Generator Improvements: EPA Moves RCRA Hazardous Waste Training Standard

Posted on 12/13/2016 by Roger Marks

Under its Generator Improvements Rule, which is now final and takes effect in May 2017, US EPA is re-organizing certain parts of the requirements for hazardous waste generators in 40 CFR 262. Among the many, many changes to the hazardous waste generator rules is the relocation of the RCRA training standards.

RCRA Training for Large Quantity Generators

If you look for training requirements in the current RCRA rules, you will find them in a couple of places. For large quantity generators, the training standard is actually split across 40 CFR 262 and 40 CFR 265.

At 40 CFR 262.34(a)(4), EPA requires large quantity generators to comply with certain requirements for treatment, storage and disposal facilities (TSDFs), including the requirement to provide annual hazardous waste training for personnel. The annual training requirement that applies to both TSDFs and large quantity generators is found at 40 CFR 265.16.

Now, to make the RCRA training rules easier to find, US EPA is moving the training rules for large EPA hazardous waste generator improvements rulequantity generators to a new section: 40 CFR 262.17.

New section 262.17 will comprise the hazardous waste management rules for large quantity generators, the relocated training standard, and a majority of the other requirements that LQGs must follow. This way, professionals who deal with RCRA won’t have to flip from section to section to find the rules that apply to their site.

Have questions about how much RCRA training your personnel need? Watch the video at to learn more.


Will This Change the Annual RCRA Training Requirement?

The annual RCRA training requirement itself will not change. Personnel at large quantity generator sites are still required to complete hazardous waste refresher training every year.

Providing annual hazardous waste training is one of the “conditions for exemption” under RCRA for large quantity generators. In other words, by providing annual training—and meeting other requirements—facilities that generate large amounts of hazardous waste are exempt from the more burdensome requirements set for TSDFs.

To learn more about “conditions for exemption” and how they differ from the RCRA “independent requirements” for generators, read EPA Generator Improvements: Hazardous Waste Enforcement Policy.

RCRA Emergency Preparedness and Contingency Planning

In addition to moving the hazardous waste training standard, EPA will relocate the contingency plan and emergency preparedness requirements for large quantity generators to a new subpart: 40 CFR 262, Subpart M.

RCRA Training for Small Quantity and “Very Small Quantity” Generators

Small quantity hazardous waste generators—those who generate between 100 kg and 1,000 kg of hazardous waste per month—are required by EPA to train employees so that they are “thoroughly familiar” with the RCRA hazardous waste rules. The RCRA training rule for SQGs is found at 40 CFR 262.34(d)(5)(iii) until May 2017, when the Generator Improvements Rule takes effect,.

After this date, the SQG training rule, along with the management standards and other “conditions for exemption” for these facilities, will move to a new section: 40 CFR 262.16. 

Meanwhile, the conditions for exemption for conditionally exempt small quantity generators (CESQGs), to be re-named “Very Small Quantity Generators,” or VSQGs, under the revised RCRA rules, will be found at 40 CFR 262.14. While providing RCRA training for personnel at VSQG sites is not explicitly required, training personnel is critical to prevent violations now punishable by fines up to $70,117 per day, per violation. 
Generator Status/Size “Old” RCRA Training Rule “New” RCRA Training Rule
LQG (1000+ kg per month)
40 CFR 262.34(a) and 265.16 40 CFR 262.17
SQG (100-1000 kg per month)
40 CFR 262.34(d)(5)(iii) 40 CFR 262.16
CESQG/VSQG (>100 kg per month)
40 CFR 261.5
(RCRA training not explicitly required)
40 CFR 262.14

Sessions are Limited! RCRA Generator Improvements Rule Update Webinar - $99 for Lion Members

Now that EPA’s Generator Improvements Rule is finalized, professionals responsible for hazardous waste management will face questions from colleagues and higher-ups about what must be done to stay in compliance. The new RCRA update webinar will give managers and personnel the answers they need to prepare and plan for big changes to these complex EPA standards.

The next session will be presented on December 21 from 1:00-2:30 p.m. ET. Sessions will follow on January 5 and January 26.

Current Lion Members can attend the webinar for $99. Those without a current Lion Membership can attend for $129. Attendance includes live, expert-led training; a digital compliance reference; and a Certificate of Attendance. 

Tags: EPA, hazardous waste, new rules, RCRA Training

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