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Hazardous Waste

Not sure if you or your employees need training? Here are some of the most frequently asked questions about the U.S. EPA's hazardous waste training standard. Click here for a printable copy (.pdf) of the EPA's training rule.

If you are shipping hazardous waste or other hazardous materials, you may be subject to the U.S. DOT's training mandate. View the Hazmat (49 CFR) Training Standard FAQs.

Generators must train their personnel
Who must be trained?
What training is required?
Isn't this just for emergency responders?
How much training is required (40 hrs., 24 hrs, etc.)?
How often is training required?
What if I hire a contractor to manage my wastes?
How does EPA training relate to training required by OSHA or DOT?
Which workshop is for me?
What training does Lion provide?
Should I take a web-based course or attend a public workshop?
Which course or workshop is for me?
If I get trained by Lion, can I train others?
Important Regulatory References on Training

1. Generators must train their personnel

Any generator accumulating waste on site is required to train his or her personnel. This requirement is part of the "accumulation rules" at 40 CFR 262.34.

Fully-regulated generators (those who generate > 1,000 kg (2,200 lbs.) total of all hazardous waste in any given month) are regulated under §262.34(a). Such generators are subject to the same training standard as treatment, storage, and disposal facilities (TSDFs). In fact, §262.34(a)(4) refers generators to TSDF training rules at 40 CFR 265.16. This rule requires specific training, according to a written, site-specific training plan and requires written records of all training given.

"Small quantity generators" (those who generate 100–1,000 kg (220–2,200 lbs.) total of all hazardous waste in any given month) are not subject to the detailed requirements of §265.16, but they are still required to "ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities" [40 CFR 262.34(d)(5)(iii)]. If a small quantity generator exceeds the threshold and becomes a fully-regulated generator in any given month, he or she must comply with fully-regulated generators' rules immediately. If you believe that you are likely to become fully regulated, all aspects of compliance, including the written training plan, should be in place and ready.

2. Who must be trained?

Under 40 CFR 265.16, generators must have records of appropriate training for all "facility personnel." This includes "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..." [see definition at 40 CFR 260.10]. It should be noted that this definition is not limited to actual full-time employees, but may include part-time or temporary workers, contractors, consultants, and others at your facility. It may also include off-site managers.

3. What training is required?

The EPA provides two performance standards:

All facility personnel must be taught "...to perform their duties in a way that ensures the facility's compliance with..." applicable regulations [40 CFR 265.16(a)(2)]; and
The training "...must include instruction which teaches...waste management procedures...relevant to the positions in which they are employed" [40 CFR 265.16(a)(2)].

The details on how your facility intends to accomplish these objectives must be documented in a formal written hazardous waste training plan. Ultimately, the training must assure that each person is performing his or her duties correctly (i.e., no violations are occurring). If a violation or problem occurs, it is an indication of insufficient training.

4. Isn't this just for emergency responders?

There is an unfortunate misunderstanding that has arisen from the way in which EPA training requirements are written. The training rule emphasizes that training must include training on the facility's hazardous waste contingency plan and on specific emergency response procedures. These details are in addition to the general performance standards, above.

5. How much training is required (40 hrs., 24 hrs., etc.)?

Unlike the Occupational Safety & Health Administration (OSHA), the EPA does not specify a particular duration of training. Again, this is left to site-by-site determination by the facility management, based on site-specific needs.

6. How often is training required?

The EPA specifies at 40 CFR 265.16(c) that personnel "...must take part in an annual review of the initial training required..." Again, particulars as to how detailed the annual retraining must be are left to the discretion of the individual site manager. Some training may be appropriate to repeat in its entirety. Other training may require only a brief overview.

7. What if I hire a contractor to manage my wastes?

The EPA requires hazardous waste generators to have a written training plan and training records for all personnel. This includes contractor employees! If you rely on contractors to assist in on-site waste management, their training must be included in your written training plan.

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

8. How does EPA training relate to training required by OSHA or DOT?

Two of the most common OSHA chemical hazard training standards include:

The Hazard Communication Standard (sometimes referred to as "employees' right to know") requires general workplace chemical hazard training, as well as chemical labeling and material safety data sheets [29 CFR 1910.1200].
The Hazardous Waste Operations Standard (HWOS or HAZWOPER) requires specific training for persons involved in site cleanup, permitted TSDF operations, or chemical emergency response outside their ordinary workplace [29 CFR 1910.120].

The U.S. Department of Transportation (DOT) also requires training for persons shipping or transporting hazardous materials (including hazardous wastes) [49 CFR 172.700].

EPA, DOT, and OSHA requirements are distinct and separate. It is generally good management practice to combine training into a single session where Agency requirements are similar; however, you must assure that you comply with each rule individually.

9. Which workshop is for me?

If you believe you have a firm understanding of the basics of the hazardous waste regulations and wish to learn only the changes that have occurred in the past year and to discuss strategic management issues and perspectives, you should attend the Advanced Hazardous Waste Management Course. Assuming that a person begins with a good understanding of the rules, this workshop will provide the required annual update training.

If you are not yet confident in your knowledge of existing regulations, or if you simply want to review the actual regulatory requirements in more depth, you should consider attending the standard Hazardous/Toxic Waste Management workshop, designed specifically to provide both initial and annual update training for hazardous waste managers.

10. What training does Lion provide?

Lion presents regularly scheduled, open enrollment, public training workshops across the United States all year long. These workshops cover EPA, DOT, and OSHA regulations. In the area of RCRA hazardous waste management, our public workshops include:

Web-based training courses are also available via the Lion Institute web site, 24 hours a day. Currently available web-based courses are:

Many more RCRA-related web-based courses are under development for future release.

11. Should I attend a public workshop or take a web-based course?

The choice between attending a public workshop versus taking an online training course is a personal decision. You should consider the following:

What is your style of learning?
- If you like classroom-style, live, instructor-led training where you can talk face to face with your neighbor or with the instructor during the breaks, and work on exercises with others, Lion's public workshops offer all of these.
- If you prefer to work at your own pace, have the option to review the information you've learned as many times as you need to, work on exercises when you feel you're ready, and still have e-mail dialog with an instructor and fellow students, web-based training courses provide this approach to learning.
How much time do you have?
- If you would like to get out of the office for two days, get your training all at once, and head back to work with a bunch of fresh ideas and tools to apply to your job, the public workshops are for you.
- If you find that you can't afford to take two full days away from the office, or just prefer to get your training in increments, applying the information as you learn, you may prefer the brief, focused lessons of Lion's web-based training courses.
When do you need training?
- Lion presents over 200 workshops per year, nationwide, so chances are one will come to a major metropolitan area convenient to you during the year. Some workshops are presented in key cities more than once per year! If you've decided to attend a public workshop, you can plan to attend the one most convenient to you, or if you need it sooner, travel to a nearby city and get a discounted rate at the hotel where the workshop will be held.
- If you want access to training immediately and whenever you need it, without traveling, Lion's web-based training courses are available 24 hours a day via the Internet.

12. Which course or workshop is for me?

If you've decided to attend a public workshop to get your hazardous waste training, what is your level of experience or comfort with the RCRA regulations?

If you are somewhat new to the field of hazardous waste management, or are looking for a good, solid review of what's required, the "Hazardous/Toxic Waste Management" workshop focuses on Lion's "20 RCRA Basics," covering essential need-to-know information for identifying and managing hazardous waste.
If you feel you have a good understanding of the standard regulatory requirements and are looking to expand your knowledge and mastery of RCRA regulations, the "Advanced Hazardous Waste Management" workshop is for you. The "Advanced" workshop goes beyond a discussion of what's required and presents Lion's "RCRA Thought Process," a valuable tool to guide you through the complex decision-making and concepts of waste identification and management options.

If you're looking into web-based courses, the Lion Institute currently has available:

Generating Hazardous Waste
This course is perfect for personnel who generate hazardous waste and manage it under satellite accumulation rules before it is moved to full accumulation. It gives a brief overview of basic RCRA concepts, and then discusses how you know you have a hazardous waste, your options for accumulating the waste, and detailed discussion of "satellite accumulation" procedures.
90-Day Hazardous Waste Accumulation
This course provides detailed discussion of the 90-day rules for generators accumulating their hazardous waste on site in containers (e.g., drums, tote bins, portable tanks, roll-offs), including container management requirements, marking and labeling, preparing and planning for emergencies, and controlling volatile organic air emissions.
90-Day Hazardous Waste Tanks
This course builds on the "90-Day Hazardous Waste Accumulation" course with a detailed discussion of the extra requirements that apply to generators storing their hazardous waste on site in tanks.
The Hazardous Waste Manifest
Designed specifically for those with responsibility for filling out, signing tracking, and managing manifest records, this course provides detailed explanation of the RCRA hazardous waste manifest requirements, including item-by-item discussion of how to fill out the form.

13. If I am trained by Lion, can I train others?

Under the training standard of 40 CFR 265.16 (applicable to generators storing hazardous waste under the 90-day rules, see preceding FAQs), the EPA requires your hazardous waste training program to be "…directed by a person trained in hazardous waste management procedures…" [40 CFR 265.16]. There are no other specific requirements for qualification of trainers. The EPA does not "approve," "certify," or otherwise accredit trainers or training programs under RCRA.

All of Lion's training products and services are designed to train you in regulatory requirements for management of hazardous waste. While our courses and workshops are not designed to teach you how to be a trainer, you will learn what you need to teach your personnel.

14. Important Regulatory References on Training

40 CRF 262.34(a)(4)—Rule for fully-regulated generators to comply with TSDF training rules at 40 CFR 265.16.
40 CFR 264.16 and 265.16—Detailed standards for "personnel" training and for planning and documenting such training.
40 CFR 260.10—Definition of "personnel."
45 FR 72026, October 30, 1980—EPA discussion of the definition of "personnel" and its applicability to contractors and other non-employees.

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