# Presentation: 231235

## Hazardous Waste and Pollution PreventionTraining Program

- (Insert Forest Name)
- National Forest
- (Insert Date of Presentation)

## Line Officer’s Responsibilities
Hazardous Waste and Pollution Prevention Training Program
Why we are building the Program 
What we propose to do; describe the tools
When we propose to do our training/assessments
Where we propose to do our training/assessments
How the program helps meet Line Officers Responsibilities

- Hazardous Waste and Pollution Prevention Training Program
- Why we are building the Program
- What we propose to do; describe the tools
- When we propose to do our training/assessments
- Where we propose to do our training/assessments
- How the program helps meet Line Officers Responsibilities

- Today’s Topics *Hazardous Waste and Pollution Prevention**Training Program*

## Line Officer’s ResponsibilitiesExecutive Order 12088 “Federal Compliance With Pollution Control Standards”, October 13, 1978, as amended by Ex. Ord. No. 12580. Jan. 23, 1987.

**	**The head of each Executive agency is responsible for compliance with applicable pollution control standards:
- Toxic Substances Control Act
- Federal Water Pollution Control Act
- Public Health Service Act
- Clean Air Act
- Noise Control Act
**Solid Waste Disposal Act (42 U.S.C. 6901 et seq.)**
- Atomic Energy Act
- Marine Protection, research, and Sanctuaries Act
- Federal Insecticide, Research, and Sanctuaries Act

## Line Officer’s ResponsibilitiesForest Service Manual 

- 2160.43b - **Safety and Health Coordinators**. Safety and Health Coordinators have responsibility for:
- 1. Complying with the **Hazard Communication Standard** (29 CFR 1910.1200) at units that handle hazardous chemicals in greater than consumer-use quantities as described in FSM 2160.5, FSM 2161.42, and FSM 2162.5.
-  2. Coordinating **training for safe transportation** of hazardous materials (49 CFR 172; FSM 2161.44).
- 3. Complying with those portions of the the hazardous waste operations and emergency response regulations (29 CFR 1910.120) for **training**, personal protective equipment, and medical surveillance.
- 4. Coordinating the medical surveillance program and the environmental monitoring program outlined in FSH 6709.12 and 29 CFR 1926.62.
- 5. Maintaining documentation of all safety and health training required by 29 CFR 1910.120, 1910.1200, and 1910.1450 and 49 CFR 172, and ensuring refresher training is accomplished, as required in these regulations.
-  6. Complying with Occupational Safety and Health Administration (OSHA) regulations on occupational exposure to hazardous chemicals in laboratories (29 CFR 1910.1450; FSM 2161.43; FSM 2162.6).
- 7. Working with managers of units handling hazardous chemicals and oil to prepare a written site-specific contingency plan where required (FSM 2165.12).
- 8. **Ensuring hazardous materials management inspections (FSM 2161.3) are conducted on a routine basis**.
- Required: Washington Office, Regional Offices, Stations, **Forests**, and Laboratories.
- Recommended: Field units handling hazardous chemicals in greater than consumer use quantities (FSM 2160.5).

## Line Officer’s ResponsibilitiesForest Service Manual 

- 2160.43c - Pollution Prevention Coordinators. Pollution Prevention Coordinators have responsibility for:
- 1. Working with project managers to ensure that **chemicals procured are the least hazardous** of those available to accomplish the task and that excess quantities of hazardous chemicals are not procured.
- 2. Working with procurement personnel to ensure the life-cycle costs of chemicals are being considered in the procurement process.
- 3. Developing a written pollution prevention plan establishing goals for reduction or elimination of hazardous materials in conjunction with the Forest Service agency-wide pollution prevention strategy prepared in response to Executive Order 12856.
- 4. Working with the Emergency Response Coordinator to prepare site-specific contingency plans for all assigned areas on National Forest System lands and lands leased by the Forest Service that temporarily store hazardous waste as outlined in FSM 2165.11.
- 5. **Managing the unit's hazardous waste program including maintaining, at the point of generation, documentation of hazardous waste generation, accumulation, transportation, and disposal as required in 40 CFR 262**.
- 6. **Ensuring that hazardous waste management inspections (FSM 2161.3) are conducted on a routine basis**.
- Required: Washington Office, Regional Offices, Stations,** Forests**, Laboratories, Hazardous Waste Generating Units.
- Recommended: Field units handling greater than consumer use quantities (FSM 2160.5) of hazardous chemicals.

## Line Officer’s ResponsibilitiesForest Service Manual 

- 2161.04c - Line Officers. It is the responsibility of line officers to:
- 1. Ensure that the following training is provided, if appropriate, and that a permanent record of all employee safety and health training is maintained (FSM 2161.4):
- a. Emergency Response (FSM 2161.41a).
- b. Hazardous Waste Operations (FSM 2161.42b).
- c. Hazard Communication Standard - Employee Right-To- Know (FSM 2161.42).
- d. Occupational Exposure to Hazardous Chemicals in Laboratories (FSM 2161.43).
- e. Transportation of Hazardous Materials (FSM 2161.44).
- f. Respiratory Protection (FSM 2161.45).
- 2. Ensure that employees' activities relating to hazardous materials are within the scope of the employees' duties (FSM 2161.6).
- 3. Review and, if necessary, rewrite job descriptions to reflect employee involvement with hazardous materials (FSM 2161.6).
- 4. Ensure that the appropriate reports are made to the National Response Center and the Local Emergency Planning Committee or State Emergency Response Commission (FSM 2165.3, FSM 2165.31, FSM 2165.32).

## Line Officer’s ResponsibilitiesForest Service Manual 

## Line Officer’s ResponsibilitiesForest Service Manual 

## Line Officer’s ResponsibilitiesForest Service Manual 

- 2161.3 - Hazardous Materials Management Inspections. Conduct **annual inspections** at facilities that routinely handle more than consumer use quantities (FSM 2160.5) of hazardous materials. It is recommended that a hazardous material management inspection be conducted annually by personnel outside of the facility being inspected. The personnel conducting these inspections should be familiar with the requirements of the Resource Conservation and Recovery Act (RCRA) and the Occupational Safety and Health Administration (OSHA). Facility personnel should conduct internal compliance inspections more frequently. Hazardous materials and hazardous wastes **checklists**, which may be used in conducting these inspections, are available in the Environmental Engineering Laws and Issues Library (FSM 2160.6).

## 	“The USFS shall develop an enhanced hazardous waste operations and management training, waste minimization training, and pollution prevention training program for their staff at each of the seven national forests in Colorado”.

**Why Build A Hazardous Waste and Pollution Prevention Training Program?***C**olorado Compliance Order on Consent requires*:

- Ed Smith,
- Colorado Department of Health
- Inspecting Leaking Forest Service Drums
- October, 1998

## Forest Service Manual,  Title 2100 - 94 - 1, Environmental Management
2160 - Hazardous Materials Management
2160.3 - Policy
Provide the appropriate level of training to employees on the potential safety and health risks form hazardous materials in accordance with the employees duties.
Incorporate pollution prevention in all aspects of hazardous materials management.  Emphasize source reduction as the primary means of maintaining compliance with applicable Federal, State, and local environmental regulations.
Ensure proper handling, storage, transportation, and disposal of hazardous materials in all activities.  Prior to disposal of any material, consider reuse and recycling of that material. 
Consider need, employee risk of exposure, effectiveness, environmental impacts, economic efficiency, and availability of less hazardous alternatives when deciding whether and which hazardous materials to use.
Ensure appropriate and timely response to releases or threats of hazardous materials.

- 2160 - Hazardous Materials Management
- 2160.3 - Policy
- Provide the appropriate level of ***training ***to employees on the ***potential safety and health risks form hazardous materials*** in accordance with the employees duties.
- Incorporate ***pollution prevention*** in all aspects of hazardous materials management.  Emphasize ***source reduction*** as the primary means of maintaining compliance with applicable Federal, State, and local environmental regulations.
- Ensure ***proper handling, storage, transportation, and disposal*** of hazardous materials in all activities.  Prior to disposal of any material, consider ***reuse and recycling*** of that material.
- Consider need, employee risk of exposure, effectiveness, environmental impacts, economic efficiency, and availability of ***less hazardous*** alternatives when deciding whether and which hazardous materials to use.
- Ensure appropriate and timely response to ***releases*** or threats of hazardous materials.

**Why Build A Hazardous Waste and Pollution Prevention Training Program?***Forest Service Policy*

## What is Pollution Prevention?Change of Products and Production Processes to reduce pollution at the source.

- Increasing Priority

## Hazardous Waste and Pollution PreventionTraining Program Basis for Program Development

- Hazardous Waste and Pollution PreventionTraining Program *Basis for Program Development*

**The Region’s Program Should:**
- Adhere to the MOU with the State of Colorado
- Maximize cooperative and consultative process with;
*The State of Colorado*. Per the MOU, the State of Colorado will provide assistance at a cost of $40,000
*Region VIII of the EPA*.  Per the Regional Foresters agreement with the EPA (Region VIII) , we will work towards a partnership similar to the partnership developed between the EPA Region VIII and the National Park Service.
*National Park Service.* Build upon the successful “Park Environment 2000” program
- Include training for all employees working with hazardous materials and hazardous waste, including seasonal and temporary help.  Course attendance should be documented.

## Hazardous Waste and Pollution Prevention Training Program First Phase Completed

**Hazardous Waste and Pollution Prevention Training Program**** **First Phase Completed

- Enhanced hazardous waste operations and management training
- RCRA
- Course Emphasized:
***Proper handling, storage, transportation, and disposal*** of hazardous materials;
- Importance of ***HazCom*** and
***Pollution prevention***
- 16 Hour Training for Hazardous Waste personnel
- Regional Office March 3 - 5, 1999
- May give again this fall, based on demand

## The Objective for the Next Phase

-   To build on the Phase I training
-   Augment Phase I training with...
-   Individual forest/district surveys by a trained team
-   On-site training
-   On-the-spot compliance assistance
-   Pollution prevention assessments
-   Individual reports for each forest/district visited

## How Will This Be Accomplished?

-   The National Park Service, Intermountain Region, developed an integrated protocol that was adapted to the Forest Service:
-   Evolved over nearly 80 parks throughout 9 states
-   Involved tens-of-millions of acres, millions of 	visitors, thousands of employees
-   Covered over 5 years of work
-   Built upon a partnership with U.S. Environmental 	Protection Agency

## The Advantages of a Protocol

- Ensures that all areas in each forest/district will be covered
- Ensures that coverage will be the same between forests/districts, and between survey teams
- Enables forest/region comparison of results
- Standardizes recommendations for consistency across the Region

## The Elements of the Protocol

-   The NPS protocol to be adapted to the Forest 	Service will involve:
-   Tailoring all materials and processes to the Forest 	Service “culture”
-   Defining a series of detailed actions
-   Preparation and acquisition supporting materials
-   Development of comprehensive checklists

## The Players in the Project

-   The protocol will involve three primary groups 	or individuals:
-   Forest Service Regional Pollution Prevention Coordinator who is coordinating the project, providing over-arching information, and supporting extenuating circumstances
-   Individual forest/district line officer and staff
-   Individual forest/district “project coordinator”
-   Contractor survey team backed by materials and 	checklists

## The Project Coordinator

- Each forest/district has been asked to assign one individual to be the project coordinator for their site.  This coordinator will...
-   Coordinate the site visit
-   Accompany the survey team during the visit
-   Transition recommendations into action

## The Details of the Protocol

- The protocol being adapted to the Forest Service includes the materials, actions, and deliverables described in the following charts

## The Forest Service “Tool Kit”

- A Tool Kit for Environmental Management was developed to address the primary Wastestreams and functions found at most forest/districts

## The Forest Service “Tool Kit”

*Each wastestream and function was identified through common “icons”*

## The Forest Service “Tool Kit”

- Environmental issues of each wastestream/function is further discussed _*graphically*_ and in text

## The Forest Service “Tool Kit”

- Environmental issues of each wastestream/function is further discussed graphically and in _*text*_

## The Forest Service “Resource Manual”

- Provides information on products, equipment and service providers, together with summaries on key management issues

## The Forest Service “Resource Manual”

*Provides information on products, *_***equipment and service providers,***_* together with summaries on key management issues*

## The Forest Service “Resource Manual”

- A “Resource Manual” was developed to provide information on products, equipment and service providers, together with summaries on _***key management issues***_

## Beginning the Survey with  Introductions

- The sequence will begin with an  introduction of the survey team to the forest/district project coordinator.  This is usually conducted by telephone.

## Pre-visit Coordination

- The survey team will work with the project coordinator and set visit dates, and briefing arrangements

## The On-site Survey Visit

- A survey team consisting of two or three specialists will conduct the survey visit; a Regional Office specialist will be part of the team
- The visit will be coordinated with the Project Coordinator
- The visit will last from 1 to 3 days per district depending on areas to be covered and geographic diversity
- All districts in a Forest will be scheduled sequentially;  usually a Forest is covered in a two week block of time

## The Site Visit Begins with the In-Briefing and Training

- The site visit will begin with an “in-briefing” to forest/district participants (i.e. line officers, principal staff including support groups such as purchasing, and all people using hazardous materials or generating hazardous waste).

- Included will be training materials (see examples), summary of visit activities, expectations, and schedule of events

## On-site Interview Checklist

- Following the “in-briefing” the survey team will interview line-officers and key project participants on the full breadth of activities, areas of concern, environmental issues, and much more

## Wastestream/Function Checklist

- An extensive site survey checklist will guide the survey team to cover all functions and Wastestreams and record findings

## Survey Visit Focus Areas

-   The visit sight survey will include any area 	that involves...
-   All areas of environmental concern of past/present 	contamination
-   Functions that are generating hazardous waste
-   Areas involved in the primary wastestreams/ 	functions defined for the Forest Service

## Possible Areas of Concern

-   The visit sight survey will primarily focus on areas that involve...
-   Warehouse and storage areas, automotive maintenance functions, painting and carpenter activities, trail maintenance, forest service facilities used by concessionaires, hazardous material and waste storage, inventory management, laboratories...
- Locked facilities

## Out-Briefing Summary

- An “out-briefing” summary will be provided at the end of the site visit - to the group of key forest/district participants

- Included will be a summary of recommendations, observations, specific fact sheets, and supporting materials

## Compliance Fact Sheets

- A series of five environmental compliance fact sheets will be provided as necessary

## Pollution Prevention Fact Sheets

- A series of nearly 30  pollution prevention possibilities matched to the primary Wastestreams and functions of the “tool kit” will be provided as appropriate

## Forest/District Final Report

- A “final report” will be prepared for each forest/district visited.  It will include background information, summary of findings, pollution prevention recommendations, and management action list

## Current Training/Assessment Schedule

## The Path Forward From Here

- Set dates for training/assessments at the (Insert Forest Name) National Forest Supervisor’s Office and District Offices.
- Initially will schedule 2 days per office:
- 0.5 Days -  Instruction and In-Briefing
- 1.25 Days - Assessments
- 0.25 Days - Out-briefing
- Tentative dates: (Insert Dates)