Who Needs Hazardous Waste Training?

The Resource Conservation and Recovery Act (RCRA) regulations require training for facility personnel at sites that generate and store hazardous waste (i.e., hazardous waste generators).  

The RCRA regulations define hazardous waste "personnel” or "facility personnel" to mean: 

"all persons who work at, or oversee the operations of, a hazardous waste facility and whose actions or failure to act may result in noncompliance with the requirements (of the RCRA regulations)."

40 CFR 260.10—Definitions

Common job responsibilities for hazardous waste personnel include:  

• Identify or count hazardous waste
• Choose hazardous waste containers
• Mark or label containers
• Handle or move waste or waste containers
• Inspect containers
• Operate a waste-generating process  
• Manage waste in satellite areas
• Read and apply Federal or state hazardous waste regulations

Employers must provide adequate hazardous waste training or "RCRA training" to personnel within 6 months of hire date, and employees must work under direct supervision of a trained employee until training is done. Annual refresher training is required [40 CFR 262.17(a)(7)], 

Find RCRA hazardous waste training.

RCRA Training for Small and Very Small Quantity Generators
RCRA training is required for personnel who work at large and small quantity generator facilities. For very small quantity generators, we strongly recommend RCRA training to ensure your facility can achieve and maintain compliance. 

 

RCRA Training for Small Quantity Generators (SQGs)
An SQG is a facility that generates less than 1000 kg (2,200 pounds) of hazardous waste and 1 kg or less of acutely hazardous waste per month.

All hazardous waste personnel at SQG facilities must be trained to be “thoroughly familiar” with proper waste handling and emergency response procedures relevant to his or her job. Training should be repeated or supplemented when the employee’s job responsibilities change or the facility’s operations change.

RCRA Training for Very Small Quantity Generators (VSQGs)
Formerly called “Conditionally Exempt Small Quantity Generators” or CESQGs, a Very Small Quantity Generator (VSQG) is a facility that generates 100 kg or less of hazardous waste per month. While there is no explicit training requirement for VSQG personnel, employees must know enough to act in compliance with applicable Federal and State regulations. RCRA Training for VSQG personnel.

Annually. Facility personnel at large quantity generator facilities must complete a program of annual RCRA refresher training. "Annually" means once per year. [40 CFR 262.17(a)(7)]

Lion recommends that personnel complete annual RCRA refresher training on a date as close to the training anniversary date as practicable, based on the previous year’s training. 

More: EPA Guidance on "Annual" Training 

For small quantity generators (SQGs) US EPA requires that all hazardous waste personnel are "thoroughly familiar" with the RCRA regulations. To ensure SQG personnel fully understand their responsibilities and have up-to-date training, annual refresher training is a best practice. 

Hazardous waste personnel must successfully complete a “program of classroom instruction, online training (e.g., computer-based or electronic), or on-the-job training that teaches them to perform their duties in a way that ensures the facility’s compliance.”  

At a minimum, training “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”

See 40 CFR 262.17(a)(7)
 

US EPA does not specify a duration for hazardous waste training, unlike some other Federal agencies. The duration of RCRA training should be commensurate with the employee's job responsibilities and be sufficient to meet the requirements of 40 CFR 262.17(a)(7) described in the question above.

A manager who oversees your facility's entire hazardous waste program likely needs more training than a general laborer, for example. Ultimately, it is the employer’s responsibility to ensure training is adequate to maintain compliance with the RCRA hazardous waste regulations.

Lion's RCRA hazardous waste management training options include: 
RCRA Hazardous Waste Management Workshop (2 days) 
RCRA Hazardous Waste Management Online Course (14 hours) 
RCRA Hazardous Waste Refresher Online Course (8 hours) 

For general site personnel like operators and laborers, we recommend:
Storing Hazardous Waste–Ops Online Course (2.5 hours)

The program must be directed by a person trained in hazardous waste management procedures. There are no specific requirements for qualification of trainers. The EPA does not "approve," "certify," or otherwise accredit trainers or training programs under RCRA.

Lion hazardous waste workshops, online courses, and webinars are designed and delivered by experienced hazardous waste instructors, experts, and research staff. RCRA courses are updated throughout the year to keep training content fresh and up to date with the latest Federal RCRA and State hazardous waste regulations. 

Yes. The EPA allows personnel to utilize online training for initial or refresher RCRA training. 

Per 40 CFR 262.17(a)(7), RCRA training can be completed via “a program of classroom instruction, online training (e.g., computer based or electronic), or on-the-job training" that teaches personnel to perform their duties in a way that ensures the facility’s compliance.”

Browse online RCRA training options or in-person RCRA workshops 

No. This is a common misconception. The EPA’s requirements emphasize the inclusion of training on the facility’s hazardous waste contingency plan for LQGs and on specific emergency response procedures for LQGs and SQGs. These details are in addition to the general performance standards.

See HAZWOPER training for emergency responders.

If you have trained your employees under the OSHA standards at 29 CFR 1910.120(p)(8) and 1910.120(q) and you’ve met the overall facility training requirements under RCRA, then no, the facility is not required to provide separate emergency response training. You must include proof of this OSHA training in your RCRA training records.

RCRA penalties for all generators depend on the type of violation. The EPA can impose civil or criminal penalties upon a site based on intent. A civil penalty can be for simple mistakes, like a generator not providing training to all employees. The maximum civil penalty for a RCRA hazardous waste violation is now more than $80,000 per day, per violation.

Criminal penalties are imposed if the EPA can prove that a generator purposely acted against the rules. For instance, if a generator was cited for not training personnel and failed to provide training after the citation, then there is evidence that the generator knew training was needed but consciously chose not to provide it. In this case, the EPA can impose a criminal penalty up to and including a jail sentence of two to five years.

In addition to monetary penalties, failure to train hazardous waste personnel can lead to serious injury and emergency releases. Waste that is not properly managed and disposed of opens the door to future liability under programs like the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA).

No. When you sign the Hazardous Waste Manifest, you certify compliance with US DOT's hazmat transportation regulations. To confidently ceritfy that your waste shipment is properly classified, named, and packaged/ containerized, you must know the 49 CFR Hazardous Materials Regulations (HMR) transport requirements that apply to your waste.  

Comprehensive training in the Department of Transportation’s (DOT) 49 CFR hazardous materials regulations is required. See the Hazmat Ground Shipper Certification workshop or online course.  

Lion’s training products and services are designed to impart comprehensive knowledge about the regulatory requirements for managing hazardous waste. You will learn what you need to teach your personnel about the RCRA regulations. You and your company’s management will have to decide whether or not you have the depth of knowledge needed to train personnel for the activities at your facility. Remember that Large Quantity Generators must specifically train their employees in on-site management of site-specific waste handling.

RCRA Training for Managers

Based on the amount of hazardous waste your site generates, you will fall into one of three categories:
Large Quantity Generator (LQG)
Small Quantity Generator (SQG)
Very Small Quantity Generator (VSQG),

This is your generator status under the RCRA regulations, which dictates the specific requirements within 40 CFR with which you must comply.

The waste accumulation limits are per calendar month, as follows:

    LQG - Generators who must follow the 90-day accumulation rules

• Generates ≥ 1,000 kilograms (2,200 pounds) of regular hazardous waste
• Generates > 1 kilogram (2.2 pounds) acutely hazardous waste

    SQG - Generators who must follow the 180-day accumulation rules but may choose to follow the 90-day accumulation rules

• Generates < 1,000 kilograms (2,200 pounds) of regular hazardous waste
• Generates ≤ 1 kilogram (2.2 pounds) of acutely hazardous waste

    VSQG - Generators who are not subject to the 90- or 180-day accumulation rules but may choose to follow either one

• Generates ≤ 100 kilograms (220 pounds) of regular hazardous waste
• Generates < 1 kilogram (2.2 pounds) of acutely hazardous waste

LQGs are required to provide and document training for all personnel; this would include contractors. If you rely on a contractor to assist in on-site management of hazardous waste or hire a contractor who produces hazardous waste on your site (e.g., painting or maintenance crews), then their training must be part of your written training plan.

The rules do allow new personnel to work under the direct supervision of a trained person for up to six months. If you have occasional one-time contractors for less than six months, you may satisfy their training requirements by assuring they are supervised in all waste management-related aspects of their job.

LQGs are required to keep specific training records for all “personnel.” This includes documenting the training with the following information:

• Employee's name
• Employee's job title
• Employee's job description
• Written description of the amount and type of training the employee received
• A record or document that proves the training has been given to and completed by the employee

SQGs have no explicit requirement to document training. However, upon inspection, an inspector could ask you to prove that employees have been trained. Without training documentation of some kind, this proof might be hard to provide. Good management dictates some sort of record of training be kept for small quantity generators. An example could be a sign-in sheet documenting the names of employees who attended, along with a description of the training and the date.

Lion offers Continuing Education Units (CEUs) calculated based on training hours, which can be submitted for approval to help you maintain certification from organizations including: AHMP, ABIH, IHMM, NEHA, REHS, CCMP, and others.

While these groups typically do not pre-approve training programs that offer certification points, professionals can submit Lion CEUs for approval from their certifying organization.