[00:00:00] :  This is, This show is brought to you by safety. FM. The following program is rated for mature audiences. It may contain adult language, adult situations and frank safety discussions. The names in certain details have been changed to protect the safe and the unsafe. But believe me, every item in here is true. When you think about the ancient title of Knight, what do you think of someone who is honorable, Brave, helpful and chivalrous. Many of those old orders still exist and they help people unify and develop leaders in the community. In March 2020 at the beginning of the pandemic, safety nights was formed. It's an online community created by and for safety professionals, I joined and was blown away. We share information to develop and support leadership within the safety community. Are members come from all areas of safety and the best part of all of this, it's free. We are not like some of those other safety groups that charge money or are subject to the whims of sensors and group administrators visit safety nights at safety nights dot com. That safety nights and nights is spelled with a K. Yeah. 40 Hour has a lot for training today on safety wars. So a large part of our business here at safety wars has always been hazardous waste site operations and emergency response training for both the construction industry and also general industry. They're identical regulations. Just different locations in the Regulation 1910 being general industry, 19 2016 construction. So the first thing that you need to work out on any of these projects is does this regulation applied to me? What I always do with my clients and anybody else is I go over to section eight of the regulation, the scope, the application and the definitions. What you always do with the regulation is you go over to what the application of that regulation is meaning doesn't apply to me. It's sort of like what the I. R. S. Where they're not going to tell you exactly how much taxes you owe. You have to figure out what applies to you. And if there's any questions, they come back. What is the scope this section? And I'm quoting this. This section covers the following operations unless the employer can demonstrate that the operation does not involve employee exposure or the reasonable possibility for employee exposure to safety and health hazards. one clean up operations required by government bodies, I'm not going to quote the whole thing but if it's required by government body involving hazardous substances that are conducted at uncontrolled hazardous waste sites including but not limited to the EPA's national priorities list. State priority lists or sites recommended for any of those lists. Corrective actions involving cleanup operations at record sites. That's resource Conservation and Recovery Act sites, voluntary cleanup operations at uncontrolled hazardous waste sites. Operations involving hazardous wastes that are conducted at PSD facilities that are regulated under the EPA regulations and emergency response operations. What you need to do is figure out which one of these supplies to you. Then you can worry about training and what the appropriate training is. Basically at all these sites, you have to determine whether you're going to need 24 hour or 40 hour. Has offered training has offers hazard space operations and emergency response. It's not a new sandwich that let's say burger king. I'm not getting burger king plug here and you determine what type of training you're going to need. Are you going to be a general site worker? You may need 40 hour training. If you're only occasionally on site, you may need 24 hours of instruction and after that training is done, then you're going to need a certain amount of actual hands on experience in the field, either three days or one day, depending on what level of training your employer chooses. Now, Let's say that you have someone coming in and they say, oh yeah, I'm 40 hour has whopper trained, everything is great. You're the employer, you have to verify that they actually have training. So you ask for the certificate, you call up the place and said you need no john smith That you do training with you and you need to verify that the second thing you need to do is decide whether or not that training is applicable to what you do. I'm going to of course tell a story here like I always do 11 years ago, I was involved in the Gulf oil spill cleanup down in Florida and on the Gulf coast there. My company that I worked for at the time I was part owner of. It was Very involved in training. We trained about 10% of the workforce there and 40 hour has whopper. I had to design a class for people who were coming into the workforce again where it was like a re entry program. That's a buzzword today. They didn't call it that then. They called it workfare or something along those lines. People had varying experiences. But these are folks that typically had very little, if any work experience, they had no work experience and hazardous waste, started operations and emergency response. A lot of them came out of prisons, came out of jails, Rehabs. They had all different types of stories and that's fine. But they still need 40 hour has what we're training. So the clients that I was working for down there and with, they have used this pool of people trying to get back on their feet, trying to make a life for themselves, trying to do the right thing. A lot of companies down there and it's been a major issue for uh certain industries like the meatpacking industry, working with food, uh huh rendering plants, things of that nature where they hire if these folks on, it's been in the news quite often in the last month or so and they feel that OSHA, the rules don't apply to them. They hire them erroneously often as independent contractors and independent contractors typically do not need to obey or follow any OSHA regulations. And what's happening is a lot of people are getting hurt. This is not something new for me because on the gulf oil spill, a lot of companies were doing fraudulent training down there. So we're not giving them training for whatever reason or we're going to throw in a couple of videos, blah, blah, blah, blah, blah, raised them through the training. We actually were audited by BP and all of our training was on videotape to prove that we were actually doing 40 hour training. Now here's the problem. I had to turn away a lot of people from that training because the training that we were doing for our people was not applicable to what some other people needed. For example, some people came into the training classes. Hey, we're going to be working for an engineering firm doing water sampling or doing some type of environmental sampling. I said, look, we're coming marine operations here and emergency response training for the specific group of people here. And a lot of this stuff I would call today stem training or steam training depending on what part of the country you're from, uh, that my Children go through at summer camp. Extra curricular activities where they're teaching people about basic science and a lot of that class that I thought was literally on basic science. So for example, we couldn't say oil floats on water. We would actually have to get a glass of water. We're gonna have to get some oil, vegetable oil, put the vegetable oil in the glass and show them that oil floats on water. And all of our training was very tactile, meaning hands on teaching about the equipment and everything else that was inappropriate for, let's say, an engineer to take that level of training because it really didn't apply to them. And we did things that apply to specifically what they were doing, A company that has people coming onto staff that Have training elsewhere. You need to evaluate if that training is applicable to what you're doing and what do you do if it is applicable? You don't do anything a 40 hour training. We're doing this activity. We know that with that drop that we have assigned here, that person is going to be all fine and dandy. We're going to be nice and sympathetic or you can have the other situation where, well this person had training and they were doing whatever on land. Now we're gonna be doing right time response or marine response training. That training is different than if you're going to have a land based response or a short based response, you're going to have to go into boating safety. You're going to have to go into how to deploy boom on water containment booms to contain the oil. You may have to discuss some of the surfactants and other chemicals. I'm not gonna mention their names or that we use to control oil spills. You're going to have to maybe go into whether these are all hazards there. Are they chemical hazards? No, but there are physical hazards and other hazards that are involved here that you're going to have to cover. Also Cold stress, cold weather Survival, cold water survival, any of those things, emergency operations all have to go into the training. And I'm gonna tell you often we go well beyond the 40 hour training when we're doing this stuff. So What do you do you have to determine whether or not that training is applicable now for the one day, if you get the 24 hour of course or the three day, if you get the 40 hour course, you can look in the regulation to determine what's appropriate to you. You need to go and for some type of training afterwards but it has to be applicable to what you're doing for this week. I had to train a whole bunch of supervisors and how they had just completed the 40 hour course. How to be a supervisor at a hazardous waste site. What do we look for? This is how you do your job, this is how you supervise the work, it's all hands on. So we had to take them through three days of that training. What the hazards are, this is what your job is, is what supervisor is. That's not the same thing as let's say an equipment operator or laborers with three days hands on it. Training out there. You're gonna be a little bit different. Maybe it's going to be how we're going to set up deacon areas. There's also what we covered this week but more hands on this is how you do things and you have someone who is a trained supervisor for this and also you need to have management and supervising training on top of that three days and thats classroom training. So there's a lot of training involved here. You need to evaluate it and you need to evaluate whether or not it's applicable to actually what you're doing now. So what are some of your options for? I'm not saying the training is not applicable, your people are not trained in this area. All different types of options. You can run them through the full 40 hour course. That's what some of my clients do. They say, well we have new people coming on, we don't know where they're coming from. They are able to produce a certificate of training. We don't know whether it's valid or not. Maybe a company went out of business, maybe they haven't had an eight hour refresher which is required every year For for a decade. So maybe we need to run them through the whole 40 hour course. Again, perhaps it's some type of supplemental training that you have to have their, perhaps we could do some type of equivalency training if it applies where they've had some other training that might apply to this. All different types of options. You just have to sit down with a qualified person. Probably a credential person or you have to really read the regulations of the letter of interpretation. I'm not making recommendations on training here, but these are some of the thought processes that you need to go through with the training. Also, if you need training and hazardous waste site operations and emergency response. Give us a call, contact us through our website. You can email me at gym at safety wars dot com and we could do all different types of training. We do zoom classes, zoom style live training. That way we could come out to your facility, you could come through our facility and do training. Whereas all different types of options that we could do. Usually if things are done on zoom or choose your platform, we have the last day where we have hands on training with live instructors and it's live instructors throughout all of our training. So give us a try. I'd love to do your training for you. I'm into it. I've been doing it pretty much for about 30 years, uh Maybe in total for 15 on my own. I started doing the hazardous waste site work as a yard boy, quote unquote yard boy when I was 16. So I'm pretty familiar with this stuff. And we also have other trainers that are very experienced in the field and add during the training classes for safety wars. This is jim, polster the views and opinions expressed on this podcast are those of the host and its guests and do not necessarily reflect the official policy or position of the company. Examples of analysis discussed within this podcast are only examples. It should not be utilized in the real world as the only solution available as they are based only on very limited and dated open source information, assumptions made within this analysis are not reflective of the position of the company. No part of this podcast may be reproduced stored in a retrieval system or transmitted in any form or by any means mechanical, electronic recording or otherwise. Without prior written permission of the creator of the podcast, jay allen. Mhm