Do you have questions about Hazardous Waste Personnel training?
… I can help.
If you generate any hazardous waste it is likely you and your employees require some form of annual RCRA training. Even if not required by the regulations I am confident you will benefit from my training. Read on to learn about the regulations for RCRA Training and how they apply to you.
Why is RCRA training required?
The generation, storage, transportation, and disposal of all waste – particularly hazardous waste – poses a threat to the environment and to the people (that’s us!) that rely on it. Since 1976 and the passage of the Resource Conservation and Recovery Act (RCRA), the U.S. Environmental Protection Agency and states with an authorized hazardous waste program have required training for companies that generate hazardous waste and their employees that work with or around it. The purpose of this training is to ensure that Hazardous Waste Personnel understand the importance of the regulations and how to comply with them.
My RCRA training fulfills the State and Federal regulatory requirements of an LQG for initial and annual refresher training. It will also be of great benefit to SQG’s and CESQG’s as it will teach you ways to maintain compliance at your company.
Who is required to receive RCRA training?
Both Federal and State regulations require annual training of applicable employees (aka: Hazardous Waste Personnel) of large quantity generators (LQG’s) of hazardous waste. A small quantity generator (SQG) must ensure their employees are “thoroughly familiar with proper waste handling and emergency procedures…” A conditionally exempt small quantity generator of hazardous waste (CESQG) has no training requirement. However, even the employees of a CESQG will benefit from RCRA training.
The training requirements of the US EPA (and most states can be summarized as follows:
Large Quantity Generator of Hazardous Waste:
- 40 CFR 262.34(a)(4) indicates the need for LQG’s to comply with the requirements for 265.16.
- 40 CFR 265.16 documents the scope, content, and frequency of training.
Annual training is required for all personnel whose job responsibilities bring them into contact with hazardous waste or will respond to a hazardous waste emergency. Personnel to be trained are sometimes referred to as Hazardous Waste Personnel, Facility Personnel, or RCRA Employees. Whatever the name, anyone who has anything to do with hazardous waste at a large quantity generator of hazardous waste must receive some form of this training. This includes those who review or sign a uniform hazardous waste manifest.
If you still have questions remaining about who you must train, contact me for a free consultation.
What must RCRA training include?
The EPA regulations are not as specific as some others in detailing the necessary training content. However, 40 CFR 265.16 does require the following for RCRA training:
- Train personnel to perform their duties in compliance with the regulations.
- Teach personnel the hazardous waste management procedures specific to your facility including implementation of the contingency plan.
- “At a minimum” training must ensure personnel can respond effectively to emergencies.
My training contains a lot more than just the regulatory requirements. Based on my years of experience assisting companies like yours with the regulations, I have crafted a training binder full of useful tools you can use to maintain compliance. Feel free to review an outline of my RCRA training.
When must I train my hazardous waste personnel?
New or re-assigned employees who work with or around hazardous waste or a hazardous waste emergency must receive initial training within six months of employment and be supervised by trained personnel in that time. Employees must receive a refresher of their initial training at least annually.
How do I ensure my RCRA training meets the requirements of the US EPA and my State environmental agency?
First of all, ensure your training provider has received annual training as this is a requirement of 40 CFR 265.16(a)(4). Also, discuss the regulations and your training needs with the training provider until you are comfortable that the person who will provide the training has the knowledge and the skills necessary.
I have 20+ years experience with the applicable regulations as a Truck Driver, Hazardous Waste Technician, Consultant, and Trainer. I have spent a lot of that time researching the RCRA regulations and assisting companies like yours to comply with them. Read testimonials from EHS professionals like you.
Where can I get more information about the EPA & State hazardous waste regulations?
- The National Center for Manufacturing Sciences (NCMS) operates EnvCap.org which contains helpful regulatory information for the states.
- I use my Blog and other social media to share what I’ve learned about the regulations regarding HazMat transportation and the generation, handling, and disposal of hazardous waste.
1. What is RCRA?: The Resource Conservation and Recovery Act, passed by Congress in 1976 is the source of hazardous waste regulations codified in Section 40 of the Code of Federal Regulations (CFR) parts 260-279.
2. Where is the regulatory citation that requires this training?: The regulatory citation is not clear, however, EPA and state agencies are clear that it is required. 40 CFR 262.34(a)(4) explains how a Large Quantity Generator (LQG) of hazardous waste can accumulate waste on-site for up to 90 days without a permit by referencing the requirements of permitted facilities in 40 CFR 265.16 which details the training requirements. If you are an LQG, applicable personnel at your facility require this training.
3. What is the intent of the training requirement?: The intent is to reduce the potential for mistakes which might threaten human health or the environment by insuring that facility personnel working in jobs where they handle hazardous waste will be thoroughly familiar with their duties and responsibilities and emergency response procedures.
4. Is training required for a Small Quantity Generator (SQG) of hazardous waste?:SQG’s are not subject to the specific training requirements of 40 CFR 262.34(a)(4) or 265.16. However, per 40 CFR 262.34(d)(5)(iii), an SQG is required to “ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities”. A minimum of an annual update is a good means to ensure your employees are “thoroughly familiar” with their responsibilities.
5. Who must receive this training?: Persons working on-site at a LQG of hazardous waste who handle hazardous waste as part of their job (i.e. ‘RCRA Personnel’ or ‘Hazardous Waste Personnel’). It may include part-time or temporary workers, contractors, consultants, and off-site managers.
6. Who are “Facility Personnel”?: 40 CFR 265.16 refers only to “Facility Personnel”, by consensus within the industry employees who require this training are referred to variously as: “Hazardous Waste Personnel” or “RCRA Personnel”. Thus, the training is sometimes referred to by different titles: “RCRA Training”, “EPA Hazardous Waste Training”, “Hazardous Waste Personnel Training”, etc. While the name may be confusing, the Federal regulations are not. 40 CFR 265.16 requires annual training of all facility personnel of a Large Quantity Generator of hazardous waste whose job brings them into contact with hazardous waste or a hazardous waste emergency. Small Quantity Generators have a training requirement as well. Hazardous waste in satellite accumulation areas are not subject to the training requirement.
7. What is a Large Quantity Generator of hazardous waste?: The term is not defined in the applicable regulations. Instead it is agreed upon by consensus within the industry and regulatory agencies to represent a Generator (i.e. manufacturing or industrial facility) that generates ≥ 1,000 Kg (2,200 lbs) of hazardous waste in any calendar month.
8. What is a Small Quantity Generator of hazardous waste?: A Generator (i.e. manufacturing or industrial facility) that generates ≥ 100 Kg (220 lbs) but <1,000 Kg (2,200 lbs) of hazardous waste in any calendar month.
9. Who is responsible to ensure that applicable personnel – including on-site contractors – receive training?: The generator (i.e. the site where hazardous waste is generated) must insure applicable personnel have been trained in compliance with the regulations.
10. How frequently must applicable personnel be trained?: Applicable personnel must be trained within six (6) months of employment and be supervised by trained personnel in that time. A review of the initial training must be conducted annually.
11. What must the training include?: The scope and type of training is not defined. However, in broad terms, the training must ensure the following: (1) employees who work with hazardous waste are able to perform their duties in compliance with the regulations, and (2) they are able to effectively respond to an emergency situation and are familiar with emergency procedures, emergency equipment, and emergency systems.
12. Who can conduct the training?: The training program must be directed by someone trained in hazardous waste management. Those providing classroom-type training should be experts in the field of hazardous waste management to ensure questions that come up during training are answered correctly.
- Introduction to US EPA
- Introduction to RCRA
- RCRA’s training requirements
- An explanation of the process of waste determination
- Description of hazardous waste generator status and the requirements for each
- Reporting requirements
- Proper use of 8700-12 Form
- Hazardous Waste Contingency Plan
- On-site waste storage and handling
- Weekly inspections
- On-site hazardous waste treatment options
- RCRA air emission standards
- Used oil management
- Universal waste types and management
- Preparation for off-site shipments of hazardous waste
- Treatment Storage and Disposal Facilities (TSDF’s)
- Recycling & Pollution Prevention
- Handling and disposal of miscellaneous wastestreams
- Preparing for Agency inspections
Read an outline of the day’s RCRA training.
14. Can the OSHA emergency response training fulfill all my RCRA training requirements?: Training used to fulfill OSHA’s regulatory requirements of 29 CFR 1910.102(p)(8) and 1910.120(q) will fulfill the emergency response training requirements for RCRA Personnel required by 40 CFR 265.16(a)(3). This applies to the emergency response portion of the training only. It does not address all the training requirements of 40 CFR 265.16(A)(1).