RCRA vs. HAZWOPER: What's the Difference?

A question that comes up when employers are selecting training for their employees is, “if I send my employee to a HAZWOPER training course, will it cover their annual RCRA hazardous waste personnel training?”

Unfortunately, the answer is usually no. Which leads to the follow up question: “What’s the difference?”

Both types of training contain the words “hazardous waste” in their descriptions. However, in this context, the words “hazardous waste” are used in two completely different sets of regulations created by two distinctly different agencies. As a result, who must get each type of required hazardous waste training—and what must be included in that training—will vary based on the employee's responsibilites. 

EPA Hazardous Waste Training

Resource Conservation and Recovery Act (RCRA)

US EPA (and RCRA-authorized states) have developed a set of management standards for materials that meet EPA’s definition of hazardous waste at 40 CFR 261.3 (i.e., solid wastes that are listed or exhibit a hazardous waste characteristic).

These rules establish keep-it-in rules for generators, transporters, and TSDFs to ensure safe on-site storage and prevent release of hazardous waste to the environment.  

Hazardous waste training is part of those requirements for generators and TSDF facilities. The requirements can vary for each person. For large quantity generators, this RCRA training requires documentation and annual refresher training.

Regardless the specific details, all RCRA training has two common requirements:

1. Prepare the employee to properly manage hazardous waste under normal circumstances;
2. Instruct the employee on what to do in the event of an emergency release.

Meet EPA's annual RCRA training mandate and keep your expertise up to date! The RCRA Hazardous Waste Management Workshop comes to cities across the Northeast US in June 2019, including Albany, Boston, North Jersey, Philadelphia, Portsmouth, and more. 

Who Needs RCRA Training?

For hazardous waste generators, the “normal condition” training could include 90/180-day container marking, inspection, and management as well as other management standards discussed at 40 CFR 262. For TSDF facility personnel this may include waste acceptance, treatment device operations, or any other operational requirements at 40 CFR 264 or 265.

Emergency response training must cover emergency procedures, emergency equipment, and emergency systems. For a large quantity generator or TSDF facility, this would include instruction in their written hazardous waste contingency plan, as required in 40 CFR 262, Subpart M or 264/265, Subpart D.

The amount of time spent in training is not specified. The EPA and states would expect the training to take as long as is needed to assure the personnel know how to do their jobs in accordance with the applicable rules at 40 CFR 262, 264, or 265.

HAZWOPER Training

Hazardous Waste Operations and Emergency Response (HAZWOPER)

HAZWOPER is a set of workplace safety standards established by OSHA for employees engaged in one of three activities:

1. Work at an environmental cleanup site (e.g., Superfund cleanup site)

2. Work at an EPA or state-permitted hazardous waste TSDF

3. Responding to releases of hazardous materials

With the exception of the TSDF standard, OSHA hazardous waste can include more than just EPA hazardous wastes. For example, the HAZWOPER emergency release standard applies to releases
of EPA hazardous wastes plus:

• DOT hazardous materials

• Superfund hazardous substances

• Biological agents

Each of the three HAZWOPER standards contains its own training requirements which not only specify the duration of the training (e.g., 40 hour, 24 hour, 8 hour), but also the specific content.

From OSHA’s perspective, there is no such thing as a generic 24-hour HAZWOPER training. What an employee needs in their 24 hours depend on whether they are actively responding to stop a release of a hazardous substance, working at a permitted TSDF, or cleaning up legacy environmental contamination.

Find the HAZWOPER course or courses that will meet your team's needs at Lion.com/HAZWOPER. Use the graphic guides on that page to see the hours of training required for each level of emergency responder or cleanup site worker. 

Who Needs RCRA and HAZWOPER Training?

An employee working with EPA hazardous waste is likely going to need both RCRA and HAZWOPER training. For example, an employee at a large quantity generator site that is responsible for weekly container inspections of the 90-day accumulation area would need annual, job-specific RCRA hazardous waste personnel training to cover things like a review of the container marking and management requirements.

In addition, they would need emergency response training that would not only meet the EPA personnel requirements, but also the HAZWOPER emergency response training. The specific time and content will depend on their expected response.

Employees that are expected to be aware of emergencies, sound alarms and evacuate must receive HAZWOPER Level 1 Awareness training. HAZWOPER Awareness training has no time frame, but does require personnel to develop specific competencies.

If the employee was going to be the emergency coordinator for the hazardous waste emergencies, they would need Level 5 incident commander training. This training requires 24 plus hours of initial content with competencies related to emergency response operations and incident command.

Both RCRA personnel and HAZWOPER emergency response training would require annual retraining to the employee’s specific competencies [40 CFR 262.17(a)(7) and 29 CFR 1910.120(q)(8)].

So, when it comes to training for hazardous waste management, the employer must examine both EPA and OSHA standards and ensure their employees receive initial and refresher training specific to their expected responsibilities under both standards.
 

RCRA and HAZWOPER Training—When You Want, Where You Want

US EPA requires hazardous waste professionals to complete annual training on the RCRA requirements. Lion makes it easy to meet your RCRA training mandate in a variety of formats—nationwide public workshops, convenient online courses, live webinars, and on-site training.

Browse RCRA training options here to find the course that fits your needs, your schedule, and your learning style.

Find HAZWOPER training for cleanup site workers or emergency responders at Lion.com/HAZWOPER. 

Tags: hazardous waste management, HAZWOPER, osha, RCRA Training, training