As a state with an authorized hazardous waste program, Colorado had the ability to make its state regulations more stringent and more broad than those of the USEPA; and it has. The Colorado hazardous waste regulations enforced by the Hazardous Materials and Waste Management Division of the Colorado Department of Public Health and Environment (CDPHE) are more strict than those of the USEPA.
For the regulations pertaining to hazardous waste management in Colorado, one must refer to 6 CCR 1007-3 of the Colorado Code of Regulations. However, many responsibilities of a hazardous waste generator are not found in the regulations but in the guidance and compliance documents of a regulatory agency; and the training requirement for a Conditionally Exempt Small Quantity Generator of hazardous waste in Colorado are a good example of this.
Nowhere in the Colorado hazardous waste regulations at 6 CCR 1007-3 Part 261.5 will you find a reference to training for hazardous waste personnel. Therefore, one can surmise that training is not required for employees of a CESQG that work with hazardous waste or may respond to a hazardous waste emergency. However, page 22 of a CDPHE guidance document: Guide to Generator Requirements of the Colorado Hazardous Waste Regulations, Seventh Edition August 2013, reads:
Although not required, the Division (the Hazardous Materials and Waste Management Division of the CDPHE) recommends that, as a best management practice, a conditionally exempt small quantity generator provide hazardous waste and emergency response training to employees that handle hazardous waste. Employees should be familiar with proper waste handling procedures relevant to their job duties.
So there you have it. Not required, but “recommended”.
I’ll “recommend” that you contact me if you are interested in training on the hazardous waste regulations of the USEPA, the CDPHE, or both.
Daniels Training Services