Cross-training RCRA Personnel for More Flexibility

Posted on 2/1/2022 by Lauren Scott and Roseanne Bottone

In the gym, cross-training—that is, varying your fitness regime with different types of exercise—can build flexibility and enhance balance, stability, and strength. A different sort of cross-training can do the same for hazardous waste generators.
In addition to hazardous waste training required for personnel under the Resource Conservation and Recovery Act (RCRA) regulations, generators must provide relevant hazmat training for employees with job responsibilities covered by US DOT’s Hazardous Materials Regulations (HMR).

Signing the Manifest and Other “Hazmat Jobs”

A recent guide for Lion students explored the training requirements for employees who sign the Uniform Hazardous Waste Manifest. Signing shipping papers is an essential part of moving hazardous materials (including hazardous waste), but it is only one of many “pre-transportation” job functions covered by the HMR.
DOT’s hazmat shipping regulations lay out specific requirements for employees who perform a wide variety of regulated jobs—classifying or naming hazardous materials; choosing, assembling, and filling packaging; marking, labeling, and placarding packages and vehicles; loading vehicles, and others

For details about the training US DOT requires for employees who ship hazardous materials (including hazardous waste), view the DOT Hazmat Training FAQ.

Without DOT Hazmat Training…

When employees lack appropriate training to prepare hazardous waste for transportation to a treatment, storage, and disposal facility (TSDF), they can easily make mistakes that lead to:

  • Delayed or rejected shipments,
  • Releases of hazardous materials/waste in transit
  • Injury to employees or supply chain personnel
  • Environmental contamination, property damage, and costly cleanups  
  • Maximum civil penalties exceeding $80,000 per day, per violation
  • Minimum civil penalties of $500+ per employee, per day for training violations
 A delayed waste shipment may also cause non-compliance with the RCRA regulations. Large- and small quantity generators must abide by time limits for accumulating hazardous waste on site (without a permit). Holding waste on site for too long can result in the generator being subject to stringent permitting requirements, stricter employee training mandates training employees, and additional reporting responsibilities—plus fines and penalties assessed by EPA or a state environmental agency. 
Like US DOT’s penalties for hazmat shipping violations, penalties for noncompliance with RCRA increase every year. As of January 12, 2022, the maximum penalty now exceeds $80,000 per day, per violation.
Cross-training personnel on RCRA on-site management rules and hazmat shipping compliance helps facilities to safely ship hazardous waste in a timely manner. Does your site have enough properly trained employees to perform all of the pre-transportation functions covered by DOT regulation?
When you cross-train key personnel to properly manage hazardous waste on site and comply with DOT’s hazmat shipping regulations, you can be confident that knowledgeable staff will be available and ready to keep your hazardous waste shipments moving—safely  on time, and in compliance.  

Upcoming DOT and RCRA Training Webinars 

Join a live, instructor-led webinar this month to help satisfy US DOT and US EPA training mandates for hazmat employees and hazardous waste personnel.

US DOT requires training for all "hazmat employees" once every three years and US EPA requires annual training for hazardous waste personnel at large quantity generator facilities,  
Hazmat Ground Shipper Certification (DOT)  Feb. 7–8
Recurrent Hazmat Ground Shipper Certification (DOT) Feb. 23 
RCRA Hazardous Waste Management  Feb. 28–Mar. 1
RCRA Hazardous Waste Management Refresher Feb. 8

* See 49 CFR 172.704 and 40 CFR 262.17

Tags: hazardous waste manifest, hazmat training, RCRA Training, shipping hazardous waste

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