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Driver Training

Guideline C-12, “Training Requirements for Drivers of Waste Transportation Vehicles” was presented in the Fall of 2013 by the Ontario Ministry of the Environment. This guideline amends Ontario Regulation 347 to include driver...


Guideline C-12, “Training Requirements for Drivers of Waste Transportation Vehicles” was presented in the Fall of 2013 by the Ontario Ministry of the Environment. This guideline amends Ontario Regulation 347 to include driver training requirements for carriers of municipal non-hazardous waste, similar to those already on the books for carriers of industrial liquid or hazardous wastes.

Waste haulers of all kinds in Ontario are advised to make themselves aware of the details of Guideline C-12 and make sure their drivers’ training is in compliance!

Ontario Regulation 347 under the Environmental Protection Act is meant to ensure that wastes are safely transported and managed from the point of generation to the ultimate processing and disposal site. The regulation includes definitions for different waste types and details the requirements for a range of waste management activities.

The new proposed guideline deals with driver training.

Regulation 347 (see paragraph 9 of subsection 16 (1)) requires drivers of waste transport vehicles to be trained in the following five areas:

i) operation of the vehicle and waste management equipment;

ii) relevant waste management legislation, regulations and guidelines;

iii) major environmental concerns for the waste to be handled;

iv) occupational health and safety concerns for the waste to be handled; and

v) emergency management procedures.

The responsibility for providing driver training rests with operators of companies involved in waste transportation.

The guideline and procedure have been prepared to assist these carriers in the design and assessment of training programs given to their drivers. According to the ministry’s documentation, it can also “be used as a syllabus either by carriers or by specialized training organizations involved in the design and offering of effective training programs.”

In the case of carriers of hazardous wastes, the guideline is not intended to require a training program in addition to the program specified under the federal Transportation of Dangerous Goods Act (TDGA) or the provincial Dangerous Goods Transportation Act. The two transport and environment training programs can be integrated into one program.

Although training under TDGA is, for the most part, sufficient to ensure compliance with Regulation 347, training is required in the following additional areas to ensure full compliance:

• relevant waste management legislation, policies and guidelines;

• major environmental concerns for the wastes to be handled.

For municipal wastes, liquid industrial wastes and for those hazardous wastes not covered by the TDGA (such as leachate toxic waste and severely toxic waste), training programs should follow this guideline.

Because of the fragmented nature of the waste management industry, programs will have to be tailored to meet the needs of individual companies. In some cases, it may be necessary for carriers to train beyond the areas identified by the guideline where there exists an important environmental or occupational health concern.

Guideline C-12 is intended for use by operators of waste management systems in designing their driver training programs or in evaluating driver training programs offered by outside training organizations. It will be used by staff of the Ministry of the Environment’s Operations Division to communicate the required components of a driver training program to operators of waste management systems, and to evaluate applications for new or revised waste management system Environmental Compliance Approvals. It will also be used by them to evaluate compliance with driver training requirements.

Approves & administration

In general, operators of companies transporting waste require an Environmental Compliance Approval (ECA) or a registration in the Environmental Activity and Sector Registry (EASR).

No matter which type of authorization is required (ECA or EASR), if the system involves the road transportation of municipal waste, liquid industrial waste or hazardous waste, it’s subject to the driver training requirements set out in Regulation 347.

When applying for either a new or a revised waste management system ECA for the transportation of waste, operators must provide written confirmation that they have an acceptable driver training program in place, which addresses the five items in paragraph 9 of subsection 16 (1) of Regulation 347.

At the same time, the operator may be required to also provide the ministry with a list confirming the names of trained drivers employed by the business at the time of application.

If the approval is issued after reviewing the application, conditions respecting driver training are typically incorporated in the ECA.

All EASR-registered waste management systems must have a driver a training program as per paragraph 9 of subsection 16(1) of Regulation 347. In addition to this, O. Reg. 351/12 has requirements related to how the training program must be documented for EASR-registered systems.

To demonstrate proof of training, all drivers of waste transportation vehicles must keep a copy of a certificate or other proof indicating that the driver of the waste transportation vehicle has received the training. (This requirement is from paragraph 4 of subsection 4(1) of O. Reg. 351/12.) The person registering a system in EASR is also required to retain a copy of the training materials used to train drivers. (From subsection 5(2) of O. reg. 351/12.)

The training materials don’t need to be retained in each truck, but are required to be retained in a way that they may be made available to the ministry upon request (for instance, filed at the business’ office). The training materials include any written material or presentations given to employees to fulfill the training requirement whether prepared by the company itself or provided by a third party. The most up-to-date training material should be retained and provided to the ministry if requested.

Waste management systems that have an ECA or have registered in EASR will typically have a requirement for a certificate to be held in the waste transportation vehicle indicating that the driver has received training. This certificate should include at a minimum the following information:

• the name of the driver;

• the date that the driver received the training; and

• the name of the organization or business that provided the training.

This certificate can either be issued by the company itself or by a third party organization that provided the training. For companies conducting their own training, Appendix 1 of the guideline has a template that can be used to generate a Certificate of Training. A driver should be able to demonstrate familiarity with the training content described in the ministry’s Guideline C-12 upon completion of the drivers training program.

Guy Crittenden is editor of this magazine. Contact Guy at
gcrittenden@solidwastemag.com


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