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The Hazardous Waste Personnel Training Requirement for a Small Quantity Generator of Hazardous Waste

Jan 17

Posted by admin in RCRA Hazardous Waste Regulations, RCRA Training | No Comments

The regulatory requirement for training employees who work with or around hazardous waste or may respond to a hazardous waste emergency depends upon your hazardous waste generator status (take this quick survey to determine your hazardous waste generator status).  A brief summary of the applicable training requirements:

  • A large quantity generator of hazardous waste must train all facility personnel within 6 months of employment and annually thereafter [40 CFR 262.34(a)(4)(i) & §265.16].
  • A conditionally exempt small quantity generator of hazardous waste has no training requirement [§261.5(b)].
  • A small quantity generator of hazardous waste is not specifically required to provide training to its facility personnel.  However, training may be necessary in order to comply with the applicable regulations [§262.34(d)(5)(iii)].

40 CFR 262.34(d)(5)(iii) reads:

The generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies;

The regulations do not specify how the generator must “ensure” that all of their employees are “thoroughly familiar” with the relevant procedures for handling waste and for responding to emergencies.  Options include:

  • On-the-job experience,
  • Prior work experience,
  • Education,
  • Signs and labels to communicate information,
  • Work Instructions or SOP’s that provide relevant guidance,
  • And training.

While not required it is assumed by the US EPA and state agencies that training will play a role – if not THE role – in complying with §262.34(d)(5)(iii) (RO11779).

It is also important to note that this regulation falls within the larger framework of an SQG’s responsibility to respond to an emergency, sometimes known as the Small Quantity Generator’s Basic Plan.  Therefore, your training must address the emergency response procedures your employees need to know relevant to their job duties.

Even if you determine that training is not required you and your employees will benefit from learning what regulations are applicable to their job duties and how those regulations fit into the greater regulatory structure.

As always, please don’t hesitate to contact me with any questions.

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Who are the “Facility Personnel” of a Hazardous Waste Generator who Must Receive Annual Training?

May 31

Posted by admin in RCRA Hazardous Waste Regulations, Regulatory Training | No Comments

If you are a Large Quantity Generator (LQG) of hazardous waste you may be aware of the requirement to train your Facility Personnel annually.  ”But”, you may ask, “ just who are my Facility Personnel?” Read the rest of this entry »

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RCRA Training is the Solution for South Carolina Company Facing EPA Fines for Hazardous Waste Violations

Apr 10

Posted by admin in Compliance and Enforcement, RCRA Hazardous Waste Regulations | No Comments

Sumter Coatings, Inc. (SCI) in Sumter, SC must pay a $55,000 civil penalty as part of a settlement with the US Environmental Protection Agency for violations of the Resource Conservation and Recovery Act (RCRA) regulations discovered at its facility during a joint US EPA & SC Department of Health and Environment inspection (press release).  Alleged violations of the hazardous waste regulations include:

  • Improper management of hazardous waste containers on site;
  • Failure to provide a sufficient base beneath containers which held hazardous waste;
  • Failure to make a hazardous waste determination;
  • Failure to inspect all areas where hazardous waste containers are stored weekly;
  • Failure to develop personnel training program to ensure compliance with hazardous waste regulations;
  • Failure to update information contained in the contingency plan, along with failing to make arrangements with local police and hospital authorities regarding the contingency plan and submitting copies of the contingency plan to first responders.
Along with the civil penalty noted above, the EPA also required the company to develop a personnel training program, develop a schedule for implementation of the training program, and identify facility employees that require training.

It is sadly ironic that yet another company is developing a training program under the shadow of an enforcement action when proactive implementation of RCRA training could have precluded the violations from occurring in the first place.  Hazardous waste training is required for all personnel of a large quantity generator who handle, manage, generate, work around, treat, recycle, etc. hazardous waste and is highly recommended for similar employees of small quantity generators.  In addition to being a regulatory requirement, it is also a good way for you and your personnel to maintain compliance with the full array of hazardous waste regulations applicable to your operations.

I can provide RCRA Training and DOT HazMat Employee training in a variety of formats and locations; either at my open enrollment events held nationwide and year round, or right at your facility with on-site training tailored to your site-specific needs.  Please review my training schedule to find a date and location convenient to you, or contact me for a free training consultation.

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The Biennial Hazardous Waste Report for 2011

Feb 11

Posted by admin in RCRA Hazardous Waste Regulations | No Comments

March 1st is the due date for submittal of the 2011 Biennial Hazardous Waste Report (EPA Form 8700-12 A/B).  Its purpose:  reporting to the EPA about the generation, management and final disposition of hazardous waste regulated by the Resource Conservation and Recovery Act (RCRA).  Though the US EPA requires the report be submitted every even-numbered year for the previous calendar year, some states have chosen to make it an annual requirement.

Each of the following regulated entities has a responsibility to submit the annual report:

  • Treatment Storage and Disposal Facility’s (TSDF’s) that treat, store, or dispose of hazardous waste on-site during the reporting year must submit the entire report.
  • Large Quantity Generators (LQG) of hazardous waste.  You are required to submit the entire report if you were an LQG for any calendar month in the reporting year.  If you wish, you need only report the waste you generated for the month you exceeded the LQG status threshold.
  • Small Quantity Generator (SQG) of hazardous waste.  An SQG may receive a notice to complete the report.  In this case you need only indicate on the form that you were an SQG for the reporting year, sign, and submit the report.

If you are unaware of your hazardous waste generator status, this survey will assist you.

The US EPA allows states to manage the RCRA Hazardous Waste Program themselves as long as their program is authorized by the Federal Agency.  To be authorized, state regulations must be at least as strict and as broad as the Federal regulations, they are allowed to be more strict and more broad.  A perfect example of this is that while the US EPA requires a Biennial Hazardous Waste Report, many states have made it an annual requirement, due each and every March 1st for the previous calendar year.  Another difference between the state and Federal level for this report is the requirement of some states, but not the US EPA, to submit the Off-Site Identification Form (Form OI).  In addition some states require separate annual reports – sometimes with fees – from companies within their borders, some examples:

  • Illinois has an annual Non-Hazardous Waste Report due February 1st.
  • Iowa (a state without an authorized RCRA Hazardous Waste Program) has an annual Hazardous Waste Activities Form due April 15th for LQG’s and SQG’s.
  • North Carolina has a Small Quantity Generator Waste Minimization Questionnaire due July 31st.

Check with your state environmental agency to determine what, if any, reporting requirements or fees they might have in addition to the US EPA.

There have been some changes to the report for 2011 in regards to definitions, source codes, form codes, and the instructions.  Minor changes were also made to the Site ID Form and the Form GM.  Read carefully the 2011 Hazardous Waste Report Instructions and Form for changes that may apply to you.

If you find yourself sitting at a desk with the report form and instructions and a stack of the previous year’s Uniform Hazardous Waste Manifests on February 29th, I urge you to consider a system to track your waste generation and off-site disposal.  Maintaining records throughout the year pays off big dividends when the Biennial (Annual in some states) Hazardous Waste Report is due.

To learn more about other regulatory requirements for hazardous waste generators including the training requirements of 40 CFR 265.16, attend one of my open enrollment training events.  This one day of training also meets the requirements of the PHMSA/US DOT for HazMat Employees involved in the transportation of hazardous materials.

Contact me to schedule on-site training!

Review my open enrollment training schedule and register now!

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