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SAN JOAQUIN
<br />CC LJ N T Y -------
<br />Environmental Health Department
<br />RCRA Large Quantity Hazardous Waste Generator Inspection Report
<br />Facility Name:
<br />Facility Address:
<br />Date:
<br />AMAZON.COM SERVICES, INC-SMF3
<br />3923 S B ST, STOCKTON
<br />March 02, 2020
<br />SUMMARY OF VIOLATIONS
<br />(CLASS I, CLASS II, or MINOR - Notice to Comply)
<br />Item #
<br />Remarks
<br />709
<br />CCR 66273.36 UWH failed to train employees and maintain records on UW handling and emergency 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 universal waste. Per Steve McCoy (Safety Manager) universal waste training is included in
<br />the RCRA training course. A summary of the topics included in the RCRA training course was not available for
<br />review during the inspection.
<br />REGULATION GUIDANCE: (a) A universal waste handler shall ensure that all personnel who manage universal
<br />wastes at the universal waste handler's facility are thoroughly familiar with proper universal waste management and
<br />emergency response procedures relative to those persons' responsibilities, as specified in subsections (b) and (c) of
<br />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 />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.
<br />This is a Class II violation.
<br />FA0025256 PR0544422 SCO01 03/02/2020
<br />EHD 22-03 Rev. 9/20/2019 Page 11 of 12 RCRA Large Quantity Hazardous Waste Generator OIR
<br />1868 E. Hazelton Avenue I Stockton, California 95205 1 T 209 468-3420 1 F 209 464-0138 1 www.sjcehd.com
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