Keys to RCRA Training at Small Quantity Generator Sites

“The small quantity generator must ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures, relevant to their responsibilities during normal facility operations and emergencies…”

[40 CFR 262.16(b)(9)(iii)]

What does RCRA require for hazardous waste training at Small Quantity Generator (SQG) sites?

The RCRA hazardous waste regulations require small quantity generators (SQGs) to ensure personnel are “thoroughly familiar” with how to properly handle hazardous waste and the emergency procedures relevant to their jobs.

For large quantity generators or LQGs, the RCRA training rules include mandatory minimum criteria for what training must cover, who can direct training, how to document training, record retention, and more. The regulations do not include this level of detail for personnel training at SQG sites.

Infographic: RCRA Generator Categories (Large, Small, and Very Small)

To provide adequate training and comply with RCRA as a small quantity generator, EH&S leaders must first identify how each employee interacts with hazardous waste as part of their job, as well as any specific knowledge or skills needed to fulfill the job role safely and in compliance with RCRA.

When training is complete, personnel should be able to describe how to properly carry out relevant job duties such as how to:

• Handle and containerize hazardous waste.
• Label and date containers.
• Properly and safely store containers.
• Inspect storage/central accumulation areas.
• Respond to a spill.

With respect to site emergency procedures: Do personnel know how to recognize an emergency when one occurs? Do they know who to call in the event of an emergency involving hazardous waste, and where to find contact information for on- or off-site emergency coordinators, the local fire department, community response organizations, and or private responders, as appropriate? 

These are all essential elements of RCRA training for hazardous waste personnel regardless of the site’s generator status or category. Effective training prepares employees to avoid errors or oversights that can lead to emergency releases, injuries and chemical exposures, improper disposal, and costly penalties for RCRA violations.

Timing of RCRA Training for SQGs

How soon to provide training for new hazardous waste personnel is another question that the regulations answer for large quantity generators but not for SQGs. New personnel at large quantity generator sites must be trained within six months of being hired or job assignment.

There is no six-month clock on personnel training for small quantity generators. That said, assigning an untrained employee to handle or manage hazardous waste poses a clear risk to facility health and safety, and of noncompliance with RCRA. The longer an employee works without the necessary understanding of hazardous waste, its hazards, or the proper way to manage it, the greater the risk.

For this reason, both large and small quantity generators should provide adequate training for new personnel as soon as practicable.

Recordkeeping and RCRA Refresher Training

Unlike large quantity generators—who are required to maintain detailed records of hazardous waste training for all personnel and keep them on site—SQGs are not required to document training at all.

Required or not, small quantity generators should make records of all RCRA training provided to personnel and keep those records on file. Without a record of training, a generator has no way to demonstrate compliance. Also, while the Federal hazardous waste regulations do not include recordkeeping requirements for SQGs, some individual states do require these records.

A state may also impose more stringent or more detailed rules for the content of training, timing of training, refresher training, etc. for personnel at SQG sites. 

The RCRA regulations require large quantity generators to provide annual refresher training for hazardous waste personnel. While the rules for small quantities generators do not include a refresher training requirement, SQGs may feel that re-training or refresher training is appropriate or even necessary at times.

SQGs may elect to provide refresher training on a regular basis, or to provide refreshers and update training on an “as needed” basis. An update may be needed when relevant regulations or requirements change, for example. Refresher training, in full or in part, may be needed if the generator observes that an employee is struggling with a particular element of the job role or could benefit from a reminder of key requirements.

RCRA Training for Small Quantity Generators

Lion offers a range of RCRA training courses for industry professionals at every stage of a career. For managers with overall responsibility for RCRA compliance, we recommend comprehensive RCRA Hazardous Waste Management training. 

For hazardous waste personnel at SQG sites, the Storing Hazardous Waste—Ops online course provides required training on proper waste handling and management practices for operations-level (ops) staff like waste handlers, operators, maintenance workers, production personnel, lab employees, and others.  

Browse all online and in-person RCRA training options at Lion.com/RCRA. 
 

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