1. MRW Operator Training Requirements New L&I rules for health and safety training. No longer applies: Chapter 296-62 Part P, Hazardous Waste Operations and Treatment, Storage, and Disposal Facilities. Historically used to determine MRW training. Changed (or will be soon) to apply only to agricultural operations.

2. New rule, but also does not technically apply to MRW: Chapter 296-843 WAC, Hazardous Waste Operations. No substantial change from 296-62 Part P. Adopted ’04. Addresses 8-, 24-, 40-, and 80-hour courses. WAC 296-843-100 Scope. This chapter applies if you have any of the following: … Employees performing clean-up operations at an uncontrolled hazardous waste site. Sites include, but are not limited to: … – Unlisted sites recognized by a federal, state or local government as an uncontrolled hazardous waste site…

3. MRW facilities are generally not considered uncontrolled if have an operating plan addressing health and safety requirements to ensure proper hazard management. Technically, the 24-hour course is no longer required.

4. What does apply? Chapter 296-800 WAC, Safety and Health Core Rules. Very general, no specific requirements. Employers must: Provide a safe workplace Free of recognized hazards Protect from chemical agents Accident prevention program Train in PPE Chemical hazard communication Etc.

5. What should employers do?: An MRW facility can be viewed as uncontrolled very easily – people leaving items when facility is closed, unknown substances – and 24-hr training required. Employers are still responsible for lots of other general health and safety requirements, as mentioned earlier. The option of 24-hour training (or more) is a good idea and conveniently will take care of many employer responsibilities.

6. L&I Contact L&I has separate compliance vs. assistance staff. Will come review facilities to help determine what training is necessary. Also will take complaints if, for example, employer, contractor, subcontractor refuse to provide adequate training. Cheryl Christian, MS. CIH Industrial Hygienist WA State Department of Labor and Industries WISHA Policy and Technical Services P.O. Box 44610 Olympia, WA 98504-4610 (360) 902-5732 chrh235@Lni.wa.gov