Federal regulation 40 CFR 265.16(c) requires “facility personnel must take part in an annual review of the initial training”. Does it mean that your employees must do the annual review (or refresher) every 12 months?
What if you are a large company with thousands of employees that require such “annual” review? Is there some flexibility?
Pratt and Whitney was such a company. It had established a RCRA training program for over 15,000 employees. It required each employee to get the annual review within a 90-day period before his anniversary date. That means the longest possible time period between training would be one year plus 90 days (15 months).
On May 21, 1997, the company wrote to EPA to seek gudiance and concurrence that such training schedule would satisfy EPA’s “annual review” requirement. The agency wrote back and told the company that since each employee would receive 4 annual reviews over a 4-year period, the training schedule met the requirements under 40 CFR 265.16(c). The memo from EPA is on file at RCRA Online.
While giving the company its concurance, EPA went on to caution the company to check with state agencies since some of them may have a different interpretation of “annual review”.