Environmental Training Requirements for Meat Processors

Environmental Training Requirements for Meat Processors

Coulter Wood

Environmental Engineer

For 121 Years…….

Fortune 500 Company Over 19,500 Employees Over 2,100 Food products Over 350 Trademarks 34 Brands are #1 or #2 in their

category Internationally recognized Process over 9.0 million hogs

annually Process 1.23 billion pounds of

turkeys annually

manufacturing & distribution center locations

REFRIGERATED FOODS Algona, IA Alma Foods – Alma, KS Austin, MN Dold Foods - Wichita, KS Fremont, NE Knoxville, IA Lloyd’s BBQ – Mendota Heights, MN Osceola Food - Osceola, IA Rochelle Foods - Rochelle, IL Swiss American – Lathrop, CA AFFILIATED FOODS Burke Corp – Nevada, IA Dan’s Prize – Browerville, MN Dan’s Prize – Long Prairie, MN Clougherty Packing - Vernon, CA SAAG’s – San Leandro, CA

GROCERY PRODUCTS Atlanta Plant – Tucker,, GA Beloit, WI Don Miguel – Dallas, TX Mexican Accent – New Berlin, WI Progressive Processing - Dubuque, IA Skippy – Little Rock, AR Stockton, CA

SPECIALTY FOODS CFI – Sparta, WI CCP – Aurora, IL DCB – Bondurant, IA DCB – Mitchellville, IA DCB – Bremen, GA DCB – Duluth, GA DCB - Perrysburg, OH DCB – Quakertown, PA DCB – Savannah, GA DCB – Visalia, CA

JOTS JOTS – Barron, WI JOTS – Faribault, MN JOTS – Melrose, MN JOTS – Montevideo, MN West Central Turkeys – Pelican Rapids, MN JOTS – Willmar, MN (2)

DISTRIBUTION CENTERS Atlanta, GA LSI – Eldridge, IA Excel - Osceola, IA Excel – Dayton, OH Prism – Stockton, CA

Training Programs We May Have in Common

GOALS OF THIS PRESENTATION Discuss the regulatory programs that have environmental

training requirements To share some commonalities from our Environmental

Management System related to training programs Review some “best practices” in the administration of

employee training

Regulatory Programs

• Clean Air Act (CAA) • Clean Water Act (CWA) • Comprehensive Environmental Response, Compensation

and Liability Act (CERCLA) • Emergency Planning and Community Right to Know Act

(EPCRA) • National Environmental Policy Act (NEPA) • Oil Pollution Act (OPA) • Resource Conservation and Recovery Act (RCRA) • Safe Drinking Water Act (SDWA) • Superfund Amendments and Reauthorization Act (SARA) • Toxic Substances Control Act (TSCA)

Federal vs. State Requirements

State and/or local requirements are unique Refer to your specific regulating agencies

Most Common in the Meat Industry

NEPA and TSCA usually don’t apply

CAA, CWA, CERCLA, EPCRA, OPA, RCRA, SARA and SDWA

Clean Air Act Requirements

WHY IS THIS THING SO CUMBERSOME?!? Companies won’t likely have the same requirements… So, what does Hormel Foods face? 2-3 areas of training required…

Clean Air Act Requirements - CERTIFICATIONS

1. REFRIGERATION TECHNICIAN CERTIFICATIONS 40 CFR 82.161(a) Type I – Small Appliances Type II – Medium, High and Very High Pressure Type III – Low Pressure Applicances Universal – Combination of Pressures Provided by Technical Schools Certification cards MUST be readily available (or carried

on the person)

Clean Air Act Requirements - CERTIFICATIONS

2. EPA METHOD 9 OPACITY TESTING CERTIFICATION 40 CFR 60.11(b)

Emissions testing requirements? “Visual determination of the opacity of emissions

from stationary sources” Qualified observers can determine the opacity of a

plume Provided by your nearest “smoke school”

Clean Air Act Requirements - TRAINING

Risk Management Plan (RMP) 40 CFR 68.54 and 40 CFR 68.71 WHO? Program 2 or 3 Prevention Employees (covered processes) • Operators, maintenance personnel, shipping and receiving personnel WHEN?

Initial training plus a refresher every three years WHAT to COVER? • Specific safety and health hazards • Emergency operations including shutdown • Safe work practices applicable to job tasks INCLUDE: • Employee’s name • Date of Training • Means used to verify that the employee understood the training

Clean Air Act Requirements – Other potential areas for training

RMP Contractor training program Emergency Response Plan training

Permit-required training Condition of the permit may required additional training Typically enforces knowledge of the permit condition

Boiler Operator Training Typically a state requirement Not specifically “environmental”

Solid Waste Incinerators Hazardous waste incinerator Medical waste incinerator

TRIVIA TIME!!

Management of “large quantity” appliances applies to all facilities using industrial process refrigeration. What is the threshold level for a “large quantity” refrigeration unit? A. >10 lbs of refrigerant B. >50 lbs of refrigerant C. >75 lbs of refrigerant D. >100 lbs of refrigerant

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Clean Water Act Requirements

1. DIRECT DISCHARGE TO SURFACE WATER? State and/or Local Requirement Wastewater Treatment Operator CERTIFICATION As required or deemed necessary

Most states offer courses

WASTEWATER PRETREATMENT


Slug Control Plan for Significant Industrial Users (SIUs) 40 CFR 403.8(f) WHO? Operators and other pretreatment workers WHEN? As required by the POTW WHAT to COVER?

• Contents of the Slug Control Plan • Slug prevention and spill control • Reporting procedures • Response actions

INCLUDE: • Employee’s name • Date of Training


Clean Water Act

Pretreatment Operation State or POTW Requirement, or Recommended WHO? Operators and other pretreatment workers WHEN? Initial plus annual refresher WHAT to COVER?

• Proper operation of equipment • Maintenance plans • Daily inspections and logs/checklists • Sample collection and analysis




Storm Water Pollution Prevention Plan (SWPPP) Training NPDES or State-Equivalent Permit / EPA Multi Sector General

Permit (MSGP) WHO? Employees who work in areas where industrial or material

handling activities are exposed to stormwater, or who are responsible for implementing control measures.

• Maintenance, shipping/receiving personnel, pollution

prevention team members, inspectors, sample collection personnel

WHEN? Initial training plus annual refresher

INDUSTRIAL STORM WATER


Storm Water Pollution Prevention Plan (SWPPP) Training NPDES or State-Equivalent Permit / EPA Multi Sector General

Permit (MSGP) WHAT to COVER? • Contents of the SWPPP • Control measures and Best Management Practices (BMPs) • Spill response • Inspections and monitoring requirements • Maintenance, planning, reporting and documentation

requirements




Construction Site Operators at Industrial Facilities 40 CFR 122.26 WHO? Operators and foremen/superintendents WHEN? Implementation of Construction Permit WHAT to COVER? • Contents of the SWPPP • Best management practices including maintenance & inspections • Spill response • Inspection and monitoring requirements INCLUDE: • Employee’s name • Date of Training


Clean Water Act

No Exposure Facilities RECOMMENDED WHO? Maintenance, operations, shipping and receiving WHEN? Initial plus annual refresher WHAT to COVER? • Contents of the SWPPP • Definition of No Exposure • Areas of concern (dumpsters, transfer areas, shops, etc.) • Inspection and documentation requirements INCLUDE: • Employee’s name • Date of Training


TRIVIA TIME!!

With regard to the Clean Water Act, what do the following acronyms stand for? (Need all three!)

NPDES POTW MCL

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CERCLA and EPCRA

Emergency Release Reporting Training RECOMMENDED WHO? Individuals responsible for the handling or use of any hazardous substance WHEN? Initial plus annual refresher or as needed (based on conditions) WHAT to COVER? • Definitions: • Spill and/or release • Reportable release • Reportable quantity • Hazardous substance • Extremely hazardous substance • NRC, SERC, LEPC

• Common release scenarios (oil products, ammonia, other chemicals) • Reporting procedures (who to call, and when)

Oil Pollution Act Requirements

Spill Prevention, Control and Countermeasure (SPCC) Training 40 CFR 112.7 WHO? Oil-handling personnel – maintenance, shipping/receiving, (some production?) WHEN? Initial plus annual refresher WHAT to COVER? • Contents of the SPCC • Discharge procedure and protocols • Spill prevention equipment plus O & M • Pollution control laws • Facility operations, maps, locations of storage equipment • Inspection and documentation requirements INCLUDE: • Employee’s name • Date of Training

Oil Pollution Act Requirements

Facility Response Plan NEEDED?

RCRA Training Requirements (Hazardous Waste)

Small Quantity Generator (SQG) Training 40 CFR 262.34(d)(5)(iii) WHO? All employees handling hazardous waste WHEN? No regulated timing – initial training plus refresher training as needed WHAT to COVER? • Proper handling, storage, transport and use • Emergency procedures • Inspection requirements INCLUDE: • Employee’s name • Date of Training

RCRA Training Requirements

Large Quantity Generator (LQG) Training 40 CFR 265.16 WHO? All facility personnel WHEN? Must be an “established program” -- therefore, at a minimum include

initial training plus annual refresher training. WHAT to COVER? • Equipment operation • Contingency plan implementation • Emergency response procedures • Monitoring equipment use, inspection and maintenance • Key parameters for automatic feed cutoff systems


Large Quantity Generator (LQG) Training 40 CFR 265.16 WHAT to COVER? cont. • Communications and alarms • Response to fire, explosion and groundwater contamination incidents • Facility shutdown operations INCLUDE: • Employee’s name, job title and description • Description of the type and amount of training required for each

position • A copy of the training plan • Date of Training


A Note on Conditionally Exempt Small Quantity Generators (CESQG) While no training is required by regulation, training similar to

that of a SQG is recommended to ensure knowledge of applicable rules and requirements.

Hazardous Waste Requirements

Several state-specific training requirements for more stringent generator status designations

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Hazardous Materials Transport Training 49 USC 5107 (as required by the need for a manifest) WHO? Employees preparing hazardous materials for shipment • Those preparing the hazardous materials shipping papers including manifests

for the transporters WHEN? Initial training (within 6 months) and refresher training every three years WHAT to COVER? • Must include hazardous waste training if shipping hazardous waste • Identification of hazardous materials • Manifests and shipping papers • Record keeping requirements INCLUDE: • Employee’s name • Date of Training


Universal Waste Training 40 CFR 273.16 and 273.36 WHO? Employees who handle or have responsibility for managing

universal waste WHEN? Recommended initial training with refresher training as needed WHAT to COVER? • Proper waste handling techniques • Emergency response procedures • Record keeping requirements INCLUDE: • Employee’s name • Date of Training

TRIVIA TIME!!

What is the #1 finding among EPA RCRA Inspectors?

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Safe Drinking Water Act Training Requirements

1. Non-transient Non-community (NTNC) water system

State and/or Local Requirement Operator CERTIFICATION As required or if deemed necessary by management

Most states offer courses Some “grandparenting” clauses exist

Other Potential Areas for Training Requirements

Agricultural Facilities (FIFRA) Pesticide safety training for workers

Lead-Based Paint Any abatement, inspections or assessments must be done by

trained/certified individuals

Asbestos Use only certified workers

Laboratory Certifications For water and/or wastewater analyses

Corporate Level Training Professional development corporate staff

Training Resources

State and local regulatory agencies Technical schools Professional training academies On the job training Corporate staff Self audits Onsite training Environmental seminar Training manual and DVD EMS Monthly conference calls As needed (periodic) events

Thank you!

QUESTIONS?

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Environmental Training Requirements for Meat Processors

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