RCRA Hazardous Waste Training

The RCRA regulations require hazardous waste training for "hazardous waste personnel," defined 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).

40 CFR 260.10

Common job responsibilities performed by hazardous waste personnel include:  

• Overseeing waste personnel or operations
• Identifying and/or characterizing solid and hazardous waste
• Counting hazardous waste and determining generator status/category
• Choosing hazardous waste containers
• Marking or labeling containers
• Handling or moving waste or waste containers
• Inspecting containers
• Operating a waste-generating process  
• Managing waste in satellite areas
• Reading and applying Federal or state hazardous waste regulations

RCRA training is required for hazardous waste personnel at large quantity and small quantity generator facilities. For very small quantity generators, we strongly recommend training employees to perform their jobs in full compliance with RCRA.

Watch this video to learn who needs RCRA training, what RCRA training for hazardous waste personnel must include, and when and how often RCRA training is required under the 40 CFR Part 262 hazardous waste regulations for generators. More videos at YouTube.com/LionTraining.

Small Quantity Generators (Less than 1000 kg per month and 1 kg or less acute hazardous waste)

• Hazardous waste personnel must be "thoroughly familiar" with their responsibilities for hazardous waste management compliance [40 CFR 262.16(b)(9)].

 Very Small Quantity Generators (100 kg or less per month and 1 kg or less acute hazardous waste)

• No explicit RCRA training requirements for VSQG personnel.
• Personnel must know enough to perform their jobs in compliance with the RCRA rules for VSQG sites in 40 CFR 262.14.
• Lion recommends the RCRA for Very Small Quantity Generators online training.

[PDF] What's My Generator Status?

Download the free generator category cheat sheet to determine which RCRA training rules apply to your personnel and activities. Knowing your generator status or category is the first step to properly manage your site's waste and provide required RCRA training for personnel.

Key rules and regulations concerning the timing of RCRA training include:

• Initial RCRA training must be provided within 6 months of the employee's hire date or assignment to the facility.
• Annual RCRA refresher training is required for hazardous waste personnel at large quantity generator (LQG) facilities.
• Personnel must work under direct supervision until trained.
• Hazardous waste personnel at small quantity generator facilities must be trained so that they are "thoroughly familiar" with their responsibilities for compliance with RCRA.

Lion offers hazardous waste training to help satisfy initial RCRA training mandates and provide annually required RCRA refresher training. 

Get more details about when and how often to provide RCRA training for personnel on the RCRA Training FAQ page.

No. When you sign the Hazardous Waste Manifest, you certify compliance with US DOT's hazmat transportation regulations. To legally certify that your hazardous material/waste was properly classified, named, and packaged/containerized, you must know the 49 CFR Hazardous Materials Regulations (HMR) transportation requirements that apply to your waste.

Therefore, professionals who sign the Hazardous Waste Manifest must complete comprehensive training in the US Department of Transportation 49 CFR Hazardous Materials Regulations (HMR). 

Ship Hazardous Waste?

Personnel who sign the Hazardous Waste Manifest must be trained on the RCRA hazardous waste and US DOT's Hazardous Materials Regulations (HMR) that apply to their job. 

Lion recommends:

Hazmat Ground Shipper Certification (DOT) and RCRA Hazardous Waste Management training.