Under 40 CFR 265.16, generators must have records of appropriate training for all "facility personnel." This includes "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..." [see definition at 40 CFR 260.10]. It should be noted that this definition is not limited to actual full-time employees, but may include part-time or temporary workers, contractors, consultants, and others at your facility. It may also include off-site managers.

The EPA provides two performance standards:

1. All facility personnel must be taught "...to perform their duties in a way that ensures the facility's compliance with..." applicable regulations [40 CFR 265.16(a)(2)]; and
2. The training "...must include instruction which teaches...waste management procedures...relevant to the positions in which they are employed" [40 CFR 265.16(a)(2)].

The details on how your facility intends to accomplish these objectives must be documented in a formal written hazardous waste training plan. Ultimately, the training must assure that each person is performing his or her duties correctly (i.e., no violations are occurring). If a violation or problem occurs, it is an indication of insufficient training.

The EPA specifies at 40 CFR 265.16(c) that personnel "...must take part in an annual review of the initial training required...."  Some hazardous waste employees, such as those working at a large quantity generator facility, are required to complete annual training; while employees at a small quantity generator facility need only be "thoroughly familiar with proper waste handling and emergency procedures."

Unlike the Occupational Safety & Health Administration (OSHA), the EPA does not specify a particular duration of training. Again, this is left to site-by-site determination by the facility management, based on site-specific needs.

Yes. Any generator accumulating waste on site is required to train his or her personnel. This requirement is part of the "accumulation rules" at 40 CFR 262.34.

Fully regulated generators (those who generate > 1,000 kg (2,200 lbs.) total of all hazardous waste in any given month) are regulated under §262.34(a). Such generators are subject to the same training standard as treatment, storage, and disposal facilities (TSDFs). In fact, §262.34(a)(4) refers generators to TSDF training rules at 40 CFR 265.16. This rule requires specific training, according to a written, site-specific training plan, and requires written records of all training given.

"Small quantity generators" (those who generate 100–1,000 kg (220–2,200 lbs.) total of all hazardous waste in any given month) are not subject to the detailed requirements of §265.16, but they are still required to "ensure that all employees are thoroughly familiar with proper waste handling and emergency procedures relevant to their responsibilities" [40 CFR 262.34(d)(5)(iii)]. If a small quantity generator exceeds the threshold and becomes a fully regulated generator in any given month, he or she must comply with fully regulated generator rules immediately. If you believe that you are likely to become fully regulated, all aspects of compliance, including the written training plan, should be in place and ready.

Two of the most common OSHA chemical hazard training standards include:

1. The Hazard Communication Standard (sometimes referred to as "employees' right to know") requires general workplace chemical hazard training, as well as chemical labeling and material safety data sheets [29 CFR 1910.1200].
2. The Hazardous Waste Operations Standard (HWOS or HAZWOPER) requires specific training for persons involved in site cleanup, permitted TSDF operations, or chemical emergency response outside their ordinary workplace [29 CFR 1910.120].

The U.S. Department of Transportation (DOT) also requires training for persons shipping or transporting hazardous materials (including hazardous wastes) [49 CFR 172.700].

EPA, DOT, and OSHA requirements are distinct and separate. It is generally good management practice to combine training into a single session where Agency requirements are similar; however, you must assure that you comply with each rule individually.

There is an unfortunate misunderstanding that has arisen from the way in which EPA training requirements are written. The training rule emphasizes that training must include training on the facility's hazardous waste contingency plan and on specific emergency response procedures. These details are in addition to the general performance standards.

This choice depends on your level of experience or comfort with the RCRA regulations.

• If you are somewhat new to the field of hazardous waste management, or are looking for a good, solid review of what's required, the Hazardous/Toxic Waste Management workshop focuses on the essential need-to-know information for identifying and managing hazardous waste. This course is also available in an online format.
• If you feel you have a good understanding of the standard regulatory requirements and are looking to expand your knowledge and mastery of RCRA regulations, the Advanced Hazardous Waste Management workshop is for you. The Advanced workshop goes beyond a discussion of what's required and teaches you how to optimize your regulatory options and gain efficiencies that improve your bottom line.

The EPA requires hazardous waste generators to have a written training plan and training records for all personnel. This includes contractor employees! If you rely on contractors to assist in on-site waste management, their training must be included in your written training plan.

The rules provide that new personnel may work under the direct supervision of a trained person for up to six months. If you have occasional one-time contractors on site for less than six months, you may satisfy their training requirements by assuring that they are supervised in all waste management–related aspects of their jobs.

Under the training standard of 40 CFR 265.16 (applicable to generators storing hazardous waste under the 90-day rules), the EPA requires your hazardous waste training program to be "…directed by a person trained in hazardous waste management procedures…" [40 CFR 265.16]. There are no other specific requirements for qualification of trainers. The EPA does not "approve," "certify," or otherwise accredit trainers or training programs under RCRA.

All of Lion's training products and services are designed to train you in regulatory requirements for management of hazardous waste. While our courses and workshops are not designed to teach you how to be a trainer, you will learn what you need to teach your personnel.