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CERS: Employee Training Plan

The Employee Training Plan task is part of the California Environmental Reporting System compliance program.

CERS ICON Employee Training Plan

Overview

The Emergency Response/Contingency Plan includes a section to describe employee training. It will usually fulfill the requirement to have a training plan. However, we advise all businesses to  develop a separate training plan that addresses the specific hazards presented at the work place. Employee training is very important. It is a major component of running a safe workplace. It also protects business operators from potential liability. The type and scope of  training program requirements for a facility depends largely on if it is a Large Quantity Generator (LQG), or a Small Quantity Generator (SQG) of hazardous waste. Below is a summary of the requirements for each category.
 

Small Quantity Generators (mandatory minimum requirements)

Small quantity generators (sites that generate less than 1000 kg/month) have fewer requirements:
  • The facility is required to provide training that ensures all employees are trained in proper waste handling and emergency procedures.

Also recommended for small quantity generators

A written training plan that includes at a minimum:

  • Training curriculum (This can be as simple as a copy of the training material used during instruction)
  • Records of training
We also encourage business operators to document employee violations of safety policies.
 

Large Quantity Generators

Large quantity generators (sites that generate more than 1000 kg/month) have more detailed requirements:

Training

  • Personnel must complete an annual classroom or on-the-job training session. The training must show employees how to complete duties safely and in compliance with regulatory requirements.
  • This training must be provided by a trained hazardous waste manager and must include:
    • Hazardous waste management.
    • Contingency plan implementation that includes:
      • Emergency procedures.
      • Emergency equipment’emergency systems.
      • Other applicable emergency plan implementation requirements.
  • Training must be provided within 6 months of initial employment or assignment to a facility. 
  • Untrained personnel may not work without supervision until they are trained.
  • Training must be renewed annually.

Documentation

  • A written training plan that includes: 
    • The job title for each position related to hazardous waste management.
    • A roster of employees with job titles.
    • A written job description for each position related to hazardous waste management that includes the requisite skill, education or other qualifications and duties of employees assigned to each position.
    • The training material covered for each job title.
  • Records of training.
  • Three years worth of training records (including those persons no longer at the facility).

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