Daniels Training Services

9 Questions to ask Your RCRA Training Provider

9 Questions to ask Your RCRA Training Provider

I hope you use my services to provide RCRA Training to your Hazardous Waste Personnel as required by the US EPA (and your State).  However, there are other training providers out there and perhaps you are considering one of them.  If so, I encourage you to ask them the following questions.  Their response to them, as compared to mine, will help you in your decision.  You may also be interested in another article of mine:  11 Questions to ask Your HazMat Employee Training Provider.  You may also contact me for a free consultation of your RCRA Training and DOT HazMat Employee Training needs.

1.  What are the regulations that require this training?

A:  The answer is more complicated than it should be.  One of the requirements of a Large Quantity Generator (LQG) of hazardous waste is that it must comply with 40 CFR 262.34(a)(4) which references the training requirements in 40 CFR 265.16 for “Facility Personnel” of a TSDF.  Read here for a more detailed explanation of the regulatory requirements for training the personnel of an LQG.

2.  Who or what are the “Facility Personnel” that I must train?

A:  Personnel or Facility Personnel are defined at 40 CFR 260.10 as “all persons who work at, or oversee the operations of, a hazardous waste facility, and whose actions or failure to act may result in noncompliance with the requirements of part 264 or 265 of this chapter.”  While intended for persons at a TSDF, the regulatory reference in #1 above links it to persons at an LQG.  These persons are also known as:  RCRA Personnel or Hazardous Waste Personnel.  Take note that this definition applies not only to your employees, but may also apply to contractors who work at your site (RO14180).

3.  How frequently must I provide training?

A:  40 CFR 265.16(b) mandates training be provided within 6 months of new employment and that untrained employees must be supervised in that time by trained personnel.  All Facility Personnel must receive an annual review of their initial training.

4.  Is your training certified or approved by the US EPA or by a State environmental agency?

A:  Neither the US EPA, nor any State, certify training providers or approve their training programs for use.

5.  When was the last time the training provider received RCRA Training?

A:  40 CFR 265.16(a)(2) requires the training program to be directed by a person who has received annual training.  Your prospective RCRA Training provider should be able to demonstrate they have attended the annual training themselves.

6.  Do the training requirements apply to facility personnel who work only near a Satellite Accumulation Area (SAA) for hazardous waste?

A:  The SAA regulations, found at 40 CFR 262.34(c), and applicable to both LQG’s and SQG’s (Small Quantity Generators of hazardous waste) do not reference the Facility Personnel training requirements of 40 CFR 265.16.  Therefore, you are not required to train personnel whose sole contact with hazardous waste is while it is in the SAA.  However, while not subject to the full training requirements, it is helpful for employees to be aware of the applicable regulations and their responsibility to comply with them.  That is why I include these topics, and others as applicable, in my training.

7.  Do the training requirements apply to facility personnel who work only with Universal Waste or Used Oil?

A:  Universal Waste and Used Oil are exempted by regulation (40 CFR 273 & 279 respectively) from the full requirements of RCRA (the Resource Conservation and Recovery Act) regulations and are not subject to the training requirements.  However, while not subject to the full training requirements, it is helpful for employees to be aware of the applicable regulations and their responsibility to comply with them.  That is why I include these topics, and others as applicable, in my training.

8.  What training is required for an SQG?

A:  As we saw in #1 above, the training requirement in 40 CFR 265.16 as referenced in 40 CFR 262.34(a)(4) applies solely to LQG’s.  So, while SQG’s do not have a requirement to train their Facility Personnel, 40 CFR 262.34(d)(iii) requires them to “…ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies.”  While not calling out a specific need for training, it leaves the SQG with the challenge of determining how to make their employees “thoroughly familiar” with the applicable regulations and procedures.

9.  Are you a lawyer?

A:  I have nothing against lawyers, and in some situations, their services are invaluable.  However, they don’t always make the best trainers because their experience has been interpreting the regulations and their legal justification instead of what you must do to comply with them.  In contrast, my experience prior to starting this business has been “on the shop floor”:  driving a truck, handling hazardous waste, completing weekly inspections, conducting agency inspections, preparing shipping papers, and more of the like.  I feel my job as your trainer is to reveal the regulations and teach you methods of compliance I have learned over the years, not the Genesis of the regulations.  At my training you’ll learn how to do your job, not why you have to do it.

Two questions remain, perhaps the questions:

  1. How much does your training cost?
  2. How far will I and my employees have to travel?

My prices for training are the best value you will find.  At my Training Seminars you may register for as low as $299/person, and $259/person for additional coworkers, if more than two weeks prior to the event.  Registration closer to the training date isn’t that much more.

My Training Seminars are held nationwide and year round, so there’s a good chance I will be coming to your area soon.  If you don’t find a convenient date or location, or if you have many people to train, consider Onsite Training.  For a flat fee of $1,999 and $10/trainee I will travel to your site and provide a full day of RCRA Training and HazMat Employee training if necessary.