Pursuant to 40 CFR 262.34(a)(4) a large quantity generator (LQG) of hazardous waste must have a training program for its facility personnel that is the same as that required for a hazardous waste Treatment Storage and Disposal Facility; the regulations for this training can be found at 40 CFR 265.16 and include the following:
- Training program must be “designed to ensure that facility personnel are able to respond effectively to emergencies by familiarizing them with emergency procedures, emergency equipment, and emergency systems…”
- Facility personnel must be trained within 6 months of new hire or new job assignment and must be supervised by a trained and knowledgeable employee in that time.
- Facility personnel must take part in an annual review of the initial training.
As of the effective date of the Generator Improvements Rule on May 30, 2017 the Federal regulations referenced in this article have changed.
The training requirements for a large quantity generator of hazardous waste are now found at 40 CFR 262.17(a)(7).
The regulations of your state may still refer to the original location of the Federal regulations.
The purpose of the annual review is to “ensure that facility personnel maintain expertise in the areas to which they are assigned thereby reducing the potential for mistakes that might threaten human health or the environment.” In other words, so they don’t get rusty, forget to follow the regulations, and a spill or accident involving hazardous waste occurs. But what is meant by “annual”? Once per calendar year? Once every 12 months? Every 365 days on the exact anniversary of the initial training?
Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste
Daniels Training Services, Inc.