It is the policy of the University of Colorado
at Boulder that all persons (faculty, student and staff) involved with
the generation, handling and management of Hazardous Waste (HW) on Campus
shall be properly trained and comply with all rules as specified by Federal
and State regulations, permits and laws. HW Generators (HWGs) are responsible
for training and management in their respective areas, as detailed below.
In the event that penalties are levied against the university
for non-compliance with local, state or federal regulations, such penalties
will be assessed, as appropriate, to the department(s) or unit(s) whose
failure to comply with the campus policies, caused or contributed to the
penalties. Departmental or unit indemnification requires that those handling
HW have been properly trained and have adhered to university policies
and procedures in accordance with local, state and federal regulations.
The Environmental Protection Agency and the Colorado Department of Public
Health and Environment require annual HW classroom and on-the-job training
for all persons who generate and handle HW. This includes personnel in
Campus laboratories and shops, as well as some office personnel (who may
generate waste copier toner, batteries etc.). Since there are thousands
of HWGs on the Boulder Campus, the task of formally training and re-training
all of them is a significant challenge. In addition to training there
are other requirements that need to be accomplished in every HW generating
area, such as weekly inspections and record keeping.
HW Generators (HWG) Training System:
The Campus has developed a Hazardous Waste (HW) proctor system to expand
the network of university resources and maintain environmental compliance
and safety standards:
- Faculty and/or staff coordinators are appointed in each waste-generating
Campus department and assign one or more HW proctors to serve as training
liaisons for the Environmental Health and Safety Division (EH&S)
of the Department of Public Safety at CU-Boulder.
- EH&S trains each of the proctors (using a train-the-trainer approach),
maintains documentation of the training presented to Proctors and provides
training materials and compliance verification checklists and guidelines
for use by every generator.
- HW proctors, in turn, train HWGs in their areas. Proctors remain
responsible for providing annual, formal training to individual faculty,
student and staff HWGs (using EH&S prepared materials) and keeping
records documenting such training.
- HWGs (faculty, student and staff) are responsible for proper management
of hazardous waste and inspections in their assigned areas, using EH&S
prepared checklists and campus procedures and guidelines.
- EH&S also schedules monthly classroom training sessions for all
HWGs that act as a safety-net for smaller departments without
proctors or generators urgently requiring training during a transitional
stage or proctor absence.
Your cooperation is required and appreciated in addressing this important
campus life-safety and environmental compliance issue. Questions regarding
the implementation of this policy should be directed to EH&S at 492-6025.
Date Revised: January 15, 1998
Approved by: Dr. Richard L. Byyny, Chancellor
Author: Dave W. Wergin, Director, Environmental Health & Safety