A Review of Training Requirements for Hazardous Waste Management

Depending on what each does, the Resource Conservation and Recovery Act (RCRA) mandates that all your personnel handling hazardous waste have job-specific training in one or more of four categories. These are:

• Management
• Generation
• Transport
• Treatment/storage/disposal

This blog entry provides Q&As about the requirements within each. Among them:

1. What are the hazardous waste disposal training requirements for management?
2. What are the hazardous waste disposal training requirements for hazmat generators?
3. What are the management requirements for RCRA Large Quantity Generators?
4. What are the management requirements for RCRA Small Quantity Generators?
5. What are the hazardous waste disposal training requirements for transporters?
6. What is HAZWOPER?
7. What are the hazardous waste training requirements for treatment/storage/disposal facilities?
8. Where can you get comprehensive advice and help about RCRA training rules?

1. What are the hazardous waste disposal training requirements for management?

There are no specific academic requirements for becoming a hazardous waste manager. However, it’s a pretty good idea to hire someone with an undergraduate degree in chemistry or biochemistry, environmental science or engineering, waste management, or toxicology. 

However, if you have someone on board with a B.S. in Phys. Ed. who nonetheless exhibits a flair for managing hazardous waste—that’s okay. Make sure they have job-specific training about handling and removing chemical, biohazard, and radioactive wastes, without defoliating the entire neighborhood.

Applicable coursework might include such esoterica as OSHA workplace hazards management training (WHMT), instruction about workplace emergencies involving hydrogen sulfide gas (H2S Alive), and training about the transportation of dangerous goods (TDG).

Also, consider that larger private and public entities usually require that the upper echelons of their hazardous waste management have a graduate degree. So, if your enterprise falls into that size category, you might want to start checking resumes. 

In sum, given the high legal, financial, and ethical stakes endemic to your hazardous waste management, you should get expert advice to make sure your leadership can pass EPA muster, educationally speaking. And you can get expert advice about that here.

2. What are the hazardous waste disposal training requirements for hazmat generators?

EPA personnel-training requirements differ according to what size “generator” the agency considers you. There are three: LQGs, SQGs, and VSQGs (see Q.3 and Q.4).

3. What are the management requirements for RCRA Large Quantity Generators?

The EPA categorizes you as a Large Quantity Generator (LQG) if you generate 1,000 kilograms per month (2,200 lbs.) or more of hazardous waste or more than one kilogram (2.20 lbs.) per month of acutely hazardous waste. As such, specialized training is required for all your hazardous waste personnel within six months of bringing them on board. 

The EPA defines “hazardous waste personnel” as anyone on your staff whose actions—or inactions—might result in noncompliance with applicable RCRA regulations. 

In other words, it’s anybody and everybody involved in selecting, marking, labeling, inspecting, moving, or otherwise fiddling with your hazardous waste containers.

Also note: whether they deal with hazardous waste daily or only incidentally, all your staff who do so must be adequately trained to RCRA standards, including personnel whom you might not think to consider. 

For example, if your lovable IT geek occasionally rolls up his sleeves to help move around a few barrels of oozing gook, he still might be considered “hazardous waste personnel.” If he’s somehow involved in “reading and applying” federal and state hazardous waste regulations.

Also, be mindful that such training is required of any outside contractors who might help you with onsite hazardous waste management—or who might incidentally produce hazmat on your property (such as painters, repair companies, or renovators). 

Again, it’s an excellent idea to get expert advice.

4. What are the management requirements for RCRA Small Quantity Generators?

In EPA parlance, small-quantity hazmat generators come in two sizes:

1. You’re a Small Quantity Generator (SQG) if you generate more than 100 kilograms (220 lbs.) but less than 1,000 kilograms (2,200 lbs.) of hazardous waste per month; or less than one kilogram (2 lbs.) of acute hazardous waste.

2. You’re a (VSQG) if you generate 1,000 kilograms (2,200 lbs.) or less per month of hazardous waste; or less than or equal to one kilogram (2 lbs.) of acute hazardous waste.

In either case (A or B), your hazardous waste personnel need only be “thoroughly familiar” with proper waste handling and emergency response procedures, per the EPA.  

So, although there’s no specific requirement for VSQGs or SQGs to have documented proof of individual training, common sense (aka CYA) dictates the need for it. An inspector could ask for proof, and not being able to present it on demand will not help your case.

Minimally you should document dates and provide descriptions of hazmat training sessions for your VSQG and SQG personnel. Also, have sign-in sheets to record which of your employees have attended them.

And might we again mention: it’s crucial to get expert advice? 

5. What are the hazardous waste disposal training requirements for transporters?

Perhaps to ensure full employment among government types, the federal training requirements for hazmat waste transporters are regulated simultaneously by three different agencies: the EPA, OSHA, and the DOT.  

But wait. There’s more!

Additional requirements are also enforced by the Federal Motor Carrier Safety Administration (FMCSA) and the Transportation Safety Administration (TSA). How can this be? With apologies to Rod Serling—submitted for your approval:

• The EPA is an independent agency of the federal government. It consolidates federal research, monitoring, standard-setting, and enforcement activities into one agency.
• OSHA concerns itself with health and safety standards for both private- and public-sector employees.
• The federal DOT oversees all facets of transportation: cars, trains, trucks, planes, and boats.
• The FMCSA administers rules stipulating how hazardous material is correctly classed, described, packaged, marked, and labeled for transit.
• The TSA conducts background checks as part of the hazmat-hauler application process, which takes up to 60 days to complete.

Given that regulations for hazardous waste transport effectively ooze from five different agencies, it’s virtually impossible to provide a list of rules that might remain relatively static over time. Also, in that required training is both “initial and recurrent,” it must be updated periodically—usually annually. (Did we mention it might be a good idea to get expert advice?) 

With those caveats, here’s a partial list of training your hazardous-waste transport employees must receive, as there might be more depending on individual job duties. Among them:

• Security awareness training about the security risks associated with hazmat transportation, and specific methods designed to diminish them
• Function-specific training relative to the particular knowledge and skills required for an individual to perform assigned hazmat-transport responsibilities properly and safely
• Safety training for drivers, warehouse workers, and any other employees who handle any hazardous waste in advance, during, and after its transportation
• Specialized driver training on vehicle inspection and operation; vehicle handling in diverse conditions; and special rules about tunnels, bridges, and railroads (see FMCSA)
• Advanced security training for companies required to have a security plan relative to their hazardous waste management
• Hazardous Waste Operations and Emergency Response (HAZWOPER) certification for employees who must drive onto hazardous waste sites, enter EPA-regulated treatment/storage/disposal facilities, or respond to hazardous waste emergencies (see Q.4)

6. What is HAZWOPER?

1. An ethnic slur?
2. A flagship fast-food hamburger made from industrial waste?
3. A big lie told to an EPA inspector?
4. None of the above? 

The answer is (d). HAZWOPER is the acronym for Hazardous Waste Operations and Emergency Response, a set of guidelines produced and maintained by OSHA to regulate workplace hazardous waste management and emergency services.

HAZWOPER certification is mandatory for employees who drive onto hazardous waste sites, enter EPA-regulated treatment/storage/disposal facilities, or respond to hazardous waste emergencies. Eight-hour refresher courses are required annually. This includes things like:

• Cleanup operations after an unplanned hazmat discharge
• Corrective actions after cleanup of an unplanned hazmat discharge, whether voluntary or mandated
• Operations involving hazmat that are conducted at treatment, storage, and disposal facilities
• Emergency response operations, in general

HAZWOPER rules stipulate that “the quantity of product spilled does not determine if an incidental spill has occurred.” Instead, several variables must be considered, like what was spilled and whence it was spilled. So, your emergency response personnel must be competent to make ad hoc decisions.

7. What are the hazardous waste training requirements for treatment/storage/disposal facilities?

The RCRA requires that your facility personnel be certified to “perform their duties in a way that ensures the facility’s compliance” with hazardous waste regulations. Yearly recertification is required and includes but is not limited to the following:

• In general: refresher coursework including updates on differentiating solid waste from hazardous waste; understanding waste codes, disposal options, and land ban requirements; determining your generator status; satellite accumulation vs. permanent storage; container requirements; facility standards; recordkeeping mandates; etc.
• About differentiating among wastes: a review of characteristics for universal wastes, waste oils, electronic waste, and metal waste, as well as addressing various updated requirements for their respective treatments and disposal. 
• As to legal requirements: Updates to liability and due diligence concerns; RCRA enforcement trends; latest RCRA preferences for organization and management of compliance data; etc.

As you might guess, different states have different requirements for ongoing certification. For example, in California, the requirement is 24 contact hours of continuing education every two years. As in many states, these courses must be approved by REHS Continuing Education Accreditation Agencies.  

8. Where can you get comprehensive advice and help about RCRA training rules?

As they tend to come from more than one government bureaucracy at haphazard intervals, RCRA training regulations are plentiful, evolving, and challenging to track. Ignoring or misunderstanding them can subject you to pecuniary and even criminal consequences. As of 2020, RCRA civil penalties can be as high as $76,764 per day, and poor employee training is one of the most frequently cited violations (see source).

As we’re wont to advise: it’s crucial to get expert advice. 

And thank you for reading our blog!