Who Needs Hazardous Waste Training?
Facilities that manage hazardous waste must comply with the Resource Conservation and Recovery Act (RCRA) regulations. Under RCRA, employers are required to train personnel on proper hazardous waste management and comply with stringent requirements for generating, storing, treating, and disposing of hazardous waste.
When and how often EPA requires hazardous waste training depends on monthly hazardous waste volume ("generator status") and other factors. For help choosing RCRA training, read the FAQ below or watch the Who Needs Hazardous Waste Training Video.
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Who must complete RCRA hazardous waste training?
Hazardous waste training is required for all “hazardous waste personnel” within six months of hire or assignment to the facility.
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US EPA defines “hazardous waste personnel” as 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)."
Personnel must complete annual
hazardous waste refresher or “RCRA refresher” training and may not work unsupervised until training is complete.
Common job responsibilities for hazardous waste personnel include:
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- 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
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.
Small Quantity Generators (SQG)
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.
Very Small Quantity Generators
Formerly called “Conditionally Exempt Small Quantity Generators,” 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 should know enough to keep your hazardous waste in compliance with Federal and State regulations.
RCRA Training for VSQG personnel.
How often is hazardous waste training required?
Annually. Hazardous waste personnel at large quantity generator facilities must complete a program of annual RCRA refresher training (40 CFR 262.17(a)(7)).
For small quantity generators (SQGs), US EPA requires that all hazardous waste personnel are "thoroughly familiar" with the RCRA regulations. To ensure personnel fully understand their responsibilities and have up-to-date training, annual training for SQG personnel is a best practice.
What training is required?
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)
Who can train personnel on hazardous waste management?
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.
What's the consequence for failure to train hazardous waste personnel?
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. But even for mistakes, a RCRA civil penalty can be as high as $75,867 per day and per incident.
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)
If I am trained by Lion Technology Inc., may I train others at my facility?
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.
What is a “generator status”?
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:
- 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
- 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
- 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
Do I need to train contractors doing work at my site?
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.
Do I need to be able to prove I was trained or that I trained my employees?
LQGs are required to keep specific training records for all “personnel.” This includes documenting the training with the following information:
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.
Will training with Lion help me maintain my professional certifications?
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.