Appendix C - Training Table 2 TABLE II Minimum Training Requirements for Personnel Engaged at EM-40 RCRA TSD Sites Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 employees directly 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 involved in TSD facilities and (ii) require a minimum (p)(7)(i) and (ii), operations on a daily or of 24 hours Initial Health DOE 1993b, occasional basis, i.e., and Safety Training, or DOE 1993c, supervising contractor equivalent instruction, for DOE 1994, and employees and evaluating current employees. However, NIEHS 1993 program outcome. EM-40 adoption of OSHA standards requires a minimum of 40 hours Initial Health and Safety Training and 24 hours supervised field experience. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 Subcontractor TSD Facility and (ii) require a minimum (p)(7)(i) and (ii), Manager (FM) responsible of 24 hours Initial Health DOE 1993b, for operations such as and Safety Training, or DOE 1993c, handling drums or equivalent instruction, for DOE 1994, and containers. The TSD FM is current employees. However, NIEHS 1993 also responsible for EM-40 adoption of OSHA supervising TSD employees standards requires a minimum and has authority to of 40 hours Initial Health direct response and Safety Training and 24 operations. hours supervised field experience. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 Subcontractor Facility and (ii) require a minimum (p)(7)(i) and (ii), Safety and of 24 hours Initial Health DOE 1993b, Health Officer (FSHO) and Safety Training, or DOE 1993c, responsible for equivalent instruction, for DOE 1994, and implementation of all current employees. However, NIEHS 1993 aspects of Safety and EM-40 adoption of OSHA Health Plan at the standards requires a minimum facility. The FSHO is of 40 hours Initial Health also responsible for and Safety Training and 24 implementing the Emergency hours supervised field Response Plan whenever experience. warranted at the facility. FSHO has authority to direct response operations and reports to upper level management. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 Subcontractor Designated and (ii) require a minimum (p)(7)(i) and (ii), Emergency Response Person of 24 hours Initial Health DOE 1993b, (DERP) certified in first and Safety Training, or DOE 1993c, aid/CPR by the American equivalent instruction, for DOE 1994, and Red Cross, or equivalent. current employees. However, NIEHS 1993 The DERP is assigned to EM-40 adoption of OSHA the facility crew to standards requires a minimum provide first aid and CPR of 40 hours Initial Health services and is on the and Safety Training and 24 facility whenever hours supervised field employees are working at experience. the facility. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 Subcontractor Facility and (ii) require a minimum (p)(7)(i) and (ii), Command Post Supervisor or of 24 hours Initial Health DOE 1993b, Facility Emergency and Safety Training, or DOE 1993c, Coordinator (FEC) equivalent instruction, for DOE 1994, and responsible for current employees. However, NIEHS 1993 implementing the emergency EM-40 adoption of OSHA plan, whenever conditions standards requires a minimum at the facility warrant of 40 hours Initial Health such action. The FEC who and Safety Training and 24 may be the same person as hours supervised field the TSD Facility Manager experience. conducts activities such as evacuation, emergency transport of facility personnel, as necessary, and notifies emergency response units and appropriate management staff. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Contractor or 29 CFR 1910.120(p)(7)(i) 29 CFR 1910.120 Subcontractor facility and (ii) require a minimum (p)(7)(i) and (ii), operators engaged in of 24 hours Initial Health DOE 1993b, activities such as and Safety Training, or DOE 1993c, handling drums or equivalent instruction, for DOE 1994, and containers, or operation current employees. However, NIEHS 1993 of a treatment unit such EM-40 adoption of OSHA as an incinerator or standards requires a minimum activated carbon of 40 hours Initial Health adsorption system. and Safety Training and 24 hours supervised field experience. EM-40 requires a minimum DOE 1993b, of 8 hours Supervisor DOE 1993c, Training. DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120(p), standards requires a minimum DOE 1991, of Facility-Specific DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 EM-40 adoption of OSHA 29 CFR 1910.120 standards requires a minimum (p)(7)(i), of 8 hours Annual Refresher DOE 1993b, Training. DOE 1993c, DOE 1994 and NIEHS 1993 Emergency Response and 29 CFR 1910.120 Periodic Rehearsal Training. (p)(8)(iv), DOE 1993b, DOE 1993c, DOE 1994 and NIEHS 1993 Hazard Communication 29 CFR 1910.120, Training 29 CFR 1926.59 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 Operational Personnel Training Requirement Reference(s) ---------------------------------------------------------------------------- EM-40 Visitors/Non-Workers OSHA requires no minimum DOE 1993b, who enter the facility. training for DOE 1993c, PPE should be issued to Visitors/Non-Workers who DOE 1994, and all Visitors/Non-Workers, enter the facility. NIEHS 1993 and they should be However, EM-40 requires a instructed on its proper minimum of 40 hours Initial use. All EM-40 employees Health and Safety Training and offsite personnel not and 24 hours supervised directly involved with TSD field experience.* facility operations, are Visitors/Non-Workers. Facility-Specific Training DOE 1991, DOE 1993b, DOE 1993c, DOE 1994, and NIEHS 1993 8 hours Annual Refresher DOE 1993b, Training.* DOE 1993c, DOE 1994, and NIEHS 1993 Radiological Worker Training, DOE Notice 5480.6, if applicable. For details, DOE 1992, see DOE Radiological Control DOE 1993b, Manual (DOE/EH-0256T). DOE 1993c, DOE 1994 and NIEHS 1993 * This training is required for all visitors/nonworkers who enter an exclusion/decontamination zone or other areas where Level A, B, or C PPE is required. This training is not required for visitors/non-workers who only enter areas where either Level D or no PPE is required. See memo from Mr. Pat Whitfield, EM-40 to EM-40 Offices, dated February 2, 1994.