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3 RCRA Compliance Tips for Spring 2023

Posted on 1/30/2023 by Roseanne Bottone

Spring is right around the corner, waiting to be sprung. As the weather improves, you may be planning for building and site maintenance, equipment updates, or increased sales that will require extra production and a new round of hiring.

More activity (and new people) at your site creates the potential for some common violations of hazardous materials and hazardous waste regulations.

To keep your site in compliance with the RCRA hazardous waste generator standards and the Hazardous Materials Regulations (HMR) this Spring, keep these tips in mind as you’re planting the seeds for the future.

Spring Tip 1: Episodic Events and Counting Hazardous Waste

Many States have adopted the rules for “Episodic Generation” that allow a Very Small Quantity Generator (VSQG) or Small Quantity Generator (SQG) to maintain their status when there are certain planned or unplanned events that increase the quantity of hazardous waste generated at a site.

If you are taking orders for later in the year, or acquiring new clients and revving up production, you may generate more hazardous waste than is typical for your site. However, the increased production of hazardous waste due to an increased rate of production is not a qualifying “episodic event.” That waste would be counted toward your generator status.

Make sure you are counting your hazardous waste generation accurately and can prove your generator category every calendar month.

Read more:

What's My RCRA Generator Category/Generator Status?
How and Why Your Generator Status Can Change

3 RCRA Compliance Tips for Spring 2023

Spring Tip 2: Contractors May Leave RCRA Violations Behind 

Outside contractors (e.g., construction workers, painters, repair people, etc.) are notorious for three bad habits that cause regulatory noncompliance for facilities subject to RCRA.

1.) Abandoning partially used products and chemicals.

2.) Leaving paint cans and pails open so the residue or leftover paint can volatilize to solidify.

3.) Tossing partially filled aerosol cans in the trash.

Depending on the nature of these materials, these may be RCRA violations. This might be a good time to develop an SOP for overseeing contractor activities.

Spring Tip 3: New Hire Training Deadlines

Business booming already in 2023? Fantastic! As you hire new employees to keep pace with increased demand, stay conscious of the training requirements for new “hazardous waste personnel” and “hazmat employees” under the RCRA regulations and the HMR.

In either case, you can’t just set new hires loose to do their jobs right away:

Hazardous Waste Storage

At large quantity generator sites, training is required within 6 months of hiring an employee. Small quantity generators must ensure that all employees are “thoroughly familiar” with proper waste handling and emergency procedures relevant to their responsibilities.

[40 CFR 262.16 and .17] [RCRA Training FAQ]

Hazardous Materials Shipping

US DOT requires initial training within 90 days of hire date or job assignment for “hazmat employees.” Recurrent training (re-training) is required at least once every three years.

[49 CFR 172.704(a)] [Hazmat Training FAQ]

New employees who will be involved in the storage, handling, management, or transportation of hazardous materials or waste must work under immediate supervision of a trained employee until they themselves have been trained.

Have some questions about what training US EPA and US DOT require for employees who handle, work with, or ship hazardous materials or hazardous waste?

Contact us now. As a leader in EH&S training since 1977, Lion has answered just about any question about hazmat, hazardous waste, and health & safety training that you can imagine.

More to Come Next Week!

For environmental, workplace safety, and transportation inspectors, more hours of daylight during the SPring provide more opportunities to make site visits and assess compliance with hazmat and hazardous waste requirements.

A stronger understanding of the regulations that apply to your site—including work done by contractors at your site—can give you peace of mind to enjoy Spring 2023 to the fullest.

Come back next week for more tips to keep your site in compliance with hazardous materials and hazardous waste regulations this Spring, and all year round. Next week, we’re coming back with tips about the records you will want to have on hand to demonstrate compliance when a regulatory inspector visits to check out your operations.

Lion’s Spring 2023 Training Schedule

Put a spring in your step with the boost of confidence that insightful, fun training can deliver.  Lion’s springtime training itinerary is jam packed. Join us someplace warm for in person training—San Diego for required DOT hazmat training in May, for example.

Full 2023 Schedule 

Or stay put and listen to the birds chirp outside your window as you complete your training online, at your own pace. And remember: Lion can bring the training to you with on-site and webinar group training options. Get your quote for training through Lion.com or call 888-546-6511 and ask about training for groups.  

Tags: episodic event, hazardous waste personnel training, hazmat employee training, hazmat shipping, RCRA compliance

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