Note: 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?

Your best practice is to ensure that facility personnel are trained each year, no later than, and ideally before, the anniversary date of their initial training.  However, US EPA is aware that “it may be infeasible for companies with many employees to train each employee exactly one year after the last training…” so it has allowed for annual training to be completed within 90 days after the anniversary date (RO14286).  Note however in this case that the extended period was not due to a busy schedule or error on the part of the generator but instead was the result of a training policy that allowed, in some cases, for up to 15 months to pass between refresher training.  Also please note that US EPA “does expect companies to attempt to provide training so that personnel are trained every year.”

State regulations for annual training may be more stringent than the Federal requirements, check with your state agency for a more site-specific determination.

If in doubt about your training, default back to the third paragraph of this article, “The purpose of the annual review is to ‘ensure that facility personnel maintain expertise in the areas to which the are assigned thereby reducing the potential for mistakes that might threaten human health or the environment’.”

Contact me with any questions you may have about the generation, identification, management, and disposal of hazardous waste Daniels Training Services, Inc. 815.821.1550 Info@DanielsTraining.com https://www.danielstraining.com/

Initial and recurrent training of your facility personnel is not only a regulatory requirement, it is a good idea as well.  Properly trained and informed employees will perform their jobs more safely and ensure your compliance with the regulations.  Contact me about the RCRA training I provide for facility personnel or for a free consultation.