had a list of employees. Mr. Smith produced a list of <br /> employees which showed work areas for employees, but not <br /> specific duties such as hazardous waste handling. Mr. Smith <br /> at no time during this interview was able to provide any <br /> evidence that any employee as well as himself had received the <br /> 40 hours of required hazardous waste training. It was <br /> explained to Mr. Smith that he had several violations at the <br /> facility due to waste storage and handling. Mr. Smith related <br /> that his problems were related to the City of Stockton and <br /> their failure to issue RV Circuits a permit to discharge into <br /> the city sewage system. Mr. Smith said all of the problems <br /> would be gone in three days if he could discharge. It was <br /> explained to Mr. Smith and Tupas that several violations <br /> relating to shipping and storage of hazardous waste more than <br /> 90 days would not be related to the discharge problem. <br /> Several containers were noted which had been stored greater <br /> than 90 days. Mr. Smith stated that these problems were <br /> related to his employee that handles the waste, who must have <br /> missed shipping some of the waste barrels. Mr. Smith was <br /> informed that when a hazardous waste hauler comes in he should <br /> remove all the waste and it was not required to wait 90 days <br /> to ship, but 90 days was the maximum time a waste could be <br /> stored at the facility. It was also indicted to Mr. Smith <br /> that the area where the waste was stored was so crowded that <br /> it was impossible to see all the labels. It was related <br /> 9 <br />