Hazardous Waste Generator Training Requirements
December 5, 2019
Hazardous Waste Generator Training Requirements
If you’re an LGQ hazardous waste generator, specialized training is required for all your “hazardous waste personnel” within six months of bringing them onboard.
The EPA defines “hazardous waste personnel” as anyone on your staff whose actions—or inactions—might result in noncompliance with applicable RCRA regulations.
Put another way: it’s anybody and everybody involved in selecting, marking, labeling, inspecting, moving, or otherwise handling your hazardous waste containers.
Also note: all staff must be adequately trained who deal with your hazardous waste, either daily or incidentally—not just your emergency responders.
That said, you might facetiously ask: Would that somehow include Taylor, that nice young MBA who works upstairs in Accounting?
The answer might surprise you.
Even if Taylor doesn’t occasionally roll up his sleeves to help toss around a few barrels of spoilt yogurt, he still might be considered “hazardous waste personnel” if he’s somehow involved in “reading and applying” federal and/or state hazardous waste regulations.
Also bear in mind that such training is required of any outside contractors who might assist you with onsite hazardous waste management—or who might incidentally produce hazardous waste on your site (such as painters, repair companies, or renovators).
Exceptions for SQGs and VSQGs
SQG hazardous waste personnel need only be “thoroughly familiar” with proper waste handling and emergency response procedures.
There’s no explicit training requirement for VSQG hazardous waste personnel, but they must be conversant with EPA and state requirements.
Sounds vague?
Hazmat experts recommend documentable training for SQG and VSQG personnel.
It’s cheaper and less time?consuming than unintended spills and releases—and the EPA fines and sanctions that go along with them.
Need training? Call us at (425) 414-3485.
Exceptions for newbies
Mercifully, new hires can work under the direct supervision of a trained person for up to six months. Ditto for contractors: their employees can assist with your hazmat management if directly supervised by a trained person—but only once, and for a period less than six months.
So what exactly does hazmat-handling training involve?
Your designated hazardous waste personnel must complete a program of classroom instruction, online training, and/or in-service training that enables them to ensure compliance with RCRA regulations.
Minimally, this includes training in emergency response procedures, application of emergency equipment, and the operation of emergency systems. And they must complete RCRA refresher training annually to remain in compliance.
However, whoever manages your entire hazardous waste program will likely need more training; and it’s solely up to you to ensure that all your personnel are adequately trained to maintain compliance with RCRA regulations.
The EPA provides a convenient laundry list of more-specific required topics, which you can learn more about here. They include:
- Procedures for using, inspecting, repairing, and replacing facility emergency and monitoring equipment
- Key parameters for automatic waste feed cutoff systems
- Communications and/or alarm systems
- Response to fires, explosions, and releases of hazardous waste constituents
- Response to groundwater contamination incidents
- Shutdown of operations
- Evacuation procedures
- Implementation of the facility contingency plan
So who can provide the required training for hazardous waste management?
Ironically enough, the EPA doesn’t approve, certify, or otherwise accredit people or programs for providing the breadth of specialized training required by the agency. Suffice to say, such training must be directed by a person trained in hazardous waste management procedures.
To traverse such a minefield, make sure the trainers you hire can present documentable evidence of extensive experience with hazardous waste management; that their instructors are experienced at teaching; and that they’re supported by research staff who keep them abreast of EPA regulations, which tend to be in bountiful and dynamic supply.
You need to document your training efforts
As an LQG, you’re required to maintain specific training records for your hazardous waste management personnel. The name, title, and job description for each must be present with a detailed description of the amount and type of training he or she has received.
A word about SQGs
Although there’s no specific requirement for SQGs to have documented proof of individual training, common sense dictates the need for it. A crotchety inspector could ask for proof, and not being able to cough it up on demand isn’t going to make him happy.
Minimally you should document dates and provide descriptions of hazmat training sessions for your SQG. Also, have sign?in sheets to record which of your employees have attended them.
Don’t get distracted. It can be dangerous—and expensive
In all likelihood, hazardous waste management is not what you’re in business to do. Instead, it’s a nettlesome byproduct of your operations. It’s overhead—and a distraction from your core competencies, for both you and your managers.
Thus, designing and administrating a training program to keep your business EPA-compliant (and your employees physically safe) is at least twice removed from what you actually get up in the morning to do.
Under such circumstances, the likelihood skyrockets for committing unintended sins of omission, commission, or both. Why take the risk?
Get expert help
Although they might be difficult to just “google,” there are sources solely dedicated to providing comprehensive employee training for hazardous waste personnel. And many of them specialize in areas of hazardous waste management specific to particular industries and operations. (E.g. aviation fueling, site remediation, chemical & pharmaceutical compliance, food industry, and more.)
We know who and where they are
We can connect you with local and regional training sources that we’ve vetted and are proud to recommend. We can offer you literally decades of documentable experience with hazardous waste management.
Our instructors are not just experienced practitioners of hazardous waste management. They’re also superb teachers who are expert at imparting their knowledge to homogenous audiences: owners, managers, and all levels of employees.
They’re supported by research staff who keep them abreast of EPA regulations. And they can help you establish an ongoing training program to keep you in state and federal compliance.