7. Adequacy and appropriateness of the role of student evaluations to provide feedback for training program improvement.
E. Students
Adequacy and appropriateness of the program for accepting students should be considered, including
1. Assurance that the student already possess the necessary skills for their job, including necessary documentation.
2. Appropriateness of methods the program uses to ensure that recruits are capable of satisfactorily completing training.
3. Review and compliance with any medical clearance policy.
F. Institutional Environment and Administrative Support
The adequacy and appropriateness of the institutional environment and administrative support system for the training program should be considered, including
1. Adequacy of the institutional commitment to the employee training program.
2. Adequacy and appropriateness of the administrative structure and administrative support.
G.Summary of Evaluation Questions
Key questions for evaluating the quality and appropriateness of an overall training program should include the following:
1. Are the program objectives clearly stated?
2. Is the program accomplishing its objectives?
3. Are appropriate facilities and staff available?
4. Is there an appropriate mix of classroom, demonstration, and hands-on training?
5. Is the program providing quality employee health and safety training that fully meets the intent of regulatory requirements?
6. What are the program's main strengths?
7. What are the program's main weaknesses?
8. What is recommended to improve the program?
9. Are instructors instructing according to their training outlines?
10. Is the evaluation tool current and appropriate for the program content?
11. Is the course material current and relevant to the target group?
Suggested Training Curriculum Guidelines
The following training curriculum guidelines are for those operations specifically identified in 29 CFR 1910.120 as requiring training. Issues such as qualifications of instructors, training certification, and similar criteria appropriate to all categories of operations addressed in 1910.120 have been covered in the preceding section and are not readdressed in each of the generic guidelines. Basic core requirements for training programs that are addressed include
1. General Hazardous Waste Operations
2. RCRA operations-Treatment, storage, and disposal facilities.
3. Emergency Response.
A. General Hazardous Waste Operations and Site-specific Training
1. Off-site training.Training course content for hazardous waste operations, required by 29 CFR 1910.120(e), should include the following topics or procedures:
a. Regulatory knowledge.
(1) An review of 29 CFR 1910.120 and the core elements of an occupational safety and health program.
(2) The content of a medical surveillance program as outlined in 29 CFR 1910.120(f).
(3) The content of an effective site safety and health plan consistent with the requirements of 29 CFR 1910.120(b) (4) (ii).
(4) Emergency response plan and procedures as outlined in 29 CFR 1910.38 and 29 CFR 1910.120(1).
(5) Adequate illumination.
(6) Sanitation recommendation and equipment.
(7) Review and explanation of OSHA's hazard-communication standard (29 CFR 1910.1200) and lock-out-tag-out standard (29 CFR 1910.147).
(8) Review of other applicable standards including but not limited to those in the construction standards (29 CFR Part 1926).
(9) Rights and responsibilities of employers and employees under applicable OSHA and EPA laws.
b. Technical knowledge.
(1) Type of potential exposures to chemical, biological, and radiological hazards; types of human responses to these hazards and recognition of those responses; principles of toxicology and information about acute and chronic hazards; health and safety considerations of new technology.
(2) Fundamentals of chemical hazards including but not limited to vapor pressure, boiling points, flash points, ph, other physical and chemical properties.
(3) Fire and explosion hazards of chemicals.
(4) General safety hazards such as but not limited to electrical hazards, powered equipment hazards, motor vehicle hazards, walking-working surface hazards, excavation hazards, and hazards associated with working in hot and cold temperature extremes.
(5) Review and knowledge of confined space entry procedures in 29 CFR 1910.146.
(6) Work practices to minimize employee risk from site hazards.
(7) Safe use of engineering controls, equipment, and any new relevant safety technology or safety procedures.
(8) Review and demonstration of competency with air sampling and monitoring equipment that may be used in a site monitoring program.
(9) Container sampling procedures and safeguarding; general drum and container handling procedures including special requirement for laboratory waste packs, shock-sensitive wastes, and radioactive wastes.
