Lion News December 2021

News / December 2021 / RCRA Housekeeping to Close 2021
Find a Course

RCRA Housekeeping to Close 2021

Posted on December 07, 2021 by Roseanne Bottone

As we count down the days until 2022, it's a good time to review and organize the "administrative" elements of your RCRA compliance efforts. Good recordkeeping is essential; inspectors commonly review paperwork like training records, manifests, and hazardous waste determination records during onsite inspections.

Annual Training and Training Records

​Is your training documentation organized, up-to-date, and easily accessible?

US EPA requires annual training for hazardous waste personnel at large quantity generator facilities (40 CFR 262.17(a)(7)). Annual refresher training should be provided as near as possible to the anniversary of the employee's previous training. For employees who are "past due" for annual training, time is running out to fit a refresher in for 2021. 

Inspectors will request training records for personnel when they visit your facility. Large quantity generators must maintain the following documents and records related to RCRA training at the facility:
  • Each employee's name and job title;
  • A written job description for each position at the facility related to hazardous waste management;
  • A written description of the type (e.g., classroom, online, or on-the-job) and amount (e.g., hours) of training provided; and
  • Records proving that personnel completed the required training or job experience. 
Training records on current personnel must be kept until the facility closes. Training records for former employees must be kept for at least three years from the date the employee last worked at the facility.

The Uniform Hazardous Waste Manifest

If you are still using paper manifests, are the last three years of your site’s manifests organized and easily accessible?

Both large- and small quantity generators (LQGs and SQGs) must keep a copy of each signed manifest for three years, or until a signed copy is received from the designated facility after the waste is delivered. This latter copy must also be retained for at least three years from the date the waste was accepted by the initial transporter.

If you have not already registered to use the EPA’s e-Manifest system, you might consider putting it on your 2022 agenda for consideration. The electronic system is expected to save industry and the states time, resources, and money. 

EPA hosts monthly webinars regarding the e-Manifest initiative. The next webinar is scheduled for Wednesday, December 8, 2021, at 2:00 PM (ET). EPA also provides updates in a quarterly newsletter

Find more details on EPA’s e-Manifest portal .

The LQG Biennial Report

Are you ready to report in 2022? Do you have a copy of the report you filed in 2020 easily accessible?

All large quantity generators must submit a biennial report by March 1, 2022. March 1 will come fast, so right now is a good time to review the Biennial Report filing instructions and start gathering the data you need to report.

A copy of each Biennial Report must be kept for at least three years from the due date of the report. 

New! Re-notification for Small Quantity Generators 

Are you a small quantity generator in a state that's adopted EPA's Generator Improvements Rule?

In states that have adopted EPA's Generator Improvements Rule, small quantity generators are required to re-notify EPA of their status every four years. 

The first deadline to re-notify was September 1, 2021. If you missed that deadline, you will want to act right away. The next re-notification deadline is September 1, 2025. 

The re-notification requirement for small quantity generators is one element of the Generator Improvements Rule that made the RCRA rules more stringent. Therefore, it is mandatory for states to adopt the re-notification rule for SQGs, if they don't already have one. Where is the Generator Improvements Rule in Effect Now?

Hazardous Waste Determination Records

Do you have all required records of your solid and hazardous waste determinations? 

40 CFR 262.11(f) lays out recordkeeping requirements for documenting hazardous waste determinations for large and small quantity generators. Generators must identify whether a solid waste is a hazardous waste, and support that determination with documentation. If the waste is a hazardous waste, all the applicable waste codes must be noted.

In addition to indicating the results of tests, sampling, and waste analyses, the generator must maintain records:
  • Documenting the tests, sampling, and analytical methods used to demonstrate the validity and relevance of the tests used.
  • Consulted to determine the process by which the waste was generated, the composition of the waste, and the properties of the waste.
  • Explaining the knowledge basis for the generator's determination.
If you used an exclusion claiming a material is not a solid waste (and, therefore by definition, not a hazardous waste), have you documented how you meet the terms of the exclusion? (See 40 CFR 261.2(f))

Inspectors are very interested in solid wastes that you determined were non-hazardous.Have you documented your assertions? Records must be maintained for at least three years from the date that the waste was last sent to on-site or off-site treatment, storage, or disposal.

Land Disposal Restrictions

Is the information on your Land Ban forms still accurate and up to date?

Take the time to review your Land Disposal Restriction (LDRs) Notifications (a.k.a. “land ban forms”). Although they are required to be sent to a Treatment, Storage, and Disposal Facility (TSDF) only with the first shipment of waste (See 40 CFR 268.7(a)(2)), it is prudent to review them periodically.

Your waste vendor may manage this for you, or your TSDF may ask on a yearly basis, “is this still correct?”

A new LDR notification must accompany any shipment of waste that has changed or if it is sent to a new TSDF. Are your process inputs different? Is the waste generated in a different way (e.g., spent solvent from paint cleanup operations vs. parts cleaning)? Have the properties or constituents of the waste changed (including the presence of new underlying hazardous constituents or their expected levels)?

Final RCRA Refresher of 2021! 

Join Lion for annual RCRA refresher training, presented live by a credentialed, experienced instructor over the web. The last RCRA Hazardous Waste Management Refresher of the year will be held on December 14.  

Can't join us live? Train at your own pace with on-demand online courses at Lion.com/RCRA
Lion - Quotes

"The instructor does a great job at presenting material in an approachable way. I have been able to save my company about $30,000 in the last year with what I have learned from Lion!"

Curtis Ahonen

EHS&S Manager

"These are the best classes I attend each year. I always take something away and implement improvements at my sites."

Kim Racine

EH&S Manager

"Lion is easily and consistently the best option for compliance training. I've learned new information from every instructor I've had."

Rachel Mathis

EHS Specialist

"Attending Lion Technology classes should be mandatory for every facility that ships or stores hazmat. "

Genell Drake

Outbound Lead

"I tried other environmental training providers, but they were all sub-standard compared to Lion. I will not stray from Lion again!"

Sara Sills

Environmental Specialist

"The instructor had knowledge of regulations and understanding of real-world situations. The presentation style was engaging and fostered a positive atmosphere for information sharing."

Linda Arlen

Safety & Environmental Compliance Officer

"As always, Lion never disappoints"

Paul Resley

Environmental Coordinator

"I have over 26 years of environmental compliance experience, and it has been some time since I have attended an environmental regulations workshop. I attended this course as preparation for EHS Audits for my six plants, and it was exactly what I was looking for."

Frank Sizemore

Director of Regulatory Affairs

"I was recently offered an opportunity to take my training through another company, but I politely declined. I only attend Lion Technology workshops."

Stephanie Gilliam

Material Production/Logistics Manager

"Excellent. I learned more in two days with Lion than at a 5-day program I took with another provider."

Francisco Gallardo

HES Technician

"The instructor was excellent. They knew all of the material without having to read from a notepad or computer. "

Gary Hartzell

Warehouse Supervisor

"I attended training from another provider and learned absolutely nothing. Lion is much better. Hands down."

Nicole Eby

Environmental Specialist

"This training broke down the regulations in an easy-to-understand manner and made them less overwhelming. I now feel I have the knowledge to make more informed decisions."

Amanda Oswald

Shipping Professional

"This is the best RCRA training I've experienced! I will be visiting Lion training again."

Cynthia L. Logsdon

Principal Environmental Engineer

"I have attended other training providers, but Lion is best. Lion is king of the hazmat jungle!!!"

Henry Watkins

Hazardous Waste Technician

"I can't say enough how pleased I was with this course! Everything finally makes sense."

Kim Graham

Lab Manager

"The instructor was energetic and made learning fun compared to dry instructors from other training providers."

Andy D’Amato

International Trade Compliance Manager

"This course went above my expectations from the moment I walked in the door. The instructor led us through two days packed with useful compliance information."

Rachel Stewart

Environmental Manager

"I have been to other training companies, but Lion’s material is much better and easier to understand."

Mark Abell

Regional Manager

"I love that the instructor emphasized the thought process behind the regs."

Rebecca Saxena

Corporate Product Stewardship Specialist

"More thorough than a class I attended last year through another company."

Troy Yonkers

HSES Representative

"Amazing instructor; real-life examples. Lion training gets better every year!"

Frank Papandrea

Environmental Manager

"The instructor clearly enjoys his job and transmits that enthusiasm. He made a dry subject very interesting and fun."

Teresa Arellanes

EHS Manager

"I can take what I learned in this workshop and apply it to everyday work and relate it to my activities."

Shane Hersh

Materials Handler

"The instructor was probably the best I ever had! He made the class enjoyable, was humorous at times, and very knowledgeable."

Mary Sue Michon

Environmental Administrator

"The instructor was great, explaining complex topics in terms that were easily understandable and answering questions clearly and thoroughly."

Brittany Holm

Lab Supervisor

"These are the best commercial course references I have seen (10+ years). Great job!"

Ed Grzybowski

EHS & Facility Engineer

"Excellent job. Made what is very dry material interesting. Thoroughly explained all topics in easy-to-understand terms."

David Hertvik

Vice President

"You blew the doors off the competition!"

Stephen Bieschke

Facilities Manager

"I like Lion's workshops the best because they really dig into the information you need to have when you leave the workshop."

Tom Bush, Jr.

EHS Manager

"Best course instructor I've ever had. Funny, relatable, engaging; made it interesting and challenged us as the professionals we are."

Amanda Schwartz

Environmental Coordinator

"The instructor was very dedicated to providing a quality experience. She did her best to make sure students were really comprehending the information."

Stephanie Venn

Inventory Control Specialist

"Lion Technology workshops are amazing!! You always learn so much, and the instructors are fantastic."

Dorothy Rurak

Environmental Specialist

"If I need thorough training or updating, I always use Lion. Lion is always the best in both instruction and materials."

Bryce Parker

EHS Manager

"I appreciate the focus on what the regulations tell us to do, as well as what is subject to interpretation."

Nicole Eby

Environmental Specialist

"The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information."

Morgan Bliss

Principal Industrial Hygienist

"Excellent course. Very interactive. Explanations are great whether you get the questions wrong or right."

Gregory Thompson

Environmental, Health & Safety Regional Manager

"I used the IT support number available and my issue was resolved within a few minutes. I don't see anything that could have made it better."

Danny Province

EHS Professional

"Content was comprehensive and seemed to really “dig in” to the material. I liked the option to review FAQs and re-review the quiz questions."

Morgan Bliss

Principal Industrial Hygienist

"The price was reasonable, the time to complete the course was manageable, and the flexibility the online training allowed made it easy to complete."

Felicia Rutledge

Hazmat Shipping Professional

"The course is well thought out and organized in a way that leads to a clearer understanding of the total training."

David Baily

Hazmat Shipping Professional

"This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things. "

Quatama Jackson

Waste Management Professional

"The training was impressive. I am not a fan of online training but this was put together very well. I would recommend Lion to others."

Donnie James

Quality Manager

"My experience with Lion training, both online and in the classroom, is that they are far better organized and provide a better sequential explanation of the material."

Robert Roose

Manager, Dangerous Goods Transportation

"Very well structured, comprehensive, and comparable to live training seminars I've participated in previously. I will recommend the online course to other colleagues with training requirement needs."

Neil Luciano

EHS Manager

"The course was very informative and presented in a way that was easily understood and remembered. I would recommend this course."

Jeffrey Tierno

Hazmat Shipping Professional

"Lion is at the top of the industry in compliance training. Course content and structure are updated frequently to make annual re-training enjoyable. I like that Lion has experts that I can contact for 1 year after the training."

Caroline Froning

Plant Chemist

"The course was very well structured and covered the material in a clear, concise manner."

Ian Martinez

Hazmat Shipping Professional

"The online course was well thought out and organized, with good interaction between the student and the course."

Larry Ybarra

Material Release Agent

"My experience with Lion classes has always been good. Lion Technology always covers the EPA requirements I must follow."

Steven Erlandson

Environmental Coordinator

"I had a positive experience utilizing this educational program. It was very informative, convenient, and rewarding from a career perspective."

John Gratacos

Logistics Manager

"Lion does a great job summarizing and communicating complicated EH&S-related regulations."

Michele Irmen

Sr. Environmental Engineer

"Far superior in terms of detail and instructional/support materials. The depth of instructor knowledge is always beyond any other training I have participated in."

Linda Arlen

Safety & Environmental Compliance Officer

"The instructor was very knowledgeable and provided pertinent information above and beyond the questions that were asked. "

Johnny Barton

Logistics Coordinator

"I have returned to Lion's compliance training for several years and prefer to stay with a trusted source. The material and presentation are far superior than others I have taken."

Robert Roose

Manager, Dangerous Goods Transportation

"I chose Lion's online webinar because it is simple, effective, and easily accessible. "

Jeremy Bost

Environmental Health & Safety Technician

"Lion's information is very thorough and accurate. Presenter was very good."

Melissa Little

Regulatory Manager

"Lion courses always set the bar for content, reference, and practical application. Membership and access to the experts is an added bonus."

John Brown, CSP

Director of Safety & Env Affairs

"The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!"

Brian Martinez

Warehouse Operator

"Excellent class, super instructor, very easy to follow. No rushing through material. Would like to take his class again."

Lawrence Patterson

EH&S Facility Maintenance & Security Manager

"I think LION does an excellent job of any training they do. Materials provided are very useful to my day-to-day work activities."

Pamela Embody

EHS Specialist

"Energetic/enthusiastic! Made training enjoyable, understandable and fun!"

Amanda Walsh

Hazardous Waste Professional

"Lion was very responsive to my initial questions and the website was user friendly."

Michael Britt

Supply Chain Director

"Convenient; I can train when I want, where I want."

Barry Cook

Hazmat Shipping Professional

"Having the tutorial buttons for additional information was extremely beneficial."

Sharon Ziemek

EHS Manager

"We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training."

Timothy Mertes

Hazmat Shipping Professional

"Lion's course was superior to others I have taken in the past. Very clear in the presentation and the examples helped to explain the content presented."

George Bersik

Hazardous Waste Professional

"Lion courses are the standard to which all other workshops should strive for!"

Brody Saleen

Registered Environmental Health Specialist

"Course instructor was better prepared and presented better than other trainers. Course manual and references were easier to use as well."

Marty Brownfield

Hazardous Waste Professional

"The instructor kept the class engaged and made learning fun. There was a lot of information to cover but time flew by. I will definitely use Lion in the future!"

Chelsea Minguela

Hazmat Shipping Professional

"Our instructor was very dynamic and kept everyone's interest. Hazmat shipping can be a dry, complicated topic but I was engaged the entire time."

Kimberly Arnao

Senior Director of EH&S

"Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers."

Robert Brenner

District Environmental Manager

"I was able to present my scenario to the instructor and worked thru the regulations together. In the past, I attended another training firm's classes. Now, I have no intention of leaving Lion!"

Diana Joyner

Senior Environmental Engineer

"The workshop covered a lot of information without being too overwhelming. Lion is much better, more comprehensive than other training providers."

George Alva

Manufacturing Manager

"The instructor did an excellent job presenting a very dry subject; keeping everyone interested and making it enjoyable."

Marc Bugg

Hazardous Waste Professional

"Well designed and thorough program. Excellent summary of requirements with references. Inclusion of regulations in hard copy form, as well as full electronic with state pertinent regulations included is a great bonus!"

Oscar Fisher

EHS Manager

"Very witty instructor, made the long times sitting bearable. One of the few training courses I can say I actually enjoyed."

John Hutchinson

Senior EHS Engineer

"The instructor made the class enjoyable. He presented in a very knowledgeable, personable manner. Best class I've ever attended. Will take one again."

John Nekoloff

Environmental Compliance Manager

"The instructor was very engaging and helped less experienced people understand the concepts."

Steve Gall

Safety Leader

"This was the 1st instructor that has made the topic actually enjoyable and easy to follow and understand. Far better than the "other" training providers our company has attended!"

Lori Hardy

Process & Resource Administrator

"I really enjoyed this training. Even after years on both sides of the comprehension coin, I find myself still learning! The quality of the delivery exceeded much of the training I have received in the past."

Neil Ozonur

Safety Officer

"The instructor created a great learning environment."

Avinash Thummadi

CAD & Environmental Manager

"Lion's training was by far the best online RCRA training I've ever taken. It was challenging and the layout was great!"

Paul Harbison

Hazardous Waste Professional

"The instructor took a rather drab set of topics and brought them to life with realistic real-life examples."

Tom Berndt

HSE Coordinator

"Given the choice, I would do all coursework this way. In-person courses go very fast without the opportunity to pause or repeat anything."

Ellen Pelton

Chemical Laboratory Manager

"I really enjoy your workshops. Thank you for such a great program and all the help Lion has provided me over the years!"

George Chatman

Hazardous Material Pharmacy Technician

"I like the consistency of Lion workshops. The materials are well put together and instructors are top notch!"

Kevin Pylka

Permitting, Compliance & Environmental Manager

"No comparison. Lion has the best RCRA training ever!!"

Matt Sabine

Environmental Specialist

"Very good. I have always appreciated the way Lion Tech develops, presents and provides training and materials."

John Troy

Environmental Specialist

"The instructor was very very informative, helpful, understandable and pleasant. This course answered many questions I had, being new to this industry."

Frances Mona

Shipping Manager

"I will never go anywhere, but to Lion Technology."

Dawn Swofford

EHS Technician

"Lion provided an excellent introduction to environmental regulations, making the transition to a new career as an EHS specialist less daunting of a task. Drinking from a fire hose when the flow of water is lessened, is much more enjoyable!"

Stephanie Weathers

SHE Specialist

"One of the best trainings I have ever received!"

Brandon Morfin

EH&S Manager

"Best instructor ever! I was going to take my DOT training w/a different provider, but based on this presentation, I will also be doing my DOT training w/Lion!"

Donna Moot

Hazardous Waste Professional

"Lion was very extensive. There was a lot of things that were covered that were actually pertaining to what I do and work with. Great Job. I will be coming back in three years! "

Tony Petrik

Hazmat Shipping Professional

"The instructor made the class very enjoyable and catered to the needs of our group."

Sarah Baker

Planner

"The instructor was very patient and engaging - willing to answer and help explain subject matter."

Misty Filipp

Material Control Superintendent

"Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!"

Marti Severs

Enterprise Safety Manager

"Lion is my preferred trainer for hazmat and DOT."

Jim Jani

Environmental Coordinator

download our latest whitepaper

Lithium battery regulations are complex and constantly evolving. If you’re just starting out with lithium battery shipping, answering the four questions in this guide will help you determine how stringently your shipment will be regulated and where to find the rules you need to ensure compliance.

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Current and Privacy Policy.

How Do I Ship A Lithium Battery