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The following is an itemized list of hazardous waste violations that have not been <br /> addressed for JAAS AUTO SERVICE as of Apri129, 2019. <br /> Open violations from June 16, 2015 inspection <br /> Violation#117- Failed to complete training on hazardous waste management and emergency response <br /> procedures. <br /> According to Mr. San, he gives instruction on the proper clean up and handling of hazardous waste whenever he <br /> sees a problem in the shop, and he has instructed his employees not to work on vehicles or spill vehicle fluids <br /> outside, but has not conducted a full training for his employees. Personnel who handle hazardous waste shall be <br /> trained within six months of assignment and take part in an annual review of the initial training received. This <br /> program shall be directed by a person trained in hazardous waste management procedures. At a minimum, the <br /> training program shall be designed to ensure that facility personnel are able to respond effectively to emergencies <br /> by familiarizing them with emergency procedures, emergency equipment, and emergency systems, including where <br /> applicable: <br /> - hazardous waste management procedures relevant to the positions in which they are employed <br /> -contingency plan implementation <br /> - procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment <br /> - key parameters for automatic waste feed cut-off systems <br /> -communications or alarm systems <br /> - response to fires or explosions <br /> - response to ground-water contamination incidents <br /> -shutdown of operations <br /> The owner or operator shall maintain the following documents and records at the facility: <br /> 1. the job title for each position at the facility related to hazardous waste management, and the name of each <br /> employee filling each job; <br /> 2. written job description for each position listed above; <br /> 3. written description of the type and amount of both introductory and continuing training that will be given to <br /> each person filing positions listed above; <br /> 4. records that document that the training has been given to and completed by facility personnel. <br /> Training records on current employees shall be kept until closure of the facility. Training records on former <br /> employees shall be kept for at least three years from the date the employee last worked at the facility. Immediately <br /> provide employees with initial or refresher hazardous waste training. Submit a copy of the roster and the syllabus to <br /> the EHD. <br /> Violation #118- Failed to maintain complete personnel training records. <br /> Employee training records for the management of hazardous waste were not available on site. Employee training <br /> records shall include: <br /> 1. the job title for each position at the facility related to hazardous waste management, and the name of each <br /> employee filling each job; <br /> 2. written job description for each position listed above; <br /> 3. written description of the type and amount of both introductory and continuing training that will be given to <br /> each person filing positions listed above; <br /> 4. records that document that the training has been given to and completed by facility personnel. <br /> Training records on current employees shall be kept until closure of the facility. Training records on former <br /> employees shall be kept for at least three years from the date the employee last worked at the facility. Ensure that <br /> employee training is properly documented. Submit a copy of the completed training records to the EHD. <br /> Violation #119-Failed to keep copies of consolidated manifesting receipts for three years. <br /> Copies of hazardous waste disposal records for the last three years were not found on site. Hazardous waste <br /> generators shall retain copies of all manifests signed off by the disposal facility and all receipts used in a <br /> consolidated manifesting procedure on site for three years and have them readily available for review. Immediately <br /> locate a copy of all manifests and receipts for the last three years, maintain them on site, and submit copies to the <br /> EHD. <br /> Page 10 of 17 <br />