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The Recordkeeping Requirements for RCRA Training for Hazardous Waste Personnel

The Recordkeeping Requirements for RCRA Training for Hazardous Waste Personnel

In an earlier article I explained the requirements for training of Facility Personnel at a Large Quantity Generator (LQG) of hazardous waste.  Just as important as providing the correct training is documenting its successful completion, that is the point of this article.

40 CFR 265.16 contains all of the regulations pertaining to the training of Facility Personnel at an LQG.  Paragraph (d) of that section mandates what your recordkeeping must include:

  1. The job title for each position at the facility related to hazardous waste management, and the name of the employee filling each job.
  2. A written job description for each position listed above.  Description may be consistent with your current job title descriptions (eg. Lead Maintenance, 2nd Shift Crew Chief, etc.), but it must include the requisite skill, education, or other qualifications, and duties of facility personnel assigned to each position.
  3. A written description of the type and amount of training (initial and annual review) to be provided.
  4. Record of training completion.  If on the job experience is used in lieu of classroom training, then documentation of its completion.

Records of training must be maintained by the owner or operator at the facility.  If a vendor or contractor provides this training for you, make certain you retain copies of the required records at your site.  Training records must be maintained…

  • For current personnel until facility closure.
  • For former employees at least three years from the last day of employment.

And, an interesting aspect of the training records for Facility Personnel is that while they may be transferred within the same company, they may not be transferred if personnel begin employment with a new company.  I find this interesting since the DOT’s training requirements for HazMat Employees does allow for the transfer of training records between companies.  The EPA realizes that the management of hazardous waste is site specific and requires training that can focus on the safe handling of hazardous waste at that location.

If you wish to receive high-quality RCRA Training and DOT HazMat Employee Training for you and a few coworkers, I suggest you sign up for one of my public/open enrollment training events.  If however, you require training for many employees and/or want site specific training, I suggest you contact me to arrange for on-site training.  Either way, it is important that you comply with the requirement to annually train your Facility Personnel who may be exposed to hazardous waste.