Jeff Those are the federal Reqs. You have state reqs that you need to meet also. When we were inspected by the Colorado Department of Public Health they told us that we had to have training and that it did not matter how many employees that I had since I was now considered a small quantity generator verses a conditionally exempt small quantity generator. EPA is going to be different than OSHA. With OSHA you have to have 10 or more employees to be subject to the reqs. I have less than 10 employees, but we perform training on everything and have a considerable safety manual that includes practically everything.
One other thing, if you are a small business the government will provide you with assistance you just need to go to the OSHA website, they may also provide assistance to others. We had a voluntary inspection from OSHA. It took a while to happen since we are not considered a high risk workplace, but it was helpful. Liz Elizabeth A. Chlipala, BS, HTL(ASCP)QIHC Manager Premier Laboratory, LLC PO Box 18592 Boulder, Colorado 80308 office (303) 682-3949 fax (303) 682-9060 www.premierlab.com Ship to Address: 1567 Skyway Drive, Unit E Longmont, Colorado 80504 -----Original Message----- From: Jeff Birkner [mailto:jbirk...@colabserv.com] Sent: Friday, March 04, 2011 7:47 AM To: Podawiltz, Thomas; Fortin, Joyce; Liz Chlipala; Rae Staskiewicz; Histonet Subject: RE: [Histonet] Competancies for handling hazardous material I have reviewed 40 CFR Part 262 and the only training requirements that I see are the RCRA for Large Quantity generators and those for university or academic institutions. I do not see any requirements for medical laboratories that fall outside of the above generator/institution types. Can someone point me in the right direction if this is not correct? Thanks! Jeffrey C. Birkner, CT(ASCP) Manager, Pathology Laboratory Section Collaborative Laboratory Services, L.L.C. 1005 Pennsylvania Ave, Suite 102 Ottumwa, IA 52501 641-455-5414 ORHC Extension #3538 jbirk...@colabserv.com -----Original Message----- From: histonet-boun...@lists.utsouthwestern.edu [mailto:histonet-boun...@lists.utsouthwestern.edu] On Behalf Of Podawiltz, Thomas Sent: Thursday, March 03, 2011 2:04 PM To: Fortin, Joyce; Liz Chlipala; Rae Staskiewicz; Histonet Subject: RE: [Histonet] Competancies for handling hazardous material We did a self audit about three or four years ago. My area is considered a small waste storage area and yes there is required training. In New Hampshire, we can get that training through the state. Tom Podawiltz, HT (ASCP) Histology Section Head/Laboratory Safety Officer LRGHealthcare 603-524-3211 ext: 3220 ________________________________________ From: histonet-boun...@lists.utsouthwestern.edu [histonet-boun...@lists.utsouthwestern.edu] On Behalf Of Fortin, Joyce [joyce.for...@uhsinc.com] Sent: Wednesday, March 02, 2011 1:21 PM To: Liz Chlipala; Rae Staskiewicz; Histonet Subject: RE: [Histonet] Competancies for handling hazardous material Could I PLEASE have this information, too? I would really appreciate it. Joyce Fortin Histology Supervisor Palmdale Regional Medical Center 38600 Medical Center Drive Palmdale, California 93551 Phone 661-382-5723 Fax 661-382-5747 email: joyce.for...@uhsinc.com ________________________________________ From: histonet-boun...@lists.utsouthwestern.edu [histonet-boun...@lists.utsouthwestern.edu] On Behalf Of Liz Chlipala [l...@premierlab.com] Sent: Wednesday, February 23, 2011 6:51 PM To: Rae Staskiewicz; Histonet Subject: RE: [Histonet] Competancies for handling hazardous material Rae We have, you need standard training, but the individuals who inspected our lab did not mention compentances. But our inspection happened because we needed to switch from a conditionally exempt small quantity generator to a small quantitiy generator and we then needed to register with the state, etc. They primarily focused on our waste streams and what chemicals were in the lab. I'm not at work right now, but I'll check tomorrow to see if I have anything that I can share with you. Liz ________________________________ From: histonet-boun...@lists.utsouthwestern.edu on behalf of Rae Staskiewicz Sent: Wed 2/23/2011 6:19 PM To: Histonet Subject: [Histonet] Competancies for handling hazardous material Has anyone been inspected by the EPA regarding removal of hazardous chemicals? It came up in a safety meeting that I should have training and competencies (beyond general safety training and PPE) for pouring xylene from staining dishes and processors into accumulation containers. Rae Ann Staskiewicz _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet UHS Confidentiality Notice: This e-mail message, including any attachments, is for the sole use of the intended recipient (s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution of this information is prohibited. If this was sent to you in error, please notify the sender by reply e-mail and destroy all copies of the original message. _______________________________________________ Histonet mailing list Histonet@lists.utsouthwestern.edu http://lists.utsouthwestern.edu/mailman/listinfo/histonet THIS MESSAGE IS CONFIDENTIAL. 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